&ER&
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
Washington DC 20460
Office of Emergency
and Remedial Response
HW-6
Solid Waste and Emergency Response
Community Relations
in Superfund:
A Handbook
Interim Version
September 1983
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COMMUNITY RELATIONS IN SUPERFUND
A HANDBOOK
United States Environmental Protection Agency
Office of Emergency and Remedial Response
September 1983 Interim Version
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NOTE
This handbook was prepared by ICF Incorporated for the Office of Emergency
and Remedial Response, U.S. Environmental Protection Agency (EPA), under EPA
contract 68-02-3669. It was revised and approved through the EPA Peer and
Administrative Review Control System. Peer reviewers were Anthony Diecidue,
L. Michael Flaherty, Inez Artico, Marcia Carlson, and Richard Hoffman.
This handbook serves as program guidance for conducting community
relations activities in the Superfund program. It incorporates EPA policy on
community relations that is not expected to change, although details of the
handbook may be modified in the future to reflect experience with a developing
program. Questions and comments concerning this handbook should be addressed
to Daphne Gemmill, U.S. Environmental Protection Agency, 401 M Street, S.W.,
Office of Emergency and Remedial Response (WH-548D), Washington, D.C. 20460.
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TABLE OF CONTENTS
PAGE
INTRODUCTION
CHAPTER 1 An Effective Community Relations Program.
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CHAPTER 2 Community Relations During Immediate and
Planned Removals.
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CHAPTER 3 Community Relations During Remedial Response 3-1
CHAPTER 4 Examples of Community Relations Techniques 4-1
CHAPTER 5 Administering a Community Relations Program 5-1
CHAPTER 6 Community Relations and Enforcement Actions
(reserved)
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APPENDIX A Examples of Community Relations Plans A-1
APPENDIX B Community Relations Guidance for Evaluating Citizen
Concerns at Superfund Sites B-1
APPENDIX C Quarterly Report Format C-1
APPENDIX D Community Relations Program Staff D-1
APPENDIX E Problem Situations.. (reserved) E-1
APPENDIX F Glossary of Terms and Acronyms F-1
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INTRODUCTION
The Super fund'" community relations program encourages two-way
communication between communities affected by releases of hazardous substances
and agencies responsible for cleanup actions. The program attempts to provide
communities with accurate information about problems posed by releases of
hazardous substances; at the same time, it gives local officials and citizens
the opportunity to comment on and provide input to technical solutions to site
problems. An effective community relations program must be an integral part
of every Superfund action.
Hazardous waste sites and other releases of hazardous substances have the
potential to create strong public concern about government action. The health
and environmental problems stemming from releases of hazardous substances are
inherently sensitive.
A community relations program can enable government staff to take
community concerns into account in planning a response and the result can be a
better response action. At the same time, it can ensure that citizens have
accurate information about the response. It is consequently an essential
component of a successful.Superfund response action.
This handbook offers specific guidance for EPA and state staff on how to
design and implement an effective community relations program. The handbook
presents guidelines for developing community relations programs for removal
actions (Chapter 2) and remedial actions (Chapter 3). Chapter 4 discusses the
advantages and disadvantages of various activities that may be included in a
community relations program. The handbook explains the administrative
requirements for the program (Chapter 5). Chapter 6, which provides guidance
on managing community relations activities during enforcement actions, will be
added to the handbook at a later date. Appendix A discusses how to draft
community relations plans and presents examples of community relations plans
for removal and remedial actions. Appendix B provides guidance on how to
conduct on-site discussions with local officials and citizens and on how to
assess community concerns on the basis of these discussions. A community
relations program quarterly report format is contained in Appendix C.
Appendix D lists the EPA Headquarters and Regional Office staffs responsible
for community relations program management and implementation. At a later
*Superfund is the $1.6 billion fund created by the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) for
responding to releases or threats of releases of hazardous substances. This
handbook also uses the term "Superfund" to describe the response program
established by the Environmental Protection Agency under CERCLA's authority.
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date, after the completion of a community relations training program, an
Appendix E will be added to the handbook. This appendix will illustrate how
community relations staff should deal with typical communications problems.
Appendix F presents brief descriptions of terms and acronyms used in the
handbook.
Subpart F of the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) requires response personnel to "be sensitive to local
community concerns (in accordance with applicable guidance)" (40 CFR
300.61(c)(3)) . This handbook serves as the referenced applicable guidance.
Under Section 105 of the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), response actions shall "to the greatest
extent possible" be in accordance with the NCP. That provision is applicable
to this handbook as well.
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CHAPTER 1
AN EFFECTIVE COMMUNITY RELATIONS PROGRAM
This chapter describes the background and objectives of the Superfund
community relations program. First, it defines the program and describes how
EPA derived the guidelines" presented in this handbook. It then explains how
the program can enhance the ability of EPA and the states to implement
cost-effective removal and remedial actions.
A. PROGRAM DEFINITION
The Superfund community relations program is a site-specific information
and communications program that must be an integral part of every Superfund-
financed remedial or removal action. , When EPA (or a state under a cooperative
agreement with EPA) decides to fund a Superfund response action lasting longer
than a few days, it must develop a community relations plan (CRP) that details:
• How citizen concern will be identified and assessed
at the site;
• How accurate information on problems associated with
the release of hazardous substances will be
distributed and explained to the community;
• How citizens will have an opportunity to comment on
and provide input to ongoing and proposed site work;
and
• How the technical alternatives and the proposed
technical solution will be explained to the community.
Specific activities listed in the CRP for soliciting citizen input and
distributing information vary from site to site, depending upon the level of
citizen concern and the nature of the site's technical problems. The
responsible agency (either EPA or the state) implements the plan, in close
coordination with other interested agencies.
All site-specific activities that encourage communication between
communities affected by releases of hazardous substances and agencies
responsible for cleanup together constitute EPA's Superfund community
relations program. The program's evolution and objectives are described below.
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B. PROGRAM BACKGROUND
The guidelines in this handbook are based upon on-scene investigations of
government response to hazardous substance problems in twenty-one communities
across the country. An EPA project team interviewed Regional EPA staff,
On-Scene Coordinators (OSCs), officials in state agencies, local officials,
citizens, and environmentalists to find out how citizens have responded to
releases of hazardous substances and to evaluate their needs and concerns.
From these investigations, EPA learned which community involvement techniques
have been effective at these twenty-one sites and deserve to be adopted in the
Superfund community relations program -- and which activities should be
avoided. The findings of EPA's investigations of citizen involvement in past
hazardous substance incidents have significant implications for the Superfund
community relations program.
First, the people who have the greatest concerns about a site or release
incident are usually those individuals directly affected by the health or
environmental problem or who believe their health is endangered. For this
reason, eliciting citizen input from local chapters of national environmental
organizations can be important, but may not provide a sufficient or accurate
representation of the views and concerns of those citizens affected by the
problem. The community relations effort must be directed primarily at the
people most directly affected by site problems.
Second, the best way to reach concerned citizens is usually through small
informal efforts that are conducted early in the response action and are held
periodically during the response action: informal living room briefings,
personal contact with an OSC, workshops, and citizen group meetings. When
public meetings are needed, they must be planned and conducted with great care
to prevent them from becoming counterproductive confrontations.
Third, both technical problems and the level of citizen concern vary
greatly from site to site. Therefore, there can be no set formulas for a
community relations program. Community relations efforts must be tailored to
the distinctive needs of each community and must be tied to the technical
response schedule. Where releases seriously threaten public health or where
the threat to public health increases during a response action, community
relations staff must have the flexibility to address citizen concerns, without
being tied down to formalized procedures.
Finally, where possible, a community relations program should carefully
identify controversial issues. The program staff should elicit citizens'
concerns about emotional, sensitive, or difficult issues from the beginning of
a response action.
C. COMMUNITY RELATIONS AND AN EFFECTIVE SUPERFUND PROGRAM
The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) was enacted by Congress to provide broad federal authority and funds
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for responding to releases or threatened releases of hazardous substances,
pollutants, or contaminants from vessels or facilities. Although the $1.6
billion response fund (Superfund) created by CERCLA seems large, the cost of
responding to releases is also large and there are many problems in need of
attention. Thus, for remedial actions, the National Contingency Plan requires
the lead agency for any site action to choose the most cost-effective remedial
alternative to address the site's problems. It may be necessary, therefore,
to explain to a community that a balance must be struck between the.need to
protect public health, welfare, and.the environment at any one site, and the
need to conserve the Fund for responding to problems at other sites.
A successful community relations program is a preventive effort. EPA has
found that a measure of prevention is critical to implementing a cleanup of a
hazardous substance release. Every site action has the potential to become
difficult to manage if communication is poor between EPA or the state
government, local governments, interest groups, and citizens. People who are
worried about releases of hazardous substances and believe that the government
has not considered their concerns may press for additional -- and more costly
-- relief. Regardless of the technical adequacy of a proposed response, it
may prove unacceptable to the local public. The best way to lessen the
chance that citizens might reject a cost-effective solution is to identify
citizen concerns, take these concerns into consideration when fashioning a
solution, and explain the rationale behind the course of action chosen.
The community relations guidelines outlined in this handbook should
enhance EPA's and states' abilities to implement cost-effective removal and
remedial actions in communities across the nation. A community relations
program can ensure that the concerns and questions of citizens are not
neglected, but are incorporated into the decisionmaking process. It can
lessen the chances for the spread of rumors or misconceptions about the nature
of the threat at the site.
The objectives of the Superfund community relations program, consequently,
are as follows:
• Gather information about the community in which a site is
located. A community relations program provides a vehicle for
exchanges between EPA, the state, the public, and local
government. It enables EPA and state staff to identify citizen
leaders, public concerns, and a site's social and political
history. Sometimes it can also yield technical data useful in
planning a solution to the site's problems -- or information
useful in an enforcement case against a responsible party.
• Inform the public of planned or ongoing actions. The program
should inform the public of the nature of the environmental
problem,,the remedies under consideration, and the progress
already made.
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Give citizens the opportunity to comment on and provide input
to technical site decisions. The program should enable
citizens to understand and comment on decisions that will have
long-term effects on their community.
Focus and resolve conflict. Conflict may be unavoidable in
some circumstances, but it can be constructive if it brings into
the open alternative viewpoints based upon solid reasons for
criticism or dissent. An effective community relations program
channels conflict into a forum where it can serve a useful
purpose. When such opposition has already arisen, a concerted
attempt to communicate with and involve all parties can help
reduce tension.
This handbook presents techniques that can aid EPA and state staff in
achieving these objectives.
D. A WORD ON INNOVATION
The problems at every Superfund site are different. Therefore, those
individuals charged with conducting a community relations program must
exercise a great deal of creativity and flexibility, and decide which measures
are appropriate for the particular removal or remedial action. The best
advice this handbook can provide is to tailor each community relations plan to
the needs of a given incident, taking into account the social and political
context and the history of public involvement in the problem.
E. AUDIENCE
This handbook is directed primarily at EPA and state technical staff,
because no community relations program can be successful without their
leadership, cooperation, support, and participation on a daily basis.
Furthermore, the handbook assumes that readers have a working knowledge of the
Superfund statutory requirements, guidance outlined in the National
Contingency Plan, and current program policies. Readers requiring more
detailed Superfund program information should consult the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, the National
Oil and Hazardous Substances Pollution Contingency Plan, and EPA guidance
manuals on enforcement, cooperative agreements, and other program policies.
The handbook does not serve as a public participation manual. In the
past, several public participation manuals have been prepared for EPA,
particularly in the water program. Readers that need detailed guidance on
public participation techniques (e.g., how to organize, publicize, and conduct
meetings) should consult these manuals.
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CHAPTER 2
COMMUNITY RELATIONS DURING IMMEDIATE AND PLANNED REMOVALS
This chapter provides a brief guide to the kinds of community relations
activities that can be undertaken during immediate and planned removals.
Whether the technical problems encountered during a removal action are simple
or complex, the social, political, economic, and psychological effects of the
action on the community can be dramatic. Citizens will want information about
the effects of exposure to hazardous substances upon their health and
environment. In addition, citizens must be given the opportunity to express
opinions and concerns about a removal action in their community. Finally,
citizens should be informed about the restrictions CERCLA and the National
Contingency Plan place on removal actions.
The purposes of the communication^ techniques discussed in this chapter
are to: (1) help EPA identify and assess citizens' perceptions of the health
and environmental threat; (2) give citizens an opportunity to comment on and
provide input to the selection of a response action, when feasible; and (3)
help community relations staff choose effective methods for distributing and
explaining information on removal actions. Readers should consult Chapter 4
for detailed explanations of the techniques suggested in this chapter.
Chapter 5 describes community relations planning requirements for removal
actions, and Appendix A provides formats for planning documents.
A. IMMEDIATE REMOVAL ACTIONS
1. Need for Communication
EPA may decide to undertake an immediate removal action in those
situations where immediate action will prevent or mitigate immediate and
significant risk of harm to human life or health or to the environment. (See
Section 300.65 of the National Contingency Plan for a definition of immediate
removal actions.) The On-Scene Coordinator's (OSC's) principal responsibility
in an immediate removal is to protect public health and property until the
emergency is abated. During such an incident, the primary community relations
activity is to inform the community about response actions and their effects
on the community.
The specific types of community relations activities during immediate
removals are likely to include responding to inquiries from the media,
providing local officials with the knowledge necessary to handle the questions
of their constituents, and giving information directly to concerned citizens.
By channeling community inquiries to the appropriate agency or official, the
community relations program can ensure that the community receives the vital
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information it needs about the effects of the release on the community's
health and safety and the government's response action. At the same time, the
program can prevent the OSC from being deluged with questions about the
operation from reporters, local officials, or citizens, diverting attention
from..necessary response actions.
2. Planning for Community Relations during Immediate Removals
Planning for community relations during immediate removals entails:
• Obtaining background information on the community
affected by the release of hazardous substances and
the possible effects of the release;
• Developing a community relations program that meets
the special needs of the community; and
• Establishing a working relationship between the
technical staff and Regional Office of Public Affairs
(OPA).
Some releases of hazardous substances require a short term immediate
removal action lasting no longer than a few days. These kinds of actions
would generally not involve substantial community relations planning because
of the nature of the emergency. In other cases, however, the immediate
removal may require longer term action and may generate considerable public
interest and need for information. For actions that may last longer than 5
days, a community relations profile -- a short form community relations plan
(CRP) -- must be prepared. If an action is anticipated to last longer than
45 days, a CRP must be prepared.
The community relations profile explains how community relations staff
intend to plan for and implement community relations activities at the site.
As detailed.in Chapter 5, the profile is submitted as part of the Immediate
Removal Request (10 Point Document). It should contain a brief outline of the
nature of community concern, the key site issues, the objectives of community
relations activities, and the communications activities considered for the
site.
The immediate removal CRP should be prepared as soon as it is known that
the response action may last longer than 45 days. The plan should succinctly
state the site background, the nature of the community concern, the key site
issues, the objectives of the community relations activities, and specific
activities to be undertaken at the site. The CRP should be submitted as soon
.as possible after the approval of the Immediate Removal Request.
Appendix A contains a detailed list of the information that must be
gathered and included in an immediate removal profile and plan, and profile
and plan formats that can be used as guides. Some communications activities
that may be conducted during immediate removals are detailed below.
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3. Suggested Community Relations Activities
Community relations programs for immediate removals should take into
consideration that the immediate removal may be only the beginning of a
lengthy presence in the community. It is possible that a planned removal or
remedial action will follow at a site. Thus, the OSC's actions during an
immediate removal may have long-term consequences for EPA or state
effectiveness during future operations at the site.
To ensure that the community is given accurate information in a timely and
efficient way during an immediate removal, OSCs and Regional OPA staff should
work with other Superfund program and state staff to:
• Designate a single contact to handle all public
inquiries.
• Provide sufficient telephone lines and staff to
support the designated public contact and publicize
the phone number in the local media.
• Contact immediately local officials, the Governor's
Office, and interested Congressional officials;
provide these officials with information about the
release and the immediate removal action.
• If sufficient interest exists, hold a news
conference or briefing to explain problems caused by
the release and the plans for the immediate removal
action. Also, establish a repository for site
information at a local library, health office, or
community center with approved technical reports,
official phone numbers, and the immediate removal CRP.
• If sufficient time exists, periodically hold small
meetings with local officials and groups of interested
citizens as early in the response action as possible.
There will be times when an immediate removal is taken at a site that has
long been a recognized problem and that is familiar to community relations
staff. For example, an immediate removal can be preceded by an assessment
period, or it can be taken midway through a remedial action. In such cases,
some of the preparatory work for a community relations program may already
have been accomplished. Local officials and citizens will be aware of the
need for action and may have a good idea of what to expect when work begins at
the site. Similarly, community relations staff may be well acquainted with
the special concerns of people living near the site. In these cases, the
community relations program can concentrate on public consultations and
briefings and news conference updates.
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When the threat to human health or the environment is especially acute,
the activities noted above may be effectively implemented through the
establishment of an on-scene information office. The office may consist of a
person stationed full-time at a trailer on the site to respond to inquiries
and to prepare fact sheets or news releases. Whenever dealings with the
public or the media appear likely to prevent the OSC from giving adequate
attention to the technical aspects of the response, an on-scene information
office should be established. In cases where Regional Office or state
resources may not be sufficient to staff such an on-scene office, a local
information repository can provide a useful vehicle for distributing
information.
B. PLANNED REMOVAL ACTIONS
Planned removals are either continuations of immediate removals or cleanup
actions, limited in time and cost, that are taken at unranked sites. (See the
National Contingency Plan, Section 300.67 for planned removal.definition.) As
with immediate removals, planned removals may lead to a remedial action and a
lengthy EPA or state presence at the site. Community planning, therefore,
should account for this possibility.
Community relations staff must design a community relations program and
prepare a CRP for each planned removal. As explained in Chapter 5, the CRP
must be submitted along with the "14 point" contractual document. The Action
Memorandum should state that the CRP has been prepared and should briefly
summarize major citizen concerns.
Based upon EPA's investigations at twenty-one hazardous waste sites, the
following guidelines are suggested for designing and implementing a community
relations program for planned removals. (See Chapter 4 for a more detailed
explanation of some of the community relations techniques referred to in these
guidelines.)
I. Hold on-site discussions with local officials and citizens.
Prior to preparing a CRP, community relations staff must meet with local
officials and interested citizens to obtain information about the site and to
identify public concerns. This information should be incorporated in the CRP
and passed on to technical and enforcement staff where relevant. (Appendix B
contains guidance on how to conduct on-site discussions.)
In addition, community relations staff can use these initial discussions
to explain the limited nature of a planned removal. Although some planned
removals will not require follow-up actions, others may not result in
permanent solutions to the problems associated with the release of hazardous
substances. Instead, they may require EPA or the state to leave a community
with a temporary remedy and an indefinite delay before further work, if any,
can begin. Local officials and citizens are likely to assume, however, that
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the purpose of the action is to provide a permanent remedy to the problem, one
that will involve the removal of all hazardous substances from the site. If
they are allowed to generate such expectations, they will be frustrated if the
planned removal is only a provisional response. At an early stage, therefore,
it is critical to prevent the development of unrealistic expectations. Early
on-site discussions can be a key factor in developing accurate expectations.
2. Assess the nature of citizen concern.
After completing the on-site discussions, community relations staff must
assess the nature and level of citizen concern at the site. Such an
assessment allows staff to match communications activities both to the
technical schedule of the response action and to citizens' information needs
and concerns. One method of assessing citizen concern is detailed in Chapter
4 and explained further in Appendix B.
3. Describe citizen concerns, community relations activities, timing,
and resource needs in a CRP.
In addition to a thorough assessment of citizen concerns, the CRP must
include: a description of specific objectives for the program; a list of all
communications activities planned for the site; a detailed workplan and
budget; a staffing plan; a schedule of activities; a list of interested
citizens; and a list of technical and community relations staff responsible
for the site.
Chapter 4 describes a number of communications techniques that can be used
in a community relations program at a planned removal or remedial action
site. Given the limited nature of a planned removal, however, many of these
techniques may not be needed or appropriate. Community relations staff should
use discretion in determining which activities would be effective at a
particular site. In general, the following activities are suggested for a
planned removal:
• Briefings for local officials and the media.
Briefings on the planned removal action are essential
at an early point in the action. They are useful for
providing information about any health or
environmental problems posed by the site and for
informing the public about the proposed response
action.
• Public meetings and workshops. In general,
meetings and workshops should be small and informal.
They should be held as early in the response action as
possible, and should be used both to identify citizen
concerns and to solicit citizen comments on the
response action. Investigations of community
involvement at sites in every EPA Region suggest that
small meetings and workshops are very effective for
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providing information and identifying citizen
concerns. Conversely, these investigations also show
that large meetings or formal public hearings do not
aid officials in identifying citizen concerns and do
not allow officials to explain effectively their
findings and proposed actions. In certain situations,
however, a large public meeting or a formal hearing
may be warranted. When this is the case, it is
advisable to hold smaller meetings with interested
citizens in advance, and to organize the public
meeting under the auspices of an existing
organization, such as the town council or the League
of Women Voters.
• Site tours. Site tours for local officials,
members of the media, and small groups of active
citizens enable community relations staff to explain
in detail the problems at the site and the proposed
solution.
• News releases. News releases are usually needed at
the beginning and completion of a response action.
They can also be used to describe significant
developments at the site. They help ensure that the
media provide accurate technical information to the
public.
• Progress reports. Community relations staff must
provide local officials and citizens with periodic
progress reports and fact sheets on site activities.
These reports should summarize past work and should
provide details of upcoming activities. The staff
should encourage the community to comment on these
reports. Where the level of community interest is
high, staff should distribute progress reports on a
monthly basis.
4. Implement activities specified in the CRP.
Following the activities laid out in the CRP can help ensure that adequate
attention is given to the community's need for information and for input into
technical decisions at the site. On occasion, it may be necessary to deviate
from the plan. As Chapter 5 points out, the CRP is a dynamic document that
should be updated to conform to changing citizen concerns and to revisions in
the technical schedule for the response action. If a planned removal extends
beyond three months, it is advisable to review the plan, to evaluate whether
it meets both the government's and the community's needs, and to modify the
plan as necessary.
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5. Prepare a responsiveness summary.
When the planned removal is concluded, a final report or "responsiveness
summary" must be prepared and should be submitted to the Office of Policy and
Program Management in the Office of Emergency and Remedial Response, EPA
Headquarters. This in-house report must describe the community relations
activities conducted and the major issues that arose at the site. In
addition, it must evaluate the effectiveness of the community relations
program at the site. The purpose of the report is to document EPA and state
actions, to assist in community relations planning in the event that long term
remedial response occurs at the site, and to help plan for subsequent
community relations programs at other sites. The summary may be used to help
document for the public record how EPA responded to key community concerns and
issues.
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CHAPTER 3
COMMUNITY RELATIONS DURING REMEDIAL RESPONSE
This chapter provides guidelines for conducting community relations
activities during remedial actions. Remedial actions are those responses to
releases on the National Priorities List that require longer term and possibly
more expensive efforts to prevent or mitigate the migration of releases of
hazardous substances. (See the definition of remedial response in Section
300.68 in the National Contingency Plan.) A community relations program is a
key part of EPA and state activities during a remedial action. As pointed
out in Chapter 1 of this handbook, without a program of ongoing communication
between the community affected by the release of hazardous substances and the
agency responsible for cleanup, EPA and the state cannot provide accurate,
understandable information to the community about site problems and cannot
incorporate community concerns into decisions about response actions.
When the federal government has lead responsibility for a remedial action,
the U.S. Army Corps of Engineers will usually be responsible for management of
remedial construction. Community relations, however, will continue to be the
responsibility of EPA during all stages of the response; the state may play a
supporting role. When the state has the lead responsibility for the remedial
action, EPA staff will review state programs and may participate in community
relations activities, as specified in the cooperative agreement. Therefore,
community relations during a remedial response may involve the efforts of
three or more agencies: EPA or state staff will manage the program, and in
certain cases, the Corps of Engineers will provide technical assistance. In
addition, other federal or state agencies may be responsible for certain
aspects of a response, with corresponding responsibilities for community
relations. The Federal Emergency Management Agency, for example, manages
Superfund-financed relocations of residents and businesses, when necessary.
The blueprint for community relations programs at remedial action sites
is the community relations plan (CRP) . This chapter discusses communications
activities that could be incorporated into a CRP for a remedial action.*
These activities or techniques, suggested here as general guidelines,
correspond to each of the technical stages of a remedial response. In
practice, however, a remedial action may not be as neatly structured as this
*Staff responsible for community relations planning should also consult
Chapter 5 and Appendix A for a detailed summary of remedial action planning
requirements.
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chapter suggests. Every site presents distinctive problems; every community
has unique needs and expectations to consider. Moreover, the specific
communications activities selected for a site will depend partly on the staff
responsible for managing them, as the techniques that work best are often
those with which staff feel comfortable.
The guidance in this chapter is organized according to the following
division of a remedial action:
1. Preliminary Assessment
2. Site Inspection
3. Priority Listing and First Notification of Proposed Action
4. Remedial Investigation
5. Feasibility Study: Development and Selection of Alternatives
6. Remedial Design
7. Construction
8. Monitoring and Documentation
9. Summary
1. Preliminary Assessment
Community outreach is important even during site discovery and
assessment. A great deal can be learned about the concerns of the affected
community through a few small steps.
At this stage, the people most interested in learning of Superfund planned
actions and most eager to communicate their understanding of site problems may
be the local officials: the mayor, public health chief, public works chief,
and so forth. Therefore, one of the first actions community relations staff
should take during the preliminary investigation of a site is to establish
contact by phone with state and local officials and with key citizens who can
provide some information about the scope and history of the problem. These
early telephone conversations should be used to gather information on the
technical and communications aspects of the problems posed by the release.
Community relations staff should also use these early contacts to explain the
limitations on the help available through Superfund. Unrealistically high
expectations of federal action and funds can lead to demands that cannot be
met at a later stage.
The preliminary assessment will not normally involve any official EPA or
state presence at the site. During this stage, it can be misleading to give
community relations activities a high public profile as further actions may or
may not be forthcoming.
2. Site Inspection
At this stage of a remedial action, EPA or a state has decided -- based on
the preliminary assessment -- that the site warrants additional study.
Community relations activities during a site inspection should focus on
informing the community of site inspection activities and the likely schedule
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of future events. Staff should emphasize the tentative nature of any plans
and should stress that the inspection should not be viewed as evidence of a
serious contamination problem. Community relations staff should inform the
community through a brief fact sheet that the site inspection is limited in
scope, and is intended primarily to gather any data needed for ranking on the
National Priorities List.
3. Priority Listing and First Notification of
Proposed Course of Action
Community relations efforts become critical once EPA has set
priorities and evaluated a site for remedial action. At this point, EPA or
state staff must conduct on-site discussions with local officials and
citizens, evaluate the nature and level of citizen concern, and determine how
the remedial investigation and feasibility study may affect citizen
concerns. The on-site discussions and the assessment of citizen concern will
become the foundation of the CRP for the site. These activities are described
below.
3.1 On-Site Community Discussions
Site problems go beyond the physically measurable, technical problems
of hazardous waste releases. The community setting of the hazardous substance
problem must also be understood before investigating the problem and proposing
a technical solution. Community relations staff should, therefore, conduct a
series of short on-site discussions with the state and local officials
involved with the site, citizen leaders representing interest groups, business
leaders, environmentalists, members of other community groups such as the
League of Women Voters, and any other interested citizens. The information
gleaned from these discussions may enhance the technical understanding of the
site if 1'ocal officials and residents know of past dumping practices. In
addition, these discussions can provide valuable information about local
attitudes toward the site and past government actions. Thus, these
discussions provide an opportunity for public input to the planning process.
They also enable community relations staff to identify the best means to
provide information to the community during the response action.
3.2 Assessment of Citizen Concern
On the basis of these community discussions, community relations
staff should assess the nature and level of citizen concern about the site.
(See Chapter 4, Assessment of Citizen Concern: A Procedure and Appendix B.)
An evaluation of the following factors can help staff determine how the level
of citizen concern at a site compares to concern at other sites, and whether
concern is likely to increase or decrease over the course of the action:
• Whether families in a community believe their
children's health may be affected by the release;
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• Whether local homeowners and businesses believe that
the site has caused them or will cause them economic
loss;
• Whether EPA's or the state's past performance at the
site is viewed by the public as competent and their
statements as credible;
• Whether an active, vocal group leader has emerged
from the local community and whether the leader has a
substantial following;
• Whether events at the site have received substantial
coverage by the media; and
• Whether more than three or four households perceive
themselves as affected by the site.
The judgments about the nature and level of citizen concern should be
reflected in the selection of communications activities to be used during the
response action. This evaluation should be explicitly stated in the CRP.
3.3 Assessment of Technical Complexity
The selection of community relations activities during the remedial
action should also be influenced by the level of technical complexity at the
site. All other things being equal, the more difficult the problems at the
site and the more complicated the probable response action, the more
comprehensive and detailed the community relations program required. Some
likely indicators of greater technical complexity at a site include:
• Heavily or widely contaminated groundwater;
• A complex mix of chemicals;
• Jointed or fractured bedrock indicating potentially
deeper contamination;
• A very large volume of contaminated material;
• The presence of very toxic, persistent chemicals;
• A large population potentially at risk;
• A sensitive or protected ecosystem at risk; or
• Other characteristics that make remedial action
longer, more difficult, more expensive, or harder to
evaluate than average.
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The analyses of how the level of technical complexity and the proposed timing
of response actions affect the selection of communications activities for the
site should also be described briefly in the CRP.
3.4 Preparation of the CRP
Having completed the on-site discussions and the assessments of citizen
concern and technical complexity, the community relations staff must then
prepare a draft CRP. The draft CRP must be submitted with the draft Action
Memorandum for federal-lead sites or with the draft cooperative agreement for
state-lead sites. It must include:
• A description of the site's background and the
background and history of community involvement at the
site;
• Community relations objectives for the site during
the remedial investigation and feasibility study;
• Any immediate community relations activities
recommended prior to approval of the complete CRP;
• A list of affected and interested groups and individ-
uals, their affiliations, addresses, and telephone
numbers;
• A schedule for completing the CRP; and
• The date the draft CRP was prepared.
The draft CRP will form the basis of the complete CRP which must be
submitted: (1) for federal-lead sites, within four weeks of the submission of
the draft Action Memorandum or prior to the initiation of the remedial
investigation, whichever comes first; or (2) for state-lead sites, with the
final cooperative agreement package. The complete CRP must include:
• The information presented in the draft CRP, updated
if necessary;
• A specification that the public will be given a
minimum three week comment period to review the
feasibility study prior to the selection of the
recommended alternative and an explanation of how this
comment period will be structured;*
*At the time the CRP is drafted, staff may know that an initial remedial
measure (IRM) will be needed at the site. Where an IRM will be needed, the
CRP must address how the community will receive prior notification of any
action. In addition, the CRP must state that citizens will have an
opportunity to comment on any recommended complex IRM at the conclusion of a
limited feasibility study, and must explain how a minimum two week comment
period w\ll be implemented. See Section 5 of this chapter for further detail.
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• A specification of the activities and techniques
that will be used to keep the community informed of
actions at the site and to elicit citizen input (e.g.,
meetings with citizen groups, periodic progress
reports) ;"•'"
• A list of technical and community relations staff
responsible for the site;
• The community relations program budget; and
• A workplan and implementation schedule.
The objectives and activities specified in the CRP should be consistent
with the community's concerns and need for information. Community relations
activities should also be tied to specific events in the technical response
schedule (e.g., small group meetings or briefings could be scheduled at the
initiation of the response action and during the comment period on the
feasibility study). Because the level of community concern and technical
problems differ at every site, there is no standard community relations
program. As an aid to community relations staff, however, this chapter
presents suggested activities corresponding to each stage of the remedial
action.
4. Remedial Investigation-*
The purposes of the community relations program during the remedial
investigation are to establish effective mechanisms for:
• Distributing understandable, accurate information
about the progress and findings of the investigation
to the public; and
• Eliciting citizen views about the findings of the
investigation.
Contact between agencies involved in cleanup and community members can be
initiated and sustained in several ways. One of the most effective management
•':In addition to the requirement for a comment period on the feasibility
study, the CRP must include a brief description of how community relations
staff will provide progress reports to the local community. Where interest
and concern are high, staff should distribute progress reports -- either
written briefings or fact sheets -- on a monthly basis.
••'"'•At some sites the remedial investigation and feasibility study are
treated as one study and as one stage in the remedial action. Where this
occurs, community relations staff should plan and implement activities
appropriate for a combined study.
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tools is to designate a Superfund community relations coordinator for the site
to channel both citizen and intergovernmental contact. Diplomatic skills on
the part of the coordinator are very important; being a good engineer or
program manager alone is not enough for this sensitive position. The
coordinator must be available to hold meetings and be interviewed after office
hours, when residents may likely be available. It is not necessary that the
community relations coordinator be present at the site everyday; however, the
coordinator's schedule should be well-publicized.
Useful forms of citizen-agency interaction during the remedial
investigation stage that should be specified in the CRP include:
• Informal meetings for distributing significant test
results or other information about the response action;
• Meetings with individual citizens or groups of
citizens affected by any results of health studies;
• Briefings of local officials and state and federal
legislators;
• Public consultations and workshops, where community
relations staff meet with small groups of citizens to
keep abreast of community concerns and pass on
information;
• Progress reports, fact sheets and news conferences;
• A repository for site information at the local
library, health office, or community center that
contains approved technical documents, official phone
numbers, and the CRP;
• Site visits.
The use of an information repository is encouraged and should be established
as soon as the state contract or cooperative agreement is signed.
It is possible that local citizens will not want to become involved in and
extensively informed about the problem of hazardous substances at this stage.
Alternatively, some citizen groups will make early and possibly large demands
for resources on any agency that indicates an interest in helping the
community. The coordinator should frequently assess the changing information
needs of the community, and if necessary, modify the CRP to reflect these
changing needs.
5. Feasibility Study: Development and
Selection of Alternatives
A major community relations effort must accompany the development of
cleanup alternatives during the feasibility study and the selection of the
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most cost-effective alternative. The release problem is not resolved, no
matter how adequate the technical measures implemented, unless the people for
whom it has been a problem find those technical measures to be an acceptable
solution. The goal of a community relations program at this stage is,
therefore, to maintain communication with local officials and citizens, to
explain the remedial alternatives in understandable terms, and to solicit
citizen input into the selection.
Special attention to community relations may be necessary at this stage if
the remedial alternatives under consideration involve permanently containing
wastes or other hazardous substances on-site. Citizens and local officials
concerned about hazardous substance problems are generally reluctant to accept
a "permanent remedy" that does not remove all hazardous substances from the
site. Statutory cost-effectiveness requirements, and the decision procedures
specified in the National Contingency Plan, however, give preference to
on-site remedies. Planning for community relations efforts should take these
requirements into account when estimating the likelihood of community
opposition to the Superfund action at this stage.
Among the community relations techniques recommended during the
feasibility study stage are the following:
• Public consultations prior to and throughout the
public evaluation of the feasibility study;
• News releases, fact sheets, and progress reports
that explain the study's progress and conclusions;
• Site tours;
• A continuation of the information repository; and
• Small public meetings, briefings, and workshops.
To ensure that citizens have ample time to review and provide input to the
alternative response actions, EPA requires that a public comment period
precede the selection of the remedial alternative for feasibility studies.
The comment period requirement varies slightly for nonexpedited and for
expedited feasibility studies.
For nonexpedited feasibility studies, a minimum three week comment period
must precede the selection of an alternative. If there is a reasonable
request for an extension (e.g., because documents are lengthy and complex or
there is a delay in providing copies to the public), community relations staff
should extend the review period, as long as the delay does not exacerbate
threats to public health, welfare, or the environment at the site. Extensions
should be for a minimum of one week and can be longer when appropriate.
Copies of the feasibility study should be provided free of charge to citizens
upon reasonable request and to the extent practicable. Prior to the comment
period, the community relations coordinator and other officials must publicize
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the availability of the feasibility study and request written comments on the
remedial alternatives. During the comment period, the coordinator should
review with the community the advantages and disadvantages of the alternatives
under consideration. Notice should be given of where written comments should
be sent and the deadline for submission. The CRP must detail how the public
will be provided opportunity to comment.
The comment period policy for initial remedial measures (IRMs), or those
actions that can be taken quickly to limit exposure or threat of exposure to a
significant health or environmental hazard during remedial planning, is
similar: EPA must provide the affected community with information about the
action and must elicit community views and concerns. When the needed action
consists of simple IRMs,* no comment period is required but EPA must provide
advance notification of the action to the community. Community relations
staff should identify the most effective way(s) to inform the community of the
action and to respond to citizen concerns. News conferences or news releases,
combined with door-to-door contacts, phone conversations, or small group
meetings, could be effective ways for providing information and for
identifying community issues.
When a complex IRM is recommended following an expedited remedial
investigation and feasibility study, the community relations staff must not
only notify the community of the recommended action, but must also provide a
minimum two week comment period. This comment period may be lengthened if
the community requests an extension as long as the extension does not
exacerbate threats to public health, welfare, or the environment at the site.
During this comment period, community relations and technical response staff
should hold small group meetings or workshops, provide fact sheets, or engage
in other activities that explain the conclusions of the limited feasibility
study to the community.
The alternative remedies for nonexpedited or expedited feasibility studies
may be presented and reviewed at a public meeting or a formal hearing where
public comment is invited. As noted above, large public meetings or formal
hearings are not necessarily encouraged; small informal meetings and the
other communications techniques listed above are encouraged instead because
they are more effective in most situations. If community relations staff
determine that a public meeting or hearing is necessary at this stage
•''Simple IRMs include: staging/overpacking drums; runon/runoff controls;
site security measures; dike/berm stabilization; fences; temporary covers;
drum/tank sealing; and temporary relocation.
•""'•"Complex IRMs include: measures such as off-site transport or disposal
of drums/tanks; off-site transport or disposal of lagoon liquids; sludges and
highly contaminated soils; leachate treatment; and temporary water supplies.
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because of citizen requests or other reasons, such meetings or hearings should
be preceded by extensive, informal interactions with local citizens, groups,
and government officials. Small-group meetings, briefings, and committee
meetings may be the best preparation for a productive formal meeting.
Adequate advance notification (generally two weeks) must be given for a public
meeting or hearing, if one is held, including newspaper and radio
advertisements and posted notices. Even if a formal hearing is held,
community relations staff should provide for receipt of written comments or
testimony from those members of the community that cannot provide oral
comments.
At the conclusion of the feasibility study stage of a remedial action,
community relations staff must prepare a "responsiveness summary." This
in-house report reviews public inquiries and comments, the issues and concerns
raised, and how EPA or the state responded. A responsiveness summary
describes how the final remedial action decision incorporated local citizen
concerns. If the government's selected alternative does not meet major
citizen concerns, the summary should explain why members of the community do
not support the recommended alternative. This report may be used to help
document for the public record how EPA or a state responded to key community
concerns and issues. The summary should be submitted with the draft Record of
Decision to EPA Headquarters.
6. Remedial Design
During the engineering design and review stage, community relations
can be critical, because different members of the community may become
involved in response action issues or people not satisfied with the
recommended alternative may press for additional action. Thus, prior to
remedial design, the responsible agency must revise the CRP to account for
the changing needs and concerns of the site community related to the selected
cleanup option. The revised CRP should be submitted two weeks after the
submission of the draft Record of Decision for federal-lead sites and with the
draft amended cooperative agreement application for state-lead sites. The
revised plan should specify all the major communications activities to be
conducted during the remedial design and construction stages and should
present a revised program budget, workplan, and schedule. Whenever the Corps
of Engineers is involved with remedial design and construction, the plan -
should also describe the Corps' support role (e.g., the Corps'
responsibilities for reviewing materials and participating in briefings). The
responsibilities of other federal agencies (if any) involved in the response
should also be outlined.
An effective community relations program for the remedial design stage
might include:
• Briefings for local officials;
• Small meetings with citizens who demonstrate
continued interest;
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• Public service announcements on radio or TV;
• News releases;
• Fact sheets and progress reports; and
• A continuation of the local information repository.
The purpose of these activities is to explain to local officials and
citizens the activities that will take place during engineering design, and
once design is completed, to explain in understandable terms the design
conclusions and construction proposal.
7. Construction
During site construction, the community relations coordinator should
continue to inform area residents and businesses of the progress of
construction, any health hazards that may be caused by construction, suitable
hazard precautions, economic effects, new findings, and the reasons for any
delays in the cleanup. To ensure that the local public is adequately
informed, the community relations coordinator must provide site information to
local officials and citizen leaders on a frequent basis. Appropriate
techniques at this stage continue as before:
• News releases, fact sheets, and progress reports;
• Briefings for officials;
• Public consultations and small informal meetings;
• Site tours; and
• A continuation of the local information repository.
Community relations staff must also make sure local residents understand
that cleanup of the site may not resolve all problems. Meetings with small
groups of citizens and officials to explain the likely results of the remedial
action may again be the most effective communications technique during this
stage of the response action.
8. Post Cleanup Documentation
Upon completion of the cleanup, the EPA staff must evaluate EPA's and
the state's interaction with the local government, interest groups, and
citizens. This includes the preparation of a responsiveness summary that
should be submitted within one month of the completion of the response action
to EPA Headquarters. A responsiveness summary may help prevent problems at
other sites; it will also suggest ways to continue public awareness at the
completed site.
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Citizens and officials should also be informed through small meetings and
briefings about the limits of and resources available for operation and
maintenance, and the agencies responsible. The future uses of the site should
be clear.
9. Summary
Exhibit 3-1 summarizes suggested community relations activities
discussed above for each of the stages of the remedial response. These
techniques may or may not be useful at any given site. Some sites may not
require extensive public consultations, briefings, etc., while responses at
other sites may require several public hearings and frequent news releases.
Chapter 4 describes in more detail each of the techniques listed in this
chapter.
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EXHIBIT 3-1
REMEDIAL RESPONSE AND COMMUNITY RELATIONS ACTIVITIES*
Step
Preliminary Assessment
Site Inspection
Priority Listing and First
Notification of Proposed Action
Remedial Investigation
Feasibility Study
Remedial Design
Remedial Construction
Post Cleanup Documentation
Community Relations Activities
Telephone contacts, telephone
discussions with officials and key
citizens
Brief fact sheet
On-site community information
discussions
Assessment of citizen concern
Fact sheet, progress report
Briefings, workshops, and public
information meetings
News conferences
Information repository
News release
Fact sheet, progress report
Public consultations
Briefings, workshops, and public
information meetings
Information repository
Comment period
Fact sheet, progress report, or
briefing
News releases
Small meetings, workshops
Information repository
News releases
Fact sheet, progress report
Briefings
Site tours
Information repository
Small meetings and briefings
"The community relations activities listed are examples of techniques that
may be effective at Superfund sites. Community relations staff should select
communications techniques that are consistent with the nature of community
concern and the technical response schedule.
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CHAPTER 4
EXAMPLES OF COMMUNITY RELATIONS TECHNIQUES
This chapter describes the purposes, benefits, and limitations of the
community relations techniques that may be used in a Superfund response. It
supplements Chapters 2 and 3, which explain when these techniques should be
used during a removal or remedial action. The following techniques are
discussed:
1. Telephone Contacts
2. On-Site Discussions
3. Assessment of Citizen Concern: Procedure
4. Briefings
5. Citizen Group Meetings
6. Exhibits ,
7. Fact Sheets/Progress Reports
8. Formal Public Hearing
9. Media Appearances
10. Presentations
11. News Conferences
12. News Releases
13. Site Tours
14. Public Consultations/Small Group Meetings
15. Public Inquiry Responses
16. Public Meetings
17. Workshops
18. Information Repository/Project File
As emphasized in Chapters 2 and 3, the key to a successful community
relations program is targeting activities to the distinctive needs of the
community. Therefore, not all of the techniques described in this chapter
are appropriate for every response action. Appendix A describes further the
importance of selecting the appropriate mix of techniques in the development
of a site-specific community relations plan (CRP) .
This chapter does not present an exhaustive discussion of public
participation techniques. Readers should consult public participation
manuals, such as the manuals prepared for EPA's water programs, for detailed
information.
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1. TELEPHONE CONTACTS
ACTIVITY
PURPOSE
TECHNIQUE
Initial contact with congressional and local officials and
concerned citizens by telephone informing them of EPA's
and the state's interest in the site, finding out which
individuals or groups are involved with the site, and
setting up personal interviews for a later date.
Removal Actions: To gain an understanding of the level of
community concern about the removal action. If time
permits, telephone interviews may be used to collect
additional information and establish contacts for public
consultations at a later date.
Remedial Actions: To collect information about the site
that will be used in planning a remedial response program.
Types of information needed are:
• Background on the site and description of the
problem.
• Recent government activities at the site.
• Nature and extent of citizen involvement.
• Names and telephone numbers of other possible
contacts.
• Person's address for fact sheets, mailing lists,
public consultation, or public meeting announcements.
The method used in contacting people by telephone is a
matter of personal discretion and common courtesy. It is
important, however, to know exactly what information is
needed from the contact (e.g., additional references, site
specifics, background information) and to be prepared with
questions.
The following list includes possible contacts and the
information available from each.
• Local Congressional staff office: After
obtaining EPA and state.clearance, contact the
Congressional representative from the area in
which the site is located. Coordinate all
contacts with Congressional liaison office in the
Region. State legislators should also be
contacted.
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1. TELEPHONE CONTACTS (continued)
TECHNIQUE:
(cont-inued) ..
• State health departments: Health officials may
.have received complaints from citizens concerning
the safety of a site. They may also know about
active community groups that have addressed the
hazardous substance problems in the state.
Moreover, these officials will know about any
state sponsored health effects studies or
monitoring conducted at the site.
• .State environmental or pollution control
agency (and' equivalent offices at the city and
county level): Contacting state or local
pollution control officials can be most effective
for finding out about concerned citizens. Often,
local resident and community groups have
contacted officials at this level seeking answers
to questions, about potential hazards, etc. These
officials can also provide impressions of citizen
expectations.
• Local elected officials (mayors, city
managers, etc.): They can explain not only what
the citizens want, but also what steps, if any,
have been taken to satisfy citizen demands.
These officials can often put citizen concerns in
perspective, identifying how important or
unimportant the hazardous substance problem is to
the community as a whole.
Telephone calls can be an inexpensive and expedient method
of acquiring initial information about the site. During
immediate removals, the telephone contacts can help the OSC
identify and deal with community concern when time for more
thorough community relations activities is not available.
In remedial response actions, telephone interviews will
often be useful for establishing a network of contacts to
be used later during on-site community discussions.
LIMITATIONS The information received through telephone calls may not be
accurate. The public may not know much about the site
except what has been circulated in rumors or newspaper
articles.
BENEFITS
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2. ON-SITE DISCUSSIONS
ACTIVITY
PURPOSE
TECHNIQUE
On-site discussions with local residents, government
officials, community groups, and media representatives.
(Note: these are not surveys of community opinion; they
are informal, on-site interviews conducted to obtain
information and to elicit community concerns.)
To gain an understanding of the site's history, the
community issues connected with the site, the level of
citizen concern, and the political climate. These
information interviews are also useful to identify credible
sources and disseminators of information.
For planned removals and remedial actions, community
information discussions are conducted prior to the
preparation of the CRP.
Arranging the discussions: At this stage of the removal
or remedial response, the names and phone numbers of the
people involved with the site may have been obtained.
Ideally, the meeting place should be at the interviewee's
office or home, conducive to candid discussions. While
government and media representatives are likely to prefer
meeting in their offices during business hours, local
residents and community groups may be available only
after-hours. Meetings at their homes may be most
convenient.
Planning the discussions: Prior to or during the
discussion, time may be spent reviewing files that contain
news clippings, documents, letters, and other sources of
information relevant to the site. Officials should assign
people with a thorough understanding of the Superfund
program, the site's problems, and interview techniques to
conduct the discussions.
Telephone interviews: In preparation for the discussions,
some information may be efficiently obtained over the
telephone -- for example, demographic facts about the
community (population, median income, etc.). In telephone
interviews, explain how the interviewee's name was
acquired, and the reason the information is needed. Be
brief. (See pages 4-2, 4-3.)
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2. COMMUNITY INFORMATION DISCUSSIONS (continued)
TECHNIQUES Meeting with local government officials: Interviews with
(continued) government officials should include a brief introduction
explaining why they are being interviewed and what kind of
information is needed (site history, government activity at
the site, a political perspective on citizen's
expectations, etc.).
Meeting with residents and community groups: Interviews
involving local residents or community groups are likely to
require more time. Be prepared with a discussion guide --
questionnaires are too formal and are likely to elicit curt
responses. Be sensitive to the residents' needs but remind
them that the purpose of the interview is to gather
preliminary information to be used in planning response
actions and appropriate citizen participation programs. In
this way, unrealistic expectations are not raised.
In many cases, the interviewee will ask questions and
express concerns about the site. With adequate
preparation, the interviewer can thus acquire information
useful for later planning, as well as respond to initial
citizen concern with accurate information and allay
unwarranted fears.
Confidentiality: At the beginning of each discussion,
explain that the report will be presented to EPA or state
officials and other interested persons. If the interviewee
would like to remain anonymous, explain that the
information will be used to understand community concerns
and that a record of the contact will be made, but EPA or
the state will not attribute any specific statements or
information to the interviewee.
Other possible contacts: During the discussions, ask for
names and phone numbers of persons who could provide
additional information on the site.
Information on citizen participation activities: Ask
whether the interviewee would like to receive any fact
sheets or other printed information as the response action
continues. Also, for future reference, keep a list of
persons interested in attending public consultations and
public meetings.
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2. COMMUNITY INFORMATION DISCUSSIONS (continued)
Maintain list of interested citizens: Staff should keep a list
of citizens who will be interested in participating in meetings
and briefings and receiving information. This list should be
updated from time to time.
BENEFITS The views of citizens and government officials are often not
stated clearly in the media. On-site discussions, however, are
excellent sources of opinions and expectations regarding- a
response action. In addition, these interviews may lead to
'additional sources not previously considered. Contacting the
full range of interested parties early in the remedial process
means that officials will not be surprised when groups surface
later on.
LIMITATIONS Much subjectivity is involved in assessing the motives and
credibility of each interviewee. In reporting on discussions to
other EPA or state officials, evaluative statements must be
attributed to specific sources.
In addition, it is important to recognize that officials may
have political or other motivation to withhold or distort
information. Recording interviews when possible may help clear
up misunderstandings that might arise in such circumstances.
Another limitation of the on-site discussions is that some
interviewees -- particularly government officials -- may believe
that their activities at the site are being evaluated. Assure
them that this is not the intention and that the purpose of the
interview is to help community relations staff understand the
community's views about the site before beginning cleanup
actions.
NOTE: See Appendix B for further information.
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3. ASSESSMENT OF CITIZEN CONCERN: PROCEDURE
ACTIVITY
PURPOSE
TECHNIQUE
• An assessment of citizen concern about the release of
hazardous substances. Information derived from this
procedure can assist officials in estimating the level of
effort to devote to community relations at the site.
To provide additional information on the level of community
concern. This procedure may be useful in:
• Assessing local concerns where no previous
contacts with the community have been made;
• . Confirming the judgments of field personnel on
the level of concern in a community; or
• Reassessing preliminary judgments about citizen ... .
concern.
This procedure is best used after the completion of the
community information discussions, performed by community
relations staff or a contractor. These on-site discussions
provide background information and indicate future
directions of local concern. If initial assessments of
citizen concern have already been made, an accurate
assessment of concern may require follow-up telephone calls
to local officials and citizen leaders to update the
information about the community.
Superfund officials may assess whether community concern at
a site is high, medium, or low by determining the presence
or absence of six characteristics after interviewing
members of the local community. An analysis of citizen
concerns at hazardous waste sites has shown that some of
these characteristics are more important than others in
determining the level of concern in a site community. The
characteristics are:
• Children's health -- whether families in the
community believe their children's health may be
affected by the hazardous substances;
• Economic loss -- whether local homeowners or
businesses believe that the site has caused them
or will cause them economic loss;
• Agency credibility -- whether the performance
and statements of EPA and the state are viewed by
the public as competent and credible;
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3. ASSESSMENT OF CITIZEN CONCERN: PROCEDURE (continued)
TECHNIQUE
(continued)
• Involvement -- whether an active, vocal group
leader has emerged from the community and whether the
group leader has a substantial local following;
• Media -- whether events at the site have received
substantial coverage by local, state, regional, and/or
national media;
• Number affected -- whether more than three or four
households perceive themselves as affected by the site;
If several of these characteristics describe the affected
community, the community relations coordinator has grounds
for considering that the level of community concern at the
site may be medium to high or has the potential to be
medium to high. Threats to children's health is a
particularly strong indicator of a potentially high level
of citizen concern at a site.
This procedure assists officials in identifying and
measuring community concern at the site or in reassessing
previous evaluations. Community relations staff should use
this assessment in determining the kinds of communications
activities to be conducted at the site.
LIMITATIONS This procedure is only one method to assess the level of
citizen concern at a Superfund site. Although it is based
on an analysis of the factors affecting levels of citizen
concern at investigated sites around the country, the use
of this procedure is necessarily subjective. The degree to
which these factors are present is a matter of judgment.
BENEFITS
NOTE
If community relations staff determine that there is a low
level of citizen concern at a site, staff should not assume
that only a minimal community relations program is needed
at the site. Every site needs an active, two-way
communication program. The assessment of citizen concern
should allow community relations staff to select those
activities that best meet the community's characteristics
and concerns.
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4-9
4. BRIEFINGS
TECHNIQUE
ACTIVITY Sessions held with local government officials, often before
a news conference. Should precede meetings and workshops
held with local citizens.
PURPOSE Removal Action: To notify officials of the nature and
reasons for the action and to keep them informed of recent
developments at the site.
Remedial Responses: To inform officials and other
interested parties about recent developments at the site,
to provide them with background material on the technical
studies, results of the field investigations and
engineering design, and to report to them on proposals and
planning for remedial Action.
Inform local officials or other attendees, generally 2 weeks
before a scheduled briefing, that a briefing concerning
recent activities at the site or other related topics will
occur. It is usually best to hold the initial briefing in
the office of the officials or at a local meeting room.
Subsequent briefings should be held at a convenient time
and location.
Present a short, official statement about the preliminary
findings from the site activities (inspections,
investigations, engineering design, etc.) and the EPA/state
decision process, and announce future steps in the process.
Answer questions from local officials and other attendees
about the statement. Anticipate questions; be prepared to
answer them without getting involved in minor details and
subjective judgments.
BENEFITS Because briefings are often held in conjunction with news
conferences, they are useful in educating the local
officials and other interested parties about the topics of
the upcoming news conference.
LIMITATIONS Bad feelings or bad publicity could result if some
individuals who believe they should be invited to the
briefings are not. Care must be taken not to exclude these
persons, or otherwise to convey an impression of favoritism
towards other interested parties.
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4-10
5. CITIZEN GROUP MEETINGS
ACTIVITY Small group meetings between community relations .-staff and
interested citizens sponsored either by the lead agency or
by a group representing community interests..
PURPOSE To exchange ideas about an appropriate remedy for the . •
release. To clear up misconceptions or misunderstandings.
To keep citizens informed and to encourage them to express
their views. ' ..' :-'>.-
TECHNIQUE EPA's or the state's role is to help organize the meeting,
to keep the group informed of developments in the response
action, and to consider its views in making response
recommendations or decisions.
BENEFITS A citizens' group can provide EPA or the state with the
public's perspective on the adequacy and acceptability of
the proposed removal/remedial response. This information
allows changes in the response program and can reduce the
probability of public controversy after a solution has been
implemented.
LIMITATIONS Attendance at group meetings is not always a substitute for
face-to-face consultations with individual citizens; it
should be a supplement to other communications techniques.
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4-11
6. EXHIBITS
ACTIVITY
PURPOSE
TECHNIQUE
BENEFITS
Setting up visual displays of maps, charts, diagrams, or
photographs. These may be accompanied by a brief text
explaining the displays and the purpose of the exhibit.
To illustrate issues associated with hazardous substance
problems in a creative and informative display.
Identify the target audience and the message to convey.
Possible audiences:
General public
Concerned citizens
Environmental groups
The media
Public officials
Possible messages:
Description of the site
Historical background
Proposed remedies
Health and safety effects associated with the site
Determine where the exhibit will be set up. For example,
if the general public is the target audience, assemble the
exhibit in a highly visible location, say a public library,
convention hall, or a shopping center. On the other hand,
if concerned citizens are the target, set up an exhibit
perhaps at a public meeting. An exhibit could even be as
simple as a bulletin board at the site or trailer if this
is a convenient communications location.
Design the exhibit and its scale according to the message
to be transmitted. Include photos or illustrations. Use
text sparingly.
Exhibits tend to stimulate public interest and
understanding. While a news clipping may be glanced at and
easily forgotten•, exhibits have a visual impact and leave a
lasting impression.
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4-12
6. EXHIBITS (continued)
LIMITATIONS Although exhibits inform the public, they are only a
one-way communication tool. One solution to this drawback
is to attach blank postcards on the exhibit, encouraging
viewers to comment or submit inquiries by mail to EPA or
the state. Another remedy is to leave the phone number of
a contact who will be available to answer questions during
working hours. Provisions must be made for responding to
any such requests, however, or citizens may lose trust in
EPA or the state.
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4-13
7. FACT SHEETS/PROGRESS REPORTS
PURPOSE
TECHNIQUE
ACTIVITY A brief progress report on an issue of concern to the
community. Includes summaries of past site work and
details of upcoming activities. Must be distributed to
government agencies with an interest in the site, area
residents, citizen groups, the media, and other interested
parties on a regular basis (at least monthly when there is
a'high level of citizen concern at a site).
To ensure public understanding of the' issues involved in
the response program and to present information on the
progress and results of the removal or remedial action.
Identify information to be transmitted. The fact sheet may
include the location of the site, the types or quantities
of substances known to be at the site, the potential
problems at the site, or an explanation of what EPA or the
state intends to do about the site. Address recurring
questions or issues of apparent concern in the fact sheet.
Select a simple format for transmitting progress reports
and maintain consistency with that format. The fact sheet
may simply state the facts or present the message using a
question-and-answer format. Avoid using bureaucratic
jargon or highly technical language because the audience is
likely to be made up of individuals with widely-varying
backgrounds.
Be concise. The purpose of the fact sheet is to provide
facts, not opinions. Fact sheets are not the only way to
keep the community informed of technical developments.
Include names and phones numbers of the person or office
issuing the fact sheet and .of other persons to contact for
further information. Date the fact sheet to accommodate
future references (e.g., for changes or updates).
BENEFITS The fact sheet provides interested persons with a brief
summary of facts and issues involved in the cleanup
operations.
LIMITATIONS If not well-written, a fact sheet, with its brief format,
could be misleading or confusing. Such problems could cost
much in time and resources.
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4-14
8. FORMAL PUBLIC HEARING
ACTIVITY
PURPOSE
TECHNIQUE
BENEFITS
Formal hearings organized by EPA and the state and open to
the public.
To provide an opportunity for formal comment and testimony
on the proposed remedial action alternative.
Anticipate the audience. In many cases, communities do
not become actively involved in hazardous substance issues
until a cleanup solution is proposed. Citizens may begin
to express a growing interest in the issue after the site
remedy is selected. Citizens' informational needs should
be adequately met before a formal hearing takes place.
Fact sheets, small-group meetings, and briefings are good
ways to disseminate necessary information in a timely way.
Schedule the hearing location and time so that citizens
have easy access. Identify and follow any procedures
established by the local and state governments for public
hearings. Ensure the availability of sufficient seating,
microphones, and recorders. Consider holding the hearing
in the evening or on a weekend to accommodate the majority
of concerned citizens.
Announce the public hearing at least
the hearing date.
2 weeks in advance of
Provide notice of the public hearing in newspapers and in
mailings to interested citizens. A follow-up phone call to
ensure that the notice has been received is also
recommended for major participants.
Provide an opportunity for local officials and citizens to
submit written comments. Not all individuals will want to
provide oral testimony. Community relations staff must
publicize where written comments can be submitted and how
they will be reviewed.
Provide a transcript of all oral and written comments.
Publicize where the transcript is available for public
review.
The major benefit of a formal public hearing is that it
permits a prepared presentation of the issues and provides
clear documentation of community concern.
LIMITATIONS A high level of citizen concern at a site may precipitate a
disorderly public hearing, where citizen groups attempt to
gain support for their positions. The public hearing can
easily become an adversarial confrontation.
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4-15
9. MEDIA APPEARANCES
ACTIVITY
PURPOSE
TECHNIQUE
BENEFITS
Live or taped interviews, or discussions held with local or
national television or radio personnel.
To keep the public informed of what EPA or the state' is
doing about the release of hazardous substances.
The need for participating in a media event should be -•-
carefully evaluated. Do not draw attention to a problem
that seems insignificant to most citizens, especially if
the community is already sensitive about the attention it
is getting. . .
On the other hand, if the community is unaware of or
confused about the magnitude of the situation, broadcasts
can reach a wide audience.
Plan exactly what to say ahead of time. Live interviews
"leave no room for mistakes or statements that might need to
be retracted later.
A media appearance reaches a wide audience and permits only
the most important issues to be covered.
LIMITATIONS A media appearance can unintentionally turn into a
regrettable event if critical facts are misstated or the
impression is conveyed that EPA or the state is not
concerned about issues important to the community.
Another limitation is that media appearances, although they
allow response to a reporter's inquiries, do not allow a
response to individual citizen concerns; there is no
immediate feedback from the audience. This limitation can
be mitigated somewhat by reviewing, prior to the media
appearance, previous assessments of citizen concerns.
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4-16
10. PRESENTATIONS
ACTIVITY
PURPOSE
TECHNIQUE
Speeches to selected audiences such as clubs and existing
civic or church organizations and classes.
To improve the public's understanding of the problems
associated with a release of hazardous substances and what
EPA or the state is doing about them.
Presentations require a substantial amount of effort to be
effective. A poorly planned presentation can distort
residents' views of the situation. Develop a presentation
that can easily be changed to suit different audiences.
Begin by selecting a standard format such as the
following:
Describe the problem
Describe how the problem affects the public
Discuss what EPA or the state is doing about it
Discuss how citizens can help or obtain additional
information
The tone and technical complexity of the presentation can
then be adjusted to suit the audience's needs.
Plan the presentation to last no more than 30 minutes. It
may be advisable to have several staff members prepared to
deliver presentations. Use the remaining time to respond
to questions from the audience.
Select supporting materials -- slides, graphics, exhibits,
etc. -- that will capture and hold the audience's
attention. Polish the delivery to achieve the same
effect. Once the necessary materials have been compiled,
conduct a trial run in front of colleagues.
Contact existing groups possibly interested in learning
about hazardous substance problems. Announce the program
in the media and through other communication tools.
Be prepared to give a presentation in the evenings or on
weekends, or whenever it is convenient for citizens to
attend.
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4-17
10. PRESENTATIONS (continued)
BENEFITS Because the presentation is delivered in person, the
audience has a chance to ask questions, and EPA or the
state has an opportunity to gauge citizens concerns.
Another benefit is that a group of people is reached at one
time, alleviating the need for responding to individual
inquiries.
LIMITATIONS It may be difficult to deviate from the format of the
presentation to accommodate different concerns of the
audience. These concerns will have to be addressed during
a question-and-answer period after the presentation.
If a presentation is to,o long or not understandable to an
audience, the audience may lose interest and become
frustrated by an inability to obtain needed information in
an efficient way.
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4-18
11. NEWS CONFERENCES
ACTIVITY
PURPOSE
TECHNIQUE
Information sessions held with media representatives.
Removal Action: To provide the media with accurate
information concerning important developments during or
after the action; to announce plans for any future actions
at the site.
Remedial Response: To provide the media with accurate
information concerning important developments in the
remedial response program; to announce future plans for
remedial action at the site.
Arrange a news conference when the occasion warrants it.
Use the news conference only to announce significant
findings. The information presented should carefully and
accurately describe the seriousness of the situation.
Notify members of the local and regional media of the time,
location, and topic of the news conference. Local
officials may also be invited to attend, either as
observers or participants, depending upon their levels of
interest and involvement in the site response. Having a
news conference with local officials underscores EPA's and
the state's responsiveness and commitment to the interests
and concerns of local officials.
Brief local officials and affected citizens about sample
results or technical study conclusions before the news
conference takes place. The affected community should not
learn the results of sampling or studies through media
sources. Community relations staff should hold briefings
and news conferences early in the working week where
possible so that citizens have an opportunity to contact
staff and obtain additional information before the weekend.
Present a short, official statement, both written and
spoken, about developments and findings. In addition,
explain EPA and state decisions to proceed with a planned
removal or remedial action and identify the next steps.
Open the conference to questions, to be answered by EPA or
state officials, local officials, and other experts
present, who have agreed to respond.
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4-19
11. NEWS CONFERENCES (continued)
TECHNIQUE
(continued)
BENEFITS
Do not overuse news conferences. Other forms
of communication, such as news releases, fact sheets, and
public consultations and meetings will be used to report
the results of the site inspection, field investigation,
and EPA or state decisions. Drawing attention to
preliminary results of technical studies may fuel
unnecessary citizen fears or unreasonable citizen demands.
Gear the news conference to the magnitude of the problem
at the site.
News conferences provide a public forum for EPA and the
••'••• state to announce plans and developments. They provide
media coverage and are an inexpensive way to reach large
numbers of citizens. By preparing a written statement,
officials can help ensure that the facts are presented
accurately to the media. During the question period, the
• EPA or state spokesperson can demonstrate knowledge of the
site and may be able to improve media relations by
providing thorough, informative answers to all questions.
LIMITATIONS There are three major risks associated with news
conferences. One risk ds that a news conference can focus
a high degree of attention on the situation, potentially
causing unnecessary local concern. Consider using news
releases, or other, lower-profile means of disseminating
information if such distortion is likely. Second, the
: presiding official may say something that is inaccurate or
that should not be quoted to the media. Another risk is
that the official's comments could be taken out of context
by the media and create false impressions among the
public. This risk is heightened when the conference is not
properly structured according to rules of order or protocol
and unanticipated questions result.
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4-20
12. NEWS RELEASES
ACTIVITY
PURPOSE
TECHNIQUE
Statement of the development of on-site actions proposed by
EPA or the state. The news release is to be distributed to
the media. Information copies should be sent to local
officials and citizen group leaders before their release.
To report the proposed course of action in investigating,
containing, or cleaning up the release of hazardous
substances. Timing of news releases should coincide with
milestones in the response program, e.g., selection of an
alternative or contractor(s), key project dates, and
completion of containment or cleanup actions. News
releases may also be used to report the results of a public
meeting and describe the way citizen concerns were
considered in the planning process.
Learn the deadlines of the relevant news agencies and
regional and local newspapers and broadcast media. Get to
know the editor and the environmental reporter who might
cover the issue.
Contact other involved agencies at the federal, state, and
local level to ensure that all facts and procedures are
coordinated and correct before releasing the statement.
Select the information to be communicated. Place the most
important and newsworthy elements up front and present
additional information in descending order of importance.
Enlist the aid of a public affairs officer in writing the
release. The news release should state the proposed
remedial response action and contain the following facts:
The findings of the investigation
A statement of what needs to be done
A statement of what will be accomplished by the
alternatives
The costs and benefits
The next steps
Use supporting paragraphs to elaborate on findings,
alternatives, and other pertinent information. Mention any
opportunities for citizen input (public consultations,
public meetings, etc.), and cite factors that might
contribute to earlier implementation or delays in the
remedial action. Contact other involved agencies before
releasing.
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4-21
12. NEWS RELEASES (continued)
TECHNIQUES Be brief. Limit the news release to essential facts and
(continued) issues.
Use simple language and avoid the use of professional
jargon and overly technical words.
Identify the issuer of the news release. The top of the
sheet should include the following:
• Name and addresses of the issuing agency;
• Release time (For Immediate Release or Please
Observe Embargo Until), and date;
• Name and phone number of a staff person to reach for
further information; and
• A headline summarizing the action taken.
BENEFITS A news release, if used by the local media, can quickly and
inexpensively reach a large audience. News releases can
inform citizens of activities at the site, and give them an
opportunity to raise questions about the findings or the
alternative remedies.
LIMITATIONS Because news releases usually can contain only the most
important information, minor details that the public may be
more interested in are often excluded. Thus, a news
release alone cannot address all citizen concerns; it must
be issued in conjunction with other methods of
communication where more attention to detail is permitted.
When announcing controversial results, it may be useful to
attach a fact sheet that contains more detailed information.
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4-22
13. SITE TOURS
ACTIVITY
PURPOSE
TECHNIQUE
Scheduled trips to the site for media representatives, local
officials, and citizens during which an opportunity to ask
questions and to photograph is provided.
To involve the media, local officials, and citizens in the
community relations program, to inform them of the issues and
problems associated with the site, and to make them aware of
EPA's or the state's involvement.
Tours may be conducted during any stage of a removal or remedial
response, as the situation warrants.
Draw up a list of individuals that might be interested in
participating in a tour, including:
• Representatives of local newspapers and television
stations;
• Interested local officials;
• Representatives of local citizens and/or service groups;
• Representatives of public interest or environmental
groups that have expressed interest in activities at the
site; and
• Individual citizens and/or nearby residents that have
expressed concern about the site.
Use this list to inform people when site tours are being
arranged.
If demand for site tours is great, select a maximum number that
can be taken on site safely. Hold additional tours if
necessary. Keep the group small enough so that all who wish to
ask questions may do so.
Think of ways to involve the tour participants at the site.
Instructions on how to read monitoring devices is one example.
Anticipate questions. A fact sheet distributed ahead of time
describing the essentials about the site encourages questions
regarding substantive issues. Have someone available to answer
technical questions in non-technical terms.
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4-23
13. SITE TOURS (continued)
Ensure that the tour complies with the safety plan for the
site.
BENEFITS The media, local officials, and citizens become familiar with
the site, the difficulties of solving the problem, as well as
the individuals involved in cleanup operations. The result
could be better understanding and more accurate reporting.
LIMITATIONS An arranged tour may lead people to believe that the problem is
larger than it really is, particularly if technical aspects of
the removal or remedial action are not explained clearly, in
terms understandable to a lay audience.
Another limitation is that the public may attempt to engage EPA
or state community relations staff in a heated, unproductive
debate in the presence of media representatives.
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4-24
.14. PUBLIC CONSULTATIONS/SMALL GROUP MEETINGS
ACTIVITY
PURPOSE
TECHNIQUE
Face-to-face meetings and conferences with small groups (5
to 10 people) of interested citizens in their homes or in
small meeting places.
Removal Action: To inform citizens of the nature of any
emergency actions in cases where immediate removals have
been undertaken or to explain the process involved in a
planned removal.
Remedial Response: To inform citizens of site activities
and answer questions. Public consultations are appropriate
techniques to gauge and develop a sensitivity to citizen
concerns. They may also be used to provide advance notice
of actions that could cause alarm, e.g., the detonation of
explosive wastes.
Identify interested citizens. Contact one of the members
of citizens' groups that would be directly affected by
cleanup plans and offer to discuss cleanup plans at the
group's convenience. Schedule the consultations after
.emergency actions are completed or after EPA or the state
has accurate information to share with the citizens.
Select a meeting place conducive to two-way interaction.
A citizens' home may be the best setting for this.
Cover such issues as:
• Extent of clean-up
• Safety and health implications
• Factors that might facilitate or delay the clean-up
• How citizens' concerns are considered in making
response action decisions.
Familiarize the citizens with the major actors in the site
clean-up. Citizens want to know who is responsible in case
they have further questions or want to voice complaints or
praise.
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4-25
14. PUBLIC CONSULTATIONS/SMALL GROUP MEETINGS (continued)
TECHNIQUE
(continued)
BENEFITS
Gear the discussion to the audience. Avoid discussing the
release problems in highly technical terms unless citizens
are knowledgeable about the topic.
Listen. Find out what the citizens want done. Some
concerns may be met by making minor changes in the selected
remedy. Other citizens' objections to the planned work
would require revisions that change the cost and scope of
work of the permanent remedy. Work out a possible
compromise or explain the reasons why citizen proposed
remedies appear to be unworkable or contradict program or
statutory requirements.
Follow-up on any major/citizen concerns, stay in touch with
the groups, and contact any new groups that have formed.
The primary benefit of public consultations is that they
allow two-way interaction between citizens and EPA and the
state. Not only will the citizens be informed about the
proposed response, but the citizens will have the
opportunity to ask questions and to express their thoughts
on the issue.
Another attractive feature of public consultations is that
they add a personal dimension to what could otherwise be
treated as a purely technical problem. Familiarity with
the considerations involved in selecting the remedy can
relieve citizen apprehension about the hazardous substance
problem.
LIMITATIONS To be effective, attendance should be restricted to about 5
to 10 individuals. In situations where more than 10
citizens would like to be included, additional
consultations or a single large public meeting may be
required. Public consultations, however, use EPA or state
staff resources intensively, requiring upwards of a
half-day of staff time to reach a limited number of
citizens.
Another limitation is that some citizens or environmental
groups may perceive restricting the number of attendees as
a ploy to "water down" the influence large groups may have
on potential actions.
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4-26
14. PUBLIC CONSULTATIONS/SMALL GROUP MEETINGS (continued)
LIMITATIONS Furthermore, unless Superfund staff have a plan that
(continued) demonstrates that all interested citizens will have an
opportunity to participate in a small group meeting, such
meetings could be viewed as exclusionary.
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4-27
15. PUBLIC INQUIRY RESPONSE
ACTIVITY
PURPOSE
TECHNIQUE
Answering questions for the public and providing
information when requested.
To keep the public informed of EPA and state activities
throughout the response program.
Staff should consider establishing a toll-free "Superfund
hotline" or should publicize local telephone numbers that
citizens can use to obtain information.
Requests for information should be handled promptly.
Telephone calls and personal visits leave little time to
prepare a response; however, answer questions as thoroughly
as possible without making the caller wait. If you are on
a tight schedule, set up a more convenient time to answer
the inquiry.
Make sure the caller's needs are understood, and state
exactly what information will be sent in response to the
inquiry. Take the opportunity to inform the caller about
other sources of information.
Written inquiries allow more time to formulate clear,
detailed answers, but it is important not to delay the
response more than a few days.
Responding to public inquiries should serve two important
purposes: to keep the public informed of response actions,
and to demonstrate the desire to provide timely responses
to citizen concerns.
LIMITATIONS It is difficult to judge whether or not citizen's questions
have been adequately answered, or whether responses have
been misinterpreted.
BENEFITS
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4-28
16. PUBLIC MEETING
ACTIVITY A large meeting open to the public. Experts are available
to present information and answer questions. Citizens may
ask questions and offer comments.
PURPOSE To inform citizens of ongoing response activities, and to
discuss and receive citizen feedback on possible courses of
action -- health studies, engineering studies, etc.
TECHNIQUE Determine the participants. Consider inviting informed
local officials to make a short presentation and to respond
to questions.
Draw up an agenda detailing specific issues to be
considered or specific tasks that must be accomplished at
the meeting.
Announce the meeting in local newspapers and broadcast
media two weeks in advance of the scheduled date.
Distribute flyers to those citizens and groups interested
in attending. Before the meeting begins, review the agenda
with participants. Clarify that the meeting is not a
formal public hearing where testimony is received.
Instead, it is a meeting to exchange information and
comments.
Hold a meeting in a comfortable setting. Make sure the
location is easily accessible, is well-lighted, and has
adequate parking and seating available.
If desirable, hold the meeting under the auspices of an
existing organization. For example, conduct the meeting
as a part of an advertised presentation to a group such as
the Rotary or the League of Women Voters (if they are open
to the general public).
Begin the meeting by stating the purpose, then outline
agenda and the procedures for making statements. State
the meeting's time limit at the outset. Also state that if
issues are not adequately addressed during the meeting, a
follow-on meeting can be scheduled.
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4-29
16. PUBLIC MEETING (continued)
Present the issues concerning th\e site, preliminary
findings, and proposed course of action. Allocate some
time for citizens to express their concerns and ask :''•
questions. Establish a time limit for each citizen; this
avoids lengthy presentations which could generate
impatience and disrupt the meeting. Meetings may last from
an hour to no more than three hours. . .
BENEFITS Public meetings provide the public with an opportunity to
express their concerns to EPA, state, or local government
officials. Meetings also provide an opportunity for EPA
and the state to present information and a proposed course
of action. Public meetings also provide one setting for
the resolution of differences between the government and
the community.
LIMITATIONS Public meetings may not be the best way to obtain citizen
input. If controversy surrounding the site has escalated,
a public meeting could provide an opportunity to intensify
conflicts rather than resolve them. Evaluate the
possibility of a public meeting getting out of hand by
reviewing the site's history and level of citizen
involvement in this and similar controversies. In
addition, if citizens in the area view public meetings as
distractions from the issues or if public meetings have
been failures in the past, then use an alternative method,
such as small public consultations, to transmit information
and obtain feedback. Or, schedule a public hearing that is
highly structured.
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4-30
17. WORKSHOPS
ACTIVITY
PURPOSE
TECHNIQUE
Formal seminars or a series of meetings that (1) promote
intensive discussion of hazardous substance issues and (2)
encourage citizens to provide comments on proposed response
actions. Experts may be invited to provide explanations of
the problems associated with releases of hazardous
substances. Speakers may also address possible remedies
for these problems.
To improve the public's understanding and to correct
misperceptions of the hazardous substance problem. To
enable EPA and state staff to identify citizen concerns and
to receive citizen comments.
Workshops must be conducted in a manner that does not
agitate the public or create unnecessary fears. Workshops
are in part meant to educate citizens, allowing them to
become aware of the difficulties in handling release
problems and enabling them to understand the problems.
Planning the workshop. Make sure an adequate number of
participants in the workshop are available. If there are
too few, consider holding an informal meeting for those
concerned and postpone the workshop until additional
interest develops. Decide ahead of time on a minimum and
maximum number of workshop participants.
Announce the workshop well in advance (at least two weeks)
of its scheduled date. Send out invitations and
registration forms to concerned citizens. Provide for
multiple registrations on each form to accommodate friends
who might also be interested in the workshop. Emphasize
that there is a limit on the number of persons who can
participate in the workshop, and provide a deadline for
registration. If the budget permits, announce the workshop
in the local newspapers and distribute posters around town.
Cover the following topics:
• Nature of release problems
• Methods of containing and cleaning up release
• Identification of health or environmental problems
• Citizen comments on the technical response that is
proposed or under way
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4-31
17. WORKSHOPS (continued)
BENEFITS Workshops provide more information to the public than is
possible through fact sheets. They also allow for two-way
communication between the public and the persons who are
running the workshops, thereby answering many of the
citizens' concerns and questions. For this reason,
workshops are particularly good for reaching opinion
leaders, interest group leaders, and the most affected
public.
LIMITATIONS Workshops reach only a small segment of the population
unless a number of them take place.
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18. INFORMATION REPOSITORY/PROJECT FILE
ACTIVITY A locally-established project file or repository containing
site information and documents on site activities.
PURPOSE To allow free and convenient public access to information
on the nature of site problems and response activities. An
information repository is a central project file where
citizens can review all site-related documents approved by
EPA or the state for public disclosure;
TECHNIQUE Determine a location early in the response action, as
warranted. Depending upon the level of citizen interest in
activities at the site, establishing a local repository may
be an effective way to communicate information to the
community. Typical locations for the file might be the
local public library, town hall, or health office.
Select and deposit the materials to be included in the
file. Typically, a project file may include:
• News releases and clippings about the site;
• Site descriptions;
• Technical data concerning the hazards posed by the
release and the response actions (e.g., remedial
investigation reports and feasibility studies);
• Non-technical descriptions of the site problems and
the response actions;
• Any reference materials relevant to the site (e.g.,
maps, chemical references, etc.);
• Announcements of all community relations activities;
• A list of contact personnel, with addresses and
telephone numbers, from whom further information can
be requested.
Publicize the existence of the repository. Notify local
government officials, citizen groups, and the local media
of the project file's location and hours of public access.
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4-33
18. LOCAL REPOSITORY/PROJECT FILE (continued)
TECHNIQUE Make sure the file is kept up-to-date. Timely replacement
of dated information helps avoid unnecessary
misunderstandings.
BENEFITS An information repository provides local officials,
citizens, and the media with easy access to accurate,
detailed, and current background data about the site. It
demonstrates that officials are responsive to citizens'
needs for comprehensive site information.
LIMITATIONS A project file requires diligent maintenance to avoid
misunderstandings based on dated information. Also, there
is always a risk that information contained in the file may
be used out of context..
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CHAPTER 5
ADMINISTERING A COMMUNITY RELATIONS PROGRAM
Chapters 2 through 4 describe techniques community relations staff can use
to develop an effective community relations program for removal' and .remedial
actions. This chapter provides guidelines on program administrative
requirements for planning, reporting, and personnel. It first examines the
development, contents, and format for a community relations plan (CRP) -- the
key program planning, management, and budget tool. It then describes the
requirement to submit program status reports to EPA Headquarters. Finally, it
explains the division of responsibility for community relations between
Headquarters and EPA Regional Offices, and discusses how to use contractor
support appropriately. The guidelines on developing CRPs apply.either to EPA
staff or state agencies taking the lead on Superfund community relations
activities.
A. PROGRAM PLANNING :
This section describes EPA requirements for the development of CRPs.
Staff responsible for developing community relations programs .should consult
Appendix A to review suggested formats for community relations planning
documents. ; .
1. Development of a Community Relations Plan
The CRP is the planning, management, and budget document that guides
the community relations program at Superfund sites. CRPs must be developed
for all Superfund planned removal and remedial actions. In addition, a
profile of community concerns and a short version plan must be developed for
certain kinds of immediate removal actions. Specific planning requirements
for each type of Superfund action are described below.. •
1.1 Immediate Removals
Chapter 2 describes a two-step planning process for immediate removal
community relations programs: • . ••...;••'
• A community relations profile must be prepared for
immediate removal actions that last longer than 5
days. It must contain a brief analysis of the nature
of citizen concern, the key site issues, and program
objectives. The profile should explain how community
relations staff intend to plan for and implement
community relations activities at the site.. It must
be submitted with the Immediate Removal Request (the
"10 Point Document"). .
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5-2
• A brief CRP that describes the site background, the
nature of community concern, the key site issues,
site-specific community relations objectives, and
activities to be undertaken at the site must be
prepared for any immediate removal that may last
longer than 45 days.
See Appendix A for suggested formats for the immediate removal community
relations profile and plan.
1.2 Planned Removals
Planned removal actions usually allow more time than immediate
removals for planning and consultations with the local community. The draft
Action Memorandum requesting approval for a planned removal must state that a
CRP has been prepared and should briefly summarize citizen concerns. A CRP
covering the entire planned removal action must be prepared along with the
"14 Point Contractual Document". The required elements of a CRP for a
planned removal action are identical to the required elements for a remedial
action. These are explained below, and are discussed further in Appendix A.
1.3 Remedial Actions
As explained in Chapter 3, CRPs must be developed for all Superfund
remedial actions, and must be revised throughout the response action to
reflect changing needs of the community and alterations in the technical
schedule.
The draft CRP must be submitted with the draft Action Memorandum for
federal-lead sites or with the draft cooperative agreement for state-lead
sites. It must include:
• The background and history of community involvement
(site history, local activity and interest, and key
community issues);
• A list of affected and interested groups and
individuals, their affiliations, addresses, and
telephone numbers;
• Site-specific objectives for the community relations
program;
• A schedule for completion of the CRP; and
• A description of any immediate community relations
activities recommended prior to submission of the
complete CRP.
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5-3
The complete CRP for the site must be prepared either I) within four
weeks of the submission of the draft Action Memorandum or prior to the
initiation of the remedial investigation, whichever comes first for
federal-lead sites; or 2) with the final cooperative agreement package for
state-lead sites. The complete CRP includes:
• The information presented in the draft CRP, updated
if necessary.
• A list of communications activities to be conducted
at the site, an explanation of how these activities
will be conducted, and a description of how these
activities relate to the technical response schedule.
• A budget, schedule, and workplan.
• A list of technical and community relations staff
responsible for site work.
The plan should clearly identify the roles and responsibilities of all
federal agencies that may be involved in the response action (e.g., the
Federal Emergency Management Agency or the Army Corps of Engineers). There
should be a provision for coordinating the activities of different federal, as
well as state and local, agencies. The division of responsibility among
various federal agencies for community relations during Superfund response
actions is outlined in interagency agreements or memoranda of understanding.
The complete plan must specify that the community will have an opportunity
to comment on the feasibility study prior to the selection of site remedy, and
must describe how community relations staff will implement the required
comment periods for nonexpedited and expedited remedial actions. (See the
comment period discussion on pp. 3-8 and 3-9 of this handbook.) The plan must
be sufficiently flexible to permit an extension of the review period where an
extension is warranted. At sites where there is significant public interest,
the plan should also provide for monthly fact sheets or progress reports on
technical and community relations work. In all cases, the plan should provide
that the community must receive advance notification of any action at the site.
EPA or state staff should revise the plan any time a major change takes
place in the community's needs for information or in the technical schedule.
The CRP, however, must be revised when the feasibility study is completed to
incorporate communications activities planned for the design and construction
phases of the action. The budget, schedule, and workplan should be revised at
this point as necessary. The revised CRP should be submitted two weeks after
the submission of the draft Record of Decision for federal-lead sites or with
the draft amended cooperative agreement application for state-lead sites.
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5-4
2. Plan Review Requirements
At the time this handbook was prepared, EPA Headquarters was revising
plan review requirements to reflect Headquarters and Regional Office
responsibilities under new delegations of authority. Community relations
staff should, therefore, consult the memorandum accompanying this handbook and
any later guidance on plan review requirements for detailed information on the
review and approval of CRPs and other program documents.
B. QUARTERLY STATUS REPORTS ON COMMUNITY RELATIONS
Each EPA Region is required to submit to Headquarters quarterly
reports on Superfund community relations activities. The reports should be
sent to the community relations coordinator in the Office of Policy and
Program Management, Office of Emergency and Remedial Response. It is
recommended that the responsibility for preparing these reports be assigned to
the Regional Superfund community relations coordinator. Quarterly reports are
due on December 31, March 31, June 30, and September 30. Guidance on the
preparation of quarterly reports and, the quarterly report format are contained
in Appendix C.
C. EPA COMMUNITY RELATIONS PERSONNEL
1. The Role of Headquarters and the Regions in Implementing Community
Relations Programs
EPA Headquarters and Regional Office staff have specific
responsibilities for the implementation of a community relations program at a
site.
Headquarters is responsible for policy development, tracking
Superfund community relations activities through quarterly status reports,
developing training programs, oversight of community relations implementation,
program evaluation, and resource analysis. Headquarters provides
informational materials on the Superfund program, expert personnel for
temporary community relations work at critical sites, overall contract
management, and other support services required in the field.
For EPA-lead responses, the Regions take the lead on developing
community relations plans and programs, developing site-specific public
information materials, supervising (through superfund project officers)
Regional Office community relations subcontractors, and implementing community
relations programs.
2. Contractor Role
Technical contractors (such as architectural and engineering firms)
can provide support services for Headquarters and Regional Office community
relations program activities in a number of situations. One principle must
be maintained throughout the program: contractors must never represent, or
even appear to represent, EPA before the public, other government officials,
or the media.
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5-5
3. Appropriate Tasks for Contractors
The community relations programs at individual sites will include
many activities for which it is appropriate to make use of contractor staff.
Some activities will be routine; others will involve behind-the-scenes
preparation; still others may require special expertise. Contractors are
especially useful for ensuring that technical information is accurate and
comprehensible.
Exhibit 5-1 illustrates the appropriate responsibilities of
contractor staff for a number of standard community relations activities. The
amount of contractor assistance asked for, and the division of responsibility
between EPA and contractor staff, will vary from site to site. The
preparation and distribution of any written materials, as well as all
appearances before the news media, must conform to EPA policy on such matters.
Technical contracting firms and their employees may be inexperienced
in assisting with community relations activities. The following section
discusses the capabilities that contractor staff assigned to community
relations should possess, and suggests how to evaluate contractors'
performance in this area.
4. Evaluating Contractors
a. Staff Qualifications
The most important contractor qualification is a clear understanding
of the specific communications and technical problems at a site. Without such
an understanding, it is difficult to speak straightforwardly and informatively
to interested citizens and officials, as a good community relations program
requires. Because the community relations program is a two-way communications
program, one-way public relations skills are not,sufficient. Instead, the
following qualifications should be looked for in the contractor staff assigned
to community relations activities:
• Strong interpersonal skills: the ability to listen
well, to speak clearly, to know how to answer a
question in a way that will not frustrate or anger
someone very concerned about a sensitive issue.
• The demonstrated ability to write clearly and to
distill detailed information into a form suitable for
a news release or a fact sheet.
• The willingness and ability to learn the technical
complexities of a site's geohydrology, the
engineering measures conducted in response, and the
potential effects of the substances at the site on
human health.
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5-6
• Knowledge of the kinds of measures that will be
used to keep a community informed of plans for and
progress at a site: interviews, informal
consultations, public meetings, news briefings,
audio-visual aids, workshops, responsiveness summaries.
• Proof of administrative competence: the ability to
organize a large meeting down to the last detail to
carry out assigned tasks punctually, to produce
written materials that are clear and neat.
• Demonstrated capacity to account for and control
expenditures.
Furthermore, the qualifications of contractor staff should be matched to the
tasks to which they are assigned. There is no need, for example, to have a
senior staff member arrange a meeting.
b. Evaluation
The community relations assistance provided by contractors may be
evaluated by means of the written reports required by the program, spot checks
with various sources, and the project officer's ongoing assessment of overall
performance. To supplement written reports as a basis for evaluation,
Headquarters or the Regional Offices may sample the techniques used by
contractors for their quality and effectiveness. For instance, the research
performed for a fact sheet or exhibit can be evaluated for clarity, factual
content, and style. Local newspaper accounts can be used for independent
assessments of the effectiveness of the community relations activities
recommended or assisted by the contractor. In addition, citizen leaders can
be contacted to determine what the local community thinks of the contractor's
efforts. Not all of these techniques are necessary, but some form of
confirmation besides contractor reports and Regional Office evaluations will
be useful in many cases.
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EXHIBIT 5-1
SAMPLE TASKS FOR CONTRACTORS IN A COMMUNITY RELATIONS PROGRAM*
Ac t i v i t.V
Contractor Responsibilities
EPA or State Responsibilities
Community information
i nterviews
Community relations plan
Telephone contacts
News releases
Public consultations
Fact sheets
Briefings and news
conferences
Workshops on hazardous
waste
Formal public meeting
or pub Iic hea ri ng
Pub lie i nqu i ry
responses
Graph ics
Conduct interviews, analyze socio-
political environment, prepare
report on site history and actors,
brief EPA
Develop and draft plan
Make follow-up calls, set interview
dates, develop community mailing
I ist
Research text of releases
Arrange small meeting with citizens
and EPA staff, prepare agenda
Research fact sheet; reproduce and
distribute sheets
Arrange time and location; brief
EPA staff on how to answer diffi-
cult questions, etc; arrange any
written handouts
Design and conduct workshops in
interested communities; arrange all
logistics and support
Arrange time and location, prepare
public notice, advise and prepare
EPA speakers, prepare agenda and any
support materials (including audio-
vi suaIs)
Prepare routine responses for EPA
approval, aid in researching more
involved responses
Prepare graphics for presentations or
briefi ngs
Clear up any questions by inter-
viewees, attend briefing
Review and approve plan
Make initial calls to all elected,
appointed, and citizen leaders
Draft, edit, and release
Meet with citizens and answer
quest ions
Draft, edit and approve fact
sheet
Invite officials or reporters,
practice answers with contractor
staff, edit and approve handouts,
prepare opening statement, answer
all questions (contractors do not
pa rt i c i pa te )
Make available technical staff to
discuss testing techniques, alterna-
tive solutions, etc. for workshop
Conduct hearing. Discuss site
problems and progress, roles of
EPA, state, other agencies, etc.;
answer questions
Read all letters, divide into
routine and involved answers, write
involved answers; handle all phone
inquiries; approve all responses
Review and approve all graphics
*The EPA Regional Office or the state response agency directs all contractor work. The support
activities listed on this exhibit are performed at the discretion of the staff with responsibility for
community relations program.
the
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EXHIBIT 5-1 (continued)
POSSIBLE.TASKS FOR CONTRACTORS IN A COMMUNITY RELATIONS PROGRAM*
Activity .Contractor ResponsibiIities EPA or State Responsibilities
Exhibits . Prepare exhibits . General design-and approva'l
-Presentations Coach EPA speakers, provide audio- Design and -deliver presentations
vi suaI support
Media appearances Brief EPA speakers Prepare substantive answers, prac-
tice form and style with contractor
•Site tours Arrange time and meeting place, con- Act as tour guide, answer questions
tact tour participants, arrange
protective gear, provide handouts
(maps, test results, fact sheets,
etc.)
Concluding report Assemble information, prepare report Review, revise, and approve
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CHAPTER 6
COMMUNITY RELATIONS AND ENFORCEMENT ACTIONS
(Reserved)
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APPENDIX A
COMMUNITY RELATIONS PLANNING DOCUMENTS
INTRODUCTION
To encourage the design and implementation of effective community
relations programs at Superfund sites, community relations planning begins
early in the response action and is generally completed before site work is
initiated. This appendix describes how to prepare the community relations
documents that are an integral part of the Superfund program: the community
relations profile (immediate removals); and the community relations plan
(immediate removals, planned removals, and remedial actions).
Chapters 2 and 3 of the handbook generally discuss these documents and
suggest activities that might be included in community relations plans
(CRPs). Chapter 5 explains EPA planning requirements in greater detail. The
sample formats and plans that are presented below should further help EPA and
state community relations staff to determine the scope and contents of these
planning documents.
A. THE COMMUNITY RELATIONS PROFILE
The community relations profile -- a short form CRP -- must be prepared
for any immediate removal action that lasts longer than 5 days. It must be
submitted with the Immediate Removal Request (the "10 Point Document") and can
later be incorporated into any immediate removal CRP. To ensure that the
profile briefly explains how EPA intends to plan for and implement community
relations activities at the site, community relations staff should use the
profile format presented in Exhibit A-l. In preparing the profile, staff
should answer the relevant questions listed in Exhibit A-2.
B. THE COMMUNITY RELATIONS PLAN
Community relations plans must be prepared for all Superfund-financed
immediate removals lasting longer than 45 days and for all planned removal and
remedial actions.
As described in Chapter 5, CRP requirements differ slightly, depending
upon the nature of the response action. For example, as soon as it is evident
that a removal action may last longer than 45 days, an immediate removal CRP
must be prepared for the site. This CRP is less detailed than the CRP
prepared for planned removal and remedial actions and is not necessarily based
upon on-site discussions.
While the structure and contents of CRPs for planned removals and remedial
actions are similar, the development process differs. A CRP covering the
entire planned removal action must be submitted along with the "14 Point
Contractual Document." For remedial actions, draft CRPs must be submitted
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A-2
with the draft Action Memorandum for federal-lead sites and with the draft
cooperative agreement for state-lead sites. A complete CRP must be
submitted: (1) for federal-lead sites, within four weeks of the submission of
the draft Action Memorandum or prior to the initiation of the remedial
investigation, whichever comes first; and (2) for state-lead sites, with the
final cooperative agreement package. Plans must be revised prior to the
initiation of site design and construction. The revised CRP should be
submitted two weeks after the submission of the draft Record of Decision for
federal-lead sites and with the draft amended cooperative agreement
application for state-lead sites. Both the planned removal CRP and the
remedial action CRP must be based upon an assessment of community concern
developed after an on-site discussion.
The following sections suggest preferred ways to structure CRPs for
immediate removals, planned removals, and remedial actions. A format for the
immediate removal CRP and sample CRPs for planned removals and remedial
actions are included.
1. CRPs for Immediate Removals
CRPs for immediate removals should include a succinct discussion of
the site background, the nature of community concern, the key site issues,
site-specific communications objectives, and activities to be undertaken at
the site that are tied to the technical response schedule. Staff may
incorporate the community relations profile into the plan as the background
discussion and explanation of program objectives. There is no suggested
length for immediate removal CRPs. As long as they clearly detail the program
planned for the site, they may be brief.
In many cases it will not be feasible to conduct on-site discussions
prior to preparing the immediate removal CRP. Community relations staff are
encouraged, however, to conduct these discussions prior to preparing the plan
whenever possible.
See Exhibit A-3 for a suggested format for immediate removal CRPs.
2. CRPs for Planned Removals and Remedial Actions
CRPs for planned removals and remedial actions must integrate
community relations activities with technical milestones. Activities
specified in these plans provide the community with vehicles for commenting on
and providing input to technical decisions. The plans are written commitments
to citizen participation on the part of EPA and the state.
Whether the plan is for a removal or remedial action, it must be
designed to respond to the needs and concerns of the interested groups in the
site community. These groups may differ in their values, favored response
action, and intensity of concern. The communications techniques for providing
information to these groups should be modified for the different audiences.
For instance, the level of technical detail in a presentation to a group of
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A-3
engineering or science teachers would be very different from a presentation to
a taxpayers organization. The local groups (to be identified in the community
information interviews and/or telephone contacts) may include:
• Neighbors of the site; •"•
• Local elected officials, political candidates,
county or municipal boards, county health departments;
• Federal or state representatives and their staffs;
• Groups organized around the issues of the site;
• Existing civic groups: League of Women Voters,
Kiwanis Club service clubs, church groups, taxpayer
groups, farm organizations, senior citizen groups,
minority groups;
• Local business groups,,Chamber of Commerce; real
estate groups;
• Environmental groups, Audubon Society, Sierra Club;
• Health organizations, local American Cancer Society
chapter;
• Officials or interest groups from nearby communities;
• Local industries and business;
• Labor unions; and
• Newspaper, radio, and television reporters, editors,
talk show hosts.
Once the interested groups in a community and their concerns about the site
are identified through on-site discussions and/or telephone contacts, the plan
can be drafted.
The CRP includes the following elements that detail the community
relations program at the site:
• Background and history of community involvement at the site:
Site history
Community involvement
• Key issues;
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A-4
• Specific objectives of the community relations program;
• Communications techniques to be used to meet specific
objectives, including progress reports on past site work and
reports on upcoming activities;
• Workplan and schedule that are tied to the technical response
workplan and schedule;'''
•
• Budget and staffing plan;*
• Appendix that lists affected and interested groups,
individuals, and contractors, their affiliations, addresses, and
telephone numbers;
• List of EPA, other federal agency, and state technical and
community relations officials responsible for the site.
These elements are described in more detail below.
The opening paragraph of the CRP identifies the location of the
release, the lead agency in the Superfund cleanup and in the community
relations program, and the period of time covered by the plan.
The background and history section begins with a brief site history
and information on cleanup plans, as well as an enforcement profile, if it is
likely to alter the technical schedule. This section also describes the
history of community involvement, including descriptions of interested groups,
their activities, past public meetings, and other inquiries or displays of
concern. The section concludes by summarizing the main public concerns and
key issues that may affect the conduct of the cleanup. Concerns and issues
likely to be raised in the future, as well as those raised in the past, are
included.
The second major section of the CRP enumerates the specific
objectives of the Superfund community relations program at the site. All
Superfund community relations programs have two major goals:
•'•For remedial actions, a detailed workplan, schedule, budget, and staffing plan
need not be completed when the draft CRP is submitted as part of the
draft Action Memorandum or the draft cooperative agreement. However, this
detail must be added to the complete CRP. See Exhibit 4 for a suggested
format for a draft CRP for remedial actions.
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A-5
• Provide accurate, timely information about the response to the
community; and
• Allow citizens to express their concerns to EPA and the state.
The purpose of this section of the CRP is to list specific objectives tailored
to the technical response timing and the level of citizen concern at the
site. Included in these objectives are the specific points that EPA and the
state want to communicate to the community at certain points in the technical
response, and the specific decisions on which local input is essential.
The community relations techniques section lists the communications
activities to be conducted in each phase of the response and specific
objectives. The section should explain how the community relations
activities selected for the site are tied to the technical response workplan
and schedule. The types of techniques that can be used in Superfund
community relations programs are described in Chapter 4, but other techniques
may be used as well, particularly activities that fit into ongoing local
arrangements. As noted in Chapter 5, the CRP must specify that the community
will have an opportunity to comment on the feasibility study prior to the
selection of a site remedy. This section of the CRP must specify how a three
week comment period will be implemented for nonexpedited remedial actions.
For any initial remedial measures (IRMs), the plan must also (1) address how
the community will receive prior notification of any site action and (2) state
that a minimum two week comment period will be provided for any complex IRM
recommended by a limited feasibility study. It should note that if there is a
reasonable request for a comment period extension (e.g., because of delays in
providing documents to citizens), community relations staff should extend the
review period, as long as the delay does not exacerbate any threat to public
health, welfare, or the environment.
This section should also detail how staff will keep citizens informed
of past site activities and upcoming events on a regular basis. Where there
is significant public interest, CRPs should provide for monthly fact sheets or
progress reports on technical and community relations work. There should be
provision for coordinating the community relations responsibilities of the
federal, state, and local agencies, in addition to EPA, involved in the
response.
The last two sections, the workplan and schedule, and the budget and
staffing plan, consist of charts. The workplan and schedule display
technical milestones and community relations activities along a time line.
The time line may be altered over the course of the Superfund response because
most activities will correspond to technical milestones, not dates. The
community relations activities should include a period for lead time to draft,
circulate, review, and approve written materials and activity plans before the
date of the activity. The budget and staffing plan details the EPA, other
federal, and state agency staff responsible for each community relations
activity. The staffing list should differentiate preparatory staff -- those
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A-6
who draft materials and arrange appointments and meeting space -- from primary
staff responsibilities, such as making a presentation, editing and approving a
fact sheet, or running a workshop. The work hours for each person responsible
for an aspect of an activity are included, along with any travel costs,
material costs, or contractor costs, for each activity.
Finally, an appendix of public officials, interested groups and
individuals, contractors, and EPA, federal, or state staff responsible for
the site is a standard part of a CRP. Names of persons contacted during the
community information interviews, as well as others referred to in the
conversations, are listed with their affiliations, if any, addresses and
telephone numbers. The appendix may be arranged under the headings of
federal, state, and local officials and local groups.
To aid their understanding of how to develop CRPs, community
relations staff should review the following samples of CRPs that have been
approved by Headquarters: the CRP for Skiljan Residence (a planned removal
action); and the CRP for the Imperial Sites, Imperial Missouri (remedial
action). These plans were developed after site visits and community
interviews, but do not necessarily reflect programs implemented at the sites.
They are presented only as examples of the preferred CRP format.
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A-7
EXHIBIT A-1
SUGGESTED FORMAT -- COMMUNITY RELATIONS PROFILE
FOR IMMEDIATE REMOVALS
DATE PROFILE PREPARED:
A. BACKGROUND
1. Release information
Date and location of release and substances released:
Nature of the threat to public health, welfare, and the environment:
Response actions, if any, taken to date:
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A-8
2. Key community concerns and issues
Concerns and issues identified by local officials and citizens
Brief evaluation of the level of citizen concern:
Identification of interested local officials, citizens, and groups,
their affiliation, addresses, and phone numbers:
Brief description of any media coverage; dates of media coverage;
identification of media contacts:
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A-9
Brief description of any actions taken by community members, or any
meetings that have already been held by EPA or the state, elected
officials, or citizens:
B. OBJECTIVES OF THE COMMUNITY RELATIONS PROGRAM
List of specific objectives for the site and why these are selected:
Brief description of activities considered for the site (staff's
preliminary view of what would constitute an effective program for
the site) and how these activities would be tied into the technical
response:
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A-10
EXHIBIT A-2
BACKGROUND INFORMATION FOR PREPARING
COMMUNITY RELATIONS PROFILES
A. BACKGROUND
1. Background of the Release
What is the location of the release; how was it identified?
What caused the release of hazardous substances?
What hazardous substances have been identified or are suspected to be
present?
What is the nature of the threat posed by the release? threats to human
health? the environment?
What immediate action is planned?
What actions have already been taken?
Are there restrictions on response actions imposed by local ordinances?
By enforcement concerns?
Who is the responsible party? If none has been identified, what is the
status of efforts to locate a responsible party?
2. Key Community Concerns and Issues
What are the primary concerns of the community? Effects of the release on
personal/family health? Contamination of water supplies? Market
value of homes or damage to property? Adverse impact on local
businesses?
What are the concerns of individual citizens or groups?
3. History of Community Involvement
How have citizens viewed any EPA or state communications activities that
have already taken place?
What coverage has been given by the media?
B. OBJECTIVES OF THE COMMUNITY RELATIONS PROGRAM
1. Specific Objectives
What are the program's specific objectives? To provide the community
with accurate, understandable information? To prepare the community
for further action?
2. Planned Activities
What activities are planned for providing the community with
information on a regular basis? For eliciting community needs and
concerns?
Who is responsible for preparing the CRP and when will it be completed?
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A-ll
EXHIBIT A-3
SUGGESTED FORMAT -- COMMUNITY RELATIONS PLANS
FOR IMMEDIATE REMOVALS
DATE PLAN PREPARED:
A. BACKGROUND OF RELEASE
1. Date of release and substances released
2. Nature of the threat to public health, welfare, and the environment
3. Response actions, if any, taken to date
B. KEY COMMUNITY CONCERNS AND ISSUES
/
1. Concerns and issues identified by local officials and citizens
2. Identification of interested local officials, citizens, and groups,
their affiliation, addresses, and phone numbers
3. Brief description of any media coverage; media coverage date;
identification of media contacts:
4. Description of actions taken by the community
C. OBJECTIVES FOR THE COMMUNITY RELATIONS PROGRAM
1. List of specific program objectives (e.g., to provide accurate,
understandable information, to prepare the community for further
action, to allay community concerns)
2. Explanation of why objectives have been selected (e.g., their targets,
their relationship to the response action)
D. COMMUNITY RELATIONS ACTIVITIES
1. List of communication activities to be performed at the site;
description of how they relate to program objectives; explanation of
how community relations activities relate to the technical response
schedule
2. Brief schedule of activities (specify date, activity, objective,
staff, workhours)
E. STAFF
1. List of staff responsible for program implementation and their
assignments
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A-12
EXHIBIT A-4
SUGGESTED FORMAT -- DRAFT COMMUNITY RELATIONS PLAN
DATE PLAN PREPARED:
A. SITE BACKGROUND
1. Date of release and substances released
2. Nature of the threat to public health, welfare, and the environment
3. Response actions, if any, taken to date
4. Enforcement status
B. HISTORY OF COMMUNITY INVOLVEMENT
1. Descriptions of any past or ongoing community activities at the site
2. Concerns and issues identified by local officials and citizens
3. Brief evaluation of the level of citizen concern
4. Identification of interested local officials, citizens, and groups,
their affiliations, addresses, and phone numbers
5. Brief description of any media coverage, dates of media coverage, and
media contacts
6. Descriptions of any other inquiries or displays of concern
C. SITE-SPECIFIC COMMUNITY RELATIONS OBJECTIVES
1. List of specific objectives for the site and why these are selected
2. Brief description of activities considered for the site (staff's
preliminary view of what would constitute an effective program for
the site), and how these activities relate to the technical response
schedule
D. IMMEDIATE COMMUNITY RELATIONS ACTIVITIES
Brief description of activities (if any) recommended prior to CRP
approval
E. SCHEDULE FOR CRP COMPLETION
Brief list of dates and staff responsibilities
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A-13
COMMUNITY RELATIONS PLAN SAMPLE CRP
Skiljan Residence/Dial Services Manufacturing Company
Clevelana, Onio
This comrounity relations plan outlines activities to be conducted during a
Superfund planned removal action at the Skiljan residence and the Dial Services
Manufacturing Company, both being located in Cleveland, Ohio. Subject to
finalization of the cooperative agreement between Ohio EPA and U.S. EPA, the Ohio
Department of Health will have the lead responsibility working in close
cooperation with U.S. EPA, Region V and Ohio EPA. This community relations plan
can be updated and revised in response to events affecting the progress of the
planned removal and/or citizens needs or concerns.
A. BACKGROUND AND KEY ISSUES
1. Site History
a. Skiljan residence
18028 Nottinghan Road
Cleveland, Ohio
On April 30, 1982, Mr. Eugene Skiljan discovered, in the course of
demolishing a barbeque pit in his backyard, several hundred vials
labeled "U.S. Radium" and "poison". Investigation by the Ohio
Department of Health (ODH) Radiological Health Program, led to
identification of the vials as spent containers possibly from Dial
Services Manufacturing, a radium dial painting company founded by the
former owner of Mr. Skiljan's residence, Mr. Walter Issel. Subsequent
surveying identified several regions of radioactivity in the backyard
and on an adjoining property, seepage off the property showing
elevated radium-226 in the water and contamination in the basement of
the home.
During the week of May 25-28, the Center for Applied Isotope Studies
(CAIS) at the University of Georgia surveyed the property more fully
for the State of Ohio and identified, in addition to the barbeque pit,
nine areas requiring excavation to remove radium-226 contaminated
soils.
b. Dial Services Manufacturing Company
1741 Rockwell Avenue
Cleveland, Ohio
Subsequent to the discovery of radium contamination on the Skiljan
property, an investigation was conducted by the ODH, Radiological
Health Program, of the building in downtown Cleveland, Ohio, where
Dial Services Manufacturing formerly painted radium dials. The firm
still exists but no longer utilizes radioactive materials. Less than
a dozen employees are engaged to teflon coat small parts. The
radioactive survey established that gamma and beta radiation levels
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A-14 SAMPIE CTP
were several times background throughout the building and that alpha
contamination, fixed to surfaces and furniture, was extensive.
Contaminated metal springs were found buried in the soil.. It was
learned that a fire occurred in the radium dial painting operation,
possibly about 1945, and that the building was rebuilt on the same
site.
2. • History of Community Concerns
a. Skiljan residence
Mr. and Mrs. Skiljan are the ones most affected by the contamination
and are, of course, extremely concerned. Although there have been no
organized groups formed, the local people are very aware of this site
due to extensive media coverage and actions by Mr. and Mrs. Skiljan.
The Skiljans erected a sign in their front yard identifying their home
as the contaminated site and requesting help in getting it cleaned
up. They also, very successfully, circulated petitions for signatures
at a local street fair. They obtained approximately 5000 signatures
backing them in their efforts. The two immediate neighbors,
especially the family to the south are very upset. This property to
the south has contaminated soil. The removal of this soil is provided
for in the scope of work.
b. Dial Services Manufacturing Company
The-operators of the Dial Services Manufacturing Company are concerned
with present worker safety, bad publicity hurting their business and
disruption of their business during clean up.
One business, Universal Pictures, located a block from Dial Services
Manufacturing has expressed some concern about radiation
contamination. Staff from ODH and the Cleveland City Dept. of Public
Health and Welfare met with the employees and assured them that their
building was sufficiently far way from the contaminated area.
Personnel from City Shelters of Cleveland, on the east side of Dial
Services Manufacturing, have expressed concern, also. The building has
been checked and levels of contamination were found to be within
acceptable levels.
c. Health concerns
The Ohio Department of Health is concerned about former employees of
Mr. Issel and Dial Services Manufacturing Company and immediate
members of Mr. Issel's family. Appeals were made via the media for
information on former employees with very little success.
Information, including a form rquesting voluntary bioassays, has been
delivered to surrounding homes and current employees. Ninty requests
for the bioassay test have been received.
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A-15 SAMPI£ CFP
B. OBJECTIVES OF THE COMMUNITY RELATIONS PLAN
The objectives of the community relations program are:
1. To keep Dial Services Manufacturing, the Skiljans and immediate property
owners apprised of the plan and time table for clean up.
2. To insure that citv officials especially interested in the sites be
informed of plans, progress and any problems which may develop.
3. To keep interested state and Congressional legislators and state officials
informed of plans and progress.
4. To insure that accurate information is disseminated to the media.
C. COMMUNITY RELATIONS TECHNIQUES
The following techniques are suggested to meet the objectives of this
coTjnunity relations plan:
Objective Technique
1. Meetings with Dial Services Mfg., To keep them informed of plans
the Skiljans and immediate and progress. These can be
property owners. one to one meetings rather
than group meetings. As clean
up starts, these will likely
be on a day to day basis.
2. Meetings with city officials. To inform interested city
officials of the plans and
progress. These should
include meetings as
preliminary plans are made,
when the schedule is set, as
any problems develop and when
work is completed. '
3. Briefings for state and To keep these interested
Congressional legislators and state individuals informed of
officials. progress. These briefings can
be oral or written.
4. Media conference. To provide all concerned media
with accurate information, an
opportunity to tour the sites
and question the contractor,
state officials and city
officials.
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A-16
5. Press releases and fact sheets,
6. Concluding report,
D. WORKPLAN AND SCHEDULE
SAMPLE CRP
To provide for community wide
dissemination of information
regarding the progress and
completion of clean up. This
can be part of rthe media
conferences unless there is
sufficient reason to provide
additional information.
To provide a record of public
involvement and instances of
contact between ODH, OEPA and
citizens or officials.
October November December
XXX
(weekly or daily as required)
Meeting with city officials
Meeting with Dial Services,
Skiljans, property owners
Briefings for state and X
Congressional legislators
Media conferences X
Site tours X
Media releases X
Concluding report
E. BUDGET AND STAFFING PLAN FOR COMMUNITY RELATIONS PLAN
Activity
Meeting with city officials
Meetings with Dial Services,
Ski 1jans, property owners
Briefings for state and
Congressional legislators
Media conference
Staff Responsibility
Bob Quill in (ODH)
Ben Wilmoth (ODH)
Lorey Roggenkamp (OEPA)
Bob Quill in (ODH)
Ben Wilmoth (ODH)
Lorey Roggenkamp (OEPA)
Bob Quill in (ODH)
Ben Wilmoth (ODH)
Paul Massa (ODH)
Bob Quill in (ODH)
Bob Hardian (U.S.EPA)
Ken Meckstroth (ODH)
X
X
X
X
Work hours
12
12
3
20
20
3
5
5
20
15
5
-45
-------
Site tours
Media releases
Concluding report
F. OFflCIALS, CITIZENS, MEDIA
Local Officials
A-17
Paul Massa (ODH)
Bob Quill in (ODH)
Ken Meckstroth. (ODH)
Lorey Roggenkamp (OEPA)
SAMPLE CRP
3
3
10
10
Federal Officials
State Officials
Concerned Citizens and Property Owners
Medi a
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A- 18
COMMUNITY RELATIONS PLAN
FOR REMEDIAL ACTION
AT THE IMPERIAL SITES
IMPERIAL, MISSOURI
This Stage I community relations plan outlines the activi-
ties to be conducted during a Superfund remedial action at
the Imperial sites in Jefferson County, Missouri, U.S. EPA
Region VII has the lead responsibility for managing the re-
medial action, which consists of initial remedial measures,
a remedial investigation, and a feasibility study. This
plan was prepared in February 1983 and revised in June 1983.
I. BACKGROUND AND HISTORY
A. SITE HISTORY
Imperial, Missouri, a suburb of St. Louis, is an unin-
corporated town of about 6,000 middle-income families.
The dioxin sites located in Imperial are nestled in a
hilly, wooded area that is still being developed.
In February 1971, a salvage oil company owned by a
Mr. Russell Bliss began hauling dioxin wastes from the
now defunct Northeastern Pharmaceutical and Chemical
Company (NEPACCO) in Verona, Missouri. The type of
dioxin, scientifically named 2,3,7,8-tetrachlorodi-
benzo-p-dioxin (TCDD) , is an unwanted byproduct re-
sulting from the manufacture of trichlorophenol, which
was produced by NEPACCO as an intermediate in the manu-
facture of hexachlorophene.
The dioxin-contaminated wastes were mixed with waste
oils and used to spray at least three horse arenas for
weed and dust control. One of these arenas was at
Bubbling Springs Ranch in Jefferson County. It was
sprayed with contaminated oil in June and July 1971.
Early in 1972, two horses died, and l.ater in the year
four more died. At the time, the cause of death was
undetermined. As a precaution, however, 850 yards of
arena soil was excavated in March 1973.
The excavated soil from Bubbling Springs Ranch was used
as residential fill at the Minker residence and the
Stout site (named after the contractor who did the exc-
avation and who owned the property at the time) . Approxi-
mately 20 truckloads of the soil were used to fill a
steep ravine on the south end of the Minker house. The
property is located on a ridge at the head of the water-
shed, and the fill area has mostly washed out into
Romaine Creek. The Stout property is on the side of a
ridge, and the contaminated soil was used to level off
an area underneath two house trailers.
PD951.001
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A-19
EPA first sampled the Imperial sites where the con-
taminated material had been used for residential fill
in May 1982. On August 18, 1982, results from this
limited sampling confirmed dioxin contamination._ A
more comprehensive sampling effort was conducted in
October to determine the extent of contamination.
In November, results from the October sampling showed
no contamination above 1 ppb from the Country Club sub-
division. Five of the 53 samples taken at the Stout
property had positive results (above 1 ppb); these
ranged from 1.5 ppb to 22.2 ppb, the latter occurring
at a depth of 10 feet.
The highest levels of dioxin contamination in the area
were found in fill material at the Minker residence and
down the slope behind the house. Of the 95 samples, 40
had positive results. The highest concentration found
was 301 ppb.
In Romaine Creek, 78 of, the 151 samples showed positive
results. Concentrations of dioxin in sediments were
highest (272 ppb) where drainage from the Minker pro-
perty ..enters the creek. The concentration decreased to
about 90 ppb 800 feet downstream, 10 ppb 2,000 feet
downstream, and below 1 ppb 6,000 feet downstream.
Samples of dust from vacuum cleaner bags were collected
from five area houses. Dioxin contamination was found
only in the sample from the Minker residence, at 3.6 ppb.
Using these findings, risk assessments were prepared
and were evaluated by EPA, CDC, and the State of Mis-
souri. These three groups determined that six house-
holds with potential daily exposure through contact
with the soil should be relocated. These households
are identified in section I-C of this plan.
At the request of residents, additional sampling from
households adjacent to the six relocatees was conducted
in December 1982. Results are not yet available.
B. COMMUNITY RELATIONS HISTORY
The following community relations activities have been
conducted by EPA to date. Community issues, concerns,
and participants are discussed in sections C and D,
below.
May and June 1982; At the time of the first EPA sam-
pling, engineers made door-to-door visits to talk with
residents whose property was being sampled.
PD951.001
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A-20
October 6 and 7, 1982; EPA staff toured the area and
visited four households near the Minker site (staff
could not contact two other households near the site)
and one household near the Stout site.
October 6, 1982; A phone line to EPA was opened; from
October to the present, approximately 30 residents have
called EPA.
October 14, 1982; A public meeting was held at Mermac
Heights Elementary School. Approximately 150 households
in the vicinity of the sites were invited. About 175 per-
sons attended. There was heavy press coverage and
attendance by local and state officials. A fact sheet
was distributed.
November 5, 1982; Dioxin Update No. 1 (stating the
status of October sampling) was sent to approximately
150 households in the vicinity.
December 1, 1982; EPA and CDC made personal visits to
the six households identified for relocation. Dioxin
Update #2 was distributed door-to-door to approximately
150 families. This included October sampling results,
maps of the sites that were sampled, action options,
future plans, and notice of a public inquiry center.
December 8, 1982; A public inquiry center was opened
at a nearby hotel for 5 days, 9 a.m. to 9 p.m. A press
conference and news release presented the findings from
the October sampling.
January 20, 1983; A spokesman for concerned citizens
near the Minker site requested a meeting between resi-
dents and responsible officials. Forty-two citizens
attended, as well as representatives from EPA, CDC,
Missouri Division of Health, Missouri Department of
Natural Resources, and a State of Missouri attorney.
There was no press attendance. Remedial actions and
citizen concerns were discussed. Handouts included a
fact sheet, dioxin questions and answers, and a summary
sheet of proposed actions.
January 29, 1983; A public hearing was held at Jeffer-
son College in Hillsboro, called by Congressman Robert
Gephardt. This was a general meeting concerning pos-
sible dioxin sites throughout Missouri. Meeting par-
ticipants included: Regional and Headquarters EPA
officials; FEMA; CDC; Missouri DNR and Health Division;
State Senator Harriet Woods; State Representative Bob
Feigenbaum; Dr. Ellen Silbergeld (Environmental Defense
Fund); and representatives from the Minker site, Stout
PD951.001
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A-21
site, Country Club Manor, Times Beach, and Warren County.
Media coverage was heavy. Informational handouts were
distributed by EPA. The Coalition for the Environment
(see Section C below) also distributed its February
"Alert Newsletter."
C. KEY PARTICIPANTS
1. At the most general level, there are approximately
150 households in the vicinity of the sites. They
will be kept informed of major activities and find-
ings. Several families have voluntarily moved out
of the area because of their concerns.
2. Two primary organized groups have been identified.
Personal contact will be maintained with these
groups through their spokespersons.
a. Country Club Manor; Gail Hanks, spokeswoman.
About eight families, well-researched, ac-
tively involved. Chief concern is health
effects from possible runoff from the Stout
site. (See Section D for further discussion
of issues.)
b. West Rock Creek Hill; Mr. Abrahamson and
Mr. Webb, spokesmen. Dennis Lynch is also a
participant who attended the January 29 meet-
ing called by Congressman Gephardt. About
12 families are involved, and have expressed
concerns about health effects and economic
impacts (property values, medical bills).
3. Eight households nearest the Minker site have been
offered relocation:
a. Harold Minker household—two adults, one
child. They have temporarily relocated.
b. John Vickers household—two adults, three
children. This is the first household down-
slope from the fill area. They have been
temporarily relocated.
c. George McArthy household—two adults. They
are in direct line of fill area drainage,
immediately below the Vickers house.
d. Dennis Lynch household—two adults, two chil-
dren.
e. Doug Keane household—this is a rental
property that is currently vacant.
PD951.001
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A-22
f. James Haeger household—two adults. Next door
neighbors to Minkers on W. Rock Creek Road.
g. Joseph Korenak household—first house south of
Minker residence, on west side of Rock Creek Road.
h. Albert Edwards household—located immediately adjacent
to Romaine Creek, approximately 1/3 mile north of
the Minker site.
4. Personal contact will be maintained with rxxfe house-
holds adjacent to the seven identified for relocation:
Crismon
Davis
Abramson
Henderson
Webb
5. Three households near the Stout site have been
offered relocation:
• Martin Hutchison (next door to site;
have already temporarily relocated)
• James Cisco (2 doors down from site;
have already temporarily relocated)
• Edward Baczynski (across street; have
already temporarily relocated)
6. Personal contact will be maintained with two house-
holds near the Stout site that have expressed concerns
• Jack Sutton (owns trailer house on Stout
site; is the developer—NHI Development
Company—of Country Club Manor subdivi-
sion)
• Peter Vogt (owns part of Stout site;
lives further up the road)
7. Other areawide groups that are involved in the
dioxin situation in Missouri are:
• Coalition for the Environment (based in
St. Louis; present at January 29 meeting)
• Missourians against Hazardous Waste (based
in Excello, Missouri)
• Environmental Defense Group (based in
Washington, D.C.; Dr. Ellen Silbergeld
attended January 29 meeting)
PD951.001
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A-23
• Sharon Rogers—attended January 29 meet-
ing as a representative of the people of
Warren County (where Bob's Home Service,
the only licensed hazardous waste land-
fill in Missouri, is located)
• Mr. Layne Jumper—Times Beach site repre-
sentative who attended the January 29
meeting.
8. The local and national press has been giving exten-
sive coverage to events at these sites.
9. Local, state, and Federal officials: Congressman
Gephardt has been actively involved in this issue,
and has been contacted by a number of residents.
He called the public hearing on January 29, 1983.
State representative Bob Feigenbaum and State Senator
Harriet Woods have also been particularly involved
in dioxin and hazardous waste issues in Missouri.
D. KEY ISSUES AND CONCERNS
1. Health Effects. What tests can be taken? Who
will pay for tests and medical expenses? What are
the effects of exposure?
2. Property Values. How can compensation be received
for lower property values? How are Federal en-
forcement actions related to residents' legal posi-
tion? Can property taxes be reduced to reflect
lower value? After cleanup, can property deeds
state that the area is clean and safe? What will
be the effects on local developers?
3. Additional Sampling. What are the results of the
December samplings? Some people have requested
that their property should also be sampled. Some
residents believe that wellwater sampling should
be conducted, and that sampling should be done for
PCBs and other possible toxic substances.
4. Relocation. Some residents living downwind from
the sites believe they should be relocated immedi-
ately because they are subject to exposure. Will
relocation of some households be necessary during
cleanup? What are the details of the relocation
and fencing process (insurance, fire-fighting access,
security)?
5. Remedial Action and Cleanup; What is the schedule
for remedial actions and cleanup? What will the
level of cleanup be? How will citizens be involved
in selecting remedial alternatives? Will con-
PD951.001
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A-24
taminated soil be contained onsite or removed?
What will the restoration and close-out procedures
be? There is a strong feeling by some people that
containing and securing the site is not an ade-
quate cleanup measure; if this solution isnchosen,
they will insist on being bought out on the basis
of lowered property values and future health
risks. If soil is removed, will the truck traffic
cause road deterioration? What traffic controls
will be provided? How will equipment used during
the cleanup be decontaminated? How will residents
be protected from dust? Can downwind residents be
relocated during on-site action?
It should be emphasized that people's two main concerns
are health effects and economic loss. It is perhaps
relevant to note that in August 1982, a Federal court
awarded over $58 million in damages to workers whose
health was affected by exposure to dioxin during the
cleanup of a 1979 train derailment in Sturgeon, Mis-
souri. Several residents in the Imperial area have
filed suit for damages, and more litigation is
expected.
Based on the issues, concerns, and citizen participation
and perceptions that have been identified, the level of
community concern at the Imperial sites should be as-
sessed as high.
E. PROPOSED REMEDIAL ACTIONS AND SCHEDULE
The activities described below will be conducted pur-
suant to a written contract between EPA and the State
of Missouri. That contract defines the responsibili-
ties of EPA and the State and provides for funding of
the proposed actions. EPA is the lead agency and will
be responsible for performing all activities at the
site other than the relocation of the residents.
• Initial Remedial Measures - Temporary relocation
will be offered to affected residents by the State
of Missouri. EPA contractors will post warning
signs around the Minker and Stout residential
areas and along Romaine Creek. Before the posting,
access agreements will be obtained from property
owners and surveys of the area will be conducted.
• Remedial Investigations - Additional data will be
collected. Aerial photographs of the area will be
taken to prepare topographic maps. Additional
soil samples from the Stout residential area will
be collected and analyzed to accurately define the
contaminated area. A hydrogeological study of
PD951.001
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A-25
Romaine Creek will be conducted by the U.S. Geo-
logical Survey to provide information about the
geology and groundwater in the area. At this
time, no additional sampling is planned for the
Minker area or Romaine Creek.
• Feasibility Study - A preliminary screening of
alternatives will be conducted to arrive at a perma-
nent remedy based on costs, environmental effects,
environmental protection/ and engineering feasibil-
ity. A more detailed evaluation will then be made
of those alternatives which appear feasible, A
selection of the most appropriate site-specific
alternative will then be made. Citizen input will
be solicited before the selection of the final
remedy.
II. OBJECTIVES OF THE COMMUNITY RELATIONS PLAN
1. Ensure that local residents and state and local
officials are kept informed of possible actions
under consideration and the reasons for these
actions.
2. Ensure that local residents, state and local
officials, and concerned groups are notified of
major findings, activities, and decisions in a
timely and effective way. Notify residents and
officials before notice is given to the media.
3. Provide the media with timely, detailed, accurate
information about the initial response, remedial
investigation, and feasibility study.
4. Effectively address citizen inquiries and con-
cerns; ensure that the best possible information
is provided. Provide a central, consistent
source (s) for people to contact.
5. Provide local residents and state and local offi-
cials with the opportunity to comment on remedial
action alternatives identified during the feasi-
bility study, before final selection of a remedy.
6. Use identified public concerns as one criterion
for the evaluation of alternatives during the
feasibility study.
7. Keep aware of changes in community concerns, in-
formation needs, and activities, and modify this
community relations plan as necessary to address
these changes.
PD951.001 8
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A-26
III. TECHNIQUES TO BE USED TO MEET OBJECTIVES
The following community relations techniques fulfill
the objectives listed above. The purpose of each tech-
nique and its application at certain stages of the tech-
nical work are discussed. The workplan and schedule
shown in Section IV shows these community relations
techniques in relation to technical milestones.
Technique
Objectives
1. Personal contact with
residents
Door-to-door or by telephone. To inform
target residents (relocatees; spokesper-
sons for two community groups; closest
neighbors) of major findings, activities,
and decisions. Should occur before fact
sheets or other public information is
released.
2. Briefing of local and
state officials
In person or by telephone. Inform
appropriate officials of plans and
developments on continuing basis. CIGL
will maintain liaison with public officials,
3. Public consultations
Informal discussions with small groups
of concerned citizens (two identified
groups and any others that arise) to re-
view issues and answer questions. Pro-
vide medical experts or other experts as
appropriate. Schedule during the feasi-
bility study to present the alternatives
and solicit input; also schedule upon
request.
PD951.001
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A-27
Technique
Objectives
4. Fact sheets and updates
To be distributed to 150 households in
vicinity as a source of accurate informa-
tion concerning findings, plans, activi-
ties. Also to be distributed at meetings
and consultations, to the media, and to
other appropriate parties (such as active
environmental groups). Ensure that fact
sheets are mailed to residents who have
moved from the area because of the dioxin
situation. Coordinate distribution with
other information releases. Invite
comments and provide further sources of
information where appropriate.
5. Press releases
To announce milestones in activities or
impart necessary information. Will be
concise, timely, and accurate. Dates of
release will be strategically planned so
release doesn't precede appropriate local
notification.
6. Press conferences (op-
tional)
To announce important findings or
actions. High-level state and Federal
officials may participate. Could be
conducted after remedial action plan is
approved and prior to construction.
7. Health advisory number
(Dioxin Program, St. Jos-
eph Hospital, St. Louis—
sponsored by CDC/Missouri
Department of Health)
To gather and provide information about
health concerns of public. Number
should be included in fact sheets or
otherwise be made known to local resi-
dents and officials.
PD951.001
10
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A-28
Technique
Objectives
8. EPA toll-free telephone
line (Office of Public
Affairs, EPA Region VII,
Kansas City)
(Office To provide a direct line of
communication for inquiries and con-
cerns. Number should be included in
fact sheets or otherwise be made known
to local residents and officials.
9. Onsite inquiry office
(optional)
To provide an onsite source of informa-
tion when controversial findings are re-
leased or when a great deal of public
interest is anticipated.
10. Regional information of-
fice (optional, for St.
Louis region)
To provide information about this and
other dioxin sites; to provide personal,
easily accessible, and consistent contact
to concerned citizens.
11. Summary of public concerns For use by EPA staff during feasibility
study; public concerns are to be used as
one criterion for the evaluation of
alternatives.
12. Interim report
To provide EPA Headquarters with a sum-
mary of public inquiries and concerns,
the responses provided, and the community
relations activities conducted.
PD951.001
11
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IV. WORKPLAN AND SCHEDULE*
Community Relations Techniques
1. Personal contact with
residents
2. Briefing of local/state
officials
3. Public consultations
4. Fact sheets and updates
5. Press releases
6. Press conferences
7. Health advisory number
8. EPA telephone line
9. Onsite inquiry office
10. Regional information
office
11. Summary of public concerns
12. Interim report
Technical Milestones
Release of
December
Sampling Posting of
Results Sites
Remedial
Investigation
Evaluation of
Feasible
Alternatives
(ongoing)
^optional, as appropriate!
(optional, as appropriate)
Selection
of
Remedy
^optional, as appropriate J
(ongoing)
(ongoing)
r
NJ
VD
*The schedule presented here is relative to technical milestones; the actual timing can be specified when
the technical work schedule is made final.
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A-30
V. BUDGET AND STAFFING PLAN
(To be provided by EPA)
APPENDIX: NOTIFICATION LIST (Available upon request)
A. Local officials
B. Interested or affected parties and organizations
C. Media
PD951.001 13
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APPENDIX B
COMMUNITY RELATIONS GUIDANCE FOR EVALUATING
CITIZEN CONCERNS AT SUPERFUND SITES
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1. INTRODUCTION
This document provides guidance for planning, conducting, and evaluating
on-site discussions with concerned citizens and local officials at Superfund
sites. These discussions provide the basis for assessing the nature and level
of citizen concern at the site -- a requirement for all non-emergency
Superfund response actions. Tasks described in this guidance may be performed
by EPA regional personnel, state response staff, or EPA-supervised contractors.
Community relations activities must be based upon information derived from
on-site discussions with concerned citizens and local public officials to
ensure that EPA or the state responds to local concerns and major issues.
Results of the on-site discussions should be incorporated into a community
relations plan (CRP) -- the planning, management, and budget cornerstone of
the community relations program for each site. Activities specified in the
CRP are tailored to the level and nature of community concerns at the site.
These on-site discussions are not a survey of citizen opinion. Rather,
they are information meetings conducted to provide community relations staff
with the background information necessary to understand the site's history
from the community's perspective, to identify concerned citizens, officials,
and organized groups, and to evaluate the level and nature of citizen
concern. This information is indispensable in preparing the CRP. The
discussions also serve as the initial public input into response plans
Concerns identified in these discussions may be taken into account in
developing technical response actions.
Information derived from on-site discussions may also be useful to the
enforcement staff. At sites where enforcement staff are seeking responsible
party cleanup, on-site discussions should be conducted and evaluated by the
time notice letters are sent out, so that enforcement personnel may be
informed of community concerns before entering negotiations with responsible
parties.
Thus, these discussions are of critical importance in designing community
relations programs that are tailored to a particular community. In turn, they
can help in the design and implementation of response actions (including
enforcement actions) that meet the community's special needs. They must,
however, be conducted with care and discretion.
Section 2 of this document describes how to plan and prepare for on-site
discussions. Section 3 offers a set of procedures that may be useful for
conducting the discussions. Finally, Section 4 provides a framework for
assessing the results of the discussions.
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2. PLANNING AND PREPARATION
This section of the guidance discusses the planning and preparation that
should precede discussions with citizens and local officials at the site. The
work effort required for the activities described will vary from site to site,
depending on the level of citizen concern and the site's technical
complexity. On the average, however, planning and preparation for on-site
discussions should require three days of work effort.
Prior to conducting the on-site discussions, the community relations staff
should plan: (1) how to acquire information about the site and identify
interested public officials and members of the local community; (2) how to
contact interested officials, citizens, and organized groups; and (3) how to
elicit information from these individuals and groups. These three phases of
the planning process are discussed separately below.
A. Acquiring Site Information and Identifying Interested Officials,
Community Members, and Groups
To ensure that key individuals are contacted and that site issues are
understood, certain steps should be performed to acquire necessary background
information, including the following:
(1) Meeting with regional EPA and state technical staff to
discuss known or suspected site problems, to identify
interested officials and citizens, and to obtain other
background information;
(2) Reviewing EPA regional office, headquarters and state
files to obtain relevant memos, documents, and
correspondence;
(3) Researching local newpaper articles for the names of
community leaders and for a preliminary indication of
major site issues;
(4) If EPA clearance has been obtained, contacting
Congressional offices in Washington or the state,
either by telephone or in person, to obtain additional
background information, as well as to inform the
offices that EPA or state staff or contractors will
soon visit the site. Congressional staff can identify
the most involved citizens and the major site issues on
the basis of inquiries to their office. It is
essential to obtain EPA clearance, however, before
making such contact. (Staff in the local or district
Congressional office nearest to the site may be
included routinely among those with whom on-site
discussions are held, as noted below.)
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B-3
Performing these four steps in the order in which they are presented here
should help maximize the efficiency with which this first phase of the
planning process is carried out.
At most sites, some or all of the following types of individuals and
groups may have concerns about the site or can provide valuable perspective on
site issues. They should, therefore, be included among those to be considered
for on-site discussions:
• Persons interested in the site, i.e., persons living
in close proximity to the site and nearby property
owners;
• State agency staff, such as health, environmental
protection, or natural resources department officials;
• Local and state elected officials, such as the mayor,
council members, local state legislators, or attorney
general;
• Staff at Congressional or state legislators' district
offices;
• County planning and health officials;
• Representatives of ad hoc citizen groups organized
because of site issues;
• Local business representatives (e.g., from the
Chamber of Commerce);
• Local civic groups;
• Neighborhood associations;
• Local chapters of environmental groups;
• Local educators and school administrators; and
• Media representatives.
It is important to encourage those members of the community who have been
the most active with respect to the site to raise their concerns in on-site
discussions.
B. Contacting Interested Officials, Citizens, and Groups
Once the background activities of the first phase of the planning process
are completed, community relations staff should draw up a list of persons to
be contacted at the site and make arrangements to meet with them. In phoning
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B-4
those persons on the contact list, staff should explain that the purpose of
the discussions is solely to obtain the views of community members on site
problems and to explore the concerns and issues identified by citizens and
local officials. Staff should stress that the discussions will not be used
to provide information to the public about site problems or possible future
site actions, but instead, that the purpose of the discussions is to assess
the level and nature of community concerns, so that community relations
activities appropriate to those concerns can be conducted and so that
community concerns can be taken into account in planning response actions.
The purpose of the discussions will usually be easily understood. Citizens
and officials will generally not object to speaking to government staff who
cannot provide them with findings on possible effects or a firm schedule for
cleanup, although they may be disappointed not to receive such information.
Rather, citizens and local officials are generally appreciative that someone
from the government is willing to meet with them and listen to their views.
They regard the discussions as an opportunity to voice their concerns and,
perhaps, to have some effect on government decisions.
If possible, all meetings should,be scheduled over a period of no more
than five days.
C. Eliciting Information from Individuals and Groups
The final phase of the planning process is to draw up a brief and informal
list of questions to guide the discussions with local officials and citizens.
Such a list may help to ensure that the discussions are efficient yet
comprehensive. These questions may serve as a reminder of the areas that
should be covered in the discussions, the kinds of information that should be
elicited, and any specific points that must be addressed. Because the on-site
discussions should not be conducted as a survey, the questions listed in
advance while planning the discussions need not be asked explicitly during
discussions. Exhibit 1 presents examples of questions that may be useful in
conducting on-site discussions.
In addition to preparing questions, community relations staff should
determine whether there are any special matters that should not be publicly
disclosed (for example, specific findings from enforcement investigations or
preliminary cost estimates for cleanup). Program and enforcement staff should
be consulted on this point before the on-site discussions are held.
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B-5
EXHIBIT 1
EXAMPLES OF QUESTIONS TO ASK IN ON-SITE DISCUSSIONS
(1) When did you first become aware of the release of hazardous substances at
the site?
(2) How would you characterize the problems at the site?
(3) What contacts have you had with local, state, EPA and other officials
about the site?
(4) What are your major concerns related to the site?
(5) What activities have you participated in, sponsored, or organized
concerning the site?
(6) How can EPA or the state best provide you with information concerning
response activities? Would you like to be included on a mailing list?
(7) What kind of information would be most useful to you (e.g., technical
information, status reports on cleanup activities)? How frequently would
you like to receive a progress report or fact sheet?
(8) Is there anything you wish to mention that we have not yet discussed?
(9) Can you suggest other individuals or groups that EPA or the state should
contact for additional information or to identify other types of concerns?
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B-6
3. CONDUCTING ON-SITE DISCUSSIONS
This section presents procedures that may be useful to EPA, the state, or
contractor support staff in conducting on-site discussions with citizens and
local officials. If possible, all discussions related to a specific site
should be conducted within a five day period.
Once the discussions have begun, staff should try to:
• Make all appointments as scheduled;
• Arrange a follow-up conversation if additional time
is needed with any official or citizen;
• Assure citizens and officials that all interviews
will be held confidential, and that no specific
statements will be attributed to any person without
prior clearance;
• Have two community relations staffers present during
the discussion, when possible, so that one can take
notes while the other leads the discussion.
About 45 minutes to one hour should be allowed for a discussion with an
individual. Less time will usually be required once the community relations
staff have become familiar with the background of community involvement
through previous discussions. If asked, staff should not hesitate to identify
some of the other citizens or officials with whom discussions are being held.
Local reporters may, on occasion, ask to attend discussions between
community relations staff and community leaders or officials. The attendance
of reporters at these discussions should be discouraged, as it might inhibit a
frank and open conversation. Reporters should be asked, instead, to meet
separately with community relations staff. If they do attend discussions with
officials, they should be included in the meeting and asked for their views
and comments, which are valuable.
At the outset of any discussion with reporters, community relations staff
should repeat that the purpose of the discussion is to collect information,
not to answer questions, and that the community relations staff are not in a
position, in any event, to provide new information on site problems or
response plans.
Community relations staff must take special care to avoid making
subjective comments about the site during the discussions and avoid conveying
specific information that may raise citizens' or officials' expectations
about response activities.
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B-7
At the end of each discussion, staff should ask the citizen or official if
he or she is interested in participating in future briefings, workshops, and
meetings, and receiving prior notification of such activities by mail. In
addition, the names of other individuals to contact in the community should be
requested. After each discussion has been concluded, staff should write up a
summary of the discussion as soon as possible.
When all the meetings have been held, staff should prepare a final list of
all interested officials and citizens with pertinent titles and affiliations,
addresses, and phone numbers. This list eventually will be included in the
community relations plan for the site.
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4. EVALUATING DISCUSSIONS
Based upon the discussion summaries and the notes from each meeting,
community relations staff should evaluate the nature and level of citizen
concern at the site. This evaluation will be incorporated into the CRP.
Community relations staff may assess whether community concern is high,
medium, or low by considering the presence or absence of the following six
characteristics, which have been found to be important indicators of community
involvement and concern in past on-site investigations conducted by EPA:
(1) Children's health -- whether families in the community
believe their children's health may be affected by
hazardous substances;
(2) Economic loss -- whether local homeowners or
businesses believe that, the site has caused or will
cause them economic loss;
(3) Agency credibility -- whether the performance and
statements of EPA and the state are viewed by the
public as competent and credible;
(4) Involvement -- whether an active, vocal group leader
(or leaders) has emerged from the community and whether
the group leader has a substantial local following;
(5) Media -- whether events at the site have received
substantial coverage by local, state, regional, or
national media; and
(6) Number affected -- whether more than three or four
households perceive themselves as affected by the site.
Some of these characteristics are more important than others in
determining the level of community concern. For example, a perceived threat
to children's health is a particularly strong indicator of a potentially high
level of citizen concern at a site. If several of the above characteristics
describe the affected community, the community relations staff have grounds
for considering that the level of community concern at the site may be medium
to high or has the potential to become medium to high.
In writing CRPs, following completion of these on-site discussions, it is
important to maintain objectivity. Consideration should be given to the
feelings of any citizens or officials mentioned. These plans will be
circulated among the state and federal agencies involved in the response.
They may also be read by members of the general public in the site community.
Allegations or opinions expressed by those with whom discussions
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B-9
were held do not need to be presented in the plans unless they are directly
relevant to the design of a community relations program. Descriptions of the
personal backgrounds or political beliefs of individuals are unnecessary.
Accusations of conflict of interest or of a complete absence of credibility
among certain officials or agencies are serious charges that are not
appropriate subjects for CRPs. Such charges should be directed to the proper
EPA or state staff according to the standard procedures in such cases. In
short, the information gathered in the on-site discussions should be carefully
weighed and presented as objectively as possible. No CRP should become an
issue itself in the community.
By planning, conducting, and evaluating the discussions in.accordance with
this guidance, community relations staff should gain a clear understanding of
the level and nature of community concern at a site. Community relations
staff should then be able to prepare an effective CRP and to tailor
communications activities at a site to the needs and concerns of local
citizens and officials.
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APPENDIX C
THE QUARTERLY REPORT
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INSTRUCTIONS FOR PREPARING QUARTERLY REPORT*
The quarterly report consists of: completed questionnaires on community
relations activities at Superfund sites; written materials prepared during the
quarter on activities at Superfund sites; and suggestions for improvements in
the Superfund community relations program. Please follow these instructions
in preparing the report.
1. Fill out a questionnaire for each removal or remedial site for which
Superfund funding has been approved. Complete the questionnaire for
both EPA-lead and state-lead actions. Use separate pages if
necessary.
2. Provide information only on community relations activities that took
place during the quarter.
3. Attach to the completed questionnaires any written materials (fact
sheets, news releases, briefings, progress reports) prepared during
the quarter for these sites.
4. Attach to the report any recommendations for improvements in the
community relations program, including any recommendations for
revisions in the community relations policy, handbook, or other
guidance documents.
5. Submit report by January 15, April 15, July 15, and October 15 for
the preceding quarter to:
Daphne Gemmill
Office of Emergency and Remedial Response (WH-548-D)
Environmental Protection Agency
401 M Street, S.W.
Washington, B.C. 20460
•'•"Report should be prepared by the Region's Superfund Community Relations
Coordinator, in coordination with the Regional Site Project Officers.
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QUARTERLY REPORT QUESTIONNAIRE
1. Site/location:
2. Describe any changes in site issues (economic, social, technical,
scientific, political) that have occurred since the preparation of the
last quarterly report:
3. Describe the community relations activities undertaken during the previous
quarter, their effects, and the concerns that arose. What issues remain?
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4. Describe community relations activities planned for the next quarter, how
they will address outstanding issues, and how they relate to technical or
enforcement activities conducted at the site:
If the feasibility study for a remedial action site will be available for
public comment during the next quarter, describe how a comment period will
be implemented and what activities community relations staff will
undertake during the comment period to assist the local community's review
of the study:
6. Describe any community rel-ations issues anticipated for the next quarter:
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7. Does the CRP currently address these issues? Do you plan to revise the
CRP?
8. Explain any deviations from the CRP for the site during the past
quarter?
9. Would you like OPPM community relations staff or contractors to assist you
in meeting certain needs during the next quarter or in resolving
particular issues?
SITE REPORT PREPARED BY:
DATE:
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APPENDIX D
Super-fund Coordinators
Superfund Community Relations Coordinators
(September 1983)
Region One
John Hackler, Superfund Coordinator
Waste Management Division
EPA - Region I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
FTS 8-223-5709 or (617) 223-5709
David Pickman, Superfund
Community Relations Coordinator
Office of Public Affairs
EPA - Region I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
FTS 8-223-5752 or (617) 223-5752
Region Two
Robert Ogg, Superfund Coordinator
Air and Waste Management Division
EPA - Region II
26 Federal Plaza
New York, New York 10278
FTS 8-264-2647 or (212) 264-2647
Lillian Johnson, Superfund
Community Relations Coordinator
Office of Public Affairs
EPA - Region II
26 Federal Plaza
New York, New York 10278
FTS 8-264-4534 or (212) 264-4534
Region Three
Ed Skernolis, Superfund Coordinator
Air and Waste Management Division
EPA - Region III
Curtis Building
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
FTS 8-597-9100 or (215) 597-9100
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Joe Donovan, Superfund
Community Relations Coordinator
Office of Public Affairs
EPA - Region III
Curtis Building
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
FTS 8-597-9905 or (215) 597-9905
Region Four
Al Smith, Superfund Coordinator
Air and Waste Management Division
EPA - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
FTS 8-257-3931 or (404) 881-3931
Gordon Kenna, Superfund
Community Relations Coodinator
Office of Public Affairs
EPA - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
FTS 8-257-3004 or (404) 881-3004
Region Five
Richard Bartelt, Chief, Superfund Coordinator/
Oil & Hazardous Materials Coordinator
.Remedial Response Branch
EPA - Region V
230 South Dearborn
Chicago, Illinois 60604
FTS 8-353-9773 or (312) 353-9773
John Perrecone, Superfund
Community Relations Coordinator
Office of Public Affairs
EPA - Region V
230 South Dearborn
Chicago, Illinois 60604
FTS 8-886-6874 or (312) 886-6874
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Region Six
William Hathaway, Superfund Coordinator
Deputy, Air and Waste Management Division
EPA - Region VI
First International Building
1201 Elm Street
Dallas, Texas 75270
FTS 8-729-9709 or (214) 767-9709
Betty Williamson, Superfund
Community Relations Coordinator
Congressional and Intergovernmental Liaison
EPA - Region VI
First International Building
1201 Elm Street
Dallas, Texas 75270
FTS 8-729-9986 or (214) 767-9986
Region Seven
David Wagoner, Director/Superfund Coordinator
Air and Waste Management Division
EPA - Region VII
324 East llth Street
Kansas City, Missouri 64106
FTS 8-758-6529 or (816) 374-6529
Rowena Michaels, Director
Office of Public Affairs
EPA - Region VII
324 East llth Street
Kansas City, Missouri 64106
FTS 8-758-5894 or (816) 374-5894
Steve Wurtz, Superfund
Community Relations Coordinator
Office of Public Affairs
EPA - Region VII
324 East llth Street
Kansas City, Missouri 64106
FTS 8-758-5894 or (816) 374-5894
Region Eight
John Wardell, Superfund Coordinator
Air and Waste Management Division
EPA - Region VIII
1860 Lincoln Street
Denver, Colorado 80095
FTS 8-327-6238 or (303) 837-6238
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Judy Herb, Director
Office of Public Affairs
EPA - Region VIII
1860 Lincoln Street
Denver, Colorado 80095
FTS 8-327-5927 or (303) 837-5927
Jane Russo, Superfund
Community Relations Coordinator
Office of Public Affairs
EPA - Region VIII
1860 Lincoln Street
Denver, Colorado 80095
7TS 8-327-5927 or (303) 837-5927
Region Nine
Harry Seraydarian, Superfund Coordinator
Director, Toxics and Waste Management Division
EPA - Region IX
215 Fremont Street
San Francisco, California 94105
FTS 8-454-7460 or (415) 974-7460
Steve Drew, Superfund
Community Relations Coordinator
Toxics and Waste Management Division
EPA - Region IX
215 Fremont Street
San Francisco, California 94105
FTS 8-454-8026 or (415) 974-8026
Region Ten
Chuck Findley, Superfund Coordinator
Air and Waste Division
EPA - Region X
1200 6th Avenue
Seattle, Washington 98101
FTS 8-399-1918 or (206) 442-1918
Deborah Yamamoto, Superfund
Community Relations Coordinator
Air and Waste Division
EPA - Region X
1200 6th Avenue
Seattle, Washington 98101
FTS 8-399-0455 or (206) 442-0455
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Headquarters Super-fund Community Relations Staff
(September 1983)
Daphne Gemmill
Community Relations Coordinator
Office of Emergency and Remedial Response
EPA Headquarters (WH-548D)
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2441 or (202) 382-2441
Anne Fenn
Assistant Community Relations Coordinator (Regions V - X)
Office of Emergency and Remedial Response
EPA Headquarters (WH-548D)
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2464 or (202) 382-2464
Allen Maples
Assistant Community Relations Coordinator (Regions I - IV)
Office of Emergency and Remedial Response
EPA Headquarters (WH-548D)
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2461 or (202) 382-2461
Michael Flaherty, Removal Actions Contact
Emergency Response Division (WH-548B)
Office of Emergency and Remedial Response
EPA Headquarters
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2196 or (202) 382-2196
Tony Diecidue, Remedial Actions Contact
Hazardous Site Control Division (WH-548E)
Office of Emergency and Remedial Response
EPA Headquarters
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2454 or (202) 382-2454
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APPENDIX E
PROBLEM SITUATIONS
(reserved)
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APPENDIX F
GLOSSARY OF TERMS AND ACRONYMS
This glossary presents brief descriptions of terms used in the community
relations handbook. The terms are organized alphabetically by broad
categories: community relations program; Superfund response actions; program
documents and requirements; and program offices and officials. The acronyms
that are applicable to program terms are listed at the end of the glossary.
Detailed definitions of these terms are provided in this handbook.
COMMUNITY RELATIONS PROGRAM
Community Relations Program. The community relations program is a
two-way communications program, designed to provide communities with
accurate, understandable information about Superfund sites and
proposed response actions, to elicit community concerns, and to
provide communities with an opportunity to comment on proposed
response actions.
Public Relations Program. A public relations program is an
information program that exists primarily to provide information to
the public about an agency and its programs. It differs from a
community relations program in that it does not necessarily promote
two-way communication.
The Superfund Response Program. The Superfund program is the
response program established by the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) to respond to
releases or threatened releases of hazardous substances, pollutants,
or contaminants from vessels or facilities. (See CERCLA and the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Part 300.)
SUPERFUND RESPONSE ACTIONS
Response Actions. Superfund response actions are those removal or
remedial actions undertaken in accordance with Section 104 of
CERCLA. The three types of response actions that may be taken under
CERCLA are described below.
Immediate Removals (IR). These are actions taken to prevent or
mitigate immediate and significant risk of harm to human life or
health or to the environment. They are subject to timing and
monetary limitations. (See Section 300.65 of the NCP.)
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F-2
Initial Remedial Measures (IRMs) These are actions that can be
taken quickly to limit exposure or threat of exposure to a
significant health or environmental hazard at sites where planning
for remedial actions is underway. IRMs may fall into two
categories: (1) relatively simple measures to stabilize or secure
the site or reduce direct human exposure to hazardous substances; and
(2) actions that are needed to remove serious threats of exposure
while the full scale remedial investigation and feasibility study are
underway. (See Section 300.68 of the NCP.)
Planned Removals (PR). These are actions that may be taken either
when (1) the conditions for ending an immediate removal exist, yet a
substantial cost savings can be realized by completing the action; or
(2) action is warranted at a site that is neither on the National
Priorities List nor meets the immediate removal criteria, but poses a
risk to public health or the environment that requires action before
the release can be added to the National Priorities List for remedial
action. Planned removals are intended to respond to situations that
require an expedited, but not immediate response. (See Section
300.67 of the NCP.)
Remedial Actions (RA). These are responses that are taken to
releases on the National Priorities List that are consistent with a
permanent remedy to prevent or mitigate the migration of a release of
hazardous substances into the environment. The lead agency for the
remedial response must select the most cost-effective remedy. (See
Section 300.68 of the NCP.)
PROGRAM DOCUMENTS AND REQUIREMENTS
Action Memorandum (AM). This is the memorandum that contains a
request for funding the Superfund action. The memorandum includes a
description of the site and the problems posed by the release,
references other relevant statutory provisions, and explains how the
technical response is being coordinated with enforcement efforts.
Comment Period. This is the period of time provided to local
officials and citizens to review the proposed Superfund remedial
action. The community relations plan must specify that the community
will have an opportunity to comment on the feasibility study prior to
the selection of a site remedy. A minimum three-week comment period
must be implemented for nonexpedited remedial actions. For any
initial remedial measures (IRMs), the plan must also (1) address how
the community will receive prior notification of any site action and
(2) state that a minimum two-week comment period will be provided for
any complex IRM recommended by a limited feasibility study.
Community Relations Plan (CRP). The CRP is the planning,
management, and budget document that guides the community relations
program at Superfund sites. A CRP must be developed for all
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F-3
Superfund planned removal and remedial actions. In addition, a less
detailed .plan must be developed for immediate removals that are
anticipated to last longer than 45 days. The plan contains: an
assessment of citizen concern; a list of communications activities to
be conducted at the site, a budget estimate, schedule, and workplan,
and a list of technical and community relations staff responsible for
site work.
Community Relations Profile. The profile—a short form CRP--is a
brief analysis of the nature of citizen concern, the key site issues,
and program objectives that must be prepared for immediate removal
actions lasting longer than 5 days.
Cooperative Agreement (CA). The cooperative agreement is the
agreement that outlines the responsibilities of the federal and state
governments for removal or remedial actions at state-lead Superfund
sites. (See "Guidance-Cooperative Agreement and Contracts with
States under CERCLA (P.L. 96-510)," U.S. EPA, OERR, March 1982.
Feasibility Study (FS). The feasibility study is conducted to
develop and analyze remedial alternatives, to recommend the
appropriate cost-effective remedial action, to prepare an
environmental assessment, and to develop a conceptual design for the
recommended action.
Fourteen Point Document. This planned removal document, prepared
by On-Scene Coordinators for EPA-lead actions, describes general site
information, explains the threat presented by the site, and provides
information regarding the proposed response action. (See the EPA
Contracts Management Manual for the required contents of the
document.)
National Contingency Plan (NCP). The NCP is the regulatory
document that guides response actions taken pursuant to CERCLA and
Section 311 of the Clean Water Act. (See the National Oil and
Hazardous Substances Pollution Contingency Plan, 40 CFR 300.)
National Priorities List (NPL). The NPL is a list of over 400
hazardous waste sites targeted for cleanup by federal and state
governments under CERCLA. Sites on the list are candidates for
remedial or enforcement action. Decisions on the type and extent of
action to be taken at the site are made on a case by case basis
according to guidelines specified in the NCP.
Quarterly Report. This is a brief summary of community relations
activities for each Superfund response in the Region. Prepared by
the Regional Superfund community relations coordinator, the report is
submitted to Headquarters where it is used to analyze community
relations programs and to identify potential communications problems
at :sites. -
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Remedial Investigation (Rl). The remedial investigation is
conducted to assess the problem at the site and to collect data
necessary for its resolution. The study supports the analysis and
selection of alternatives in the feasibility study.
Responsiveness Summary (RS). This is an in-house EPA report
prepared by community relations staff at two points during remedial
response: at the conclusion of the feasibility study and at the
conclusion of the response action. It is also prepared at the
conclusion of a planned removal. This report reviews public
inquiries, the issues and concerns raised, and how EPA or the state
responded to these issues and concerns. The report may be used to
help document for the public record how EPA responded to key
community concerns and issues.
State Superfund Contract. The state contract is the legal
agreement that outlines federal and state government responsibilities
at EPA-lead actions. (See "Guidance-Cooperative Agreements and
Contracts with States under CERCLA (P.L. 96-510)," U.S. EPA, OERR,
March 1982.)
Ten Point Document. Also known as the immediate removal request,
this document is prepared by the On-Scene Coordinator to justify the
request for Headquarters approval for immediate removal actions.
PROGRAM OFFICES AND OFFICIALS
Community Relations Coordinator (CRC). The CRC is the Regional
Office staff person responsible for designing and implementing a
site-specific community relations program. The CRC works closely
with the site's On-Scene Coordinator to establish a site-specific
communications program.
Emergency Response Division (ERD). This is the division within
the Headquarters Office of Emergency and Remedial Response (OERR)
that is responsible for conducting Superfund removal actions. ERD's
staff reviews all community relations plans submitted for removal
actions. ERD is responsible for preparing the Action Memorandum, the
Fourteen and Ten Point Documents, and the planned removal cooperative
agreement or state contract for Office Director and Assistant
Administrator approval.
Hazardous Site Control Division (HSCD). This is the division
within the Headquarters Office of Emergency and Remedial Response
that is responsible for conducting Superfund remedial actions.
HSCD's staff reviews all community relations plans submitted for
remedial actions. HSCD is responsible for preparing the Action
Memorandum, the remedial action cooperative agreement or state
contract, and the statement of work for Office Director and Assistant
Administrator approval.
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The Office of Emergency and Remedial Response (OERR). This is the
EPA office responsible for establishing Superfund policies, for
implementing the Superfund Program, and for evaluating program
effectiveness.
The Office of Policy and Program Management (OPPM). This is the
office within OERR that is responsible for developing community
relations policies, reviewing and approving community relations
plans, tracking communications activities at sites, and conducting
program evaluations and resource analysis.
The Regional Office of Public Affairs (OPA) . Staff in the
Regional Office of Public Affairs are responsible for helping' to
design and implement a community relations program at each site where
Superfund monies have been obligated. The office works closely with
the technical staff at the site and in the Regional Office in
conducting community relations programs.
On-Scene Coordinator (OSC). This is the federal or state official
that coordinates and directs the Superfund technical response at the
site. The OSC works closely with the community relations staff to
establish site-specific community relations programs.
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COMMUNITY RELATIONS ACRONYMS
AM Action Memorandum
CA Cooperative Agreement
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act
CRC Community Relations Coordinator
CRP Community Relations Plan
ERD Emergency Response Division
FS Feasibility Study
HSCD Hazardous Site Control Division
IR Immediate Removal
IRM Initial Remedial Measure
NCR The National Oil and Hazardous Substances Pollution
Contingency Plan
NPL National Priorities List
OERR Office of Emergency and Remedial Response
OPA Office of Public Affairs
OPPM Office of Policy and Program Management
OSC On-Scene Coordinator
PR Planned Removal
RA Remedial Action
Rl Remedial Investigation
RS Responsiveness Summary
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ACKNOWLEDGEMENT
This handbook is a product of the combined efforts of ICF Incorporated,
EPA's Office of Emergency and Remedial Response, and EPA Regional and State
Superfund and public affairs staff concerned.about citizen involvement in
responding to hazardous substances problems.
Daphne Gemmill and Barry Jordan served as EPA's project officers. Their
guidance and direction in developing the handbook benefitted from the
contributions of Anthony Diecidue, Anne Fenn, L. Michael Flaherty, and Allen
Maples from EPA Headquarters. The ICF staff for this project include James R.
Janis, Project Manager, Carol Andress, Edwin Berk, Bradley Brockbank, Margo
Brown, James Bunchuck, Carole Francis, Sara Nielsen, Robin Sandenburgh, Mary
Sexton, Corliss Wallingford, Zella Williams, and Dana Wohlford. The initial
guidance of Dr. Steven Cohen of Columbia University is also very much
appreciated.
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