RCRA Public Participation Checklist
AEPA
EPA-530-F-20-001 | https://www.epa.gov/rcra
Community Engagement Assessment Worksheet
for RCRA Permit Activities
Effective, timely, and meaningful community engagement yields significant benefits, especially in communities near
hazardous waste sites. The purpose of this worksheet is to help gather information on issues that may trigger community
concerns or sensitivities - and help state and EPA staff determine whether enhanced outreach or an environmental
justice analysis may be needed.
The following worksheet is a preliminary tool that recommends elements for consideration (both standard and critical)
when planning for effective community engagement. It is designed to be used during one-on-one meetings between
community engagement staff and EPA RCRA Technical Project Managers ("TPM", including permit-writers, corrective
action specialists, enforcement specialists, etc.). This tool can be used at various stages or milestones of the RCRA
permit process, when community engagement is either required or may be considered (e.g., new permits, class two or
class three permit modifications, permit renewals with significant changes, corrective action activities such as interim
measures, consent decrees or orders, corrective action remedy selection and construction, and permit components
including facility investigations).
RCRA Regulated Facility:
EPA Authority:
City/State:
Technical Project Manager:
Facility Activity (e.g., CA 550, etc.):
Community Engagement Staff:
Checklist for RCRA Public Participation
Standard Elements of Effective
Community Engagement
Conduct a discussion on the big picture. Use notes from
Google Earth Aerial Analysis and EJSCREEN analysis.
Discuss aspects such as: relative residential proximity
to the facility fence-line; population demographics;
cumulative environmental impacts (e.g., other facilities
nearby); size of facility acreage; and buffer areas. Have
the Technical Project Manager share maps of the facility's
RCRA-regulated units/cleanup areas and gain a general
understanding. Be sure to become more familiar with
those units that are in close proximity to the facility's
fence-line. Discuss the EPA and the state environmental
agency's RCRA regulatory roles at the facility. Discuss
the facility's permitting and enforcement history. Discuss
any technical challenges that may impact timing of any
potential community engagement activities.
Comments
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RCRA Public Participation Checklist
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Standard Elements of Effective
v
N
Comments
Community Engagement
T
2
Review historic public comment records, meeting
summaries, and transcripts for indications of potential
community or environmental justice concerns (e.g.,
pre-application meeting summary, public comments on class
two or class three permit mod request, public comments on
draft permit, newspaper archives, hearing transcripts).
3
Discuss current and/or past public input/concerns from
previous facility-based work.
4
Consider the nature of the facility's relationship with
community. Some facilities have a very positive relationship
with communities by actively improving health, safety, and
environmental performance and communicating openly
with neighbors about the facility's performance. Conversely,
some facilities struggle establishing a trusting relationship
with their community.
5
Identify whether a community group has been organized
or established as a result of real/perceived environmental,
health or financial impacts from the RCRA facility.
6
Identify whether other external stakeholders have
expressed concerns about real/perceived environmental,
health or financial impacts from the RCRA facility (e.g., state
or Congressional representative; news media). Take note if
any community revitalization efforts are taking place nearby.
7
Consider information on heightened sensitivity due to real/perceived threats to the community outside-of-the-
fence-line due to any of the following considerations (determined through review of available facility documents
and other supporting information):
7a
Air. Evidence of migration of facility-related air
contaminants (e.g., RCRA-regulated constituents, such
as particulates, volatile organic compounds) through
observations, a fence-line monitoring program, or other
air monitors within the vicinity of the RCRA facility.
7b
Air. Evidence of migration of site-related contaminants
(e.g., present or historic) through air deposition into soil
onto nearby residential/industrial/ commercial facility
properties.
7c
Storm-water Run-off/Surface Water. Evidence of
migration of site-related contaminants into nearby
drainage pathways or surface water bodies (e.g., streams,
lakes, neighborhood ditches).
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Standard Elements of Effective
Community Engagement
Y
N
Comments
7d
Groundwater ("GW"). Evidence of GW contamination
near or outside of the facility's fence-line. Consider
assessments of the facility's point of compliance GW wells
near the facility's boundaries (called sentinel wells), as
well as off-site GW wells.
7e
Groundwater ("GW"). Evidence of contaminated GW that
may pose actual or perceived threats to private/municipal
drinking water wells.
7f
Groundwater ("GW"). Evidence of contaminated GW
discharge, or potential discharge into a surface water body
or low topographic area. If so, discuss if discharge area is
used by public (e.g., stream or ditches on private properties
versus an on-site pond) and what controls are in place.
7g
Groundwater ("GW"). Evidence of GW contamination
type at levels that could or have caused vapor intrusion
("VI") outside the fence-line such as into residential
homes, or within the fence-line into an active facility
building where workers are present.
8
Consider other issues that may trigger community sensitivities and may justify enhanced community
engagement.
8a
Unique potential exposure pathways of facility-related
contamination (e.g., subsistence fishing, hunting
and consuming wild game, harvesting wild plants for
subsistence, community gardening).
8b
Probable cultural, tribal, historic, or archeological sites
listed or eligible for listing in the National Register of
Historic Places that are nearby (e.g., churches, recreation
and parks, sacred sites, historic structures, landmarks).
8c
Other issues
Suggested Recommendations for Future Community Engagement Direction:
RCRA Public Participation Checklist
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Critical Elements of Enhanced
Community Engagement
Y
N
Comments
1
Discuss the facility's capacity to help coordinate
community engagement (e.g., presence of local
community advisory panel, experience level in community
engagement & outreach, willingness to fund public
notices, willingness to participate in public/private/
philanthropic partnership.)
2
Review EPA's ECHO database to view whether the RCRA
facility has existing (media) permits [such as Clean Air Act
(CAA), National Pollutant Discharge Elimination System
(NPDES), etc.] that in the last two years have:
1. renewed and assess level of public comments/feedback
submitted;
2. received any Notice of Violations (NOVs) by the state/
local agency or EPA;
3. been placed under any enforcement order.
Also review if nearby facilities have had community
concerns.
3
Review institutional knowledge present within EPA
internal tracking mechanisms:
• EJ Complaint database, Enforcement Hotline, Controlled
Correspondence and Congressional Inquiry
• Reportable Chemical Releases or incidents (EPCRA;
refer to the ERNS database maintained by Superfund)
It is noted that chemical accidents, spills or releases
(although not related to the RCRA activity) may erode
levels of community trust in the facility and the regulated
agencies. Therefore, it is advisable to be prepared when
planning outreach, such as public meetings.
4
Consider other factors from the EPA HQ "EJ and
Permitting" Analysis that may be useful.
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