16 th Annual OSC Readiness Training Program NCP Community Involvement Requirements and Additional Recommendations Katy Miley,

www.trainex.org/osc2013

16th Annual OSC Readiness Training Program

NCP Community Involvement Requirements

and Additional Recommendations

Katy Miley, R7 OSC

16th Annual OSC Readiness Training Program www.trainex.org/osc2013 2

Course Agenda

Requirements and recommendations for CI on your removal site NCP required CI activities, deliverables, and

timelines for removal actions Administrative Records Recommended CI activities

OSC/CIC/media relations coordination Case study example Guidance on developing effective

presentations and engaging audiences


Removal Activity CI Requirements

Reference document Removal Process Community Involvement

Activities handout



Designate a lead agency spokesperson OSC Community Involvement Coordinator Press Officer Public Information Officer

• ICS



Time-Critical Removal with Planning Period < Six Months

• Establish an administrative record (AR) and make AR file available for public inspection in repository NLT 60 days of initiation of on-site activities

• Establish a local repository at or near location of response action and publish notice in local paper of AR file availability within 60 days of initiation of on-site activities

• As appropriate, provide a 30 day public comment period on AR file and include response to comments received during comment period in the AR file



Non-Time Critical Removal with Planning Period ≥ Six Months

• Establish an administrative record (AR)

• Establish a local repository near site location and place AR file in repository no later than the signing of the EE/CA approval memorandum

• Conduct an EE/CA or its equivalent that includes community interviews and preparation of a CIP/CRP prior to EE/CA completion

• Publish notice in local paper of availability and description of EE/CA and publish notice of AR availability

• Allow a 30 day comment period on selection of removal action and prepare written response to significant comments



Removal with On-Site Action Expected to Last >120 Days: Time-critical or non-time critical

• Establish an administrative record (AR) and establish a local repository near site location

• Conduct community interviews and prepare a Community Involvement Plan (CIP) by the end of initial 120 days of site work

• Place AR file in repository by the end of the initial 120 days of site work

• Publish notice in local paper of AR file availability



Emergency Removal where on-site activities are initiated

within hours of determination and cease within 30 days• Establish an administrative record (AR) and make

available for public inspection in at central location

• Make AR file available NLT 60 days of start of on-site activities and publish notice in local paper of AR file availability

• As appropriate, provide a 30 day public comment period and include response to comments received during comment period in the AR file


The Administrative Record

Reference Documents AR removal guidance flowchart 2010 – Revised guidance on compiling

administrative records for CERCLA response actions

Published FR notice direct final rule 11.7.12



What is it for? To provide the public the information that EPA

used to make a decision To provide the public an opportunity to comment

on the decision, as appropriate What goes in it?

Information used to make the decision and CI documents• Pictures• State reports• Site assessment data• CIP



How is it developed? Determine site documents that were considered

for the decision Request an AR through your regional records

center Where does it go?

Removals• Central repository and repository near your site• Stop by the library near site and get a business card

Emergencies• Central repository – i.e. EPA Regional Office


Removal Activity CI Recommendations

Build your site team OSC Counsel CIC Technical Team

• Toxicologist/Risk Assessor• SSC• Other Federal Partners

– ATSDR, USACE



Know your site Develop a site summary

• Site background• Contaminants of concern• Cleanup plans• Site team members• Superfund ID numbers

Provide site summary to your CIC• Summary = Fact sheet

Provide site summary to your counsel• Counsel can assist with access agreements and other

negotiations



Know your communication objectives and issues Gain access? Resolve conflict? Get input? Provide information/increase awareness?

Know your community/audience Rural/urban/EJ Residents/workers/local business owners City officials/elected officials/media



Know your message Data results from sampling activities Locations where work may be conducted Long term site plan

Know your communication techniques Fact sheet Availability session/open house/public meeting

• Power points• Maps• Charts

Social media


Summary

CI requirements for Removals in the NCP are distributed and cross referenced through Section 300 300.415, 300.800, 300.820

For successful CI you may need to consider additional community engagement activities Be creative and pro-active

Engage your regional office of public affairs and other site team members early and often