OSC 2007 Evaluation Report

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2007 OSC Readiness Training Program Evaluation Report • I experienced some confusion differentiating between OPA and CERCLA authorities and programs. The material seemed to switch back and forth. • Include a broader range of examples to stimulate discussion. • Examples of “good” and “poor” case studies are judgmental and this is a situation where an OSC’s preferences could end up highlighting EPA’s arbitrary nature. • Include more discussion on problem areas associated with PRP change of attitude during response activities. (Two responses) • Do not need to describe the type of PRP. The personality of the PRP is irrelevant; OSC should only worry about PRP’s technical and financial viability. • I think we should go through all of the modules again and identify necessary changes/deletions, etc. • Topics to be shortened: case examples, HASP, and modules One, Two and Four. Comments on instructional methods and materials • Excellent instructors. (Six responses) • Knowledge and expertise of instructors was obvious. • The way information on PRP lead removal actions was spelled out was very helpful. • Practical exercises are not needed. • Liked the course notes in the manual. (Four responses) • The course manual is excellent for reference material. (Five responses) • Include a slide in Module One that goes into the actual authorities by which the OSC can act under 311c and 106, and the NCP. Perhaps provide the appropriate statute and NCP language sections as an appendix. • If manual is meant to be a reference, it needs to be beefed up. • Hard to find some of the reference materials in the handout. (Two responses) • Include a list of acronyms with definitions. (Two responses) • Improve the numbering and organization of the amendments. (Two responses) • Add slides on what OSC files are needed on PRP- versus Fund-lead sites. • Add a slide about why “Enforcement First” is the policy and link it to CERCLA/OPA citations or law. (Two responses) • Add an example of “Work to Be Performed”/Statement of Word (SOW) from an Administrative Order of Consent (AOC)/Unilateral Administrative Order (UAO). • Add more on field interactions with the PRP. • Video of pathway site would have been a good introduction to this case study. • I like the interaction with the audience. Is there a way to increase this? • Encourage a broader discussion about Regional differences. • Too much class discussion. (Two responses) C-93 Comments about Individual Training Courses
2007 OSC Readiness Training Program Evaluation Report • Ensure we have an attorney willing to participate in the course even if attorney is in the audience. • Make an all-day course and include cost-recovery modules and PRP search process. (Two responses) • Need to move faster – do not worry so much about audience participation. Comments on course name and abstract expectations • Describe as a primer for new OSCs and as a refresher for experienced OSCs or OSCs unfamiliar with PRP responses. Comments on recommending course to colleagues • Course should be mandatory. (Two responses) • This course should be taken by new OSCs and as a refresher for experienced or unfamiliar OSCs. (Five responses) • It is obvious that the budget is not getting bigger for fund-lead sites, so PRP sites will become increasingly important (or at least there will be more pressure to find PRPs). • Due to the course material, it would not suit my colleagues. • Yes, because it basically gives one insight on how OSCs address PRPs. General Comments • Add a N/A option to evaluation form for those whose jobs do not apply to this work. • This would be a great addition to OSC 201. • The “Iron Fist” was excellent. Attendee’s suggestions for future course offerings • Topics to lengthen: - Presentation on safety issues, real versus potential issues that should stop work, and the authority that identifies the need to stop work (Two responses) - When EPA should take over work at a site - Oversight costs - Headquarter guidance - Information about field interactions with the PRP - When an OSC should to get help from another OSC - The need to work with those who think like you so as to show a uniform approach • Topics to add: - More information about a communication plan - Example of “Work to be Performed”/SOW from an AOC/UAO - Discussion on community relations - Information about completing PRP searches during site assessments - Linking stop work issues to real threat, not potential threat - Linking “Enforcement First” to CERCLA/OPA citations or law C-94 Comments about Individual Training Courses
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