United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
&EPA
DIRECTIVE NUMBER:
9375.1-^-k
TITLE1 State Participation in the Superfund Program Manual
Appendix K - Community Relations Plan Format and
Sample Plan
March 24, 1986
March 24, 1986
OERR
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
^0 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
9375.1-2 State Participation in the Superfund Remedial
Program, February 1984 (August 1985 reprint)
OS WER OS WER OS WER
: DIRECTIVE DIRECTIVE Dl
-------
__
United Slates Environmental Protection Agencv
f Washington. DC 20460
Interim Directive Number
9375.1-4-k
&EPA
OSWER Directive Initiation
__ Originator Information
Mail Coda
WH-546E
Name of Contact Person
Debbie Swichkow
Lead Office
Signature of Office Director
D AA-OSWER
Title
Appendix K, Community Relations Plan Format and Sample Plan
in the;State Participation 1n the Superfund Program Manual, Volume 1)
Represents a carefully constructed consensus as to how to enable an
!hnoS!tV%JOIIlinunit^relat1ons ?rogram 1n the course of enforcement.actions
?Thil tlr^Ll*™ t me Perserv1"9 the Integrity of the enforcemeat,,process.
PhlnJJJTf VJu*1!0 b61"9 US6d Wlth Sl1ght "wdlflcatlon and Interim Guidance
- Chapter VI of the Community Relations Handbook (see 9230.0-3-a)
fey words: Superfund, CERCIA, remedial program, state participation
cooperative agreements, community relations, enforcement.
enforcement action
I Type of Directive (Manual. Potoy Omctiw. Announumuti. tte.1
Does this Directive Supersede Previous Directive^)?
If "Yes" to Either Question. What Directive (number, title)
Status
D Draft
D Final
Does It Supplement Previous Directive(s)?
Q New
LJ Revision
Yes
No I
Review Plan
U AA-OSWER O OUST
D OERR D OWPE
D OSW D fleQlon9
This Request Meets OSWER Directives System Formal
Signature of Lead Office^ireqtives Officer
D OECM
D OGC
" OPPE
D
Olher (Specify)
Signature of O^WER Oirecti
EPA Form 1315-17 (10-85)
Date
Date
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_
•>
s +S/J » UNITED STATES ENVIRONMENTAL. PROTECTION AGfc'NCY
WASHINGTON DC 20460
9375.1-4-k
MEMORANDUM
SUBJECT: Addendum to the manual State Participation in the
Superfund Program -- Appendix K, ''Community -
Relations Plan Format ^d Sample Plan"
FROM: Sam Morekas, Chief V)
State and Regl onal Xoordfnat Ion Branch
Hazardous Site Control Division
TO: Mailing List
RplatnneD majer1a1 Included as Appendix K, "Community
thl n Kif +?" F°;mat and Samp1e P1an"> has be^ extracted from
the pub icat on Community Relations in Superfund; A Handhnnfc
JS *u I!''1!1 • reflects a revTslon of the Intet-m version of
the Handbook issued in September, 1983. This material has
been rewritten to reflect additional years of experience in
Ml ™i:j|C°T!lty re1at1ons Activities at Superfund sitSs.
far J??Slil; I ? H -6 [eV1Se^ mater1a1 ^ on practical guidance
I^P II 9 andulinPleinenting community relations activities
rather than on the rationale for such activities.
mater1a1 is s^1! considered DRAFT guidance, it
Attachment
-------
Date/
Addendum #
Topic
6/22/84 #1 Site Closeout
9/12/84 #2
9/28/84 #3
Minority and
Women's Business
Reporting
Changes to IG
Audit
Quality Assurance
Project Plan
Revised Letter of
Credit Procedures
Provision
CHANGES TO DATE
Instruction
. New pages
. New page
. New pages
. New page
Change
"... which must
be sent within
120 days." to
"... which
must be sent
within 90 days."
Add, as the
second sentence
in the para-
graph, "In
addition, the
Award Official
will send the
State a copy of
the final audit
report within 15
days of its
receipt."
Change "The re-
sponse must be
dispatched with-
in 120 days..."
to "The response
must be dis-
patched within
90 days..."
New pages
Replacanent pages
9375.1-4
3/24/86
Revised Page iii
Location/Page
Appendix F, Pages P-22
and 23
Appendix H, Page H-23
Appendix P, Pages
P-37-P-47
Appendix F, Page F-24
Appendix C, Page C-12,
first complete paragraph
Appendix C, Page C-12
first complete paragraph
Appendix C, Page C-12
footnote
Appendix L, formerly
reserved
Appendix F, Pages F-3
through F-6
111
-------
CHANGES TO DATE (Continued)
Date/
Addendum #
12/10/84 #4
Multi-Site Coop-
erative Agreements
Instruction
Replacement
pages
Replacement
pages
Replacement
pages
Replacement
pages
New pages
Replacement
page
New pages
Replacement
pages
New pages
Replacement
page
New page
Replacement
pages
New page
Change "...at
quarterly inter-
vals commencing
at the start of
the project." to
"...within 30
days of the end
of the Federal
fiscal quarter."
New pages
Replacement
pages
New pages
Replacement
pages
Replacement
pages
New pages
'j 375.1-4
3/24/86
Revised Page iv
Location/Page
Table of Contents, Pages
xin through xvii
List of Exhibits, Pages
xvii and xix
List of Acronyms, Pages
a - through e
Chapter II, Pages II-1
through 6
Chapter II, Page II-7
and Exhibit II-2
Chapter III, Page 111-17
Chapter III, Pages
111-18 through 27 and
Exhibits 111-10 and
III-ll
Chapter IV, Pages
IV-5 through IV-7
Chapter IV, Pages IV-8
through IV-11
Chapter V, Page V-7 and
V-8
Chapter V, Page V-9
Appendix E, Pages E-l
through E-22
Appendix E, Page E-23
Appendix F, Page F-lb,
Section K, indented
paragraph
Appendix F, Pages F-25
and F-26
Appendix J, Pages J-l,
J-2, and J-7
Appendix J, Pages J-8
and J-9
Appendix N, Pages N-l
through N-6
Appendix P, Pages P-l,
P-2, and P-47
Appendix P, Pages P-48
through P-51
iv
-------
Date/
Addendum #
1/4/85 #5
Topic
Advance Match
CHANCES TO DATE (Continued)
Instruction
New pages
1/11/85 #6 Site Safety Plan
Guidance
8/2/85 #7 Obtaining Equipment
Under a CERCIA
Cooperative Agreement
9/17/85 #8 Intergovernmental
Review Procedures
State Cooperative
Agreements for Pre-
Remedial Activities
12/18/85 #9 Action Memorandum
Guidance
12/20/85 #10 Model Statement of
Work for a Remedial
Investigation/
Feasibility Study
12/20/85 #11 Site Safety Plan
Guidance
1/31/86 #12 Quality Assurance
Project Plan
. New pages
. New pages
. Replacement page
. Replacement pages
. New pages
Replacement pages
Replacement pages
. Replacement pages
. Replacement pages
. Replacement pages
. Replacement pages
3/5/86 #13 Superfund Supplement . Replacement pages
Guidance
9375.1-4
3/24/86
Revised Page iva
Location/Page
New Appendix S, Pages
S-l through S-9
Appendix M, formerly
reserved
New Appendix T, Pages
T-l through T-15
Table of Contents, Pages
xiii through xix
List of Exhibits, Pages
xx and xxi
Appendix D, Pages D-l
through D-28
Appendix A, formerly
reserved
Table of Contents, Pages
xiii through xix
Appendix B, Pages
B-l through B-9
Table of Contents, Pages
xiii through xix
Appendix E, Pages
E-l through E-21
Table of Contents, Pages
xiii through xix
Appendix M, Pages M-l
through M-28
Table of Contents, Pages
xiii through xix
Appendix L, Pages L-l
through L-12
Table of Contents,
Pages xiii through
xix
Appendix P, Pages P-l
through P-16
iva
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9375.1-4
3/24/86
Revised Page ivb
CHANGES TO DATE (Continued)
Date/
Addendum ft Topic Instruction Location/Page
3/14/86 #14 Audits of Cooperative . Replacement pages . Table of Contents Pages
Agreements xiii through xix
. List of Exhibits, Pages
xx through xxii
. New pages . Chapter IX, Pages IX-1
through IX-24
3/24/86 #15 Community Relations . Replacement pages . Table of Contents, Pages
Plan xiii through xix
. Appendix K, Pages K-l
through K-
ivb
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TABLE OF CONTENTS
9375.1-4
3/24/86
Revised Page xiii
PAGE
LIST OF ACRONYMS AND ABBREVIATIONS a
I. INTRODUCTION 1-1
A. Purpose of the Manual 1-2
B. Background -- Key Terms , 1-3
B.I Remedial Response 1-4
B.2 Remedial Response Agreements 1-4
B.3 State Assurances 1-5
B.3.a Cost-Sharing 1-5
B.3.D Off-Site Treatment, Storage, 1-6
or Disposal
B.3.c Operation and Maintenance (O&M) 1-7
B.4 State Credits 1-7
C. Overview of the Manual 1-7
II. CONCURRENT ADMINISTRATIVE EVENTS II-l
A. Initiation of Enforcement Activities II-2
B. Initiation of Forward Planning II-2
C. Development of Site-Specific Schedules II-5
D. Development of the Remedial II-5
Accomplishments Plan (RAP)
E. Development of the Action Memorandum II-5
F. Identification and Review of State II-6
Credit Submissions
G. Intergovernmental Review II-7
III. DEVELOPMENT OF COOPERATIVE AGREEMENT III-l
APPLICATION PACKAGES
A. Completion of the Cooperative Agreement III-2
Application Form
DATE
12/10/84
12/10/84
Kill
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9375.1-4
3/24/86
Revised Page xiv
PAGE DATE
A.I Part IV - Project Narrative III-2
Statement
A.2 Part III - Pro]ect Budget III-3
A.2.a Allowable Costs III-4
A.2.b Enforcement Costs III-5
A.2.c Calculation of State Cost Share III-5
B. Development of Cooperative Agreement III-6
Provisions
B^l General Assistance Requirements III-6
B.2 Superfund Program Requirements III-7
B.2.a Provision of CERCLA III-8
Section 104(c)(3) Assurances
• B.2.b The National Environmental III-9
Policy Act Of 1969 (NEPA)
B.2.C Quality Assurance/Quality 111-10
Control (QA/QC)
B.2.d Site Safety Plan III-ll
B.2.e Expedited Procurement 111-12
C. Completion of the Procurement System 111-12
Certification Form
D. Other Submissions 111-13
D.I Community Relations Plan (CRP) 111-13
D.I.a Draft Community Relations 111-13
Plan
D.l.b Complete Community 111-14
Relations Plan
D.2 Certification Letter 111-15
D.3 Intergovernmental Review Comments 111-15
E. Deviation Requests to Permit the IIT-15
Allowability of Pre-Award Costs
F. Multi-Site Cooperative Agreements 111-17 12/10/84
F.I Activities That May Be Included 111-18
in Multi-Site Cooperat'ive
Agreements
F.2 Intergovernmental Review 111-19
F.3 Contents of a Multi-Site Cooperative 111-20
Agreement
xiv
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9375.1-4
3/24/86
Revised Page xv
F.3.a Cooperative Agreement
Application Form
F.3.b Multi-Site Cooperative
Agreement Application
Provisions
F.3.c Procurement System
Certification Form
F.3.d Certification and
Enforcement Letters
F.4 Accounting for Multi-Site
Cooperative Agreements
F.5 Administration of Multi-Site
Cooperative Agreements
F.5.a Project Management
F.S.b Project/Budget Periods
F.5.c Quarterly Reports
IV. DEVELOPMENT OF EPA-LEAD REMEDIAL PLANNING
AGREEMENTS
A. The Scope of Work for Remedial Planning
B. Documentation of Terms and
Responsibilities
B.I EPA Responsibilities
B.2 State Responsibilities
B.3 General Terms
C. Other Submissions
C.I Community Relations Plan (CRP)
C.2 Intergovernmental Review Comments
D. Management Assistance Cooperative
Agreements
V. DEVELOPMENT OF SUPERFUND STATE CONTRACTS
A. Development of the Statement of Work (SOW)
B. Development of State Cost-Sharing Terms
B.I Calculation of the State's Cost Share
B.2 Negotiation of Payment Terms
C. Documentation of Other Terms and
Responsibilities
PAGE DATE
111-20
111-23
111-23
111-23
111-24
111-26
111-26
111-26
111-27
IV-1
IV-3
IV-3
IV-3
IV-4
IV-4
IV-5
IV-5
IV-6
IV-6 12/10/84
V-l
V-2
V-2
V-2
V-3
V-4
xv
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9375.1-4
3/24/86
Revised Page xvi
C.I EPA Responsibilities
C.2 State Responsibilities
C.3 General Terms
D. Other Submissions
D.I Community Relations Plan (CRP)
D.2 Certification Letter
D.3 Intergovernmental Review Comments
E. Multi-Site Superfund State Contracts
PAGE DATE
V-4
V-5
V-6
V-7
V-7
V-8
V-8
V-8 12/10/84
VI. EXECUTION OF REMEDIAL AGREEMENTS VI-1
A. Review of the Draft Agreement VI-1
A.I Review of the Draft Cooperative Vl-2
Agreement Application Package
A.2 Review of the Draft EPA-Lead VI-2
Submission
B. Final Regional Review and Preparation VI-2
of the Concurrence Package
C. Approval and Execution VI-4
VII. ADMINISTRATION OF REMEDIAL AGREEMENTS VII-1
A. Monitoring Financial Commitments vn-i
A.I State Drawdowns Under a Cooperative VII-2
Agreement
A.2 State Payment of Cost Share Under Vll-3
a Superfund State Contract
B. Monitoring Technical Commitments Vll-3
B.I Monitoring Site Activities Vll-4
B.2 Monitoring State Assurances and VII-5
Compliance with Special Conditions
C. Coordinating EPA-Lead Remedial Agreements VII-5
with Performance Agreements
D. Documenting Remedial Activity VII-6
xvi
-------
D.I Regional Files
D.2 EPA Headquarters Files
D.3 State Files
9375.1-4
3/24/86
Revised Page xvii
PAGE DATE
VII-6
VII-6
VII-7
E. Documenting Completion of Remedial
Implementation [RESERVED]
VIII. AGREEMENT MODIFICATIONS
A. Project Adjustments
A.I Adjustments to State-Lead Projects
A.2 Adjustments to EPA-Lead Projects
B. Initiation of Remedial Design and
Remedial Action
B.I Records of Decision (RODs)
B.2 Incorporating Remedial Design and
Remedial Action into an
Agreement Between EPA and the State
C. Initiation of Operation and Maintenance
IX. AUDITS OF COOPERATIVE AGREEMENTS
A. Types of Audits
A.I Interim Audits
A.2 Final Audits
A.3 CERCLA Credit Audits
B. Scheduling the Audit and Preliminary
Activities
B.I Scheduling the Audit
B.2 Regional Preparation for the Audit
B.3 State Preparation for the Audit
C. Procedures for the Audit
C.I Entrance Conference
C.2 Audit Standards and Tasks
C.3 Draft Audit Report
C.4 Exit Conference
C.5 Final Audit Report
C.6 Findings and Recommendations Related
to EPA Administration
VIII-l
VIII-1
VIII-l
VI11 -2
VI11-3
VIII-l
VIII-5
VIII-7
IX-1
IX—1
IX-4
IX-7
IX-7
IX-8
IX-8
IX-9
IX-9
IX-11
IX-12
IX-12
IX-15
IX-19
IX-19
IX-20
3/14/85
xvii
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9375.1-4
3/24/86
Revised Page xviii
D. Resolution of Audit Findings and Follow-up
Actions
D.I Review of Final Audit Report and
Resolution of State Disagreements
D.2 Resolution of DIGA Disagreements
and Disputes
D.3 Issuance of the Final Determination
Letter
D.4 Review for Adequacy
E. Implementation of Corrective Actions
APPENDICES
Introduction to the Appendices
Appendix A - PA/SI Guidance
Action Memorandum Guidance
PAGE
IX-20
IX-20
IX-21
IX-22
IX-23
IX-24
DATE
Appendix B -
Appendix C -
Appendix D -
Appendix E -
Appendix F -
Appendix G -
Appendix H -
Appendix I -
Appendix J -
A-l
B-l
9/17/85
12/20/85
Procedures for Developing and Processing C-l
CERCLA State Credit Claims
Procedures for Implementing Intergovern- D-l 9/17/85
mental Review
Model Statement of Work for State-lead E-l 12/10/84
Remedial Investigation/Feasibility Study
Projects
Sample Cooperative Agreement Application F-l
Provisions
Sample Cooperative Agreement Application G-l
Package
Sample Articles for Superfund State H-l
Contracts and Other EPA-Lead Remedial
Agreements
Sample Superfund State Contract 1-1
Sample Certification Letters J-l 12/10/84
xvi 11
-------
Appendix K -
Appendix L -
Appendix M -
Appendix N -
Appendix 0 -
Appendix P -
Appendix Q -
Appendix R -
Appendix S -
ppendix T -
9375.1-4
3/24/86
Revised Page xix
Sample Community Relations Plan Format
and Sample Plan (CRP)
K-l 3/24/86
Sample Quality Assurance/Quality Control L-l 1/31/86
Plan
Sample Site Safety Plan
Instructions for Using Superfund Letter
of Credit Account Numbers Under
Cooperative Agreements
Record of Decision (ROD)/Enforcement
Decision Document (EDO) Guidance
Superfund Supplement Guidance
Glossary of Terms
List of References
Advance Match Procedures
Obtaining Equipment for Use Under
a CERCLA Cooperative Agreement
M-l
N-l
12/20/85
12/10/84
0-1 1/17/86
P-l 3/5/86
Q-l
R-l
S-l 1/4/85
T-l 8/9/85
xix
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9375.1-4-K
3/24/86
Revised Page K-l
APPENDIX K
COMMUNITY RELATIONS PLAN FORMAT
AND SAMPLE PLAN
PURPOSE
This appendix has been provided to assist Regional
personnel — especially Remedial Project Managers (RPMs)
and Regional Superfund Community Relations Coordinators
(RSCRCs) — and State staff — such as State Project
Officers (SPOs) and State Community Relations Coordinators
(SCRCs) — in developing Community Relations Plans (CRPs)
for remedial sites.
BACKGROUND
The Superfund community relations program is a two-
way, site-specific program for communication and informa-
tion exchange that is implemented for every remedial re-
sponse initiated under CERCLA. It must involve citizens
from the affected communities and representatives from the
Federal, State, and local agencies taking part in the re-
sponse. The program's goal is to keep local citizens in-
formed about planned and on-going remedial activities
while also providing them an opportunity to comment on and
supply information about the response.
Community relations activities may be the resoonsibil-
ity of either EPA or the State, depending upon which
agency is taking the lead for the remedial response activ-
ities in question. For State-lead projects, this respon-
sibility will be determined during negotiation of the
Cooperative Agreement application covering the project,
and may be assumed either by EPA or the State. For
Federal-lead projects, EPA Regional community relations
staff, with the assistance of RPMs, will conduct the com-
munity relations program. In either case, a CRP must be
developed and implemented for each Superfund remedial
project.
A CRP is the planning, management, and budget document
that specifies community relations activities to be under-
taken at a site. As such, it is an essential and integral
part of remedial response activities. The CRP, however,
must be based on interviews conducted in the communitv
with interested State and local officials, community resi-
dents, and media representatives. Only after obtaining a
K-l
-------
9375. L- -K
3/24/B6
sed -^ge K-2
firsthand understanding of the community issues, suagested
techniques for involvement, and information needs c.nn a
CRP be written to reflect the concerns of the community in
question (see Section 2 of this appendix).
After completion of the community interviews and care-
ful consideration of the information gathered, Superfund
community relations staff will have sufficient information
to prepare a draft CRP. The trigger point for preparing
the draft CRP should be the onset of EPA and State negoti-
ation of a remedial response agreement for the first proj-
ect at the site in question. A CRP should include the
following elements:
Overview of Community Relations Plan
Capsule Site Description
Community Background
Highlights of Community Relations Program for the
Site
Community Relations Techniques and Timing
Appendices.
A draft plan must be -submitted along with the draft agree-
ment covering the first phase of remedial planning --
either a Cooperative Agreement application or a draft
Memorandum of Understanding (MOU) . The plan will form the
basis for the complete CRP, which should oe submitted with
the final agreement package. If., the project is to be un-
dertaken in response to a State letter of request, a com-
plete CRP must be developed and approved prior to the
initiation of remedial activities at the site.
Before a remedial design or remedial action is imple-
mented at the site, the responsible agency must revise the
CRP to reflect the changing needs and concerns of the com-
munity and the additional requirements of the new proj-
ect. The revised CRP must be submitted with either the
Cooperative Agreement application or the Superfund State
Contract (SSC) that is negotiated to cover this phase of
remedial response. A public notice and fact sheet should
also be prepared uoon completion cf the final engineering
design. More specific procedures for preparing the CRP
and background on the Supeirfund community relations
K-2
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9375.1-4-K
3/24/86
Revised Page K-3
program in general can be found in CommunityReiations in
Superfund; A Handbook. Refer to section 300 67 of ?h»
National Oil and Hazardous Substances Pollu??on Contin
gency Plan for specific regulatory guidance Lontln-
APPENDIX SUMMARY
For the use of concerned State and EPA Regional staff
this appendix contains the following guidance:
On-site discussion guidance document
CRP sample format
Sample CRP.
The activities presented in Section 2, Community Relation*
SI" ^rorJ^'H"6 qeneral ««•"•"•»• for prepar ng a
CRP. in practice, however, needs of individual CRPs will
vary Every site presents special problems and every com-
th?^ r^" UniqUe needS and expectations to consider* For
Staff ^' a Sample CRP has been Prided in Section 3
Staff members preparing CRPs should tailor plans to re-
flect the needs of the site and the situation in question
K-3
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1. INTRODUCTION
This document provides guidance for planning, ccncucti.\g, an a evaluating
on-site discussions with concerned citizens and local officials at Superfund
sites. These discussions provide the basis for assessing the nature and level
of citizen concern at the site -- a requirement for all non-emergency
Superfund response actions. Tasks described in this guidance may be performed
by EPA regional personnel, state response staff, or £?A-supervisea contractors.
Community relations activities must be based upon information derived from
on-site discussions with concerned citizens and local public officials to
ensure that EPA or the state responds to local concerns and major issues.
Results of the on-site discussions should be incorporated :nto a community
relations plan (CRP) -- the planning, management, and budget cornerstone of
the community relations program for each sice. Acnvititi :cec:i:ed in the
CRP are tailored to the level and nature of community concerns at the site.
These on-site discussions are not a survey of citizen opinion. Rather,
they are information meetings conducted to provide comrauni'.y leianons staff
with the background information necessary to uncierstdr.d the s^e's history
from the community's perspective, to identify concerned citizens, officials,
and organized groups, and to evaluate the level and nature of citizen
concern. This information is indispensable in preparing the CRF. The
discussions also serve as the initial public input into response plans.
Concerns identified in these discussions may be taken im.o .i^.ourit in
developing technical response actions.
Information derived from on-site discussions may also v->: .isiorul to the
enforcement staff. At sites where enforcement staff are ?si-r- n.i; responsible
party cleanup, on-site discussions should be conducted and ev
-------
2. PLANNING AND PREPARATION
This section of the guidance discusses the planning and preparation that
should precede discussions with citizens and local officials at the site. The
work effort required for the activities described will vary from site to site,
depending on the level of citizen concern and the site's technical
complexity. On the average, however, planning and preparation for on-site
discussions should require three days of work effort.
Prior to conducting the on-site discussions, the community relations staff
should plan: (1) how to acquire information about the site and identify
interested public officials and members of the local community; (2) how to
contact interested officials, citizens, and organized groups; and (3) how to
elicit information from these individuals and groups. These three phases of
the planning process are discussed separately below.
A. Acquiring Site Information and Identifying Interested Officials,
Community Members, and Groups
To ensure that key individuals are contacted and that site issues are
understood, certain steps should be performed to acquire necessary background
information, including the following:
(1) Meeting with regional EPA and state technical staff to
discuss known or suspected site problems, to identify
interested officials and citizens, and to obtain other
background information;
(2) Reviewing EPA regional office, headquarters and state
fi ies to obtain relevant memos, documents, and
correspondence;
(3) Researching local newpaper articles for the names of
community leaders and for a preliminary indication of
major site issues;
(4) If EPA clearance has been obtained, contacting
Congressional offices in Washington or the state,
either by telephone or in person, to obtain additional
background information, as well as to inform the
offices that EPA or state staff or contractors will
soon visit the site. Congressional staff can identify
the most involved citizens and the major site issues on
the basis of inquiries to their office. It is
essential to obtain EPA clearance, however, before
making such contact. (Staff in the local or district
Congressional office nearest to the site may be
included routinely among those with whom on-site
discussions are held, as noted below.)
K-6
-------
9375.1-4-k
Performing these four steps in the order in which they are presented here
should help maximize the efficiency with which this first phase of the
planning process is carried out.
At most sites, some or all of the following types of individuals and
groups may have concerns about the site or can provide valuable perspective on
site issues. They should, therefore, be included among those to be considered
for on-site discussions:
• Persons interested in the site, i.e., persons living
in close proximity to the site and nearby property
owners;
• State agency staff, such as health, environmental
protection, or natural resources department officials;
• Local and state elected officials, such as the mayor,
council members, local state legislators, or attorney
general;
• Staff at Congressional or state legislators' district
offices;
• County planning and health officials;
• Representatives of ad hoc citizen groups organized
because of site issues;
• Local business representatives (e.g., from the
Chamber of Commerce);
• Local civic groups;
• Neighborhood associations;
• Local chapters of environmental groups;
• Local educators and school administrators; and
• Media representatives.
It is important to encourage those members of the community who have been
the most active with respect to the site to raise their concerns in on-site
discussions.
B. Contacting Interested Officials, Citizens, and Groups
Once the background activities of the first phase of the planning process
are completed, community relations staff should draw up a list of persons to
be contacted at the site and make arrangements to meet with them. In phoning
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those persons on the contact list, staff should explain that the purpose of
the discussions is solely to obtain the views of community members or. site
problems and to explore the concerns and issues identified by citizens and
local officials. Staff should stress that the discussions uill not be used
to provide information to the public about site problems or possible future
site actions, but instead, that the purpose of the discussions is to assess
the level and nature of community concerns, so that community relations
activities appropriate to those concerns can be conducted and so that
community concerns can be taken into account in planning response actions.
The purpose of the discussions uill usually be easily understood Citizens
and officials will generally not object Co speaking to government staff uho
cannot provide them with findings on possible effects or a firm schedule for
cleanup, although they may be disappointed not to receive such information.
Rather, citizens and local officials are generally appreciative tr.at someone
from the government is willing to meet with them and listen to their vieus.
They regard the discussions as an opportunity to voice their concerns and.
perhaps, to have some effect on government decisions.
If possible, all meetings should,be scheduled over a period of no more
than five days.
C. Eliciting Information from Individuals and Groups
The final phase of the planning process is to drau up a brief and informal
list of questions to guide the discussions with local officials and citizens
Such a list may help to ensure that the discussions are efficient yet
comprehensive. These questions may serve as a reminder of the areas that
should be covered in the discussions, the kinds of information that should be
elicited, and any specific points that must be addressed. Because the on-site
discussions should not be conducted as a survey, the questions listed in
advance while planning the discussions need not be asked explicitly during
discussions. Exhibit 1 presents examples of questions that may be useful in
conducting on-site discussions.
In addition to preparing questions, community relations staff should
determine whether there are any special matters that should not be publicly
disclosed (for example, specific findings from enforcement investigations or
preliminary cost estimates for cleanup). Program and enforcement staff should
be consulted on this point before the on-site discussions are held.
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9375.1-4-k
those persons on the contact list, staff should explain that the purpose of
the discussions is solely to obtain the views of community members on site
problems and to explore the concerns and issues identified by citizens and
local officials. Staff should stress that the discussions will not be used
to provide information to the public about site problems or possible future
site actions, but instead, that the purpose of the discussions is to assess
the level and nature of community concerns, so that comraimity relations
activities appropriate to those concerns can be conducted and so that
community concerns can be taken into account in planning response actions.
The purpose of the discussions will usually be easily understood. Citizens
and officials will generally not object to speaking to government staff who
cannot provide them with findings on possible effects or a firm schedule for
cleanup, although they may be disappointed not to receive such information.
Rather, citizens and local officials are generally apprecianve that someone
from the government is willing to meet with them and listen to their views.
They regard the discussions as an opportunity to voice their concerns and,
perhaps, to have some effect on government decisions.
If possible, all meetings should be scheduled over a period of no more
than five days.
C. Eliciting Information from Individuals and Groups
The final phase of the planning process is to draw up a brief and informal
list of questions to guide the discussions with local officials and citizens:
Such a list may help to ensure that the discussions are efficient yet
comprehensive. These questions may serve as a reminder of the areas that
should be covered in the discussions, the kinds of information that should be
elicited, and any specific points that must be addressed. Because the on-site
discussions should not be conducted as a survey, the questions listed in
advance while planning the discussions need not be asked explicitly during
discussions. Exhibit 1 presents examples of questions that may be useful in
conducting on-site discussions.
In addition to preparing questions, community relations staff should
determine whether there are any special matters that should not be publicly
disclosed (for example, specific findings from enforcement investigations or
preliminary cost estimates for cleanup). Program and enforcement staff should
be consulted on this point before the on-site discussions are held.
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EXHIBIT 1
EXAMPLES OF QUESTIONS TO ASK IN ON-SITE DISCUSSIONS
(1) When did you first become aware of the release of hazardous substances at
the site?
(2) How would you characterize the problems at the site?
(3) What contacts have you had with local, state, EPA and other officials
about the site?
(4) What are your major concerns related to the site?
(5) What activities have you participated in, sponsored, or organized
concerning the site?
(6) How can EPA or the state best provide you with information concerning
response activities? Would you like to be included on a mailing list?
(7) What kind of information would be most useful to you (e.g., technical
information, status reports on cleanup activities)? How frequently would
you like to receive a progress report or fact sheet?
(8) Is there anything you wish to mention that we have not yet discussed?
(9) Can you suggest other individuals or groups that EPA or the state should
contact for additional information or to identify other types of concerns?
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3. CONDUCTING ON-SITE DISCUSSIONS
This section presents procedures that may be useful to EPA, the state, or
contractor support staff in conducting on-site discussions with citizens and
local officials. If possible, all discussions related to a specific site
should be conducted within a five day period.
Once the discussions have begun, staff should try to:
• Make all appointments as scheduled;
• Arrange a follow-up conversation if additional time
is needed with any official or citizen;
• Assure citizens and officials that all interviews
will be held confidential, and that no specific
statements will be attributed to any person without
prior clearance;
• Have two community relations staffers present during
the discussion, when possible, so that one can take
notes while the other leads the discussion.
About 45 minutes to one hour should be allowed for a discussion with an
individual. Less time will usually be required once the community relations
staff have become familiar with the background of community involvement
through previous discussions. If asked, staff should not hesitate to identify
some of the other citizens or officials with whom discussions are being held.
Local reporters may, on occasion, ask to attend discussions between
community relations staff and community leaders or officials. The attendance
of reporters at these discussions should be discouraged, as it might inhibit a
frank and open conversation. Reporters should be asked, instead, to meet
separately with community relations staff. If they do attend discussions with
officials, they should be included in the meeting and asked for their views
and comments, which are valuable.
At the outset of any discussion with reporters, community relations staff
should repeat that the purpose of the discussion is to collect information,
not to answer questions, and that the community relations staff are not in a
position, in any event, to provide new information on site problems or
response plans.
•
Community relations staff must take special care to avoid making
subjective comments about the site during the discussions and avoid conveying
specific information that may raise citizens or officials expectations
about response activities.
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At the end of each discussion, staff should ask the citizen or official if
he or she is interested in participating in future briefings, workshops, and
meetings, and receiving prior notification of such activities by mail. In
addition, the names of other individuals to contact in the community should be
requested. After each discussion has been concluded, staff should write up a
summary of the discussion as soon as possible.
When all the meetings have been held, staff should prepare a final list of
all interested officials and citizens with pertinent titles and affiliations,
addresses, and phone numbers. This list eventually will be included in the
community relations plan for the site.
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4. EVALUATING DISCUSSIONS
Based upon the discussion summaries and the notes from --.ac.h meeting,
community relations staff should evaluate the nature and level of citizen
concern at the site. This evaluation will be incorporated into the CRP.
Community relations staff may assess whether community concern is high,
medium, or low by considering the presence or absence of the following six'
characteristics, which have been found to be important indicators of community
involvement and concern in past on-site investigations conducted by EPA:
(1) Children's health — whether families in the community
believe their children's health may be df^ec^eu by
hazardous substances;
(2) Economic loss -- whether local homeowners or
businesses believe that, the site has caused or will
cause them economic loss;
(3) Agency credibility -- whether the performance and
statements of EPA and the state are viewed by -he
public as competent and credible;
(4) Involvement -- whether an active, vocal group leader
(or leaders) has emerged from the community and whether
the group leader has a substantial local follouing;
(5) Hedia -- whether events at the site have received
substantial coverage by local, state, regional, or
national media; and
(6) Number affected -- whether more than t-n.ee ui :our
households perceive themselves as affected by trie site.
Some of these characteristics are more important than others in
determining^the level of community concern. For example, a perceived threat
to children's health is a particularly strong indicator of a potentially high
level of citizen concern at a site. If several of the aoove characteristics
describe the affected community, the community relations staff have grounds
for considering that the level of community concern at the site may be medium
to high or has the potential to become medium to high
In writing CRPs, following completion of these on-site discussions, it is
important to maintain objectivity. Consider?*.ion should be given to the
feelings of any citizens or officials mentioned. These plans will be
circulated among the state and federal agencies involved in the response.
They may also be read by members of the general public, in the site community.
Allegations or opinions expressed by those with whom discussions
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were held do not need to be presented in the plans unless they are directly
relevant to the design of a community relations program. Descriptions of the
personal backgrounds or political beliefs of individuals ari unnecessary.
Accusations of conflict of interest or of a complete absence of credibility
among certain officials or agencies are serious charges that are not
appropriate subjects for CRPs. Such charges should be directed to the proper
EPA or state staff according to the standard procedures in such cases. In'
short, the information gathered in the on-site discussions should be carefully
weighed and presented as objectively as possible. No CRP should become an
issue itself in the community.
By planning, conducting, and evaluating the discussions in accordance with
this guidance, community relations staff should gain a clear understanding of
the level and nature of community concern at a site. Community relations
staff should then be able to prepare an effective CRP and to tailor
communications activities at a site to the needs and concerns of local
citizens and officials.
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In all three sections, but pan. ...ularly in the last, the focus should b»
on the community s perceptions of the events and problems at the site
and not on the technical history of the site.
Length: May vary between three to seven pages, depending on the history
and level of community involvement in the problems posed by the site.
0. Highlights of Community Relations Program for the Site
PurP°se: This section should provide concrete details on community
relations approaches to be taken at the site. These approaches should
follow directly and logically from Section C's discussion of the community
and its perceptions of the problems posed by the site. This section will
not restate the goals or objectives of conducting community relations at
Superfund sites. Instead, it will develop a strategy for communicating
with a specific community.
Suggested topics:
Resources to be used in the community relations program (e.g.,
local organizations, meeting places);
Key individuals or organizations which will play a role in
community relations activities;
• Areas of sensitivity that must be considered in conducting
community relations.
E. Community Relations Techniques and Timing
Purpose: This section should state what community relations activities
will be conducted at the site, and when they must be implemented. This
section should also suggest additional techniques that might be conducted
at the site, depending on circumstances as the response action proceeds
and when in the remedial process they are likely to be most effective.
Len8th: Two to three pages. Matrix format may be suitable for this
section.
Appendices
• Mailing List of Interested Parties and Key Contacts*
• Suggested Locations of Meetings and Information Repositories
-(Note: Names and addresses of individuals should not be included in the
the community relations plan that is made available in the information
repository for public review. Names and addresses should, however be
f'l°r ) maiUng Ust as part of the Community Relations Coordinator's
* * * March 1986 Draft * * *
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'•-k
APPENDIX A
SAMPLE COMMUNITY RELATIONS PLAN
The following community relations plan for the Sludge Pond sice is
intended to illustrate the suggested format and content of community relations
plans as discussed in Chapter 3 of this Handbook. While the plan is based on
actual community interviews conducted for a Superfund remedial site names
locations, and technical details have been changed so that the plan can be'
viewed as an illustration only.
********
COMMUNITY RELATIONS PLAN
SLUDGE POND SITE, WOODBURY, CONNECTICUT
1. OVERVIEW OF COMMUNITY RELATIONS PLAN
This community relations plan identifies issues of community concern
regarding the Sludge Pond Superfund site in Woodbury, Connecticut and
outlines community relations activities to be conducted during the remedial
investigation and feasibility study (RI/FS) of the site. In general
community concern about the site is low; having known for almost forty years
that the site was a source of contamination, residents appear mcre-or-less
resigned to its presence in their community. The initiation of remedial
activity at the site, however, is likely to reawaken the interest and concern
of the community. An effective community relations program for this site
should therefore prepare for this potential revival of community interest and
attempt to educate, without alarming, residents so that they can better
understand the Superfund remedial process. In particular, the community
relations program for Sludge Pond should enlist the support and cooperation of
the town and county officials of Woodbury. These individuals have a long-
standing familiarity with the area and its residents, and hold visible
positions of responsibility within the community; therefore chey should be
considered as a key resource in the effort to communicate ooenly and
effectively with the townspeople of Woodbury.
This draft community relations plan has been prepared to aid EPA in
developing a community relations program tailored to the needs of the
community affected by the Sludge Pond site. EPA conducts community relations
activities to ensure that the local public has input to decisions about
Superfund actions and is kept well-informed about the progress of those
actions. The plan is divided into the following sections:
• Capsule Site Description
• Community Background
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9375.1-a-k
• Highlights of the Community Relations Program for
Sludge Pond
• Community Relations Activities
• Attachments: Site Mailing List and Suggested
Locations for Meetings and Informat:on Files
The information in this plan is based primarily on discussions conducted
in Litchfieid County, Connecticut, in August 1985, with the District Health
Department, officials from the Litchfieid County Office of the Connecticut
Department of Environmental Protection (DEP), the first selectman of Woodbury
Township, a Litchfieid County Commissioner, and residents of Woodbury and
Watertown Townships. The "Preliminary Investigation Report/Lewis Iron Works
Site," prepared by contractors to Eastern Manufacturing Company, also provided
valuable information.1
The U.S. Environmental Protection Agency (EPA) Region I Office has lead
responsibility for managing this RI/FS; the EPA Region I Office of Public
Affairs will oversee all community relations activities at the site. The
Office of Community Involvement in the Ground Water Quality Division at DEP
will play a major role in implementing community relations activities.
2. CAPSULE SITE DESCRIPTION
Site History
The Sludge Pond site is located on a forty-acre tract of land, one mile
south of the Town of Woodbury on Route 6. (Exhibits 1 and 2 illustrate the
location of the site within the state, and surrounding geographical
landmarks.) To the north of the site is Tanner Lake, used for recreational
fishing and swimming. The closest residences are approximately one-quarter
mile away, located to the northwest and west across Route 6.
For nearly sixty years from 1886 to 1945, the site was the manufacturing
location of Lewis Iron Works, a major producer of charcoal, pig iron, and
organic chemicals. Liquid tar residues from chemical processing were
discharged into a two-acre depression on site, giving to the area its current
name of "Sludge Pond." Lewis Iron Works shut down its chemical operations in
early 1944, and a year later, ceased operations entirely. Among the current
owners of the site property are Eastern Manufacturing, whose nearby plant
produces automotive parts; the Wilscn Lumber Company; and the township of
Woodbury, which operated an eight-acre municipal landfill adjacent to the
Sludge Pond site from 1961 to 1969.
Interested readers are advised that this, as well as other technical
reports (such as the RI/FS work plan), will be made available at the
information repository to be established within Woodbury. These reports will
give full details of the typp and extent of the problem found at Sludge Pond.
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Exhibit 1
SITE LOCATION MAP
SLUDGE POND SITE
LITCHFIELD COUNTY, CONNECTICUT
NEW LONDON
-J
w*g*$
sffi*' \
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9375.1-4-k
Exhibit 2
SLUDGE POND SITE VICINITY MAP
•-i I
LBELLAIRE
TAPAWINGO SKI AREA
LAUREL LAKE
YOUNGER ROAD
GREEN
LAKE
O
cc
TOWN OF.
WOODBURY
TANNER LAKE
1
SCALE IN MILES
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In the late 1940s, shortly after the closing of the Iron Works, residents
as far away as three miles from the site reported that their well water had a
chemical taste and bad odor." Samples taken by the Connecticut Geological
Study in 1949 indicated that phenol-contaminated ground water had affected
eight private wells, located to the west and northwest of Sludge Pond. In the
1960s, the surface sludges on site caught fire and burned out of control for
several weeks.
Limited water sampling conducted since 1980 has confirmed the 1940
findings of phenol in the area ground water. In addition, DEP found evidence
of heavy metals in Sludge Pond in 1980. This evidence of heavy metal
contamination was not, however, confirmed by monitoring samples taken by EPA's
Field Investigation Team in 1982, or by on-site testing conducted by Eastern
Manufacturing 1983. After private wells were tested by DEP and the District
Health Department in 1980, residents were told that their water was drinkable.
Sludge Pond was proposed for the National Priorities List (NPL) in
December 1982. The site has recently been designated a Fund-lead site for the
RI/FS, although enforcement proceedings are underway against Eastern
Manufacturing as a potentially responsible party.
3. COMMUNITY BACKGROUND
a. Community Profile
The town of Woodbury, named for the abundance of trees in the area,
developed in the 1820's as settlers journeyed to western Connecticut in search
of farm land. However, because of the town's fairly remote location, industry
did not begin to develop in the area until about a half-century later. In
1882, George Lewis - an area entrepreneur - erected a blast furnace for the
manufacture of charcoals, and the Lewis Iron Works soon became the area's
largest employer.
Several of the Woodbury residents interviewed for this plan recalled the
days when their relatives or neighbors worked at the Iron Works, and old
photographs of the company's vast lumber stocks and furnace can still be seen
in the local library and on the walls of the town office building.
Since the closing of the Iron Works, major sources of employment in the
area have included light industry and farming. Local craft industries dating
from the early nineteenth century continue to flourish in the area, as do
antique stores and clock shops. Dairy and poultry farms occupy a significant
portion of the land in Litchfield and Berkshire counties.
In general, however, Woodbury Township remains a quiet, rural area,
somewhat insulated from the industrial development to the south and east.
Judging from the experience of individuals interviewed for this plan, many
members of the community have been long-time residents in the area, and the
Township's small population (7,000 reported in the 1980 Census) has meant that
local officials know, and are known by, most of the area's residents. There
also seems to be a significant number of senior citizens in the community;
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discussion of aging issues and provision of facilities for the elderly have
been prominent concerns in the community, and according to the Township Clerk,
a central meeting place in the area is the Litchfield County Senior Center.
b. Chronology of Community Involvement at the Sludge Pond Site
Local officials^have described community reaction to the proximity of an
NTL site as "quiet," particularly in the past year. The District Health
Department receives only infrequent inquiries about the safety of private well
water which, according to users, is a brownish-orange color and stains
bathroom fixtures and laundry. The last call was received at the beginning of
the summer (1985) from a prospective home builder who was concerned about the
condition of the ground water directly south of Sludge Pond. Because the
groundwater flow from the site runs west -- and, in the opinion of some local
officials, is confined to a narrow finger of an aquifer -- the Health
Department assured the caller that his property was not threatened by
contamination from the site.
The level of community concern, while never high, was perhaps at its peak
in the early 1980s, when DEP analyzed sludges from Sludge Pond and sampled
water from a number of private wells. Early in 1980, a local resident living
on a farm with contaminated well water wrote to the District Health
Department after reading an article in the Waterbury Republican about the
suspected hazards at the site. She was concerned because guests could not
drink her water, though she herself was accustomed to its distinctive taste.
When interviewed, this same resident stated that she and her husband knew
abcut the problems with their well when they purchased their house and farm,
and in fact were able to buy the property at a reduced price because of the
discolored water.
Also in 1980, the Township of Woodbury took over and began rebuilding a
town water system from an independent water company. A major part of this
project, which was financed through loans and grants from the Farmers' Home
Administration, was the replacement of leaking wooden main pipes. Some
community members also attempted to obtain a Health Department grant to have
the water mains extended to the residents with private wells who had
experienced bad well water. According to a County Commissioner, to obtain
funding from the Health Department for this extension, it was necessary to
demonstrate that the water was not fit for drinking. Because this
demonstration was never made, the Township was unable to finance an extended
water system. While affected citizens could conceivably put in their own
connecting pipes to tap into the town water system, this option appears to be
well beyond the means of individual residents.
Shortly after the site was listed on the NPL in December 1982, the
Litchfield County Herald ran an article announcing Sludge Pond as one of
"EPA's 400 Worst." Though several residents could recall the article, the
classification of Sludge Pond as a Superfund site did not particularly alarm
residents or motivate them to take organized action. No community groups have
been formed to participate in the investigation of the site, or to voice an
opinion as to how the site should or could be addressed. In general, affected
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937S.l-/l-k
residents have dealt with the problem of contaminated well water in fairly
quiet and individual ways: some carry bottles of town water home for
drinking, and take extra measures (e.g., filtering and bleaching) to prevent
staining of laundry. From the point of view of local officials, a far more
urgent issue is the potential closure of the Litchfield-Berkshire municipal
landfill. DEP has found evidence of contamination in monitoring wells at the
landfill, and is therefore seeking to close the area. Because closure would
mean that area waste would have to be transported further away, local
officials are particularly concerned that some citizens will resort to dumping
refuse on back roads rather than paying the higher transporting fees for waste
removal.
c. Key Community Concerns
Currently, as throughout the past five years, there seems to be a fairly
low level of community concern about contamination from Sludge Pond. This low
level can be accounted for by several factors:
• Citizens have lived with the knowledge that Sludge
Pond was contaminated for a long period of time.
• Citizens view the contamination primarily as a
nuisance, but not as a public health hazard. Residents
rely on the fact that DEP and the Health Department have
never declared the water undrinkable as evidence that
the water is safe to drink.
• Only a few residents are affected and their houses are
scattered over farm land about two miles northwest from
the site. In conversations with community members,
about six families were mentioned as having had problems
with their private wells. At least two of these
families have now moved to homes on the village water
supply; another had problems only when he installed a
well before being connected to the town water system.
It is important, however, not to mistake the current low level of
community concern about Sludge Pond for lack of interest. Citizens are not
indifferent to the environmental problem posed by Sludge Pond; their attitude
might he more accurately characterized as resigned. In their view, the
problem is intractable. According to one resident, because such large
quantities of sludge were once deposited on site, it would literally take
moving a small mountain to eliminate the years' accumulation of waste.
Furthermore, many residents consider their community too rural and
economically insignificant to command federal attention or funds for a cleanup.
The initiation of the Sludge Pond RI/FS is bound to change this attitude
of resignation. The arrival on site of investigation teams, and discussion of
solution alternatives during the feasibility study may cause people to
reconsider that perhaps the problems at Sludge Pond are capable of a solution
and worthy of being addressed. In developing a community relations program
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9375.1-4-k
for this site, it is important to anticipate this potential for renewed
community interest. The following kinds of concern, voiced individually and
in a low key manner during community interviews, are likely to become more
visible and pressing during the RI/FS:
• Property Values: Some residents have suffered
losses in the market value of their property as a result
of groundwater contamination in the area. When one
resident put his property up for sale, he was told by
the realtor that the listing had to carry a statement
that his well water was contaminated. He has been
unable to sell his property, despite a substantial
decrease in his asking price, and has had to go into
debt to purchase a new home.
• Inconvenience: Contaminated well water has
inconvenienced affected residents in a number of ways:
they must carry bottled water to their homes from the
homes of friends or relatives on village water, and take
extra measures to get their laundry clean. There is
also the problem of the water having a bad odor. One
resident claims her plumbing has been affected by the
contaminants in her water. One resident did complain of
a rash that did not heal while she was using private
well water, but in general it appears that citizens
regard the contamination of ground water as a nuisance,
rather than a health hazard.
• Follow-up with community after site work: Over the
past five years, technical teams from EPA, DEP, the
District Health Department, and Eastern Manufacturing
have been in the area to sample site monitoring wells
and private wells and install a fence around the site.
Some residents complained that there was no adequate
follow-up to these visits, or explanation as to what had
been the purpose or results of testing. Owners of
private wells where samples had been taken did receive
copies of laboratory slips listing the levels of various
contaminants. However, they were not familiar with the
types of contaminants being tested, nor did they
understand how to interpret the detected levels of these
contaminants. Local officials were also irritated that
they had not been informed of the results of sampling
activities.
• Financing and conducting remedial work: At least
one local official and one resident wondered how the
investigation and possible cleanup of Sludge Pond would
be financed. The official's concern was that the
township could not afford remedial action at the site;
at the same time, he did not consider it fair that
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Eastern Manufacturing, as a potentially responsible
party, might be liable for remedial costs since the
company had not created Sludge Pond. In general,
community members do not appear to be knowledgeable
about the Superfund remedial or enforcement process, or
its technical and legal requirements. For example, one
elected official who had witnessed a technical crew on
site found it difficult to understand why sampling had
to be delayed until EPA-approved bottles were obtained.
He was also somewhat impatient that EPA would be
initiating a remedial investigation of the site, when
the site had already been investigated a number of times.
4. HIGHLIGHTS OF THE COMMUNITY RELATIONS PROGRAM AT
SLUDGE POND
The community relations program at the Sludge Pond site should be designed
to provide an opportunity for the community to learn about and participate in
the Superfund remedial process, without disrupting the community's confidence
that the site poses no new or immediate hazards. To be effective, the
community relations program must be gauged according to the community's need
for information, and its interest and willingness to participate in the
remedial process.
The community relations program at the Sludge Pond site should take the
following approaches:
*• Enlist the support and participation of local officials in
coordinating community relations activities. Appropriate officials to
involve in a community relations program include the Town First Selectman: the
County Commissioner for Litchfield, and District Health Department officials
These officials are visible and trusted leaders in the coamunity, and are
therefore an invaluable resource in EPA's effort to understand and monitor
community concern. To gain the support of local officials, it is essential
that they be regularly and fully informed of site activities, plans, findings
and developments.
2< Provide follow-up explanations about sampling and test results to
area residents. Concise and easily-understood information should be
available to all area residents on the schedule of technical activities their
purpose, and their outcome. Where information cannot be released to the
public -- either because of quality assurance requirements, or the sensitivity
of enforcement proceedings -- a clear and simple explanation as to why the
information must be withheld is in order. Community relations staff should
also, however, attempt to identify special situations or concerns where more
specialized information may be required, or where certain types of information
is desired by single individuals or groups. In particular, owners of property
where samples are taken should be provided with follow-up explanations of what
was done and found on their land. Finally, to ensure that inquiries from the
community are handled efficiently and consistently, a single EPA contact
should be established for the site.
K-25
* * * M0~»lt lOOf. !>.-., r*. ...
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9375.1-4-k
3. Educate area residents and local officials about the procedures.
policies, and requirements of the Superfund program. To dispel some of the
current confusion about EPA's purpose and responsibilities at the site, an
effort should be made to circulate basic information to the community
describing the Superfund process. Questions asked by community members during
on-site discussions indicate that the following areas c-vjld be given special
emphasis: scoring and ranking of NPL sites; the schedule and stages of an
RI/FS; and the criteria used to select a cleanup alternative.
4. Let the townspeople "set the pace" for the community relations
program. Staff should be aware that federal involvement in local issues has
not always been well-regarded by townspeople. Federal, and even state,
programs are seen as excessively bureaucratic and insensitive to the realities
of local government budgets and planning. It is important, therefore, not to
"overdo" or overplan community relations activities in a way that might
discourage the community from participating. Large, formal meetings will
almost certainly be inappropriate for this community, as will activities that
are planned without the consultation of key local officials.
5. COMMUNITY RELATIONS ACTIVITIES
The following activities are required for the Sludge Pond site community
relations program. Exhibit 3 illustrates the timing of each activity during
the remedial schedule for the site.
1. A public comment period on the draft feasibility study report. A
minimum three-week public comment period must be held to allow citizens to
express their opinions on EPA's preferred alternative for remedial action at
Sludge Pond. Community input should be encouraged at this point by informing
citizens that their opinions will be considered by EPA in the ultimate
decision on how the site will be addressed during remedial design and remedial
action.
2. Preparation of responsiveness summary. This document is required as
part of the Record of Decision for the site. It should summarize public
concerns and issues raised during the public comment period on the draft
feasibility study. In addition, the responsiveness summary documents
responses made by EPA and the State to these concerns.
3. Revision of Community Relations Plan. Once the Record of Decision
has been issued for Sludge Pond, this community relations plan should be
revised to outline community relations activities appropriate to the remedial
design and remedial action (RD/RA) phase. The revision of the community
relations plan should:
• Update facts, and verify the information included in
this community relations plan prepared for the RI/FS.
• Assess the community relations program to date, and
indicate whether the same or different approaches will
be taken during RD/RA.
K-26
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9375.1-n-k
• Develop a strategy for preparing the community for a
future role during RD/RA and ongoing operation and
maintenance.
It is advised that community interviews be held prior to the revision of the
Sludge Pond community relations plan.
In addition to these basic requirements for a community relations program
at Sludge Pond, a number of activities will be undertaken to ensure that the
community is well informed about site activities and has the opportunity to
express their concerns. Activities, and their approximate timing, are as
follows:
1. Establish and maintain information repositories; Fact sheets,
technical summaries, site reports (including the community relations plan),
and information on the Superfund program will be placed in the information
repositories. An information respository will be located at the Woodbury
Public Library.
2. Establish an information contact: A technical or community relations
staff person will be designated to respond directly to public inquiries
regarding site activities. In contacts with the press, $his person should
coordinate with EPA Community Relations staff and the DEP Community
Involvement staff.
3- Hold meetings with local officials, and contact them periodically by
Phone: The County Commissioner and the town's First Selectman have indicated
that they want to be kept informed about site plans and findings. Meetings
with local officials should include both EPA and DEP officials and should be
held at the following technical milestones:
• Completion of the final work plan;
• Completion of the draft RI/FS report; and
• Prior to initiation of remedial action.
*• Conduct informal meetings with residents: A meeting with residents
is advisable prior to the RI, and before any on-site activities involving use
of earth-moving devices or other heavy machinery. The meeting should include
interested citizens, the EPA Remedial Project Manager, the DEP Community
Involvement Coordinator and REM II technical and community relations
contractor assistance as necessary.
s- Prepare fact sheets and technical summaries; One fact sheet might be
released at the beginning of the remedial investigation to inform area
residents and other interested citizens about EPA's site plans and the
procedures of the Superfund program. Another fact sheet (including a
technical summary) might be prepared to explain the findings of the remedial
investigation and to outline each of the remedial alternatives considered for
the Sludge Pond site. A detailed description of the Agency's preferred
remedial alternative(s) should also be provided.
K-?7
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9375.1-4-k
6- Provide news releases to local newspapers: Prepared statements might
be released to local papers, such as the Litchfield County Herald and the
Waterbury Republication to announce discovery of any significant findings at
the site during the RI/FS, or to notify the community of any public meetings.
Additional news releases are advisable at the following milestones:
• Upon completion of the draft FS report; and
• Prior to initiation of remedial action.
Addresses and phone numbers of local newspapers are included in Appendix A.
1• Hold public meeting; A public meeting held during the public comment
period would provide an opportunity for EPA to answer citizens' questions
directly and to receive the recommended remedial alternative. According to
community residents, as few as twenty or as many as two hundred community
residents might attend such a meeting. Planning should therefore be
flexible. A suggested location for this meeting is the auditorium of one of
Woodbury s public schools (Elementary, Middle or High School.) The meeting
should be coordinated with the Woodbury and Watertown Township Officers.
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* * * March 1986 Draf-t * * *
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P-375. l-4-k
Community Relations
Tcchn i QUB
1) Information Rcposi
2) establish In format
Contact
3) Meetings w/ Local
'i ) Telephone Contact
Complet ion
of the
Work Plan
tory X —
ion X —
Officials X
X --•
LXiiiBll 3
1 1 M 1 NC
Completion or
During Remedial the Remedial
Investigation Investigation
During the Completion of Completion of
Feasibility the Draft the final
Studv(FS) FS Report FS Heoort
X
ins t let ion of
Pamrd la 1
r-.c 1 1 on
_. . x
X
X
x
w/ Local Officials
5) Informal Discussion
w/ Residents
6) Fact Sheets/Technical
Summaries
7) News Releases
8) 3-Week Public Comment
Pe r i od
9) Ptibl ic Meet ing
10) Responsiveness Summary
11) Revise CRP
..... provide as needed
X
X-
X
X
* * * March 1986 Draft * * *
K-2Q
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ATTACHMENT A
LIST OF CONTACTS AND INTERESTED PARTIES
A. Federal Elected Officials
(names and addresses) (phone)
B. State Elected Officials
(names and addresses) (phone)
C. Local Officials
(names and addresses) (phone)
D. U.S. EPA Region I Officials
(names and addresses) (phone)
E. State and Local Agencies
(names and addresses) (phone)
F. Community Organizations, Environmental Groups, and
Citizens' Groups*
(names and addresses) (phone)
G. Newspapers
(name and address) (phone)
*Names and addresses of private citizens should not appear in the
community relations plan that is released to the public.
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ATTACHMENT B
LOCATIONS FOR INFORMATION
REPOSITORY AND PUBLIC MEETING
Information Repository;
Woodbury Public Library (203) 246-4567
202 V. State Street
Voodbury, Connecticut 06798
Hours: Mon-Fri 9 am-9 pm
Sat 9 am-5 pm
Sun 12 noon-5 pro
Woodbury Public Schools (203) 246-1234
Elementary School
231 Chapel Street
Voodbury, Connecticut 06798
Middle School (203) 246-2468
105 E. Main Street
Voodbury, Connecticut 06798
High School (203) 246-1359
414 V. Main Street
Voodbury. Connecticut 06798
Voodbury Township Office (203) 246-4568
(basement of Voodbury Public Library)
202 V. State Street
Woodbury, Connecticut 06798
K-31
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