1.  www.trainex.org/osc2013  16 th Annual OSC Readiness Training Program NCP Community Involvement Requirements and Additional Recommendations Katy Miley, R7 OSC

2.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 1 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

3.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 2 Removal Activity CI Requirements  Reference document  Removal Process Community Involvement Activities handout

4.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 3 Removal Activity CI Requirements  Designate a lead agency spokesperson  OSC  Community Involvement Coordinator  Press Officer  Public Information Officer ICS

5.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 4 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

6.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 5 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

7.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 6 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

8.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 7 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

9.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 8 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

10.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 9 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

11.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 10 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

12.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 11 Removal Activity CI Recommendations  Build your site team  OSC  Counsel  CIC  Technical Team Toxicologist/Risk Assessor SSC Other Federal Partners –ATSDR, USACE

13.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 12 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

14.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 13 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

15.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 14 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

16.  16 th Annual OSC Readiness Training Program  www.trainex.org/osc2013 15 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