ncp community involvement requirements and additional recommendations
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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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 3
Removal Activity CI Requirements
Reference document Removal Process Community Involvement
Activities handout
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 4
Removal Activity CI Requirements
Designate a lead agency spokesperson OSC Community Involvement Coordinator Press Officer Public Information Officer
• ICS
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 5
Removal Activity CI Requirements
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 6
Removal Activity CI Requirements
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 7
Removal Activity CI Requirements
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 8
Removal Activity CI Requirements
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 9
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 10
The Administrative Record
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 11
The Administrative Record
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 12
Removal Activity CI Recommendations
Build your site team OSC Counsel CIC Technical Team
• Toxicologist/Risk Assessor• SSC• Other Federal Partners
– ATSDR, USACE
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 13
Removal Activity CI Recommendations
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 14
Removal Activity CI Recommendations
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 15
Removal Activity CI Recommendations
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
16th Annual OSC Readiness Training Program www.trainex.org/osc2013 16
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
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