vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9230.0-19
TITLE:
Proposed Method to Evaluate the Effectiveness of
Community Involvement in Superfund
APPROVAL DATE: 9/18/90
EFFECTIVE DATE: .9/18/90
ORIGINATING OFFICE: Office of Solid Waste
0 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
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Proposed Method to Evaluate Effectiveness of Community Involvement
in Superfund
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Describes a kproposed method to evaluate how effectively
EPA's Superfund community Involvement Program provides adequate and meaningful
participation by the public in cleanup activities.
5. K«yword« NCP; Superfund; community relations
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OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
SEP I 8 1990
SOLID JVASTE A.NO EME»G?.NCY
OSWER Directive 9230.0-19
MEMORANDUM
SUBJECT: Proposed Method to Evaluate the Effectiveness of
Community Involvement in Superfund (Superfund
Management Review: Recommendatio/i #/b.A)
FROM: Henry L. Longest II, Director
Office of Emergency and Remedial^R^ipdnse
t
TO: 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, IX
Director, Hazardous Waste Division
Region. X. .
Community Involvement Coordinators; Regions I - X
Purpose: To describe a proposed method for evaluating how
effectively EPA's Superfund Community Involvement program
provides adequate and meaningful opportunities for public
participation in decisions made at Superfund Sites.
Background: EPA established the Superfund community
involvement program in- response to public participation
requirements in CERCLA/SARA and in the National Contingency Plan
(NCP). Sections 300.430(c) and (f) of the NCP specify the lead
agency's responsibilities. These include:
1. Developing a Community Relations Plan (CRP), based on
— — - Interviews, which provides opportunities for
involvement in a variety of site decisions throughout
the process, including remedy selection;
2. Providing educational opportunities about site
activities and the Superfund process;
3. Making information readily available to the public; and
4. Informing the community of the availability of Technical
Assistance Grants.
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OSWER Directive 9230.0-19
In addition to meeting these minimum requirements, the
program often goes beyond what is mandated, taking a proactive
approach to providing community members a variety of additional
opportunities for involvement and input to the decision-making
process.
Nevertheless, the community involvement program has been
criticized by some groups and individuals as being primarily a
"public relations" program, rather than a "public involvement"
program. They imply that EPA focuses on giving selected
information to communities rather than on providing opportunities
for truly involving community members in the decisions being
made.
The Administrator's Superfund Management Review (SMR)
acknowledged these and other criticisms of the community
involvement program, as well as its accomplishments, while
recognizing EPA's past and present community involvement efforts,
the SMR recommended that the Agency promote even greater citizen
participation in the Superfund decision-making process, carrying
out that recommendation requires that we develop a method for
evaluating the effectiveness of our current community involvement
efforts and the impacts -of any changes made to it.
EPA community involvement staff have recognized this need
for years. Central to the issue is the question of qualitative
versus quantitative measures.
Historically, there has been a reluctance to evaluate the
program on quantitative measures alone because simply counting
community involvement products and activities does not
necessarily indicate the quality of efforts. Also, staff fear
that quantitative targets will be imposed which would not
necessarily provide for better community involvement. On the
other hand, they recognize that the nature of the work does not
easily yield meaningful qualitative measures, as do the technical
components of the process.
Objective: To inform staff of a proposed method to measure
the effectiveness of Superfund's efforts to incorporate citizen
concerns into the clean-up process.
Implementations Any evaluation of community involvement
program effectiveness should be designed to provide information
about both quantitative and qualitative aspects of the program.
No one of these measures can be used without supporting data from
the others in evaluating the overall effectiveness of our
community involvement efforts. The method described below is
intended to accomplish that goal through a three-pronged approach
to data collection.
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OSWER Directive 9230.0-19
Extensive discussion among Regional community involvement
staff identified the need to further define evaluation criteria
and appropriate uses for information gathered in each component
of this proposed method. To meet this need, Community
Involvement Coordinators will adopt or refine the proposed
measurement method, and develop an approach for its
implementation at the National Community Involvement
Coordinators' meeting in November, 1990.
Furthermore, to measure any "progress" in the program the
method also must start with baseline information about community
impact on past site decisions. All information must be used
collectively to provide a full picture of the program that: l)
offers an overview of where we are currently; 2) yields the
numbers and types of opportunities provided for community
involvement; and 3) allows for on-going feedback from community
members about their perceptions of our efforts. To meet these
goals, the following measurement method is proposed:
1. Establishing Baseline and case Histories
To gain insight into how community input has influenced site
decisions in the past, EPA will review a sample of Administrative
Records and RODs to analyze when communities were provided
opportunities for input and how the resulting community input was
considered in-the decision-making process. The information will
be used to develop case studies to show if and where the
community had any impact on final remedy selection.
2. Reporting Opportunities for Public Involvement
To provide information on the types and numbers of
opportunities EPA provides for community involvement,
Headquarters will investigate the possibility of having key
activities reported in CERCLIS. If it is possible to incorporate
community involvement activities into CERCLIS, Regions will be
responsible for quarterly information updates. Activities to be
reported will be selected from the following list:
o CRPsr developed/revised _
o public meetings held/facilitated
o informational meetings held/facilitated
o community taskforce/advisory groups participated in
o open houses/availability sessions held
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OSWER Directive 9230.0-19
o responsiveness summaries written
o small group meetings held/facilitated
o site tours conducted
o fact sheets developed
o news releases distributed
o information updates/status reports issued
o news conferences held
o educational/informational workshops conducted
o public notices published
o information repositories established/updated
o Administrative Record files established/updated, and
o TAGS issued
3. Monitoring Future Program Effectiveness
Headquarters will provide Regions with a system, including
computer software, which is designed to give Superfund staff and
management direct feedback from community members about the
effectiveness of various on-going community involvement
activities. This system is one of Superfund's Total Quality
Management initiatives, and will be implemented on an
experimental basis early in the next fiscal year. When fully
operational, it will allow Regional and Headquarters staff to
compile and evaluate data concerning community responses to the
outreach activities EPA provides. Data collected through this
process will provide site-specific as well as national trend
information on "how are we doing?"
Another component of this system will evaluate and improve
the effectiveness of EPA's internal coordination — a critical
aspect in any Superfund site decision. This component provides
training, tools, and methods, for improving the team approach to
decision-making, thus providing for community concerns, along
with technical and legal issues, to be fully considered
throughout site activities.
Conclusion: Superfund management is committed to providing
meaningful opportunities for public involvement throughout the
clean-up process. The proposed measurement method described in
this memorandum will help us to fulfill that commitment. By
determining our current effectiveness at providing for full
participation by citizens, we are laying the groundwork for a
future of full public involvement in Superfund decision making
and mutually satisfactory two-way communication between EPA and
citizens.
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OSWER Directive 9230.0-19
Please direct any questions or comments on this memorandum
to Melissa Shapiro or Jeff Langholz of my staff at FTS 382-2350
and FTS 382-2460, respectively, or to Marilyn Null of Region VIII
at FTS 330-1141.
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