United States
             Environmental Protection
             Agency
Office of
Solid Waste and
Emergency Response
             DIRECTIVE NUMBER:  9230.0-15

             "ITLE: Role of Community Interviews in Development
             of a Community Relations Program for Remedial Response
             APPROVAL DATE:   6/15/90

             EFFECTIVE DATE:   6/15/90

             ORIGINATING OFFICE: OERR/HSCD

             e FINAL

             D DRAFT

               STATUS:


             REFERENCE (other documents):
OSWER      OSWER      OSWER
     DIRECTIVE   DIRECTIVE   Dl

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                                Washington. DC 20460
                QSWER Directive Initiation Request
                                  1. Directive Number
                                    9230.0-15
                                2. Originator Information
     Name o< Conuct Person
        Melissa Shapiro
     3. Till*
     Mail Coda
        OS-220
Office
  HSCD
Telephone Cod*
          Role of  Community Interviewsin the Development of a Community Relations
            Program for Remedial Response	
     4 Summary of Directive (include onei statement 01 purpose)
             Offers guidance in response to recent Regional questions regarding community
             relations interviews required by the NCP.
     S. Keywords
          CERCLA; NCP; Community Relations
     DA. uoes i nis Uuecuvc supersede rrevious uirecuveisj t
      b. Dots It Supplement Previous DlrectJve(i)?
         [x  | No   I   I Yts    What directive (number, title}


          x ] No   |   [ Yet    What drecttve (number, tffie)
     7. Dnn Level
         A-SlonedbyAM3AA
B - Signed by Office Director
      C - For Review & Comment
         > - h Development
           8. Document to be distributed to States by Headquarters?  LJYM   IZ]No
This Request Meets OSWEM Directives System Format Standards.
9. Sgnature ol Lead Office Directives Coordinator
Betti VanEpps
10. Name and Title ol Approving Official
Henry L. Longest II, Director OERR
Date
6/15/90
Date
6/15/90
     EPA Form 1315-17 (Rev. S-17) Previous editions are obsolete.
   OSWER          OSWER               OSWER              0
VE     DIRECTIVE         DIRECTIVE        DIRECTIVE

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^ ^v ^m - :
USE,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
           WASHINGTON, D.C. 20460
   MEMORANDUM

   SUBJECT:



   PROM:



   TO:
                              UN I 5 1990
                                            OSWER Directive #9230.0-15

                                                        OFFICE OF
                                               SOLID WASTE AND EMERGENCY RESPONSE
  Role of community Interviews  in the Development of a
  Community Relations Program for Rei^ed^jil Response

  Henry L. Longest II, Director,   jrifV^-
  Office of Emergency and Remedial /response

  Director, waste Management Division
    Regions I,  IV, V, VII, vm
  Director, Emergency and Remedial Response  Division
    Region II
  Director, Hazardous Waste Management  Division
    Regions III, VI, IX
  Director, Hazardous Waste Division
    Region X
   PURPOSE;

        To offer guidance in response to  recent Regional Office
   questions regarding the community relations interviews  required  by
   the National contingency Plan.

   BACKGROUND;

        Without a doubt, the interviews are the single most  important
   element in the development of a site-specific community relations
   plan (CRP).  The CRP, in turn, serves  as the backbone of  the  entire
   community relations program during a remedial response.   I  hope  you
   find the following information useful  in clarifying the role  of
   this crucial activity.

   POLICY;

        1) The CRP should be based upon interviews  conducted with the
   community.  The National Contingency Plan  (NCP)  requires  interviews
   and the development of a CRP based upon them.  Among  the  community
   relations activities  required by Section 300.430(c)(2)(i)of the  NCP
   is "...preparing a formal community relations plan  (CRP), based  on
   the community interviews and other relevant information..."
                                                            Printed an Recycled Paper

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                                      OSWER Directive #9230.0-15

     2)  Interviews should be conducted among a variety of people.
Staff ordinarily speak first with state and local officials to
obtain background information and to let these people know that
area residents will also be interviewed.  The group of interviewees
should not, however, be limited to these officials.  "These
discussions with elected officials cannot in themselves generate
enough information to develop an adequate community relations plan.
Special efforts must be' made to interview local residents,
particularly those who are not affiliated with any group."
(Community Relations i_n Superfund — A Handbook, OSWER Directive
#9230.0-3B, p.3-4).  staff should interview a broad range of people
so as to gain the greatest variety of perspectives about the site,
including potentially responsible parties.  Furthermore, the staff
should "...never limit conversations to the most visible groups or
individuals." (Community Relations Handbook, p.3-4)

     3)  Interviews should be conducted with at least 15 - 25
residents.  It is imperative that staff interview a group that
represents a cross-section of the community.  This number is
typically at least fifteen to twenty-five persons, depending on the
size and complexity of the site, but it can be more.  At one
particularly complex site, for example, Regional staff conducted
over two hundred interviews.

     4)  contractors should never conduct interviews without the
presence of EPA staff.  EPA dependence on contractors has been a
particularly controversial issue and community relations was named
in a recent memorandum from Administrator Reilly as an area
potentially vulnerable to contractor misuse  (See attached
memorandum),  interviews are most often conducted by some
combination of the Remedial Project Manager, community relations
staff, enforcement staff and contractors.  Remedial Project
Managers are especially encouraged to conduct community interviews
as a way of learning about a community and its issues, as well as
meeting community leaders early and fostering positive
relationships.

     For more information regarding community interviews, refer to
Chapter 3 of Community Relations iri Superfund — A Handbook, and
Section 300.430(c)(2)(i) and accompanying preamble of the NCP.  If
you have additional questions, please contact Melissa Shapiro of my
staff at FTS 382-2350 or Jeff Langholz at FTS 382-2460.


Attachment


cc: Public Affairs Directors
    Regional Community Relations Coordinators

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