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


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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

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            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.

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                                      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.

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                   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

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     OSWER Directive 9230.0-4
COMMUNITY RELATIONS GUIDANCE FOR EVALUATING
   CITIZEN CONCERNS AT SUPERFUND SITES
             August 1983

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                       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.

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                       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.)

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                       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

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                       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.

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                  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?

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                       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.

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                      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.

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                       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

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                        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.

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