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Community Relations Plan, December 2002

Section 7 - Future Public Involvement Plans

The public involvement activities implemented since August 1999 have both maintained and improved CSSA�s existing relations with the community. Several neighbors to the post are former/current CSSA employees or relatives of former/current CSSA employees. Prior to the initial CRP of August 1999, CSSA had received a few inquiries from the community regarding activities on-post; most related to brush clearing activities, prescribed burning, and explosives detonations. During a review of TCEQ�s CSSA file, one letter from a community member requesting information about CSSA�s air permit was found. Public participation in the corrective action process is required to begin upon completion of the RCRA Facility Investigation (RFI) and Corrective Measures Study (CMS). The RFI investigation is still occurring at CSSA and the CMS has not been initiated. The details of the RCRA Corrective Action Process and the associated documents required by the EPA can be found in Appendix A.

To comply with the Order, and foster effective communication between CSSA and the community, interviews with community members were held in August 1999 and April through June 2002. Discussions with state and local officials, community leaders, local business owners, well owners whose wells were sampled by CSSA, and interested citizens identified the public information needs, as well as the most effective method for disseminating this information. Input from the community provides information that maximizes efforts and provides effective management of the community relations plan. In addition, information gathered during the 2002 interviews regarding the best way to continue to provide information to the community should be evaluated. Based on the information gathered in the August 1999 and July 2002 CRP, four objectives were developed for the CRP at CSSA:

Provide the community with timely and accurate information;

Establish and maintain two-way communication between CSSA and the community;

Respond to specific community concerns and needs that arise for environmental activities; and

Provide opportunities for citizen input and involvement.

These objectives guide the overall community relations activities. Past activities conducted to ensure that the community is properly informed and included in the process were discussed in Section 5. The following paragraphs discuss future activities to ensure these four objectives are met in the future:

7.1 - Provide the Community with Information

7.1.1   Administrative Record/Information Repository

The Environmental Encyclopedia Administrative Record will continue to be updated and maintained at the main branch of the San Antonio Library, 600 Soledad Plaza, San Antonio, TX 78205. Updated information will be added to the Administrative Record on a quarterly basis.

7.1.2   Newsletters/Fact Sheets

Information releases in the form of fact sheets will be prepared on a quarterly basis. The most up-to-date mailing list will be used for each fact sheet. Fact sheets will be prepared to report the results of each quarterly groundwater monitoring event. All information releases or fact sheets will also include the name, address, and telephone number of a CSSA representative responsible for inquiries about the CSSA environmental program.

7.1.3   Mailing List

The mailing list will continue to be updated for forwarded addresses or returned items following each informational mail out. In addition, the mailing list will include media representatives, city and county officials, state and federal agencies with jurisdiction over wildlife resources, and key regulatory agency officials. Furthermore, newspaper notices will invite people to be added to the mailing list so that they will receive any public notices or other information disseminated during the corrective action process.

7.1.4   Contact Person

The contact person will remain LTC Jason D. Shirley. The PAO from Fort Sam Houston, Mr. Phil Reidinger, will continue to support LTC Shirley responding to inquiries from the public.

7.1.5   Statement of Basis

A Statement of Basis (SB) will be prepared which summarizes the information contained in the RFI and CMS reports. The SB is designed to facilitate public participation in the remedy selection. The SB will be placed in the administrative record so that it is available for public review and comment.

7.1.6   Public Notice

A public notice will be issued after the CMS has been completed and a cleanup alternative is proposed. A notice and brief analysis of the SB will be published and appropriate documents will be made available to the public for review at the local information repository. Sufficient information will be included in the notice and analysis to provide a reasonable explanation of the proposed remedy and a list of the remedial alternatives analyzed during the CMS (refer to Table 7.1 for an outline). The notice and analysis will be published, at a minimum, in a major local newspaper of general circulation. The notification will also be sent to facility mailing list recipients. Appendix D, Media Contacts, lists local newspapers intended to carry all public notices. Public notices for future public meetings will be issued.

Table 7.1 - Newspaper Notification Content Summary

The newspaper notification should include the following:

Facility name and location

Date and location of public meeting (if scheduled) - If a meeting has not been requested or scheduled, the notice will inform the public of its right to request one.

Public participation - The notice will inform the public of its role in the remediation selection process and provide the following information:

  1. Location of the information repositories and administrative record

  2. Methods by which the public may submit comments

  3. The dates of the public comment period

Identification of a proposed remedy

Alternative remedies evaluated in the CMS

Request for public comments - The notice will emphasize that the agency is soliciting public comment on ALL of the corrective measure alternatives, as well as on the proposed remedy. It will include a clear statement that the proposed remedy is only a preliminary determination and that other options could be selected as the remedy based upon public comment, new information, or a reevaluation of existing information.

7.2 - Establish Two-Way Communication Between CSSA and the Community

As part of its CRP, CSSA will continue to conduct public meetings if the public continues to indicate that these meetings are helpful. CSSA will host future meetings in subsequent years based on community interest. These meetings will follow the format of the meetings held in October 2001 and 2002, with CSSA�s environmental contractors technical staff presenting displays of information describing CSSA�s environmental program. Representatives from the EPA, TCEQ, Edwards Aquifer Authority, Bexar Metropolitan Water District, San Antonio Metropolitan Health District and other entities involved in the environmental program at CSSA will be invited to participate in the public meetings.

Various community involvement alternatives including development of a RAB or a Technical Review Committee (TRC) were discussed and considered. Based on EPA guidance concerning community involvement in remedial actions, a RAB may be formed according to the level of community interest. Alternatively, DoD criteria for determining sufficient, sustained community interest for formation of a RAB include: 1) request of at least 50 citizens; or 2) the request of Federal, State or local officials. As reported in Section 6, one interviewee expressed an interest in the development of a RAB. The same interviewee indicated his interest in serving as a member of the RAB. CSSA is investigating the possibility of creation of a TRC and the degree of community interest in creation of a RAB.

7.3 - Respond to Community Concerns and Needs that Arise for Environmental Activities

CSSA will continue to respond to concerns and questions from citizens or groups. CSSA will continue to respond to the need for environmental activities such as GAC filtration units, under the guidelines of the Off-post Groundwater Monitoring Response Plan.The CSSA contact point for the community, LTC Shirley, will continue to be presented in all newsletters and fact sheets. Any change in this contact person, as may be affected by any future change in post command, will be noted on subsequent mailouts. Each question or comment will receive a telephone response or written response to follow, if requested, in a timely manner.

7.4 - Provide for Citizen Input and Involvement

7.4.1   Hold Public Meetings

The next annual public meetings will be held in October 2002 to facilitate two-way discussions between regulators and the community, if necessary. A public meeting will be held each year to facilitate community participation in the CSSA environmental program. These meetings will be advertised in the local newspapers, and through invitation to community members on the CSSA mailing list. Meetings are not recorded for the public record.

7.4.2   Public Comment Period

A public comment period is a designated time period in which citizens can formally review and comment on the proposed course of action or decision in response to CMS or CMI workplan. A public comment period is required before corrective measures can be implemented. Upon publication of the SB for CSSA, a public comment period will be held to allow comment on the proposed remedy. The public comment period will last 45 days.

7.4.3   Response to Comments/Responsiveness Summary

A response to comments identifies changes to the SB and the reasons for the changes. It also briefly describes and responds to all significant comments received during the public comment period. The response to comments is written in a clear and understandable style so that it is easy for the community to understand how public comments were considered. Following the public comment period for the SB, a responsiveness summary will be compiled which lists all of the comments received and the responses to each.

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