PODCAST TRANSCRIPT 
Associated report: EPA Region 7 Did Not Effectively Engage with the Community Surrounding the Findett Corp. Superfund Site

DANA: Hello! My name is Dana Baldwin, and I work in the Office of Audit within the Office of Inspector General, an independent office of the U.S. Environmental Protection Agency that helps the Agency protect the environment in a more efficient and cost-effective manner. Our workforce includes auditors, program analysts, investigators, and other subject-matter experts. Although the OIG is part of EPA, Congress provides us with our funding separate from the agency to ensure our independence. Joining me today is health scientist Jonathan Morrand.
Jonathan, your team recently completed an evaluation that relates to contamination of groundwater in the Elm Point Wellfield, which is the drinking water source in St. Charles, Missouri. It is my understanding that the contamination involved the Findett Corporation Superfund site. Is that correct?

JONATHAN: Yes, EPA Region 7, which includes Missouri, determined that Ameren Missouri’s active electrical distribution and transmission substation contaminated the City of St. Charles’ groundwater. Ameren Missouri provides electric and gas service to 64 counties in the greater St. Louis area and one of its substations is part of the Findett Corp. Superfund Site in St. Charles.

DANA: What is a Superfund site?

JONATHAN: Superfund is an informal name for the Comprehensive Environmental Response, Compensation, and Liability Act, which Congress enacted in 1980. The Act authorizes the EPA to clean up contaminated sites or to force responsible parties to perform the cleanup. To carry out this authority, the EPA established its Superfund program to clean up some of the nation’s most contaminated land and to respond to environmental emergencies, oil spills, and natural disasters. 

DANA: In terms of the Findett Corp. Superfund Site cleanup, what does the Comprehensive Environmental Response, Compensation, and Liability Act require? 

JONATHAN: The Act requires the EPA to ensure contaminated groundwater that is a source of drinking water is restored to beneficial use. Practically speaking, this means that the EPA must clean up the Findett site, such that the community has the best opportunity to productively use it following the cleanup. EPA’s Region 7 must take action to ensure that the groundwater does not exceed maximum contaminant levels. While EPA Region 7 identified Ameren Missouri as a responsibility party in that effort, the Agency cannot require Ameren to clean up the site beyond set maximum contaminant levels. 

DANA: Jonathan, what contaminants were found in the groundwater?

JONATHAN: The EPA and others have identified contaminants of concern known as volatile organic compounds in the groundwater that serves St. Charles. 

DANA: Does contamination of the groundwater mean that the community of St. Charles shouldn’t drink the water from its wells?

JONATHAN: No, Dana. While contamination was found in the groundwater, there has been no contamination detected in the treated drinking water.

DANA: How did the city government react to the recent discovery of contaminants in the groundwater?

JONATHAN: The city independently decided to shut down the city’s wells. In January of 2022, the City of St. Charles shut down one of five active drinking water wells. It took this action after identifying traces of hazardous chemicals in the groundwater. Over the next 13 months, the city suspended operation of another three wells. These actions left only one well to serve over 70,000 residents. Again, let me be clear, federal and state regulators did not require these closures. They maintain the drinking water is safe. 

DANA: So, why did the city take those actions? 

JONATHAN: The City of St. Charles argues that any amount of groundwater pollution is a risk to its residents. It contends that continuing to pump its wells after contamination has been detected would worsen the problem, potentially exposing residents to harm.

DANA: What type of harm are we talking about?

JONATHAN: If volatile organic compounds are consumed over an extended time, they can cause negative health impacts, such as liver damage, neurological issues, bladder cancer, and heart defects. However, no volatile organic compounds have been found in the treated drinking water. 

DANA: Jonathan, the point of the OIG’s evaluation was to determine whether the EPA adhered to federal laws, regulations, and Agency guidance pertaining to community engagement standards and practices at the Findett Corp. Superfund Site. What led the OIG to conduct this evaluation?

JONATHAN: Prior to this evaluation, the OIG performed what we call an “inquiry” into potential contamination of the Elm Point Wellfield drinking water source in St. Charles. That initial effort included a site visit, conducting interviews, gathering data, and analyzing a variety of issues. Based on the inquiry’s findings, the inspector general decided to open an evaluation to look into the EPA’s response. St. Charles community leaders and members have expressed dissatisfaction with cleanup efforts at the Superfund site. The OIG wanted to gauge whether the EPA used all the tools available to it to help the community understand and participate in those efforts.

DANA: So, there is a fundamental conflict between what EPA Region 7 considers safe and what the city views as safe. Has this situation made the EPA’s responsibilities involving community involvement more important? 

JONATHAN: Absolutely! In fact, Congress established community involvement as an integral component of the Superfund process. Toward that end, the EPA developed a Community Involvement Handbook and a Superfund Community Involvement Toolkit. These advise conducting early, frequent, and meaningful community involvement and outline available technical assistance resources.

DANA: And yet the OIG’s evaluation found that EPA Region 7 did not effectively communicate with the public. What was the reason for this finding?

JONATHAN: Well, to start, some information that EPA Region 7 provided to the public was difficult to understand or access because the region could have better complied with Plain Language requirements or EPA guidance for public facing documents. The Plain Writing Act of 2010 is meant to enhance citizen access to government information and services by requiring federal agencies, such as the EPA, to use clear, concise, and well-organized writing when developing public documents. For example, the region developed three fact sheets that were far too technical. Further, some Region 7 staff are not regularly trained on Plain Language requirements and Superfund communication guidance. Such training could increase public understanding of EPA communications and decrease the need for the public to seek clarification from Agency staff to correct misinformation. Another finding is that EPA Region 7 used obscure media sources to distribute public information, choosing to save costs by publishing in low circulation newspapers. 

DANA: What else did the team find, Jonathan?

JONATHAN: EPA Region 7 didn’t update its community involvement plan for the Findett site as site conditions and public perceptions changed. Its most recent plan, which should form the backbone of the site's community involvement program as required by the EPA’s National Contingency Plan, was neither timely nor robust. Because Region 7 did not make updates, it was not prepared to engage the community efficiently and effectively. Additionally, the EPA did not gather sufficient community perspectives during its development of the plan.

DANA: Ultimately, your team concluded that Region 7 didn’t successfully facilitate community and city involvement, either. Why did this occur?

JONATHAN: Well, technical staff leading the Superfund process, including community involvement, were unaware of the tools and resources available for assessing or providing for the technical assistance needs in St. Charles. Distrust of EPA Region 7 and the process grew among community members and city officials. The worsening relationship between city officials and Region 7 caused a delay of site actions, such as water sampling. Additionally, inconsistent positions and messaging caused confusion in the community. While Region 7 has maintained that St. Charles residents’ drinking water is safe, the City of St. Charles argues that Region 7’s and Ameren’s actions cannot protect public health. Because of their opposing views on cleanup plans and the overall poor working relationship, EPA Region 7 and the City of St. Charles issued to the public conflicting messages about the health risks of the groundwater contamination, which resulted in confusion across the St. Charles community. Despite evidence of city stakeholder discontent in 2022, Region staff did not request tools and resources available from the EPA to improve their engagement efforts with the city until the fall of 2023.

DANA: Wow. That is surprising information, Jonathan. What did your team recommend to the EPA in this report? 

JONATHAN: We recommend five things:
First, that Region 7 should assess the need for alternative dispute resolution services. Second, that Region 7 should develop a plan to ensure key personnel should receive regular and ongoing training on the EPA’s community involvement resources and the use of plain language in public-facing documents. Third, that Region 7 should implement a method to identify and prioritize community needs for technical support. Fourth, that key community engagement personnel should have regular opportunities to develop an understanding of site and community activities and provide recommendations for community engagement. And, fifth, that Region 7 should implement procedures for updating community involvement as site conditions change.

DANA: Thank you Jonathan for joining me to talk about this important topic. To read this and other reports on the EPA’s response to drinking water contamination, as well as other EPA OIG work, please visit www.epaoig.gov.