Superfund: EPA's Community Relations Efforts Could Be More Effective
(Letter Report, 04/08/94, GAO/RCED-94-156).

In the course of cleaning up hazardous waste sites, the Environmental
Protection Agency (EPA) is required to provide information to residents
living near the sites and involve them in decisions.  Legislation passed
in 1980 further requires EPA to conduct specific community relations
efforts, such as public meetings and comment periods, during Superfund
cleanups.  Although EPA has done the community relations efforts
required by law, many residents GAO spoke with were dissatisfied,
believing that EPA needs to reach out earlier to communities and to
continue that outreach through the cleanup process.  EPA provided the
mandated public notices and opportunities for public comment, held
meetings, and made information available in locations accessible to the
public.  EPA also usually informed residents that technical assistance
grants were available.  Given concerns about health and property values
around Superfund sites, achieving consensus about cleanup decisions may
be difficult, and EPA may not be able to earn the public's trust even
with the best intentions and community relations outreach.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-94-156
     TITLE:  Superfund: EPA's Community Relations Efforts Could Be More 
             Effective
      DATE:  04/08/94
   SUBJECT:  Environment evaluation
             Environmental legislation
             Environmental monitoring
             Public relations
             Information dissemination operations
             Hazardous substances
             Safety standards
             Public lands
             Environmental impact statements
IDENTIFIER:  Superfund Program
             National Oil and Hazardous Substances Pollution Contingency 
             Plan
             EPA National Priorities List
             EPA Community Relations Program
             
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Cover
================================================================ COVER


Report to Congressional Requesters

April 1994

SUPERFUND - EPA'S COMMUNITY
RELATIONS EFFORTS COULD BE MORE
EFFECTIVE

GAO/RCED-94-156

EPA's Community Relation Efforts Concerning Superfund


Abbreviations
=============================================================== ABBREV

  ATSDR - Agency for Toxic Substances and Disease Registry
  CERCLA - Comprehensive Environmental Response, Compensation, and
     Liability Act
  EPA - Environmental Protection Agency
  NCP - National Oil and Hazardous Substances Pollution Contingency
     Plan
  NPL - National Priorities List
  PCBs - polychlorinated biphenyls
  SARA - Superfund Amendments and Reauthorization Act
  TAG - technical assistance grant

Letter
=============================================================== LETTER


B-247753

April 8, 1994

The Honorable Frank R.  Lautenberg
Chairman, Subcommittee on Superfund,
 Recycling, and Solid Waste Management
Committee on Environment and Public
 Works
United States Senate

The Honorable Louis Stokes
Chairman, Subcommittee on VA, HUD,
 and Independent Agencies
Committee on Appropriations
House of Representatives

The Honorable Jim Chapman
House of Representatives

The primary mission of Superfund, the Environmental Protection
Agency's (EPA) program to clean up the nation's most hazardous waste
sites, is to protect human health and the environment.  However, EPA
is also responsible for providing information to residents who live
near these sites and involving them in cleanup decisions.  In 1986,
the Congress formally recognized the importance of the public's input
by amending the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA or Superfund) to require EPA to
conduct specific community relations activities, such as public
meetings and comment periods, during Superfund cleanups.  The agency
was also authorized to provide technical assistance grants (TAG) to
communities to enable them to participate more fully in cleanup
decisions. 

In response to your concerns about whether communities are adequately
involved in decisions about their local Superfund sites, this report
discusses EPA's efforts to give communities a voice in
decision-making.  You asked that we (1) provide background on the
Superfund program's requirements for community relations activities,
(2) review the extent to which EPA is fulfilling these requirements,
and (3) ascertain community residents' feelings about the adequacy of
EPA's efforts. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Although EPA performed the community relations activities required by
the law, many residents with whom we spoke were not satisfied.  For
sites we reviewed, EPA provided the statutorily mandated public
notices and opportunities for public comment, held meetings, and made
information available in locations accessible to the public.  In
addition, as required by its regulations EPA usually informed
residents of the availability of technical assistance grants.  In
some cases, EPA exceeded the requirements of the law by holding extra
meetings, providing bilingual documents, and meeting with families
individually.  However, given the concerns about health and property
values around Superfund sites, achieving consensus about cleanup
decisions may be difficult, and EPA may not be able to earn the
public's trust even with the best intentions and community relations
outreach.  In spite of EPA's efforts, most residents we contacted
near eight Superfund sites we visited were frustrated because they
believed EPA

  undertook its outreach efforts too late or did not involve enough
     of the affected community members throughout the cleanup
     process,

  did not listen to residents' input or adequately involve community
     members in decisions about cleanups in their communities,

  provided information repositories (places where the public has open
     and convenient access to key documents on a Superfund site) that
     were not as useful and accessible as they could be,

  did not use the most effective media for disseminating public
     notices and did not communicate technical information
     effectively, and

  had experienced high staff turnover, resulting in a lack of
     continuity and knowledge about sites. 


   BACKGROUND, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :2

CERCLA gave EPA the authority and funding to clean up hazardous sites
that threaten human health and the environment, and Superfund was
reauthorized by the Superfund Amendments and Reauthorization Act of
1986 (SARA).  Authorization for the Superfund program has totaled
$15.2 billion.  Superfund's authorization expires in 1994, and the
administration's bill now under consideration proposes changes that
will affect many aspects of the program, including community
relations. 

EPA learns of potentially hazardous sites from state and local
officials and the general public.  After investigating these sites,
EPA places the worst ones on the National Priorities List (NPL) for
Superfund cleanup.  As of September 30, 1993, the NPL included 1,320
sites.  Inclusion on the NPL triggers key Superfund community
relations requirements, for such things as public notices and
meetings, opportunities for the public to comment on proposed cleanup
remedies, and fact sheets to provide information about the site and
its cleanup. 

We performed our work at EPA headquarters in Washington, D.C., and
Regions II (New York), V (Chicago), VI (Dallas), and IX (San
Francisco).  Regions II and V have the highest number of Superfund
sites.  In addition to reviewing pertinent laws and regulations, we
interviewed community relations officials from EPA headquarters and
all 10 regions.  We also reviewed files at 15 site information
repositories to determine if they contained required documentation on
key community relations activities.  To assess how community
residents view EPA's community relations efforts for sites undergoing
remedial cleanup actions, we met with 65 residents living near eight
Superfund sites.  We first met with groups of residents at three
sites in New Jersey.  We also held five focus groups, or structured
meetings in which participants responded to questions about EPA's
community relations efforts, for selected residents at five Superfund
sites in the other EPA regions and interviewed other residents
individually at these sites.  Where possible, at all eight sites we
visited, we also interviewed local officials and the parties
responsible for conducting the cleanup.  We conducted our review
between January 1993 and February 1994 in accordance with generally
accepted government auditing standards. 


   EPA MUST PROVIDE FOR PUBLIC
   INPUT AT MOST STAGES IN
   SUPERFUND CLEANUPS
------------------------------------------------------------ Letter :3

To foster opportunities for public involvement in cleanups, the
Congress included in SARA minimum requirements for public
participation at Superfund sites undergoing remedial cleanup actions. 
An EPA regulation, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), implements these requirements and
specifies how and when the agency will conduct Superfund community
relations activities for Superfund sites undergoing both removal
actions and more extensive remedial actions. 

EPA's community relations handbook, updated in January 1992, includes
the public participation requirements in SARA and the NCP, as well as
EPA's community relations policies issued since 1983.  It also
suggests techniques that regional staff can use to supplement the
basic requirements.  The handbook sets forth the agency's overall
community relations objectives:  to allow the public to comment on
and provide input to technical decisions, to inform the public of
planned and ongoing actions, and to identify concerns so that the
communities' needs can be better addressed and conflicts can be
resolved. 

Before beginning the cleanup of a site, EPA requires an in-depth
study assessing the contamination at the site, estimating the risks
posed to the surrounding community and environment, and evaluating
alternatives for treating or containing the waste.  However, prior to
the study, the NCP requires EPA to (1) develop a community relations
plan describing a community's information needs and outlining
activities to meet these needs and (2) identify local officials and
interested parties. 

SARA authorizes EPA to provide grants of up to $50,000-- TAGs--to
allow groups affected by a Superfund site to hire experts to help
them understand technical information about the site.  Under the NCP,
EPA is to notify the community about the availability of these
grants.  SARA also requires EPA to establish an information
repository where the public has open and convenient access to key
documents on the Superfund site.  Finally, EPA must (1) issue public
notices in a major local newspaper about planned and final cleanup
activities and (2) notify the public about the existence of the
information repository. 

SARA provides opportunities for public participation when both the
proposed and final cleanup plans for a site become available.  For
the proposed cleanup plan, EPA must provide a reasonable opportunity
for public comment, announced by a public notice in a major local
newspaper, and a public meeting.  A transcript of the public meeting
must be made available in the information repository.  The final
cleanup plan must include a summary of EPA's responses to the
comments and questions received as well as a written explanation of
any major changes to the proposed plan. 

Once EPA has selected the cleanup remedy and completed the design,
including technical drawings and specifications, under the NCP it
must issue a fact sheet explaining the design.  If appropriate, EPA
must also hold a public briefing before starting the cleanup--if the
cleanup involves burning contaminated soil on-site, for example. 
Neither SARA nor the NCP requires any community relations efforts
during the cleanup design, site cleanup, or ongoing operations and
maintenance activities at the site once long-term cleanup has begun. 
Some maintenance activities go on for a very long or indefinite
period of time; for example, groundwater pumping and treatment
systems may operate indefinitely and require continuing inspection. 

Although EPA headquarters provides regions with guidance on community
relations activities, implementation is left to community relations
coordinators in the regions.  As of February 1994, EPA had three
staff members in headquarters providing oversight and developing
policy for the Community Relations Program and about 80 regional
coordinators.  In some regions, coordinators manage community
relations at 20-30 sites, although the work load has been as high as
42 sites.  EPA may also delegate community relations responsibilities
to the states or responsible parties performing the cleanup. 
However, EPA is responsible for overseeing their activities. 


   EPA MET MOST COMMUNITY
   RELATIONS REQUIREMENTS
------------------------------------------------------------ Letter :4

EPA performed the community relations activities required by statute
and in some instances made additional efforts.  At each of the eight
sites where we met with residents, EPA conducted outreach as part of
its initial involvement with communities and developed the community
relations plan required by its regulations before beginning the site
study.  For each of the 15 sites reviewed, EPA provided the mandated
opportunities for public comment and meetings to discuss the proposed
cleanup and also established an information repository in a public
library.  EPA also published the required public notices announcing
its proposed cleanup plans and comment periods in major newspapers
and provided other written information such as fact sheets about the
cleanup. 

In some instances, however, EPA's community relations activities were
not performed as effectively as they could have been.  For example,
EPA did not always contact all nearby residents when early site
activities began or include them on the original mailing lists.  EPA
awarded TAGs to communities to hire experts to help them understand
technical information at 2 of the 15 sites reviewed and provided
information about TAGs at 9 of these sites.  However, the agency
could not provide evidence that it had notified residents about the
grants at four of these sites as the NCP requires.  Furthermore, most
of the information repositories that we visited were missing key
documents, including community relations plans, information on TAGs,
and transcripts of public meetings.  We were not able to determine
whether the missing documents had not been included by EPA or had
been removed by patrons.  During our visits to these repositories, we
also observed that some of them were cluttered with materials and
that documents were stored in boxes making it difficult to find
information.  While EPA relies on librarians or others to maintain
the repositories, the agency is ultimately responsible for them. 
Finally, although EPA's guidance suggests that public notices be
designed to attract attention and displayed in the most widely read
section of the newspaper, we had trouble finding some notices because
they were in fine print and not prominently displayed. 

In other instances, EPA's community relations efforts exceeded the
requirements of the law.  For example, at the South Bay asbestos site
in Alviso, California, EPA conducted public meetings and provided
fact sheets in both English and Spanish to ensure that the entire
community could participate.  (See app.  I for more information about
the South Bay asbestos site.) Additionally, at the Montclair/West
Orange radium site in Essex County, New Jersey, EPA tried to improve
communication with local residents by having key EPA staff available
at an office in Montclair four days each week.  (For more information
on the Montclair/West Orange site, see app.  II.)


   RESIDENTS ARE DISSATISFIED WITH
   EPA'S COMMUNITY RELATIONS
   EFFORTS
------------------------------------------------------------ Letter :5

Even when EPA went beyond the minimum requirements for community
relations activities, residents were not necessarily satisfied.  Many
of the 65 community residents with whom we spoke at eight Superfund
sites were generally dissatisfied with EPA's efforts.  Residents'
comments included the following complaints: 

  EPA's outreach efforts did not occur early enough and did not reach
     everyone. 

  EPA did not adequately consider residents' health concerns and
     preferences when selecting remedies. 

  The information repositories were not always useful because they
     contained too much material or were incomplete, too far away, or
     difficult to use. 

  EPA's printed materials used technical language that made them hard
     to understand. 

  Once site cleanup actually began, residents did not receive updated
     information, and their concerns and questions about the ongoing
     cleanup remained unanswered. 

  The high level of EPA staff turnover made it difficult for
     residents to know whom to contact and resulted in a lack of
     program continuity and staff knowledge about sites. 


      EARLY AND THOROUGH OUTREACH
      WAS LACKING
---------------------------------------------------------- Letter :5.1

EPA conducted outreach activities as part of its initial involvement
with communities, but residents and local officials we spoke with at
several sites believe these efforts did not occur early enough and
were not thorough enough.  For example, at the Ewan Property Dump in
Florence Township, New Jersey, fire officials threatened not to
respond to site emergencies because EPA had not provided information
about site contamination and activities.  (For more information on
the Ewan site, see app.  III.) Moreover, EPA did not always contact
all nearby residents when early site activities began or include them
on the original 1988 mailing lists.  At the Texarkana Wood Preserving
Company site in Texarkana, Texas, EPA did not contact residents of
adjacent Texarkana, Arkansas, during its initial outreach efforts. 
Nor did EPA include Arkansas residents on its initial mailing list,
even though some lived within a mile of the site.  The agency
included more of the Arkansas residents and added them to the mailing
list when it was updated in 1992.  (App.  IV presents more
information on the Texarkana site.)

In addition, many residents we met with had trouble obtaining
information on TAGs that could be used to hire experts to help
residents understand technical information.  For example, residents
at the Tri-County Landfill in South Elgin, Illinois, asked us to give
them any information we might have on the grants because they were
unable to obtain the information from EPA.  (App.  V contains
information on the Tri-County site.) The director of the group that
received a grant for the South Bay asbestos site in Alviso,
California, said he found out about the grant from a local
environmental group, not from EPA.  He also complained about the long
and frustrating application process and the requirement that costs
first be incurred and then submitted to EPA for eventual
reimbursement.\1

EPA headquarters officials in charge of TAGs said that the grant
application form and accompanying guidance for applicants have been
revised and should be available soon. 

The EPA Administrator and others have recognized that many
communities near Superfund sites have not been given the opportunity
to participate fully in the Superfund process.  Community relations
coordinators with whom we spoke at their national meeting in February
1994 agreed that outreach should occur earlier and more often at
Superfund sites.  However, they said that even current outreach
efforts strain available program resources.  They also noted that
public involvement is currently designed to begin when a site is
listed on the NPL, which is not early enough.  Because many public
concerns arise while the site is being investigated for possible
inclusion on the NPL, the need for earlier and more extensive public
involvement in the Superfund process has been a recurrent theme at
meetings with representatives from industry, state and local
governments, and communities. 

The Superfund reform bill proposed in February 1994 provides for
community involvement in the cleanup process from the time a site is
identified through cleanup.  The proposed bill would (1) establish
community working groups as a representative public forum to provide
direct, regular, and meaningful input to EPA's decisions about the
site and (2) fund offices in each state and on each tribal land
affected by a Superfund site to provide citizens and elected
officials with information about the site and the Superfund process. 
Although the bill should help to address communities' concerns, it is
obviously too early to tell what overall impact the proposed changes
might have. 


--------------------
\1 Our November 1992 testimony on TAGs identified requirements that
made it difficult for communities to receive and use grants and
discussed the small number of grants awarded:  EPA's Superfund TAG
Program:  Grants Benefit Citizens but Administrative Barriers Remain
(GAO/T-RCED-93-1, Nov.  10, 1992). 


      RESIDENTS BELIEVE EPA DOES
      NOT CONSIDER THEIR INPUT
---------------------------------------------------------- Letter :5.2

As mandated by law, EPA has provided opportunities for public comment
and meetings to discuss the proposed cleanups, but many residents we
met with believe their input was not considered.  For example,
residents at the South Bay asbestos site said that although they
repeatedly told EPA that children played on the contaminated levee,
it took years to get a fence and warning signs put up.  Residents
there also said they have told EPA that the street sweeper kicks up
clouds of dust, although it is supposed to be wet-sweeping to control
asbestos-contaminated dust.  We observed that the street sweeper
dampened the street but still generated dust clouds; children
following the sweeper were enveloped in these clouds. 

Residents we met with at several sites believe that EPA had already
made decisions about sites before obtaining their input.  For
example, at the Texarkana Wood Preserving site, several residents
said that EPA had already identified incineration as the remedy when
the proposed plan was released.  Residents felt that nothing could be
done to change EPA's decision and that their input was ignored. 

However, according to EPA officials, the agency has changed remedies
as a result of community input.  Community relations coordinators and
EPA headquarters officials also told us communities' receptiveness to
site remedies varies.  Some communities have accepted controversial
remedies, such as incineration; in other communities, even extensive
community relations efforts have not gained residents' acceptance of
incineration.  For example, at the Brio Refining, Inc., site in
Houston, Texas, residents opposed the use of incineration as the
cleanup remedy.  (For more information on the Brio site, see app. 
VI.)


      INFORMATION REPOSITORIES ARE
      NOT ALWAYS USEFUL TO
      RESIDENTS
---------------------------------------------------------- Letter :5.3

EPA established information repositories in public libraries for all
of the 15 sites that we reviewed, but individual residents complained
that the repositories were not conveniently located or easy to use. 
To be most useful to the affected community, an information
repository must be near the Superfund site.  We found that the
location of the repositories ranged from several yards to over 5
miles from the affected community.  Residents in Indianapolis,
Indiana, complained that the repository for the Reilly Tar and
Chemical Company site, located 5 miles from the site, was not
convenient and could have been moved when a new public library was
built only a few blocks away from the site.  (App.  VII contains more
information about the Reilly site.)

Residents we met with also complained that the large amounts of
information contained in the repositories make them difficult to use. 
Most of the repositories we visited consisted of binders and folders;
the Brio site repository included 115 binders.  Other repositories
included a mix of microfilm rolls or microfiche cards and binders. 
The Texarkana site repository consisted mainly of microfiche cards,
each containing 20-30 pages of text.  The cost to photocopy each page
was 25 cents.  Residents living near this site and two other sites
complained about the high photocopying costs. 

Community relations coordinators we interviewed said that other
Superfund repositories have similar problems.  Coordinators have
complained at their national meetings that finding locations for
repositories is difficult because EPA offers no financial or other
incentives to libraries and other groups for housing the documents. 
Two coordinators agreed that repositories are housed too far from
residents or in inadequate locations.  One coordinator said that EPA
had to purchase shelving for the host library to house site
documents.  Several coordinators also agreed that once the
repositories are established, they do not have enough time and
resources to check repositories as frequently as they would like. 


      INFORMATION EPA PROVIDES IS
      OVERLY TECHNICAL
---------------------------------------------------------- Letter :5.4

A number of residents we spoke with at the eight sites complained
about the information provided to the community.  For example, some
said that the public notices were hard to find and suggested that
they be more prominently displayed and included in free local papers
to reach additional residents.  Representatives of the party
responsible for cleaning up the site, as well as two residents living
near the Reilly Tar and Chemical Company site, thought that EPA
should publish notices of public meetings in the free local newspaper
instead of the major Indianapolis newspaper, which they said most
residents do not routinely read. 

Although the purpose of fact sheets is to inform the public of the
status and findings of cleanup actions at Superfund sites, residents
we met with at all eight sites said they found the written
information about the sites overly technical and hard to understand. 
Residents we met with at several sites also complained that
discussions during public meetings were technically complex and
difficult to understand.  For example, one resident at the Roebling
Steel Company site in Burlington County, New Jersey, said that EPA
uses terms, such as "hot spots," that he didn't understand.  (App. 
VIII presents information about the Roebling site.)

To ascertain the approximate educational level required to understand
EPA's fact sheets and identify why residents we spoke with find them
difficult to understand, we used a computer program to analyze the
readability of 20 fact sheets, 2 provided by each of EPA's 10
regions.  We found that some college education was needed to
understand 16 of them, although a reading level of the 6th to 10th
grade is recommended for documents intended for the general public. 
Given the difficulty of reading these materials, EPA may not be
ensuring that all citizens understand the cleanup issues. 

We discussed the results of our readability assessment at the
national meeting of the Community Relations Coordinators in February
1994, and they were not surprised by our findings.  Several said that
residents have complained that the fact sheets are too technical but
that reviews by EPA legal and technical staff often result in changes
that make the fact sheets harder to read.  Most coordinators present
expressed interest in trying a computerized readability analysis to
improve their fact sheets, and one region had already tried using a
readability formula in a pilot study. 

Even when EPA went beyond the minimum requirements for providing
information, many residents we spoke with were not necessarily
satisfied with the communication, the remedy selected, or the
presence of a Superfund site in their communities.  For example, at
the South Bay asbestos site, many residents we met with were still
concerned about the timing for completing the cleanup and about
possible decreases in their property values, even though EPA had
provided bilingual information to the community.  EPA officials noted
that for high-profile or controversial sites, the agency has (1)
provided open houses or conducted meetings at which people can talk
to agency officials individually, (2) issued flyers and monthly
newsletters, or (3) made public service announcements.  In spite of
these extra efforts, residents still believe that their input is not
considered, the cleanup process is too slow, and health and property
values in their community are in jeopardy. 


      INFORMATION WAS NOT UPDATED
      ONCE CLEANUP BEGAN
---------------------------------------------------------- Letter :5.5

Several residents said they did not receive ongoing information once
cleanup was under way at their sites.  For example, at the
Montclair/West Orange radium site in Essex County, New Jersey, one
resident complained that EPA did not provide information to him while
the cleanup was under way because his home is not contaminated. 
Although he did not have to relocate, the noise and dust from heavy
equipment, demolition, and construction activities affected his well-
being.  (See fig.  1.) EPA could also have allayed the concerns of
two residents at the South Bay asbestos site by providing better
information during the ongoing site cleanup and removal of the
contaminated levee.  These residents said they feared that their
homes would flood again after the contaminated levee was removed. 
They were unaware that EPA intended to rebuild the levee with clean
soil.  EPA's failure to inform them about this aspect of the cleanup
created needless anxiety.  (See fig.  2.)

   Figure 1:  Removal of
   Contaminated Soil From Under
   Houses in Essex County, New
   Jersey

   (See figure in printed
   edition.)

   Figure 2:  Workers Covering
   Contaminated Levee Soil Being
   Removed From the South Bay
   Asbestos Site in Alviso,
   California

   (See figure in printed
   edition.)

While EPA is not required to conduct any formal community relations
activities during the actual site cleanup, EPA officials agreed that
such activities are often helpful and necessary.  In fact, some EPA
officials with whom we spoke said that they continue community
outreach during this phase.  For example, EPA officials in two
regions said that they issue fact sheets to keep the public informed
during and at the completion of the remedial action. 


      HIGH STAFF TURNOVER MAKES
      COMMUNITY RELATIONS
      DIFFICULT
---------------------------------------------------------- Letter :5.6

The high turnover rate of EPA's community relations and technical
staff contributed to residents' frustrations and caused a lack of
continuity and staff knowledge about sites.  Residents we met with at
several sites stated that they were often confused about whom to
contact because of staff turnover.  A woman living near the Texarkana
site said that she had had contact with three different coordinators
since activities began at the site.  Several residents also
complained to us that coordinators and managers of remedial projects
were not able to answer their questions.  We found similar problems
in the course of our review.  At three of the sites we visited,
coordinators could not answer some of our questions because of the
short time they had been associated with the sites. 

EPA community relations officials concur that staff turnover has been
high in the program.  They attribute this turnover to the lack of
opportunities for promotion as well as the sometimes stressful
situations in dealing with the public.  Coordinators and managers
told us that they have encountered angry people threatening them,
picketing, or blocking site entrances.  However, EPA officials said
that even with a more stable work force and fewer sites assigned to
each coordinator, some cleanup decisions would still be
controversial. 


   CONCLUSIONS
------------------------------------------------------------ Letter :6

Although EPA had, for the most part, carried out the required
Superfund community relations activities at the sites we reviewed,
residents were still not satisfied with EPA's efforts.  The residents
we spoke with stressed that EPA needs to reach out earlier to
communities and to continue that outreach throughout the cleanup
activities.  We agree that earlier and more complete community
outreach would improve EPA's community relations efforts.  In the
face of residents' concerns about health and property values around
Superfund sites, EPA's best community relations efforts may not earn
public trust or result in consensus about cleanup decisions.  The
need for effective and ongoing communication with community members
at Superfund sites will grow more pressing in the next few years as
more sites reach cleanup status and/or undergo long-term cleanup
procedures that could last indefinitely.  Conducting the required
outreach activities from the time that EPA first becomes actively
involved in investigating a site through completion of the cleanup
could help ensure that EPA's community relations goals are met. 

We recognize that the heavy work load and turnover of the community
relations coordinators hampers EPA's achievements.  This dilemma is
not likely to be resolved quickly because community relations
activities must compete for scarce Superfund dollars with site
cleanup efforts, research into new cleanup technologies, and other
program needs.  Additional resources would likely be needed to carry
out some community relations improvements, such as the increased
opportunities for community input requested by residents we
interviewed and envisioned in the administration's proposed Superfund
bill.  Nevertheless, many of the residents' complaints cannot be
blamed on the agency's resource constraints.  For example, more
understandable presentation of technical information in fact sheets
and at meetings does not require additional resources.  To ensure the
maximum benefit from the resources it has for community relations,
EPA must aggressively seek communities' input into decisions early
and throughout the process; make public notices as accessible as
possible; pay more attention to information, concerns, and
suggestions offered by residents; and explain in simple language the
technical reasons for cleanup decisions, especially at sites where
residents are in disagreement. 


      RECOMMENDATIONS
---------------------------------------------------------- Letter :6.1

We recommend that the EPA Administrator direct the agency to take the
following actions: 

  Include the community in cleanup decisions from the time of EPA's
     earliest active involvement in a site through completion of the
     cleanup by requiring public meetings, the creation and updating
     of mailing lists, and opportunities for public comment. 

  Explore ways to ensure that the information repositories are more
     useful and accessible to the public and maintained in a way so
     that documents are publicly available. 

  Make public notices available to a broader segment of the public by
     redesigning them to make them more visible in newspapers and
     printing them in local newspapers where available. 

  Assess the benefits of routinely performing readability assessments
     of fact sheets and other documents intended for the general
     public to make these documents less technical and accessible to
     a broader segment of the public. 

  Assess the current and future work loads of community relations
     staff to ensure that the work loads are reasonable and develop a
     plan to help minimize turnover. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :7

We discussed a draft of this report with the Chief of the State and
Local Coordination Branch, the Chief of the State Involvement
Section, the National TAG Coordinator, and the National Community
Relations Coordinator in EPA's Office of Solid Waste and Emergency
Response, who generally agreed with the facts presented.  We
incorporated their suggested revisions where appropriate.  EPA also
said that any recommendation to expand community involvement
activities to such early points as site discovery could create a
demand for limited Superfund resources that would be difficult to
meet.  As requested, we did not obtain written agency comments on the
draft report. 


---------------------------------------------------------- Letter :7.1

As agreed with your offices, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter.  At that time, we will
send copies to the Administrator, EPA.  We will also make copies
available to others on request. 

This work was performed under the direction of Peter F.  Guerrero,
Director, Environmental Protection Issues, who can be reached on
(202) 512-6112 if you or your staff have any questions.  Major
contributors to this report are listed in appendix X. 

Keith O.  Fultz
Assistant Comptroller General


SOUTH BAY ASBESTOS SITE, ALVISO,
CALIFORNIA - REGION IX
=========================================================== Appendix I


      BACKGROUND
------------------------------------------------------- Appendix I:0.1

The South Bay asbestos site includes portions of the 14-square-mile
community of Alviso, built on shorelands near San Jose at the
southern end of the San Francisco Bay.  Tidewater marshes surround
Alviso, and tidal waterways separate it from San Jose.  Alviso has a
long history of flooding, in part as a result of the pumping of
groundwater for agricultural purposes, which has caused the land in
Alviso to settle to about 3 feet below sea level.  The community
includes about 2,200 residents, about 85 percent of whom speak
Spanish, as well as local industries. 

Asbestos, a known human carcinogen, poses the major health risk at
this Superfund site.  Fill used to raise low-lying areas contained
asbestos.  Additionally, after major flooding in Alviso in 1983, San
Jose had a levee built around Alviso to divert flood waters and
provide flood protection.  The levee soil included serpentine rock
containing naturally occurring asbestos fibers.  After California
officials discovered asbestos during a routine permit inspection of
construction work, the site was listed on the National Priorities
List (NPL) in October 1984.  San Jose and the construction company
that built the levee have been identified as the responsible parties
and have agreed to carry out site cleanup. 


      CLEANUP REMEDY AND SITE
      STATUS
------------------------------------------------------- Appendix I:0.2

In 1985, the Environmental Protection Agency (EPA) completed
emergency response activities to reduce exposure to asbestos fibers
in airborne dust by paving part of the schoolyard and an unpaved road
that carries heavy truck traffic.  Additionally, a temporary dust
suppressant has been sprayed on the levee annually since 1986. 

Following the completion of the site study in December 1988, EPA
divided the site into two areas for cleanup:  (1) the levee and (2)
the general site, which included other contaminated parts of the
community.  The levee cleanup plan called for covering most of the
levee with clean soil and native vegetation and capping the rest with
a concrete-like substance.  After citizens expressed concern about
the aesthetics and safety of the capped portion, EPA amended the
remedy to use soil and vegetation to cover the entire levee.  After
negotiations with the responsible parties, EPA amended the cleanup
plan again in 1991 to include the eventual removal of the levee,
appropriate disposal of the levee material, and restoration of
wetlands covered by the levee.  Warning signs were also installed
along the levee, and a portion across the street from the elementary
school was fenced to preclude its use as a shortcut by students
walking home from school.  In the fall 1993, the levee was removed
and replaced with a new levee of clean fill dirt.  The cleanup plan
for the general site included paving contaminated yards and
wet-sweeping Alviso streets monthly to control dust, imposing
inspections and deed restrictions on landfills, and routine site
monitoring to ensure protection of public health. 


      EPA'S COMMUNITY RELATIONS
      ACTIONS
------------------------------------------------------- Appendix I:0.3

EPA has completed most of the community relations activities in
Alviso, including developing a community relations plan, establishing
information repositories, holding public meetings and comment
periods, and providing information to the public.  In March 1993, EPA
revised the community relations plan and noted that many of
residents' concerns mentioned in the original November 1986 plan were
still relevant.  In addition to performing the required activities,
EPA translated fact sheets into Spanish and provided simultaneous
bilingual interpretation for meetings with residents.  EPA also
conducted an education program through the elementary school,
staffing an information booth at a PTA meeting and using assemblies
and student information packets to warn children and their parents of
the dangers of playing on the levee.  Finally, EPA established a
toll-free number for residents to contact the agency and extended
comment periods to provide residents with additional time to make
their views known. 

On June 22, 1992, EPA awarded a $50,000 technical assistance grant
(TAG) to the Organizaciï¿½n de la Comunidad de Alviso to hire
independent technical advisers to help citizens understand and
comment on technical factors in cleanup decisions that affect the
community. 


      RESIDENTS' CONCERNS AND
      SUGGESTIONS
------------------------------------------------------- Appendix I:0.4

Although EPA has generally completed the required community relations
activities and undertaken additional ones, the nine residents and two
business owners with whom we spoke were generally frustrated by EPA's
lack of responsiveness and the highly technical nature of the
information that EPA provided.  Several residents expressed concern
about the possible health effects of asbestos, slow pace of the
cleanup, and impact of the site's designation as a Superfund site on
property values. 

These residents said that EPA staff mean well but don't listen to
suggestions from the community.  To decrease dust, one resident asked
for signs barring trucks from using Alviso as a shortcut to the local
landfill, but instead got warning signs on the levee.  The residents
we talked with were also concerned about asbestos dust in their
homes; one said that EPA has refused to test this dust.  Furthermore,
two residents said they have told EPA about holes in the levee as a
result of squirrels digging, and one added that spraying the levee
for dust control is ineffective because the local squirrels start
digging holes before EPA has even finished spraying.  One resident
also said that EPA has done nothing about street sweepers' dumping
dust in piles at the edge of the marshland, from where it blows back
into the community.  Another resident said she has also notified EPA
staff about possible environmental violations by some businesses in
the community, but that they were not interested.  According to these
residents, their complaints to EPA and San Jose are not listened to. 

Several residents with whom we spoke raised questions about the
responsiveness of EPA staff.  While EPA staff visit about once a
year, residents said that little has happened with the site cleanup
until recently.  The director of the TAG group suggested that more
frequent contact with residents would be helpful.  Furthermore, one
resident said that staff turnover has caused problems because EPA
staff give different answers to questions.  Both residents and
business owners complained that EPA staff have not returned their
phone calls or responded to their requests for information.  For
example, one resident said that after he repeatedly asked EPA to send
him the results of asbestos sampling performed on his family's
property, he has hired an attorney to help him obtain the information
but still doesn't have it. 

These residents voiced a number of health and other concerns about
the levee removal, which was occurring at the time of our visit. 
They said that over the years, EPA had told them to take precautions,
such as wet-mopping the inside and hosing down the outside of their
homes to avoid contact with asbestos.  However, they were confused
because EPA said they didn't need to close doors and windows or stay
indoors during the levee removal.  One resident noted that workers
were dressed in moonsuits, but that children played and residents
watched the removal just across the street with no protection.  Two
other residents we interviewed were fearful about the removal of the
levee because of the approaching rainy season and the possiblity of
flooding without the levee.  They were unaware that the levee was
being replaced with clean fill until we explained this to them. 

The residents we met with said that EPA has provided a lot of
information but that much of it, including the fact sheets, is too
technical and is therefore hard for many of them to understand.  The
fact sheets about the site are also sometimes outdated.  For example,
one resident said that the fact sheets given out at a school ice
cream social were about 6 months old.  Two residents suggested that
fact sheets would be helpful if they were less technical and issued
more frequently.  Some residents did, however, acknowledge the
usefulness of EPA's translating documents and meetings for the
largely Spanish-speaking population. 

EPA established information repositories within the community at the
local public library and the Family Health Foundation.  The director
of the group that holds the TAG and a few residents with whom we
spoke had used the repositories, but the director noted that
photocopying costs are high.  We readily located the documents in the
library, although we were unable to find the community relations plan
or any information notifying residents about the TAGs.  The librarian
said that some files were in a shed because of a shortage of space at
the one-room library. 

Several residents who participated in our focus group and two local
business owners expressed concern about an environmental lawsuit
filed against local businesses by the group that has the TAG and the
Environmental Law Foundation.  Some residents said that while they
were also concerned about health issues and the businesses, they did
not like the divisive effect the lawsuit was having on their
community and questioned the extent to which the TAG group informs
and represents the community as a whole.  Some residents and business
owners also raised questions about whether the TAG moneys were being
used to help fund the lawsuit against local businesses.  We have
referred questions raised about the use of TAG moneys's to EPA's
Office of Inspector General for review. 


MONTCLAIR/WEST ORANGE RADIUM SITE,
ESSEX COUNTY, NEW JERSEY - REGION
II
========================================================== Appendix II


      BACKGROUND
------------------------------------------------------ Appendix II:0.1

The Montclair/West Orange radium site is one of two NPL sites located
in suburban Essex County in northeastern New Jersey:  32,000 people
live within a mile of the two sites.  The site covers approximately
39 acres, and about 350 homes in older, well-established residential
neighborhoods.  Numerous homes and surrounding areas are contaminated
with radioactive wastes. 

Many residents have lived in the area for over 30 years, but younger
families have moved to the area in search of affordable and
convenient housing.  The once highly industrialized region has
maintained a small, yet diverse, manufacturing and service base. 
Land use has shifted since the 1950s to include fewer new industries
and more residential properties. 

In 1979, the New Jersey Department of Environmental Protection began
a program to identify and investigate former radium-processing
facilities within the state.  Concerned about possible off-site
disposal of radium by-products and waste material, New Jersey
requested that EPA conduct an aerial survey to detect any areas with
elevated levels of gamma radiation.  EPA's 1981 survey of Essex
County identified approximately 53 areas of possible radioactive
contamination.  After further investigation, New Jersey and EPA
identified the three communities of Montclair, West Orange, and Glen
Ridge as possibly containing radioactive waste material.  New Jersey
selected 12 homes for initial cleanup, relocated nine families, and
began excavation.  Cleanup consisted of removing radioactive soil,
which sometimes involved tearing up yards, driveways, and basements. 
When New Jersey exhausted its cleanup funds after resolving soil
disposal problems, it abandoned the project, leaving the cleanup of
four homes unfinished.  According to an EPA official, three of the
four homes eventually had to be demolished.  The residents, who had
moved out with the promise of being able to return to their homes,
were permanently relocated. 

According to an EPA official responsible for the site, all
credibility within the community was lost by the time the site was
returned to EPA for cleanup and community outreach.  The angry
community residents considered the state and federal governments to
be one and the same.  During the time when the state was responsible
for work at the site, EPA maintained oversight of community relations
activities. 


      CLEANUP REMEDY AND SITE
      STATUS
------------------------------------------------------ Appendix II:0.2

As a result of EPA's phased approach for this site, some homes are
undergoing cleanup while others are still in the cleanup design
phase.  EPA has completed construction for the second of five cleanup
phases and has a small amount of restoration remaining for this
phase.  EPA has linked its community relations activities to
activities in progress, such as design efforts, construction of the
remedy, the relocation of residents, and the restoration of the
houses.  The pilot project phase targeted the 4 homes mentioned above
plus 10 other properties; the first phase targeted 40 properties in
West Orange and Glen Ridge (the nearby site); the second and third
phases target an additional 80 and 54 homes, respectively; while the
final phases target the remaining approximately 50 contaminated homes
in the area.  EPA has subcontracted with the U.S.  Army Corps of
Engineers to oversee the relocation of families and the cleanup. 


      EPA'S COMMUNITY RELATIONS
      ACTIONS
------------------------------------------------------ Appendix II:0.3

According to a 1992 revised community relations plan and the
Community Relations Coordinator, EPA has completed the community
relations activities in Montclair and West Orange.  In addition to
developing the community relations plan, EPA has established
information repositories, provided information to the public, and
held public meetings and comment periods.  The plan, which EPA
revised for the cleanup design and actual cleanup phases, noted that
residents' concerns mentioned in the original plan were still
relevant.  These concerns included the potential health effects of
long-term exposure, dust dispersed during soil removal, and eating
garden vegetables; the negative effects on residential property
values and the area's tax base; anxieties about soil disposal,
temporary relocation, and property damage during cleanup; and a lack
of access to information.  The plan stated that most concerns about
health effects had diminished.  According to an EPA official, the
agency has gone beyond the mandated community relations activities by
meeting with families individually at different phases of the project
to discuss site issues, as well as to address each resident's unique
concerns. 

EPA gives the site high priority and views it as one of its
successful community relations sites.  In addition, EPA has
established a contact office in Montclair to improve communication at
the two sites in the area.  According to an EPA official, the
Community Relations Coordinator and/or the Remedial Project Manager
are located on-site four days a week.  This EPA official also told us
that this on-site office is the only one of its kind that EPA has set
up in New Jersey. 


      RESIDENTS' CONCERNS AND
      SUGGESTIONS
------------------------------------------------------ Appendix II:0.4

We spoke with three West Orange residents who lived on a dead-end
street where 10 homes were located.  Two of these residents were
relocated temporarily during cleanup activities.  EPA did not
consider the third resident to be an "affected" citizen since his
home was not contaminated and he did not have to relocate.  He was
upset because although his home was not contaminated, he had to
contend with torn up streets and with noise and dust resulting from
heavy equipment, street sweepers, and work crews that were placing
steel pilings into the ground.  He stated that EPA did not notify him
about the work that needed to be done until after the fact and
provided very vague information.  He also said that the contractor
performing the work would not provide any answers to his questions. 
He felt that he had a fair knowledge about the site, but, he said, it
was only because he asked for information. 

The two other West Orange residents we spoke with felt that although
EPA provided their community with an opportunity to provide input to
the cleanup decision, the federal government was going to do whatever
it wanted no matter what they said.  These two residents also felt
that EPA had adequately informed them about the extent of
contamination.  One resident considered the home renovations to be
excellent.  In general, these residents felt that EPA was very
helpful to individuals but not to the community as a whole. 

According to the Chairman of the Montclair Radon Task Force, EPA is
good about providing information in the form of newsletters. 
However, in his view, EPA's efforts usually come too late.  He also
stated that the Corps of Engineers lacks sensitivity and expertise in
providing assistance to families to be relocated.  He added that high
staff turnover within EPA and other government offices involved with
the site has been disruptive. 

According to the Chairman of the Montclair Radon Task Force, although
EPA offered the group a TAG, the task force declined to apply for the
grant.  The task force believed its members had enough expertise to
understand the information EPA provided to the community. 


EWAN PROPERTY DUMP, BURLINGTON
COUNTY, NEW JERSEY - REGION II
========================================================= Appendix III


      BACKGROUND
----------------------------------------------------- Appendix III:0.1

Ewan Property Dump is situated over a major source of drinking water. 
The 43-acre site, located in the New Jersey pinelands, is surrounded
by forest, agricultural land, and residential areas.  Residential
developments are located both north and east of the site.  Private
wells provide drinking water for about 250 area residences. 

In 1982, local residents discovered and reported the site to the
Burlington County Health Department and the New Jersey Department of
Environmental Protection.  The site was investigated by Burlington
County in September 1982, by New Jersey in December 1982, and by EPA
in September 1984.  EPA added the site to the NPL in September 1983
and began the site study in 1985. 

EPA concluded that one 4-acre area on the site contained
approximately 500 to 8,000 drums of industrial waste that had been
buried from 1974 to 1975.  Automotive undercoating, paint residues,
and other products were buried in trenches and covered with dirt. 
However, as the ground settled, the drums became exposed.  During the
December 1982 inspection, officials from New Jersey sampled the
exposed drums, and test results showed the presence of heavy metals,
volatile organic substances, and polynuclear hydrocarbons.  In March
1983, New Jersey directed the property owner to clean up the site. 
The owner denied knowledge of the dumping and, therefore, would not
take responsibility for the cleanup.  However, EPA has identified and
notified approximately 30 potentially responsible parties.  EPA has
ordered 17 parties to remove contaminated materials and drums.  EPA
is overseeing these activities to ensure that they are conducted in
accordance with existing laws and regulations. 

During the summer of 1983, New Jersey installed five monitoring
wells.  Analysis of the drum liquids, soil samples, and samples from
the monitoring wells showed contamination.  New Jersey was concerned
that the drums might leak and contaminate the area's sole source of
groundwater, so the state requested the immediate removal of the
drums in December 1983.  However, EPA determined that the site did
not meet the requirements for an immediate removal action because
there was no immediate health threat. 

Since the site was discovered, local residents have actively pursued
local, state, and federal help in controlling the problem.  Residents
living in local developments have held meetings, signed petitions,
and written letters to the agencies and to elected officials in an
effort to promote government action on the site.  Soon after the
site's discovery, residents went onto the site and dug up some drums
to try to determine how many were buried there.  The residents have
also worked with the Coalition Against Toxics, an environmental
group. 


      CLEANUP REMEDY AND SITE
      STATUS
----------------------------------------------------- Appendix III:0.2

According to EPA officials, EPA divided the cleanup of the Ewan
Property site into two phases.  The first phase, which was in
remedial design during our spring 1993 visit, addresses the buried
drums and the heavily contaminated soil nearby.  Activities in this
phase include, among other things, providing a buffer zone and
constructing an access road and site facilities.  At the time of our
visit, EPA expected cleanup to begin sometime in April 1993.  The
second cleanup phase, which is scheduled to begin after the first
phase is complete, will address groundwater contamination and less
contaminated soil. 


      EPA'S COMMUNITY RELATIONS
      ACTIONS
----------------------------------------------------- Appendix III:0.3

EPA has completed the community relations activities at the site,
including developing a community relations plan, establishing an
information repository, holding public meetings and comment periods,
and providing information to the public.  According to the site's
April 1985 community relations plan, the residents' primary concern
is getting the site cleaned up.  The plan also stated that residents
believe that the site is a "blight" on their community and that homes
have decreased in value by 10 to 15 percent since the site was
discovered.  Some residents were also concerned about the future
quality of drinking water from private wells.  Finally, the plan
indicated that the residents' more general concerns are knowing how
many drums are buried at the site and whether there are any health
risks associated with the contaminants found on the site. 


      RESIDENTS' CONCERNS AND
      SUGGESTIONS
----------------------------------------------------- Appendix III:0.4

Although EPA met the community relations requirements and provided
other requested services, residents are still not satisfied with
EPA's activities at the site, according to our interviews with seven
people in the community.  Some of the residents we interviewed feel
that EPA operates in a reactive mode; that is, EPA personnel provide
information only if residents telephone to complain.  Some of the
residents we interviewed also feel that there is no one on-site they
can approach with their concerns or contact in case of an emergency. 
Some of these residents said they do not trust EPA and that EPA does
not consider their comments and suggestions. 

According to township officials, EPA did not initially respond to the
township's and community's concerns about the migration of
contaminated groundwater, the impact on traffic, and fire safety. 
The township's solicitor stated that at one point, the township's
committee was pressing for legal action because it was concerned
about groundwater migration and the impact of trucks on rural
traffic.  EPA did not talk to the community or the township early in
the process to obtain information about their concerns.  He also
stated that EPA needs to recognize the importance of early community
involvement.  One local fire official said his department initially
resorted to threatening not to respond to site emergencies if EPA did
not provide information about site activities and contamination.  He
added that his relationship with the current EPA staff is good and
that he knows what the plans are for the site. 

As noted in the community relations plan, residents are still
concerned about getting the site cleaned up and the impact of the
site on their property values and their ability to sell their homes. 
Residents stated that they would like for EPA to provide information
on a regular basis, preferably quarterly.  According to information
provided by EPA staff, community residents requested this during a
series of public meetings in the fall of 1992.  EPA has been
providing site information on a quarterly basis since that time. 

Three of the residents we spoke with could not recall EPA's providing
information on TAGs.  One resident stated that she had heard about
TAGs from another source and requested the brochure on the grants. 
In her view, the brochure was not very clear and further explanation
was needed.  According to EPA's records, the agency informed the
community about TAGs during a public meeting in 1989. 

According to EPA personnel, their relationship with community
residents is very fragile, and they have been working to improve the
situation by meeting residents' demands to the extent possible.  The
residents requested that EPA provide a buffer zone between the
residential development and the access road to reduce the noise level
caused by trucks going in and out of the site.  The residents also
requested that EPA build the access road 50 feet from the original
road, which currently borders a residential development.  However,
some of the residents we interviewed do not feel that their
suggestions for alternative access roads to the site were taken into
consideration.  In addition, residents asked EPA to put a fence up
between the residential development and the access road used by the
trucks to transport hazardous wastes in order to ensure the safety of
children and the public, but the road is still not completely fenced
in. 

Some of the residents we spoke with also stated that unlike current
EPA personnel, past personnel were unresponsive to the community's
needs and concerns.  Residents noted that past EPA personnel also (1)
gave residents the impression that they did not want to be at the
public meetings, (2) were not very informative, and (3) did not
relate well to the public. 

According to EPA officials, the site has also had problems with
vandalism and with union picketers protesting the fact that nonunion
employees were working at the site. 


TEXARKANA WOOD PRESERVING COMPANY
SITE, TEXARKANA, TEXAS - REGION VI
========================================================== Appendix IV


      BACKGROUND
------------------------------------------------------ Appendix IV:0.1

The Texarkana Wood Preserving Company site is located in the extreme
northeast corner of Texas, just south of the city limits of
Texarkana.  Texarkana, the largest city in Bowie County, is located
178 miles east of Dallas on the Texas/Arkansas state line.  The
Texarkana site has been used for wood preserving operations since the
early 1900s.  The entire site is located on the 100-year floodplain
of Days Creek.  About 1,000 people live within a 1-mile radius. 

The Texarkana site covers approximately 25 acres and consists of
surface holding areas for liquids, processing areas, and former work
areas.  Low areas that tend to be swampy lie just north of the main
processing area and in the southeast corner of the site. 

The soil surrounding these areas and the shallow groundwater are
contaminated with the wood preserving wastes pentachlorophenol and
creosote, as well as with mercury and dioxin.  Pentachlorophenol is
one of the most heavily used pesticides in the United States.  Animal
studies indicate that short-term high-level exposure to
pentachlorophenol can damage the liver, kidneys, skin, lungs, nervous
system, and gastrointestinal tract.  Animals exposed to this chemical
show an increased risk of cancer.  Creosote is primarily made up of
polynuclear aromatic hydrocarbons, some of which are considered
probable carcinogens. 


      CLEANUP REMEDY AND SITE
      STATUS
------------------------------------------------------ Appendix IV:0.2

EPA selected incineration as the remedy to be used to treat
contamination in the soil and shallow groundwater at Texarkana.  This
method will be used to eliminate contaminants from 77,000 cubic yards
of soil and 16 million gallons of groundwater.  At the time of our
meetings with Texarkana and Arkansas officials, the design of the
remedy was almost complete. 


      EPA'S COMMUNITY RELATIONS
      ACTIONS
------------------------------------------------------ Appendix IV:0.3

EPA has completed most of the community relations activities in
Texarkana, including developing a community relations plan,
establishing information repositories, holding public meetings and
comment periods, and providing information to the public.  Although
EPA fulfilled these requirements, the 10 residents we spoke with were
dissatisfied because they felt they were not made a part of the
cleanup process.  They said that EPA had not involved them early
enough, that mailing lists were incomplete, that the information
repository is not easily accessible and/or available, that EPA is
unresponsive, and that the selected remedy (incineration) is
unacceptable. 

The comments that EPA received from residents during the comment
period led the agency to believe that the public supported
incineration as the remedy but preferred off-site incineration. 
However, the summary of the public comments on the proposed remedy
prepared by EPA states that Texarkana residents thought that
incineration would adversely affect the health of those who live in
the area. 


      RESIDENTS' CONCERNS AND
      SUGGESTIONS
------------------------------------------------------ Appendix IV:0.4

Although EPA has generally completed the required community relations
activities, the residents with whom we spoke were frustrated by EPA's
unresponsive behavior and lack of outreach.  These residents distrust
EPA, believe they were not involved early enough in the cleanup
process, and worry that incineration may endanger their health. 

The residents we spoke with thought that EPA did not conduct early
and thorough outreach when beginning community relations activities
at this site in 1988.  The Arkansas residents noted that EPA did not
contact them during its initial outreach efforts even though site
activities would also affect them.  Three residents said that they
had personally canvassed their area to determine how many people knew
about site-related activity and found that most people and
institutions--such as an elementary school, churches, and a day care
center--had not been informed.  The residents sent EPA a list with
the names of approximately 2,000 individuals who live near the site,
but they still did not receive any information.  EPA added the names
to the updated mailing list in 1992. 

According to these residents, their complaints led the Arkansas
Attorney General to file a complaint arguing that EPA had violated
certain community relations requirements by failing to (1) notify
Arkansas state officials and residents and (2) conduct a study that
adequately assessed the proposed remedy of incineration.  This suit
was dismissed in 1993 because the parties agreed to resolve their
dispute out of court.  Incineration has not yet begun at the site. 

The residents also complained that the repository is located in the
genealogy section of the public library, a heavily used section. 
They believe that the library does not have the space or the staff to
maintain the repository.  For example, the residents told us that
envelopes and packages of information on the site that are shipped to
the library are not filed, but remain on the shelves.  Some of these
residents said they had spent thousands of dollars in telephone
calls, time, labor, and research at the library just trying to keep
up with technical information.  Some of the residents said that
documents are all mixed up and that no one in the library has any
idea where anything is. 

During our review, we found the Texarkana repository overwhelming. 
We counted 62 microfiche cards related to EPA's decision to use
incineration alone; another shelf was full of microfiche cards on
other related site documents.  Each microfiche card could contain
20-30 pages of text.  The library has two microfiche viewers, but
only one has photocopying capability.  The charge is 25 cents per
page to make a photocopy. 

Most of the residents we spoke with stated that they believe that
emissions from the on-site incinerator will somehow harm their
health.  Residents stated that in this area, the winds blow to a
greater degree towards Arkansas.  Some of these residents believe
that they have already been affected by the site, and they are
concerned about their children's illnesses. 

Other residents also expressed concern that EPA did not choose
another cleanup technology.  A local businessman is marketing a
remedy that he states will do the job just as effectively as
incineration with less threat to the general public.  The residents
we talked with have presented this option to EPA, hoping the agency
will change the selected remedy. 


TRI-COUNTY LANDFILL, SOUTH ELGIN,
ILLINOIS - REGION V
=========================================================== Appendix V


      BACKGROUND
------------------------------------------------------- Appendix V:0.1

Tri-County Landfill is a 46-acre inactive landfill that was used for
solid waste disposal from April 1968 until December 1976.  A prairie
path separates Tri-County from an active landfill.  The rural
community of South Elgin, which has a population of over 7,000,
includes a mix of agricultural activities and light industrial,
commercial, and residential developments. 

The primary public health and environmental concern is that
contamination from the landfill could leach into the groundwater that
supplies local drinking water wells and adversely affect nearby
surface waters, such as the Fox River.  Public water supply wells are
located within 1 mile of the site, and rural residents use private
wells.  Residents use the Fox River for recreational activities, such
as fishing, boating, and swimming. 

Beginning in 1971, residents living nearby have filed several
complaints against Tri-County with the Illinois Environmental
Protection Agency.  The complaints concerned the appearance of
surface water contamination and the potential for drinking water
contamination.  Several residents and local officials had also
observed suspicious late night and early morning dumping at the
landfill. 


      CLEANUP REMEDY AND SITE
      STATUS
------------------------------------------------------- Appendix V:0.2

EPA proposed a cleanup plan for Tri-County in July 1992.  This plan
included a combination of remedies for the various contaminated
media:  draining standing surface water on the landfill and a small
portion of the wetland area to the south; consolidating contaminated
sediments and the drill cuttings stored in drums in the landfill
area; and, finally, capping the landfill.  The landfill cap will
consist of 2 feet of permeable clay topped by 8 inches of topsoil to
support vegetation.  A groundwater collection system will be
installed to collect contaminated groundwater as it leaves the site. 
Contaminated groundwater located off-site will not be collected, even
if it is contaminated above EPA's maximum allowable levels.  The
cleanup remedy also includes an active collection system to capture
landfill gases.  The remedy also includes institutional controls,
such as site fencing, deed restrictions, and a groundwater monitoring
program.  Currently, the site is in the final design stage. 


      EPA'S COMMUNITY RELATIONS
      ACTIONS
------------------------------------------------------- Appendix V:0.3

EPA has completed most of the community relations activities at the
Tri-County site, including developing a community relations plan,
establishing an information repository, holding public meetings and
comment periods, and providing information to the public. 


      RESIDENTS' CONCERNS AND
      SUGGESTIONS
------------------------------------------------------- Appendix V:0.4

On June 30, 1993, we held a focus group discussion with 10 community
residents regarding EPA's community relations program.  The residents
with whom we spoke were frustrated about the slow pace of the
cleanup, the overwhelming nature of the information in the
repository, and a lack of information from EPA.  The 10 residents we
spoke with thought that the Superfund cleanup process was too lengthy
and that EPA generally moved too slowly.  These residents stated that
EPA is wasting too much time doing additional studies of the site
when enough studies have already been done.  One resident stated that
when she moved into her house 16 years ago, the real estate agent and
other homeowners told her that Tri-County, which is visible from her
kitchen window, would be a park in just 2 years.  Another resident
said that, after feeling ignored by county and state environmental
officials, they had hoped that EPA would help them.  However, their
requests for information on the Tri-County Landfill site were either
ignored or unanswered by EPA.  Of the 10 residents who participated
in our discussion, 7 residents had filled out requests to have their
names placed on EPA's mailing list.  Only three of these seven
residents received information from EPA.  One resident recalled
writing several letters, but she never received any response and was
not placed on the mailing list.  Another resident stated that because
of the lack of two-way communication, residents believed they had no
input to the decision-making process. 

Residents who had used the information repository thought it was not
very useful, either because the information was not easily accessible
or because they could not understand the information.  One resident
mentioned that in the past it was difficult to use the repository
because it was kept in closed stacks, which meant materials could
only be retrieved with the assistance of the librarian.  After
searching through volumes of information, this resident finally
called the remedial project manager and requested specific chapters
of the documents he could not locate.  The project manager then sent
the requested chapters to the resident.  Another resident said he
spent more than $24 photocopying information on the site but could
not interpret the information. 

Some of the residents we talked with were aware of the availability
of TAGs to hire independent experts to help them understand the
technical aspects of the cleanup but were unable to get additional
information.  One resident said that she called her Senator and
Congressman to inquire about the grants; when she was told that there
were no such grants, she did not ask EPA. 

These residents believe that the turnover of EPA staff is another
barrier to communication with the community.  They stated that from
one meeting to the next, they encountered a new group of EPA
personnel to deal with.  They believe that when turnover is high,
progress is upset and nothing gets accomplished.  In one example they
cited, two attorneys who represented EPA at a public meeting could
not answer technical questions.  Another resident also complained
that the allotted time to speak during a meeting (5 minutes) was not
enough. 

According to these residents, EPA is at a disadvantage when dealing
with the massive garbage industry in nearby Chicago.  One resident
referred to EPA as David and the garbage industry as Goliath.  The
residents expressed concern that EPA does not have the resources to
fight industry.  One resident stated that the landfill operator's
rights were being protected to a greater degree than those of the
residents. 

The residents we spoke with suggested several ways in which EPA could
improve its community relations program.  First, they said EPA should
provide a layman's summary of the information, especially the very
technical information, given at public meetings.  They believe that
if EPA holds a meeting, it should provide the public with
understandable information.  These residents felt inadequately
prepared to comment on remedies and other site decisions because they
had difficulty understanding the technical information.  One resident
thought that roundtable or small group discussions would be more
productive than the format EPA uses.  The residents also believe that
potentially responsible parties should not be invited to public
meetings because they are accompanied by their lawyers, and the
residents feel too intimidated to ask questions.  Finally, these
residents suggested that EPA be required to generate reports, either
quarterly, semiannually, or annually, describing the status of the
cleanup and other relevant activities. 


BRIO REFINING, INC., SITE, HARRIS
COUNTY, TEXAS - REGION VI
========================================================== Appendix VI


      BACKGROUND
------------------------------------------------------ Appendix VI:0.1

The Brio Refining, Inc., site is located in southern Harris County,
approximately 20 miles southeast of Houston, Texas.  The Brio site
occupies about 58.1 acres.  The area is heavily populated, with about
5,800 people living within a mile of the site.  Residences,
businesses, a hospital, and a school are located within a half mile
of the site. 

An oil refinery and various owners operated at Brio between 1957 and
1982.  From 1957 to 1969, the major industrial operation included the
regeneration of assorted metals and recovery of chemicals.  In the
operation, pits were used to store both raw materials and process
wastes.  Between 500,000 and 700,000 cubic yards of soil on-site are
contaminated with hazardous materials, such as heavy metals, volatile
organic compounds, and fuel oil residues.  In addition, the
groundwater contains high levels of volatile organic compounds.  The
results of a site investigation conducted by the state of Texas led
EPA to propose the site for the NPL in October 1984.  The site was
added to the NPL in March 1989. 


      CLEANUP REMEDY AND SITE
      STATUS
------------------------------------------------------ Appendix VI:0.2

In June 1985, EPA and the responsible parties agreed to conduct a
site study with EPA's oversight.  In 1988, EPA proposed excavation
and incineration of contaminated soil as the remedy for the site. 
EPA held a public meeting on February 9, 1988, to accept public
comments on the proposed plan.  Approximately 350 people attended the
public meeting.  EPA then selected incineration as the method that
would best protect public health and the environment, finalizing the
cleanup decision on March 31, 1988.  On April 4, 1991, EPA and the
responsible parties signed a consent decree, an agreement detailing
how the selected remedy will be implemented at the site.  At the time
of this review, the remedial design had been completed and the
construction of the incinerator was near completion. 

The Agency for Toxic Substances and Disease Registry (ATSDR) has also
been actively involved in the cleanup.  ATSDR is determining any
health impacts of releases from the Brio site and advising EPA of any
health consequences of the site's remediation.  In February 1989,
ATSDR conducted a public health assessment on the site.  In 1990,
ATSDR funded a University of Texas School of Public Health review of
health findings from a local citizens' health survey and
environmental data for the site.  On the basis of the preliminary
health findings from that review, ATSDR is conducting a full health
investigation that consists of a cross-sectional symptom and illness
prevalence study and a reconstruction of the rates at which
congenital defects occurred in one subdivision near the site between
1981 and 1992.  Furthermore, in 1992, ATSDR established a Community
Assistance Panel, a group of 16 area residents, to help gather the
community's health concerns. 


      EPA'S COMMUNITY RELATIONS
      ACTIONS
------------------------------------------------------ Appendix VI:0.3

EPA has completed most of the community relations activities at Brio,
including developing a community relations plan, establishing the
information repository, holding public meetings and comment periods,
and providing information to the public.  On January 31, 1991, EPA
awarded a TAG to a group called Homes, Environment and Lives in Peril
to hire technical advisers to help citizens understand and comment on
the technical factors in the cleanup decisions.  A member of this
group noted that on numerous occasions, he had tried to get EPA to
meet with residents and the group's technical adviser to discuss
issues of concern, but EPA said such a meeting would be
time-consuming and expensive to plan and would lead to unproductive
discussion about the selected remedy.  An EPA official we spoke with
said that the agency had not held a public meeting since the site's
remedy was chosen about 2 years ago. 

EPA site officials said that community members openly oppose
incineration as the remedy and are concerned about groundwater
contamination and effects on health and property values.  Residents
had also been concerned about their children's attending the Weber
Elementary School, located in a subdivision adjacent to the site and
closed in 1991.  At the time of our review, the subdivision was
nearly empty, with few residents.  According to EPA, the citizens of
the subdivision have filed a class-action lawsuit, and the developer
is in the process of buying up their homes. 

In addition to EPA's community relations activities, a group of
potentially responsible parties, the Brio Site Task Force, has its
own community relations effort.  Since 1985, the task force has
conducted outreach activities to keep the community informed.  Task
force officials we spoke with said that they have been very
aggressive in conducting community relations activities such as
conducting community meetings, maintaining the information
repository, issuing fact sheets and press releases, and holding open
houses.  In addition, the task force established the Community
Leadership Group, which meets monthly to discuss issues of concern. 
The group's meetings, which are not open to the public, include
representatives from four subdivisions, two cities, a college, a
hospital, and the county government. 


      RESIDENTS' CONCERNS AND
      SUGGESTIONS
------------------------------------------------------ Appendix VI:0.4

On September 21, 1993, we held a focus group discussion with seven
community residents and spoke separately with two community leaders
regarding EPA's community relations program.  Although EPA generally
met key community relations requirements, most of the residents and
community leaders with whom we talked believe that EPA has not done a
good job at the site.  Five of the seven residents believe that the
site should have been investigated and cleaned up many years ago. 
One resident noted that when he first became interested in site
activities, he was confused about who worked for whom and what
everyone's role was in the cleanup.  Some residents said that the
newsletters distributed by the responsible parties were mistakenly
believed to be from EPA.  Another resident said that the telephone
number listed on the responsible parties' newsletters for additional
information was also assumed to be an EPA number and that they had to
call a long-distance number to contact officials in EPA's Region VI. 

Two residents and a community leader with whom we spoke said that EPA
was unresponsive to their requests for public meetings.  They said
that they had been asking EPA for the past 2 years to meet with the
community, but EPA refused.  They reported that EPA staff said that
it would take too much time away from their work.  However, according
to the residents, EPA staff usually attended the monthly meetings
sponsored by the responsible parties' Community Leadership Group. 
They did not understand why EPA staff had time to attend the
responsible parties' monthly meetings, which included only selected
members of the community, but did not make time to meet with the
general public. 

Two residents said that EPA should have conducted the site study
itself and not have allowed the responsible parties to do it even
though the study was conducted with EPA's oversight.  These residents
said that they did not trust the responsible parties to conduct the
study and propose how the site will be cleaned up since they were
responsible for contaminating the site.  They believed that EPA
should conduct the site study and select and implement the remedy,
while the responsible parties should just be responsible for the
cleanup costs. 

These residents suggested several ways in which EPA could improve
community relations.  In their view, EPA should first speed up the
cleanup process by setting some rigid timetables for completion of
specific cleanup activities.  Next, in cases in which a site is known
to be or can be expected to be controversial, EPA should take a
leadership role and decrease the role of the responsible parties.  At
these sites, EPA should conduct the site study, design, and remedy;
otherwise, EPA will not have the community's confidence.  At
difficult sites, EPA must also set up a local office as early in the
process as possible.  Finally, EPA should use other federal
government agencies that are already capable of doing research and
helping with the cleanup. 


REILLY TAR AND CHEMICAL
CORPORATION SITE, INDIANAPOLIS,
INDIANA - REGION V
========================================================= Appendix VII


      BACKGROUND
----------------------------------------------------- Appendix VII:0.1

The Reilly Tar and Chemical Corporation site is located on
approximately 120 acres of land just outside of Indianapolis.  A mix
of industrial, commercial, and residential properties surround the
site.  Residential areas lie immediately to the north and east of the
site and, at a distance, to the southeast.  Approximately 450
households lie within three-quarters of a mile of the site.  (Figure
VII.1 shows the proximity of the site to one household in
Indianapolis.)

   Figure VII.1:  View of the
   Reilly Tar and Chemical
   Corporation Site From
   Resident's Backyard in
   Indianapolis, Indiana

   (See figure in printed
   edition.)

The Reilly Tar and Chemical Corporation has produced specialty
chemicals and related products since the early 1950s, and Reilly
Industries has ongoing operations at the site.  Until 1972, a
coal-tar refining and wood-treatment facility using creosote operated
on the site.  The site contains a trench, a landfill, a lime pond
with cooling water from a boiler, and several pits used to dispose of
wastes.  The plant produces pyridine, alkyl pyridines, niacinamide,
vinyl pyridine, alpha picoline, beta picoline, and gamma picoline. 
Problems at the site include the contamination of groundwater and
surface water with creosotes and ammonia.  Volatile organic
compounds, including toluene, contaminate the soil.  At the
recommendation of the state, EPA included the site on the NPL in
1984. 


      CLEANUP REMEDY AND SITE
      STATUS
----------------------------------------------------- Appendix VII:0.2

In 1987, Reilly Industries agreed to conduct a site study and
recommend cleanup alternatives.  Reilly conducted the site study in
three phases between 1988 and 1990.  On June 30, 1992, EPA selected a
cleanup remedy for controlling groundwater contamination at the site. 
Reilly also conducted a risk assessment that showed potential risks
to public health from contact with contaminated soil; EPA approved
this risk assessment.  In July and August 1993, EPA held a public
comment period on a proposed plan to address several areas that
contributed to soil and groundwater contamination, including the lime
pond, and various disposal pits.  In its proposed plan, EPA
recommended that low-temperature thermal desorption be used to clean
up contaminated soil in four of these areas.\2 The recommended remedy
at the remaining area, the landfill, will depend on the results of
further tests of the sludge. 


--------------------
\2 This process heats waste in a controlled environment and causes
organic compounds to vaporize from the waste. 


      EPA'S COMMUNITY RELATIONS
      ACTIONS
----------------------------------------------------- Appendix VII:0.3

EPA has completed most of the community relations activities at
Reilly, including developing a community relations plan, establishing
an information repository, holding public meetings and comment
periods, and providing information to the public.  EPA's final
community relations plan notes that there has been considerable
controversy about the site since 1955.  Nearby residents complained
frequently to local and state authorities in 1980 about odors,
waste-handling practices that could potentially contaminate
groundwater, and other nuisances and possible hazards at the site. 
According to EPA and state records, and interviews with area
residents, complaints about ongoing site operations have been filed
and investigated. 

In addition to EPA's community relations activities, Reilly
Industries has its own community relations program.  Reilly officials
we spoke with said that they began outreach activities in January
1991, when they held a meeting with residents to discuss groundwater
contamination.  Reilly has also established and recruited community
members to join the Neighborhood Involvement Council.  The purpose of
the council is to inform residents about site activities.  Reilly has
also sent flyers to residents and met with them before EPA's public
meetings to explain site-related issues. 


      RESIDENTS' CONCERNS AND
      SUGGESTIONS
----------------------------------------------------- Appendix VII:0.4

On August 11, 1993, we held a focus group discussion with nine
community residents regarding EPA's community relations program. 
Although EPA generally met key community relations requirements,
residents with whom we spoke were frustrated by the slow pace of the
cleanup, the location of the information repository, and a lack of
information from EPA.  Three residents said that although the site
was declared a Superfund site 9 years ago, it has not yet been
cleaned up.  They were not certain why EPA had, in their view, done
nothing to expedite the cleanup process and had taken years to decide
what to do.  They noted that children in a nearby area play on the
Reilly property and said that EPA should clean up the area.  One
resident said that, had EPA cleaned up the area earlier, many people
would not have moved out of the neighborhood. 

Two residents we spoke with said that the information repository was
not in a convenient location.  The repository is currently located in
a public library in downtown Indianapolis, about 5 miles from the
community.  These residents said that they wished EPA would place the
same information in the West Indianapolis Library in their
neighborhood so that they could get to it more easily. 

Two of the residents with whom we spoke were not aware that EPA
maintained a mailing list for the site.  They said that they had not
received any information from EPA even when the agency said it would
mail information to residents.  Two residents noted that they had
tried to get on EPA's mailing list but were still not included on it
to the best of their knowledge.  Furthermore, the responsible party
and two residents we talked with suggested that EPA use the free area
newspaper to advertise meetings instead of the major newspaper
because a lot of people in the neighborhood do not read the
Indianapolis paper and may therefore not be aware of EPA's meetings
and activities. 

These residents suggested several other ways in which EPA could
improve community relations.  First, in their view, EPA should set up
a local office in the area so that an EPA representative could be
present.  (EPA's Region V office is located about 4 hours away in
Chicago.) Next, EPA could work more aggressively and increase the
pace of the cleanup.  Third, EPA should stop delegating part of its
authority to the state, since the state program is being cut back
drastically.  These residents believe that since EPA started the job
at the site, the agency should also finish it and not delegate it to
someone else.  Finally, in order to inform everyone of upcoming
meetings, they said that EPA should select the whole zip code or a
quadrant of a specific neighborhood and mail everyone in that area a
postcard.  These residents said that doing so would not cost very
much since there are only between 200 and 300 hundred homes.  They
noted that under this approach, all residents would have information
in their mailboxes. 


ROEBLING STEEL COMPANY SITE,
FLORENCE TOWNSHIP, NEW JERSEY -
REGION II
======================================================== Appendix VIII


      BACKGROUND
---------------------------------------------------- Appendix VIII:0.1

The Roebling Steel Company site is an inactive factory that produced
steel products from 1906 until 1982.  More recently, the site has
housed a variety of storage and recycling operations that produced
raw materials and waste products now stored or buried on-site.  The
complex 200-acre site includes 55 buildings, two inactive sludge
pits, a steel furnace slag pile, a building containing bagged dust
from plant emissions, electrical transformers that contain oil
tainted with PCBs (polychlorinated biphenyls), trailer trucks with
unknown contents, soil soaked with oils, storage tanks, drums
containing potentially hazardous materials, an abandoned landfill,
and a slag pile.  (See fig.  VIII.1.) The site is next to the
Delaware River, and the groundwater lies only about 10 feet below the
surface.  For their drinking water, approximately 12,000 local
residents depend on groundwater drawn from wells within 3 miles of
the site, and many use the river and adjacent wetlands for
recreation. 

   Figure VIII.1:  Pile of Debris
   at the Roebling Steel Company
   Site in Florence Township, New
   Jersey

   (See figure in printed
   edition.)

Chemical and physical hazards at the site pose serious health threats
that are made worse by vandalism and trespassing.  People on or near
the site could come into contact with or accidentally breathe
contaminated materials from exposed asbestos and chemical dust,
aboveground storage tanks, piles of chemicals, or the PCB-containing
transformers.  The transformers have also leaked oils tainted with
PCBs onto the ground.  Groundwater under the site is potentially
contaminated with heavy metals, including chromium, lead, cadmium,
nickel, zinc, and copper.  Sediments at the site may be contaminated
with lead and polycyclic aromatic hydrocarbons.  The soil at the site
and an adjacent playground are contaminated with lead and other heavy
metals.  Sporadic vandalism has resulted in the partial or total
destruction of several buildings, as well as tire fires.  The closest
homes are only about 100 feet from the site's boundaries.  Children
swim and ice skate at the site.  Rainwater runoff from the site may
have contaminated the adjacent Delaware River. 


      CLEANUP REMEDY AND SITE
      STATUS
---------------------------------------------------- Appendix VIII:0.2

EPA's approach includes both emergency removal actions and
longer-term cleanup actions because of the site's size and
complexity.  The New Jersey Department of Environmental Protection
removed explosive chemicals in 1985.  In 1987 and 1988, EPA
stabilized the site's most hazardous areas by removing materials for
recycling or for shipping to approved disposal facilities.  The
actions included securing 37 tons of baghouse dust with tarpaulins
and barriers and wrapping or containing exposed asbestos.  In 1990,
EPA removed additional contaminated materials and developed plans to
install a fence to restrict access to the slag pile.  The plans also
call for the removal and disposal of lead contamination from the
playground. 

EPA will clean up the remaining contamination in two phases.  The
first phase will address on-site hazards that require expedited
cleanup but that were too complex and expensive to clean up under the
emergency removal program.  These areas include the remaining drums
and exterior tanks, the transformers, a baghouse dust pile, chemical
piles, and tires.  In this phase, EPA excavated lead-contaminated
soil in an adjacent park and replaced it with soil and vegetation. 
EPA also conducted soil tests for lead and other contaminants on
properties across the street from the park and arranged for a blood
testing program for children residing nearby.  In the second phase,
EPA will determine the nature and extent of contamination over the
entire site.  EPA is now planning a site study in which the agency
will examine soils, surface water, groundwater, sediments, air,
lagoons, and other remaining contamination sources. 


      EPA'S COMMUNITY RELATIONS
      ACTIONS
---------------------------------------------------- Appendix VIII:0.3

EPA has completed most of the community relations activities at the
site, including developing a community relations plan, establishing
an information repository, holding public meetings and comment
periods, and providing information to the public.  The March 1989
community relations plan noted that residents showed a high level of
interest during the removal of hazardous materials and during other
incidents, such as fires.  The plan listed the following specific
areas that citizens are concerned about: 

  the need for more frequent and complete information from EPA;

  health and safety concerns about children who play on the site and
     about potential hazards released by fires or the eventual
     cleanup; and

  frustration at not having local union contractors involved in
     cleanup efforts at the facility. 


      RESIDENTS' CONCERNS AND
      SUGGESTIONS
---------------------------------------------------- Appendix VIII:0.4

Although EPA has generally completed the required community relations
activities, the six residents and two local officials with whom we
spoke wanted more information from EPA and were anxious to have the
cleanup completed.  These residents and officials expressed
dissatisfaction with the information EPA provided and the frequency
with which it was provided.  They want more information from EPA,
especially about when and how the site will be cleaned up.  According
to these residents, EPA promised to provide quarterly newsletters to
the community, but they had not received a newsletter in over a year. 
Limited staff resources prevented EPA from providing the detailed
quarterly status reports in nontechnical language that were requested
by town officials, according to EPA staff. 

The Fire Commissioner said that he received about two mailings each
year but that they were vague, saying only that EPA is cleaning up
the site.  He said that he had to give EPA an ultimatum stating that
if he could not get better information about contamination at the
site and better access to EPA personnel, the fire department would be
unable to respond to emergencies at the site.  He also noted that EPA
had not reimbursed the department for about $8,000 worth of fire
equipment lost while responding to a site fire.  According to EPA
staff, the agency has since provided a site contaminant list to the
fire department and other officials, has conducted special site
tours, and has constructed a special gate to allow fire trucks easier
access to a local creek to obtain water in the event of fire on the
site. 

The residents and officials we interviewed expressed concern about
the cleanup time frames.  Constituents have asked the mayor about the
site's cleanup status and voiced concerns about having the land
remain idle when the community needs jobs.  The mayor said he could
not respond to their questions because he does not have answers about
the site from EPA and is not even on EPA's mailing list.  One
individual also said that residents are frightened because EPA has
not explained why cleanup dates keep changing.  Another resident said
that he has attended at least three of EPA's meetings and has found
them quite informative, but that information is needed on when the
cleanup will start.  Residents with whom we spoke believe EPA is
dragging its feet and spending too much time doing studies.  One
resident said that in meetings EPA uses technical terms he doesn't
understand, such as "hot spots." Most of the residents with whom we
spoke said they didn't know the Community Relations Coordinator. 

Five residents who are also members of the Department of Economic
Development said that they feel EPA did not consider the community's
input in making decisions about the site.  They said that EPA had
planned its agenda before asking for community input.  They said that
their primary concerns are the time lag between various phases of the
Superfund process, the site's impact on the tax base, the negative
image of having a Superfund site in the community, and the potential
impact of the contamination on groundwater. 

One resident interviewed was unfamiliar with the information
repository, located in the municipal building, while several others
did not find its contents helpful.  For example, the Fire
Commissioner said that the technical information is not very helpful
because he has to go through the file and pull out bits and pieces to
obtain the information he needs.  The mayor, who had been given
documents from the information repository by the township's
administrator, said that the documents may provide answers to at
least some of his questions but that the administrator told him that
EPA sends little information to the files and sends it infrequently. 

Finally, not all residents or officials were aware of TAGs.  The Fire
Commissioner said that he had never heard of these grants.  Other
residents said that although EPA mentioned the availability of the
grants at the first public meeting, nothing had been mentioned about
them subsequently. 


OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================== Appendix IX

The Chairman of the Subcommittee on Superfund, Recycling, and Solid
Waste Management, Senate Committee on Environment and Public Works,
requested that GAO review EPA's community relations program.  In
addition to providing background on the requirements for community
relations activities in the Superfund program, GAO was asked to
assess the extent to which EPA is fulfilling these requirements and
to ascertain community residents' feelings about EPA's efforts.  The
Chairman and one Member of the Subcommittee on VA, HUD, and
Independent Agencies, House Committee on Appropriations, asked to be
joint requesters of the report and specifically asked that we review
community relations at the Texarkana Woodpreserving Superfund site in
Texarkana, Texas. 

We performed our work at EPA headquarters in Washington, D.C., and
Regions II (New York), V (Chicago), VI (Dallas), and IX (San
Francisco).  We selected regions Regions II and V because they have
the largest number of Superfund sites, and Regions VI and IX provide
geographical diversity.  We also selected Region VI to see what
differences, if any, exist in regions with a small number of sites,
sites that are spread out geographically, and a small number of
community relations staff.  Although we wanted to meet with residents
in Region VIII, the region with the fewest Superfund sites, an
insufficient number of residents agreed to participate. 

To provide background on EPA's responsibilities for involving
communities in Superfund cleanups and assess EPA's compliance with
the requirements, we reviewed pertinent laws and regulations.  We
obtained and reviewed guidance and directives that headquarters and
the regions issued to assist community relations staff in conducting
community relations activities.  We also interviewed community
relations officials from EPA headquarters' Office of Solid Waste and
Emergency Response/Hazardous Site Control Division and all 10 regions
about how EPA involves communities in the Superfund decision-making
process.  We also reviewed files at 15 information repositories in
Regions V, VI, and IX to determine if they documented key required
community relations activities.  Our review focused on remedial
cleanup phases between the time of inclusion on the NPL and
completion of the cleanup. 

To determine how various communities view the timing and quality of
EPA's community relations efforts for Superfund sites undergoing
remedial cleanup actions, we conducted five focus groups in Regions
V, VI, and IX.  In a focus group, 8-10 people participate in a
structured meeting and respond to questions administered by a
moderator and assistant moderator.  The focus group session usually
lasts about an hour and a half and is recorded by a transcriber to
ensure that responses are accurately documented.  Our focus group
participants were primarily community residents who have attended
EPA's meetings and/or who have otherwise shown interest in their
local Superfund site.  Participants were also recommended by EPA,
selected by GAO from EPA's mailing list for the site, or recommended
by other residents.  We also interviewed other parties involved with
the sites where we held focus groups to obtain their views on EPA's
community relations efforts.  For example, we interviewed potentially
responsible parties on their views of EPA's efforts and local
officials to determine if the information EPA provided them was
adequate to assist them in emergency responses.  Although we did not
conduct focus groups in Region II, we talked with community members
at three different Superfund sites in that region. 

Finally, because of EPA's crucial role in conveying technical
information about site conditions and cleanup to the public, we
analyzed the readability of EPA's fact sheets, which are intended to
provide basic information on a site to the general public.  Using a
computer program, we performed a readability assessment of 20 fact
sheets, 2 from each region, to determine how easy or difficult the
information EPA provided to communities is to understand.  We
obtained information on average sentence length and number of
syllables per word, passive versus active voice, and other
readability factors to determine whether the information presented in
the fact sheets can be understood by the general public. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IX

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C. 

Bernice Steinhardt, Associate Director
Stanley J.Czerwinski, Assistant Director
Bonnie Beckett-Hoffmann, Evaluator-in-Charge
Angelia Kelly, Staff Evaluator
Fran Featherston, Senior Social Science Analyst
Phyllis Turner, Writer-Editor

CHICAGO REGIONAL OFFICE

James B.  Musial, Regional Management Representative
Rosa Maria Torres-Lerma, Site Senior
Josï¿½ Alfredo Gï¿½mez, Staff Evaluator

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