U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Evaluation Report
An Overall Strategy Can Improve
Communication Efforts at
Asbestos Superfund Site in
Libby, Montana
Report No. 11-P-0430
Augusts, 2011
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Report Contributors: Ganesa Curley
Allison Button
Christine El-Zoghbi
Ryan Patterson
Wendy Wierzbicki
Martha Chang
Eric Lewis
Abbreviations
CEP Community engagement plan
CIP Community involvement plan
EPA U.S. Environmental Protection Agency
ERS Environmental resource specialist
FAQs Frequently asked questions
OIG Office of Inspector General
OU Operable unit
Cover photos: from left: EPA information center staff, Libby, Montana;
handouts at the EPA information center. (EPA photos)
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail: OIG Hotline@epa.gov write: EPA Inspector General Hotline
phone: 1-888-546-8740 1200 Pennsylvania Avenue NW
fax: 703-347-8330 Mailcode 8431P (Room N-4330)
online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
11-P-0430
Augusts, 2011
Catalyst for Improving the Environment
Why We Did This Review
In response to a congressional
request, we evaluated how the
U.S. Environmental Protection
Agency (EPA) communicates
information to the public at
the Libby Asbestos Superfund
Site in Libby, Montana.
Background
The Libby site includes
portions of the towns of Libby
and Troy, Montana. An
inactive vermiculite mine
contaminated with naturally
occurring asbestos is located
7 miles outside of Libby.
About 12,000 people live
within a 10-mile radius of the
town of Libby. EPA has
conducted cleanup activities at
the Libby site since 2000.
EPA policy on community
involvement goes beyond the
letter of the law and
recommends implementing
additional activities to ensure
community participation in the
Superfund cleanup process.
For further information,
contact our Office of
Congressional, Public Affairs
and Management at
(202)566-2391.
The full report is at:
www.epa.qov/oiq/reports/2011/
20110803-11-P-0430.pdf
An Overall Strategy Can Improve
Communication Efforts at Asbestos Superfund
Site in Libby, Montana
What We Found
Region 8 does not have an overall communication strategy to guide, coordinate,
and evaluate its communication efforts at the Libby Asbestos Superfund Site.
Despite extensive communication efforts that exceed minimum Superfund
requirements, Region 8 has not fully satisfied community concerns about health
risk or effectively communicated the limitations of its risk assessment. Libby
residents repeatedly raised questions about recontamination and EPA's ongoing
and planned activities, including the cleanup of operable unit 1 and activity-based
sampling events, even though Region 8 has provided information on those
subjects. Recurring questions may signify that Region 8 needs to address them
more clearly.
We also found that some Region 8 outreach products may be difficult for Libby
residents to understand. Some materials intended for the general public are written
for a highly educated audience. Understandable outreach products ensure that
Region 8's messages are successfully communicated to the public.
An overall communication strategy could help Region 8 assess the effectiveness of
and improve its communication activities. Region 8's community engagement
plan could serve as the overall communication strategy with the addition of
guidance-recommended elements. These elements include key messages,
timelines, measures of success, and mechanisms for identifying public concerns
and obtaining public feedback. The addition of these elements to the community
engagement plan may assist EPA in better addressing community concerns and
helping the public make informed decisions regarding risk.
What We Recommend
We recommend that the EPA Region 8 Regional Administrator ensure that Libby
outreach products are readable for a general audience. We also recommend that
the Regional Administrator revise the Libby community engagement plan to serve
as the overall communication strategy by adding key messages to address specific
public concerns and site activities, timelines for community involvement activities
and outreach products, measures for successful communication, and mechanisms
for identifying community concerns and collecting feedback. We also recommend
implementing a process for ongoing evaluation of Region 8's communication.
Region 8 agreed to take sufficient corrective actions.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
Augusts, 2011
MEMORANDUM
SUBJECT: An Overall Strategy Can Improve Communication Efforts at
Asbestos Superfund Site in Libby, Montana
Report No. ll-P-0430
FROM: Arthur A. Elkins, Jr.
Inspector General
TO: James B. Martin
Regional Administrator, EPA Region 8
This is a report on the subject evaluation conducted by the Office of Inspector General (OIG) of
the U.S. Environmental Protection Agency (EPA). This report contains findings that describe the
problems the OIG has identified and corrective actions the OIG recommends. This report
represents the opinion of the OIG and does not necessarily represent the final EPA position.
Final determinations on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.
The estimated direct labor and travel costs for this report are $543,000.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 90 calendar days. Your response will be posted on the OIG's public website, along
with our comments on your response. Your response should be provided in an Adobe PDF file
that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of
1973, as amended. If your response contains data that you do not want to be released to the
public, you should identify the data for redaction. You should include a corrective actions plan
for your actions, including milestone dates. We have no objections to the further release of this
report to the public. This report will be available at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Wade Najjum,
Assistant Inspector General for Program Evaluation, at (202) 566-0832 or najjum.wade@epa.gov:
or Eric Lewis, Director, Special Reviews, Office of Program Evaluation, at (202) 566-2664 or
lewis.eric@epa.gov.
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An Overall Strategy Can Improve Communication 11-P-0430
Efforts at Asbestos Superfund Site in Libby, Montana
Table of Contents
Chapters
1 Introduction 1
Purpose 1
Background 1
Noteworthy Achievements 2
Scope and Methodology 3
2 Overall Communication Strategy Needed for the
Libby Asbestos Superfund Site 4
Libby Residents Concerned About Health Risks and Site Activities 4
Readability Levels of Outreach Products Limit Communication 5
CEP Could Serve as Communication Strategy With Addition of
Key Elements 6
Conclusion 8
Recommendations 8
EPA Region 8 Response to Draft Report and OIG Evaluation 9
Status of Recommendations and Potential Monetary Benefits 10
Appendices
A Description of Operable Units at the Libby Asbestos Superfund Site 11
B Communication Strategy Key Elements 12
C EPA Region 8 Response to Draft Report 13
D Detailed OIG Evaluation of EPA Response 25
E Distribution 27
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Chapter 1
Introduction
Purpose
In August 2010, congressional requestors asked the U.S. Environmental
Protection Agency (EPA), Office of Inspector General (OIG), to investigate
EPA's efforts to communicate the risks of asbestos exposure in Libby, Montana.
In response, the OIG agreed to evaluate how EPA communicates information to
the public at the Libby Asbestos Superfund Site.
Background
Site History
The Libby Asbestos Superfund Site includes portions of the towns of Libby and
Troy, and an inactive vermiculite mine. The mine is 7 miles northeast of the town
of Libby. About 12,000 people live within a 10-mile radius of the town of Libby.
Vermiculite had been mined at the site since the 1920s. The vermiculite from the
mine was contaminated with asbestos. Asbestos is a human carcinogen that causes
mesothelioma and lung cancer. The mine closed in 1990, but may have produced
up to 80 percent of the world's vermiculite. EPA started cleanup activities in
2000. In 2002, the area was listed as a Superfund site. Since 2007, EPA has
conducted activity-based sampling as part of its overall site evaluation. The
sampling measures personal exposure levels by simulating daily activities. EPA
declared the site a public health emergency on June 17, 2009.
The site is divided into eight cleanup areas, or operable units (OUs). Appendix A
lists all eight OUs. OU1 and OU4 have been the focus of many community
concerns identified in our evaluation. OU1 includes the former export plant and
Riverside Park. EPA removed contaminated soil and issued a remedy in May
2010 for OU1. OU1 will be referred to as the export plant in this report. As of the
end of the 2010 construction season, EPA has conducted cleanups for parts of
OU4, including 1,460 businesses and homes.
Superfund Communication Strategies
Code of Federal Regulations Chapter 40, Part 300.430, requires EPA to prepare a
community relations plan. This plan is also referred to as the community
involvement plan (CIP). The EPA Superfund Community Involvement Handbook
presents legal and policy requirements for community involvement. The
Handbook identifies the CIP as the comprehensive strategy for all community
involvement and outreach at a site. It specifies activities to address community
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concerns and expectations. Region 8's guide for outreach activities at Libby is the
community engagement plan (CEP).
The Super/and Community Involvement Toolkit suggests developing one overall
communication strategy and many message specific strategies to meet the
communication needs of a site. These needs are outlined in the CIP. The Toolkit
suggests incorporating the overall communication strategy as part of the CIP. The
Toolkit also recommends elements to plan for communication. These elements
include identifying goals, key messages, audiences, concerns, activities, and
timelines. It also includes setting measures for success and feedback mechanisms.
These elements are described in appendix B.
Noteworthy Achievements
Region 8 communication efforts at the site
exceed minimum community involvement
requirements. Region 8 has selected
spokespersons, conducted community
interviews, prepared a CEP, and established an
information repository. Region 8
communicates with the public by providing
information in fact sheets, mailings,
newspapers, public meetings, and letters. For
example, site team members travel to Libby
monthly to meet with community groups.
Region 8 also makes information available to
the public on its website. Since the start of our
review in November 2010, EPA has updated
the Libby website and expanded the Frequently
Asked Questions (FAQs) section. In January
2011, the OIG found over 280 documents on
the EPA Libby website.
Figure 1: Libby webpage index
Site
Risk Assessment
Cleanup Activities
of
In
Contacts
Source: EPA Region 8 Libby Asbestos
website, http://www.epa.gov/libby/,
January 2011.
In 1999, Region 8 established an information center in downtown Libby. The
center is a community resource that provides information about EPA's work. We
identified approximately 30 handouts on display at the center. Additional
documents were available in binders and on shelves. Region 8 also has a database
of resident inquiries. Since 2005, a project manager has been located at the
information center.
Region 8 also provides support through its environmental resource specialist
(ERS) located in Libby. The ERS assists residents with questions about
vermiculite and asbestos. The ERS has responded to over 475 phone calls since
2007.
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Scope and Methodology
We conducted this evaluation from November 2010 to June 2011 in accordance
with generally accepted government auditing standards. Those standards require
that we plan and perform the review to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our
objective. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our objective.
We reviewed EPA policies and guidance to identify the requirements for
community involvement and communications. We also reviewed Region 8's CEP
described by the site team as the guide for conducting outreach activities at the
site.
We analyzed minutes and recordings from public meetings. These meetings
included those of the community advisory group, technical advisory group, board
of county commissioners, and city council. We also reviewed information center
database entries from the Libby Hotline and the ERS call log.
We interviewed staff from the EPA Office of Solid Waste and Emergency
Response and the Region 8 Superfund Remedial Response Program. We also
reviewed the information on EPA's Libby website and at the Libby information
center. The scope of our evaluation includes Region 8 communication and
activities from 2007 to 2010.
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Chapter 2
Overall Communication Strategy Needed for the
Libby Asbestos Superfund Site
Region 8 does not have an overall communication strategy to plan, coordinate,
and evaluate communication efforts at the Libby Asbestos Superfund Site.
Despite extensive communication efforts, Region 8 has not fully satisfied
community concerns about health risks or effectively communicated the limits of
its risk assessment. Residents also have recurring questions about
recontamination, the export plant, and activity sampling, even though Region 8
has provided information on those subjects. We also found that many public
documents may be difficult for Libby residents to understand. These documents
are often written for a highly educated audience. While not required, an overall
communication strategy can help Region 8 evaluate and improve its
communication activities. Region 8's CEP could serve as the overall
communication strategy with the addition of guidance-recommended key
elements. These include key messages, timelines, measures of success and
feedback mechanisms.
Libby Residents Concerned About Health Risks and Site Activities
Region 8's communication efforts may never fully address the community's main
concern. Community members consistently ask, "Is the Libby site safe?" Region 8
has performed considerable risk communication over the last 2 years. This includes
explaining risk assessments and their limitations on its website However, Region 8
staff noted that many Libby residents still expect that EPA's pending risk
assessment will provide answers on safety. Risk assessments are not designed to
definitively determine whether a site is safe. Instead, they identify levels at which
the risk posed to human health is low enough to warrant no further cleanup action.
Region 8 maintains that it addresses the uncertainty of not having a risk assessment
through cleanup efforts. EPA's goal is to eliminate exposure pathways to reduce
exposure risk, and therefore, health risks. Completion of the risk assessment has
been postponed from September 2010 to September 2012. Until then, Region 8
could use residents' questions and feedback to plan communications that address
health and safety concerns and risk assessment limitations.
In the interim, Libby residents want more information on ongoing and planned
activities. Residents' questions include whether activity sampling results suggest
that Libby schools are safe, and what steps residents can take to reduce exposure
risk. Table 1 provides a detailed list of issues we identified as being raised in
public meetings and through EPA databases from 2007 to 2010. Recurring
concerns may show that Region 8 needs to address them more clearly.
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Table 1: Libby Resident Concerns Identified by OIG, 2007-2010
Risk communication
Long-term safety of living in Libby and the safety of residents' homes
EPA's methodology for developing cleanup criteria
Status and preliminary findings for the ongoing toxicity study and risk
assessment
Precautionary measures to reduce exposure
Recontamination
Exposure to asbestos during cleanup and from asbestos left in place after
cleanup
EPA procedures and enforcement efforts to address and prevent asbestos
recontamination
Export plant
Rationale for making cleanup decisions prior to completion of a risk assessment
Opportunities for future community involvement in cleanup decisions
Asbestos exposure risk and risk notification
Responsibility for day-to-day site maintenance activities
Activity sampling
Updates for all ongoing and planned activity sampling activities
Results and interpretation of all past activity sampling activities, including their
limitations
Source: Minutes and recordings of public, community advisory group, technical advisory group,
board of county commissioners, and city council meetings; and information center database
entries, including Hotline and ERS call logs.
Readability Levels of Outreach Products Limit Communication
Material in the FAQs section of the Region 8 Libby website is written for a highly
educated audience. Some portions of the FAQs for the Libby site are written at a
graduate-school level. On average, the FAQs are written at a 15th-grade level.
This equates to high school plus 3 years of college. We calculated the level of
Region 8 responses to its FAQs with the Flesch-Kincaid Grade Level Readability
Formula. This formula uses the average number of words per sentence and the
average number of syllables per word. For example, this report is written at a
12th-grade level. EPA recommends that documents be written for a broad public
audience and suggests that they be written at an eighth-grade level. Table 2 details
the reading grade levels of each FAQs section. Material written at these levels
may be difficult for the general public to understand.
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Table 2: FAQ section reading grade levels
TArt *- *-*i Flesch-Kincaid
FAQs sect,on title readjng grade |eve|
General Interest 14
Action Levels and Removal Clearance Criteria 15
Activity-Based Sampling 15
Asbestos Ambient Air Issues 17
Background Levels 11
Communication and Public Involvement 17
Former Export and Screening Plants 14
Grace Settlement Funds 13
Kootenai Business Park 15
Progress of Cleanup 17
Public Health Emergency 14
Public Health Risks 18
Records of Decision 15
Residential Cleanups 13
Risk Assessment 15
Schools 15
Temporary Relocation of Property Owners in Libby 18
Worker Concerns 17
Average of All FAQs 15
Source: EPA OIG analysis of Flesch-Kincaid readability level for all FAQ responses found
on Region 8's Libby website as of January 2011.
CEP Could Serve as Communication Strategy With Addition of
Key Elements
Region 8 does not have an overall communication strategy to guide, coordinate,
or assess communication efforts. Region 8's CEP could serve as the overall
communication strategy with the addition of key elements. These elements
include key messages, general timelines, measures of success, and feedback
mechanisms. Although not required, an overall communication strategy could
guide Region 8's efforts to better determine and address information needs in the
community.
Identifying Key Messages Could Improve Information Consistency
Region 8 does not communicate consistent key messages to Libby residents. We
found variations in what Region 8 staff stated to be key messages. During
interviews, Region 8 staff also noted that inconsistent messages have made
communication of certain topics challenging. One example is health and exposure
risks. Also, information center staff did not have set materials to provide to new
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residents for a variety of general questions. Center staff limited their
recommendations to readily available handouts. Interviews show that the
information center staff is the community's primary information source.
However, the information center maintains only a subset of Region 8's outreach
products in hard copy. Outreach products at the information center, and in
general, should reflect key messages and be accessible to residents. Overarching
key messages ensure that Region 8 staff delivers consistent and helpful messages
to Libby residents.
Timelines Could Help Libby Residents Know When EPA Will Provide
Information
Region 8 can increase its updates of events and publications through general
timelines. Residents want to know when EPA will provide information. We found
that many residents had questions about the status and timeline for the risk
assessment and activity sampling results. Residents want predictable
communication about events, the status of EPA's efforts, and future plans. EPA's
Toolkit recommends establishing a timeline for community involvement activities
that are linked to technical milestones or referenced seasonally or quarterly.
Activities such as annual briefings and updates should be provided on a
predictable basis. However, we found they often are not. Region 8 could create a
forum where upcoming events and new information are constantly posted and
updated.
Measures of Success Could Assist Region 8 in Evaluating Its
Communication Efforts
Region 8 has not established measures of success to assess the effectiveness of its
communication efforts. Measures may include tracking the number of people
reached and changes resulting from activities. Region 8 has exerted much effort
and many resources toward communication and plans to increase its efforts.
Region 8 needs to ensure that its efforts are successful and the community
understands its messages. Establishing measures could help Region 8 improve
communications.
Mechanisms for Obtaining Public Concerns and Feedback Could
Help Region 8 Meet Expectations and Information Needs
Region 8 has not incorporated formal feedback mechanisms to regularly identify
public concerns. Region 8 formally collects resident feedback during mandatory
updates of the Libby CEP and Superfund milestones. However, we found that
Region 8 typically plans communications based on informal discussions with
community members. EPA's Toolkit provides many mechanisms for obtaining
public input. Some are listed in table 3. Site teams can use the Toolkit to evaluate
and refine their work. Region 8 could collect and evaluate feedback through its
website, public meetings, and the information center databases. Through these
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mechanisms, Region 8 could better meet the expectations and information needs
of the community.
Table 3: Examples of mechanisms for identifying concerns and gathering feedback
Release a draft of the CEP for feedback from the community.
When analyzing sampling results, announce results and initial interpretation, and
solicit comments.
Hold informal comment periods to accept feedback on proposed site activities,
decisions, or issues.
Ask people to fill out an evaluation card following meetings, presentations, or
workshops.
Use comment boxes for general feedback.
Conduct a community satisfaction survey midway through cleanup.
Use feedback questionnaires for input from community advisory groups, focus
groups, and public meetings.
Post a website survey that the public can access and fill out.
Source: EPA Superfund Community Involvement Toolkit.
Conclusion
An overall communication strategy can help EPA better plan and evaluate
communication activities and products. In addition, Region 8 documents could be
more useful if written for the general public. Region 8's CEP can serve as its
overall communication strategy by developing feedback mechanisms and success
measures to ensure that the public receives timely key messages.
Recommendations
We recommend that the EPA Regional Administrator, Region 8:
1. Ensure that Libby outreach products are readable for a general
audience.
2. Revise the Libby CEP to serve as the overall communication strategy
by including:
a. Key messages that address specific public concerns and site
activities
b. Timelines for community involvement activities and outreach
products
c. Measures for successful communication
d. Mechanisms for identifying community concerns and
collecting feedback
3. Implement a process for ongoing evaluation of Region 8's
communication strategy and incorporate results into community
involvement planning.
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EPA Region 8 Response to Draft Report and OIG Evaluation
The OIG reviewed and considered Region 8 comments. The report was revised
where appropriate. Region 8's comments are in appendix C and the OIG's
detailed evaluation is in appendix D. In its official response, Region 8 agreed with
recommendations 1 and 3 but did not fully agree with recommendation 2.
However, Region 8 agreed with all three recommendations after followup
discussions. The region has committed to completing actions that will meet the
intent of the recommendations.
Region 8 agreed with our first recommendation to revise the FAQs section of the
website. It will also assess the readability level of future fact sheets to ensure that
both are at or below a 12th grade reading level.
Region 8 initially disagreed with recommendations 2a and 2b. Region 8 stated
that key messages and timelines are more appropriate for communication
strategies and not CIPs. The CEP is Libby's CIP. Region 8, however, offered to
provide an approximate timeline of activities for the upcoming year at annual
meetings and through annual fact sheets. Because Region 8 does not have an
overall communication strategy, Region 8 agreed in discussions to use the CEP as
this strategy. It will include in the CEP the recommended elements from the
report. Overarching key messages, such as for risk communication, will be
developed by the site team and through resident interviews. General timelines
informing the community of upcoming events will be available and routinely
updated at the information center and on the Libby website.
In its official response for recommendation 2d, Region 8 indicated it will expand
efforts to collect feedback and identify concerns. These include using tear offs on
fact sheets, a comment link on the Libby website, suggestion boxes at information
centers, and comment cards at community meetings and availability sessions. In
addition, Region 8 agreed in discussions to adapt its current database system to
uniformly store, track, and analyze residents' questions and feedback.
Region 8's official response concurred with recommendations 2c and 3. Region 8
will identify quantifiable measures of success and announce their results at annual
update meetings and in fact sheets. In addition, Region 8 indicated in discussions
that it will implement a survey tool to measure customer satisfaction. To further
address recommendation 3, Region 8 will conduct a special round of interviews in
2012. These interviews will focus on community involvement effectiveness at the
site. The results will be incorporated into the CEP. Public comments will also be
solicited for the next major revision of the CEP.
In its final response to this report, Region 8 should provide a corrective action plan
that includes brief descriptions of the actions that will be conducted to implement
each recommendation, milestone or target dates, and the responsible offices.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (in SOOOs)
Rec.
No.
1
2
Page
No.
8
8
Subject
Ensure that Libby outreach products are readable
for a general audience.
Revise the Libby CEP to serve as the overall
communication strategy by including:
Status1
0
0
Action Official
Regional Administrator,
Region 8
Regional Administrator,
Region 8
Planned
Completion
Date
Claimed Agreed-To
Amount Amount
a. Key messages that address specific public
concerns and site activities
b. Timelines for community involvement
activities and outreach products
c. Measures for successful communication
d. Mechanisms for identifying community
concerns and collecting feedback
Implement a process for ongoing evaluation of
Region 8's communication strategy and incorporate
results into community involvement planning.
Regional Administrator,
Region 8
0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is undecided with resolution efforts in progress
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Appendix A
Description of Operable Units at the
Libby Asbestos Superfund Site
Operable unit
1
2
3
4
5
6
7
Site description
The former export plant, situated north of downtown Libby, which includes the
embankments of Highway 27, the former export plant, and Riverside Park.
The former screening plant, which includes areas impacted by contamination from
the plant and also includes the Flyway property, a privately owned property, and the
Rainy Creek Road Frontage and Highway 37 right-of-way.
The former vermiculite mine, which includes the surrounding geographic area
impacted by releases from the mine, including Rainy Creek and the Kootenai River.
The City of Libby, which includes residential, commercial, industrial, and public
properties, including schools and parks. OU4 includes only those properties not
included in other OUs.
The Stimson Lumber Mill site, which includes all former properties that are now
owned and managed by the Kootenai Business Park Industrial Authority.
The Burlington Northern Santa Fe Railroad yard and transportation corridors.
The Town of Troy, which includes all residential, commercial, and public
properties, located approximately 20 miles west of downtown Libby.
U.S. and Montana state highways and secondary highways that lie within the
boundaries of OU4 and OU7.
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Appendix B
Communication Strategy Key Elements
The Superfund Community Involvement Toolkit identifies basic elements, key questions, and
other guidance for site teams to consider when developing overarching communication strategies
for Superfund sites. These basic elements and related key questions are summarized below.
Strategy elements
Goals
Messages
Target audience
Public concerns
Activities
Timelines
Measures
Feedback
mechanisms
Examples of key questions
What does EPA want to achieve with the communication? Is EPA
providing information, increasing awareness, encouraging action, changing
behavior, promoting community participation, or something else?
Are goals clear, simple, action-oriented statements about what EPA
hopes to accomplish through outreach?
Do the other elements of the strategy relate to the goal(s)? Once you
have established your goals, every other element of the strategy should relate
to those goals.
Are the messages identified? Focus on two to three key messages and
rank them by importance, timeliness, or other factors.
Have all potential audiences been identified?
Once messages are identified, ask yourself: Who is involved, affected,
interested? What information do they already have? What information
do they need?
Has the community involvement plan been prepared based on
community interviews and other relevant information?
Is the plan issue-specific in that it identifies the community's issues,
needs, and concerns?
Are specific community involvement activities and outreach products
identified?
Do activities and outreach products address public concerns? The
community involvement plan should identify specific activities, outreach
products, or programs that EPA will use to address the community's
concerns.
Is there a timeline for activities throughout the pipeline (e.g., as the site
team gets sampling results, we will hold a series of ground water workshops),
or referenced by seasons (e.g., by spring 2002, we will hold a ...)?
How will EPA know if its communication goals are met?
Are measures of success identified?
Are there mechanisms for audiences to provide feedback?
Is EPA gathering and reviewing feedback after delivery? Feedback can
be used to evaluate progress and identify concerns for planning information
needs.
Based on audience feedback and measures for success, determine: What
are the strategy strengths? Where can it be improved? How should your
strategy be amended to ensure continued effectiveness?
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Appendix C
EPA Region 8 Response to Draft Report
June 28, 2011
Ref: 8RA
MEMORANDUM
SUBJECT: Region 8's Response
OIG Draft Evaluation Report:
EPA Can Improve Its Communication Efforts at
Asbestos Superfund Site in Libby, Montana
Project No. OPE-FY11-0005
FROM: James B. Martin
Regional Administrator
TO: Wade T. Najjum
Assistant Inspector General for Program Evaluation
Attached is EPA Region 8's response to the Office of Inspector General's (OIG) Draft
Evaluation Report Project No.OPE-FY11-0005, EPA Can Improve Its Communication Efforts at
Asbestos Superfund Site in Libby, Montana. The response addresses factual issues, provides
information on Region 8's community involvement program in Libby, Montana, indicates
concurrence or nonconcurrence with each finding and proposed recommendation, and identifies
alternative approaches to addressing some recommendations.
If you have any questions regarding this report, please contact me or your staff may contact
Sonya Pennock, Supervisor, Public Affairs and Involvement/Office of Communications and
Public Involvement, at 303-312-6600 or pennock.sonya@epa.gov.
Attachment
cc: Mathy Stanislaus, Assistant Administrator for Solid Waste and Emergency Response
Jim Woolford, Director, Office of Superfund Remediation and Technology Innovation
Paul Anastas, Assistant Administrator for Research and Development
11-P-0430 13
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Environmental Protection Agency, Region 8
Response to
Draft Evaluation Report - Office of Inspector General
EPA Can Improve Its Communication Efforts at Asbestos Superfund Site in Libby
Montana, June 2, 2011
At a Glance: Please revise to reflect any changes made in response to Region 8's comments.
Because EPA's community involvement program in Libby is so extensive, it may have
been difficult for the Inspector General (IG) to determine the extent of our effort in that
community. In addition to responding to recommendations, Region 8's comments are designed
to provide the IG with more information on community involvement and on Region 8's
community involvement efforts in Libby.
Chapter 1
Superfund Communication Strategies
p_J_:"EPA's communication strategy is called the community engagement plan (CEP)."
p.2: "These elements include identifying goals, key messages, audiences, concerns, activities and
timelines. It also includes setting measures for success and feedback mechanisms."
Response: Communication strategies are very different from community involvement plans. It
appears that the IG cited the Superfund Community Involvement Toolkit tool for communication
strategies (Tool #3), not community involvement plans (Tool #7).
Distinction between communication strategy and community involvement plan.
o Tool #3 - Communication strategies are a tool for planning EPA's
communications around a short-term, specific issue, event, action or problem. In
2010, EPA produced communication strategies for the release of activity-base
sampling data in Libby schools, responding to difficult citizens, OU3 Slash Pile
Burning, risk assessment communications and preparation for a CBS News
interview. So far in 2011, Region 8 has drafted two communication strategies for
Libby - Annual Update and Release of Draft Toxicity Values. Region 8 uses
communication strategies as an internal communication planning tool.
o CI Toolkit #7 - Community involvement plans are required by the National
Contingency Plan. They are long-term plans that lay out a broad outline for
communication and involvement over a period of years (up to 5 years). They are
based on community interviews. The Libby community involvement plan was
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titled "Community Engagement Plan" to reflect the preference of the Assistant
Administrator of EPA's Office of Solid Waste and Emergency Response for the
term "community engagement" instead of "community involvement." The Libby
Community Engagement Plan was updated following the OU1 & 2 Records of
Decision in 2010.
Noteworthy Achievements
Response: This section gives short shrift to the vast amount of community involvement and
communication that has taken place at the site. Here are some examples:
An EPA project manager is onsite in Libby and is available to Libby residents for
responses to questions and concerns.
Other Libby site team members travel to Libby monthly and meet with a vast array of
community groups and individuals including the Lincoln County Commission, Libby
City Council, Healthy Communities Initiative (A business and public sector group),
Chamber of Commerce, Lincoln County Health Board, Libby Technical Assistance Grant
recipients, and Community Advisory Group. We meet with other groups as the need and
interest arise. We host periodic drop-in availability sessions where individuals can drop
by and raise questions and concerns with staff. Since the beginning of 2011, we have
hosted nine such availability sessions. We host at least one public meeting each year,
frequently more. The timing of more formal public meetings is dependent on when a
topic is ripe: annual update meeting, proposed plans, release of sampling results, release
of draft toxicity values, etc.
We regularly produce fact sheets and other communication materials. For example, in
2010, EPA produced two proposed plans, the annual project update fact sheet, a fact
sheet on activity-based sampling and a guide to homeowners prior to the onset of
construction on their properties. So far in 2011, we have updated all of the six existing
best practices fact sheets, and drafted the annual update fact sheet, a new best practice
fact sheet for homeowners performing yard work, a fact sheet summarizing the Libby
story, and a fact sheet describing the process for developing toxicity values.
Chapter 2 - Public Communications Can Be Improved at the Libby Asbestos Superfund
Site.
Libby Residents Concerned About Health Risks and Site Activities
P.4: First paragraph, last sentence. "Until then, Region 8 should be clearer about what health and
safety questions these results can and cannot address."
Response: In the past two years, EPA has performed considerable risk communication in Libby.
At our monthly meetings with community groups, much of our discussion hinges around risk-
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related issues. We've talked with and met with the City Council and David Thompson Search
and Rescue building tenants about risks associated with usage of the park and search and rescue
facility. EPA has produced and distributed seven best practices fact sheets that guide Libby
residents on ways to reduce potential exposures to Libby Amphibole asbestos as they perform
certain activities. Over the years, EPA has discussed risk assessment in many setting with
existing groups like Libby City Council, Technical Assistance Grant (TAG) recipient,
Community Advisory Group (CAG) and at public meetings and availability sessions. In early
2011, EPA conducted a series of 21 workshops in Libby on the risk assessment process. The
presentation at these sessions clearly explained what a risk assessment does and what it does not
do. We also have posted Q & As on the web page with this information.
The fact that there are no Libby Amphibole asbestos-specific toxicity values has complicated our
ability to make definitive assessments of site risks.
In May 2011, EPA released the draft toxicity values for Libby Amphibole asbestos. This was a
precedent-setting action. It is not EPA policy to provide information to the public about draft
Integrated Risk Information System (IRIS) toxicity values that are still undergoing review within
EPA and intergovernmental review. The Agency waits until the formal public comment process.
However, given the impact that the draft toxicity values will have on EPA's assessment of the
risks and subsequent cleanup decisions, the Agency felt it was appropriate to provide the draft
IRIS toxicity information before it went to intergovernmental review. The week of May 3, 2011,
headquarters and Region 8 staff met with key stakeholders and groups, hosted a public meeting
and held 2 availability sessions to discuss the draft values and initial information on how those
values might impact site risks (A total of 18 meetings were held.). These meetings were followed
by more meetings and availability sessions the week of May 10, 2011. At these meetings,
citizens asked questions, shared opinions and made suggestions to EPA staff. At these meetings,
we provided the public with special annotated copies of the PowerPoint presentation, the annual
update fact sheet, a background fact sheet on EPA's involvement in Libby and a fact sheet
explaining what toxicity values are, how the values are used in the risk assessment process, and
what the IRIS review process for the draft toxicity values will be. Region 8 has since begun
discussions with key stakeholders on the impact the draft values have on our ability to make
cleanup decisions for OUs 5 and 8.
P4, last paragraph: "In the interim. Libby residents want more information on ongoing and
planned activities. Residents' questions include whether activity sampling results suggest that
Libby schools are safe and what steps residents can take to reduce exposure risk."
Response:
At the 2010 annual update public meeting EPA presented the sample results from Libby schools
to the community and explained their significance. EPA also met with the Libby School District
to explain the results. At the May 2011 public meeting on the draft toxicity values, EPA
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specifically showed how those draft toxicity values, coupled with exposure data impacted our
understanding of risks at the Libby schools. We also are placing this information in the FAQ
section of the Libby web page. EPA has produced and distributed seven best practice fact sheets
that guide residents on how to reduce exposures has they perform certain activities.
P. 5 Table 1 Recurring Communication Issues
Response:
Please clarify if the IG is suggesting that the matters are not resolved for lack of an effort at
communication. EPA has exerted considerable effort to address the concerns identified in this
table and will continue to do so. In some cases, EPA does not yet have enough information to
fully address the issue. In other cases, some citizens disagree with EPA's response. Below is a
summary of our efforts:
Risk Communication:
o EPA has discussed risks and its approach to risk reduction throughout the process.
o So far in 2011, EPA has conducted a series of 21 risk assessment workshops and
has released draft toxicity values for Libby Amphibole asbestos.
o As the IG pointed out, EPA doesn't use the term "safe." Our goal is reduce risk
from exposure to target levels. EPA staff have explained this distinction in fact
sheets, decision documents, web site Q & As, and at meetings.
o Until the IRIS process for identifying toxicity values for Libby Amphibole
asbestos is completed, EPA cannot produce a final risk assessment.
o In the meantime, EPA is using existing toxicity information for asbestos to guide
our cleanup criteria for interim response actions. During our monthly meetings we
keep citizens apprised of the status of response activity and study progress.
o EPA was not in a position to discuss the toxicity values specific to Libby
Amphibole asbestos until the information had been reviewed within EPA. That
review was completed at the end of April 2011.
o In May 2011 EPA released the draft toxicity values that are undergoing IRIS
review. At that time EPA conducted extensive public outreach. The process used
is discussed above.
o EPA has developed a series of seven best practice fact sheets that provide
information on precautions that residents can take to reduce exposures. These fact
sheets are distributed at public meetings, available in the Libby and Troy
information centers and posted on the web page. EPA will continue to develop
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best practices fact sheets when sampling identifies an activity that might increase
exposure to Libby Amphibole asbestos.
Recontamination
o During response actions considerable effort is made to ensure that dust from
construction is not spread. The soil is watered down prior to the onset of work and
kept wet during the response action. The requirement is that no dust be visible
during the response action. In addition, EPA monitors the air to confirm that dust
suppression efforts are successful. Trucks transporting contaminated material
must follow an extensive protocol laid out in the Remedial Action Work Plan
(RAWP) for making sure that the contaminated material is not released on roads.
o EPA's Environmental Resource Specialist has worked with the city and local
construction firms to help them use similar controls when they are disturbing soil
in the community. EPA has discussed its protocols with the city, the county, the
Technical Assistance Grant recipient, the Community Advisory Group, and with
private citizens. EPA also has included the information on the site web page, in
the annual update fact sheet and in all the best practices fact sheets.
o The potential for recontamination is a continuing concern for EPA. This year, in
response to community feedback, EPA revised its removal action approach in
order to reduce the potential for recontamination by addressing alleys adjoining
properties undergoing response actions, removing all shrubs and trees in
contaminated soil and starting to conduct residential response actions on a
neighborhood-by neighborhood basis. This revised approach was discussed at the
public meetings that were held in May, in small group meetings with property
owners and explained in the update fact sheet.
o EPA will undertake activity-based sampling efforts this year and in 2012 designed
to better understand the potential for recontamination.
o In addition, preventing long-term recontamination will be the focus of
institutional controls. For the past few years EPA has convened a work group that
includes local government and private citizens that will help develop long-term
operations and maintenance protocols for the site. In 2011, EPA began discussing
institutional controls at public meetings and held a public Q & A session on the
topic. EPA will continue to seek input from the community as we begin to flesh
out options for long-term institutional controls.
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Export Plant
o Prior to and during the 60-day public comment period for the OU1 proposed plan
there was extensive discussion with local officials, community groups and at the
public comment meeting about EPA's decision to produce a Record of Decision
(ROD). Some elected officials and community members expressed their
opposition to producing a ROD prior to the availability of the final risk
assessment. After considering public input, EPA documented its rationale for
proceeding with the ROD in that document, in the response to comments attached
to the ROD and on the web page. In response to public comments, EPA included
a provision in the ROD that, following the construction of the remedy, the Region
will conduct activity-based sampling and, using the Libby Amphibole asbestos-
specific draft toxicity values, update our assessment of risks to be sure that the
remediation is protective.
o EPA continues to meet at least monthly with the city in a public forum to discuss
the cleanup of OU1. We have provided risk information to the city and have
marked areas at the park that should not be disturbed. The property is owned by
the city. The city has a responsibility to notify those given permits for park use of
the precautions that need to be taken. The remediation of the former export plant
property is scheduled for the 2011 construction season.
Activity-based sampling
o In 2010, EPA developed and distributed flyers and published a public notice on
activity-based sampling (ABS) explaining why we were doing it and describing
what people were likely to observe. EPA also has explained the ABS results as
they relate to specific areas with the appropriate stakeholders such as the school
board. ABS information and sample results are posted on the Libby web page.
o At the May 2011 public meeting, EPA described its activity-based sampling plans
for 2011.
o Information and questions about ABS are included on the site web page.
Readability Levels of Outreach Products Limit Communication
Response:
Because of the technical nature of some of the subject matter, EPA continually struggles with the
difficulties of making its information understandable to citizens. There is an ongoing "pull and
tug" between the need to be accurate and the need to be easy to understand. In addition, there are
some residents in Libby who have accused EPA of "dumbing down" its informational materials.
Others have requested that we strive to make our materials easier to understand. A random
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analysis of fact sheets produced in the past two years indicates that fact sheet reading levels
range from Grades 9.9 to 13.8. We strive to reach a 12th grade reading level or below. We agree
that we should have paid closer attention to the reading level of the FAQs and will review and
revise either by rewriting or adding a simplified summary at the beginning of the question.
Addition of Key Elements Could Strengthen Region 8's Communication Strategy
Response:
It appears that the IG is applying the communication strategy guidelines to the community
involvement plan. As explained in an earlier response, they are different documents that serve
different purposes.
Identifying Key Messages Could Assist Region 8 staff.
o Because the community involvement plan is a long-range (up to 5 years)
communication plan, it would be very difficult to include key messages that
would remain relevant for that period. When EPA develops communication
strategies for specific actions, issues, events, it does include key messages
pertinent to that subject and incorporates these messages in its outreach associated
with the specific action, issue or event.
Timelines Could Help Libby Residents Know When EPA Will Provide Information
o EPA meets monthly with various community groups including public meetings
with the TAG and CAG. These meetings are held on the same day and time each
month and are noticed in the newspaper.
o We have found that trying to arbitrarily set time frames for formal public
meetings (for example, quarterly meetings) is not an effective use of community
or EPA staff time. If there is no new information to provide and discuss, people
who come to the meeting feel that their time has not been well used. Instead, in
consultation with elected officials and other key stakeholders, we plan formal
public meetings when we have information that will be of interest to the
community such as reporting sample results, annual pre-construction season
meetings, and release of draft toxicity values. We also hold public meetings in
response to community requests for information on a specific topic. For example,
EPA recently hosted a public Q & A sessions focused on the bark piles on OU5
and future remedy operations and maintenance. EPA wants to host meetings at
meaningful times. EPA provides several weeks' advance notice of public
meetings.
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Measures of Success Could Assist Region 8 in Evaluating Its Communication Efforts
o While we try to gauge success by seeking informal public feedback, we agree that
trying to more systematically measure community involvement is desirable.
o One of the obstacles we face is that some of the tools generally used to evaluate
effectiveness such as surveys, questionnaires and focus groups are, as a practical
matter, not feasible due to the requirements of the Paperwork Reduction Act. It
takes approximately 6-9 months to get an Information Collection Request
approved by OMB.
o The Community Involvement Impact Analysis Project referred to in Table 3 is no
longer available and the questionnaire has expired.
Mechanisms for Obtaining Public Concerns and Feedback Could Help Region 8 Meet
Expectations and Information Needs.
o As indicated above, there are obstacles to using some tools for seeking feedback.
o Periodically, EPA has included "tear offs" in fact sheets seeking feedback on the
understandability of the information, identifying other information people might
want to have, etc. We have received feedback through this approach that has
helped us identify future topics for fact sheets and areas where we need to
improve our communications.
o Periodically, EPA provides comment cards at public meetings seeking input on
the understandability of the information presented and seeking input on other
topics of interest and suggestions for improving the public meetings. The
feedback received through this mechanism has helped EPA's site team learn if
meeting presentations have been clear and understandable and if the format
worked for the community.
o EPA regularly seeks informal suggestions for improving our public process from
those individuals and groups with whom we meet and incorporates these
suggestions into our program when feasible.
The goal of community involvement in the Superfund process is to make sure that interested
citizens at Superfund sites have access to site-related information and an opportunity to
participate in EPA's process. Community involvement efforts cannot guarantee that citizens will
agree with EPA's actions, assure that EPA can do what citizens' want, or provide answers to
questions for which the necessary information is not yet available. Region 8 believes that the
extensive community involvement process in Libby provides easy access to site-related
information and many opportunities for interested citizens to participate in our remedial process.
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Over the years, EPA has responded to input received from the public. For example, in response
to concerns about the shrinking economic base of the community, EPA hosted two
redevelopment workshops. When Stinger Welding was considering moving to Libby, EPA
worked with the city and the company to make sure that contamination issues were resolved to
expedite the move. In 2009, in response to long-standing community concerns about health care
for those with asbestos related disease, EPA issued its first ever finding of a public health
emergency under Superfund which paved the way for the Department of Health and Human
Services to provide health care assistance. At the present time, in response to the city's desire to
expand Riverside Park, EPA is working with the city to tailor the OU1 cleanup to facilitate
redevelopment. EPA is also providing the city with funding for part of this work. Because
residential property owners have been dissatisfied with the quality of replacement soil that is
being used in residential response actions, this year EPA has brought in a soils expert to advise
the agency on how to amend the replacement soil so that it provides a better growing medium.
Recommendations
1. Ensure that Libby outreach products are readable for a general audience.
Response:
EPA concurs with this recommendation.
EPA will run the Flesch-Kincaid Grade Level Readability Formula on all future
fact sheets in order to produce fact sheets at or below a 12th grade reading level.
EPA will revise the FAQ section of the of the web page and either rewrite Q & As
that require more than a 12th Grade reading level or include a simple summary of
the response at the beginning of the answer. The revision of the FAQ section will
be completed by 12/31/11.
2. Revise the Libby CEP to include
a. Key messages that address specific public concerns and site activities
b. Timelines for community involvement activities and outreach products
c. Measures for successful communication
d. Mechanisms for identifying community concerns and collecting feedback
Response:
EPA partially concurs with this recommendation.
a) & b) are not appropriate for a community involvement plan. Key messages and
timelines for activities are more appropriate for communication strategies. EPA's
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communication strategies have and will continue to include key messages and
timelines for the specific activity, issue or event.
At the annual update meeting and through the annual update fact sheet, EPA will
include an approximate timeline for site activities for the upcoming year and will
identify those community involvement activities planned for the year and the
approximate timing for the activities. The next annual update meeting and fact
sheet will be in the spring of 2012.
c) EPA will identify quantifiable general measures of success. The measures will
be discussed in the spring 2012 update meeting and placed in the December 31,
2012 addendum to the 2010 Community Engagement Plan.
d) Region 8 will use fact sheet tear offs in all fact sheets, distribute comment
cards at all public meetings and availability sessions, add a comment link on
EPA's Libby web page and place suggestion boxes in the Libby and Troy
Information Centers as mechanisms for the public to identify concerns and
provide feedback. The web page link and suggestion boxes will be in place by
September 3 0,2011.
3. Implement a process for ongoing evaluation of Region 8's communication strategy and
incorporate results into community involvement planning.
Region 8 concurs that the site team should engage in ongoing evaluation of the
community involvement program.
In response to recommendations 2.c. and 3 Region 8 will identify quantifiable
measures of success and announce them at the annual update meeting and in the
update fact sheet in spring of 2012. Each year at the update meeting and in the update
fact sheet, EPA will report on these measures.
Measuring community involvement effectiveness is inherently subjective. As we have
explained in this response document, the limitations imposed by the Paperwork
Reduction Act make evaluating community involvement, even subjectively, hard to
accomplish. Given these limitations, Region 8 will endeavor to use the community
interview process for community involvement plans, which is exempt from the
requirements of the Paperwork Reduction Act, to periodically evaluate community
involvement in Libby. In 2012, Region 8 will conduct a special round of interviews
focused on the effectiveness of community involvement in Libby. The Region will
report the results of these interviews in an addendum to the 2010 Community
Engagement Plan along with an outline of actions the Region will take to address
shortcomings identified in the interviews. The addendum will be published by
December 31, 2012. Region 8 also will include evaluation questions in the interviews
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that will be conducted for the next major update of the Community Engagement Plan.
This update will take place following the next Record of Decision or in 2015
whichever comes first.
Region 8 will solicit public comment on the next major revision of the Community
Engagement Plan which should take place following the next Record of Decision or
in 2015, whichever comes sooner.
Region 8 will continue to seek informal feedback from the Libby community during
monthly meetings.
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Appendix D
Detailed OIG Evaluation of EPA Response
CIP vs Communication Strategy
Region 8's response states that communication strategies are very different from community
involvement plans (CIPs). This response indicates that the Libby CEP is not the overall
communication strategy for the site. We are aware of the difference between CIPs and
communication strategies and were informed by Region 8 staff during our review that the Libby
CEP serves as its overall communication strategy.
The Superfund Community Involvement Handbook states that "The CIP is the comprehensive
strategy for all community involvement and outreach at the site. A communication strategy for each
element of the overall CIP should guide the development and become part of the CIP" (p. 29).
Tool #3, Communication Strategies, further clarifies this by stating:
A communication strategy is a list of messages, audiences, potential message
vehicles, resources required, and feedback mechanisms to meet the unique
communication needs of a Superfund Site. These needs are outlined in the
Community Involvement Plan prepared for each site. In these cases the Community
Involvement Plan serves as a communication strategy for the site. Message-specific
communication strategies contain the exact details of message content, audience, and
delivery or the individual messages you will develop. You will develop one overall
communication strategy and many message-specific strategies, (p.l)
From our interpretation, EPA's Toolkit advises site teams to develop one overall communication
strategy as well as many message-specific communication strategies. In cases where there is not
a separate strategy, the CIP can serve as the overall communication strategy. The Agency's
response regarding Tool #3 references only message-specific communication strategies, which
we do not include in our discussion of the CEP. We are aware that Region 8 has created
numerous message-specific strategies, which we have reviewed. However, the focus of our
report is the overall communication strategy for the site. Since Region 8 has provided
clarification of the CEP's purpose, we have revised our report to reflect that Region 8 does not
have an overall communication strategy. Our findings indicate that an overall communication
strategy will be useful for communications planning at Libby. Region 8 can revise the CEP to
serve as its overall communication strategy by including key elements. Our recommendations
remain unaffected by this clarification.
Recommendation 2
Region 8's response states that key messages and timelines are not appropriate for CIPs.
Region 8 states that these are more appropriate for message-specific communication strategies
developed for specific actions, issues, and events. Recommendations 2a and 2b do not refer to
key messages or timelines for one-time events, activities, or issues that might need a "message-
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specific" communication strategy. We are referring to the analytical process used to identify the
why, what, who, when, where, and how of relaying information for an overall communication
strategy. Overall key messages help ensure message consistency and delivery for the entire
Libby Superfund site.
Region 8's response also states that because the CEP is a long-range plan, it would be very
difficult to include key messages that would remain relevant. We do not expect these
overarching messages to change frequently, but as the CEP is a living document, we do not
believe that adjusting these messages periodically to reflect new information is unreasonable.
We are not requesting that Region 8 arbitrarily set time frames for formal public meetings. The
Toolkit recommends establishing a timeline for community involvement activities that are linked
to technical milestones, or referenced seasonally or quarterly. Toolkit examples include: "As the
site team receives sampling results, we will hold a series of groundwater workshops," or "EPA
will hold meetings within two weeks of the start of field work to agree on a testing cycle."
Recommendation 2b reflects our concern that notifying residents of meetings and events a
couple of weeks in advance may not provide them with the broad roadmap they seem to want.
In addition, while it is helpful that Region 8 meets monthly with the City Council, County
Commissioners, CAG, TAG, and others, attendance at these meetings is limited. As a result, an
easily-accessible forum that is updated with upcoming events and new or changing information
may satisfy the community's desire to be kept informed of Region 8's activities.
EPA announced in the Federal Register on May 4, 2011, its plans to renew the OMB-approved
Information Collection Request (OMB #2050-0096), expiring July 31, 2011. Upon renewal,
Region 8 can also implement this survey as a tool for measuring customer satisfaction under
Recommendation 2c.
For Recommendation 2d, in addition to tear offs, comment cards, suggestion boxes and Web
links, Region 8 should consider how it plans to uniformly store, track, and analyze incoming
information. Region 8 already has in place a database system that tracks resident questions and
concerns that can be optimized to identify issues and run reports that further guide EPA's efforts.
Region 8 Communication Efforts
Region 8's response details numerous communication activities that were performed in 2011 to
address our findings. As the scope of this evaluation is limited to 2010, we will not include these
activities in our report. We encourage Region 8 to measure the effectiveness of these 2011
communication activities as well as systematically gather feedback to identify additional
concerns and issues. This will assist Region 8 to ensure that communication efforts are meeting
information needs and are presented clearly to the Libby residents.
In addition, table 1 lists the common questions asked by Libby residents during public meetings
and events that we identified during our evaluation. They are provided in this report so that
Region 8 might be aware of frequent topics of concern and seek ways, including those discussed
in the report, to more effectively identify and address these information needs in the community.
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Appendix E
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
Assistant Administrator for Research and Development
Regional Administrator, Region 8
Agency Followup Official (the CFO)
Agency Followup Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Director, Office of Superfund Remediation and Technology Innovation,
Office of Solid Waste and Emergency Response
Audit Followup Coordinator, Office of Solid Waste and Emergency Response
Audit Followup Coordinator, Region 8
Regional Public Affairs Office, Region 8
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