EPA Region 7 Did Not
Effectively Engage with the
Community Surrounding
the Findett Corp.
Superfund Site
April 17, 2024 | Report No. 24-E-0033
xt*sPEcro
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Report Contributors
Seth Gerhart
Patrick Gilbride
Jonathan Morrand
Julie Narimatsu
Nirvair Stein
Chip Triebwasser
Abbreviations
C.F.R. Code of Federal Regulations
EPA U.S. Environmental Protection Agency
OIG Office of Inspector General
Cover Image
St. Charles City Well 5, which is near the Ameren substation, a source of groundwater contamination at
the Findett Corp. Superfund Site. (EPA OIG image)
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24-E-0033
April 17, 2024
At a Glance
EPA Region 7 Did Not Effectively Engage with the Community
Surrounding the Findett Corp. Superfund Site
Why We Did This Evaluation
To accomplish this objective:
The U.S. Environmental Protection
Agency Office of Inspector General
conducted this evaluation to determine
whether the EPA adhered to federal
laws, regulations, and EPA guidance
pertaining to community engagement
standards and practices at the Findett
Corp. Superfund Site. Contamination of
the groundwater at the Findett Corp.
Superfund Site and the EPA's
response to that contamination has
long been an issue of concern in the
St. Charles, Missouri community.
We initiated this evaluation based on
an OIG inquiry into the EPA's response
to contamination of the drinking water
source in St. Charles, Missouri.
To support these EPA mission-
related efforts:
• Ensuring clean and safe water.
• Partnering with states and other
stakeholders.
• Operating efficiently and
effectively.
To address these top EPA
management challenges:
• Integrating and leading
environmental justice.
• Maximizing compliance with
environmental laws and
regulations.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG.PublicAffairs@epa.gov.
List of OIG reports.
What We Found
EPA Region 7 did not effectively engage with the community affected by the Findett Corp.
Superfund Site. The region's public-facing documents and presentations were too technical
for the public to easily understand. The region also distributed information in newspapers
with low circulation to reduce costs. As a result, members of the St. Charles, Missouri
community, which is near the Findett Corp. Superfund Site, were unaware of opportunities
for public participation and confused about the cleanup process. Further, after the discovery
of an additional source of contamination, Region 7 did not promptly develop a new or
updated community involvement plan for St. Charles. The 2021 plan that the region
ultimately developed did not reflect changing site conditions or have the benefit of robust and
diverse community feedback.
In addition, Region 7 did not effectively facilitate community involvement by providing timely
technical assistance or other tools to the St. Charles community. It also did not use
available mediation services in a timely manner to mitigate the contentious relationships
among the Findett Corp. Superfund Site stakeholders. EPA guidance encourages staff to
use these techniques to prevent, mitigate, and resolve environmental conflicts. Instead,
Region 7 staff, the City of St. Charles, and the potentially responsible party, which is the
party responsible for contamination at a site, engaged in months of worsening conflict. This
conflict delayed the region's cleanup activities, including water sampling and the
development of a water-pumping strategy. Region 7 and the city disagreed about the risks
from the groundwater contamination, resulting in conflicting public messages and confusion
among St. Charles residents. Had Region 7 used the EPA's available tools to enhance
community involvement and stakeholder engagement at the Findett Corp. Superfund Site
earlier, it may have minimized site cleanup delays and mitigated the community's mistrust
in the EPA.
Without effective community engagement, the public may not know
about remediation activities, and groundwater contamination cleanup
may not occur in a timely manner.
Recommendations and Planned Agency Corrective Actions
We recommend that the regional administrator for Region 7 (1) assess the need for
alternative dispute resolution services at the Findett Corp. Superfund Site, (2) implement a
plan to regularly train Superfund staff on community involvement and plain language
resources, (3) develop procedures to help Superfund site teams identify community needs
for supplemental technical support, (4) establish regular opportunities for community
involvement coordinators to better understand and provide recommendations on site and
community activities, and (5) implement procedures for updating community involvement
plans as site conditions change. The EPA agreed with all recommendations and provided
corrective actions with estimated completion dates. Recommendation 1 was completed.
Planned corrective actions for Recommendations 2 and 3 meet the intent of our
recommendations, and these recommendations are resolved with corrective actions
pending. Recommendations 4 and 5 remain unresolved.
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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
April 17, 2024
MEMORANDUM
SUBJECT: EPA Region 7 Did Not Effectively Engage with the Community Surrounding the Findett Corp.
Superfund Site
Report No. 24-E-0033
FROM:
Sean W. O'Donnell, Inspector General
TO:
Meghan McCollister, Regional Administrator
EPA Region 7
This is our report on the subject evaluation conducted by the U.S. Environmental Protection Agency Office of
Inspector General. The project number for this evaluation was QSRE-FY23-0069. This report contains findings that
describe the problems the OIG has identified and corrective actions the OIG recommends. Final determinations
on matters in this report will be made by EPA managers in accordance with established audit resolution
procedures.
The Region 7 Superfund and Emergency Management Division and Office of Public Affairs are responsible for the
issues discussed in this report.
In accordance with EPA Manual 2750, your office completed corrective actions for Recommendation 1. Your office
also provided acceptable planned corrective actions and estimated milestone dates in response to
Recommendations 2 and 3. These recommendations are resolved with corrective actions pending. Afinal response
pertaining to these recommendations is not required; however, if you submit a response, it will be posted on the
OIG's website, along with our memorandum commenting on your response.
Action Required
Recommendations 4 and 5 are unresolved. EPA Manual 2750 requires that recommendations be resolved
promptly. Therefore, we request that the EPA provide us within 60 days its responses concerning specific actions
in process or alternative corrective actions proposed on the recommendations. Your response will be posted on
the OIG's website, along with our memorandum commenting on your response. Your response should be provided
as an Adobe PDF file that complies with the accessibility requirements of section 508 of the Rehabilitation Act of
1973, as amended. The final response should not contain data that you do not want to be released to the public;
if your response contains such data, you should identify the data for redaction or removal along with
corresponding justification. The Inspector General Act of 1978, as amended, requires that we report in our
semiannual reports to Congress on each audit or evaluation report for which we receive no Agency response
within 60 calendar days.
We will post this report to our website at www.epaoig.gov.
To report potential fraud, waste, abuse, misconduct, or mismanagement, contact the OIG Hotline at (888) 546-8740 or OIG.Hotline@epa.gov.
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Table of Con
Chapters
1 Introduction 1
Purpose 1
Background 1
Responsible Offices 10
Scope and Methodology 10
Prior Reports 11
2 Region 7 Did Not Effectively Engage with the Community 12
Region 7 Did Not Effectively Communicate with the Public 12
Region 7 Did Not Update Its Community Involvement Plan for the Findett Corp.
Superfund Site 16
Region 7 Did Not Successfully Facilitate Community and City Involvement 19
Conclusions 25
Recommendations 26
Agency Response and OIG Assessment 27
Status of Recommendations 28
A Agency Response 29
B Distribution 35
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Chapter 1
Introduction
Purpose
The U.S. Environmental Protection Agency Office of Inspector General initiated this evaluation to
determine whether the EPA adhered to federal laws, regulations, and EPA guidance pertaining to
community engagement standards and practices at the Findett Corp. Superfund Site. We initiated this
evaluation based on an OIG inquiry into the EPA's response to the contamination of the drinking water
source in St. Charles, Missouri.
Top management challenges addressed
This evaluation addresses the following top management challenges for the Agency, as identified in OIG Report
No. 24-N-0008. The EPA's Fiscal Year 2024 Top Management Challenges, issued November 15, 2023:
• Integrating and implementing environmental justice.
• Maximizing compliance with environmental laws and regulations.
Background
City of St. Charles Drinking Water Contamination
In January 2022, the City of St. Charles shut down one of its five active drinking water wells. It took this
action after traces of cis-l,2-dichloroethene and vinyl chloride were found in the groundwater. As
depicted in Figure 1, the chemicals were not found in the treated drinking water. Over the next
13 months, the city suspended the operation of three other wells. These actions left one well to serve
the city's over 70,000 residents. The directors of the city's public water system independently decided to
shut down the wells. Region 7 did not require the closures. Region 7 and the City of St. Charles maintain
that the drinking water is safe to drink because the treated drinking water has never shown any
contamination.
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Figure 1: A public drinking water system providing clean drinking water from a contaminated
groundwater source
Source: EPAOIG image.
EPA Region 7, which includes Missouri, determined that Ameren Missouri's, or Ameren's, active
electrical distribution and transmission substation contaminated the City of St. Charles' groundwater at
the Findett Corp. Superfund Site in St. Charles.1 Ameren provides electric and gas service to 64 counties
in Missouri, including those in the greater St. Louis area. The company's previous use of cleaning
solvents at the substation are a primary source of the water contamination.2 As a result, Region 7
identified Ameren as a potentially responsible party. A potentially responsible party is any person or
company that is potentially responsible for or contributing to a spill or other contamination at a
Superfund site. Contaminants of concern in the St. Charles groundwater include vinyl chloride;
tetrachiorethylene; trichloroethylene; and cis-l,2-dichloroethylene. If consumed over an extended time,
volatile organic compounds can cause negative health impacts, such as liver damage, neurological
issues, cancer, and heart defects. The City of St. Charles has not detected the contaminants of concern
in the city's treated drinking water.
The EPA Superfund Program
Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act in 1980.
Informally called Superfund, the Act authorizes the EPA to clean up contaminated sites or to force
responsible parties to perform the cleanup. To carry out this authority, the EPA established its
Superfund program. The Superfund program cleans up some of the nation's most contaminated land
1 Region 7 uses "Findett Corp." as a designation for this Superfund Site. This report primarily focuses on Region 7's
community engagement related to the portion of the Findett Corp. Superfund site contamination caused by the
Ameren substation.
2 See the EPA's "FINDETT CORP. ST. CHARLES, MO, Cleanup Activities" webpage.
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and responds to environmental emergencies, oil spills, and natural disasters. The sites that the EPA
identifies for cleanup are referred to as Superfund sites. The EPA maintains a list of Superfund sites that
it has prioritized for action called the National Priorities List. The National Priorities List identifies the
sites eligible for federal funding under the EPA Superfund program. Figure 2 provides additional details
about the Superfund cleanup process.
Figure 2: The EPA Superfund cleanup process
i
Cleanup Process
Cleaning up Superfund
sites
is a complex, multiphase
process.
Site Assessment
The EPA visits the site to evaluate
potential hazards.
National Priorities Listi
The EPA prioritizes sites
according to a Hazard Ranking
System score.
Remedial Investigation
The EPA evaluates the
contamination and potential
treatment options.
Records of Decision
The EPA explains cleanup
activities and recommends a
cleanup plan
Remedial Design and Action
The EPA implements the cleanup
plan.
Site Reuse and Redevelopment
The EPA can consider reuse at a site
at any point The cleanup process
goal is to achieve future use.
National Priorities List Deletion
The EPA completes cleanup and
determines the site no longer need
to be on the National Priorities List
Source: OIG summary of the EPA's "Superfund Cleanup Process" webpaqe. (EPA OIG image)
The EPA seeks to identify the potentially responsible party for contamination at a site to negotiate the
party's cleanup of the site with EPA oversight. In the absence of a potentially responsible party, the EPA
takes responsibility for a Superfund site's cleanup. During the cleanup process, the EPA sometimes
divides Superfund sites into distinct subareas, called operable units. The EPA may organize operable
units based on geography, specific site problems, or areas requiring specific action.
Each of the EPA's ten regional offices has a Superfund and Emergency Management Division, which
administers the Superfund program at sites within the region's borders. Region 7's remedial project
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managers are typically responsible for managing cleanup activities at Superfund sites to ensure that all
parties comply with the EPA's National Oil and Hazardous Substances Pollution Contingency Plan,
hereafter referred to as the EPA's National Contingency Plan.3 The remedial project managers are also
responsible for community outreach and involvement. The EPA site team for each Superfund site
typically includes a community involvement coordinator. Community involvement coordinators work
under each region's Office of Public Affairs and receive specialized training on EPA community
involvement tools. Community involvement coordinators advise the remedial project managers and
conduct community involvement and outreach activities. Community involvement staff can also
coordinate with EPA headquarters staff to obtain contractor support to enhance community
engagement at Superfund sites.
EPA Community Engagement During the Superfund Process
Congress established community involvement as an integral component of the Superfund process. Both
the Comprehensive Environmental Response, Compensation, and Liability Act and the EPA's National
Contingency Plan set forth minimum requirements for community involvement in the Superfund
process. The EPA has supplemented these requirements with additional guidance, such as the Superfund
Community Involvement Handbook, which is available on the "Superfund Community Involvement Tools
and Resources" webpage. The handbook, published in 2005 and updated in 2016 and 2020, advises EPA
site teams to "conduct early, frequent, and meaningful community involvement." Before the EPA begins
Superfund field work, the EPA's National Contingency Plan requires that the EPA, as the lead agency and
to the extent practicable, fulfill the minimum community involvement requirements shown in Figure 3.
3 The EPA's National Contingency Plan outlines the organizational structure and process for preparing for and
responding to discharges and releases of oil, hazardous substances, pollutants, and contaminants in the United
States. The EPA developed the National Contingency Plan after Congress enacted the Comprehensive
Environmental Response, Compensation, and Liability Act.
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Figure 3: Minimum community involvement requirements at Superfund sites
Conduct interviews with stakeholders to solicit their concerns and information needs and
to learn how and when citizens would like to be involved in the Superfund process.
Prepare a formal community involvement plan based on the community interviews and other
relevant information. The community involvement plan specifies the community engagement
activities expected to be undertaken during the remedial response and is intended to:
Ensure that the public has appropriate opportunities for involvement in a wide variety
of site-related decisions, including site analysis and characterization, alternatives
analysis, and selection of remedy.
Determine, based on the community interviews, appropriate activities to ensure
public involvement.
Provide appropriate opportunities for the community to learn about the site.
Establish at least one local information repository at or near the location of the response
action.
Inform the community of the availability of technical assistance grants.
Note'. While the National Contingency Plan refers to a community relations plan, it is also known as a community
involvement plan.
Source: OIG summary of the EPA's National Contingency Plan, 40 C.F.R. § 300.430(c)(2). (EPA OIG image)
To help Superfund site teams meet Congress's intent of informing communities and encouraging public
participation throughout the Superfund process, the EPA also developed the Superfund Community
Involvement Toolkit. Site teams can use the toolkit, in conjunction with the Superfund Community
Involvement Handbook, to determine and implement an appropriate mix of community involvement
activities on a site-specific basis. The handbook and the toolkit outline technical assistance resources
that the EPA can offer communities to help them navigate and understand the complexities of
Superfund site cleanups. For example, as detailed in Figure 4, the toolkit includes several mechanisms
for meaningful community engagement.
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Figure 4: EPA technical assistance tools for Superfund sites
Technical
Assistance
Services for
Communities
These services provide supplemental, nonadvocacy technical assistance resources
at no cost to communities. The EPA contracts with scientists, engineers, and other
professionals to review and explain information to communities.
Technical
Assistance Needs
Assessments
These assessments identify additional support that a community may require to
understand technical information and to participate meaningfully in the Superfund
decision-making process.
Conflict
Prevention and
Resolution Center
This center helps prevent or manage conflicts by providing the EPA with expertise in
consensus building, collaborative problem solving, alternative dispute resolution, and
environmental conflict resolution. The center also has contracts to provide neutral
third-party facilitators and training that can improve community involvement activities.
Technical
Assistance
Grants
These grants provide funds to qualified community groups to contract with
independent technical advisors who will explain technical information, Superfund
program plans, and site-specific documents to communities affected by National
Priorities List sites.
Source: OIG summary of the EPA Superfund Community Involvement Toolkit. (EPA OIG image)
The EPA has national contracts to provide community engagement tools, including the Technical
Assistance Services for Communities program and a Conflict Prevention and Resolution Center. Regional
staff can use these resources to augment their capacity to conduct community involvement activities.
For example, regions can use contractor assistance to develop community involvement plans,
coordinate community interviews, and translate technical materials into easily digestible formats for
communities.
In addition to the Comprehensive Environmental Response, Compensation, and Liability Act, other laws
and guidance govern the EPA's communication with communities. For example, per the Plain Language
Act of 2010, the EPA's communications with the public should be in language that is easy for the
community to understand and use. EPA guidance, such as the Superfund Community Involvement
Handbook and the Superfund Community Involvement Toolkit, emphasizes the importance of using plain
language in Superfund community involvement activities. Specifically, the toolkit includes a document
that describes how to create and distribute fact sheets that the community can easily understand.
Additionally, the EPA's National Contingency Plan requires the Agency to publish certain information in
major local newspapers of general circulation so that the information reaches as many community
members as possible.
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The Findett Corp. Superfund Site
The Findett Corp. Superfund Site, shown in the time-lapse map in Figure 5, consists of four operable
units, three of which address groundwater contamination in the Elm Point Wellfield. Operable Units 1
and 2 address contaminated soil and groundwater within the neighboring properties owned by two
affiliated companies. Operable Unit 3 addresses groundwater contamination that migrated off-site from
Operable Units 1 and 2. Operable Unit 4 has a separate and distinct contaminated groundwater plume
emanating from Ameren's electrical substation. Although the Findett Corp. Superfund Site is not on the
National Priorities List, the EPA manages the site like it would if the site were on the National Priorities
List, using Superfund authority and following Superfund processes.4
Groundwater plume
Groundwater contamination moves slowly, so contaminants tend to remain concentrated in the form
of a plume, which generally flows along the same path as the groundwater.
Figure 5: The Findett Corp. Superfund Site overtime
Note: The image above is linked to a video. Click on the image or scan the QR code to view the video.
Source: OIG timeline summary of significant events at the Findett Corp. Superfund Site. (EPA OIG image)
4 The EPA proposed the site for the National Priorities List in 1984 but withdrew that proposal because of the
potential overlapping jurisdiction with the Resource Conservation and Recovery Act. The EPA, however, has
continued to manage the site using Superfund authorities because the Agency had already met significant
administrative milestones, including filing a consent decree and record of decision.
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Contamination of the St. Charles groundwater has long been an issue of concern at the Findett Corp.
Superfund Site. As detailed in Table 1, Region 7 and the City of St. Charles had conflicting perspectives
on the risk that St. Charles residents face from that contamination. Because the Findett Corp. Superfund
Site involves contaminated groundwater that the community uses for drinking water, action on
contaminants is generally based on maximum contaminant levels.
Maximum contaminant levels
The EPA determines maximum contaminant levels pursuant to the Safe Drinking Water Act. A
maximum contaminant level is the highest level of a contaminant that is allowed in drinking
water.
Table 1: Health-based standards used by Region 7 and the City of St. Charles
Government entity
Basis used for making health-based decisions
Actions taken
EPA Region 7
Exceedances of the maximum contaminant levels in
the groundwater (pretreatment).
Require the potentially
responsible party to restore the
use of the groundwater by
reducing contamination to the
maximum contaminant levels.
EPA Region 7
Exceedances of the maximum contaminant levels in
the drinking water distribution system
(posttreatment).
Because there have not been any
detections of contamination in the
drinking water distribution system,
no actions have been taken.
City of St. Charles
Detections of contamination in the drinking water
wells (pretreatment).
Shutdown of the wells.
City of St. Charles
Possible threats to drinking water wells based on
detections of contamination in nearby groundwater
(pretreatment).
Shutdown of the wells.
Source: OIG summary of EPA policies, Region 7 documents, and the City of St. Charles website. (EPA OIG table)
EPA Region 7 is bound by the Comprehensive Environmental Response, Compensation, and Liability Act
to ensure that contaminated groundwater that is a source of drinking water is restored to beneficial use.
Beneficial use describes the cleanup standard to which the EPA should clean up the site, such that the
community has the best opportunity to productively use the site following the cleanup. Because the
groundwater is contaminated at the Findett Corp. Superfund Site, Region 7 must take action to ensure
the groundwater does not exceed the maximum contaminant levels. Region 7 cannot require potentially
responsible parties, such as Ameren, to clean up the site beyond the point of beneficial use, which is the
maximum contaminant levels. The City of St. Charles argues, however, that it cannot accept the risk
regardless of whether the contamination is below the maximum contaminant levels. It contends that
continuing to pump its wells after contamination is detected would worsen the problem, potentially
exposing residents to harm.
Since 2005, the city suspended operation of six of its seven drinking water wells because of
contaminants in the wellfield, which is an area surrounding a series of water wells. The most recent
closure occurred in February 2023, as shown earlier in Figure 5. In 2012, EPA Region 7 issued an
enforcement action memorandum to address a threat to the St. Charles drinking water supply, directing
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the Findett Corp. Superfund Site's potentially responsible parties to replace a portion of the public
drinking water wells. However, Region 7 subsequently decided that replacing the wellfield was no longer
necessary because it believed the plume was fully contained within the substation and that interim
treatment measures were effective. The city's interim director of public works disagreed and remained
concerned about the long-term viability of the Elm Point Wellfield as a flexible, safe, and reliable source
of drinking water.
As of September 2023, the city's last remaining operational well was City Well 10. The city's decisions to
close city wells have decreased its capacity to pump enough water to meet the community's needs. As
shown in Figure 6, the city pumped less water in 2022 than in 2021 and less in 2023 than in 2022
because of the decreasing number of available wells. For example, in December 2022, the city shut
down the well it typically relied on for most of its drinking water, City Well 9. This made the city increase
its pumping of City Well 10 in 2023. Operating one well reduces the system's resilience because there
are no other wells to make up for any potential lost production if the remaining well needs maintenance
or becomes contaminated. According to the city, it has made up for the decreased system production by
buying water from the City of St. Louis. However, the City of St. Charles could not provide data on the
total volume of water purchased. The city said it is more expensive to buy water from St. Louis than it
would be to pump and treat water from its own wellfield.
Figure 6: Production from the St. Charles public water system from January 2021 through
December 2023
600
1 500 I I
-III
400
I I I h
I I I I
2021 2022 2023 2021 2022 2023 2021 2022 2023 2021 2022 2023
Jan-Feb-March Apr-May-June July-Aug-Sept Oct-Nov-Dec
Source: OIG analysis of St. Charles data. (EPA OIG image)
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Both the City of St. Charles and Region 7 acknowledge that, although the groundwater in the wellfield is
contaminated, the contaminants of concern have never been detected in the treated drinking water
that people consume. City officials, including the director of public works, allege, however, that actions
by Region 7 and the potentially responsible party have not and will not adequately protect public health.
Responsible Offices
The Region 7 Superfund and Emergency Management Division is responsible for cleaning up and
restoring contaminated sites using its Superfund authorities. It manages approximately 100 Superfund
sites with various long-term environmental and human health threats, including the Findett Corp.
Superfund Site. From fiscal years 2019 through 2023, the Region 7 Superfund and Emergency
Management Division's annual budget ranged from approximately $41 million to $197 million.5
The Region 7 Office of Public Affairs, which includes community involvement coordinators, is responsible
for advising the site team on planning and conducting community involvement activities and producing
some public-facing documents. From fiscal years 2019 through 2023, the Region 7 Office of Public
Affairs' budget ranged from approximately $1.3 million to $1.8 million.
Scope and Methodology
We conducted this evaluation from April 2023 to December 2023 in accordance with the Quality
Standards for Inspection and Evaluation published in December 2020 by the Council of the Inspectors
General on Integrity and Efficiency. Those standards require that we perform the evaluation to obtain
sufficient and appropriate evidence to support our findings.
We interviewed Region 7 Superfund and Emergency Management Division and Office of Public Affairs
staff, Office of Land and Emergency Management staff at EPA headquarters, City of St. Charles officials
and contractors, and members of the public. We also interviewed community involvement staff in two
other regions to identify best practices in the use of the EPA's technical support services.
We analyzed Region 7 correspondence from 2012 through 2023, national data for EPA technical
assistance at Superfund sites, and budgetary information from 2019 through 2023. We also analyzed
Region 7-developed fact sheets and frequently-asked-question documents released in late 2022 and
early 2023 to determine whether they complied with plain language requirements.
During our inquiry, which occurred before we initiated this evaluation, we conducted a site visit to the
Elm Point Wellfield. We also interviewed Region 7 staff, Missouri Department of Natural Resources staff,
St. Charles officials and staff, and met with St. Charles community members.
5 In fiscal year 2022, Region 7's Superfund and Emergency Management Division received approximately
$125 million in supplemental funding from the Infrastructure Investment and Jobs Act.
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Prior Reports
The EPA OIG issued Report No. 21-P-0223. EPA's Office of Land and Emergency Management Lacked a
Nationally Consistent Strategy for Communicating Health Risks at Contaminated Sites, on September 9,
2021. The objective was to determine whether the EPA communicated sampling results or other
indicators of human health risk in a manner that allowed impacted communities to make decisions
about managing their risks of exposure to harmful contaminants or substances. The report covered
eight contaminated sites. The OIG found that the EPA's Office of Land and Emergency Management did
not consistently adhere to existing guidance on risk communication, including the Agency's Seven
Cardinal Rules of Risk Communication. The OIG recommended that the Office of Land and Emergency
Management implement internal controls to:
(1) achieve OLEMwide [Office of Land and Emergency Management], nationally
consistent risk communication to improve public awareness and understanding of
risks; (2) monitor its risk communication efforts; and (3) provide community
members with information to manage their risks when exposed to actual or
potential environmental health hazards.
The EPA agreed with the OIG's recommendations and reported that it completed corrective actions as of
September 30, 2022.
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Chapter 2
Region 7 Did Not Effectively Engage with the Community
Region 7 did not effectively engage the City of St. Charles officials and community members about the
Findett Corp. Superfund Site cleanup activities. Region 7's communications with the public could have
better aligned with plain language mandates. Additionally, to reduce costs, the region did not always
distribute information in major local newspapers of general circulation per the EPA's National
Contingency Plan requirements. Key Region 7 staff were not familiar with guidance governing the
accessibility of public-facing documents. As a result, the St. Charles community was unaware of
opportunities for public participation and confused about the cleanup process.
Additionally, Region 7's 2021 community involvement plan was incomplete and did not reflect changing
site conditions or incorporate diverse community feedback.6 Region 7 did not facilitate community
involvement by providing technical assistance or other tools to the St. Charles community until
November 2022 and only did so at the request of a community member. It also did not take advantage
of available mediation services to mitigate the poor working relationships among Findett Corp.
Superfund Site stakeholders. Remedial project managers in Region 7 were unaware of the availability of
the EPA's technical assistance resources, even though they are available at no cost to EPA regional
offices. Enhanced Region 7 community involvement and conflict mitigation could minimize cleanup
delays and restore public trust in the Agency.
Region 7 Did Not Effectively Communicate with the Public
Region 7 did not effectively communicate with the St. Charles community about the Findett Corp.
Superfund Site. The region's public-facing documents were too technical for the public to easily
understand. The region also distributed information in poorly circulated local newspapers to reduce
costs. The region's ineffective communication meant that the St. Charles community was unaware of
opportunities for public participation and struggled to understand the EPA's site cleanup activities.
Some Region 7 Public Information Was Difficult to Understand or Access
Region 7's communications could have better complied with plain language requirements and EPA
guidance for public-facing documents. The Plain Writing Act of 2010 is meant to enhance citizen access
to government information and services by requiring federal agencies, such as the EPA, to use clear,
concise, and well-organized writing when developing public documents. The associated Federal Plain
Language Guidelines (March 2011; Revision 1, May 2011) comprises five major principles that federal
agencies should generally follow.7 In addition to these five major principles, the EPA has a plain writing
webpage, the Superfund Community Involvement Toolkits "Fact Sheets" document, and a Superfund
Community Involvement Handbook to help Agency staff meet the requirements of the Plain Writing Act.
6 The 2021 community involvement plan was updated in August 2023.
7 All subsequent references to the Federal Plain Language Guidelines refer to the Revision 1 version.
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Despite generally being the lead personnel for communicating with the public, Region 7's remedial
project managers were unfamiliar with and not regularly trained on the available resources governing
the accessibility of public documents.
Some Region 7 Publications Were Too Technical
Region 7 could have improved its use of plain language in the three fact sheets it developed for the
St. Charles community in accordance with the Plain Writing Act of 2010 and plain language guidance.
We compared these fact sheets against 17 plain language elements from the EPA and the Federal Plain
Language Guidelines. The three Region 7 fact sheets, which discussed sampling technology and the
likelihood of consuming contaminated water, did not meet approximately 81 percent of the 17 plain
language elements, for an average compliance rate of 19 percent. For example, the Federal Plain
Language Guidelines direct federal government staff to write public-facing documents at a readability
level that the intended audience can understand. The EPA's Superfund Community Involvement Toolkit's
"Fact Sheets" document recommends writing public-facing text at the eighth-grade level unless site
demographics indicate the audience has a different educational background. In contrast, as shown in
Table 2, Region 7 wrote public documents at the first- to second-year undergraduate level, despite
nearly half of the St. Charles' population not having a college degree.8
Region 7 also distributed fact sheets developed by the Office of Land and Emergency Management, an
EPA headquarters program office. As also shown in Table 2, the two headquarters fact sheets that we
reviewed complied with the 17 plain language elements about 75 percent of the time.
Table 2: OIG analysis of EPA public documents distributed for the Findett Corp. Superfund Site
Compliance with
Flesch-Kincaid
plain language
reading grade level
Developed by
Document title
elements (%)
equivalent
Region 7
Findett Operable Unit 4
(Ameren Substation) FAQs
18
2nd-year undergraduate
reading grade level
Region 7
Direct Push Technology Fact
Sheet, Findett Corp.
Superfund Site, St. Charles
Missouri - EPA Region 7,
February 2023
21
1st-year undergraduate
reading grade level
Region 7
Findett Corp. Superfund Site
Fact Sheet, St. Charles,
Missouri - EPA Region 7,
November 2022
19
2nd-year undergraduate
reading grade level
Average Region 7
compliance rate
19
8 We used the Flesch-Kincaid grade-level readability formula to analyze and rate text based on a U.S. grade school
educational level. For example, a grade level score of 8.0 means that an eighth grader should be able to
understand the text. The formula uses the average number of words per sentence and the average number of
syllables per word to generate a readability level.
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Compliance with
Flesch-Kincaid
plain language
reading grade level
Developed by
Document title
elements (%)
equivalent
EPA headquarters: Office of
Community Guide to Pump
75
9th-grade high school
Land and Emergency
and Treat
reading grade level
Management
EPA headquarters: Office of
Community Guide to
75
10th-grade high school
Land and Emergency
Bioremediation
reading grade level
Management
Average EPA headquarters
—
75
—
compliance rate
Note: FAQs = Frequently Asked Questions.
Source: OIG analysis of Region 7 and EPA headquarters documents. (EPA OIG table)
We interviewed five St. Charles residents who were actively involved in learning about the Findett Corp.
Superfund Site. Of the five residents, two said that Region 7's information about the Findett Corp.
Superfund Site is too technical and filled with government jargon. For example, on January 10, 2023, a
community member requested that Region 7 explain its sampling method to the community, and the
region sent a 111-page work plan to that community member. The resident responded with an
additional request that Region 7 provide more digestible educational materials to the community. The
EPA's February through April 2023 Technical Assistance Needs Assessment for the Findett Corp.
Superfund Site, which included interviews with 21 St. Charles community members and stakeholders,
similarly found that Region 7's site documents were difficult to access or understand. The Technical
Assistance Needs Assessment recommended that Region 7 develop, as a top priority, plain language fact
sheets to help the public interpret technical documents.
Key Region 7 Staff Are Not Regularly Trained on Plain Language Requirements and
Superfund Communication Guidance
Region 7's remedial project managers were unfamiliar with specific guidance governing the accessibility
of public-facing documents. One remedial project manager stated that the project manager thought
new employees received training on the topic but noted that the region does not require continuing
education for plain language requirements and best practices. Following the community involvement
coordinators' creation of an outline, remedial project managers are responsible for the initial
development of the public-facing products. The assigned editor assesses the public documents for plain
language, but the editor does not use Superfund-specific plain language communication tools. Rather,
according to a Region 7 public affairs manager and an editor, public affairs staff rely on experience to
ensure documents are in plain language. In some cases, the editor must also balance technical and legal
staff's preferences for language that accurately describes science and laws in less simple terms. A
Region 7 manager stated that regional staff updated the Findett Operable Unit 4 (Ameren Substation)
FAQs document after community meetings indicated that residents were confused, but that update has
not eliminated other plain language barriers, such as the unnecessary use of acronyms. Publications that
are not in plain language could decrease public understanding of government communications, increase
the need for the public to seek clarification from Agency staff, and result in the EPA needing to correct
misinformation.
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Region 7 Distributed Information via Obscure Media
Region 7 staff distributed information in media with low circulation to reduce costs. As shown in
Figure 7, Region 7 is required to use major local newspapers of general circulation to publish public
notices at certain junctures. The National Contingency Plan emphasizes the importance of placing public
notices in widely circulated media because the notices help the EPA meet Congress's intent for
communities surrounding Superfund sites to have appropriate opportunities to learn about the sites and
be involved in a wide variety of decisions.
Figure 7: Superfund site activities that require public notices in major local newspapers
Source: OIG summary of the EPA's Public Notices document and 40 C.F.R. § 300.430 (c)(5)(H). (EPA OIG image)
Between 2019 and 2023, Region 7 published at least six of eight public notices in two newspapers. A
representative of one of those newspapers stated that the newspaper averages approximately
30,000 online views per month and 35,000 print distributions. Assuming each online view was a unique
viewer and there was no overlap between print and online readership, a conservatively high estimate
means that approximately 16 percent of St. Charles County residents would have received Region 7's
notices. The City of St. Charles has a population of 70,493 as of the 2020 decennial census. Assuming the
city readership matches the county readership, 11,279 city residents would have received Region 7's
notices. While Region 7 evaluated the readership of this newspaper, it did not assess that of the other
newspaper or of more frequently read newspapers.
Because Region 7 published public notices in newspapers with low circulation, two of the
five community group members we interviewed, and a representative of the City of St. Charles stated
that Region 7's selected newspapers were not widely read by the affected residents. If members of the
public are not informed in a timely manner about site-related activities, they cannot easily provide input
to the Agency or otherwise participate in the Superfund cleanup process. For example, from
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November 6 through 9, 2022, three individuals emailed Region 7, noting that they were not informed in
a timely fashion about a public comment period for a proposed consent decree for the Findett Corp.
Superfund Site. The individuals sent the emails ranging from three to six days after the scheduled end
date of the public comment period. Two of the five community members we interviewed recommended
Region 7 publish public notices in more widely distributed news sources, such as a major local
newspaper or local television news stations. According to the EPA's Superfund Community Involvement
Toolkit's "Public Meetings" document, a formal notice is usually not enough to stimulate attendance,
and it advises that EPA staff should take additional steps, such as contacting the media, to grab the
community's attention.
According to two community involvement coordinators involved in developing and issuing public
notices, cost is a factor in how Region 7 chooses newspapers for information distribution; specifically,
the region occasionally uses smaller newspapers because they cost less than major newspapers. The
EPA's "Public Notices" and "Public Comment Periods" sections of the Superfund Community Involvement
Toolkit provide guidance on ensuring public notifications reach the EPA's intended audience. According
to the guidance in the toolkit, the EPA can identify major newspapers or other methods for obtaining
information within the affected community by interviewing community members. Based on our review
of the Agency's 2021 community involvement plan, which should include appropriate channels for
reaching the community, such as the news media and other information mechanisms through which
community members can obtain site-related information, we could not find evidence that Region 7 staff
took this step to maximize the reach of their communications.
Region 7 Did Not Update Its Community Involvement Plan for the
Findett Corp. Superfund Site
Region 7's July 2021 community involvement plan for the Findett Corp. Superfund Site, which should
form the backbone of the site's community involvement program, as required by the EPA's National
Contingency Plan, was neither timely nor robust. Because Region 7 did not update the community
involvement plan as site conditions changed, Region 7 was not prepared to engage the community
efficiently and effectively. Additionally, the region did not gather sufficient community perspectives
during its development of the plan.
The EPA's National Contingency Plan requires the EPA to prepare a community involvement plan to
enable appropriate community involvement throughout the Superfund cleanup process. Per the
National Contingency Plan, the EPA must, to the extent practicable, conduct community interviews to
inform the plan and to document the results in a formal community involvement plan. The EPA's
Community Involvement Handbook states that a well-developed community involvement plan will
enable community members affected by a Superfund site to understand the ways in which they can
participate in decision-making throughout the cleanup process. The community involvement plan is
intended to be a "living document" that is updated as conditions change, and all members of the site
team should be involved in its development and implementation.
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Region 7 developed a community involvement plan for the Findett Corp. Superfund Site in 2002.9
In 2010, quarterly monitoring detected an additional groundwater plume, which the Agency designated
as Operable Unit 4 in 2012. Despite this significant change, Region 7 did not develop a new or update
the existing community involvement plan until 2021, as shown in Figure 8. This gap between the 2002
community involvement plan, the Operable Unit 4 identification, and the 2021 community involvement
plan meant that the information originally gathered in 2002 was out of date.
Figure 8: Community involvement plan updates were delayed
2002
Community Involvement
Plan Published
2010
Additional
Plume Detected
2012
OU4
Designated
2021
Community
Involvement
Plan Published
rfl
19 Years
c
Note: OU4 = Operarable Unit 4.
Source: OIG summary of events at the Findett Corp. Superfund Site. (EPA OIG image)
Further, as shown in Table 3, the 2021 community involvement plan was less comprehensive when
compared to the 2002 community involvement plan. For example, Region 7 did not conduct sufficient
interviews for the 2021 community involvement plan. Office of Solid Waste and Emergency Response
Directive No. 9230.0-20, Innovative Methods to Increase Public Involvement in Superfund Community
Relations, recommends conducting interviews with at least 15 to 25 people when developing a
community involvement plan, depending on the complexity of the site and the level of citizen interest.10
The guidance states that "increasing the number of interviews with citizens is one of the most effective
methods to enhance citizen participation" and that significant up-front investment "helps ensure that
the Region identifies and focuses attention on those issues that are most important to the community."
The 2002 community involvement plan, which did not specify the exact number of interviews
conducted, referenced interviews with local officials, community groups, residents, and business
9 Region 7 used a contractor to develop the 2002 community involvement plan.
10 In 2015, the EPA changed the name of the Office of Solid Waste and Emergency Response to the Office of Land
and Emergency Management.
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owners. In contrast, in developing the 2021 community involvement plan, Region 7 emailed only eight
staff members from the City of St. Charles to gather community views on the Superfund site. Region 7
received only one response from a city official who expressed dissatisfaction with the EPA's actions at
the Findett Corp. Superfund Site. Because Region 7 only engaged city officials and collected only one
response, it did not get a diverse community perspective on the remediation efforts.
Table 3: Analysis of Region 7's 2002 and 2021 community involvement plans for the Findett Corp.
Superfund Site
The community The community The community involvement
involvement plan met I I involvement plan partially ^ plan did not meet the
the guidance met the guidance guidance
2002
2021
Community
Community
involvement
involvement
Applicable guidance
plan
plan
The National Contingency Plan requires, to the extent practicable, at least
one information repository be established at or near the location of the
response action.*
X
The Superfund Community Involvement Toolkit's aid for community
interviews recommends conducting interviews with a diverse group of
stakeholders to gain the greatest variety of perspectives about the site.
X
The EPA headquarters template for community involvement plans
recommends including water-related "issues of concern to residents" and
"site-specific information" about contaminants of concern.
l=l
The EPA headquarters template for community involvement plans
recognizes that key topics for community concern include community
"perceptions and opinions of EPA and the cleanup process," "whether
there are other sources of pollution that affect the community," and
"whether there are past experiences of mistrust or any other concerns."
X
The Superfund Community Involvement Handbook recognizes that "a key
to evaluating short- or long-term community involvement efforts is
identifying reasonable goals and objectives" and that it is a good idea to
"identify key messages and appropriate communication methods."
l=l
The Superfund Community Involvement Handbook recommends site
teams consider identifying nongovernment locations to hold public
meetings while the Community Involvement Template has space to "insert
example meeting venues from interviews and information gathering."
X
Note'. The 2021 community involvement plan discusses polychlorinated biphenyls and volatile organic compounds,
including benzene, and links to those chemicals' respective fact sheets. The plan does not mention other specific
volatile organic compounds that are contaminants of concern, which include: trichloroethylene; cis-1,2-
dichloroethylene; and vinyl chloride. The 2021 community involvement plan also discusses objectives, but not goals,
which the Superfund Community Involvement Handbook describes as distinct items.
Source: OIG analysis of Region 7 community involvement plans.
* Region 7 used the Kathryn Linnemann Branch of the St. Charles City-County Library system in the city of
St. Charles as an online repository but did not list it in the 2021 community involvement plan. Rather, the community
involvement plan listed the Middendorf-Kredell Branch, about 12 miles west of the city of St. Charles.
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In its 2021 community involvement plan, Region 7 could have also included information about the
nearby Weldon Superfund Site, which had a history of community activism, distrust, and frustration with
the EPA. Awareness of frustrations at a nearby Superfund site could have provided Region 7 staff with
important, early context regarding community feelings at the Findett Corp. Superfund Site. Region 7
could have also included a list of available meeting locations for hosting public meetings. A prepared list
of potential meeting venues may have better prepared the region for the November 17, 2022 public
meeting, which was not able to accommodate all those who wished to attend. Region 7 did not
prioritize updating the community involvement plan because of the number of sites the community
involvement coordinators were responsible for and a perception that the public was not interested in
the Findett Corp. Superfund Site. However, these deficiencies contributed to Region 7's public
communication challenges and its reduced capacity to foresee community concerns.
Region 7 Did Not Successfully Facilitate Community and City
Involvement
Region 7 staff did not effectively facilitate community or city involvement at the Findett Corp. Superfund
Site. The remedial project managers did not take advantage of available tools and staff expertise, such
as the community involvement coordinators, to provide the technical assistance that the surrounding
community needed. Also, the contentious relationship among Findett Corp. Superfund Site stakeholders
delayed cleanup activities. Conflicting messages on the health risks from the groundwater
contamination also caused confusion in and additional mistrust by the St. Charles community. Although
the EPA's Superfund Community Involvement Handbook states that additional community involvement
efforts may be needed if there are increasing levels of community distrust, Region 7 did not use
alternative dispute resolution services or other mediation tools as the relationship between the EPA and
the community deteriorated.
Alternative dispute resolution
The EPA's Conflict Prevention and Resolution Center provides alternative dispute resolution
services to the Agency. Alternative dispute resolution is any procedure used to resolve a
controversial issue. Alternative dispute resolution involves a neutral third party that has no
stake in the substantive outcome.
Technical Staff Led the Superfund Process, including Community Involvement,
but Were Unaware of Available Tools and Resources
Between November 6, 2022, and February 23, 2023, the St. Charles community expressed frustration
with and distrust of Region 7 staff on at least 37 occasions via emails and during Region 7's public
briefings. Further, our interviews with five community leaders in St. Charles revealed that four distrusted
the EPA. The leaders also indicated that others in the St. Charles community that they had spoken to
were similarly distrustful. Figure 9 shows the public perceptions that were discovered during Region 7's
February through April 2023 Findett Corp. Superfund Site Technical Assistance Needs Assessment
interview of 21 community members and stakeholders.
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Figure 9: Public perceptions of Region 7's activities in the Findett Corp. Superfund Site Technical
Assistance Needs Assessment
Source: OIG summary of the 2023 Findett Corp. Superfund Site Technical Assistance Needs Assessment.
(EPA OIG image)
According to the EPA's Superfund Community Involvement Handbook, EPA staff should interact with the
community in ways that promote trust to ensure that the EPA's community involvement is effective. The
handbook also provides solutions for when a community has lost trust in the process. These solutions
include seeking out the EPA's Conflict Prevention and Resolution Center for mediation or facilitation
services, providing the community with an opportunity to form a community advisory group, or
providing technical assistance services to the community. However, Region 7 did not use the Technical
Assistance Services for Communities program until November 2022 and only did so at the request of a
community member.
Community advisory groups
Community advisory groups serve as the focal point for the exchange of information among the
local community and agencies involved in the cleanup of a Superfund site. The purpose of such
groups is to provide a public forum for the community to present and discuss their needs and
concerns related to the decision-making process, which can help the EPA make better decisions on
how to clean up the site. According to EPA guidance on community advisory groups, the EPA should
inform and educate the community about the purpose of a community advisory group and how to
participate in one.
The remedial project manager is responsible for managing the community involvement activities for the
Superfund site. However, the remedial project managers directly involved with the Findett Corp.
Superfund Site did not have the necessary knowledge about tools for assessing or providing for the
technical assistance needs in St. Charles. The remedial project managers stated that they rely on the
expertise of the community involvement coordinators to identify opportunities to use tools such as a
Technical Assistance Needs Assessment or the Technical Assistance Services for Communities program.
Although the managers rely on the coordinators to identify these opportunities, the managers indicated
that they typically only involve the coordinators in meetings in which they plan to discuss community
involvement. Region 7 also does not require its remedial project managers to receive ongoing training
20
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on technical assistance resources. According to Region 7 community involvement coordinators, these
managers do not always attend community involvement trainings when offered, despite community
involvement being a core component of their roles. The Technical Assistance for Communities program
and the Conflict Prevention and Resolution Center are managed under national EPA contracts and are
available to augment the regional capacity at no cost to the region.
Region 7 could improve its procedures by using a systematic approach for involving community
involvement coordinators in meetings and prioritizing sites for technical assistance. In Region 9, for
example, community involvement staff use a scoring system for prioritizing Superfund sites for technical
assistance resources, which has helped the region leverage that support significantly more than any
other region, as shown in Figure 10. A Region 1 community involvement coordinator told us that
Region 1 uses Conflict Prevention and Resolution Center resources to help fill community involvement
resource gaps.11 Both regions use technical assistance resources for issuing effective plain language
public communications and for developing community involvement plans. Using those resources in
similar ways could help Region 7 improve the deficiencies in the areas discussed above.
Figure 10: EPA region use of the Technical Assistance Services for Communities program from
2006 through 2022
Source: EPA OIG analysis of EPA community involvement data. (EPA OIG image)
Improving remedial project managers' knowledge of technical assistance tools, regularly including
community involvement coordinators in site team meetings, and establishing a process for prioritizing
11 We could not compare regional use of the Conflict Prevention and Resolution Center because EPA headquarters
has not tracked those data for several years.
21
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communities for technical assistance tools would help Region 7 better assess and meet the technical
assistance needs of communities. Increasing the use of technical assistance tools could mitigate
resource challenges in the regions and improve community involvement.
Region 7's Unsuccessful Engagement with the City Delayed Site Actions
The contentious relationship between the City of St. Charles and Region 7 delayed site actions and the
development of a mitigation strategy at the Findett Corp. Superfund Site. Region 7 and Ameren were
unable to promptly gain the access to city property that they needed to investigate contamination. The
lack of access delayed any cleanup strategies or decisions. Further, Region 7 instructed the city and
Ameren to work together to develop a well-pumping plan for the St. Charles public water system, even
though Region 7 knew there was a hostile relationship between these entities. Region 7 did not take an
active mediation role or seek independent dispute resolution services, even though the city's officials
requested independent oversight of the Findett Corp. Superfund Site.
Water Sampling Was Delayed Because of Conflicts
The worsening relationship between city officials and Region 7 and the subsequent loss of trust caused a
delay of site actions, such as water sampling and testing. As shown in Figure 11, in December 2021,
contamination in a city drinking water well and nearby monitoring well increased without explanation.
As a result, it was critical for Region 7 to identify the source of the contamination and to develop a plan
to address it. Ameren intended to conduct this work in April 2022 but, according to Region 7 staff, the
City of St. Charles placed locks on its wells. When, in October 2022, Region 7 claimed that the city had
denied Ameren access, a representative for the city asserted that the region's account was "plainly
false" and a "blatant mischaracterization of the facts." Then, to address city concerns regarding Ameren
conducting the sampling work, Region 7 hired a contractor to conduct the groundwater sampling at
various locations and depths in the wellfield. The city contends that Region 7 told the city on
November 17, 2022, that the region would meet with the city to schedule the sampling. However,
according to the city, there was no such meeting. Region 7 notified the city's contractor on
November 29, 2022, that the region's contractor was going to begin sampling on Monday, December 5,
2022. However, on the afternoon of Friday, December 2, 2022, the city required the contractor to sign
an access agreement that included minimum insurance requirements. Region 7's contractor could not
meet those requirements by December 5 and, thus, did not access city property for sampling. The city's
director of public works described the delay as "ridiculous" and showing "a lack of concern" for the
situation. The director added that alleging that the city was at fault for the delay was "as preposterous
as [the region's] selection of a company that fails to meet minimum requirements of a qualified
contractor." The director also stated that "to blame the city for the delay is a blatant lie and reinforces
our lack of confidence and trust in [the remedial project manager's] abilities to objectively perform [the
remedial project manager's] job."
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Figure 11. Timeline of events surrounding access issues for water sampling
Contamination unexpectedly increases In a city well and a nearby monitoring well.
December 2021:
February 2022:
April 2022:
September 2022:
Ameren, under Region 7 oversight begins sampling to characterize the contamination
plume.
Ameren is unable to access city property for sampling because the city wants a more
detailed scope of work.
City sampling indicates high levels of vinyl chloride in a city well. Region 7 responds
that it is working with Ameren to assess the reason for increasing contamination.
October 13,2022:
November 29, 2022:
Region 7 tells the city it would conduct planned sampling instead of Ameren to rule out
any alternate sources of contamination. It notes that it would provide a work plan and
that it would like access in November or December.
Region 7 notifies stakeholders, including the city contractor, but not the city, of planned
investigation work for December 5 through December 16.
The city responds and includes a temporary access aqreement with minimum insurance
************** requirements.
Region 7's contractor cannot access city property to conduct sampling because it does
not meet the city's insurance requirements. Region 7 expresses disappointment that the
fieldwork cannot be completed because of the "surprising" access requirements.
December 15, 2022:
December 22, 2022:
January 17, 2023:
May 10, 2023:
Region 7 formally informs the city of the region's legal authorities to access the city
property for sampling, but says it prefers to obtain access consensually.
The city signs a consent for access agreement for EPA contractors, stating that "any
questions from the USEPA could have been resolved with a simple phone call to the City
of St Charles which would have allowed for the timely start of the limited subsurface
investigation."
Region 7 contractors begin sampling under the new access agreement.
Region 7 facilitates an access agreement between Ameren and the city.
Source: OIG summary of correspondence between Region 7 and the City of St. Charles. (EPA OIG figure)
Because of the poor working relationship between Region 7, the city, and Ameren, the water sampling
was delayed for nine months, as neither Ameren nor Region 7 contractors were able to promptly gain
access to city property. Although the poor working relationships between these key stakeholders
tangibly impacted the progress of the Superfund process, Region 7 did not pursue available mediation
services through the EPA's Conflict Prevention and Resolution Center until October 2023.
Region 7 Did Not Mediate Known Disagreements Between the City and the Potentially
Responsible Party on Water-Pumping Strategies
Region 7 staff did not take an active role in the development of the city's well-pumping plan, which the
city would follow to ensure that its well pumping does not introduce groundwater contamination into its
23
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drinking water supply. The City of St. Charles owns and operates the drinking water wells. As such, it is
the entity that would implement a well-pumping plan, choosing which wells to pump at any given time
to try to meet the demand of its consumers and maintain the system. While Region 7 has not designated
the well-pumping plan as an institutional control, the City of St. Charles could manage the pumping of its
wells in a manner that could prevent contamination from spreading into the city's drinking water supply.
Institutional controls
Institutional controls are nonengineered instruments, such as administrative and legal measures, that help
minimize the potential for human exposure to contamination. Institutional controls are important because
they reduce exposure to contamination by limiting land or resource use and guiding human behavior.
In March 2023, Region 7 informed the public that the city's increased pumping rates at two wells likely
shifted the groundwater plume, thereby causing the EPA's existing remediation strategy to fail. The
EPA's guidance document. Institutional Controls: A Guide to Planning, Implementing, Maintaining, and
Enforcing Institutional Controls at Contaminated Sites, states that site managers should seek input from
local governments and responsible parties to help the managers select the most appropriate response
to contamination. It can be critical for the site manager to foster cooperation and coordination among
stakeholders to ensure long-term protectiveness at the site.
Although unrestricted pumping could cause contamination to spread to the drinking water, Region 7
maintained a passive role during the development of the well-pumping plan, even after the city made it
clear to the region that the city and Ameren did not agree on a strategy for safely operating the wells. In
March 2023, Region 7 staff communicated to the City of St. Charles that the region expected the city to
collaborate with Ameren to develop a well-pumping plan, even though Region 7 knew Ameren and the
city's relationship was contentious. Region 7 encouraged Ameren to respond to city comments, but
there was no other evidence that Region 7 actively mediated or facilitated the development of the well-
pumping plan.
Region 7 did not actively engage with the city in the development of the well-pumping plan because,
according to two Region 7 staff, the plan should be developed by the city. The region did not use the
EPA's Conflict Prevention and Resolution Center to help mediate the conflicts and ensure that the
well-pumping plan was developed in a timely manner. As of October 2023, the city and Ameren have
not agreed on a well-pumping plan.
Conflicting Perspectives and Messages Caused Confusion in the Community
While Region 7 has maintained that there is no reason to believe there are any health risks to consuming
the St. Charles drinking water, the City of St. Charles argues that Region 7's and Ameren's actions and
inaction are a threat to public health. Because of their opposing views on cleanup plans and their poor
working relationship, Region 7 and the City of St. Charles issued conflicting messages about the health
risks of the groundwater contamination, which resulted in confusion in the St. Charles community.
Pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act, in cases in
which contaminated groundwater is a current or future source of drinking water, the EPA is to restore
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the site to the point of beneficial use. At the Findett Corp. Superfund Site, restoring the site to beneficial
use means ensuring that the groundwater meets drinking water standards or, in other words, does not
exceed maximum contaminant levels. According to one St. Charles resident, community members were
surprised by the EPA's assertion at the November 2022 public meeting that the EPA did not recommend
closing the wells and that the water was safe because they had heard on the news that the city had shut
down the wells.
Region 7 Did Not Use Tools to Mitigate City Distrust
Despite worsening contamination from Operable Unit 4 in December 2021 and evidence of city
discontent as early as 2014, Region 7 staff did not request help from the Technical Assistance Support
for Communities program until a community member asked for it in November 2022. Region 7 also did
not seek out Conflict Prevention and Resolution Center resources to improve its engagement efforts
with the city until October 2023, even though Region 7 considered the meetings with the city to be
contentious as early as March 2022. The EPA's Superfund Community Involvement Handbook states that
Superfund site teams should be "prepared to anticipate and respond to the community's concerns,
fears, and potential areas of misunderstanding or confusion" and that additional community
involvement efforts may be needed when faced with elevated community distrust, particularly when the
public interprets the EPA's preferred course of action as improper or inadequate. While stakeholders
may disagree with Agency decisions, they are more likely to understand and accept them if there is trust
in the EPA and belief that the process is fair, and their input considered. The EPA's Conflict Prevention
and Resolution Center can also provide independent conflict resolution specialists to facilitate and
mediate constructive discussions between interested parties.
By 2021, Region 7 staff were aware that the city's public works managers disagreed with the EPA's
decision not to require the potentially responsible parties to replace a portion of city wells. Region 7
staff were also aware of at least one nearby Superfund site that had already bred community mistrust in
the EPA. The already-deteriorating relationship, which worsened with conflicts related to the water
sampling, culminated in the City of St. Charles issuing an official letter on December 13, 2022,
denouncing Region 7's actions and recommendations as "woefully inadequate," "egregious," and
"preposterous." In one letter, dated September 27, 2022, the mayor's office asserted an "imminent and
substantial endangerment of the health and welfare of the citizens of St. Charles." The City of St. Charles
also requested the EPA administrator establish headquarters oversight of EPA Region 7 regarding the
Findett Corp. Superfund Site. While Region 7 does not believe that there are any risks from consuming
or otherwise using the St. Charles drinking water because samples of treated drinking water show no
contamination, the region had not attempted to resolve the city's fears by bringing in an impartial third
party. It was not until October 2023 that Region 7 contacted the EPA's Conflict Prevention and
Resolution Center for mediation services.
Conclusions
Region 7 could have improved its public communications with St. Charles community members and city
officials, developed a more robust community involvement plan, and better facilitated community
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involvement. Because the region did not use technical assistance tools and resources in a timely
manner, the community was not able to fully participate or understand the cleanup process, which may
have resulted in community distrust of Region 7. Region 7's unsuccessful engagement with the city
resulted in conflicting messages from the city and the region about the public health risks of the
groundwater contamination, cleanup delays, and public confusion. Procedural improvements, such as
ensuring Superfund managers and staff receive training on technical assistance resources and
implementing a systematic method to identify and prioritize community needs for technical assistance,
could improve Region 7's Superfund community involvement. Clear, understandable, and accessible
information from Region 7 may have overcome the conflicting messaging from the city and the region,
but the combination of ineffective city engagement and ineffective public communications negatively
impacted the community's confidence in Region 7's oversight. Despite the increasingly contentious
relationships among the Superfund site stakeholders, Region 7 did not use available mediation tools to
mitigate the situation until October 2023. Based on the procedural deficiencies identified at the Findett
Corp. Superfund Site, Region 7 can broadly apply lessons learned to improve its community involvement
processes at Superfund sites throughout the region.
Recommendations
We recommend that the regional administrator for Region 7:
1. In coordination with the Conflict Prevention and Resolution Center, assess the need for
alternative dispute resolution services at the Findett Corp. Superfund Site.
2. Develop a plan, in collaboration with community involvement coordinators, to ensure remedial
project managers and Superfund and Emergency Management Division supervisors receive
regular and ongoing training on the availability of the EPA's community engagement resources
and on the use of plain language in public-facing EPA documents intended for Superfund
communities.
3. Implement a systematic method to help Region 7 Superfund site teams identify and prioritize
community needs for technical support from the EPA's Conflict Prevention and Resolution
Center and Technical Assistance Services for Communities program.
4. Establish regular opportunities for community involvement coordinators to develop an ongoing
understanding of site and community activities and to provide recommendations for community
engagement.
5. Implement procedures for updating community involvement plans as site conditions change.
Procedures should include a process to ensure the community involvement plans follow
relevant EPA community involvement guidelines and the circumstances under which the EPA's
technical assistance programs will be used to support plan development.
26
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Agency Response and OIG Assessment
Appendix A includes Region 7's response to our draft report. The region also provided technical
comments, which we reviewed and used to make appropriate changes for the final report. Region 7
agreed with all recommendations and provided corrective actions with estimated completion dates.
Based on the information provided and supporting documentation, we agree that the corrective action
for Recommendation 1 was completed and that the planned corrective actions for Recommendations 2
and 3 meet the intent of our recommendations. Recommendations 2 and 3 are resolved with corrective
actions pending. We do not agree with Region 7's planned corrective actions for Recommendations 4
and 5, and those recommendations are unresolved.
Region 7's corrective actions for Recommendation 4 included hiring additional community involvement
coordinators, creating a site-specific electronic repository for tracking and documenting community
needs, and adjusting the format of a weekly meeting to identify increases in community needs. These
corrective actions do not ensure that community involvement coordinators, specifically, will have a
meaningful opportunity to understand site and community activities and provide informed
recommendations for community involvement. As noted in Chapter 2, community involvement
coordinators do not regularly attend site team meetings at which they would recognize those
opportunities. Assuring these community involvement coordinators can provide meaningful input at site
team meetings will promote Region 7's ability to assess and meet the technical assistance needs of
communities. This recommendation is unresolved pending Region 7 clarifying how it will meaningfully
incorporate community involvement coordinators into site team meetings.
Region 7's corrective actions for Recommendation 5 involved new procedures for reviewing the
community involvement plan when public interest or site conditions change and the addition of a
checklist for use during annual community involvement plan reviews. These corrective actions do not
include outlining the process to ensure that the community involvement plans follow the relevant EPA
community involvement guidelines. Our analysis demonstrates that Region 7's 2021 community
involvement plan was less comprehensive than the 2002 community involvement plan. These
deficiencies contributed to Region 7's public communication challenges and its reduced capacity to
foresee community concerns. Following the established guidance could help the region overcome these
deficiencies in future community involvement plans. Recommendation 5 is unresolved pending
Region 7's update to its corrective action to specify how it will assure future community involvement
plans follow relevant guidance.
27
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Status of Recommendations
Rec. No. Page No.
Recommendation
Status*
Action Official
Planned
Completion
Date
1 26
In coordination with the Conflict Prevention and Resolution Center, assess the
need for alternative dispute resolution services at the Findett Corp. Superfund
Site.
C
Regional Administrator
for Region 7
10/24/23
2 26
Develop a plan, in collaboration with community involvement coordinators, to
ensure remedial project managers and Superfund and Emergency Management
Division supervisors receive regular and ongoing training on the availability of the
EPA's community engagement resources and on the use of plain language in
public-facing EPA documents intended for Superfund communities.
R
Regional Administrator
for Region 7
12/31/24
3 26
Implement a systematic method to help Region 7 Superfund site teams identify
and prioritize community needs for technical support from the EPA's Conflict
Prevention and Resolution Center and Technical Assistance Services for
Communities program.
R
Regional Administrator
for Region 7
12/31/24
4 26
Establish regular opportunities for community involvement coordinators to
develop an ongoing understanding of site and community activities and to
provide recommendations for community engagement.
U
Regional Administrator
for Region 7
5 26
Implement procedures for updating community involvement plans as site
conditions change. Procedures should include a process to ensure the
community involvement plans follow relevant EPA community involvement
guidelines and the circumstances under which the EPA's technical assistance
U
Regional Administrator
for Region 7
programs will be used to support plan development.
* C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
28
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Agency Response
Appendix A
V-K X4"
"U pro"^
REGION 7 ADMINISTRATOR
LENEXA, KS 66219
<:
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uj
March 6, 2024
MEMORANDUM
SUBJECT: Response to the Office of Inspector General Draft Report, Project No. OSRE-FY23-0069,
"EPA Region 7 Did Not Engage with the Community Surrounding the Findett Corp.
Superfund Site," dated February 6, 2024
Thank you for the opportunity to respond to the issues and recommendations in the subject draft audit
report. The following is a summary of the U.S. Environmental Protection Agency's overall position, and
its position on each of the report's recommendations. We have provided high-level corrective actions
and estimated completion dates.
AGENCY'S OVERALL POSITION
The agency concurs with all the recommendations, and notes that Region 7 has already begun
implementation of some of these recommendations. The EPA met all statutory requirements for
community involvement outlined in the Comprehensive Environmental Response, Compensation, and
Liability Act and the National Contingency Plan and will continue to meet them. The EPA continued
developing and implementing communication and coordination measures to identify and prioritize
community needs during the timeframe when the OIG was performing its evaluation. The measures
align well with much of what the OIG is recommending. Attached is a technical comments document
that provides clarification and explains the agency's position on several report statements and findings.
FROM:
TO:
Patrick Gilbride, Director
Implementation, Execution, and Enforcement Directorate
Office of Special Review and Evaluation
29
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AGENCY'S RESPONSE TO DRAFT AUDIT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Corrective Action
Est. Completion
Date
1
In coordination
with the Conflict
Prevention and
Resolution Center,
assess the need for
alternative dispute
resolution services
at the Findett Corp.
Superfund Site.
In Fall 2023, Region 7 assessed the need for alternative
dispute resolution at the Findett Corp. Superfund Site before
receiving the OIG recommendations.
As a result of Region 7's assessment, the agency proposed to
the city of St. Charles that the group bring on a neutral party
to facilitate discussions. In coordination with the city and the
Conflict Prevention and Resolution Center, Region 7
interviewed and selected a facilitator to enable more
productive technical consultations between the agency and
the city.
Completed
2
Develop a plan, in
EPA Region 7 agrees that awareness of community
1. Assess Site
collaboration with
engagement resources and the effective use of plain language
Profile pages
community
writing in public products are essential building blocks of a
using the CDC
involvement
thriving community involvement program.
Clear
coordinators, to
Communication
ensure remedial
Region 7 remedial project managers attend annual regional
Index:
project managers
training that includes a module on community involvement
Completed
and Superfund and
taught by a Region 7 senior community involvement
2. Integrate CDC's
Emergency
coordinator. The learning objectives include increasing
Clear
Management
knowledge of the CERCLA community involvement process
Communication
Division supervisors
and the EPA's extensive engagement resources. The training
Index: Due -
receive regular and
also addresses the requirement to use plain language in
December 31,
ongoing training on
public products. The region trains and coaches CICs so they
2024
the availability of
can advise RPMs on what resources are available and how to
3. Training Plans:
the EPA's
employ plain language effectively.
Due - December
community
31, 2024
engagement
Region 7 utilizes most of the engagement resources outlined
4. Assess Training
resources and on
on the EPA's web page:
Modules: Due -
the use of plain
https://www.epa.gov/superfund/superfundcommunity-
December 31,
language in public-
involvement-tools-and-resources.
2024
facing EPA
documents
We have completed numerous efforts for the St. Charles site
intended for
to involve and engage the community in the Superfund
Superfund
process. Community involvement is always a dynamic
communities.
process, ever-evolving as new needs and interests are
identified or come to the fore. Some of the resources and
tools we've utilized for the Findett Corp. Site include a site
profile web page, Technical Assistance Needs Assessment,
Community Advisory Group, Technical Assistance Services for
Communities' resources, community interviews, Community
Involvement Plans, public fact sheets, public notices, CAG
30
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meetings, EPA public meetings and public availability sessions,
frequently asked questions, information repository, mailing
and email engagement and lists, media engagement, social
media and live streaming events, congressional and
intergovernmental engagements, and more.
Region 7 RPMs integrate CICs on their site teams and include
them in team meetings.
Region 7 has a well-defined procedure for reviewing and
approving all community involvement public products,
including the Region's Review Official and the Public Affairs
Director or deputy.
Actions:
1. The Public Affairs Director instructed Region 7 CICs to
conduct an assessment of selected Superfund site profile
web pages using the Centers for Disease Control Clear
Communication Index
https://www.cdc.gov/ccindex/index.html. The team
completed the assessment and is now developing a
training module for RPMs, CICs, the Review Official, and
others in the review chain for Superfund public products.
2. Region 7 will complete the project to integrate the CDC's
Clear Communication Index in its development, review
and approval process for public products and train staff.
3. Region 7 will prioritize community involvement as part of
the RPMs' annual training plans.
4. Region 7 will assess its community involvement and plain
language training modules provided to new RPMs and
CICs and adjust the training as needed.
3
Implement a
systematic method
to help Region 7
Superfund site
teams identify and
prioritize
community needs
for technical
support from the
EPA's Conflict
Prevention and
Resolution Center
and Technical
Assistance Services
for Communities
program.
Region 7 utilizes the Community Involvement Plan process as
the systematic method for Superfund site teams to identify
and prioritize community needs for technical support. The
process includes reviewing whether EPA's Conflict Prevention
and Resolution Center assets or the Technical Assistance
Services for Communities Program capabilities are applicable
to meeting the needs of the community and EPA.
Region 7's senior CICs are experts in their field, with the
knowledge and skills to advise RPMs on when to apply these
capabilities. Beyond the CIP development process, which
includes formal community interviews and informal
discussions with community members and local leaders, the
CICs and RPMs are expected to monitor community needs for
technical assistance and other tools available through EPA's
multiple engagement resources, including CPRC and TASC.
1. Due: December
31, 2024
31
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We've found that the level of community interest and thus
needs at different sites and even over time at the same site
can vary.
Beyond meeting the statutory requirements for community
involvement, the Region strives to adapt and surge capacity to
meet a community's changing needs and interests, which
occurred in this instance. The Region adjusted its time and
attention to better involve and engage stakeholders and
community members as their interests and needs changed.
In Fall 2022, the EPA saw increased community interest in the
site. The RPMs, CICs, and Office of Public Affairs managers
and staff worked to promptly take action and increase
engagement with the community, including:
• Increased e-mail correspondence with individual
community members and stakeholders,
• Established a new weekly e-mail update to a local group
of community members and stakeholders,
• Issued several news releases, including six in 2023,
• Made proactive calls to news reporters,
• Published two fact sheets (a site-specific update and a
Direct Push Technology information fact sheet),
• Secured technical assistance resources through the EPA's
Technical Assistance Services Contract program,
• Conducted a Technical Assistance Needs Assessment,
o A TASC technical advisor was assigned to the site in
2023 to assist the community as needed,
o As part of the TANA process, the EPA's TASC
contractor presented information in 2023 on the
additional technical resources available to the
community during a community meeting.
• Secured assistance through the EPA's Conflict Prevention
and Resolution Center,
o Secured a facilitator for the weekly technical
meetings between the EPA and the city
• Assisted the community in establishing a Community
Advisory Group. Region 7 continues coordinating with
EPA Headquarters to ensure the community can access
additional technical assistance services.
Action:
1. Region 7 utilizes the Community Involvement Plan
process to systematically review, identify and prioritize
community needs for technical support. To augment
32
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issue-focused reviews of community involvement needs
at a site, Region 7 will establish a new annual
requirement for site teams (CICs and RPMs) to determine
if an *active site's CIP should be updated. To support this
annual review, Region 7 will develop a checklist that
includes assessing if CPRC and TASC tools are
recommended.
* Definition of "active sites:" An active site is one with
planned actions for a fiscal year. Active sites are identified
in the Region 7 Fiscal Year Superfund Comprehensive
Accomplishment Plan (SCAP).
4
Establish regular
opportunities for
community
involvement
coordinators to
develop an ongoing
understanding of
site and community
activities and to
provide
recommendations
for community
engagement.
Region 7 agrees that continued and even greater integration
of the practices and principles of successful community
involvement into site team planning is warranted. CICs are
already key members of the site teams led by the RPMs.
Community involvement and engagement are topics site
teams discuss with advice from the CICs that go beyond
meeting the statutory requirements for community
involvement. For some communities, this has included the
need for the team to engage state and county health
department experts on public health efforts, such as free
childhood blood lead testing. The identification and planning
for these supplemental efforts can begin anytime throughout
the CERCLA process, including at sites that have entered the
five-year review phase in the lifecycle of a Superfund site.
Actions:
1. Region 7 has recruited four additional CICs in the past
12 months, more than tripled the number of CICs
(from 2 to 7) on board in 2022. The additional
capacity will facilitate increased awareness and ability
to act more quickly in surging resources to meet
changing community involvement needs.
2. SEMD's Remedial Branch has established new site-
specific folder structures in a Microsoft Teams
channel to better track and document changes in
community needs and facilitate increased situational
awareness.
3. The Office of Public Affairs changed the weekly
community involvement meetings approach to an
agenda-driven focused "report and discuss" model
that increases situational awareness of changing
needs at sites. The meetings now integrate an agenda
topic discussion to identify any increases in external
attention and engagement needs at sites. OPA's
1. Completed
2. Completed
3. Completed
33
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Superfund and Emergency Response press officer
participates in the meetings for this purpose.
Implement
procedures for
updating
community
involvement plans
as site conditions
change. Procedures
should include a
process to ensure
the community
involvement plans
follow relevant
guidelines outlined
in the EPA's
Community
Involvement Plan
Tool and the
circumstances
under which the
EPA's Technical
Services for
Communities
program will be
used to support
plan development.
The EPA Region 7 complies with community involvement
requirements outlined in the National Contingency Plan. The
Community Involvement Plan process serves as the
systematic method for Superfund site teams to identify and
prioritize community needs for technical support from the
EPA's Conflict Prevention and Resolution Center and Technical
Assistance Services for Communities Program. As
professionals and subject matter experts, CICs monitor
community technical assistance needs continuously. Levels of
community interest vary at sites and even over time at the
same site. The EPA adjusts its level of engagement to be
appropriate for the level of community interest identified by
the agency and the availability of resources. Technical
assistance resources are limited and, therefore, are tailored
to site-specific engagement requirements and community
needs. Region 7 and the city started holding weekly meetings
on March 1, 2023, to discuss technical aspects of the site and
increase communications between the two parties.
Additionally, Region 7 created a SharePoint site to share
documents and information and to encourage collaboration
between the EPA, the Potentially Responsible Party for
Operable Unit 4, and the City of St. Charles. Region 7 also
provides documents, such as work plans and other technical
documents, to the city for review and to seek comments.
Actions:
1. Region 7 reviews community involvement plans when
public interest increases at a site and when there are
changes in site conditions or cleanup actions. We have
integrated new procedures that will regularly be used to
formally discuss if either site conditions or a community's
needs are changing, which triggers a review of the CIP.
Please see Action # 3 under Recommendation #4 above
and Action #2 immediately below.
2. See the EPA Action item in response to the OIG
Recommendation # 3 above. Region 7 CICs and RPMs will
conduct annual reviews of CIPs for "active sites." The CICs
will develop and use a new checklist to assess whether
the CIPs for these "active sites" should be revised.
Definition of active sites: An active site is one that has
planned actions for a fiscal year.
1. Completed
2. Due: December
31, 2024
If you have any questions regarding this response, please contact the Region 7 Audit Follow-Up
Coordinator, Kathy Finazzo, at Finazzo.Kathvffiepa.gov or (913) 551-7833.
34
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Appendix B
Distribution
The Administrator
Deputy Administrator
Chief of Staff, Office of the Administrator
Deputy Chief of Staff for Management, Office of the Administrator
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Continuous Improvement, Office of the Chief Financial Officer
Director, Office of Regional Operations
Audit Follow-Up Coordinator, Office of the Administrator
Regional Administrator, Region 7
Deputy Regional Administrator, Region 7
Regional Audit Follow-Up Coordinator, Region 7
Regional Public Affairs Officer, Region 7
Director, Region 7 Superfund and Emergency Management Division
Office of Policy OIG Liaison
Office of Policy GAO Liaison
35
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Whistleblower Protection
U.S. Environmental Protection Agency
The whistleblower protection coordinator's role
is to educate Agency employees about
prohibitions against retaliation for protected
disclosures and the rights and remedies against
retaliation. For more information, please visit
the OIG's whistleblower protection webpage.
Contact us:
Congressional Inquiries: OIG.CoiwessionalAffairs(53epa.gov
Media Inquiries: OIG,PublicAffairs@epa.gov
line EPA OIG Hotline: OIG.Hotline@epa.gov
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