Environmental Protection Agency Urttceof Solid Waste and Emergency Response v>EPA DIRECTIVE NUMBER: 9230.0-04 TITLE: Community Relations Guidance for Evaluating Citizen Concerns at Superfund Sites APPROVAL DATE: October 17, 1983 EFFECTIVE DATE: October 17, 1983 ORIGINATING OFFICE: OERR/HRSD £2 FINAL D DRAFT STATUS: REFERENCE (other documents): OSWER OSWER OSWER E DIRECTIVE DIRECTIVE D ------- 03/19/87 United Statee Envlronmerrtal Protection Agency Washington, D.C. 20460 EPA OSWER Directive Initiation Reques 2. Originator Information Name of Contact Person Mil Cod* Office GEMMILL OERR/HRSD 3. Title COMMUNITY RELATIONS GUIDANCE FOR EVALUATING CITIZEN CONCERNS AT SUPERFUND SfT*S 1. Directive Number ,* 9230.0-04 Telephone Number 382-2460 4. Summary of Directive (Include brief statement of purpose) Guides Regional and State community relations staffs in conducting and evaluating on-site discussions with citizens and local authorities prior to non-emergency Superfund response actions, (10/17/83. 13 pp) 5. Keywords SUPERFUND, CERCLA, COMMUNITY RELATIONS 6a. Does this Directive Supersede Previous Dlrectlve(e)?| | yes | X| NO b. Does it Supplement Previous Directive**}? | } yes 1 X NO v\ 7. Draft Level A-SignedbyAA/DAA '" "] B • Signed by Office Director c-FbrHevi This Request Meets OSWER Directives System Format 8. Signature of Lead Office Directives Coordinator 9. Name and Title of Approving Official THOMAS What directive (number, title) ftat directive (number, title) ew A Comment I I In Development Date Date 10/17/83 OSWER OSWER OSWER DIRECTIVE DIRECTIVE ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 t OCT I T i:&3 OSWER Directive 9230.0-4 MEMORANDUM SUBJECT: Community Relations Guidance for Evaluating Citizens ("Concerns at Superfund Sites FROM: ^^Lee M. Thomas, Assistant Administrator Office of Solid Waste and Emergency Response JdSeffnine S. Cooper, Special Assistant // to the Administrator for External Affairs TO: Addressees The attached document has been prepared to provide Regional and State community relations staffs with guidance for conducting and evaluating on-site discussions with citizens and local officals prior to non-emergency Superfund response actions. These discus- sions provide an opportunity 1) for citizens to express their concerns about the site and 2) for EPA or the State to obtain information that may be useful in planning response actions. As a result of these discussions, community relations staff should be able to understand the site's history from the community's perspective, to identify concerned citizens, officals, and groups, and to evaluate the nature and level of citizens concern. The results of these discussions must be described in the Community Relations plan (CRP) and must form the basis of community relations activities conducted during the response action. During the June meeting of the Regional Superfund Community Relations Coordinators, several Coordinators shared their exper- iences with on-site discussions. During the on-site discussions held thus far, citizens and officials have appreciated the oppor- tunity to express their concerns to government officals before response actions are underway. Early contact with concerned citizens and officials demonstrates that SPA or the State is trying to be responsive to local needs. At the Chera-Dyne site in Ohio, for example, the Regional community relations staff made early contact with the Hamilton Appalachian Peoples' Service Organization {HAPSO), an active citizen group. Despite the delays in initiating site work at Chem-Dyne, EPA established a good working relationship with HAPSO because the early and ongoing contact with the group. ------- OSWER Directive 9230.0-4 -2- Experience has shown, moreover, that community relations staff obtain valuable information about the nature of site contamination or about potentially responsive parties during these discussions, and that this information facilitates selecting the appropriate response action. At the Laskin/Poplar Oil site in Ohio, early contact with local citizens prompted some of those people to pro- vide information about the activities of the current owner of the site that was previously not known by EPA. An on-site 'discussion is not a required activity prior to an immediate removal action. It may, however, be a useful communica- tions technique when combined with efforts to inform citizens about the technical work at sites where emergency actions are scheduled. At a site near Gaffney, South Carolina, for example, the Regional Community Relations Coordinator visited local residents four days betore removal actions were to begin. While part of the purpose of the visits was to inform the local residents of the emergency actions EPA was about to undertake, the Coordinator also inquired about the site history and citizen concerns about the quality of well water in the area around the site. By asking residents if they had any complaints about well water, the Coordin- ator responded to citizen concerns and gathered valuable information about the nature of the site problems. The purpose of this guidance, therefore, is to support the on- site work that is already taking place in the Regions and to encour- age those Regions that have not conducted on-site discussions to implement this valuable two-way communications tool as soon as possible. I ask you to share this guidance with the State staff that have community relations responsibilities defined in coopera- tive agreements. The attached guidance document has three parts in addition to the introductory materials. The first describes how to gather the necessary background information to plan the on-site discussions. The second section offers guidelines for conducting effective discussions. The final section provides criteria for evaluating the discussions in preparation for briefing EPA or State staff and for developing the CRP. The guidance has been reviewed both at EPA Headquarters and in the Regions. We will continue to look forward to your comments on this paper as you gain more experience in performing on-site discus- sions and in evaluating the nature of citizens' concerns. I urge you to provide additional comments to Ms. Daphne Gemmill (FTS-382- 2460), and to contact her if you have any questions. ------- OSWER Directive 9230.0-4 -3- Addressees: Regional Administrators (Regions I-X) Public Affairs Directors (Regions i-x) Air and Hazardous Waste Division Directors (Regions I-X) Environmental Services Division Directors (Regions I-X) Superfund Coordinators (Regions I-X) Superfund Community Relations Coordinators (Regions I-X) Attachment ------- OSWER Directive 9230.0-4 COMMUNITY RELATIONS GUIDANCE FOR EVALUATING CITIZEN CONCERNS AT SUPERFUND SITES August 1983 ------- OSWER Directive 9230.0-4 1. INTRODUCTION This document provides guidance for planning, conducting, and 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 EPA-supervised contractors. Community relations activities must be based upon information derived from on-site discussions with concerned citizens and local public officials to ensure chat EPA or the state responds to local concerns and major issues. Results of the on-site discussions should be incorporated into Community Relations Plans (CRP) -- the planning, management, and budget cornerstone of the community relations program for each site. Activities specified in tha 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 informal meetings conducted to provide community relations staff with the background information necessary to understand the site's history from the community's perspective, to identify concerned citizens, officials, and organized groups, and to evaluate the scone and nature of citizen concern. This information is indispensible in preparing the CRP. The discussions also serve as the initial public input into response plans. Concerns identified in these discussions may be taken into account in developing technical response actions. into account Information derived from on-site discussions may also be useful to the enforcement staff. At sites where enforcement staff are seeking responsible party cleanup, on-site discussions should b« conducted and evaluated by the time notice letters are sent out, so that enforcement personnel may be informed of community concerns before entering negotiations with responsible parties. Thus, these discussions are of critical importance in designing community relations programs that are tailored to a particular community. In turn, they can help in the design and implementation of response actions (including enforcement actions) that meet the community's special needs. They must, however, be conducted with care and discretion. Section 2 of this document describes how to plan and prepare for on-site discussions. Section 3 offers a set of procedures that may be useful for conducting the discussions. Finally, Section 4 provides a framework for assessing the results of the discussions. ------- OSWER Directive 9230.0-4 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 wofk 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 files to obtain relevant meraos, documents, and correspondence; (3) Researching local newspaper 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.) ------- OSWER Directive 9230.0-4 - 3 - 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: • 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 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 ------- OSWER Directive 9230.0-4 - 4 - 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 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 appreciative 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, 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. Since 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. ------- OSWER Directive 9230.0-4 - 5 - 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? ------- OSWER Directive 9230.0-4 - 6 - 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 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 has 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 is 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. ------- OSWER Directive 9230.0-4 - 7 - 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 sufnmary 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. ------- OSWER Directive 9230.0-4 - 8 - 4. EVALUATING DISCUSSIONS Based upon the discussion summaries and the notes from each meeting, community relations staff should evaluate the nature and level of citizen concern at the site. This evaluation will be incorporated into the community relations plan. 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 affected by hazardous substances; (2) Economic loss -- whether local homeowners or businesses believe chat 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 the 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 following; (5) Media -- whether events at the site have received substantial coverage by local, state, regional, or national media; and (6) Number affected -- whether more than three or four households perceive themselves as affected by the 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 above characteristics describe the affected community, the community relations staff has 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. Consideration 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, at request. Allegations or opinions expressed by those with whom discussions ------- OSWER Directive 9230.0-4 - 9 - 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 are 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. ------- |