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And again, here we are.

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This is… you have joined a federal facility academy.

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federal facilities. Next slide, please.

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This is, as I mentioned earlier, a case for if you're just joining. This is a third in the series of 11. For those of you that are interested, there is an opportunity for you to get a certificate if you complete all 11 webinars.

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In addition to the 3-day course, the 3-day course is either in person or it is also virtual instructor-led. Keep in mind, a 3-day course.

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It's only reserved for those that work at other federal agencies, those that work for the EPA, state or tribals organizations that are involved in cleanup, removal, remediation.

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Um, but if you do qualify to do the 11 plus 3, you will get a certificate from a senior leader in the office of Superfund Emergency Management, which shows your dedication to increase your knowledge and being involved.

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With federal facilities. Next slide, please.

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Um… This is, next slide, please.

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Right, so can, um… Go back on. So again, this is the certificate as I mentioned, you get also for those of you that may miss one of the webinars. Don't worry. It is archived, and there's opportunity for you to view the webinar.

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at a time of your convenience, and then you would just go through the webinar, and then there's a process where you have to respond to some questions, evaluation to fill out, and you can still get constructive credit for that.

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And with that, thank you for your patience for housekeeping administrative rules at this time, I'd like to turn you over to our outstanding speaking team.

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All right, Brian, go ahead. I'm going to do something with the slides real quick.

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Sure, sure. So, good afternoon or morning, depending on where you're located. We're going to do quick introductions. So my name is Brian Engler. I'm an EPA Region 4 Remedial Project Manager. I've been with EPA about.

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18 years and almost all that time I've spent cleaning up Superfund sites. I've… I've done that both as an RPM and also an on-sync coordinator, so I've worked on about 50 Superfund sites. I've done a lot of community involvement and really looking forward to, uh.

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talking to you guys about community involvement today, and I'll turn it over to.

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Uh, Haley next.

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Perfect. Hello, my name is Haley Pryson. I started at EPA in September of 2023. So I've been with the agency for a little over two and a half years. I initially started in FIFRO, which is the Federal Facility Restoration and Reuse Office. Recently, we went through a big reorg within EPA, so now I'm part of the cleanup implementation branch within OSEM.

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Um, so very excited to be working with that team. Some of my other background, I have a master's in environmental studies from Indiana University, where I focus on environmental science, law, and policy, as well as natural resource conservation. And some of my previous work experience was working with the City of Bloomington, Indiana, where I was actually a community event specialist. So I did a lot of community involvement there.

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I was a crew lead for Earth Corps doing environmental restoration work in the Pacific Northwest, and then also worked for the city of Bellevue, Washington, where I was a supervisor for a kids environmental training program. So before we start, I'll hand over to Nadia for her to introduce herself.

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Thanks, Haley. Thanks, Brian. Hi, everybody. My name is Nadia Rose. I am the Community Involvement Program Lead in the Office of Superfund and Emergency Management at EPA headquarters. I've spent most of my career in Superfund enforcement and came over to community involvement.

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Um, more recently, but happy to be here. Um, most of my experience is at private sites, but I'm here to kind of talk about a few of those things that are true, no matter what… where the site is. So I'll be leading on Brian and Haley here to talk about their federal facility experience, but here to.

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Perfect. So today we will be talking about community involvement at federal facilities. This course will go over community involvement requirements and activities at Federal Facility Superfund sites listed on the NPL, which is the national priorities list. Obviously, being part of the federal government and the alphabet soup of acronyms, I will try to.

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Um, explain whenever I use an acronym, um, but if there is something that I forget to say, please feel free to write it in the chat, and we will try and explain what that is, because there are so many acronyms. I definitely understand.

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Um, so yeah, talking about this in accordance with CERCLA, which is the Comprehensive Environmental Response Compensation, and Liability Act. So we'll be talking about the NCP and CERCLA throughout this presentation.

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Well, a brief overview. First, we'll be talking about the lead agency role at Federal Facilities and how that looks a little bit different than private federal… I mean, than private super fund sites. We'll then be talking about levels of community involvement, NPL listing actions, removal actions.

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socioeconomic considerations within community involvement, remedial actions, as well as CI within post-run actions.

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All right. Next slide, please. All right, perfect. So I'm going to be starting us off with the lead agency role within community involvement. Next slide, please.

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Perfect. Thank you.

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Hey, Haley, I'm sorry to interrupt it. Did you want me to release a poll about people's background?

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Oh yeah, that would be great, let's start with that first.

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All right. Did it pop up?

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Yes.

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Okay.

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Oh, absolutely. All right, so we're gonna give it about another 10 seconds. I want to thank everyone for participating. Right now, it looks like what's trending is zero to three years, 42% of the population.

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As far as experience with community involvement. After zero to three years, three to five years, 5 to 10, and more to 15. So it looks like 10 to 15 years is our lowest population.

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was 0 to 3 years being in the lead, and then the additional question is.

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Who do you work for right now? What is trending is a third of the folks in the room are state and local government, followed by consultants and engineering firms.

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with EPA trailing. and other fellow agencies… and a very minute population for DoD. Doe, academia. I'll be closing this poll in 5 seconds, 5.

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4, 3… 21. Thank you all for participating.

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So you… so yeah, 0 to 3 years, 44 44% of our population is what is trending, followed by… 3 to 5 years, 17% more than 15 years, 16%, and as far as participants in the room, still state in government, 34%, consulting engineering firms, 29%, EPA, 20%.

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I'll turn a note back over to you, Haley.

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Okay, perfect. Thank you so much. It's super helpful for us to see what kind of experience we have in the room, and thank you all for being here.

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Awesome. So I'm going to get started with the lead agency definition. So the NCP, which again is the National Oil and Hazardous Substances Pollution Contingency Plan states the cases where a federal agency that's not the EPA will serve as the lead agency.

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So the lead agency is the agency that's going to provide things such as the OSCs, which are the on-scene coordinators, the RPMs, which are the remedial project managers, and they are the ones that plan and implement response actions under the NCP.

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In the cases of a release of a hazardous substance, pollutant, or contaminant where the release is on or where the source of the release is from any facility under the jurisdiction, custody, or control of the DOW, DOE.

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Then DOE or the DOW will be the lead agency for that Superfund cleanup site.

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In the case of a release on, or the source of, or the release is from a facility under the jurisdiction, custody, or control of a federal agency other than the EPA, the Coast Guard, DOW, or DOE, then that agency will be the lead agency for medial actions and removal actions other than emergencies.

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All right, next slide, please. Cool, so the role of federal agencies within this process. So Executive Order 12580 delegated presidential authorities under CERCLA to the heads of different executive branch agencies under certain circumstances.

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Um, within these powers, these agencies are given the responsibility to provide opportunities for public participation within the cleanup process.

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This means that those federal agencies are the lead agency for these CERCLA actions and community involvement activities at federal facilities.

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The foundation of effective community involvement at NPL sites generally starts with a commitment to the principle that the public should be meaningfully involved within the decision-making process.

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EPA should work with that federal agency to ensure that the community involvement requirements in any federal facility agreement, which is the FFA, so again, another abbreviation will probably reference multiple times within this, are fulfilled, including the federal facilities obligations to.

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Fulfill the community involvement activities required by CERCLA or addressed in the NCP, as well as involve the community throughout the cleanup process within resource constraints.

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So meaningful community involvement requires careful coordination from all of the different agencies involved. This requires a commitment to a process that seeks and facilitates public input on EPA actions by providing timely and culturally appropriate information, access for people with disabilities.

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And language access for persons with limited English proficiency, considering issues of access raised by location, transportation, as well as other factors affecting participation. And by making available technical assistance to build community-based capacity for participating.

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So next slide, please.

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Cool, so community involvement in federal facility documents. So once that site is listed on the NPL, which is again the national priorities list, the Superfund process and community involvement activities apply equally at federal facility sites as they would for private sites within Circum. For federal facilities on the NPL, CERCLA requires an interagency agreement, an IAG.

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or a federal facilities agreement, which is an FFA. The FFA usually includes community involvement activities and the EPA remedial Project Manager, the RPM, as advised by the Community Involvement Coordinator if there is one on the site, a CAC, should ensure that community involvement is adequately addressed throughout the whole process.

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The site management plan is a component of the FFA and identifies necessary documents, processes, and milestones. The best way to ensure that community involvement is addressed adequately within this process is to ensure that federal facility prepares a community involvement plan or a similar document.

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And a CIP is a living document. So this document exists for the life of the cleanup process, and for some of these federal facility sites, um, they're so large that these processes take a very, very long time. So it's important to continually be going back to that CIP and making sure that it's still.

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really reflecting the community that's there. Um, we recommend doing this every 2 or 3 years, just because communities are rapidly changing sometimes around these sites.

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So compliance with Superfund community involvement objectives is tempered by budget constraints and fiscal uncertainties. Obviously, we're seeing that all around the federal government right now. And these 2 facets of government impact programs nationwide. The challenge is to make sure that the community.

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to assure the community that that site cleanup continues to be efficient and effective by planning for budget contingencies internally within the site team and externally within the community.

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If this site has been on the NPL for some time, CI activities and requirements may vary depending on what phase of the Superfund process that the site is in at that time. While required CI activities may be sufficient to meet the needs of the affected community, the site team should.

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be continually assessing the situation to make sure that additional activities are not needed to fully engage the community, and if they are, they're responsible for trying to figure out what those would be.

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All right, next slide, please. Cool, so at federal facility sites in the NPL, the EPA should. So CERCLA and NCB provisions on early and meaningful community involvement apply equally to federal sites as they do to the private sites, as previously mentioned. However, because other federal agencies often have the lead cleanup authority at these sites.

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They also have the lead responsibility for making sure that the community involvement process is followed as well.

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Accordingly, EPA's primary role at federal facility sites on the NPL tends to be providing oversight of the other federal agencies' community involvement activities to make sure that the circular requirements, as well as the NCP and EPA guidance, are being met.

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EPA site team also can act as an advisor, and in most successful instances, a partner in the development and implementation of the other agency's community involvement program for a site.

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This may involve acting as an advocate for meaningful community involvement at various points in the process. Epa site teams should work very closely with the Federal Facility Lead Agency so that they can be an effective so there can be effective approach to developing these while also considering potential resource constraints that either agency could be facing.

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All right, next slide, please. Well, we're going to mention briefly some levels of community involvement. Next slide.

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Cool, so I'm going to be talking briefly about history and trends in community involvement within the federal government. Um, so as a result of NEPA, which is the National Environmental Policy Act in 1969, community involvement in the US changed from the dad approach, the decide, announce, and defend.

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to more inclusive stakeholder involvement by integrating the community within that decision-making process.

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Um, NEPA requires that environmental impact studies be performed on any federal action that could potentially have an environmental impact, and informing the public and receiving public comments throughout that process.

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In 1980, Congress made public involvement in the decision-making process, an important part of the cleanup process, while the Superfund program was established by CERCLA. The role of community involvement in Superfund decision-making was strengthened by SARA, which is the Superfund Amendments and Reauthorization Act of 1986.

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The NCP describes EPA's process for conducting Superfund community involvement.

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Since 1986, the government began widely informing the public, seeking comments, and then factoring those public comments within decisions that are being made within the federal government.

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Many times, public comments resulted in government agencies changing their proposed solutions. In fact, there are examples of Superfund sites where EPA has altered a proposed remedy to clean up a site based on community input. And this can be really important as, you know, the community has been potentially at this.

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area for a lot of years, and they really know what that community needs. They might know of additional issues that someone coming in from a federal agency wouldn't know just by doing research on the site or the history of that land.

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So the EPA agency-wide public involvement Policy affirms this Superfund approach to community involvement. The policy reflects the change of perception within community involvement, not just within EPA, but also the country.

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Community involvement within EPA's programs has evolved because EPA has learned that community involvement improves the decision-making process and the agency's decisions. Not only are the agency's decisions better, but they're also a lot more likely to be accepted by the community if the community feels like they really were able to play an integral part within that decision-making process.

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Next slide, please. Awesome. So this is a chart here, so we'll talk about this. So this table just picks different stages in the stakeholder involvement spectrum. It is up to the site team to decide what the goal or outcome of the community involvement effort will be, and to communicate that both internally and externally.

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throughout the community. It is a legal requirement to inform the public and respond to public comments at different steps in the Superfund cleanup pipeline. So at a minimum, you will be performing activities noted in the first two rows of the table or levels of the spectrum.

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Keep in mind, the level of community involvement will also be definitely site-specific, and this will look different no matter where the site is and who the community is, and, you know, some communities really want to be involved in the process, and others take a more hands-off approach. Either way, this should be taken early and often throughout the cleanup process.

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At some sites with low public interest, it might not even be necessary to move past the inform level, and that site team can proceed with the decision as long as the opportunity for public input was provided.

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However, when there is a significant amount of public interest, it will be necessary to involve and collaborate within communities to reach decisions.

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It is important to recognize that the number of activities, expense, and time devoted to the public participation do not mean the same thing as potential for actual public influence on the decision.

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Within community involvement, a great deal of time, effort, and resources can easily be expended on the wrong pursuits, in turn leading to negative results. This is particularly true when you follow a prescribed set of activities in a law or regulation without first understanding the role for the community.

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Um, within that Superfund decision-making process, and also just understanding the community and what the needs will be there.

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Awesome. Next slide, and I will be handing it over.

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All right. Thank you, Haley. So we're going to talk about community advisory boards, specifically restoration advisory boards and site-specific advisory boards which apply to these OFAs we're going to talk about.

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So if you've heard about a community advisory group or a private site, it's a very similar concept. Next slide, please.

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All right, so over to the left, we see a photo of DOE's Hanford Advisory Board taken in 2018.

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So some really key ingredients for advisory board success include things like good working relationships between the all the agencies that are part of the FFA. That's the.

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Other federal agency, in this case it would be DOE, the EPA, and also with the state.

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But the most important part about these advisory boards is that they're a way for the community to really participate and cite decisions. They're also a great opportunity to take feedback from the community and then carry that into decisions that are made.

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Um, by all the agencies involved in the FFA.

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Um, you can also use them to keep the community informed about the Board's activities, about the site activities. So, you know, think of these as really a great two-way communication tool. There are a lot of requirements in the NCP.

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for community involvement. But the… I think of these boards as going above and beyond. And we're going to give a few examples of that, of how you can go above and beyond today.

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So, really quickly, for the Department of War, you have Restoration Advisory boards, and then for DOE, you have site-specific advisory boards. But these are very similar and in some ways different than others, but they consist of the lead agency that's going to be.

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The DOE, Navy, Air Force, Army, and the regulators at CPA, the state, and then you have stakeholder groups and citizens as well involved in these. Next slide, please.

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Alright, so over to the left, we're going to talk about Restoration Advisory boards first, and you can see over to the left all the components that are part of Restoration advisory Boards. You have the installation itself.

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You have community members, you have EPA, you have local groups, you have local government and state government and all those components together make up the RAB.

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So there was a 1990, we advanced, let's see. Sorry about that.

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Um, so there was a 1994 joint guidance, uh, and since that time, there's been about 300 RABs established. And these basically consist of a stakeholder group that meets on a regular basis to discuss clean activities, cleanup activities is really.

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One of the best forums for information exchange and to establish community understanding for a cleanup site. Next slide, please.

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All right. So now we're talking about site-specific advisory boards. These are specific to DOE. And these are a little bit different in that I think of them as much more formal because they're governed by the Federal Advisory Committee Act.

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That means they're open to the public, they're announced in a Federal Register. There's actually a formal response to any recommendations that come out of.

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these boards were also not… these are boards where people… they vote. Members vote, and we are not voting members.

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So they vote, they make recommendations. And then the lead federal agency makes a formal response to those recommendations. There's currently 8 boards. You can see them listed over to the right. There's the Hanford Advisory Board, Paducah Citizens Advisory Board, the Portsmouth Site Specific Advisory Board.

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And several others that we've got listed here. These are… just think of these as… they're very similar, but this is… they're much more formally governed.

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Next slide, please.

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Alright, so EPA really, you know, when you're part of one of these, think of yourself as participating as a liaison, because that's really what you are. You're there to listen, to provide the EPA perspective, all the agencies that are part of the federal facilities agreement.

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should be a part of these boards, and that's again, that's going to be the DOE, the DOW agency, Navy, Army, Air Force.

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EPA and the state should all participate in these together. These boards don't replace all the existing community involvement requirements that are part of the NCP. Think of them as a way to go above and beyond.

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And to really meet the intent of community involvement and community engagement.

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Next slide, please. So this… this image, this picture depicts the circle of pipeline. We're going to drop a link to this website. It's an internal EPA website that's plugged into SIMS. Really kind of a neat website. We're going to drop a link to it in the chat.

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So you can access it. But in each stage of the circle pipeline in this image, there's more information link that you can click on. And for that phase of the circle pipeline, it will list all the opportunities that are there for community.

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involvement. We'll also drop a link in the chat to the community involvement Handbook, which has.

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basically a lot of additional information. We're going to talk about that through… throughout the rest of this presentation, but those are there for you to access.

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And next slide, please. And this brings us to our case study. So, we've talked a little bit about the requirements for community involvement. A lot of those are outlined in the NCP. They're things that we absolutely want to do, have to do. They are regulatory requirements.

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So I think of public meetings as a way to really go above and beyond and meet the intent of community involvement. So we're going to talk a little bit about an open house that took place at NES Pensacola.

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Um, we were involved with this and the Navy was the lead agency. So it was FDP, EPA, and the Navy that took took that basically took part in this next slide, please.

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So, a little bit of background about NAS Pensacola. It is on the MPL. The listing is about 5,900 acres. It's located 5 miles west of Pensacola. Since the 1800s, the military has been there in some sort of a capacity.

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It's currently Housing Training Support Facilities for the Navy's aircraft. It's the home of the Blue Angels, and it was listed in 1989. Next slide, please.

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So, like a lot of, uh, a lot of military bases, there have been plane crashes, other things there that have involved the use of AFFF. And so there are some PFAS issues.

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at Pensacola, if you were to look in Sims right now, you'd see 25 operable units.

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Three of those are PFAS operable units, and there is a plume that extends off base to the west, where there are some private residences located.

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Next slide. So, because of the PFAS issue, the Navy has done some sampling. They sampled in 2019, and when the new MCLs or PFAS were promulgated, they plan to do some additional sampling. That is a really big effort. There's a lot of.

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A lot of people that live off-base to the west, and so one of the most effective ways to communicate with the public is through an open house. And that's what the Navy planned to do for this sampling effort. So the open house was located at a local church.

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Um, there were a lot of different attendees. The Navy had to risk communication team there.

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That was about 16 members that specialized in risk communication.

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There were at least two Navy RPMs there, a number of other staff from the Navy facilities, engineering, systems command in the Southeast.

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They had probably about 8 people total. There were 3 EPA, uh, 3 FD RPMs. I was the only EPA RPM. We had numerous public attendees. There were numerous media outlets there. There were, I think, three TV stations.

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several other radio stations, and there were 3 over the course of 2 days, we had 3 sessions where the public could come, learn about this, sign up to have additional sampling, and talk to us if they wanted. Next slide, please.

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So I just wanted to show some some pictures to show how this worked.

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So over to the right, you can see the interior of the church and you can see how we have this set up. There's a poster, a number of posters throughout the room. And as you walk in, you're greeted with a greeting poster. The next poster you're walked over to.

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explains to you why the Navy's doing the sampling, talks about.

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The Department of Navy's policy. And then there's a number of other posters where they talk about sampling results and a lot of different things. I want to walk you through some of those posters and kind of just explain that you have this open house functioned. So over to the left.

00:29:11.000 --> 00:29:17.000
you see an example of a poster setup. This was our health effects poster. And so we had a number of.

00:29:17.000 --> 00:29:35.000
handouts that the public could take with them and really learn about PFAS, what it is, why we're concerned about it, and each one of these posters, someone would escort them through, make sure any questions they had were answered. That was the whole point of this.

00:29:35.000 --> 00:29:44.000
Open House was to give them all the information they needed, make sure every one of their questions got answered. So it was a really well organized.

00:29:44.000 --> 00:29:50.000
open house. Next slide, please.

00:29:50.000 --> 00:29:53.000
All right, so this is one of the first posters.

00:29:53.000 --> 00:30:09.000
that they saw when they came in the door. And, you know, right up front, I just want to point out a couple things. You know, the intent of this poster is to explain why the Navy is doing additional sampling, why they're going to do drinking water hookups. And so one of the.

00:30:09.000 --> 00:30:24.000
things we were upfront about was there's an EPA MCL that's been promulgated. That's the reason we're taking this action. The Navy has what they called, at the time, a DOD, it's DOW Interim Action Level.

00:30:24.000 --> 00:30:40.000
And so they're kind of triaging hookups, they're doing the most important ones first, and that's what this poster explains. And so it, you know, it's really intended to introduce them to the whole purpose of why we're doing this. I'll also say that.

00:30:40.000 --> 00:30:58.000
the Navy, EPA, and FDEP all worked together on these posters. The Navy drafted them, and then we provided comments, redesign suggestions where appropriate. And so these posters really represent, you know, compromises between our agency.

00:30:58.000 --> 00:31:04.000
agencies to give the community the most and the best accurate information we could.

00:31:04.000 --> 00:31:10.000
Next slide, please.

00:31:10.000 --> 00:31:27.000
All right, so this is one of the sampling results posters. All this relays to the public is the 2019 sampling area. You'll recall the I said the Navy took samples in 2019, did some drinking waters, water hookups. It shows them the locations.

00:31:27.000 --> 00:31:40.000
in which that took place, highlighted in red, kind of pink. And then you can see that expanded 2025 sampling area. This is the area.

00:31:40.000 --> 00:31:55.000
that the Navy's gonna sample. And there are a lot of people that lived in this area, and that's why this open house was so necessary. It was it was advertised in newspapers on radio, and the intent was to get as many people in.

00:31:55.000 --> 00:32:03.000
As we could, uh, sign them up, have them sign up for sampling if they had private wells, and then… and then really do that sampling.

00:32:03.000 --> 00:32:09.000
So this just relays previous sampling results in areas that we're going to sample.

00:32:09.000 --> 00:32:19.000
Next slide, please. So this… this is the poster that I was probably the most involved in. I was actually.

00:32:19.000 --> 00:32:34.000
stationed at this poster. And I'll just say there were a number of people who came to this meeting and really wanted to talk to EPA and FDEP. That was, you know, they had a lot of questions for us. You know, they wanted to hear what the Navy said.

00:32:34.000 --> 00:32:45.000
Um, you know, they wanted to talk to the regulatory agencies as well. So this this poster we designed kind of with the intent to explain to folks.

00:32:45.000 --> 00:33:01.000
you know, where the Navy is in the cleanup process. You know, and we've… we've kind of made this into a lot of plain language. Rather than show the entire circle of pipeline, which we had on one of the earlier slides, we've kind of kept this in plain language terms.

00:33:01.000 --> 00:33:19.000
So we explain here in this poster that, look, the Navy is in the process of investigating PFAS contamination at NAS Pensacola. After that, they're going to determine cleanup options. They're going to plan and implement those options, and we're going to provide regulatory oversight while they.

00:33:19.000 --> 00:33:36.000
do that. At any stage in that process under CERCLA, they can take an interim action, and that's really what this is. That's, you know, part of this sampling and the drinking water hookups are all part of an interim action that the Navy's doing, and so that's the intent of this poster.

00:33:36.000 --> 00:33:45.000
is to kind of explain the CERCLA process to them. Next slide, please.

00:33:45.000 --> 00:34:02.000
We would then escort them to the next poster, and so this poster explains to them what happens next, uh, you know, if they have if the results are below the action levels, nothing else happens. If they're above they'll be hooked up to what's called a.

00:34:02.000 --> 00:34:20.000
poet system. It's a point-of-entry treatment system. It's just a filtration system that the Navy installs. They test it periodically, but this explains all this to them. There's also QR codes that they can scan, go to the Navy's website, which has even more detail.

00:34:20.000 --> 00:34:27.000
that explains this whole process to them. Next slide, please.

00:34:27.000 --> 00:34:42.000
And lastly, this is the poster where we could walk them over, and they could sign up to have sampling done if it hadn't been done already, and make an appointment. And there's also a phone number that the Navy had set up.

00:34:42.000 --> 00:34:46.000
There was a person at this poster who would take their information down.

00:34:46.000 --> 00:34:57.000
And basically set them up for an appointment. And let's go to the next slide.

00:34:57.000 --> 00:35:13.000
There we go. So I just want to, you know, just emphasize that all of what we're talking about here in this public meeting really meets our administrators priorities. You know, and I think mostly a pillar.

00:35:13.000 --> 00:35:29.000
1 and pillar three, but, uh, you know, clean air, land, water for every American. That's part of the intent of this. And then also when we come to Pillar three, you know, really the cross agency partnership, I think is a big part of these open houses. We, you know, the Navy spent a lot of time.

00:35:29.000 --> 00:35:45.000
planning this putting resources in it and really wanted our participation. It was important to them, and it was important to us. The the main objective here is to get the public the information they need.

00:35:45.000 --> 00:35:53.000
And, um, and get them really good information. Next slide, please.

00:35:53.000 --> 00:36:09.000
And we're just gonna… we're gonna… we're not gonna watch this, but there… I mentioned there were 3 TV stations. This is probably one of the better media coverage pieces I saw on this. And so we'll drop this in the chat for you to watch if you're interested.

00:36:09.000 --> 00:36:19.000
Uh, after the class, you can see it, but it's a really good example, I think, of, you know, the typical type of coverage that one of these open houses sees. This was really.

00:36:19.000 --> 00:36:30.000
well advertised, uh, and it received a lot of attention, but it's… it's probably also, in my opinion, an example of an open house that went really, really well.

00:36:30.000 --> 00:36:34.000
And so we were able to reach a lot of people with this open house.

00:36:34.000 --> 00:36:44.000
And I think we're moving on to removal action, community involvement next or no, no, it's actually. Yeah. So we're turning it back over.

00:36:44.000 --> 00:36:46.000
Haley or Nanya, I believe.

00:36:46.000 --> 00:37:02.000
That's me, Brian. Thank you. What a great case study. Thank you for sharing that. So I'm going to talk to you a little bit about initial NPL listing and community involvement.

00:37:02.000 --> 00:37:10.000
So site assessment often begins with federal facilities when the facility has been listed on the federal agency hazardous waste compliance docket.

00:37:10.000 --> 00:37:20.000
Section 120 of CERCLA requires EPA to establish this docket of federal facilities, which are managing or have managed hazardous waste or have had a release of hazardous waste.

00:37:20.000 --> 00:37:31.000
So the docket identifies all federal facilities that must be evaluated to determine whether they pose a risk to human health and the environment, and it makes this information available to the public.

00:37:31.000 --> 00:37:46.000
EPA, state, and tribal partners, or the appropriate federal agency, then conducts a preliminary assessment that you'll see on this pipeline here, or PA. If warranted, a site inspection, SI or other more in-depth assessment is conducted to determine whether.

00:37:46.000 --> 00:38:03.000
The site warrants short or long-term cleanup attention. At the conclusion of the assessment, a hazard ranking system model is applied to derive a preliminary site score. Community involvement does not start at the PA and SI process.

00:38:03.000 --> 00:38:09.000
Because many sites assess for inclusion on the NPL fall into other categories for cleanup.

00:38:09.000 --> 00:38:20.000
However, it's always a good opportunity to get to know your community. It is an opportunity to develop trust and credibility in the agency's ability to deal fairly and effectively with site issues.

00:38:20.000 --> 00:38:35.000
Once the PA is complete, the report is made publicly available and the federal agency determines whether to also require a site investigation. From there, EPA will decide whether the site should be proposed for the NPL or the National Priority List.

00:38:35.000 --> 00:38:47.000
An initial EPA proposal to include a federal site on the NPL is reviewed by the Office of Management and Budget, or OMB, which provides an opportunity for the responsible federal agency to provide input.

00:38:47.000 --> 00:38:53.000
Even at this stage, it is possible that the federal government may decide against addressing the contamination with an MPL listing.

00:38:53.000 --> 00:39:01.000
If EPA proposes a site for the NPL, the agency follows the same listing process used for any site proposed for the MPL.

00:39:01.000 --> 00:39:07.000
And just want to highlight this green box on the slide here, as although community involvement is not required at.

00:39:07.000 --> 00:39:18.000
The preliminary assessment or site inspection stage, it does provide the opportunity to get to know the community. It's never too early to do that.

00:39:18.000 --> 00:39:30.000
Adding a site to the MPL requires EPA to follow established rulemaking procedures. Epa must first publish a notice in the Federal Register proposing to add a site to the MPL and requesting public comments.

00:39:30.000 --> 00:39:35.000
EPA must consider and address all comments and make a final determination about whether to list the site.

00:39:35.000 --> 00:39:41.000
If the agency decides to list the site, it must publish a final rule in the Federal Register.

00:39:41.000 --> 00:39:52.000
Typically, EPA adds new sites to the NPL twice each calendar year in the spring or the fall, but they can't happen outside of that timeframe as well.

00:39:52.000 --> 00:40:09.000
As an important first step, the site team should assess the situation to determine an appropriate mix of community involvement activities and plan an approach that addresses the needs of the community. In most cases, the site team should expect increased community concern or interest when a site is proposed for the MPL.

00:40:09.000 --> 00:40:21.000
While informing the public through a Federal Register notice is required, conducting additional activities to inform the community about the NPL listing process and how they can submit comments is also appropriate.

00:40:21.000 --> 00:40:33.000
Listing a site on the NPL also may attract media attention, so preparing a press release or using social media may be useful. The team should consider developing talking points for media interviews.

00:40:33.000 --> 00:40:48.000
And as I mentioned, you know, there are a lot… There's a few required things, but there's a lot more creative steps that site teams can take, really depending on the needs and the interests of that community.

00:40:48.000 --> 00:41:00.000
All right. And I think that's back over to Brian.

00:41:00.000 --> 00:41:05.000
All right. Sorry for the delay coming back off mute.

00:41:05.000 --> 00:41:09.000
So now we're going to talk about removal action community involvement.

00:41:09.000 --> 00:41:33.000
Next slide, please. And so there are really 3 types of removal actions, and uh… The 1st is emergency response. I typically think of an emergency response as something like maybe a tanker truck roller rollover, or perhaps a chemical plant fire. It's something that's really, really urgent.

00:41:33.000 --> 00:41:39.000
Uh, action is typically required within hours. There's not a lot of planning time.

00:41:39.000 --> 00:41:49.000
For removal actions, you typically have an action memo prepared for an emergency response. There isn't actually time to prepare an action memo, so it's done after the fact.

00:41:49.000 --> 00:42:03.000
Um, we're typically gonna be looking at an on-scene coordinator for an emergency response. It's pretty typical. Also, that happens a lot for time-critical removal actions, which is our second type of removal action.

00:42:03.000 --> 00:42:13.000
Time-critical removal action is one where action is required within six months, and so there's a… there's as much as a six-month planning period, is how I think about it.

00:42:13.000 --> 00:42:28.000
Typically, by this time, there's an action memo that's written. That action memo really documents the justification under the NCP for the removal action. It also documents the funding for the for the removal action.

00:42:28.000 --> 00:42:42.000
If you haven't dealt with an action memo before, you can kind of think of these as almost like a condensed proposed plan, but they don't go out for public comment and they're really, it really is a memo.

00:42:42.000 --> 00:42:58.000
The last type of removal action is a non-type critical removal action. This means there's a planning period of more than 6 months, and so it's a… these are typically bigger. They have less urgency, and so you have more time to plan.

00:42:58.000 --> 00:43:07.000
They also have an additional requirement, which is what we call an engineering evaluation cost analysis, and ECA for short is how you'll.

00:43:07.000 --> 00:43:25.000
how you'll hear people refer to these. And these have to be in place. They go out for public comment, but they're finalized before the action memo is signed. And so you'll see the little animation that just came came up, but the point here is that each one of these.

00:43:25.000 --> 00:43:34.000
requires different levels of community involvement. So let's let's move on to our next slide.

00:43:34.000 --> 00:43:47.000
So, when I think about removal actions, there are really three things that we always have to do under the NCP. We have to the agency has to designate a spokesperson.

00:43:47.000 --> 00:43:58.000
That might be an on-scene coordinator, it might be an RPM if you're talking about typically a non-time crude removal action might also be a CIC. I'm a big proponent of.

00:43:58.000 --> 00:44:13.000
Using CICs, I work on both federal facilities and private sites, and I always have a CIC assigned in my sites. And if you're really busy, they make great spokespeople, spokesperson for the sites. They're great at interacting.

00:44:13.000 --> 00:44:20.000
community, so I really encourage you to use a CIC if you have access to one.

00:44:20.000 --> 00:44:31.000
You also establish an administrative record, and then you inform the community about the availability of that administrative record. That's typically done through a newspaper notification.

00:44:31.000 --> 00:44:36.000
So, all removal actions require some level of community engagement.

00:44:36.000 --> 00:44:52.000
at a bare minimum, you're gonna do that admin record, you're gonna notify the community about it, uh, you're going to have a spokesperson. But really, community engagement should be driven by public interest. That's the thing I want to emphasize on this slide that really.

00:44:52.000 --> 00:45:04.000
uh, you know, these are not… I don't think of removal actions or remedial actions as cookie-cutter. Uh, you really need to pay attention to your community, and you really need to meet their needs.

00:45:04.000 --> 00:45:12.000
Next slide, please.

00:45:12.000 --> 00:45:18.000
There we go. It's a little slow, I think.

00:45:18.000 --> 00:45:34.000
There we go. All right. So there's a couple of other thresholds to think about when you want to when you meet the requirements for removal actions. So if you are on site more than 120 days, there's some extra things you have to do.

00:45:34.000 --> 00:45:48.000
or even the NCP. You have to do community interviews. You're also going to do a community involvement plan and you're going to establish an information repository. Typically, that's established somewhere like a local library.

00:45:48.000 --> 00:45:59.000
Um, if we're talking about a non-time critical removal action, where you've got that extended planning that planning period of at least 6 months.

00:45:59.000 --> 00:46:14.000
or more than 6 months, rather, you're going to publish a notice of availability of that ECA. Again, that's the engineering evaluation cost analysis that you're doing. I really think of that ECA, it's very similar to a proposed plan.

00:46:14.000 --> 00:46:21.000
It also goes out for public comment period at least 30 days, which that that can be extended.

00:46:21.000 --> 00:46:33.000
And then you're going to have a responsiveness summary to any public comments you receive on the ECA. Those are going to become a part of your administrative record. Again, you only do the ECA for a non-time critical.

00:46:33.000 --> 00:46:56.000
removal action. That's where you've got more than 6 months to plan your removal action. So you've got a bit more time and you're going to need it to do that ECA. It is a little bit of work. And again, I… I always think of those like a proposed plan, very similar. Next slide, please.

00:46:56.000 --> 00:47:09.000
Alright, so this… this table comes from the Superfund Community Involvement Handbook, which there'll be a link in the chat where you can access that. Highly recommend you download a copy.

00:47:09.000 --> 00:47:25.000
Uh, table looks kind of noisy at first, but really, there's a couple key things that you want to think about and remember here. These first three things that we talked about, designating an agency spokesperson, establishing administrative record.

00:47:25.000 --> 00:47:38.000
And also notifying the public about the availability of that record. Those are things that you're going to do for all types of removal actions. Again, there's four types of removal actions. You've got an emergency response.

00:47:38.000 --> 00:47:54.000
Um, you've got time critical and those can be either where you're on site less than 120 days or more than 120 days. And then you have the non-time critical removal action. That's where you have that extended planning period of more than six months.

00:47:54.000 --> 00:48:05.000
Regardless of which of those you're doing, you're always going to do those three core community involvement required things for all removal actions.

00:48:05.000 --> 00:48:18.000
So when we move over to the non-time critical, there are a couple of additional things that we have to do that we should think about. We're going to do the ECA.

00:48:18.000 --> 00:48:24.000
There's going to be a public comment period associated with that ECA. And then the other thing I want to emphasize.

00:48:24.000 --> 00:48:41.000
is for a non-time critical removal action, the important thing here is how long are you going to be on site? If you're on site more than 120 days, you're going to do a community involvement plan and you're going to get to do some community interviews. Those are important aspects when you're doing.

00:48:41.000 --> 00:48:56.000
a community involvement plan. You need to go talk to the community. And that's probably one of the most enjoyable things, uh, you know, that you get to do at these sites, in my opinion. But it's also a good idea, in my opinion, to involve your CIC.

00:48:56.000 --> 00:49:11.000
If for an other federal agency, they're going to have, uh, they're going to have PIOs and things like that. They're going to be able to do some of this themselves. But you know, there are a lot of really important considerations for removal actions.

00:49:11.000 --> 00:49:16.000
Let's look at our next slide.

00:49:16.000 --> 00:49:30.000
So now we're going to do a quiz question. I believe you're going to get a poll. And so just I'm going to read this and just answer in the poll and Jr. If you can, tell us how the poll is looking. I'm going to read this is a true or false question?

00:49:30.000 --> 00:49:45.000
A removal is time critical when a site evaluation has been conducted and it's determined that there is not an immediate emergency, but on-site removal activity must begin within six months.

00:49:45.000 --> 00:49:54.000
Is that true or false?

00:49:54.000 --> 00:49:55.000
The poll is released. Uh, right.

00:49:55.000 --> 00:50:00.000
All right. Poll should be up for you. All right. Tell us what you think. Is this true or false?

00:50:00.000 --> 00:50:11.000
Right now, what's trending is 70 to 80% are saying true, 20% are saying false. I'll close the poll.

00:50:11.000 --> 00:50:19.000
and 5, 4… 3, 2… One.

00:50:19.000 --> 00:50:20.000
ending the poll.

00:50:20.000 --> 00:50:34.000
Fantastic. So that question is true. That is true that, you know, there's not an immediate emergency, but you do need to start within 6 months. That means it's time critical, okay? So had it been more than 6 months, it would be a non-time critical.

00:50:34.000 --> 00:50:47.000
removal action. So let's look at our next question. Next slide. So same thing, you're going to get a poll, and I'm just going to read this out loud and just answer in the poll.

00:50:47.000 --> 00:50:48.000
Oh.

00:50:48.000 --> 00:50:53.000
What two community involvement activities are required when a removal action on site takes less than.

00:50:53.000 --> 00:51:01.000
120 days. Do you a complete a community involvement plan?

00:51:01.000 --> 00:51:09.000
B, do you establish an administrative record? Do you see notify the public about the availability of the administrative record?

00:51:09.000 --> 00:51:24.000
Do you de-establish an information repository? Do you conduct community interviews? Remember, the key here is that you're on site for less than 120 days, and there was that threshold triggers something special.

00:51:24.000 --> 00:51:28.000
And we talked about that. So, you know, the answer.

00:51:28.000 --> 00:51:31.000
How's it? How's it looking so far? I don't want to give it away. How's it looking? Jam?

00:51:31.000 --> 00:51:40.000
Sure. Sure. Right now, it looks like… Um, definitely over 70% are saying C.

00:51:40.000 --> 00:51:43.000
As well as B.

00:51:43.000 --> 00:51:56.000
That's right, yeah, that's right. So, you know, the important thing to remember here is that when you're on-site more than 120 days, that triggers the community involvement Plan.

00:51:56.000 --> 00:52:03.000
the community interviews and the information repository that shows up in the local library, for example.

00:52:03.000 --> 00:52:16.000
Um, for all the removal actions, especially, you know, those that are less than 120 days, you know, you're doing those 3 core things, which is the you got an agency spokesperson. Typically.

00:52:16.000 --> 00:52:31.000
an on-scene coordinator, an RPM, CIC sometimes. But you're also going to do the administrative record. You always have to do that, and you're going to notify the public about that, uh, that AR's availability, typically in a newspaper notification.

00:52:31.000 --> 00:52:41.000
So good job, good job. Next slide. All right, same drill this time. I'm going to read this out loud.

00:52:41.000 --> 00:52:49.000
Which activities are required when a removal action on-site activity takes more than 120 days?

00:52:49.000 --> 00:52:55.000
Do you A complete the communications plan? Do you be establish an administrative record?

00:52:55.000 --> 00:53:04.000
Do you see notify the public about the availability of the administrative record? Do you DE establish an information repository?

00:53:04.000 --> 00:53:11.000
Do you… do you conduct community interviews? There's more than one right answer here, obviously, but.

00:53:11.000 --> 00:53:19.000
Which… which of these do you guys think we need to do?

00:53:19.000 --> 00:53:24.000
All right. What is trending right now is a.

00:53:24.000 --> 00:53:32.000
An E, that is what is trending right now. No one is definitely selecting C.

00:53:32.000 --> 00:53:37.000
Okay, so, you know, a couple. Couple key things.

00:53:37.000 --> 00:53:53.000
you know, A, let's talk about AA for a second. We didn't… we didn't… we talked about a community involvement plan, but not a communications plan. Yeah, it's kind of a… it's kind of a trick question. Sorry, I apologize for that, but it's not A, because there is no communications plan.

00:53:53.000 --> 00:54:08.000
There might be informally, you could certainly sit down with your your section chief or your Ofa and talk a little bit about that. But there's no there's no NCP or circle of meaning for that. So so really the thing that would be.

00:54:08.000 --> 00:54:13.000
written for more than 120 days on site would be a community involvement plan.

00:54:13.000 --> 00:54:19.000
You do establish an administrative records, so B would be one of the answers. You always have to do that.

00:54:19.000 --> 00:54:26.000
You're always going to notify the public about the availability of the administrative records. So, so far, the answers are B and C.

00:54:26.000 --> 00:54:41.000
Um, because you're on site for more than 120 days, you're also going to establish an information repository, probably in a local library. That's a good place to do it. But because you're on site more than 120 days, that triggers that requirement.

00:54:41.000 --> 00:54:53.000
So far, answers B, C, and D. And then the last one, E, we are going to do community interviews because we're going to prepare, we're going to use the information we gain from the community when we interview them.

00:54:53.000 --> 00:55:03.000
to prepare that community involvement plan. So the answer here is B, C, D, and E. A would be the only one that that you wouldn't do. And again, ACE.

00:55:03.000 --> 00:55:07.000
kind of a… it would be a community involvement plan that you would have to do.

00:55:07.000 --> 00:55:11.000
All right, next question. I believe this is our last.

00:55:11.000 --> 00:55:17.000
Quiz question. All right, same thing this time. I'm going to read this out loud. You'll get a poll.

00:55:17.000 --> 00:55:26.000
Which activities are required for a non-time-critical removal action with a planning period of more than 6 months?

00:55:26.000 --> 00:55:31.000
Do you A respond to public comments and a responsiveness summary?

00:55:31.000 --> 00:55:38.000
The UB establish an administrative record. Do you see hold a public meeting?

00:55:38.000 --> 00:55:46.000
Do you D hold a public comment period? Think about why you might be doing that. What might you need to hold the public comment period for?

00:55:46.000 --> 00:55:54.000
Do you E conduct community interviews?

00:55:54.000 --> 00:55:57.000
How's our poll looking, JR?

00:55:57.000 --> 00:56:18.000
Uh, it seems like everyone is… There's no clear, um, okay, I take it back, it looks like… D is trending at 70%, and the others are trending between 50 and 60%. I can close the poll in 5, 4.

00:56:18.000 --> 00:56:22.000
Okay.

00:56:22.000 --> 00:56:31.000
Three, two… one and yes, D is trending the most right now, followed by B.

00:56:31.000 --> 00:56:38.000
Okay, fantastic. So, think about this. This is a… this is a non-time critical removal action.

00:56:38.000 --> 00:56:49.000
there's something unique happening here that doesn't happen with the other type of removal actions, and that is the ECA, right? That ECA, the Engineering Evaluation Cost Analysis.

00:56:49.000 --> 00:57:04.000
Um, is… you're gonna… that's gonna be prepared by the other federal agency. If it was a fund lead, we would prepare it, but it goes out for public comments. And then you have a responsiveness summary that becomes a part of your administrative record. So.

00:57:04.000 --> 00:57:20.000
Um, you know, that immediately tells you that, um… you know, A and D are correct answers, because you've got that ECA. And then the other thing, B, we're always going to do an administrative record. We would do that for all types of removal actions.

00:57:20.000 --> 00:57:32.000
we're gonna do community interviews, because this is a non-time critical removal action. That means we've got an extended planning period. We're probably also going to be on site.

00:57:32.000 --> 00:57:47.000
For more than 120 days, even if we weren't, because it's non-time critical, we do still do the interviews, and we would do the community involvement plan. The one thing we're not required to do here is the public meeting. But again.

00:57:47.000 --> 00:57:53.000
If it were me, that's… that's the kind of thing that we want to talk about with our other federal agency.

00:57:53.000 --> 00:58:03.000
And, you know, evaluate on a case-by-case basis. They're the lead, they get to make the decision, but they're probably going to ask you about it. And you can provide some recommendations, but, you know.

00:58:03.000 --> 00:58:17.000
A public meeting is a great way to meet the intent of the NCP, the intent of community involvement, but it's a great example of where you're going above and beyond the NCP requirements.

00:58:17.000 --> 00:58:26.000
to do so. And I think that's our last… Quiz question. And so I'm going to turn it back over to one of our other presenters.

00:58:26.000 --> 00:58:36.000
Hi there. So I will take us through our next brief section on socioeconomic considerations within the community involvement process. Next slide, please.

00:58:36.000 --> 00:58:46.000
Cool. So, um, we're the basis of this section is coming from is from EPA Pillar 1 within the priority document, clean air, land, and water for every American.

00:58:46.000 --> 00:59:03.000
Um, so within this, every American should have access to clean air, land, and water. Um, so this includes taking steps to incorporate these considerations into the work, including assessing impacts to pollution burden, underserved and tribal communities, and regulatory development processes, and to consider these.

00:59:03.000 --> 00:59:18.000
Options to maximize benefits to these communities. I'm taking immediate and affirmative steps to improve early and more frequent engagement, um, will help with agency rulemakings, permitting, enforcing decisions, and policies.

00:59:18.000 --> 00:59:39.000
Next slide, please. So community involvement is about protection and engagement. So in order to make sure that we are involving the community in a way that is meaningful, it's really important to look at the members of the community and figure out how to best reach them. If you're not able to reach the community that you're working nearby.

00:59:39.000 --> 00:59:55.000
Um, the community involvement, you won't get the meaningful community input you need to really make the decisions. Um, some of these things that can be considered within this community involvement process could be the time, location of public meetings.

00:59:55.000 --> 01:00:12.000
Um, some communities might have more parents or more working folks that, um, you know, would make either night meetings or day meetings, um, a better option for people within that community. The language of outreach is really important to consider. If the area has a very low English-speaking population near the site.

01:00:12.000 --> 01:00:27.000
Doing all of the outreach in English might not be the most beneficial way to reach those communities, um, and now there's a lot of different resources for transcribing information and being able to reach those communities nearby, even if they're not primarily English-speaking.

01:00:27.000 --> 01:00:43.000
Um, it could be helpful to find trusted members within the community to loop into that process to have their public meetings, even if it's just for them to be there and welcome community members so that they can see someone in their own trusted community there that is also on board with this process.

01:00:43.000 --> 01:00:59.000
Another way is just how the outreach is done. A few years ago, I was really lucky to go and help instructive training in Anchorage, Alaska, and they were saying there that sometimes this communication is done by things like radio and.

01:00:59.000 --> 01:01:08.000
newspaper to some of these more remote areas that might not even have internet access, so radio sometimes is used in those more remote areas, which I thought was very interesting.

01:01:08.000 --> 01:01:33.000
Cool. Next slide, please. Cool. So here are some options to take to engage communities within this process. Reviewing community data from previous five-year reviews, especially from some of those really long-standing sites, to see, okay, five years ago, what kind of community input did we get during community interviews and things such as that? We'll talk more about five-year reviews later within this training.

01:01:33.000 --> 01:01:49.000
strategies to engage the neighborhoods that you might be missing, um, updating the community involvement plan, and again, I had mentioned earlier in this training that that is a living document that really should be reviewed and updated throughout the process, um, especially if the community has drastically changed.

01:01:49.000 --> 01:02:03.000
expanding understanding of community concerns through engagement, as well as making sure that all of the different federal agencies and local agencies are on board to help address community needs, um, for these site-specific issues.

01:02:03.000 --> 01:02:25.000
Cool. Next slide, please. Cool. Just another quick chart we'll go over. So how to take action using information to understand potential land and resource use, unique activities that could result in exposures. And this was another thing that came up in that training that I was doing in Alaska. You know, there's a very high population of tribal members in that area.

01:02:25.000 --> 01:02:41.000
And they had mentioned that, you know, there's an area that the general public is not allowed to go and fish and consume from that area, but they are allowed to do substantial fishing in that area because it is native land of theirs. And because of that.

01:02:41.000 --> 01:02:56.000
then you would have to look at things like the fish and other things that could be exposure pathways. Um, and then these can be included within that conceptual site model. So really knowing the community, knowing what they're using the land for, um, is really important to protect that community.

01:02:56.000 --> 01:03:07.000
ensure that relevant exposure scenarios are included within that risk assessment is very important. And then considering any other non-site-related factors that could influence risk and provide context.

01:03:07.000 --> 01:03:16.000
Okay, perfect. I am going to be handing over to Nadia now. Thank you.

01:03:16.000 --> 01:03:33.000
Great. Thank you, Haley. All right. I am back for a short section on remedial action, community involvement. Ray just sent in the chat this link to a really nice pipeline that outlines the community involvement activities throughout the Superfund process.

01:03:33.000 --> 01:03:52.000
So, once a federal facility is listed on the National Priorities List, the site enters the Superfund process that's outlined in that link that I just had them send. The NCP requires specific community involvement activities at certain points throughout the process, and there are activities necessary to achieve long-term strategic objectives.

01:03:52.000 --> 01:04:10.000
And it's generally referred to as remedial actions. So this is where I think Haley mentioned lingo and acronyms and verbiage. Remedial action, it's a big word for the Superfund process as a whole, but it's also kind of a zoomed-in way to talk about.

01:04:10.000 --> 01:04:24.000
a specific part of the process. So here, we're kind of taking the umbrella view, and we're going to talk through a couple sections that step through this, but I'm just going to start here at the beginning after NPL listing.

01:04:24.000 --> 01:04:32.000
All right. So consistent with the Ncp. The lead agency should conduct the following community act.

01:04:32.000 --> 01:04:43.000
Community involvement activities prior to the initiation of the RI field activities. And RI is remedial investigation, which I think is outlined on that link that Ray sent in the chat.

01:04:43.000 --> 01:04:58.000
So you want to conduct community interviews to solicit people's concerns and determine how and when people want to be involved. This is really a community-led process. Prepare a formal community involvement plan to specify outreach activities that the agency expects to undertake.

01:04:58.000 --> 01:05:03.000
This really helps us have transparency with the community on what they can expect from us.

01:05:03.000 --> 01:05:09.000
Establish and maintain a local information repository at or near the location of the site.

01:05:09.000 --> 01:05:17.000
You also want to establish the administrative record file and make it available to the public as part of the information repository.

01:05:17.000 --> 01:05:34.000
Then you want to publish a public notice to announce the availability of the administrative record for the selection of a remedial action in a newspaper of major local circulation, or use one or more other mechanisms to give adequate notice to the public of the availability of the administrative record file.

01:05:34.000 --> 01:05:44.000
And then, of course, you want to inform the community of the availability of a technical assistance grant or a TAG.

01:05:44.000 --> 01:05:59.000
So let's talk a little bit about public notice in newspapers. Some public notices are required to be published in a newspaper of general circulation. There were changes made to the NCP in 2015 to allow adequate notice to a community via a major local newspaper.

01:05:59.000 --> 01:06:05.000
of general circulation, or by using other mechanisms in six specific instances.

01:06:05.000 --> 01:06:20.000
So EPA is required to follow the statutory public notice requirement associated in CERCLA 117, which is publication in a major local newspaper of general circulation that will continue to be required for.

01:06:20.000 --> 01:06:33.000
Notice of availability of the proposed plan, notice of availability of the record of decision, or the ROD. Notice that briefly summarizes the explanation of significant differences to the rod.

01:06:33.000 --> 01:06:50.000
Notice of Availability and a brief description of the proposed amendment to the record of decision, or the ROD, and notice of availability of the amended record of decision. So that was a lot of lingo, a lot of words. Basically, there are these six instances where the statute says we must.

01:06:50.000 --> 01:07:09.000
provide public notice in a newspaper of general circulation. There are other instances throughout the process, throughout the Superfund process that have been amended in the NCP that expand that to other general mechanisms to kind of keep up with modern times, but unless the statute is revised.

01:07:09.000 --> 01:07:16.000
These six pieces need to stay in a general newspaper circulation.

01:07:16.000 --> 01:07:34.000
And you'll see a lot of these, it's the rod explanation of significant differences to the rod, proposed amendment to the rod, or the final amended rod. So that's basically saying when the record of decision is published or changed through various mechanisms.

01:07:34.000 --> 01:07:51.000
change it… so, like I said here, changes were made to the NCP in 2015 to allow adequate notice to a community via major local newspaper of general circulation, or by using other mechanisms for things that are not listed on this slide.

01:07:51.000 --> 01:08:09.000
All right. So let's talk about what those other mechanisms are. So, effective May 4th, 2015, EPA promulgated the final rule to amend the NCP to broaden those mechanisms. And so, as a result, the lead agency can publish a notice in a major local newspaper of general circulation. How many times can I say that today?

01:08:09.000 --> 01:08:17.000
Or use one or more other mechanisms to notify the public, which are specified in the rules. So the other mechanisms are.

01:08:17.000 --> 01:08:32.000
that… I'm just gonna read these straight to you, because they are straight out of the NCP. That requires a notice of the availability of the administrative record file for CERCLA actions were based on the site evaluation, the lead agency determines that a removal action is appropriate.

01:08:32.000 --> 01:08:36.000
And that less than six months exists before an on-site removal.

01:08:36.000 --> 01:08:54.000
Must begin. For notification of engineering, evaluation, cost analysis, or an ECA, where the lead agency determines that a removal action is appropriate and a planning period of at least 6 months exists prior to initiation of the on-site removal activities.

01:08:54.000 --> 01:09:06.000
Uh, we have NPL deletions, the availability of the administrative record at the commencement of the remedial investigation, the availability of the administrative record when an ECA is issued for public comment.

01:09:06.000 --> 01:09:12.000
Let's read that acronym. out here.

01:09:12.000 --> 01:09:22.000
Haley or Brian, can I tag you in here? This acronym NTCRA, non-time critical removal Action. There we go. Thank you.

01:09:22.000 --> 01:09:36.000
Always testing us. It's still hard 10 years in. And then notification of the administrative record for all other removal actions not included in Section 30820A. So, here you see a lot about the administrative record.

01:09:36.000 --> 01:09:47.000
Some examples of those are distributing flyers door-to-door, mailing notices to homes, sending email notifications, making phone calls, or posting on websites.

01:09:47.000 --> 01:09:53.000
All right. So, we want to keep in mind.

01:09:53.000 --> 01:10:13.000
that the needs of a community at a site can change. The site may be of low to moderate interest to a community, depending on the phase of the process that you're in, but maybe due to emerging issues, it comes up back as a hot topic, and people want to get involved. If the community has a higher level of interest, that may require more community involvement activities.

01:10:13.000 --> 01:10:30.000
And there's things that we can do at headquarters and in the regions to support the range of those activities. So you'll see here on the low end, you know, prepare the CIP, the community involvement Plan, establish the local information repository, but then maybe as the community gets more interested.

01:10:30.000 --> 01:10:46.000
You want to do that communication strategy, as Brian talked about earlier. Maybe you want to host an availability session or an open house. And then maybe if the community is really getting involved, they want to form a community advisory group. They want a technical assistance needs assessment.

01:10:46.000 --> 01:10:54.000
Um, or maybe some community visioning for site reuse.

01:10:54.000 --> 01:11:00.000
So the lead cleanup agency should conduct these community involvement activities.

01:11:00.000 --> 01:11:16.000
They're going to be publishing the public notice in the newspaper. They're going to make the proposed plan and supporting information available to the public, which is the administrative record and the information repository. Provide the 30 day public comment period or extend it if if appropriate.

01:11:16.000 --> 01:11:30.000
Provide the opportunity for a public meeting during the public comment period at or near the site, where you'll want to… they will want to have a transcript that is made available to the public, and also prepare the responsiveness summary included in the record of decision.

01:11:30.000 --> 01:11:37.000
And then finally, publishing that notice of availability of the rod in the newspaper.

01:11:37.000 --> 01:11:52.000
you want to note that the lead agency must provide the opportunity for a public meeting to be held during the public comment period at or near the site. This can be done by including language in the proposed plan and the fact sheet. If that's if that's a method that you're using at the site that the States or the public can request.

01:11:52.000 --> 01:12:15.000
a public meeting by contacting the federal agency. If significant interest in a public meeting is demonstrated, the site team can then plan a public meeting in response to that public interest. And I think, um, Brian's case study was a great example of that. If it is known or anticipated that there will be a high level of interest, the site team can plan for the public meeting in advance and announce it in conjunction with the public comment period.

01:12:15.000 --> 01:12:34.000
and notice of the proposed plan availability. So, again, depends on your site and the community and what they're looking for. If you know that it's going to get requested, might as well start early and plan it early. But if you're not sure, you can wait and put out that notice so that they can request a public meeting.

01:12:34.000 --> 01:12:38.000
All right, we have a couple more polls here.

01:12:38.000 --> 01:12:54.000
I'm going to read this out while maybe we get that poll pull pulled up. So, test your understanding, true or false. At a minimum, a 30-day public comment period is required on a proposed plan and upon timely request, the lead agency will extend the public comment period by a minimum of 30 additional days.

01:12:54.000 --> 01:13:02.000
Days. Let's see if we're able to get that pull up.

01:13:02.000 --> 01:13:04.000
Feel free to shout me out if.

01:13:04.000 --> 01:13:06.000
Um, I'm having problems finding the poll. Unless Shelly or Ray can find it.

01:13:06.000 --> 01:13:12.000
No worries.

01:13:12.000 --> 01:13:24.000
Well, why don't we give folks a minute? come up with your answer. It's okay if we if we don't have the real poll here. All right. The answer to this one is true.

01:13:24.000 --> 01:13:37.000
The NCP in section 430 F3. 1C says that… At a minimum, a 30-day public comment period is required on the proposed plan.

01:13:37.000 --> 01:13:42.000
And upon a timely request, the lead agency will extend it by minimum of 30 days.

01:13:42.000 --> 01:13:56.000
All right, next question. Which of these are conducted to gather information for a community involvement plan and serve as a way to meet the community members and learn about their site related needs, concerns, and expectations.

01:13:56.000 --> 01:14:01.000
As well as how the community gets information and prefers to receive site-related information.

01:14:01.000 --> 01:14:10.000
So this is a select all that apply. We have action memo, a public meeting, a press release, the proposed plan.

01:14:10.000 --> 01:14:15.000
Community interviews. Water.

01:14:15.000 --> 01:14:16.000
Yes.

01:14:16.000 --> 01:14:36.000
Uh, pull… pull us up, and right now… community interview is trending followed by public meeting. I'll close the poll and… 5, 4, 3… 2 1… and community interviews is leading, followed by public meeting.

01:14:36.000 --> 01:14:44.000
Awesome. Community Interviews is correct. Great job, everybody.

01:14:44.000 --> 01:14:49.000
All right. Next poll.

01:14:49.000 --> 01:15:04.000
We just have 2 more, this one and the next one. So a blank of a public meeting held during a proposed planned public comment period must be kept and made available to the public. A transcript, a video recording, a photo log, a sign-in sheet, or an audio recording.

01:15:04.000 --> 01:15:08.000
This is a select one multiple choice.

01:15:08.000 --> 01:15:25.000
pull this up right now. Transcript is trending. It's trending significantly over 90%. I'll close the pole in 5, 4, 3.

01:15:25.000 --> 01:15:30.000
21 92% said transcript that responded.

01:15:30.000 --> 01:15:38.000
Also, great job to that 92%. A transcript is the correct answer to this question.

01:15:38.000 --> 01:15:44.000
All right, one more poll for you all. At least for me.

01:15:44.000 --> 01:15:49.000
The lead agency must publish a blank for the following events.

01:15:49.000 --> 01:16:00.000
The public comment period on the proposed plan. And the remedial alternative has been selected in the rod is signed.

01:16:00.000 --> 01:16:01.000
Pull this up.

01:16:01.000 --> 01:16:09.000
Alright, so your options are responsiveness summary, fact sheet, action memo, public notice, or proposed plan.

01:16:09.000 --> 01:16:16.000
Right now, public notice is turning at 80%. I will close the poll in 5.

01:16:16.000 --> 01:16:25.000
4, 3… 2 1 public notice is trending at 86%.

01:16:25.000 --> 01:16:29.000
That is correct. Public notice is the correct answer here.

01:16:29.000 --> 01:16:34.000
All right. Thank you all for hanging in there. I'm going to turn it over to Haley, I believe now. Thank you guys for the polls.

01:16:34.000 --> 01:16:50.000
Yes. All right. Hello! Just a couple more sections. So home stretch here. So I will be talking about community involvement and post rod actions. Next slide, please.

01:16:50.000 --> 01:16:56.000
And here, rod is record of decision. I think we've talked about that a little bit today, but just a reminder.

01:16:56.000 --> 01:17:05.000
So generally, there are three types of rod changes, each with their own type of documentation and steps that will be needed for community involvement.

01:17:05.000 --> 01:17:23.000
So there are non-significant or minor change. So these changes can be things such as the type or cost of materials, equipment, facilities, services, and supplies that are being used to implement the remedy. The change will not have a significant impact on the scope or the cost or performance of the remedy.

01:17:23.000 --> 01:17:44.000
Um, these changes should simply be recorded in the project file. Now, there are also significant changes. So these generally involve a change to a component of a remedy that does not fundamentally alter the overall cleanup approach. After adoption of a rod, CERCLA requires an explanation of significant differences in ESD.

01:17:44.000 --> 01:17:54.000
If a remedial action, enforcement action, or any settlement or consent decree differs significantly from that initial ROD.

01:17:54.000 --> 01:17:59.000
And then the most extreme kind of change here, which are the fundamental changes.

01:17:59.000 --> 01:18:14.000
involve a larger change or changes in the scope, performance, cost, or multiple significant changes that overall have the effect of a complete and fundamental change to the rod. When fundamental changes are made to that rod, a proposed plan.

01:18:14.000 --> 01:18:31.000
for the amended rod that highlights the proposed challenge changes must be issues. An amended rod that documents the changes follows the proposed plan. When this occurs, the community involvement requirements are similar to those required for the initial proposed plan.

01:18:31.000 --> 01:18:46.000
All right, next slide, please. Cool. So, for the non-significant or minor changes, there are no statutory requirements or provisions in the NCP that address community involvement when only minor changes are made to the rod.

01:18:46.000 --> 01:19:04.000
For significant changes, the requirements are to issue an ESD, again, that explanation of significant differences that describes to the public the nature of the significant changes, summarizes the information that led to making the changes, and affirm that these revised remedies comply with this.

01:19:04.000 --> 01:19:22.000
statutory and regulatory requirements. Making the ESD and supporting information available to the public in the administrative record and information repositories necessary, as well as publishing a public notice in a major local newspaper of general circulation that briefly summarizes the significant differences.

01:19:22.000 --> 01:19:26.000
and states the reason for these changes being made.

01:19:26.000 --> 01:19:47.000
All right, next slide, please. Alright, and then for that more extreme change within the rod. So fundamental changes within a rod amendment. Consistent with CERCLA, the NCP and existing EPA CERCLA guidance, the lead agency should publish a notice of the availability of the Rod Amendment and a brief description of the proposed amendment.

01:19:47.000 --> 01:20:04.000
And again, that local newspaper of general circulation. This will also require a public comment period of at least 30 days for the submission of comments on the proposed plan to amend the ROD and extend that period by a minimum of 30 days if it is requested in a timely manner.

01:20:04.000 --> 01:20:12.000
Um, we also provide the opportunity for a public meeting during the comment period, with a, um, keeping a transcript of comments received during the public meeting.

01:20:12.000 --> 01:20:30.000
Also preparing a in response to comments that includes a brief explanation of the proposed rod amendment and a response to each of the significant comments, criticisms, and new relevant information received during the comment period. Consistent with the NCP, this summary should be included in that amended ROD.

01:20:30.000 --> 01:20:47.000
A final decision on whether to amend the rod generally is only made after consideration of public comments. If the lead agency and EPA decide to go ahead and formally amend the rod, the lead agency should take the following steps consistent with CERCLA, the NCP, and existing EPA CERCLA guidance.

01:20:47.000 --> 01:21:04.000
These are to publish a notice of the availability of amended rod in a major local newspaper, as well as make the amend raw and supporting information available in the administrative record and information repository before their remedial action begins.

01:21:04.000 --> 01:21:08.000
Great. Next slide, please.

01:21:08.000 --> 01:21:22.000
All right, so this here is showing those three different kinds of rods, and this is just to show that changes that significantly or fundamentally affect the remedy selected in the raw typically involve more explanation and enhanced community involvement.

01:21:22.000 --> 01:21:28.000
I'll give you just a second to look through those.

01:21:28.000 --> 01:21:51.000
Cool. Next slide, please. And finally, I will talk about five-year reviews in the community. So Section 121 of CERCLA requires remedial actions that result in any hazardous substance, pollutant, or contaminants remaining at the site be subject to a five-year review. So this is a review that will happen every five years, just to make sure that the remedy is still protective at that site.

01:21:51.000 --> 01:22:04.000
The purpose is to determine the remedy will be protective of human health and the environment. For federal facility sites, the lead agency conducts the review, prepares the reports, and submits the report to EPA for review and comment.

01:22:04.000 --> 01:22:19.000
The lead agency is responsible for ensuring that the recommendations and follow-up actions in the report are completed. No community involvement activities during operation and maintenance or the five-year review are mandated in CERCLA or addressed in the NCP.

01:22:19.000 --> 01:22:36.000
Five-year reviews undertaken by the lead federal agency should include notifying the community that the review will be conducted, requesting information from the community about the site, if appropriate, notifying the community that the review has been completed and preparing a summary of the review and making it available.

01:22:36.000 --> 01:22:46.000
at a local repository or on a web page. The 5-year review is a good time to assess the level of community involvement at that site.

01:22:46.000 --> 01:23:00.000
Cool. And next slide, please. The EPA 2001 comprehensive 5-year review guidance provides the policies and procedures for conducting these five-year reviews at Superfund sites.

01:23:00.000 --> 01:23:15.000
The 2001 guidance states that the site team should consider conducting additional community involvement activities at high-profile sites, which would be those with significant public interest, and any other sites where there's a need for an additional community involvement activities.

01:23:15.000 --> 01:23:25.000
This may include notifying local public officials, including the primary local health agency, and the leadership of any relevant neighborhood and civic groups.

01:23:25.000 --> 01:23:37.000
In addition to this notification, you may also wish to interview several community members, at least some of whom live or work near the site, to get their views about current site conditions, problems, or related concerns.

01:23:37.000 --> 01:23:49.000
If there was or is a Citizens Advisory group, representatives of these groups should be briefed at the outset of the five-year review process, and, if requested, at other appropriate points of that five-year review process.

01:23:49.000 --> 01:24:01.000
You may also want to consider appropriate ways, such as public meetings, or an opportunity for submitting written comments to get broader public involvement within that five-year process.

01:24:01.000 --> 01:24:06.000
Going ahead, we have one more poll. I believe this is the last one.

01:24:06.000 --> 01:24:14.000
Um, so Tess, your understanding, true or false? A five-year review requires a notice be published in a newspaper of major circulation.

01:24:14.000 --> 01:24:19.000
Pull this release.

01:24:19.000 --> 01:24:29.000
Right now, we're trending at 80% plus for true. I will close the poll in 5.

01:24:29.000 --> 01:24:34.000
4. Three. Two, one.

01:24:34.000 --> 01:24:38.000
Uh, we're near 84% for true.

01:24:38.000 --> 01:24:53.000
Okay, so actually it's saying that the answer for this is false, which I do think I want to look more into. I think that what this is saying is there are also other effective methods for notifying the community as well, such as posting information and reports on the site's web page or social media site.

01:24:53.000 --> 01:25:09.000
disseminating reports, distributing postcards, fact sheets, and flyers via mail, email, social media, or at events. Um, issuing press releases, and placing advertisements in local newspapers, community newspapers, or newsletters. So I think this is just saying there's a lot of different methods that can be used.

01:25:09.000 --> 01:25:21.000
to a polish this notice. I am going to pass it on for our last section, which is with Nadia. Thank you.

01:25:21.000 --> 01:25:41.000
Thanks, Haley. Sorry it took me a second to get back on here. So just a brief overview on EPA technical assistance at federal facilities on the national priorities list. So at complex sites where there's strong community interest, a lead federal agency should consider assessing the community's needs for technical assistance.

01:25:41.000 --> 01:25:59.000
Through a technical assistance needs assessment, or a TANNA, as we call it. The TANA is a site-specific process that identifies whether a community requires additional support from EPA or from a lead agency to understand technical information and to enable meaningful community involvement in the Superfund decision-making process.

01:25:59.000 --> 01:26:18.000
The TANNA then helps direct the community towards the next best step for technical assistance for them. This is very site-specific, and so it's hard to make broad brushes here on what the best path is, but in summary, the technical assistance grant is something that the community applies for.

01:26:18.000 --> 01:26:27.000
and receives. They can contract their own technical advisor to interpret or explain technical reports, site conditions, and EPA's proposed cleanup.

01:26:27.000 --> 01:26:34.000
proposals and decisions. The initial grant of $50,000 is available to qualified community groups.

01:26:34.000 --> 01:26:53.000
Task is providing independent assistance through an EPA contract that helps communities better understand the science regulations, and policies of environmental issues and EPA actions. Under the task contract, the contractor provides scientists, engineers, or other professionals to review and explain information to communities.

01:26:53.000 --> 01:27:10.000
on a project-specific basis, and is provided at no cost to the communities. This is mostly used for EPA lead sites, although the lines there, again, are very site-specific, depending on what is going on at the site and what the community needs are.

01:27:10.000 --> 01:27:18.000
But for federal facilities, there is the TAP program, Technical Assistance for Public Participation. And this is.

01:27:18.000 --> 01:27:36.000
for Department of War RABS, as I think Brian covered earlier. So TAP provides funds for small businesses to conduct independent technical analyses for community members of RABS on topics of concern at DOW Environmental Restoration sites.

01:27:36.000 --> 01:27:44.000
Up to $25,000 per year, and a total of $100,000 per DOW installation is available for those.

01:27:44.000 --> 01:27:51.000
And I believe your handout should have all the websites there. Please let us know in the Q&A if it's not, and we'll send those in the chat.

01:27:51.000 --> 01:28:07.000
Um, and as I mentioned, tag and task are used more at private NPL sites, but there are specific circumstances where they can be used at federal facilities. It's usually a… a site-specific conversation, so… That is it for that slide.

01:28:07.000 --> 01:28:12.000
I think maybe Haley or Brian is going to just give us a quick overview. I have Brian. Yeah.

01:28:12.000 --> 01:28:26.000
Yeah, yeah, so… so just just in review, you know, a couple slides left. I just want to emphasize what an important role community involvement plays in Superfund.

01:28:26.000 --> 01:28:36.000
But also in Circle, as we work with our federal partners. I mean, it's a really important aspect of everything they and we do.

01:28:36.000 --> 01:28:44.000
you know, when you're working with the other federal agency, it, you know, really coordination across the entire site team, including the state.

01:28:44.000 --> 01:28:56.000
is necessary. And so, all the information we covered in these slides, this is really great information on CERCLA that allows you to go ask important questions, and.

01:28:56.000 --> 01:29:06.000
you know, ask about public comment periods and that kind of thing, and really, you know, get the pulse of the agencies you're working with.

01:29:06.000 --> 01:29:12.000
You know, a lot of times, we also talked about some examples, public meetings.

01:29:12.000 --> 01:29:25.000
Um, things like that. These are great opportunities to go above and beyond. And sometimes they're really needed to meet the intent of community involvement under the NCP. There's a lot of requirements.

01:29:25.000 --> 01:29:34.000
But, you know, the important thing is here is that community involvement really should be tailored to the community. And so that's something really important.

01:29:34.000 --> 01:29:42.000
Uh, to remember, and I think we're ready to move on to our next slide, which I believe is, um… Our contact information.

01:29:42.000 --> 01:29:54.000
Yeah, so here's… we've got emails, phone numbers here. Um, if you've got questions, reach out to us. I think we've got a lot of good questions in the chat, too. I've been trying to answer a few, and.

01:29:54.000 --> 01:30:01.000
When JR gives me the go-ahead, I'm ready to answer a few verbally. So I'll… I'll pass it back to JR now.

01:30:01.000 --> 01:30:22.000
No, I appreciate it. Thank you, Haley, Nadia, Brian on, you know, outstanding presentation talking about community involvement in you know, at Federal facilities. Much appreciated. Before we go into questions, a couple little administrative notes, but.

01:30:22.000 --> 01:30:45.000
First of all, you have our contact information. I know some of you have been emailing the speakers and the moderators. We'll get back to you in 12 to 36 h. Please be patient. As far as questions in general, if something is site specific, it may not be addressed today. So please don't be offended. We want to try to address the questions that everybody can benefit from immediately given the short.

01:30:45.000 --> 01:31:02.000
timeframe that we have. Again, you know, I told you about the webinars we have up and coming. There's different webinars with FRTR, Tech Direct is another source where you can.

01:31:02.000 --> 01:31:10.000
see what we have going on as far as webinars with Kluen. Uh, next slide, please.

01:31:10.000 --> 01:31:21.000
Um, again, this is where you register at. Don't worry about, yes, that was a previous webinar that was conducted, but my whole point here is showing you again.

01:31:21.000 --> 01:31:39.000
Where can he accessed the materials after this? This is a site. You click on those different plus buttons there. You get access. Make sure you provide the feedback form in order to get your certificate. Once you fill out the feedback form. Next slide, please.

01:31:39.000 --> 01:32:07.000
There's a box. You look up right hand corner, you know, above my head, possibly. I certify they had tinnitus alive seminar and view the archives, or… view the archive if it was recording, please send me a certificate. You'll get your certificate. That is really it. All right, next next slide, please.

01:32:07.000 --> 01:32:22.000
I think that's the last slot. Okay, okay. So we're about to go into Q&A. I have one question for our speakers. So I think this is more of a statement, but I don't know in 90 seconds or less, if you can amplify it.

01:32:22.000 --> 01:32:34.000
And the statement was, try tribal organizations or tribes should be included in RAVs and CABS when appropriate.

01:32:34.000 --> 01:32:42.000
I would agree with that, yeah, I would agree with that. Again, it depends on the site and proximity. But yeah, I would agree with that.

01:32:42.000 --> 01:32:48.000
Okay, and with that, I'll let Ray and Shelly kind of take over the questions, the Q&A.

01:32:48.000 --> 01:32:53.000
I will go off camera now.

01:32:53.000 --> 01:32:59.000
Sure, um, let's see here. We have nine questions in the queue here.

01:32:59.000 --> 01:33:08.000
Um… Can you talk about the difference in an AR and an IR?

01:33:08.000 --> 01:33:12.000
I can start, and maybe Brian and Haley, you can chime in.

01:33:12.000 --> 01:33:29.000
Um, so the administrative record and the information repository is what we're referring to here. The administrative record is a file of documents that the agency used to rely on to make their decisions.

01:33:29.000 --> 01:33:46.000
The administrative record is used in court, in litigation. It's used to uphold the agency's decisions under judicial review, which is a whole law school class we could have separately. But that is the purpose of the administrative record.

01:33:46.000 --> 01:34:06.000
The information repository, my understanding, Brian and Haley, you can let me know if this is your understanding, too, can be broader than the administrative record. So the administrative record is always in the information repository, but the information repository may contain more information that the community would benefit from than just the administrative record.

01:34:06.000 --> 01:34:17.000
Yeah, I would say that's a great answer. And I, you know, to kind of sum it up, I think of the administrative records being legally curated, right? It's more of a legal.

01:34:17.000 --> 01:34:30.000
Uh, you know, they're both, uh, information tools, and then the information repository is kind of more for the public. It's more digestible in a lot of ways, and so… so yeah, yeah, great answer.

01:34:30.000 --> 01:34:46.000
Great, great. Another question we have, how do you determine who to interview for community interviews?

01:34:46.000 --> 01:34:47.000
Sure.

01:34:47.000 --> 01:34:56.000
I can. I can take a little shot at that one first, if you if you want. So, you know, one of the things I've used is proximity to the site. That's the easiest thing to think about, but you know it's also a good idea to put some.

01:34:56.000 --> 01:35:13.000
Research in ahead of any site trips. You know, learn about the site, learn about the surrounding communities. Use all of that information collectively. You know, your your lead agency is going to determine who they want to interview. If they're doing interviews.

01:35:13.000 --> 01:35:20.000
But, you know, that type of information, that's the type of information I would use to make recommendations to them.

01:35:20.000 --> 01:35:21.000
So I hope that helps.

01:35:21.000 --> 01:35:26.000
Okay. Yeah. Hey, Brian, there's a there's kind of a piggyback on that.

01:35:26.000 --> 01:35:39.000
are the community interviews required, or can they be waived if the federal facility feels they have a good pulse on the community?

01:35:39.000 --> 01:35:40.000
I can…

01:35:40.000 --> 01:35:47.000
So that's a great question, and I'm not. I'm not sure of the absolute answer there, but I'm pretty sure community… I'm pretty sure they're required when you prepare a plan, but I'll defer to Nadia on that.

01:35:47.000 --> 01:36:03.000
Yeah, so the link I sent you all with the pipeline that says community involvement activities throughout the Superfund remedial process, there, it does say that community interviews are required activities during the remedial investigation and feasibility study. That's the only place where they're listed as.

01:36:03.000 --> 01:36:08.000
required, I believe, but that would be what I would go off of here.

01:36:08.000 --> 01:36:09.000
Okay.

01:36:09.000 --> 01:36:10.000
Okay.

01:36:10.000 --> 01:36:27.000
Haley, do you have anything you'd add?

01:36:27.000 --> 01:36:42.000
Okay. All right. Thank you. We do have a question. What is the actual guidance document that DOD/DOW is using referring to when they require the cip update every 5 years?

01:36:42.000 --> 01:36:55.000
And then parentheses for every federal facility I have worked on this is a requirement, but I am not sure where it comes from.

01:36:55.000 --> 01:37:00.000
I'm going to Virta Haley or Nadia on that one.

01:37:00.000 --> 01:37:15.000
I am not personally sure what the DoD, DOW guidance is. Um, on EPA's end of things, we don't require this to be updated, um, but if the lead federal agency has their own policy, um.

01:37:15.000 --> 01:37:28.000
I don't know exactly what that is. I definitely agree that it should be updated frequently to keep up with the community, but I, um, unfortunately can't tell you right now where that exact guidance comes from.

01:37:28.000 --> 01:37:29.000
Yeah. Just concurring.

01:37:29.000 --> 01:37:50.000
Okay. Okay. Alright, we also have a question. Can a facility submit a master cip for a whole facility, or is it an individualized one specific to a removal action at a smaller site required?

01:37:50.000 --> 01:38:05.000
So I would say that if they've got a master CIP, and it's been updated recently, that's probably sufficient. Sometimes with other federal agencies, you do see very old community involvement plans.

01:38:05.000 --> 01:38:13.000
Again, it's a great idea to update those, but if they have a recently updated one, then they're probably just fine.

01:38:13.000 --> 01:38:28.000
Yeah, and there's another pipeline similar to the remedial one I sent you all that I've been referring to, that's for removals. And on that, the CIP is only required for long-term time critical removals or non-time critical removals.

01:38:28.000 --> 01:38:35.000
Not for short-term or emergency responses. So, um, I think that kind of goes to what what Brian's saying as well.

01:38:35.000 --> 01:38:44.000
Haley, anything to add?

01:38:44.000 --> 01:38:56.000
Okay, and then finally, we have a question. What are the requirements for community involvement for closing sites or partially deleting sites from the NPL?

01:38:56.000 --> 01:38:59.000
Good question.

01:38:59.000 --> 01:39:21.000
I have it up so I can. take that, and you guys can can weigh in. So for for NPL deletion, we have a Federal Register notice announcing the intent to delete. We have a public notice, a public comment period, a responsiveness summary to the public comments, and adding the deletion docket to the information repository. So those are all the required things.

01:39:21.000 --> 01:39:24.000
Um, would you add anything in your experience, Brian or Haley?

01:39:24.000 --> 01:39:26.000
No, I think that's a good answer.

01:39:26.000 --> 01:39:29.000
Yep, that sounds good.

01:39:29.000 --> 01:39:33.000
Okay, I don't see any more questions. Back to you, Jr.

01:39:33.000 --> 01:39:46.000
Okay. Hi, everyone. Just 3 things. Again, I want to thank our speakers for for being available today to present this critical topic.

01:39:46.000 --> 01:40:01.000
Um, I don't know if, uh, Nadia or Pete, if you can throw up the contact information again for everyone. Um, again, the contact information is great. Excellent. So here's the contact information for speakers.

01:40:01.000 --> 01:40:08.000
You weren't able to get your question answered, or you feel that it didn't meet your, uh, your, your satisfaction.

01:40:08.000 --> 01:40:22.000
And, um, I'm gonna let Ray confirm there's no last minute questions that came through and I'm going to place Haley on the spot. Haley, if you want to give maybe a 90 second blurb.

01:40:22.000 --> 01:40:33.000
Um, about 5-year reviews, because you'll be one of the speakers for that on May 13th.

01:40:33.000 --> 01:40:34.000
Yeah, I don't have the question pulled up. Jr, what is the specific question?

01:40:34.000 --> 01:40:38.000
Sorry to put you on this.

01:40:38.000 --> 01:40:48.000
Oh, no, um, if you could just put, um… promote the speaking on May 13th, I'll have your reviews. You mentioned five-year reviews several times today.

01:40:48.000 --> 01:41:09.000
Oh, got it, yes. Yeah, yeah, absolutely. Um, so the next webinar series will be on five-year reviews. I am the 5-year review coordinator for the Federal Facility Superfund program. Um, so we'll be talking about the different sections required within that. Noting at things such as community involvement, which was the entirety of this.

01:41:09.000 --> 01:41:24.000
Um, so if you have more questions specifically on community involvement within the five-year review process, feel free to bring it there. But yeah, we have a awesome team set up for that and look forward to seeing you all hopefully at that webinar. Thank you.

01:41:24.000 --> 01:41:29.000
Great. Anything else in room, Ray or Shelly? Anything else?

01:41:29.000 --> 01:41:31.000
Thank you all so much.

01:41:31.000 --> 01:41:32.000
No, no, we're, uh, we're all good. We're all good. Thank you, Jr. And thank you, team.

01:41:32.000 --> 01:41:37.000
Cover. Okay, well, this concludes.

01:41:37.000 --> 01:41:39.000
Thanks, everyone.

01:41:39.000 --> 01:41:43.000
Yes, this concludes our webinar on fire facility community involvement. Thank you for joining. Have a great day.

01:41:43.000 --> 01:41:52.000
And thank you.Thank
