United States
             Environmental Protection
           Office of
           Solid Waste and
           Emergency Response

                     Planning for Sufficient Community
                Relations: Superfund Mgmt Review Rec #43A
              APPROVAL DATE:     3/7/90

              EFFECTIVE DATE:     3/7/90


              Q FINAL

              D DRAFT


              REFERENCE (other documents):
 OS WER      OS WER      OS WER

                    Form Approved OMB No. 0704-0188
1. Acrency Use Only:

2. Report Date:
3. Report Type And Dates Covered:
4. Title And Subtitle: Planning for Sufficient
Community Relations (Superfund Management Review:
6. Author(s) :
                               5.  Funding Numbers:
7. Performing Organization Names And Addresses:
Environmental Protection Agency
Office of Solid Waste and Emergency Response
401 M Street, SW
Washington, DC  20460
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9. Sponsoring/Monitoring Agency Name(s)
   And Address(es):
Environmental Protection Agency
Office of Emergency and Remedial Response
401 M Street, SW
Washington, DC  20460
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                                   Agency Report Number:
11. Supplementary Notes:
12a. Distribution/Availability Statement:
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13. Abstract: Provides guidance to Regional staff on planning for sufficient
 community relations at all stages of the Superfund process.  This document
identifies specific planning activities that have been used successfully in
the Regions.
14. Subject Terms:
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                                                   16. Price Code: A02
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                       WASHINGTON, D.C. 20460
                                                      OFFICE OF
                                            SOLID WASTE AND EMERGENCY RESPONSE
                             OSWER DIRECTIVE  9230.0-08
Planning for Sufficient Community Relati
(Superfund Management Review: #4
Henry L. Longest II, Director
Office of Emergency and Remedial Response

Director, Waste Management Division
  Regions I, IV, V, VII, VIII
Director, Emergency and Remedial Response  Division
  Region II
Director, Hazardous Waste Management Division
  Regions III, VI
Director, Toxic and Waste Management Division
  Region IX
Director, Hazardous Waste Division
  Region X

     The purpose of this short  sheet  is to provide  guidance to
Regional staff on planning  for  sufficient community relations

     The Superfund Management Review  (SMR)  found  that "limited
time and resources for Regional  staff  keep  them from doing the
communication they think necessary and essential.   Site managers
and community relations staff are concerned that  EPA may be
letting some potentially serious conflicts  develop  with
communities because they cannot  get out to  the sites early enough
or frequently enough."  This document  has been prepared to help
Superfund managers promote  earlier and more freguent citizen
involvement at Superfund site communities.
                                                          Printed on Recycled Paper

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                                      OSWER DIRECTIVE 9230.0-08


     This guidance identifies specific planning activities that
have been used successfully in the Regions.  These activities
encourage Superfund managers to take the following steps:

o    integrate community relations into all technical phases,
o    ensure responsive community relations activities,
o    dedicate adequate resources to support community relations
     needs, and
o    establish realistic schedules to meet Superfund site
     community needs.

I.	Integrate Community Relations Into All Technical Phases

     Integrating community relations into the remedial process
at sites is a team effort that takes the commitment of both the
Community Relations Coordinator (CRC) and the Remedial Project
Manager (RPM).   To integrate community relations into the
remedial process, Regions should do the following:

o    Train all technical staff in community relations.  Because
     technical staff are site managers, it is important for them
     to understand community relations concepts and requirements.
     RPMs have found the two-day Community Relations Skills
     Training Course, sponsored by headquarters, to be extremely
     useful.  This free course is offered periodically in each
     Region.  Many Regions have also developed their own Regional
     training programs that are very successful.

o    Encourage RPMs to be active in community relations.
     Community relations works best when the CRC and RPM are a
     team in which the RPM is an active player.  While CRCs can
     provide expert advice and guidance, RPMs should not divorce
     themselves entirely from all community relations activities.
     To do so alienates community relations from the overall
     remedial process.  Involvement by the RPM furthers public
     participation and ensures integration of community
     relations in the remedial process.

     One way for RPMs to be involved is for them to participate
     in the community interviews conducted as part of the
     Community Relations Plan (CRP).   Frequently, these
     interviews can be scheduled to coincide with the RPM's trip
     to the site on other matters.  Even though the RPM may not
     be active in the interviews or assist in the preparation of
     the CRP, the RPM's presence has several positive effects.
     Citizens see that there is real interest in what they have

                                     OSWER DIRECTIVE 9230.0-08

     to say, the RPM begins to know individuals in the community
     (which is a start to establishing trust),  and the RPM gets
     first-hand understanding of community interests and

     It is also effective for RPMs to participate in other
     community relations activities.  They can coordinate with
     the CRC to attend community meetings, make periodic
     telephone calls to key people in the community, or
     informally visit with community members when they make site
     visits.  Although they will not be able to participate in
     all community relations activities, they should request
     briefings after key activities and keep a steady dialogue
     with the CRC.

     Make CRCs integral members of the site team.  CRCs have
     expertise in planning and implementing community relations,
     but they can only contribute if they are made members of the
     site team.  RPMs must recognize however, that just as their
     own workloads preclude them from participating in all
     community relations activities, CRCs have tremendous
     workload requirements that result in their inability to
     attend all site meetings.  Therefore, the RPM and CRC need
     to coordinate at critical points and keep each other up to
     date at all times.
II.  Ensure Responsive CommunityRelations Activities

     The SMR found that about one-quarter to one-third of
Superfund sites were controversial enough to warrant extensive
community involvement.  To respond to this critical finding, the
study recommended that "...EPA should inform citizens early at
all sites, and should then work most intensively at those sites
where there appear to be substantial citizen concerns and
incipient controversies."  To ensure that community needs are
identified and appropriate community relations activities are
performed, EPA should do the following:

o    Prepare community relations plans (CRPs) and keep them
     current.  The CRP is the main tool that identifies
     community relations needs and CRC activities for a given
     site.  Because the CRP is developed prior to the beginning
     of Remedial Investigation field work, it is an early
     opportunity for EPA to assess the level and nature of
     citizen concerns.  It can be the basis of an initial
     assessment to determine whether the site will require
     extensive community involvement.

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                                     OSWER DIRECTIVE 9230.0-08

     Although EPA is required to revise the CRP after the Record
     of Decision (ROD) is signed, several Regions do not wait
     until this technical milestone is reached.  Instead, if
     changes at the site occur, the RPM and CRC should update the
     CRP so the document is accurate and timely.  Periodic
     updates also bring Regional staff into the community,
     provide EPA additional opportunities to talk with the public
     and continue fostering good relationships between the Agency
     and the site community.

o    Maintain regular communications with the community.
     Communities want to know they are being heard.  This can be
     accomplished by making monthly telephone calls to key local
     officials or citizen leaders.  These telephone calls help
     the RPM and CRC follow community interest in the site and
     let the community know that EPA wants the community's input.
     The RPM and CRC can also use this communication technique to
     update the community on site progress and other site-related
     activities.  Regions have also set up toll-free numbers that
     are advertised to residents in a site community.  This
     technique provides citizens with easy access to EPA and can
     let EPA know if there are unresolved issues or problems in
     the community.

     Another way to maintain contact with the community is
     through fact sheets.  Some Regions have implemented a policy
     of preparing bi-monthly fact sheets for all sites.  A fact
     sheet can include information that encourages public
     participation by encouraging citizens with questions and/or
     comments to write or call the RPM and CRC.  It may also
     include a blank mailing label where citizens who are not
     already part of the mailing list are encouraged to add their
     names.  The letters or telephone calls that RPMs and CRCs
     receive assist EPA in measuring the level and type of
     interest that exists. This understanding is critical to
     planning and scheduling responsive community relations

     In order to perform these planning and communication
activities, as well as respond to specific community needs,
adequate resources must be available.

Ill,.Dedicate Adequate Resources to Support Community Relations

     The allocation of adequate resources is a vital step in
planning for sufficient community relations and requires
cooperation and coordination between EPA technical and community

                              - 5 -
                                     OSWER DIRECTIVE 9230.0-08

relations staff.  The following resource planning guidelines are
currently in use in many Regions to assist in allocating adequate
funds toward community relations activities.

o    The more complex a site is, the greater the community
     relations needs will be.  The CRP identifies the community
     relations activities required by a given site and serves as
     a useful planning tool for preparing the community relations
     budget.  RPMs, in consultation with CRCs, should prepare a
     budget with sufficient funds for staffing and financing
     planned community relations activities. In addition, Regions
     should do the following:

o    Establish "...a discretionary fund that [can be used] to
     fund additional work necessary to respond to citizen
     concerns," as recommended by the SMR.  Responding to the
     public's request for more sampling activities is a possible
     way to make use of the discretionary fund.  The
     discretionary fund may also be used to finance additional
     community relations activities at a site where the level and
     nature of community interest warrants additional activities
     not included in the original budget.  As described in the
     SMR, the discretionary fund can enable RPMs and CRCs to
     respond to the site community's needs, thereby enabling the
     citizens to become "partners in the (decision-making)
     process, rather than angry adversaries."

o    Determine appropriate staffing.  EPA Managers need to
     consider the site's community relations needs in making
     technical staff decisions.  Whenever possible, EPA managers
     need to staff the most controversial sites with more senior
     personnel who are experienced in dealing with the public.

     In the event that one team member must be replaced, an EPA
     manager may be able to preserve some level of continuity by
     keeping the second team member at the site.  For example,
     whenever possible, if the RPM is new, the CRC should not be
     switched.  As quickly as possible, new staff need to be
     educated about the site's history and the community's
     involvement and concerns.
IV.  Establish Realistic Schedules To Meet Superfund Site
Community Needs

     Community relations activities are part of the Superfund
process and need to be built into every remedial schedule.   If
adequate time is not factored into the schedule to meet community
relations needs, delays imposed by citizens are more likely.

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                                     OSWER DIRECTIVE 9230.0-08

     ROD deadlines should be based on remedial schedules that
reflect both technical and community relations milestones.  By
working closely with CRCs, RPMs can become familiar with the
public involvement needs of a community and plan accordingly.
Many Regions use the following techniques to meet Superfund site
community needs:

o    Anticipate public involvement needs throughout the remedial
     process.  For scheduling purposes, it is best to determine
     well in advance which communities will request standard
     30-day public comment periods and which will need
     extensions, based on the level of community interest,
     involvement, and other site-related activity.  If a site
     community shows little interest in a site, a 30-day public
     comment period is generally required.  If, however, there is
     substantial interest in the site, the RPM should factor
     adequate time (generally 60 days) for public comment and
     response into the remedial schedule.  Anticipating the
     amount of time a community will need for a public comment
     period is critical to scheduling realistic ROD deadlines.

o    Plan for a public meeting to initiate each public comment
     period. At least one month of planning is required.  The
     CRCs assist the RPM in coordinating a public meeting by
     contacting the local community leaders, providing notice of
     the meeting in local newspapers, preparing a fact sheet,
     preparing graphics for the presentation, and providing
     overall meeting logistics support.  It is best to reserve
     the meeting space at least four weeks ahead of time.  The
     RPM, CRC, and other guest speakers at the meeting should
     organize a planning meeting at least three weeks ahead of
     the public meeting.  The public notice should be placed in
     the local newspapers two weeks in advance of the meeting.
     The "dry run," or rehearsal, should take place one week
     before the meeting.  Advance planning and practice is key to
     preparing an effective public meeting.

o    Track upcoming technical milestones with community relations
     needs.  Some Regions have established computer-based
     tracking systems to assist RPMs and CRCs in closely
     coordinating technical and community relations activities.
     Other Regions use manual tracking systems or hold bi-weekly
     or monthly coordination meetings between RPMs and CRCs.
     Whether the Regions use computer-based manual tracking
     systems to track both technical and community relations
     milestones at each Superfund site is not important.  What is
     critical, however, is that regular tracking and coordination
     of efforts is taking place between RPMs and CRCs.

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                                     OSWER DIRECTIVE 9230.0-08

     By considering the community relations needs at all stages
of the Superfund process, RPMs can work with CRCs to prepare
remedial schedules that reflect realistic remedial goals and
deadlines, and provide sufficient lead time for planning
community relations activities.