LESSONS LEARNED ABOUT

        SUPERFUND

COMMUNITY INVOLVEMENT
   EPA SUPERFUND RESPONSE STAFF TELL
      HOW PUBLIC INVOLVEMENT
     HAS HELPED CLEAN UP SITES

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 SUBJECT:   Lessons  Learned About  Community  Involvement
      Getting  the public  involved  in  Superfund  cleanups  is  an
 important  responsibility all  of us share.  Not only  is  it  the
 right thing to  do  — people should have  a  say  in decisions that
 affect  their  lives  — but often it leads to more successful and
 satisfying outcomes. While we are all  familiar with  our minimum
 legal responsibilities for public involvement, I am  committed  to
 helping you do  more to reach  out  to  community  members at your
 sites and  enable their appropriate and meaningful participation
 in the  cleanup  decision-making process.

      Attached to this memo you will  find ten short stories about
 experiences your colleagues have  had working with the public,
 along with a  two page summary of  some  of the key lessons learned
 (these  stories  are  also  being placed in the Superfund section  of
 the EPA intranet).  The  stories are  told from  the point of view
 of the  RPMs,  OSCs,  and CICs who were involved.  In several of  the
 stories you will also hear from community members.   These  stories
 deal  with  a variety of kinds  of sites  and situations.   All of
 them, however,  show the  value of  sincere efforts to  engage the
 public. I  think you will  find these  stories interesting as well
 as illuminating.

      I  know community involvement is just one  of many site
 factors competing for your time and  attention.  I also  appreciate
 that  you are  busy,  hard  working people so that it may not  always
 be possible to  do all the community  involvement work that  is
 desirable.  You do  have  to set priorities and make choices.
 Nevertheless,  we must remain  mindful of our responsibility to
 include those who will be living with  the remedy in our site
 planning.  And,  at  a minimum,  we must  do our best to:

      — build community  relationships  early in the process.
      — listen  carefully  to what  the public is saying.
      — deal  responsively with major legitimate concerns.
      — explain clearly what  we are planning to do.
      — change  actions where  public  suggestions have merit.

      I believe  these stories  show that community involvement does
make  a difference and,  in many cases,  can do so without unusual
 commitments of  time and energy.   Often all it takes is developing
 a collaborative relationship with a couple of key community
members, who then can do much of the additional work with  you.  I

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hope you will read the stories, discuss them with your
colleagues, and think about ways you can improve upon your own
community involvement practice.

     Thank you for helping to make Superfund a successful
environmental protection program!

                              Steve Luftig
                              Director, OERR

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                              TABLE OF CONTENTS
INTRODUCTION •

KEY LESSONS LEARNED

1  Putting the Responsibility on the Community in Nashua, NH
2  Early Involvement Makes a Real Difference at the Li Tungsten Site
3  Fear Mongering Gives Way to Fact Finding in Palmerton, PA
4.  East Fork Poplar Creek Cleanup Public Participation Helps Save $ 160 Million
5  Successful Partnering with a Community Leader in Michigan City, IN
6  Community Cooperation in Cushing Leads To Effective Emergency Response
7  Jumping on the Community Participation Bandwagon in Jasper County, MO
8.  Loosening the Loggerheads at Leadville
9  Building Ties to the Community Finally Pays Off in Los Angeles
10 EPA Dunking Helps Wash Out Community Resistance

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                                   INTRODUCTION
       The tales you are about to read are REAL  The names of the people involved have not
been changed because we want to recognize their achievements  These are SUCCESS stories
about how your colleague RPMs, OSCs, and CICs have overcome obstacles, inertia, opposition,
and mistrust in the communities where they were doing Superrund cleanups  In reading these
tales you may find yourself nodding in amazement or agreement You may also find yourself
feeling that these cases are the aberrations  Your own experience may suggest that the
approaches described only work in special circumstances But then, that's what many of the tale
tellers thought too, before either  outside circumstances, blind luck, or a flash of inspiration got
them to work on a program of meaningful community involvement. In any case, these tales
should challenge you to reflect on your own understanding and practice of public participation
You probably will  learn something useful.  And at the very least, these tales will give you a few
minutes interesting respite from the stress of your work day.

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                         KEY LESSONS LEARNED
Community Involvement Improves Decision Quality

   o   The community task force made a "significant contribution" to the clean-up effort (Ed
       Als, Region 2 RPM for Li Tungsten)

   o   Significant community involvement in the risk assessment led to a better product and
       increased public confidence in the project. (Fred MacMillan, Region 3 RPM for
       Palmerton)

   o   Getting the public more involved is "the right thing to do and will usually lead to better
       decisions " (David Page, Dept of Energy RPM for Poplar Creek, Region 4)

Build Relationships

   o   "Hang around" in the community and interact with people routinely to show that you are
       sincerely interested in their welfare. (Mike Holmes, Region 8 CIC for Leadville)

  o    Be visible and available  Seek out opportunities to meet with community members during
       their normal activities Always find the time to answer questions and listen to  concerns
       (Paul Groulx, Region 1 OSC for Johns-Manville)

   o   Persist in building relationships and proactively reach out to break through community
       suspicion and opposition   (Mary Kay Voytilla, Region 10 RPM for ASARCO)

   o   Engage in meaningful dialogue and you will minimize delays from public misunderstanding
       and criticism.  (Ed Als, Region 2 RPM for Li Tungsten)

Be Proactive

   o   "If we had proactively gotten the community involved, we would have built trust initially
       Instead, we waited for the community to come to us and by that time they already
       distrusted us " (Noemi Emeric, Region 5 CIC for Michigan City)

   o   "Regardless of how good a solution is, it cannot be implemented without getting people
       on board " (Michelle Pirzadeh, Region 10 CIC for ASARCO)

   o   Providing the community with early drafts of technical documents is worthwhile in the
       long run. (Mark Doolan, Region 7 RPM for Jasper County)

   o   Ask for help.  If you sincerely seek information or support from a community you
       will almost always get something worthwhile  (Dorm Walters, Region 6 CIC for
       Hudson Refinery)

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 Plan Ahead

   o  "Learning what the citizens are thinking far in advance of the development of the
       proposed plan is a tremendous advantage " (Tony Able, Region 4 RPM for Poplar Creek)

   o  Take the time to anticipate public concerns and likely reactions and develop effective
       involvement strategies (Andy Bain, Region 9 CIC for Del Amo/Montrose)

 Cooperate and Collaborate

   o  The sooner you reach out the better  You will be more successful with "early,
       humble coordination " (Rita Engblom, Region 6 RPM for Hudson Refinery)

   o  "If it wasn't for CIC Andy Bain, a genuine partner, I would have given up." (Cynthia
       Babich, community activist, Del Amo/Montrose, Region 9)

   o  Be willing to shed your own preconceptions and to listen to and learn from your critics
       Share ownership, responsibility, work and credit   (Fred MacMillan, Region 3 RPM for
       Palmerton)

   o   Tremendous gains can be achieved by partnering with community leaders to engage the
       public  (Noemi Emeric, Region 5 CIC for Michigan City)

Communicate Clearly

   o   Frequent open and honest communication fosters a high level of trust and cooperation.
       (Mark Doolan, Region 7 RPM for Jasper County)

   o   You will be most successful when you regularly interact with the community and
       proactively share information  in an understandable way  (Paul Groulx, Region 1 OSC for
       Johns-Manville)

Be Creative

   o   Don't be afraid to go beyond the traditional community relations approach   Adapt your
       style and activities to the community (Mike Holmes, Region 8 RPM for Leadville)

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             Putting the Responsibility  on the
       Community in Nashua New  Hampshire
 From 1900 to 1985, the Johns-Manville Company operated an asbestos building-product
 manufacturing facility in Nashua, New Hampshire The City of Nashua condemned the buildings
 in 1994 Fire Chief Mike Buxton brought in EPA because an abandoned building was leaking
 PCBs and there was a risk of fire Many homes, schools, a hospital, and elderly and low-income
 housing developments are close to the site  EPA On-Scene Coordinator (OSC) Paul Groulx
 encouraged the City to participate and they ended up offering funding and other valuable
 resources for this cleanup

 The site was politically complex Dennis Pinski of the New Hampshire Department of Health
 and Human Services says EPA reconized this and, "did a tremendous amount of planning and
 preparation from the outset  EPA was committed to involving the city and the public from day
 one." EPA called a meeting with stakeholders selected by the city. Groulx suggested that the
 community organize a task force to help plan the cleanup  He convinced them that the site was
 their problem, not EPA's, and it was up to them to decide how to proceed  Paul Groulx
 "worked for the community," according to Liza Judge, who had been the Community
 Involvement Coordinator on  site. He saw it as his job to keep people informed and  get their
 buy-in  Groulx says "A lot of effort was expended up front to give them their stake in the effort
 and get them up to  speed  I empowered the community without giving the store away "
 Approximately 50 community members joined the Citizen's Task Force  According to Suzanne
 Simon of Agency for Toxic Substances and Disease Registry (ATSDR), who assisted OSC
 Groulx with outreach programs, "the Citizen's Task Force was expected to interact with the
 EPA, not be locked in battle  Paul Groulx engaged them from the start   He  listened and built a
 foundation based on communication." Lisa Judge adds, "Paul was dedicated to getting to the
 heart of what was bothering people "  We "helped them come to consensus on  how to
 communicate with each other They learned to be clear and concise, and documented what
 happened at each meeting, though it was time consuming," according to ATSDR rep Simon
 This was critical to  the development of trust. Bonnie St Pierre, who chaired the Citizen's Task
 Force says that the  interested support of Paul Groulx was critical  "We were babes in the woods
 and not very political Region 1 helped us along.  They welcomed us and explained why we
 were important We never felt like outsiders We worked side-by-side with EPA. EPA was not
 the enemy, it was there to help us. They told us which meetings were key to attend  They
 taught and  guided us with questions like 'What is your goal?'"

 "Everyone  had the same mission, goals and willingness to keep to the agenda It was a group of
 good workers", said Bonnie St. Pierre  "Everyone tried to be there and work things out. Some
 problems did occur  in the beginning and they were worked out successfully offline," according
to Suzanne Simon  When asked if there was total agreement among stakeholders, Bonnie St
Pierre noted that the Citizens Task Force listened to minority voices  They worked around
problem people and would not permit them to take over meetings. One member was negative

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 and suspicious of the government  The other members told him that they would address his
 concerns one-to-one after the meeting  They gave him a special assignment to collect data to
 support his beliefs

 At first, EPA held public meetings for residents. These never were very well attended  EPA
 found it was better to invite community members to come by the site  Groulx was in the trailer
 the same hours every day  Wednesday night was Open Trailer Night with coffee and cookies
 Community members appreciated Paul's availability, interest and responsiveness  Among other
 things they said  "He always made the time to answer questions and listen to complaints" "He
 never shied away from face-to-face forums " "He was devoted to the site."  "The mission and
 trust communicated by OSC Groulx permeated all the local groups " Task force members
 describe him as exceptional and upbeat — having integrity and openness  Suzanne Simon
 believes "the lead EPA person on a site really sets the tone for how the community works with
 other agencies."

 EPA's initial work plan called for demolition and burial of waste on the property under a cap
 Ultimately the Task Force found it would be more prudent to remove everything and avoid land
 use restrictions and perpetual monitoring EPA and the state worked hard to make the
 community's recommendation work.  "The site team had an ambitious, yet realistic plan and
 battle cry of'ahead of schedule and under budget,'  and they did it," according to Dennis Pinski
 EPA, the State and the Task Force organized a successful media event after the demolition to
 announce the elimination of a serious threat  At the end of the project, the residents held a
 picnic and made mugs to celebrate the cleanup

 "That Task Force is the most impressive  thing I've  seen," said Rod Turpin of EPA As the
 project moves  into a new phase, Fire Chief Buxton  (who gave a professional paper on the
 success of the site) brought in a sign announcing 'The Partnership Continues ' According to
 Suzanne Simon, "for me this site was one of the highlights of the last seven years  I never felt
 more part of a  team."

 Lessons Learned:

 Plan Ahead. The better the plan, the better the project Anticipate problems. Get community
 members involved and working together  and with you from the outset

 Ask For The Community's Help. Members of the community will have valuable information,
 ideas, and energy. Explain that while you care about eliminating the threats and getting the site
 cleaned up, it is the community that has the most stake in the outcome and that its members will
 need to get involved and have sustained participation if the project is to be a success.

 Communicate! Communicate!  Communicate!  You will be most successful when you
 regularly interact with the community and when you proactively share information, good and
bad, in a way that community members understand.

Be Visible and Available  Seek opportunities to meet with community members during their
normal activities such as neighborhood events, fairs, or PTA meetings  Be patient and leave
time to answer questions. Be informal and avoid acting in bureaucratic ways

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  Early  Involvement Makes  a Real Difference
                      at the Li Tungsten Site
 The Li Tungsten cleanup is a good example of how early and meaningful public involvement can
 lead to a better cleanup  Unlike at most other National Priorities List (NPL) sites, the Glen Cove,
 New York community around the Li Tungsten NPL site played a substantive role in planning for
 the cleanup  The Li Tungsten Superfund Site Community Task Force was organized in 1993,
 prior to the initiation of the remedial investigation (RI) to test the effectiveness of early
 community involvement  in the Superfund cleanup process  The Task Force provided assistance
 and valuable input to EPA on the best approach for dealing with soils, sediments and ground
 water contaminated by forty years of tungsten products manufacturing  The Task Force, which
 over time varied in size from 15 to 25 members, represented residents, business interests, local
 environmental organizations, potentially responsible parties, including the site owner, and local
 and state governments  It convened once a month to talk with EPA about the site, to offer
 relevant data and information about community needs and prospective uses of the property, to
 review and comment on  site-related documents and proposed actions, and to help EPA select the
 most appropriate remedy Remedial Project Manager (RPM) Ed Als says that the Task Force
 made a significant contribution to the clean-up effort, primarily through early scoping of issues
 and dissemination of information to the community

 One of the first actions of the Task Force was to form a technical subcommittee to review and
 provide input on the interim remedial action (IRA)  The IRA was necessary to eliminate site
 clutter and dangerous conditions so the remedial investigation could proceed  During this review
 the Task Force stressed the importance of "quick tracking" the site cleanup With this impetus,
 EPA began procurement of the RI subcontracting concurrently with the ongoing IRA activities
 This meant the RI contractor would be ready to start as soon as the IRA was complete

 The Task Force devoted a substantial amount of time to assessing desired future land uses  The
 site borders Glen Cove Creek, which ultimately empties into Long Island Sound.  The nearby City
 of Glen Cove was considering a number of redevelopment options,  including  restoration of its
 waterfront  So determining how the site might be utilized after the  cleanup and how its use
 should fit into other plans for the surrounding community was of paramount importance. With
 the assistance of an able facilitator and technical advisor, the Task Force became very familiar
 with the Superfund "process* and provided inputs and recommendations to EPA about what
 should be done with the site  The RPM believes that the Task Force involvement improved the
 quality of the RI Report and substantially influenced EPA's feasibility study deliberations.

 Ed was skeptical at first about the atypical, expanded level of public participation that was tried at
this site, especially the development of the Task Force charter, which included a significant set of
rules regarding meetings  and membership.  He thought the group was likely to get bogged down
in formality and possibly  even subtract rather than add to the cleanup process  While he still feels
that the group met more  often than was really necessary in the first two years,  overall it has been a

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positive force  A large measure of credit belongs to two capable co-chairpersons and several
"core" members who have worked reasonably and diligently with EPA Given a meaningful role
to play, they have come to appreciate the big technical, legal, and financial issues and have helped
the rest of the community better understand EPA's actions as well as its limitations and
constraints

Lessons Learned:

o  Start Early.  Formation of the Task Force at the outset allowed the membership to see the
Superfund process from beginning to end, which greatly reduced the misunderstanding that leads
to distrust and lack of community cooperation

o  The Public Has Useful Knowledge. The risk assessment was improved because of the Task
Force's input on how the property had been used and the anticipated future land uses  The Task
Force's discussions and input on future land use provided a good foundation for site planning and
decision making

o  Reach Out  Be willing to take time and even go out of your way to keep the community
informed.  Engage in ongoing meaningful dialogue and you will minimize delays from public
misunderstanding and criticism

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   Fear Mongering Gives Way  to Fact Finding

                 in Palmerton,  Pennsylvania

       The Palmerton Zinc Supertund Site consists of a community of 5,000 in a valley
 sandwiched between two former zinc smelting plants From 1898 to 1981 operations from these
 plants resulted in 2,000 acres of denuded mountainside, a 2 V2 mile long "Cinder Bank" composed
 of more than 30,000,000 tons of smelter residue, and contaminated ground water and surface
 waters

       The history of EPA in Palmerton is rife with controversy, much of it from the potentially
 responsible parties (PRPs) themselves and well-organized splinter groups EPA long endured
 accusations concerning its agenda and expertise. And there was copious anti-government rhetoric
 and  assertions that the contamination in Palmerton was not associated with past or present
 industrial practices, but instead was the result of lead paint, gasoline, cigarettes, etc  One of the
 PRPs even threatened to sue Palmerton residents that cooperated with an EPA-sponsored interim
 cleanup of homes

       Following a three-year effort culminating in 1994, EPA successfully "fingerprinted" the
 hazardous metals contamination, proving its overwhelming industrial origins  The information
 was irrefutable Rather than using these results as a club, EPA used them to reach out to its
 critics and supporters alike and involve them in the next step of the process, the risk assessment

       The same day the chemical fingerprinting data was released, EPA invited all stakeholders
 to provide input to what would become one of the most complicated risk assessments the Agency
 had ever undertaken. Within weeks, community members and others submitted good ideas on
 how to approach the risk assessment and helpful information about things such as housecleaning
 practices, resident longevity, and land use practices  All of this input was ultimately used in and
 helped strengthen the risk assessment.

       Not long after EPA's invitation for ideas and data, a PRP-fiinded community group, the
 Palmerton Environmental Task Force (PETF), offered to conduct the risk assessment EPA said
 this would not be possible, but extended the group an invitation to participate as colleagues in the
 process  Fred MacMillan, the Remedial Project Manager (RPM), coordinated the effort for EPA
 and arranged for regular meetings between PETF,  the PRPs, and EPA's risk assessment
 professionals  These meetings were held on a rotating basis in the Region's offices in Philadelphia
 and in Palmerton every two weeks for almost two  years   It was a very open process. Data,
 methodology, issues and concerns were all freely shared and discussed. PETF members took
 minutes of the meetings and published a newsletter to explain the process and keep the
 community informed about the group's progress. Despite individual agendas, which still surfaced
occasionally, the risk assessment itself was handled in a collegial fashion  A noteworthy example
was the group's agreement on the need for "bioavailability studies" for lead. Bioavailability
studies help determine how much of an environmental contaminant like lead in soil is actually
absorbed from exposure (e.g. ingestion). Fred arranged to have soils from Palmerton dovetailed

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 into a bioavailability study in progress at EPA Region VIII during the course of the risk
 assessment   One of the PRPs helped EPA gain access for sampling and provided necessary
 laboratory pre-screening of the soil samples used in the bioavailability study

       The exchange of technical data was so complete that both EPA and PETF had sufficient
 information to "crunch the numbers" to determine risk levels for contaminants of concern  EPA
 then shared a preliminary draft of the risk assessment with the PETF and the public This led to
 additional input that resulted in some valuable corrections to the data  By involving members of
 the community in the actual work of the assessment, EPA not only gained helpful information, but
 also established a high level  of public confidence No one complained about the process or felt
 blind-sided by the results  Although not everyone was pleased with the conclusions of the risk
 assessment,  no one felt left  out of the process

       EPA and the Palmerton community gained far more than just a completed risk assessment
 from this exercise; things like a better understanding of people's misgivings about a very technical
 process that affects them, a greater respect for EPA use of that process to ensure protectiveness,
 and perhaps most important, a sense in each of what is important to the other. A few things did
 get lost along the way, like some distrust and preconceptions Nobody missed them

 LESSONS LEARNED:

 Don't Ignore Community Involvement Increased public /stakeholder involvement is here to
 stay Don't run from it, manage itl If you communicate with all parties openly, early and often
 you will be more successful and have fewer headaches

 Be Organized  Help the community to establish and manage a coordinating committee Make
 sure the group has clear goals and good ground rules Explain constraints.  Establish a schedule,
but be flexible in providing additional time to develop community acceptance

Let Go of Your Ego  Be willing to shed your own preconceptions and to listen to and learn from
your critics  Share ownership, responsibility, work and credit.

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            East Fork Poplar Creek Cleanup
 Public Participation Helps  Save $160 Million
       During the 1950s and 1960s, the lower east fork of Poplar Creek in Tennessee was
contaminated with over a quarter million pounds of mercury from the production of nuclear
weapons at the Oak Ridge Reservation When the Department of Energy (DOE) began to plan
the cleanup in 1993, its preliminary estimate was that the project would cost $168 million. Four
years later, a proposed remedy costing only $8 million was selected  Public participation was
crucial in achieving this $160 million savings according to the DOE Program Manager, David
       Early in the planning process, DOE set up a citizens working group (CWG) that played a
major role in the remedy selection process  Thirty-one people volunteered to participate
(everyone who indicated an interest was included in the CWG) with the understanding that there
would be a meeting a month over an extended period of time. Because of the CWG members'
interest and involvement, the group actually met almost every two weeks for fourteen months
Early on, the CWG asked insightful questions and pushed DOE to justify assumptions about
exposure, toxicity, cost, and cleanup impacts  This led DOE to reconsider the threats posed by
the type of mercury that was present and a revision of the proposed cleanup level from 50 parts
per million to 180 parts per million  Subsequently, the cleanup level was once again revised to
400 ppm This occurred because the CWG, not the government, developed a persuasive case that
the reduction of risk to human health and the ecosystem did not justify the expenditure of tax
dollars necessary to achieve the more stringent cleanup level

       David Page says that getting the public more involved is "the right thing to do and usually
will lead to better decisions " He believes that even without such substantial dollar savings, the
$250,000 that DOE spent on community involvement work would have been worthwhile in terms
of citizen goodwill and satisfaction with the outcome  Tony Able, the EPA Remedial Project
Manager who partnered with David Page, agrees that more community involvement earlier in the
process is a real asset.  He says that "learning what the citizens are thinking far in advance of the
development of the proposed plan is a tremendous advantage "

Lessons Learned:

o Don't underestimate the value of public input Even in the absence of technical expertise,
citizens have ideas and perspectives that can make a real difference in the success of the cleanup

o Develop trust  Openness on the part of the government plus ownership through involvement
of the community establishes the trust that enables better decisions to be made

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      Successful Partnering with a Community
            Leader in Michigan City, Indiana
 After a ten-year process, the Waste Inc  Site in Michigan City was finally cleaned up in 1997.  The
 community involvement effort at this former municipal landfill was complex due to high levels of
 distrust When EPA began work, the Army Corp of Engineers was completing a dredging project
 adjacent to the site  The community was upset with the way the dredging was handled and also
 because no community members were given an opportunity to participate in the decision-making
 process Unfortunately, the EPA site team when the project began refused to discuss with the
 residents their concerns about the dredging project -- "a big mistake" according to Remedial
 Project Manager (RPM) Dion Novak. This situation was complicated by the extensive number of
 potentially responsible parties (PRPs). Many of these PRPs were small businesses who were angry
 because they did not understand why they should be held liable for following accepted practice for
 routine disposal of their wastes

 Save the Dunes, a local organization, sued to get the site cleaned up According to its Executive
 Director, many PRPs (including the City and politicians) were in collaboration to delay the
 cleanup The local newspaper, a PRP, did not publish the notice of a 30-day review period for the
 consent order until the review period was over To compound this error, EPA said that if the
 residents still wanted a 30-day comment period, which is not legally required, it would delay
 cleanup This upset the community, even though the Region's intention in providing the review
 had been to improve its relations with the public

 One of the things that helped begin to turn the situation around was when EPA formed a
 partnership with Danielle Livinghouse of the LaPorte County Health Department and Rhonda Lee
 of the local Minority Health Coalition Lee began to work as a community leader, assisting EPA by
 identifying interested residents and other key stakeholders, and communicating with the
 community, particularly hard-to-reach citizens Soon the distrust started to fade

 Community Involvement Coordinator Noemi Emeric worked closely with Rhonda Lee and kept
 her fully briefed on EPA's evolving plans for the site. In turn, Lee helped Emeric to better
 understand the community's needs and ways to communicate effectively with it. Emeric also helped
 to prepare  Lee for her leadership role Rhonda Lee reports that she received valuable training that
 made her a better liaison She began to advertise and host meetings, go  door-to-door giving out
 flyers, and invite EPA as her guest She used her own personal experiences to make information
 understandable and user-friendly  The working relationship between EPA and the community
 steadily improved

Further gains were made through informal get-togethers,  where key players got to know each
other as people Prompt responses to phone calls, letters, and other community concerns were all
keys to building trust The partnership organized an appearance on a local talk show with the
county health department and local emergency planning agency to discuss site activities and
progress

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 EPA looked for opportunities to involve the public in decisions at all levels For example, when a
 "No Fishing" sign was needed at the site, the Region asked the community to design it  When the
 remedy was selected in 1994, EPA sought input from the community and incorporated many
 comments into the ROD  These included adding a contingency to contain deep ground water at the
 site, removing an underground storage tank, improving site security, and using a synthetic cap,
 rather than one made from natural materials.

 After the cleanup was completed, the site team worked with stakeholders, including the PRPs, to
 host an open house to celebrate the success of the partnership The Mayor and EPA staff
 described the clean-up efforts to a group of elementary school students.  This included photographs
 of the cleanup and  a site tour for the students. The local newspaper, radio and television stations
 documented the event  "The celebration was a great opportunity to applaud the community's
 involvement and efforts," according to Emeric

 In the end, everyone was working cooperatively together toward the same goal The community
 groups felt EPA learned to listen and changed its perception of the value of public involvement in
 the project.  The Region "operated in good faith and  kept [its] word" said Danielle Livinghouse
 According to CIC Emeric,  "the level of community involvement was great -- phone calls were
 returned quickly and folks saw enough progress that they didn't feel it was necessary to come to
 meetings  The community  was more willing to accept EPA's decisions "
 Lessons Learned:

 Enlist the Help of Community Leaders.  Tremendous gains can be achieved by  partnering with a
 community leader to engage the public  Utilize a few key people with influence to assist in building
 larger community relations  and trust

 Be Proactive.  Get out into the community. Don't wait for the community to come to you Find
 the time to carefully listen to the concerns of the public. Be willing to talk about any issue the
 residents want to discuss, even if it is not directly related to the site  Follow through on your
 commitments

 Explain What Is Going On. At the outset, describe clearly what you plan to do and how the
 community can be involved. Provide your objectives  and a realistic schedule  Also educate the
 community about the  limitations of your authority and other relevant constraints.

Maintain the Same Site Team.  Consistency  with EPA site personnel goes a long way in building
trust and showing a dedication to the community's long-term interests.

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         Community Cooperation  in Gushing
     Leads To Effective Emergency Response
       Students at the middle school of this small Oklahoma town were concerned about the old
 Hudson Refinery site  They started a letter writing campaign to get public officials to investigate
 the refinery that had been left inactive since 1982  This was not the first time the site came to the
 attention of EPA In 1987,  EPA and Hudson Oil and Refining Company had signed a Final
 Consent Decree ("FCD") which set aside $1 million for some cleanup and closure of the facility
 In 1994 a U.S District Court issued an Order for Closure of the consent  decree when available
 resources had been exhausted even though the requirements of the FCD had not been completed
 At least partially as  a result of the students' initiative and persistence,  EPA came back to the site
 in the summer of 1998 and discovered friable asbestos containing material torn and hanging from
 refinery equipment. The Agency determined there was an imminent and substantial threat to
 public health and the environment and quickly mobilized for an emergency response.

       More than a month after the response was underway, Rita Engblom, the on-scene
 coordinator, was alarmed at the discovery of a corroded tank of anhydrous hydrofluoric acid
 (HF) releasing HF vapors It was quickly determined that this tank, with the potential to release
 enough HF to cause a 6 mile plume, posed a significant danger to the community  This discovery
 lent a new urgency to the cleanup action.  Over 400 people lived within a quarter-mile of the site
 They would have to be evacuated during the transfer of HF from the storage tank  Engblom and
 community involvement coordinator Donn Walters agreed that early and frequent coordination
 with local officials and citizens would be helpful. The results of their proactive coordination
 efforts exceeded expectations. By reaching out to the community the they found invaluable
 support for this emergency action  In addition to gaining information about the plant from people
 who had worked there when it was active, the local government staged much of the support for
 the HF transfer.

       The city manager brought in representatives from the fire and  police departments, the
 emergency planning office, and local hospital. This coordination and planning group, which came
 to include staff from the State and other Federal agencies, continued to meet regularly
 According to Engblom, it "took out of my hands" a lot of the time-consuming logistical work in
 getting ready for the one-day evacuation The group did not rely on the typical use of newspaper
 notices and fact sheets to keep the community informed  On several occasions, local fire and
 police personnel went door-to-door in the area to be evacuated. They handed out flyers,
 explained and updated the situation, reassured the residents, and delivered details about safety
 plans  Local ministers volunteered to keep their congregations aware of the latest developments

            EPA, the Oklahoma Department of Environmental Quality ("ODEQ"), the City of
Gushing, the Local Emergency Planning Commission, and the local Police and Fire  Departments
conducted a public meeting a couple of weeks before the agreed upon evacuation date  This
meeting was held to provide information about the recommended evacuation of residents The

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 door-to-door efforts led to a large turnout   While the meeting hall was packed, it was not with
 anxious or upset people  Everyone was calm and the meeting proceeded in an orderly,
 cooperative atmosphere, unusual given the nature of the potential danger. The meeting was
 broadcast and rebroadcast by a local network station to ensure everyone in the community would
 be fully informed

        During the evacuation, the City opened the Youth and Community Center for anyone who
 needed a place to stay  The ODEQ assisted EPA with the press  The local fire department loaned
 equipment, the highway department re-routed traffic, and the police department guarded vacated
 homes. The United States Coast Guard set up decontamination facilities The American Red
 Cross set up a kitchen and a first aid station   The State Emergency Management  Commission
 provided assistance with pets And several local businesses donated their services, such as
 supplying food to people involved in the evacuation. As a result of all this, though the evacuation
 itself was stressful, it proceeded smoothly with the community bonding together in support of
 EPA

       Reflecting on the effort, Engblom says that everyone involved was unbelievably helpful
 She adds, "the key was early, humble coordination "  She didn't wait to disclose any information
 until she already had a plan or knew the all the implications  She had developed such a good
 working relationship with the community representatives that she felt comfortable  sharing
 information as it was developed  and as a result "got a lot more help than I ever imagined."
 Walters too was impressed by the contribution of local organizations.  He emphasizes that it was
 "a total community effort with outstanding cooperation and partnership by all the parties
 involved " The State, which played an active role in the response partnership, also was
 significantly impressed with EPA's efforts to be inclusive Mark S Coleman, Executive Director
 for ODEQ writes, "  inclusion of the local community early in the process ensured that the
 recommended evacuation proceeded smoothly"

 Lessons Learned:

 o  Ask For Assistance. If you sincerely seek information or support from a community you will
 almost always get something worthwhile. And you will probably be pleasantly surprised at how
 much useful help and  support does come your way

 o  Partnership Pays Off.  In an emergency situation, collaboration may seem like a luxury. It
 almost never is  The time spent building strong working relationships will be returned multifold in
 valuable good will and support that can make a crucial difference

o  Early Involvement Is Key.   The sooner you reach out the better.  This helps to demonstrate
your interest and commitment and sets the stage for the cooperation from the community.  The
longer you wait to involve others the harder it is to get started and the fewer good  ideas you will
have as timely input.

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    Jumping  on the  Community  Participation

 Bandwagon in Jasper County, Missouri

       Between 1850 and 1970, Jasper County was at the heart of one of the highest lead and
 zinc production areas in the world The wastes from the operations polluted surface water,
 ground water, and soil.  Over 2,400 residential yards were contaminated with lead above
 acceptable levels. In 1995, at the completion of an exposure study which showed elevated blood
 lead levels in residents, Mark Doolan, the Remedial Project Manager (RPM), planned an
 availability session with local government officials to talk about the results  He orchestrated
 extensive local media coverage and sent out 30 personal letters of invitation, but only three
 officials attended  Not willing to give up, Doolan personally contacted the Mayor of the City of
 Joplin to explain the seriousness of the situation and to seek his support  That very evening the
 City Council was told about the problem and agreed to establish a community advisory group
 (CAG) to work with EPA in planning and conducting the response.

       The CAG has been a big success, according to Earl Carr, the CAG Chair  It has been
 much more than just an  effective way of getting everyone with an interest in the site talking and
 working together  The CAG has become a catalyst for planning and implementing a number of
 health and environmental activities beyond the scope of what EPA is able to do  For example,
 the CAG has sponsored the delivery of local health education programs for school children, the
 development of a Lead Poisoning Prevention merit badge for the local Girl Scout chapter, and
 applied for and been awarded a $1 million grant from the Department of Housing and Urban
 Development for interior lead paint abatement.

       All of these efforts have contributed to the feeling on the part of the citizens that they  are
 involved and making a difference  Mark Doolan believes this positive outlook has carried over to
 help EPA accomplish its responsibilities more smoothly  The community bought into EPA's
 proposal for treatability  study of an innovative technology, phosphate stabilization of metals.
 Without a good rapport with the community Doolan knows he would have had a difficult time
justifying the approach and getting support for it

       The success that Doolan has had results from his willingness to go well beyond a good
 communications strategy. Previous to joining EPA as an RPM, he was a consultant who had
 extensive experience at Superfund sites He says, "the sites that had the most problems with
 remedy selection were generally the ones where the least community involvement work had been
 done "  Consequently he always invests a considerable amount of his own time, about 30% over
the first year, to direct contact with community members  And he looks for ways to provide
support and service that  will demonstrate his interest in the welfare of the community. For
example, he organized a public "risk assessment 101" course that helped lay the foundations for
acceptance of the risk management decisions being made He also arranged for the community to
receive $200,000 (part coming from response funds and part from discretionary Regional funds)
to develop its own environmental masterplan This plan included institutional controls that EPA

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 otherwise would have had to develop

       Although he is a believer in openness and sharing of information, Doolan was at first
 reluctant to convey early drafts of technical documents to the community  In part this was
 because of one environmental activist who tended to overreact to every new piece of data, making
 life much more difficult for EPA But Doolan found that the early consultation helped build more
 trust over time  And while he still is frustrated sometimes with the reaction he gets from the
 environmentalist, the two of them now a have a basic respect for one another and are able to have
 a constructive relationship

 Lessons Learned

 Involvement Is A Good Investment. Efforts to include the community up front pay big
 dividends in terms of  acceptance of EPA actions and result in a more effective remedial action

 Think Communication. Frequent open and honest communication with the community has
 fostered a high level of trust in EPA and its actions, and has created a true spirit of cooperation
 with the community

Be Open. Providing the community with early drafts of technical documents for review and
comment is worthwhile in the long run even though it may cause short term disagreements and
difficulties

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     Loosening the  Loggerheads at Leadville:
                Community Involvement by
                        "Hanging Around"
       Starting in 1983 EPA began planning for a Superfund cleanup of the California Gulch
 mining site in Leadville, Colorado By 1995 the Colorado legislative representative from the
 community was suggesting that EPA staff be hanged at the city limits  Today EPA is working in
 partnership with local leaders to complete a successful cleanup  What turned this situation so
 dramatically around1?

       One big factor was the appointment of Mike Holmes,  a former On-Scene Coordinator, as
 the new Community Involvement Coordinator.  He took the hanging comment as good, free
 advice~and began spending a significant amount of time "hanging around" in the community
 making conversation and learning about its culture and concerns. Mike says that in this kind of
 situation you can't be "an occasional visitor You must be there regularly, listening and
 responding in a neighborly way "  You are going to increase your chances of success if "you pay
 close attention to what the community is worried about and make its agenda part of your own "
 Mike adds that you must avoid the temptation to lecture the community and to have an attitude
 that you are there to save it  Instead, find out what it perceives as the primary threats and deal
 with them along with the problems that are on your agenda For example, while EPA's priority
 remained  the reduction of the possibility of child ingestion of lead, the EPA team began to focus
 more attention on the stream quality and fishing, on reducing the impacts to the Arkansas River,
 and on improving recreational opportunities These were the  issues at the top of the community's
 list of concerns In addition, Mike and the EPA team undertook several innovative initiatives
 They

    — supplemented monthly public meetings by sitting down in residents' living rooms and
      talking with, not to, them
    ~ held weekly dialogues with county commissioners to listen to their concerns and to
      exchange ideas
    -- showed respect for Leadville's mining heritage by working with the town to develop an
      historic preservation plan that would help guide cleanup decisions
    - demonstrated EPA's responsiveness by initiating a series of small removal actions targeted
      to the community's most important concerns.

Although  time-consuming, establishing a presence in the community — hanging around « was the
keystone of the team's efforts. Informal face-to-face  conversations with EPA staff, not with
contractors, made the difference For the first time there was  real communication  This led to
understanding and eventually the trust needed to move forward  The turnabout was so complete
that the team was invited to the wedding of a county commissioner's daughter* I

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Lessons Learned:

Build Relationships. Invest the substantial amount of time necessary to show the community
you are "real people" sincerely concerned about its well being

Be Creative.  Don't be afraid to go beyond the traditional community relations approach
Adapt your style and activities to the community

Show Progress. The best community relations tools are often "bulldozers and backhoes" that
demonstrate EPA is serious about completing the cleanup and getting out of town

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  Building Ties  to  the Community  Finally Pays

                             Off in Los  Angeles


 Located in a mixed industrial and residential area of Los Angeles County, the Montrose Corporation site was
 the west coast's largest manufacturer of DDT  Plant operations significantly contaminated storm sewers,
 groundwater and soils close to the plant, as well as Pacific ocean sediments  Across the street, the Del Amo
 Waste Site, a former synthetic rubber manufacturing plant, is about 50 yards from a number of residential
 backyards. In 1991 the Region 9 team inherited the Del Amo site from the State of California, along with a lot
 of community distrust and ill will

 EPA's biggest challenge was to address community fears about possible adverse human health impacts  The
 neighbors' concerns were heightened when, in 1994, EPA discovered bowling ball-sized chunks of DDT
 contaminated fill buned in two residential yards Region 9 began a time critical removal action, but did not
 adequately develop its risk communication messages  This had the unfortunate effect of adding to existing fear
 and suggesting to the community that it was at high nsk of exposure  To address community health concerns,
 EPA and Agency for Toxic Substances and Disease Registry (ATSDR), cooperated to open a clinic to evaluate
 the health impacts from both sites

 The Del Amo Action Committee (DAAC) is a citizen's group headed by Cynthia Babich.  She is a local
 community organizer who was personally affected by the DDT fill  She says some in the community became
 frustrated when there was no quick information available, when information was only provided when the
 community asked the right questions, or when the information was too technical or inconsistent (i e, data
 sometimes given as parts per million and at other times as parts per billion)  For already fearful residents,
 confusing or incorrect information easily sparked mistrust  Rightly or wrongly, due to the prior history of
 problems with state regulators, the residents tended to interpret miscommumcations as deliberate attempts to
 withhold information or mislead

 The DAAC requested an extensive permanent relocation of residents This put the site team, which wanted to
 be responsive to the community and build credibility, in a bind. EPA management believed that relocation was
 unnecessary. Finally agreement was reached to temporarily relocate 30 families during the excavation work
 Then it was difficult to get the residents to move back  This resulted in greatly expanded costs and excessive
 time needed for the cleanup while addressing only a fraction of the problems at both sites

 Site team members often were overwhelmed by these and other social issues, according to  Remedial Project
 Manager Bruni Davila.  Since other agencies on the project, like the Army Corps of Engineers, had no public
 participation experience or community involvement training at all, the site team bore the brunt of citizen
 interaction  This resulted in considerable stress that led to much burnout and subsequent team turnover  The
 community was frustrated by this turnover and by continually having to get new staff up-to-speed

 Ultimately, the Region undertook to overcome the community resistance with a proactive, energetic, and
 focused effort to reach out to community members. The site team developed a strategy to engage the
community The team offered workshops and poster board sessions about site problems and clean-up
solutions, did door-to-door neighborhood visits and dialogues with focus groups, distributed many readable
fact sheets, and established a community accessible database of resources on the Internet.  At the request of
Congresswoman Harman, negotiations between the Del Amo PRPs and the community took priority over the
response work  In March 1997, EPA facilitated a successful private buy out deal between  the Del Amo PRPs
and 65 neighbors living closest to the site

Because of the attention and persistence, the site team's relationship with the community finally began to

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 improve According to Cynthia Babich, "if it wasn't for Community Involvement Coordinator Andy Bam, a
 genuine partner, I would have given up  The present EPA team works hard and has been highly committed and
 motivated "  Eventually, the community accepted compromise solutions based on an increasing trust in EPA
 For example, during the public comment period for the Del Amo Waste Pits, the community reviewed the five
 remedies in the proposed plan and overwhelmingly supported EPA's preferred cleanup alternative  Later on
 there was a very positive and collaborative DDT fill removal that was accomplished with care to ensure no dust
 was generated A Community Advisory Panel, organized  by both EPA and the Del Amo PRPs, is now
 focusing on land reuse options, such as a neighborhood park and multi-use center, to be funded by the PRPs

 Lessons Learned:

 Plan Carefully. Take the time to anticipate the public's concerns and likely reactions and develop effective
 involvement strategies Be consistent about EPA plans and clear on the difference between community assisted
 decisions and ones which the agency has little discretion to share

 Be Calm And Patient. Listen to cnticism and "venting" without getting defensive
 Coordinate With Other Agencies. Work in partnership with the State, ATSDR and others  Community trust
 and acceptance is greatly strengthened when all responders cooperate and have mutually shared objectives
 Plan And Manage Meetings Well. Have ground rules that ensure everyone has a voice, including non-
English speakers  Keep the microphone open and moving around the audience Give community groups an
opportunity to speak at the start of a meeting to reduce tension and opposition.

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              EPA Dunking Helps Wash  Out

                     Community Resistance

 The Asarco Tacoma Smelter is located along Commencement Bay in Ruston, Washington, a small
 town surrounded by the metropolitan city of Tacoma  Owned by ASARCO, Inc, the smelter
 processed lead and copper for close to a century  The plant released sulfur dioxide gases and dust
 particles (containing arsenic and other metals) into the air Much of the dust settled nearby
 contaminating the soil and the waters of Commencement Bay  ASARCO poured hot slag, a waste
 product of the smelting process (containing lead, arsenic, copper, and other metals), into
 Commencement Bay to cool and harden, creating an artificial shoreline  Some slag was cooled on
 land, resulting in a black, rock-like material that was sold to residents and businesses in the
 community for landscaping purposes, driveways, sandblast grit, fill, and other purposes  The clean-
 up involved smelter demolition, site and marine cleanup, and residential soil cleanup

 An expedited action to clean up eleven of the most seriously contaminated properties showed
 Region 10 a hint of the problem it faced The property owners refused access because they did not
 think any response was necessary.  Residents were distrustful of government and its warnings of
 health risks with no  irrefutable causal link  And they were loyal to ASARCO, the town's sole tax
 source which had employed the residents for generations  When the company made the business
 decision to close and move overseas, the Ruston community blamed EPA for the job losses

 Cleanup of hundreds of residential yards still needed to be done  Region 10 management realized
 that if it did not change and find a way to break through the resistance,  the community would block
 the work  According to Community Involvement Coordinator Michelle Pirzadeh, "regardless of
 how good a recommended solution is, it cannot be implemented without getting people on board
 To prove ourselves we needed to visibly address concerns, follow through on promises and build
 trust - with no surprises"

 The Ruston/North Tacoma Community Workgroup formed in 1990 when the planning for the
 residential cleanup began  The workgroup included community members and met on a monthly
 basis until the start of cleanup activities in 1993  Initially, the workgroup was somewhat negative
 and reactive, according to Mary Kay Voytilla, Remedial Project Manager for the residential area
 Workgroup members would not actively engage in discussions about how the cleanup could best
 meet the needs of the community. Instead they questioned the need for the cleanup  Charlene
Hagan, Town Council  member, described the relationship between EPA and the community as
adversarial  "EPA was heavy handed and the community operated like a lynch mob "

The members of the site team recognized it would have to redouble its efforts to reach out and
include the community in cleanup They became more personally involved and began knocking on
doors, interviewing residents on the process and the type of involvement desired  They held
workshops and created opportunities for dialogue, such as one-on-one availability sessions.  For the
first time, residents began to feel that EPA really was listening to and interested in what they had to
say.  The site team took other steps to reach out and get involved in the community

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 o Clayton Johnson, a Ruston resident, was asked to be the community liaison and serve as EPA's
 eyes and ears at key meetings  He answered resident's questions and help to facilitate issues even
 though some community members still saw him as an EPA spy

 o EPA formed the Ruston/North Tacoma Coordinating Forum to facilitate discussion and
 coordination among the various agencies and organizations involved in or affected by the
 residential cleanup  The Forum assisted in the development and selection of a remedy that would
 be implementable in the community

 o The site team stopped holding large meetings   Instead they used smaller public meetings in
 residents' homes

 o Fact sheets, mailers and a Residential Soils Bulletin on the progress of the cleanup were routinely
 distributed to residents, property owners, business and schools  Under a cooperative agreement,
 the Tacoma-Pierce County Health Department developed two brochures related to the handling
 and disposal of contaminated soil

 o The Region provided informational brochures and bankers'  seminars for professionals involved in
 property transactions  They wrote up typical real estate questions and answers related to property
 values and set up a database for property transactions

 o The site team showed its commitment to the community by volunteering at a local fund raising
 event to be dumped in a water tank

 Lessons Learned:

 Community Buy-in Is Critical. Regardless of how good a technical solution may be, it will not
 be successful without community support

 Resistance Is Not The End Of The Road.  Persist in building relationships and proactively reachm| out to
break through suspicion and opposition                                                *

Create A Community Liaison.  A resident who is willing to served as a go-between and facilitator is an
invaluable resource.

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