United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9200.3-14-2
EPA-540/R-94/021
PB94-963247
April 1994
Superfund
v/EPA
SUPERFUND PROGRAM
MANAGEMENT MANUAL
FISCAL YEAR 1994
Program Goals and Priorities
Program Planning and Reporting Requirements
Superfund Financial Management and FTE Distribution
SCAP/STARS Targets/Measures and Definitions
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* DISCLAIMER
The policies and procedures established in this document are intended
solely for the guidance of employees of the U.S. Environmental
Protection Agency. They are not intended and cannot be relied upon to
create any rights, substantive or procedural, enforceable by any party in
litigation with the United States. EPA reserves the right to act at
variance with these policies and procedures and to change them at any
time without public notice.
U.S. Environment'"' '-lection Agency
Region 5, Librarv {> '. "J)
77 West Jackson i"--. .yard, 12th Floor wmhma * , «
Chicago. IL 60604-3590 "' '°n
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OSWER Directive 9200.3-14-2
USE AND STRUCTURE OF THE MANUAL
The information in this Manual is targeted to Unit, Section and Branch Chiefs. Its pri-
mary purpose is to provide:
The primary program goals and priorities for FY 94; and
An overview of the Superfund program management processes (planning, accom-
plishment reporting and program evaluation, and resource allocation).
The FY 94 Superfund Program Management Manual consists of information on:
Manager's schedule of significant events;
Program goals and priorities;
Program planning and reporting requirements; and
Financial management and FTE distribution.
Appendix A contains targets/measures and definitions for site screening and assessment/
regional decisions, early and long-term actions, program support activities, enforcement, and
Federal Facilities.
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OSWER Directive 9200.3-14-2
FY 94 SUPERFUND PROGRAM MANAGEMENT MANUAL
TABLE OF CONTENTS
CHAPTER I - PROGRAM GOALS AND PRIORITIES 1-1
OVERVIEW OF PROGRAM GOALS 1-1
FISCAL YEAR 94 THEMES 1-1
A FRAMEWORK OF PRIORITIES 1-1
INTEGRATED PRIORITY SETTING MATRIX 1-3
ACCELERATED CLEANUP AND EMERGENCY RESPONSE 1-7
ENFORCEMENT. 1-7
ENFORCEMENT FAIRNESS 1-8
BASE CLOSURES 1-9
CONSTRUCTION COMPLETIONS 1-10
Federal Facilities 1-10
EFFECTIVE CONTRACT MANAGEMENT 1-10
Federal Facilities 1-10
ENVIRONMENTAL JUSTICE AND MEANINGFUL
COMMUNITY INVOLVEMENT 1-10
Public Involvement/Communicating Success 1-11
Federal Facilities 1-11
ENHANCEMENT OF STATE ROLE Ml
INNOVATIVE TECHNOLOGIES Ml
FEDERAL FACILITY INITIATIVES M2
Integrated Management Strategy 1-13
SUPERFUND ACCELERATED CLEANUP MODEL (SACM) 1-14
INTEGRATED TIMELINE FOR SITE MANAGEMENT 1-18
SCAP/STRATEGIC TARGETED ACTIVITIES FOR RESULTS
SYSTEM (STARS) TARGETS AND MEASURES 1-21
CHAPTER II - PROGRAM PLANNING AND REPORTING
REQUIREMENTS II-l
INTRODUCTION II-l
INTEGRATED PLANNING II-l
INTRODUCTION TO THE SUPERFUND COMPREHENSIVE
ACCOMPLISHMENTS PLAN (SCAP) II-3
RELATIONSHIP OF SCAP TO OTHER MANAGEMENT TOOLS II-5
The Management Tools II-5
The Superfund Information Systems II-6
OVERVIEW OF THE SCAP PROCESS II-6
HQ/REGIONAL ROLES AND RESPONSIBILITIES II-7
Maintaining SCAP in CERCLIS II-7
Program Assessment II-8
PROCEDURES FOR ANNUAL TARGET SETTING II-9
PLANNING FOR NEGOTIATIONS 11-10
Planning Process 11-10
REGIONAL ACCOMPLISHMENT REPORTING 11-12
April 1994
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OSWER Directive 9200.3-14-2
HQ EVALUATION OF REGIONAL PERFORMANCE 11-13
Quarterly Reporting 11-14
Mid-Year Assessment 11-14
End-of-Year Assessment 11-16
Regional Reviews 11-16
Management Reporting 11-17
Superfund Management Reports 11-17
Annual Reporting Requirements 11-18
SCAPISTARS ADJUSTMENTS AND AMENDMENTS 11-18
CHAPTER III - SUPERFUND FINANCIAL MANAGEMENT AND FTE
DISTRIBUTION III-l
OUTYEAR BUDGET DEVELOPMENT III-l
FY 95 BUDGET DEVELOPMENT III-l
DEVELOPMENT OF THE FY 94 NATIONAL BUDGET III-3
FY 94 REGIONAL BUDGET III-3
Response Budget III-3
Enforcement Budget III-4
Federal Facilities Budget III-4
RELATIONSHIP BETWEEN SCAP AND THE ANNUAL
REGIONAL BUDGET III-5
ADVICE OF ALLOWANCE PROCEDURES AND FINANCIAL
REPORTING REQUIREMENTS III-7
Regional Allowances III-7
The AOA Process III-7
AOA Flexibility III-8
RA Allowance 111-10
Non-Site Specific Funding Flexibility 111-10
AOA Change Request Procedures 111-12
Financial Management and Funding Processes 111-12
OVERVIEW OF THE FTE DISTRIBUTION PROCESS 111-12
ACRONYMS I
ORGANIZATIONAL CHARTS 1
Office of Emergency and Remedial Response 1
Office of Program Management 2
Emergency Response Division 3
Hazardous Site Evaluation Division 4
Hazardous Site Control Division 5
Office of Waste Programs Enforcement 7
CERCLA Enforcement Division 8
Office of Federal Facilities Enforcement 9
Superfund Revitalization Office 10
Office of Enforcement and Compliance Assurance 11
EPA REGIONAL MAP
April 1994 ii
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OSWER Directive 9200.3-14-2
LIST OF EXHIBITS
CHAPTER I
1-1 FY 94 Superfund Challenges 1-2
1-2 Integrated Priority Setting Matrix 1-4
1-3 Environmental Management Strategic Plan 1-12
1-4 Integrated Management Strategy 1-14
1-5 Simplified Comparison of Superfund "Pipelines" 1-17
1-6 Integrated Timeline 1-19
1-7 FY 94 SCAP/STARS Targets and Measures 1-22
CHAPTER II
II-l Flexibility Scale For Budget/Planning II-2
II-2 HQ/Regional Integrated Planning Responsibilities II-4
II-3 HQ/Regional SCAP and CERCLIS Responsibilities II-7
II-4 Evaluation Responsibilities II-9
II-5 Procedures For Annual Target Setting 11-11
II-6 Regional Planning for Negotiations 11-12
II-7 The Regional Evaluation Process 11-15
II-8 CFO Performance Measures 11-19
II-9 Amendments and Adjustments 11-21
11-10 SCAP Amendment Process 11-22
CHAPTER III
III-l Process for Developing the Outyear and FY 95 Budget III-2
III-2 The Advice of Allowance Process III-9
III-3 Change Request Required 111-14
III-4 AOA Change Request Procedures 111-15
III-5 Financial Management and Funding Processes 111-16
III-6 Handling Financial Data in the CERCLIS Environment 111-18
iii April 1994
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OSWER Directive 9200.3-14-2
This Page Intentionally
Left Blank
April 1994 iv
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OSWER Directive 9200.3-14-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS
JULY QUARTER 4 (FISCAL YEAR (FY) 93)
6 The Assistant Administrator for the Office of Solid Waste and Emergency Re-
sponse (AA SWER) or the Director, Program Operations Division (POD) in the
Office of Federal Facilities Enforcement (OFFE) and the Office of the Comptrol-
ler (OC) approves the fourth quarter Advice of Allowance (AOA)
8 Headquarters (HQ) pulls 3rd quarter FY 93 accomplishments data from the Com-
prehensive Environmental Response, Compensation, and Liability Information
System (CERCLIS) and provides for:
1) Comparison of Regionally reported accomplishments in the Office of Pollution
Prevention (OPP) Strategic Targeted Activities for Results System (STARS);
and
2) Special enforcement reports
8 HQ submits FY 95 Superfund budget request to the Administrator
8 HQ pulls data from CERCLIS to review and analyze:
1) Regional Superfund Comprehensive Accomplishments Plan (SCAP)/STARS
and pipeline workload and budget request;
2) Past Regional accomplishments and planned durations/dollars; and
3) Regional request for 10 percent budget reserve
19-23 Regional conference calls on HQ analyses
19-23 HQ/Regions reconcile accomplishments data contained in the OPP STARS system
(third quarter accomplishments)
23 OPP STARS system closes (third quarter accomplishments)
AUG.
6 HQ pulls accomplishments data from CERCLIS
9-20 HQ/Regions conduct negotiations on final FY 94 SCAP/STARS targets and
budget
20 Administrator passback of FY 95 budget request
31 HQ sends memorandum to Regions on final budgets, targets and measures
31 HQ submits National Priorities List (NPL) proposed rules to the Office of Man-
agement and Budget (OMB)
SEPT.
8 Regions revise CERCLIS to reflect final budgets, targets and measures
April 1994
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OSWER Directive 9200.3-14-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
SEPT. (continued)
8 HQ pulls data from CERCLIS for first quarter (FY 94) AOA
8 HQ pulls accomplishments data from CERCLIS
8 HQ revises FY 95 budget request and submits it to OMB
20 HQ makes final FY 94 Full Time Equivalent (FTE) distribution
24 HQ submits FY 94 first quarter AOA request to the AA SWER or Director, POD/
OFFE and places it in CERHELP
30* Regions input AOA to the Integrated Financial Management System (IFMS)
OCT. QUARTER 1 (FY 94)
1 HQ distributes final FY 94 Superfund Program Implementation Manual
5* The AA SWER or Director, POD/OFFE and OC approves the first quarter AOA
7 HQ pulls 4th quarter FY 93 accomplishments data from CERCLIS and provides
for:
1) Special program reports; and
2) End-of-year assessment for FY 93.
15 HQ pulls 4th quarter FY 93 accomplishments data from CERCLIS for comparison
of Regionally reported end-of-year accomplishments in OPP FY 93 STARS
NOV.
1 Enforcement extramural budget carryover calculated
5 HQ/Regions set FY 94 final targets, including open season changes in CERHELP
5 HQ pulls accomplishments data from CERCLIS
18-24 HQ/Regions reconcile accomplishment data contained in OPP STARS system
(fourth quarter FY 93)
19 HQ distributes final FY 94 Superfund Program Management Manual for Branch/
Section/Unit Chiefs
19 OMB passback of FY 95 budget request
* Dependent on approval of final appropriation
April 1994 vi
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OSWER Directive 9200.3-14-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
NOV. (continued)
24 OPP STARS system closes (fourth quarter FY 93)
DEC.
7 HQ pulls CERCLIS data for:
1) Second quarter AOA; and
2) FY 95 Congressional Budget
17 HQ appeal of the OMB FY 95 budget passback
23 HQ submits second quarter AOA request submitted to AA SWER or Director,
POD/OFFE and places it in CERHELP
30 Regions input AOA to IFMS
JAN. QUARTER 2 (FY 94)
5 The AA SWER or Director, POD/OFFE and OC approves the second quarter
AOA
7 HQ pulls accomplishments data from CERCLIS and provides for special reports
7 Regions submit list of non-Federal Facility proposed and final NPL sites that did
not receive a removal investigation during calendar year 1993
14 HQ submits FY 95 budget request to the President
25-27 HQ/Regional Superfund Program Management meeting
28 Regions submit Fund mega-site Management Plans for FY 95 to the Hazardous
Site Control Division (HSCD)
FEB.
7 HQ pulls national Environmental Indicators (El) data from CERCLIS
18 HQ prepares El questions and answers to send to the Regions
25 HQ submits NPL proposed rule to OMB
MARCH
7 HQ pulls data from CERCLIS for enforcement extramural budget and third-
quarter AOA
vii April 1994
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OSWER Directive 9200.3-14-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
MARCH (continued)
18 HQ distributes draft FY 95 Superfund Program Implementation Manual for Re-
gional review
25 HQ submits third quarter AOA request to the AA SWER or Director, POD/OFFE
and places it in CERHELP
31 Regions input AOA to IFMS
31 Regional response to HQ El questions and answers
APRIL QUARTER 3 (FY 94)
5 The AA SWER or Director, POD/OFFE and OC approves the third quarter AOA
5 Regional comments on FY 95 Superfund Program Implementation Manual due
7 HQ pulls accomplishments data from CERCLIS and provides for:
1) Comparison of Regionally reported second quarter accomplishments in OPP
STARS;
2) Special program reports; and
3) Mid-year performance evaluation
11-15 CERCLIS Change Management Council Meeting
15 Regions submit current FY STARS amendment requests to HQ
18-22 HQ/Regions reconcile accomplishments data contained in OPP STARS system
(second quarter accomplishments)
22 OPP STARS system closes (second quarter accomplishments)
29 HQ distributes FY 93 El analysis to HQ/Regional managers
29 HQ prepares preliminary Regional operating plan based on past three years obli-
gating/tasking averages
MAY
6 HQ analysis of Regional pipeline
6 HQ allocates 90 percent of FY 95 budget to Regions
13 Regional NPL site fact sheets updated in NPL-Production Assistance Database
(PAD)
April 1994 viii
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OSWER Directive 9200.3-14-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
MAY (continued)
16-31 Regions generate their plan for FY 95 by updating schedules and financial infor-
mation in WasteLAN and uploading to CERCLIS
20 HQ distributes final FY 95 Superfund Program Implementation Manual
31 HQ submits NPL final rule to OMB
JUNE
1-30 Regions generate their plans for FY 95 by updating schedules and financial infor-
mation in WasteLAN and uploading to CERCLIS
7 HQ pulls CERCLIS data for fourth quarter AOA
7 HQ pulls planning information from CERCLIS to support FY 96 budget request
8 HQ distributes draft FY 95 Superfund Program Management Manual
17 HQ presents FY 96 Superfund goals and priorities to the Administrator
24 HQ submits fourth quarter AOA request to the AA SWER or Director, POD/
OFFE and places it in CERHELP
24 Regional comments on FY 95 Superfund Program Management Manual due
30 Regions submit enforcement mega-site management plans to the Office of Waste
Programs Enforcement (OWPE)
30 Regions input AOA to IFMS
JULY QUARTER 4 (FY 94)
6 The AA SWER or Director, POD/OFFE and OC approves the fourth quarter
AOA
8 HQ submits FY 96 Superfund budget request to the Administrator
8 HQ pulls accomplishments data from CERCLIS and provides for:
1) Comparison of Regionally reported accomplishments in OPP STARS; and
2) Special program reports
8 HQ distributes final FY 95 Superfund Program Management Manual
ix April 1994
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OSWER Directive 9200.3-14-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
JULY (continued)
15 HQ pulls data from CERCLIS to review and analyze:
1) Regional SCAP/STARS and pipeline workload and budget request;
2) Past Regional accomplishments and planned durations/dollars; and
3) Regional requests for 10 percent reserve
18-22 Regional conference calls on HQ analyses
18-22 HQ/Regions reconcile accomplishments data contained in OPP STARS system
(third quarter accomplishments)
22 OPP STARS system closes (third quarter accomplishments)
AUG.
8-19 HQ/Regions conduct negotiations on final FY 95 SCAP/STARS targets and
budget
19 Administrator passback of FY 96 budget
31 HQ sends memorandum to Regions on final budgets, targets and measures
31 HQ submits NPL proposed rule to OMB
SEPT.
8 Regions revise CERCLIS to reflect final budgets, targets and measures
8 HQ pulls data from CERCLIS for first quarter FY 95 AOA
8 HQ pulls accomplishments data from CERCLIS
9 HQ revises FY 96 budget request and submits it to OMB
19 HQ performs final FY 95 FTE distribution
23 HQ submits FY 95 first quarter AOA request to the AA SWER or Director, POD/
OFFE and places it in CERHELP
30* Regions input AOA to IFMS
OCT. QUARTER 1 (FY 95)
5* The A A SWER or Director, POD/OFFE and OC approves the first quarter AOA
7 HQ pulls accomplishment data from CERCLIS and provides for:
1) Special program reports; and
2) FY 94 end-of-year assessment.
* Dependent on approval of final appropriation
April 1994 x
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OSWER Directive 9200.3-14-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
OCT. (continued)
17 HQ pulls 4th quarter FY 94 accomplishments data from CERCLIS for comparison
of Regionally reported end-of-year accomplishments in FY 94 STARS
NOV.
1 Enforcement extramural budget carryover calculated
7 HQ/Regions set FY 95 final targets, including open season changes in CERHELP
14-18 HQ/Regions reconcile accomplishments data contained in OPP STARS system
(fourth quarter FY 94)
18 OPP STARS system closes (fourth quarter FY 94)
18 OMB passback of FY 96 budget request
30 HQ submits NPL final rule to OMB
DEC.
7 HQ pulls CERCLIS data for:
1) Second quarter AOA; and
2) FY 96 Congressional budget
16 HQ appeal of the OMB FY 96 budget passback
23 HQ submits second quarter AOA request to AA SWER or Director, POD/OFFE
and places it in CERHELP
30 Regions input AOA to IFMS
* Dependent on approval of final appropriation
xi April 1994
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OSWER Directive 9200.3-14-2
CHAPTER I
PROGRAM GOALS AND PRIORITIES
April 1994
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OSWER Directive 9200.3-14-2
CHAPTER I - PROGRAM GOALS AND PRIORITIES
OVERVIEW OF PROGRAM GOALS
The focus of the Superfund program is to maximize the protection of human
health and the environment through fast, effective cleanup of priority
hazardous waste sites and releases. Protecting human health and the
environment, maximizing participation of the Potentially Responsible Parties
(PRPs), and ensuring enforcement fairness are three of the Superfund program's
highest priorities.
FISCAL YEAR 94 THEMES
Fiscal Year (FY) 94 is a critical year for the Superfund program as the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act
(SARA), is scheduled for reauthorization in October 1994. Superfund is now
more than 13 years old. After 13 years, significant progress has been made in
reducing risks posed to human and natural ecosystems from releases of
hazardous substances into the environment. Accomplishments in FY 94 will
expand and refine Superfund's measures of success, refocus the debate on
Superfund progress, and explore options for making administrative changes that
will improve Superfund in the future.
Increasing programmatic demands, and the pending reauthorization, have
made it important that the programmatic priorities and challenges be defined
and clearly communicated. Exhibit 1-1 summarizes the nine challenges that
Regional and Headquarters (HQ) Superfund managers must work together to
address in FY 94. In addition, a HQ/Regional task force identified improvements
to the Superfund program that will be implemented by the Agency before
September 30, 1994. (Superfund Administrative Improvements, June 23, 1993.)
These challenges and administrative improvements will be discussed in more
detail later in this chapter.
A FRAMEWORK OF PRIORITIES
The highest priority of the Superfund program is the management of
imminent risk to human health and the environment. Worst site/worst
problems first is a guiding Superfund principle. Efforts to streamline and
accelerate the entire Superfund process also support this important goal. While
it is being determined whether a site poses imminent risk, the Agency moves on
to other priorities, using enforcement tools to ensure maximum PRP
involvement.
1-1 April 1994
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OSWER Directive 9200.3-14-2
EXHIBIT 1-1
FY 94 SUPERFUND CHALLENGES
Emergency Response and Accelerate
Cleanup
Enforcement
Enforcement Fairness
Military Base Closure
Construction Completions
Effective Contract Management
Environmental Justice
Enhancement of State Role
Innovative Technologies
Given current resource constraints, maximizing PRP involvement in the
cleanup process will be necessary to meet the mandates of SARA and the goals of
the Agency.
When PRPs are recalcitrant, the Region must determine what mix of Fund
and enforcement tools should be used to move the site expeditiously to cleanup.
Both a Unilateral Administrative Order (UAO) and Fund-financed action should
be considered. If UAOs are issued and the PRPs do not comply, a Fund-financed
cleanup should be considered, as appropriate, to ensure that the site moves
forward quickly. Appropriate cost recovery efforts should be pursued when PRPs
do not comply and Fund-financed activities are initiated.
One of the tools used by the Agency to reconcile the competing Superfund
priorities is the Integrated Priority Setting Matrix. The Matrix was initially
developed in 1989 by the Office of Waste Programs Enforcement (OWPE), the
Office of Emergency and Remedial Response (OERR), Office of Federal Facilities
Enforcement (OFFE) and the Regions. It is evaluated on a yearly basis to ensure
that the latest program priorities are accurately reflected. The Matrix is used by
the Office of Solid Waste and Emergency Response (OSWER) and the new Office
of Enforcement and Compliance Assurance (OECA), formerly OWPE, to allocate
resources in Superfund to the highest priority activities.
April 1994
1-2
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OSWER Directive 9200.3-14-2
INTEGRATED PRIORITY SETTING MATRIX
The Integrated Priority Setting Matrix shown in Exhibit 1-2 has been
reorganized to reflect the key challenges in FY 94 and the Superfund
Administrative Improvements.
The new Matrix is designed to:
Identify the most significant program priorities that support the challenges;
List the major activities or tools that receive resources, grouped according to
their contribution to a program priority; and
Arrange the program priorities and major tools in order of importance,
where possible.
The Matrix provides a framework for establishing, testing, and adjusting
resource levels and will be used by HQ and the Regions in making trade-off
decisions during:
FY 95 budget formulation;
FY 94 operating plan development, target setting and negotiation; and
FY 94 mid-year adjustment.
The overall organization of the Matrix is governed by the following concepts:
All of the activities listed in the Matrix contribute in a significant manner to
Superfund program success. Therefore, priority setting must be presented in
terms of maintenance of an essential minimum baseline of activity across the
board; and
A baseline of activities must be supported to ensure that a constant flow of
projects is maintained and that the entire program maintains its operating
integrity.
1-3 April 1994
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OSWER Directive 9200.3-14-2
EXHIBIT 1-2
INTEGRATED PRIORITY SETTING MATRIX
PROGRAM
CHALLENGES
PROGRAM
PRIORITIES
TOOLS
Emergency
Response and
Accelerate
Cleanup
Mitigate Risks from
Immediate Threats
Classic Emergencies (Fund and PRP)
Early Actions (Fund, PRP, Federal Facility)
Regional Decisions
Timely Remediation
of Sites
Conduct Early Actions to Cleanup National
Priorities List (NPL) Sites
Remedial Design (RD) Starts
Complete Ongoing Remedial Investigation/
Feasibility Studies (RI/FSs)
Initiate Expanded Site Inspections/Remedial
Investigations (ESI/RI) at Sites Where
Significant Response Actions are Needed
Work with other Federal Agencies to
Accelerate Cleanup
Initiate Integrated Site Assessments (Fund
and PRP)
Develop and Utilize Presumptive Remedies
Develop Soil Trigger Levels for Cleanup
Enforcement
Maximize PRP
Participation
Cleanup Negotiations
Section 106 Settlement Referrals
Section 106 UAOs
Administrative Orders (AOs) for Early Actions
Federal Facility Interagency Agreement (IAG)
Compliance Monitoring/Enforcement
Federal Facility IAG Negotiation/Signature
Site Assessment Negotiations
PRP Searches
Take Enforcement
Actions for PRP
Response
Section 106 or 106/107 Litigation to Enforce
UAOs
Compliance Monitoring/Enforcement
Section 104 Access
Enforcement
Fairness
Equitable Treatment
ofPRPs
De minimis Settlements
Mixed Funding Settlements
Settlements with Municipalities
Use Alternative Dispute Resolution (ADR) to
Facilitate Settlement
PRP Allocations of Responsibility
Greater Fairness for Superfund Site
Owners
Section 107 Statute of Limitation
(SOL) Cost Recovery Referrals(>$200K)
April 1994
1-4
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OSWER Directive 9200.3-14-2
EXHIBIT 1-2 (continued)
INTEGRATED PRIORITY SETTING MATRIX
PROGRAM
CHALLENGES
PROGRAM
PRIORITIES
TOOLS
Enforcement
Fairness
(continued)
Equitable Treatment of
PRPs (continued)
Section 122 Administrative
Settlements
Improve the Effectiveness of Cost
Recovery
Managing Voluntary Cleanups
Section 104(e) Referrals
Base Closures
Expedited Remediation and
Property Transfer of Military
Bases
Assist Department of Defense (DoD)
with Assessing Sites
Ensure that Remedies Selected
Meet Superfund Criteria
Act Quickly on Clean Parcel
Determinations (120(h))
Construction
Completions
Maintain the Pace of
Construction Completions
Complete Ongoing Remedial
Actions (RAs) (Fund, PRP, and
Federal Facility)
Prepare and Approve RA
Reports and Preliminary and
Final Site Close-Out Reports
Initiate Long-Term RA
Construction
Complete Ongoing Remedial
Designs (RDs)
Delete Sites from the NPL
Perform Five Year Reviews
Contract
Management
Effective Contract
Management
Implement Recommendations of
Contracts Task Forces
Implement Long-Term Contracting
Strategy (LTCS)
Follow Contract Management
Principles
1-5
April 1994
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OSWER Directive 9200.3-14-2
EXHIBIT 1-2 (continued)
INTEGRATED PRIORITY SETTING MATRIX
PROGRAM
CHALLENGES
PROGRAM
PRIORITIES
TOOLS
Environmental
Justice and
Meaningful
Community
Involvement
Assure Every Citizen
Receives Comparable
Protection and Community
Participation in Site
Decision Making
Implement an Environmental Justice
Strategy for Superfund Sites
Site-Specific Advisory Boards
(Federal Facility)
Technical Assistance Grants (TAGs)
Administrative Records (Early and
Long-Term Actions)
Public Outreach
Communicate Progress in
the Superfund Program
Develop New Public Participation
Strategy
Public Forums
Superfund at Work
Congressional Briefings
Superfund Response Alerts
Superfund Brochures and Fact Sheets
Superfund Progress Reports
Community Relations Activities
Technical Review Committee
(Federal Facility)
Enhancement of
State Role
Support Development of
State Capability and
Expand State Participation
Deferral of Cleanup Responsibilities
at Non-NPL Sites to States
EPA/State Relationships
Technical Assistance
Core Program Cooperative Agreement
(CPCA)
Innovative
Technologies
Encourage and Foster the
Use of Innovative
Treatment Technologies
Treatability Studies
Superfund Innovative Technology
Evaluation (SITE) Program
Federal Facility Development of
Innovative Technologies/
Private-Public Partnership
Other
Core Activities that
Support the Superfund
Program
Contract Laboratory Program
Removal Support
Remedial Project Support
Comprehensive Environmental
Response, Compensation, and
Liability Information System
(CERCLIS) Data Base Management
Records Management
Program Management
Training
April 1994
1-6
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OSWER Directive 9200.3-14-2
ACCELERATED CLEANUP AND EMERGENCY RESPONSE
The technical complexity of hazardous waste site cleanup coupled with
complex Superfund site study and cleanup requirements have left the Superfund
program vulnerable to criticism on the slow pace of achieving cleanup. The
Administrative Improvements identified new and continued initiatives that
Regional managers should implement to accelerate cleanup. The initiatives that
are being implemented include:
Superfund Accelerated Cleanup Model (SACM) SACM was introduced in
FY 92, piloted with field demonstrations in FY 93, and is being implemented
in FY 94. The purpose of SACM is to streamline and accelerate the cleanup
process, resulting in prompt risk reduction and restoration of the
environment over the long term. A discussion of SACM is presented later in
this chapter;
Presumptive remedies Promoting the use of presumptive remedies for
cleanup of municipal landfills and volatile organic chemicals in soil and
expanding the use of presumptive remedies to other sites;
Dense Non-Aqueous Phase Liquid (DNAPL) contamination Developing
and implementing a methodology for quickly assessing the presence of and
developing a remedial strategy for addressing DNAPL contamination; and
Soil trigger levels Developing national soil assessment and cleanup trigger
levels for a variety of chemicals.
ENFORCEMENT
One of Superfund's major program challenges is to maximize PRP response.
Responsible parties have been performing an ever increasing proportion of
response actions at Superfund sites. Creative and effective use of all relevant
enforcement tools is essential to accelerating cleanup and completing
construction. In the spirit of the enforcement first initiative, the following
priorities have been identified for FY 94:
PRP search/compliance enforcement A high-caliber PRP search is the
foundation of EPA's enforcement process. Also, Regions are encouraged to
use administrative subpoena authorities in cases of non-compliance with
information requests issued under Section 104(e) and, if necessary, use
statutory penalty provisions to enforce compliance.
* Aggressively seek settlement for PRP response with more parties Well
planned negotiations need to be initiated and completed within the special
notice moratoria or schedules presented in general notice letters (GNLs).
1-7 April 1994
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OSWER Directive 9200.3-14-2
Cleanup negotiation process Regions should manage the cleanup
negotiation process within the timeframes established under Section 122.
Special Notice Letters (SNLs) should be issued in a timely manner.
Section 106 settlements Regions should be prepared to issue a UAO
promptly after the negotiation moratorium deadlines, if there are viable PRPs
and a settlement has not been reached.
Early action enforcement Regions should work to maintain or increase the
percentage of early actions conducted by PRPs, particularly time critical and
Non-Time Critical (NTC) removals and early actions under remedial
authority. Regions are required to support their early action enforcement
decisions in Record of Decisions (RODs) or Action Memoranda. A sound
Administrative Record (AR) will be the Agency's key to defending itself
against Section 106(b) claims from PRPs seeking reimbursement for their
early action costs.
Compliance monitoring Once a settlement is reached it is equally
important to effectively monitor PRP compliance with the UAO,
Administrative Order on Consent (AOC), or Consent Decree (CD).
Appropriate enforcement actions, including statutory penalties, should be
taken where there is failure or refusal to comply.
Federal Facilities To ensure Federal government accountability, continued
oversight of existing Interagency Agreements (lAGs) or Federal Facility
Compliance Agreements (FFCAs) is paramount.
ENFORCEMENT FAIRNESS
One of the most pressing matters facing the Superfund program is to ensure
that parties who have responsibility for cleanup are treated equitably. Speedy
and fair resolution of their liability is vital. The following initiatives address this
issue:
Greater use of allocation tools It is important that information on
allocation and liability issues be shared with PRPs early in the negotiation
process. EPA will offer Alternative Dispute Resolution (ADR) to facilitate
PRP allocation deliberations at sites with upcoming Remedial Design
(RD)/Remedial Action (RA) negotiations. The use of ADR may assist in
reaching an allocation of responsibility among the PRPs and save transaction
costs. Where possible and appropriate, Regions should prepare or adopt Non-
Binding Allocations of Responsibility (NBARs) to promote settlement.
Foster more small volume waste contributor settlements The main
objectives of the early de_ minimis settlement strategy are to reduce PRP
April 1994 1-8
-------
OSWER Directive 9200.3-14-2
transaction costs, preserve government resources, and settle with eligible de_
minimis parties quickly. In addition to settling with de_ minimis parties,
Regions are encouraged to identify sites where parties that have sent
extremely small amounts of waste, referred to as de micromis, are subject to
contribution actions and move to settle with those parties. Regions should
use an AOC for early de_ minimis and de micromis settlements.
Greater fairness for Superfund site owners Regions should provide site
owners an opportunity to submit information or meet with EPA before the
Agency imposes a lien on their property.
Evaluate the mixed funding policy During FY 94, the Agency will evaluate
the different mixed funding options, explore alternatives for streamlining the
mixed funding decision making process and the documentation required, and
pilot several mixed funding settlements.
Cost recovery In FY 94, the focus of the cost recovery program will be on
selecting and developing the best cost recovery cases that will maximize
recovery of Trust Fund monies. An active cost recovery program also will
encourage voluntary PRP cleanup action by eliminating incentives for PRPs
to allow the government to conduct the response action.
Non-settlors Includes vigorous pursuit of non-settlors, UAO enforcement,
and cost recovery of cases with response costs greater than $200,000 and viable
PRPs and selected cases under $200,000, including seeking penalties and treble
damages.
Voluntary cleanup A strategy is under development to encourage States to
manage projects that may not be on the Region's agenda for immediate
attention, but where the PRPs indicate a strong desire to proceed with
remediation.
BASE CLOSURES
Under the Base Realignment and Closure Acts of 1988 and 1990, 113 military
installations are scheduled for closure or realignment. Of this total, 21 sites are
on the National Priorities List (NPL), and there are a number of non-NPL sites
requiring some degree of decontamination. The Agency must continue to assist
the Department of Defense (DoD) in assessing these properties, accelerating
actions wherever possible, listing sites on the NPL where appropriate, and
ensuring that remedies selected at NPL sites meet Superfund criteria.
1-9 April 1994
-------
OSWER Directive 9200.3-14-2
CONSTRUCTION COMPLETIONS
EPA has publicly committed to increasing the number of NPL construction
completions. Construction completions continue to be an agency goal. The
construction completion target includes 265 sites by the end of FY 94 and 650 sites
by the end of the year 2000. Regions and States must work together to
continuously identify opportunities for expediting construction completions and
response actions. Maximum PRP involvement will be imperative to meeting
these goals.
Federal Facilities
The primary mission of OFFE is to ensure that the hazardous waste sites
owned or operated by the Federal government are addressed and cleaned up as
quickly as possible. Regional efforts should be focused on getting to completion
of construction activities at Federal Facilities whether they are accomplished
under remedial or removal authority.
EFFECTIVE CONTRACT MANAGEMENT
Good contract management is a Superfund priority, as well as an Agency-
wide priority. The Agency will continue to implement the recommendations of
the task force on Alternate Remedial Contracting Strategy (ARCS) contracts, and
build a future with reliable cost-effective contracts across the program through
implementation of the Superfund Long-Term Contracting Strategy (LTCS).
Responsible, knowledgeable, and reliable personnel should oversee the
procurement and administration of all Superfund contracts. Senior
management involvement is essential and all staff must work together and
communicate with their contracting support offices.
Federal Facilities
At Federal Facility sites, particular attention must be paid to potential or
actual conflicts of interest involving EPA contractors who also may be working
for another Federal agency. OFFE is developing a strategy for improving the
government's procurement process, addressing inter-agency conflicts of interest,
and the issue of contractor indemnification.
ENVIRONMENTAL JUSTICE AND MEANINGFUL COMMUNITY
INVOLVEMENT
Superfund will strive to assure that every citizen receives comparable
protection under CERCLA, regardless of ethnicity or economic status.
Accordingly, all communities must be guaranteed early and increasingly
April 1994 1-10
-------
OSWER Directive 9200.3-14-2
effective ways to participate in site decision-making, not only to accelerate
cleanups, but also to restore land for economic development. As part of the
Administrative Improvements, site specific strategies for addressing equity issues
at each site and a new Superfund environmental justice strategy will be
developed.
Public Involvement/Communicating Success
Superfund personnel must make a commitment to convey progress and
accomplishments at every opportunity. The public's perception of the
Superfund program will not improve unless they are meaningfully involved in
site decisions and informed of EPA's progress. The focus should be to recognize
and, where appropriate, consider their concerns and communicate early, often,
and always.
Federal Facilities
OFFE is working with the Office of Environmental Equity to establish
information exchange and create opportunities for joint policy-making with
other Federal agencies.
The Regions must continue to support citizen input at Federal Facility NPL
sites. This may be accomplished by participating in Technical Review
Committees (TRCs) and other community relations efforts such as
implementing Site Specific Advisory Boards (SSABs).
ENHANCEMENT OF STATE ROLE
EPA will encourage more environmental cleanup sooner, by expanding the
State role to address the potentially large number of sites now in the NPL listing
queue, and enlisting the States' participation in a complementary cleanup
program. EPA will not propose sites for the NPL that are being satisfactorily
cleaned up by a participating State.
INNOVATIVE TECHNOLOGIES
OSWER is seeking to further the use of innovative treatment technologies to
clean up permanently contaminated sites. Innovative technologies should be
routinely considered in all Feasibility Study (FS) projects and Engineering
Evaluations/Cost Analyses (EE/CAs), and these technologies should not be
eliminated as a feasible remedy solely because of uncertainties in their
performance or cost.
Ml April 1994
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OSWER Directive 9200.3-14-2
FEDERAL FACILITY INITIATIVES
Superfund Federal Facilities enforcement remains a key Agency issue because
of the high visibility and significant threat posed by military and weapons sites;
the impact of military base closings; the significant resources needed to oversee
DoD/Department of Energy (DOE) efforts at NPL sites; and heightened State and
local public interest. Federal Facilities program goals for FY 94 are based on a
number of related factors, including overall Superfund program goals,
anticipated resource constraints, Congressional interest, and statutory
requirements. In response, OFFE developed a strategic plan for the Federal
government's environmental management program which will promote
assistance to and coordination among Federal agencies while identifying high
priority environmental needs. This plan consists of traditional and non-
traditional strategies for preventing pollution, achieving and monitoring
compliance, and expeditiously cleaning up Federal hazardous and radioactive
waste sites. Exhibit 1-3 lists the ten points of the strategic plan.
EXHIBIT 1-3
ENVIRONMENTAL MANAGEMENT STRATEGIC PLAN
Involving Citizens in Federal Environmental Decision Making
Enforcing the Laws
Preventing Pollution
Accelerating Cleanup and Reuse of Closing Bases
Accelerating Site Cleanup and Restoration
Developing Innovative Technologies at Federal Facilities
Addressing Nuclear Weapons Complexes
Multi-media Enforcement
Conserving Natural Resources on Federal Lands
Building the Federal Environmental Infrastructure
April 1994
1-12
-------
OSWER Directive 9200.3-14-2
In addition to these initiatives, OFFE is also encouraging the following site
management strategies to accelerate cleanup:
Tiered oversight of Federal Facility cleanup activities. For example, reducing
oversight at facilities that have demonstrated consistently high performance
in field activities, self auditing, compliance, and response;
Use State and Resource Conservation and Recovery Act (RCRA) resources to
provide oversight, especially at non-NPL sites;
Increased use of Focused Feasibility Studies (FFSs), interim RODs and
presumptive remedies; and
Initiating the RD before the ROD is signed.
Integrated Management Strategy
The Office of Enforcement (OE)/OFFE is also developing an "Integrated
Management Strategy" (IMS) cleanup plan. The purpose of the IMS is to work
with Federal agencies to reach agreements on key cleanup issues that will result
in acceleration at the field and technical level across all agency programs. The
key elements of the IMS are listed in Exhibit 1-4. For additional information on
the Federal Facilities initiatives, see the Superfund Program Implementation
Manual, Volume II, Appendix D.
1-13 April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT 1-4
INTEGRATED MANAGEMENT STRATEGY
Define the Scope and Cost of the Federal Government Legacy from
Past Practices
Set National Cleanup Goals Each Year Against Which the Public
and Congress Can Measure Progress
Develop Presumptive Remedies for Pollution Problems that are
Commonly Found at a Number of Federal Sites
Re-evaluate the Quality Assurance/Quality Control Requirements
for Sampling and Analysis During Remedial Investigation (RI)
Improve the Government's Procurement Process, Address Inter-
Agency Conflict of Interest (COI) and Contractor Indemnification
Use Federal Facilities as Testing and Demonstration Centers for
Developing Innovative Site Assessment and Cleanup Technologies
Transfer the Lessons Learned in the Base Closure Program to the
Cleanup Program at Large
Establish an Annual Planning Process for Federal Facilities that
Focuses on Priority Problems
Establish an Annual Environmental Liability Reporting
Requirement
SUPERFUND ACCELERATED CLEANUP MODEL (SACM)
OSWER, through its continued investigation of ways to make the Superfund
program more efficient, developed a model for streamlining the Superfund
program. The purpose of SACM is to accelerate and increase the efficiency of
hazardous waste cleanups.
Expectations for implementation of SACM in FY 94 are summarized below:
SACM is the usual way of doing business at Superfund sites In FY 92 and
FY 93, the SACM concept was developed and the principles were applied to
various pilot projects and other sites, where appropriate. The results of these
projects were shared within the program and with outside interest groups
April 1994 1-14
-------
OSWER Directive 9200.3-14-2
through mid-year and end-of-year pilot reports. The results of SACM projects
in FY 94 will continue to be evaluated and shared because the success of these
shared experiences will enable the program to move forward with applying
SACM principles to all Superfund sites.
Regions should have an up-to-date site inventory and workplan This is a
two-step process. Regions should first establish an inventory of all known
NFL and non-NPL sites. This inventory should be updated periodically and
include everything except for "classic" emergencies that are unpredictable by
nature. Regions should condense the inventory by culling out sites that need
no Federal response. The remaining sites will be the basis for developing an
annual workplan of sites on which to focus. When developing the workplan,
Regions should work with the States and begin to identify sites appropriate
for State lead. The Regional Decision Team (RDT) should use the inventory
and workplan to ensure that the worst sites are given the highest priority.
The Regions should use the most appropriate response authority to address
each site (i.e., enforcement, removal, remedial, State lead).
Regions should substantially reduce the Site Inspection Prioritization (SIP)
backlog As Regions develop their workplans, it is important that decisions
are made on sites that have received Preliminary Assessments and Site
Inspections (P As/Sis). Eliminating the SIP backlog will allow the program to
better deal with new sites.
Prior to the implementation of SACM, a number of NPL sites started the
remedial process under the traditional Superfund pipeline. These sites will
proceed under that pipeline to completion. Regions should continue, however,
to explore possibilities for expediting cleanup at these sites, reflecting the
principles of timeliness and efficiency that are the underpinnings of SACM
implementation.
The two models of the Superfund process will operate simultaneously in FY
94. Exhibit 1-5 provides a simplified comparison of SACM and the traditional
Superfund process.
In FY 94, the Agency will analyze critical portions of the SACM pipeline to
show progress in Superfund cleanups. These measures will address the need for
continuous improvements relative to meeting the program's goal of accelerating
cleanup and reducing risk. The following indicators will be tracked:
Duration from Site Discovery to Site Construction Completion;
Duration from Cleanup Decision to RD Completion;
Duration from Cleanup Decision to Each Cleanup Action Completion;
1-15 April 1994
-------
OSWER Directive 9200.3-14-2
Percent of Sites with Early Actions;
Duration from Regional Decision or ROD to PRP Cleanup Negotiation
Completion; and
Percentage of PRP-Lead Cleanup Actions to All Cleanup Actions.
Each of the elements of SACM are summarized in the following sections. For
more detailed information on implementing SACM, see the Superfund Program
Implementation Manual, Volume II, Appendices A-C.
April 1994 1-16
-------
OSWER Directive 9200.3-14-2
EXHIBIT 1-5
SIMPLIFIED COMPARISON OF SUPERFUND "PIPELINES"
^ . ^ f j n Superfund Accelerated
Current Superfund Process a/an^p Model (SACM)
Enforcement
Activities/
State
Participation/
Community
Relations
Site Discovery
i
Preliminary Assessment (PA)
Site Inspection (SI)*
Expanded Site Inspection (ESI)
I
Hazard Ranking System(HRS)
National Priorities List (NPD*
I
Remedial Investigation (RI)/1
Feasibility Study (FS)*
Selection of Remedy/
Record of Decision (ROD)
1
Remedial Design (RD)
Remedial Action (RA)
I
Operation and
Maintenance (O&M)
I
NPL Deletion
Site
Screening &
Assessment
(PA, SI, ESI, RI)
'Assessments combined
Removal
Action, As
Necessary
* Indicates assessment phase of pipeline
Regional
Decision
Team
Long-
Term
Hazard
Ranking
Early
Action
Long-
Term
Action
Early
Action
Complete
Cleanup
Complete
Enforcement
Activities/
State
Participation/
Community
Relations
1-17
April 1994
-------
OSWER Directive 9200.3-14-2
INTEGRATED TIMELINE FOR SITE MANAGEMENT
The Integrated Timeline (Exhibit 1-6) is a multi-step site management process
that identifies critical decision points and spans 46 quarters. It provides an
overview of the major remedial and enforcement activities required in the
Superfund long-term cleanup process. The timeline has been updated to
incorporate the trend analyses performed over the last three years.
To embody the concept of good timeline management, trends analyses will
continue to be undertaken in FY 94 for sites that are currently going through the
traditional Superfund pipeline. For internal management purposes, the average
duration will be trackedby Regionfor sites where RD starts or RA starts are
planned in FY 94 as follows:
ROD to RD start; and
ROD to RA start.
In addition, RI/FS start to completion time frames and cleanup negotiation
time frames also will be tracked.
The Federal Facilities program also will be tracking the following durations
and timespans under Superfund Comprehensive Accomplishments Plan
(SCAP):
NPL listing to RI/FS start;
RI/FS start to RA complete;
ROD to RA start;
RD start to RD complete; and
RA start to RA complete.
The durations in the Integrated Timeline should be used unless more
accurate estimates are available. When better planning data and schedules are
developed, Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS) must be revised to reflect these
schedules.
April 1994 1-18
-------
EXHIBIT 1-6
INTEGRATED TIMELINE
vo
1
PHASES OF Elapsed time in Quarters
ACTIVITY 2 4 6 8 10 12 14 16 18 20 22 24
RP Search and
Notification
Rl/FS
Negotiation
Rl/FS
Settlement
Rl/FS
RD/RA
Negotiations
Community
Relations
Cost
Recovery
104
id /
RIFS
dminisl
tecord
\
RPS
>csiGr<
RIFS
ative
1
RPS
ED
RIFS
RPS
RIFS
RPS
RIFS
Sup
CRP
RPS
RIFS
dement
Notice 1:
RPS
Dm
RIFS
IGener
sued
RPS
IRI
RIFS
K
RPS
RIFS
Or,
^
RPS
On
P
RIFS
lit FS Re
Pu
F
RPS
iftFSRe
roposed
RIFS
s*
Mtt
ilic Meet
actShec
RPS
3ort&
Plan
RIFS
ng.
*~X\
IX
RPS
ROD
RPS
RPS
U-
SNP SNP SNP SNP{4
NP
NP
PCI
Update
Documentation
Past Costs
NP NP/N
Good
Ot
on
Faith '
er
CRPR
K.
"CDRl =
CM 1 =
CRPRl =
TRA] =
GNP 1 =
HZ] =
NP 1 =
HcH =
PRA 1 =
RJFSl =
RPS 1 =
3NE] =
.ROD Si
Spe
N
K
Up
LEGEND
CD Referral
Community Relations Plan
Compliance Monitoring
CRP Revised
Fund RA
Fund RD
General Notice Preparation
Negotiations
Negotiation Preparation
Public Comment
PRPRA
PRPRD
Rl/FS
Responsible Party Search
Special Notice Preparation
-Settlement Preparations
=UAO
=RD Done Under UAO
gnature
cial Noli
ssued
N 1
ce
^F
date Do.
ictShee
cumenta
Costs
ion on P
ast
PHASES OF 2 4 6 8 10 12 14 16 18 20 22 24
ACTIVITY Elapsed Time in Quarters
OSWER Directive 9200.3-14-2
-------
EXHIBIT 1-6 (continued)
INTEGRATED TIMELINE
8
^
w
HH
1
N)
0
PHASES OF Elapsed Time In Quarters 1^7
ACTIVITY 22 24 26 28 30 32 34 36 38 40 42 44 ^50
RD/RA
Settlement/
Referral
RD
RA
Community
Relations
Cost
Recovery
|SP
CD SI
1
gned
SP I SP
/Decl
\ re- CD
\Func
/Dec
/ re:
\Enfon
Bton\
rtJAO >
RD /
G **~
stoi\
MO \
»ment/
CDR
- UAOI
CDR
ssued
FRD or UAOD + CM
_L
FHD or UAO[
tCM
LEGEND
[ CDR 1 =CD Referral
CRP -C
CM 1 =C
[CRPRl =C
TRA! =F
FRDl =F
GNPl =G
ommunity Relations Pit
ompliance Monitoring
RP Revised
und RA
undRD
eneral Notice Preparat
in
on
N =Negotiations
1 NP 1 ^Negotiation Preparation
1 PC 1 =Pubhc Comment
fPRTl =PRPRA
1 PRDl =PRPRD
1 RIFS 1 =RI/FS
rRPSl =Responsible Party Search
1 SNP 1 =Special Notice Preparation
1 SP 1 =Settlement Preparations
1 U 1 =UAO
lUAQDl =RD Done Under UAO
FRA
PRA & CM
1 l
File First Claim fa
Oversight Costs
I/I
1
"~
F
lie Claim
RQ
for Fun
TtA
1
PHASES OF 22 24 26 28 30 32 34 36 38 40 42 44 /£r50
ACTIVITY ilapsetf Time In Quarters /r
' l«»MH««M«8M{^^
J
Directive 9200.3-14-2
-------
OSWER Directive 9200.3-14-2
SCAP/STRATEGIC TARGETED ACTIVITIES FOR RESULTS SYSTEM (STARS)
TARGETS AND MEASURES
New targets and measures for FY 94 have been developed to align the
program more closely with SACM. Targets and measures developed for FY 94
are broader in scope than in FY 93. A concerted effort was made to combine
targets and measures that in the past were tracked separately to provide
maximum flexibility to the Regions in program implementation, and provide
incentives for conducting actions at problem sites prior to NPL proposal. By
incorporating and tracking cleanup actions on a broader level, the FY 94 targets
and measures provide more program-wide measures of progress being made
towards site cleanup, not just those activities at NPL sites.
Every attempt has been made to equate SACM activities and definitions to
pre-SACM activities and definitions. Many of the targets/measures and
definitions embody the FY 93 targets/measures. For example, FY 93 RA
Completions are characterized in FY 94 as Early and Long-Term Action
Completions (ACT-6); therefore, pre-SACM sites completing a RA in FY 94
would receive credit for an Early and Long-Term Action Completions (ACT-6).
Semi-annual targets are established in SCAP/STARS. Accomplishments will
be pulled from CERCLIS on a quarterly basis on the date specified in the Manager's
Schedule of Significant Events at the beginning of the Manual. Any exceptions to
the SCAP/STARS accomplishment definitions provided in the Appendix will be
handled on a case-by-case basis. Exception requests must be provided in writing to
the appropriate HQ office and formally approved.
Exhibit 1-7 presents the targets/measures and indicates if they are STARS
and/or SCAP. The Superfund Program Management Manual Appendix
contains STARS/SCAP definitions.
1-21 April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT 1-7
FY 94 SCAP/STARS TARGETS AND MEASURES
Target/Measure
STARS
SCAP
Site Screening and Assessment
SSA-l Site Characterization Starts
SSA-2 Site Screening and Assessment Decisions
Regional Decision
RDT-l Decision Document Developed
Early and Long-Term Actions
ACT-l Duration from Site Discovery to Site Completion
ACT-2 Duration from Cleanup Decision to RD Completion
ACT-3 Duration from Cleanup Decision to Each Cleanup
Action Completion
ACT-4 Percent of Sites with Early Actions
ACT-5 Sites Addressed Through Early or Long- Term
Action Starts
ACT-6 Early and Long- Term Action Completions
ACT-7 NPL Site Construction Completions Through Early
or Long-Term Actions
ACT-8 Non-NPL and NPL Caliber Site Construction
Completions Through Early or Long-Term Actions
ACT-9 Five-Year Review Starts
Enforcement
ENF-1 Duration From Regional Decision or ROD to PRP
Cleanup Negotiation Completion
ENF-2 Cleanup Negotiation Completion
ENF-3 Settlements for Cleanup Actions
(including dollar value)
ENF-4 De minimis Settlements and
number of PRPs
ENF-5 Percentage of PRP Lead Cleanup Actions to All
Cleanup Actions
ENF-6 Past Costs Addressed >$200,000
(number of actions and dollar value)
MEASURE
TARGET
MEASURE
MEASURE
TARGET
TARGET
MEASURE
TARGET
MEASURE
TARGET
MEASURE
MEASURE
TARGET
MEASURE
MEASURE
MEASURE
MEASURE
MEASURE
MEASURE
TARGET
MEASURE
MEASURE
MEASURE
TARGET
MEASURE
TARGET
MEASURE
TARGET
April 1994
1-22
-------
OSWER Directive 9200.3-14-2
EXHIBIT 1-7 (continued)
FY 94 SCAP/STARS TARGETS AND MEASURES
Target/Measure
STARS
SCAP
Environmental Indicators
EI-l Progress Through Environmental Indicators
Federal Facilities
FF-l Base Closure Decisions
FF-2 FFA/IAG
FF-3 FFA/IAG Completions
FF-4 Federal Facility Dispute Resolutions
FF-5 RI/FS Starts (First and Subsequent)
FF-6 Timespan from NPL Listing to RI/FS Start
FF-7 RI/FS Completions (RODs) (First and Subsequent)
FF-8 RI/FS Duration
FF-9 RD Starts (First and Subsequent)
FF-10 RD Completions (First and Subsequent)
FF-11 RD Duration
FF-12 RA Starts (First and Subsequent)
FF-13 Timespan from ROD Signature to RA Start
FF-14 RA Completions (First and Subsequent)
FF-15 Final RA Completion
FF-16 RA Duration
FF-17 Timespan from RI/FS Start to RA Complete
FF-18 Removal/ERA/RCRA Corrective Action Starts and
Completions
FF-19 Federal Facility NPL Deletion
MEASURE
MEASURE
MEASURE
TARGET
MEASURE
TARGET
MEASURE
MEASURE
MEASURE
MEASURE
MEASURE
MEASURE
TARGET
MEASURE
TARGET
MEASURE
MEASURE
MEASURE
MEASURE
MEASURE
MEASURE
TARGET
TARGET
MEASURE
MEASURE
MEASURE
MEASURE
1-23
April 1994
-------
-------
OSWER Directive 9200.3-14-2
CHAPTER II
PROGRAM PLANNING
AND REPORTING REQUIREMENTS
April 1994
-------
-------
OSWER Directive 9200.3-14-2
CHAPTER II - PROGRAM PLANNING AND REPORTING
REQUIREMENTS
INTRODUCTION
This chapter presents the response, enforcement, and Federal Facilities
planning and reporting requirements. During the development of this Manual
the Administrator was evaluating options for the integration and reorganization
of OWPE and OE. At the time of printing, a decision has been made to form the
Office of Enforcement and Compliance Assurance (OECA). Though a majority of
the planning and reporting requirements are not expected to be affected by the
reorganization, the HQ contacts and the specific requirements for transferring
information and documents from the Regions to HQ will probably be revised. In
this manual, OECA is used as the Regional contact point for all Superfund
enforcement issues. When the roles and responsibilities have been defined and
new procedures developed, an addendum to the Manual may be issued.
INTEGRATED PLANNING
Planning in the Superfund program is accomplished through the budget,
SCAP, and the performance evaluation process. Successful planning requires the
reflection and accurate costing of program priorities in the budget and workload
model, and translation of the priorities and resource requirements into specific
output commitments in SCAP and STARS. Candid evaluation of performance
against these commitments is essential to assess the viability of program
priorities, resource requirements, and overall effectiveness.
Integrated planning is the responsibility of HQ, Regional program offices,
Regional finance offices, the States, the Office of Regional Counsel (ORC), and
DOJ. Information on planned activities should also be coordinated with the
Natural Resources Trustees and the Agency for Toxic Substances and Disease
Registry (ATSDR). To provide adequate resources for priority actions at
Superfund sites, HQ allocates resources within and between response actions and
enforcement activities. Regions are responsible for providing data on the level
of resources needed to accomplish those priority activities and negotiate
commitments consistent with realistic site planning. Regions should not accept
targets that require completion of activities that cannot be funded or staffed
within the resources provided. This requires Regions to reconcile FY 95 targets
and their Superfund pipeline with the financial operating plan proposed by HQ.
Budget flexibility is greatest in the planning years. Realistic outyear planning
data (milestones and funding needs) allows HQ to prepare requests for resources
based on Regional needs. Exhibit II-l summarizes levels of flexibility as the
II-l April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT II-l
FLEXIBILITY SCALE FOR BUDGETING/PLANNING
Minimum
Maximum
Operating Year Budget
(FY94)
Planning Year Budget
(FY95)
Outyear Budget
(FY96)
1. Operating Plan Establishes
Funding Ceiling (93/4)
Development of Operating
Plan Begins 6 Months Prior to
FY; 90 percent of Operating
Plan based on Prior Year's
Obligations (Begins 94/2)
Formulation Begins 12-18
Months Prior to FY;
Largely Dependent on
Regional Planning Data in
CERCLIS
(Begins 94/3)
2. Semi-Annual Targets are Set -
- STARS targets can be
changed only through formal
Regional Administrator
request
- Sites can be substituted to
meet commitments
2. SCAP/STARS Targets
finalized in August
2. No Targets Set but
Schedules
and Estimated costs for RA
and Early Action Under
Remedial Authority Help
to Drive Budget Request
3. Pricing Factors are Set -
Cannot Change Pricing on
Events/Activities
3. Pricing Factors can be
changed through
Regional/HQ Consensus
3. Pricing Factors are Subject
to Review
4. Additional Funds can only
be Obtained through
Special Requests
4. The Budget is Set but
There is More Leeway to
Make Adjustments based
on Proven Need
4. Budget is Constrained
Based on Resource Cap
Imposed by AA and
Administrator Unless
Exception can be Justified
5. Regions have Flexibility
within General Budget and
AOA Structure to Shift
Funds to Meet Priority
Activities
5. Regions Request Funds to
Meet Regional Pipeline
Goals and National
Program Priorities
5. Maximum Flexibility to
Design Budget to Optimize
Cross-Program Priorities
6. Mid-Year SCAP
Evaluation Used to Realign
Current Year Resources
6. Final SCAP Targets Set
Final Resource Levels
(94/4)
7. Flexibility on Dollars much
Greater than FTEs through
Reg. Reprogramming
7. Flexibility on Dollars and
FTE may be Constrained
by President's Budget
operating year is entered. Major phases in the decision making continuum
include:
Formulation of the outyear budget occurs 12 to 18 months prior to the FY.
Development of the budget includes identification of major program issues,
analysis of program costs, and alignment of resources among competing
priorities. These activities receive resource allocations that are established by
the Administrator and the Assistant Administrator for the Office of Solid
Waste and Emergency Response (AA SWER) or the Assistant Administrator
for the Office of Enforcement Compliance Assurance (AA OECA). These
April 1994
II-2
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OSWER Directive 9200.3-14-2
allocations balance the needs of the Superfund program with the needs of
other Agency programs.
Development of the initial operating plan occurs six months prior to the FY
and is finalized before the start of the FY. The proposed response and
enforcement operating plans are developed based on the average amount of
money obligated/tasked by the Region over the past three years. The Federal
Facility operating plan is based on the number of sites on the NPL. OSWER
and OECA negotiate the final operating plan based on Regional response to
the initial operating plan, the Regional pipeline, past Regional
accomplishments and planned durations/dollars, Regional requests for the
budget reserve, and associated SCAP/STARS output commitments. OSWER
and OECA provide resources to support the program through the Advice of
Allowance (AOA) and workload process. Regions are expected to work
within the annual Regional budgets established at the start of the year until
the mid-year evaluation. Regions have flexibility within the general budget
and AOA structure to shift funds as needed to meet priority activities. (See
Chapter III for additional information on shifting funds.) Once the operating
plan is established at the start of the year, additional resources generally can be
shifted to a Region only at the expense of resources from other Regions.
However, HQ may shift funds among the Regions depending on the level of
use and need.
Use of the mid-year evaluation to realign resources in the current FY.
Current year resource adjustments focus on changes needed due to cost and
project schedule modifications. Changes may result in shifts within program
areas and among Regions, and revised annual funding levels. Estimates
developed in April/May for the upcoming FY represent the first formal
opportunity for changing resources among program areas at a national level.
The revised resource estimates also serve as a "baseline" for examining
program needs in the budget year.
Exhibit II-2 describes the information flow and HQ and Regional
responsibilities associated with integrated planning.
INTRODUCTION TO THE SUPERFUND COMPREHENSIVE
ACCOMPLISHMENTS PLAN (SCAP)
The SCAP process is used by the Superfund program to plan, budget, track,
and evaluate progress toward Superfund site cleanup. The SCAP planning
process is a dynamic, ongoing effort that has a significant impact on Superfund
resource allocation and program evaluation. Planned obligations and STARS
targets and measures are generated through SCAP and influence the Superfund
budget and evaluation process. SCAP planning is a day-to-day responsibility of
the Regions. An annual process has been established through which HQ and
II-3 April 1994
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OSWER Directive 9200.3-14-2
EXHIBIT II-2
HQ/REGIONAL INTEGRATED PLANNING RESPONSIBILITIES
Regional Responsibilities
HQ Responsibilities
Manage projects to integrate
Enforcement and Fund milestones
and to ensure schedules and
timelines are met
Negotiate and assess the status of
response and enforcement
mega-sites
Involve the State, ORC and finance
offices in the planning process
Provide accurate, complete and
timely project planning data in
WasteLAN and assure that data are
accurately uploaded to CERCLIS
Follow established planning
procedures and requirements so
that HQ has a common basis with
which to evaluate Regional
proposals (See Chapter III and
Volume II Appendices)
Assess Federal agencies cleanup
needs identified as part of the Office
of Management and Budget (OMB)
A-106 process
Identify multi-media planning and
cleanup opportunities
Recognize that missed
commitments severely impact
resource availability
Identify potential unused funds and
return them to HQ within
reasonable timeframe for
redistribution
Establish a combined Fund and
Enforcement hierarchy of program
priorities in consultation with the
Regions to be used in negotiations
and adjustments of targets (See
Integrated Priority Setting Matrix,
Chapter I)
Review integrated operating plans
and site commitments proposed by
the Regions prior to negotiations
Coordinate OSWER, OECA, OFFE,
DOJ, Financial Management
Division (FMD), and the Office of
Administration and Resources
Management (OARM) activities
throughout the planning process
Work with Regional managers to
formulate preliminary resource
requests and determine how
resources should be adjusted to
meet program priorities
Negotiate and assess the status of
response and enforcement
mega-sites
Communicate with the Regions on
changes/additions to SCAP
schedules
Provide funding and FTE levels
consistent with each Region's active
pipeline phases, shifting Regional
resources if needed to support
priority activities
Develop policy and guidance in
response to Congressional or
Agency initiatives
April 1994
II-4
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OSWER Directive 9200.3-14-2
Regions formally negotiate plans for the future. CERCLIS serves as the conduit
for the SCAP process by providing both HQ and Regions with direct access to the
same data. Reports can be produced allowing for daily, interactive updates of
planning and site cleanup progress information.
RELATIONSHIP OF SCAP TO OTHER MANAGEMENT TOOLS
The SCAP process is crucial to Superfund program planning, tracking, and
evaluation. As the Superfund program's central planning mechanism, it is
interrelated with all Agency and Superfund program specific planning and
management systems, including the EPA and Superfund strategic plans, the
Superfund budget, Agency Operating Plan, STARS, and the Superfund workload
models. SCAP/STARS targets/measures are designed to reflect the strategic
plans and the Agency's goals and priorities for the upcoming year. In some cases,
new SCAP categories are developed, or the projections for SCAP activities are
adjusted to match the Agency's goals.
The Management Tools
Most of the Superfund program's budget is based on SCAP. The operating
year's budget is developed 18 months prior to its beginning. For example, SCAP
data existing in the third quarter of FY 94 will be used to formulate the FY 96
budget and the total level of FTEs to be made available for distribution through
the workload model.
The Superfund budget provides the basis for the Agency Operating Plan. The
Operating Plan, which is finalized prior to the FY, establishes the funds available
to the Regions for performing Superfund work. Enforcement operating plans
are adjusted in the first quarter of the FY based on Regional contract carryover.
STARS is used by EPA to set and monitor the Agency's environmental
objectives for a FY. National and Regional STARS goals for Superfund are
established and tracked through SCAP and the STARS data base. STARS targets
are a subset of those contained in SCAP. STARS targets and measures are
reported quarterly by the Regions to the Office of Policy, Planning, and
Evaluation (OPPE). OPPE tracks Regional progress toward STARS goals on a
quarterly basis as part of the overall Agency performance evaluation process. HQ
will not recognize a STARS accomplishment unless it is correctly recorded in
CERCLIS and the STARS data base.
The Superfund workload models distribute FTEs for each program and
Region. There are three Superfund program models: the Hazardous Site and
Spill Response model, which distributes resources for the site assessment and
response programs; the Technical Enforcement model, which distributes
enforcement FTEs and extramural dollars; and the Federal Facilities Superfund
Workload model, which distributes resources for response and enforcement
II-5 April 1994
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OSWER Directive 9200.3-14-2
activities at Federal Facilities. SCAP plans form the basis of the workload
models. In FY 94, each Region's FTEs are frozen at the FY 90 levels. While the
freeze ensures that the total Regional Superfund resources are not affected,
shifting of resources within the Region among the different program areas to
support Agency/Regional program priorities may occur. The workload models
are expected to be unfrozen in FY 95 and new models are currently under
development.
OFFE will coordinate with OERR and OECA throughout the SCAP process.
OFFE will rely on CERCLIS data in planning, budgeting, tracking, and evaluating
progress at Superfund Federal Facility sites. CERCLIS data are used, in part, to
feed the Federal Facilities workload model. In addition to CERCLIS, OFFE and
the Regions will utilize information gathered in conjunction with the A-106
Pollution Abatement Planning Process to evaluate the adequacy of other Federal
agency budgeting for Superfund sites. These data will enable OFFE and the
Regions to evaluate actual outlays and accomplishments at Superfund sites as
they relate to budget authorities and obligations.
The Superfund Information Systems
Effective management of the Superfund program requires the availability of
accurate information on Superfund sites throughout the country. CERCLIS was
developed in the mid-1980s as an integrated system to hold national site
assessment, remedial, removal, enforcement, and financial information. To
facilitate Regional use of the information in the centralized CERCLIS data base, a
local area network (LAN) version of CERCLIS, called WasteLAN, was
implemented. In this Manual, the term CERCLIS is used when discussing
official program data and HQ information management tools as well as to
encompass both the CERCLIS (site specific) and CERHELP (non-site specific) data
bases. WasteLAN is used when discussing rules for the Regions to follow when
entering and updating site and non-site specific information.
OVERVIEW OF THE SCAP PROCESS
The SCAP process generates data that fulfill the following functions:
Tracking of accomplishments against targets/measures;
Updating planning (schedules and funds) for the current FY;
Developing planning data for the upcoming FY; and
Providing data for outyear budget planning purposes.
The SCAP planning cycle begins in late April/early May and ends with
formal negotiations in late August. It is essential that SCAP data remain current
April 1994 II-6
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OSWER Directive 9200.3-14-2
and up-to-date throughout the year and that accomplishments be reported as
soon as they occur. Site schedules and financial planning information should be
reviewed and updated on an ongoing basis (at a minimum on a monthly basis).
HQIREGIONAL ROLES AND RESPONSIBILITIES
Maintaining SCAP in CERCLIS
Exhibit II-3 describes the HQ/Regional responsibilities for maintaining SCAP
data in CERCLIS/WasteLAN.
EXHIBIT II-3
HQ/REGIONAL SCAP AND CERCLIS RESPONSIBILITIES
Regional Responsibilities
HQ Responsibilities
Maintaining CERCLIS/WasteLAN and
selected portions of the CERHELP data
base
Planning and scheduling all events and
enforcement activities from site assessment
and PRP search through NPL deletion
Keeping SCAP planning data current in
WasteLAN, including updating site
schedules established at the ESI/RI stage
and cost estimates for long-term action and
early action under remedial authority when
better planning data become available
Updating site back-up in the CERHELP
Targets and Accomplishments data file to
reflect adjustments to SCAP throughout the
year
Reporting accomplishments in WasteLAN
as they occur
Reconciling WasteLAN financial data with
Integrated Financial Management System
(IFMS) and Technical Enforcement Support
Work Assignment Tracking System
(TESWATS) data
Uploading WasteLAN data to CERCLIS on
a regular basis
Entering and maintaining quarterly
planning, budget, and accomplishment
reporting in CERHELP for non-site specific
activities
Preparing SCAP amendments and change
requests
Tracking and maintaining the enforcement
extramural budget and the Federal
Facilities budget
Entering negotiated final SCAP/STARS
targets and measures and site back-up in
the CERHELP Targets and
Accomplishments data file
Updating the numbers and site back-up
in the Targets and Accomplishments data
file to reflect approved amendments to
the SCAP throughout the year
Entering preliminary and final budget
data in the CERHELP Budget Control
(BC)/AOA system
Determining the AOA based on SCAP
planned activities in CERCLIS
Entering and maintaining AOA data in
the CERHELP BC/AOA system
Responding to Regional requests for
changes in plans through the
amendment/change request process
11-7
April 1994
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OSWER Directive 9200.3-14-2
Program Assessment
HQ and the Regions have different roles and responsibilities in Superfund
program evaluation and management, as shown in Exhibit II-4.
The Superfund evaluation process provides managers with an opportunity to
meet program objectives by:
Examining program accomplishments;
Analyzing and discussing issues that affect the successful operation of the
Superfund program; and
Initiating changes in program operations or reallocating/redirecting
resources.
The strategy for assessing the performance of the Superfund program is
comprised of the following:
Establishing semi-annual and annual targets and planning measures;
Quarterly reporting of response and enforcement SCAP/STARS
accomplishments based on CERCLIS data;
Semi-annual reporting of response internal measures and Federal Facility
SCAP/STARS accomplishments based on CERCLIS data;
Quarterly evaluation of enforcement accomplishments against internal
measures;
Semi-annual performance evaluation; and
Regional reviews.
This strategy enables management to recognize high performance,
concentrate Superfund resources in those Regions that demonstrate success, and
provide training and technical assistance to those Regions that are experiencing
difficulties.
In addition to the program management and assessment tools traditionally
used by OSWER, OFFE will also be utilizing the A-106 Pollution Abatement
Planning Process to ensure sufficient Federal agency funding of response
programs. Modifications to the A-106 process have been made to provide OFFE,
Regions, OMB, other Federal agencies, and Congress with improved information
to evaluate accomplishments at Federal Facilities.
April 1994 II-8
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OSWER Directive 9200.3-14-2
EXHIBIT II-4
EVALUATION RESPONSIBILITIES
Regional Responsibilities
HQ Responsibilities
Meet quarterly SCAP and STARS
targets and solve performance
problems when they arise
Provide quarterly SCAP and
STARS data to HQ through
CERCLIS
Maintain CERCLIS data quality at
high levels for Superfund program
and project management
Negotiate performance standards
that provide individual
accountability for targets
Assess Federal agency needs
identified during the OMB A-106
process
Participate in the Regional reviews
Provide guidance to the Regions for
the quarterly reporting, the mid-year
assessment, the year-end assessment,
and Regional reviews
Implement and report on follow-up
action items from the Superfund
quarterly and/or mid-year
assessment and Regional reviews
Review performance data reported by
the Regions and assist Regions having
difficulties in meeting targets
Conduct Regional reviews
Continually assess program
performance and analyze timeliness
and quality of work
Recommend resource reallocation
based on Regional needs and
performance
Assure that all staff are informed of
the results of performance reporting
Compare Federal agency budget
authorities, obligations and outlays to
monitor cleanup activities
PROCEDURES FOR ANNUAL TARGET SETTING
The process for developing SCAP and STARS targets/measures for a FY
begins with the SCAP developed during the third quarter of the previous FY. All
targets/measures are established in August only after negotiations between
OERR, OECA, OFFE, and the Regions. In the Regions, a joint review of
commitments should be undertaken by the program office and ORC. The dates
for pulling CERCLIS data that will be used in developing the proposed Regional
operating plan, generating the Regional workload and budget, and negotiations
II-9
April 1994
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OSWER Directive 9200.3-14-2
can be found in the Manager's Schedule of Significant Events presented at the
beginning of this Manual.
The Region's focus in preparing for negotiations should be on its individual
pipeline (i.e., more site assessments or more construction completion oriented),
the overall goals and priorities of the program, and how it can achieve its
portion of the national effort given proposed resources. HQ compares Regional
plans with program goals and resource allocations. In addition, HQ reviews past
Regional accomplishments and planned durations/dollars to ensure that the
Region is planning the appropriate amount of work given the dollars it is
requesting. This provides HQ with a benchmark going into negotiations on
what the Region should be able to accomplish based on its unique pipeline
status.
The procedures for target setting for the upcoming FY are contained in Exhibit
II-5.
PLANNING FOR NEGOTIATIONS
Regions are required to keep the SCAP data in WasteLAN and CERCLIS up-
to-date and accurate. Changes in planning information (schedules and funds)
should be entered into WasteLAN within five days after the Remedial Project
Manager (RPM)/On-Scene Coordinator (OSQ/Site Assessment Manager (SAM)
are aware of the need for the change.
Planning Process
As a final check to ensure that SCAP data are up-to-date, Regions should
generate CERCLIS SCAP and Audit reports routinely, especially those Regions
that have delegated responsibility for entering information into the WasteLAN
data base to RPMs, OSCs, and SAMs. At an absolute minimum, reports should
be generated prior to HQ development of the proposed operating plan and in late
June for internal review of the planning data in CERCLIS. These planning data
should reflect any adjustments or approved amendments made to the annual
plan. Exhibit II-6 outlines the steps a Regions must go through to prepare for
negotiations.
On the fifth working day of July, HQ pulls SCAP reports from CERCLIS. The
data in these reports serve as the basis for HQ/Regional final negotiations. HQ
will perform all negotiations based on the information in CERCLIS on these pull
dates. To ensure consistency in the negotiation phase, the CERCLIS data bases
are frozen prior to pulling the reports used for negotiations. As a result, all
parties (HQ and the Regions) will have identical data for use during the
negotiation process.
April 1994 11-10
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OSWER Directive 9200.3-14-2
EXHIBIT II-5
PROCEDURES FOR ANNUAL TARGET SETTING
Month
Regional Responsibilities
HQ Responsibilities
April/May
Consult with States and ORC
on FY 95 activities
Prepare program and
enforcement Regional operating
plan based on past three years
average Regional
obligations / tasking
Analyze Regional pipelines
Allocate 90 percent of FY 95
budget to Regions (proposed
operating plan)
May/June
Update site schedules and
funding needs based on
proposed operating plan,
Regional pipeline, and national
goals and priorities
June
Submit enforcement mega-site
plans
July
Participate in HQ conference
calls on analysis of Regional
plan
Review Regional SCAP/STARS
and pipeline workload and budget
Review past Regional
accomplishments and planned
durations /dollars
1 Review Regional requests for 10
percent budget reserve
1 Prepare Federal Facility Regional
operating plan based on the
number of NPL sites
1 Conduct Regional conference calls
on the results of the analyses
August
' Negotiate final targets/
measures and budget
Enter schedule or target
changes that result from the
negotiations into WasteLAN
Negotiate final targets/ measures
and budget
1 Enter final commitments and site
specific back-up into CERHELP
September
Send targets/measures, site
backup, and Regional budgets to
AAs for approval
Submit final STARS targets to
OPPE
November
Revise negotiated targets
during STARS open season
based on commitments missed
in the prior year
Calculate Technical Enforcement
Support carryover funds
Revise Regional Enforcement
operating plans
11-11
April 1994
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OSWER Directive 9200.3-14-2
EXHIBIT II-6
REGIONAL PLANNING FOR NEGOTIATIONS
Month
Activity
May/June
July/August
Identify response, enforcement, and Federal Facility projects
as "Primary" (P) or "Alternate" (A) in the Activity/Event
Planning Status field (C1725/C2110).
- Primary projects have the greatest likelihood of
meeting schedules and are used to determine
SCAP/STARS commitment.
- Alternates are projects that can be substituted for
primary targets that slip or are deferred.
Identify events/activities requiring funding by placing
"Approved" (APR) in the Funding Priority Status Field
(C2625/C3225). The total of all approved funding must not
exceed the proposed operating plan.
- Only "Primary" targets/measures should have an
"Approved" funding status.
- Projects the Regions would like to conduct with
the 10 percent budget reserve should have a
Funding Priority Status of "Alternate" (ALT).
CERCLIS data quality problems that affect the SCAP update shall be resolved
prior to negotiations. These problems are to be resolved on a Region-specific
basis through telephone calls between HQ and the IMC or program manager.
REGIONAL ACCOMPLISHMENT REPORTING
Accomplishments data are entered into WasteLAN by the IMC, RPM, OSC,
SAM or other designated program staff (i.e., PRP search, cost recovery) or are
recorded on Site Information Forms (SIF), Integrated SIFs (ISIFs), CERHELP Non-
Site/Incident Activity Maintenance Forms or other Regional data entry forms,
and entered into WasteLAN by the IMC or designee. Data on accomplishments
should be entered into WasteLAN within five working days of the event or
activity occurring. Only accomplishments correctly reported in CERCLIS will be
recognized by HQ.
Prior to the fifth day of each month, Regions should generate CERCLIS SCAP
reports for internal review or review WasteLAN data. Regions should perform
data quality checks and make adjustments to WasteLAN if the data base does not
April 1994
11-12
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OSWER Directive 9200.3-14-2
reflect actual accomplishments. Regions need to be sure the information
reflected in CERCLIS is up-to-date and accurate.
On the fifth working day of each month, HQ will pull data from CERCLIS on
a selected number of key indicators of progress in the Superfund program (e.g.,
construction completions, early action completions, site characterization starts,
negotiations, RODs, on-site construction starts, response settlements and
referrals, cost recovery actions/decisions). These numbers will be the official
numbers used in any reports of progress given to the Administrator, the AA
SWER, the AA for OECA, Congress, and the news media.
On the fifth working day of each quarter, HQ pulls SCAP reports from
CERCLIS. It is important to note that in addition to reporting accomplishments
through WasteLAN to CERCLIS, Regions must enter STARS accomplishments
for the second, third, and fourth quarters directly into the OPPE STARS system.
(OPPE will not track STARS first quarter accomplishments.) HQ will compare
the STARS data entered by the Regions into the OPPE STARS system with SCAP
reports. If HQ identifies a discrepancy in the accomplishments reported by a
Region, they will note it in the STARS system and contact the Region.
Discrepancies between HQ and the Regions on STARS accomplishments must be
resolved, generally by the 18th working day of a quarter.
Preliminary end of the year accomplishments will be pulled on the fifth
working day of September; it is the starting point for preparing for the end of the
year assessment in November. Since many senior managers and Congress
request final accomplishments immediately following the end of the year,
CERCLIS accomplishment reports will be pulled on the fifth and the tenth
working days of October and reported to OPPE in mid-November (See Manager's
Schedule of Significant Events at the beginning of this Manual for specific dates).
This allows the Regions ample opportunity to review end-of-year financial data,
ensure that all accomplishments are accurately reflected in CERCLIS, and
determine which commitments were not met.
HQ EVALUATION OF REGIONAL PERFORMANCE
Accomplishment data for SCAP and STARS are pulled from CERCLIS at the
close of business on the fifth working day of the quarter. HQ management bases
its evaluation of Regional program performance on these data. The data are
pulled on a selected number of key indicators of progress in the Superfund
program (e.g., construction completions, early action completions, site
characterization starts, response settlements and referrals, RODs, on-site
construction starts, and cost recovery activities). These numbers are the official
numbers used in any reports of progress given to the Administrator, Deputy
Administrator (DA), AAs, Congress, and the media. Detailed HQ management
evaluation occurs at two points during the FY: after the second quarter (mid-year
11-13 April 1994
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OSWER Directive 9200.3-14-2
assessment) and after the fourth quarter (end-of-year assessment). (See Exhibit II-
7.) In addition, HQ will be conducting Regional reviews in FY 94.
Quarterly Reporting
The purpose of quarterly reporting is to track Regional progress toward
accomplishing SCAP and STARS targets. HQ divisions are tasked quarterly in
OECA and semi-annually in OERR and OFFE, usually through a memorandum,
to provide a narrative of activities taking place in the Regions. The primary
purpose of this memo is to provide an opportunity for top Agency managers to
share their candid assessment of the program goals and initiatives where the
Regions are experiencing success as well as problems, and the actions HQ can
take to improve Regional performance. These narratives, in conjunction with
the quarterly or semi-annual performance numbers, are placed in a
memorandum to the DA, giving a more balanced and thorough view of
program status and issues. The memoranda contain the most significant
issues/activities and performance highlights from the previous quarters, and
may include information on early actions in the news, emergency response
activities, a Total Quality Management (TQM) project taking place in a Region,
and the like. It gives OERR, OECA, and OFFE the opportunity to convey
important issues, instead of merely presenting SCAP/STARS numbers.
In addition to reporting accomplishments through CERCLIS, Regions must
enter STARS accomplishments into the OPPE STARS system.
Mid-Year Assessment
The purpose of the mid-year assessment is to:
Track Regional progress toward accomplishing SCAP and STARS targets;
Evaluate Regional accomplishments against internal planning and reporting
measures;
Identify and assess problems impacting performance;
Work with Regions experiencing difficulty in meeting their targets;
Provide both HQ and the Regions with an opportunity to assess performance;
Consider the impact of Regional program performance on the Superfund
pipeline; and
Identify trends in program performance and adjust program management
strategies accordingly.
April 1994 11-14
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OSWER Directive 9200.3-14-2
EXHIBIT II-7
THE REGIONAL EVALUATION PROCESS
4th Quarter
End-of-Year
Assessment
2nd Quarter
Mid-Year
Assessment
* Pull CERCLIS
Reports on
SCAP/STARS
Accomplishments
and Internal
Measures
Pull CERCLIS
Reports on
SCAP/STARS
Accomplishments
Pull CERCLIS
Reports on
SCAP/STARS
Accomplishments
and Internal
Measures
Pull CERCLIS
Reports on SCAP
Accomplishments
* Report on
Progress of
Regions Having
Difficulties
Meeting Targets
* Develop Senior
Management
Reports Package
Develop Senior
Management
Reports Package
* Evaluate Program
Status
* Evaluate
Program
* Evaluate Annual
Performance and
Produce National
Progress Report
* Distribute
Deputy
Administrator
(DA) Memo
* Provide Input into
Next FY Resource
Allocation Process
* Brief Senior
Management
* Distribute DA
Memo
* Brief Senior
Management
On the fifth working day of April, second quarter SCAP data are pulled from
CERCLIS. Prior to the mid-year STARS briefing (the second week in May),
OERR, OFFE, and OECA Directors have briefed the AA SWER or AA OECA on
the steps being taken to ensure the accomplishment of annual targets. To ensure
that these actions are implemented, HQ will track follow-up items and reallocate
resources. The results of the mid-year assessment can also affect resource
allocations for the next FY. The measure of a Region's ability to meet their targets
will be considered in August when final FY 95 SCAP/STARS commitments and
Regional budgets are established.
11-15
April 1994
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OSWER Directive 9200.3-14-2
End-of-Year Assessment
Before the end of the fourth quarter, there is a preliminary pull for end-of-
year accomplishments (the first week of September). This pull is used to project
end-of-year accomplishments. It is important to stress that this is only a
projection and that the actual pulls, on the fifth and tenth working days of
October, are likely to be somewhat different than the projected numbers. Since
many Superfund managers and Congress request final accomplishments
immediately, Regions should make every attempt to update CERCLIS at the
earliest possible date and, in no event, any later than the fifth working day after
the end of the year.
In November, HQ conducts the official end-of-year assessment. This
assessment is an integrated analysis of program performance activities for the
year. The purpose of the end-of-year assessment is to emphasize pipeline issues
(e.g., slipped targets and their impact on commitments for the next year). The
end-of-year review also notes progress toward implementing strategies identified
in the mid-year assessment, and identifies Regions that might require additional
assistance as the new FY begins.
HQ considers the end-of-year assessment in developing the final
SCAP/STARS target and measures. In this way, the results of the end-of-year
assessment have a double impact.
Regional Reviews
Before the beginning of the FY, the program offices and Regions identify key
program areas and issues in the strategic plans or individual program
management guidance. Those issues that HQ program managers believe to be
important to the general success of the program's mission are selected for
discussion during the Regional reviews. Recent audits of Regional
accomplishment reporting have identified the need for improvements,
specifically in the area of:
Documentation of accomplishments;
Consistent understanding/application of definitions; and
CERCLIS/WasteLAN data quality.
On-site visits to all ten Regions will be conducted by senior program
managers. Region specific agendas will be developed. The on-site visits will
include discussions on the program areas and issues identified. The product of
the review would be negotiated plans for continued improvement.
April 1994 11-16
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OSWER Directive 9200.3-14-2
Management Reporting
Periodically, reports are pulled from CERCLIS that provide national
information on Superfund planning and progress. These reports must be
consistent with the SCAP/STARS data. It is essential that end-of-month
CERCLIS data be up-to-date as of the close of business on the fifth working day of
the following month. (Specific dates are listed in the Manager's Schedule of
Significant Events found at the beginning of this Manual.) This is the day that
data will be pulled from CERCLIS. It is strongly recommended that planning and
accomplishment data be entered into WasteLAN as events, activities, and
slippage occur.
The following sections provide a brief description of the reports available to
support Superfund program management.
Superfund Management Reports
The implementation of an integrated CERCLIS data base and the
improvement of CERCLIS data quality led to the development of a series of
senior management reports. These management tools are designed to
supplement conventional quarterly SCAP/STARS accomplishment reporting
by providing a more comprehensive examination of program activity. The
format and content of the reports package has evolved over time to address a
variety of project needs. Using data that is downloaded from CERCLIS, the
INSITE II system provides EPA senior managers with summary graphic
reports and backup site detail information.
The FY 94 packages provide graphical representations of the status of
SCAP/STARS targets and accomplishments, as well as analytic summaries of
key aspects of the program including: status and duration of events; trend
analysis of PRP involvement; the current status of ESI/RI/FS and RA
projects; cost recovery candidates; and the current status of negotiations,
settlements, and litigation. Analysis of the status of ESI/RI/FS and RA
projects is used to support the review of the worst sites first initiative.
The reports, produced semi-annually, illustrate the progress being made by
the Agency in both the movement of projects through the Superfund
pipeline and in the trend toward increased involvement by PRPs.
Additional management reports produced by OECA include:
SOL Management Report (ENFR-17) (under development) - This report
lists all planned and actual completion dates for removals, site
assessments, and remedial activities by FY quarter. Planned and actual
obligations for each activity are linked with cost recovery actions.
11-17 April 1994
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OSWER Directive 9200.3-14-2
Negotiation Master Report (ENFR-59) - This report lists all negotiations
to-date. Data are divided by negotiation category and summarized by FY,
Region, milestones, completed negotiations, and ongoing negotiations.
Enforcement Data Audit Report (ENFR-8) - This is a comprehensive
report used to monitor enforcement data quality. The report consists of
two pages per site; the first page lists all enforcement data and the second
page lists all response data by site. Enforcement actions without a quality
flag are printed on this report. Summary pages are currently being
developed.
Annual Reporting Requirements
The Chief Financial Officer's (CFO) Act of 1990 requires all agencies with a
trust fund program to submit, in addition to an annual financial statement, a
report on program performance measures. Agencies have been directed to
establish long-term goals and develop measures that are understandable to
the general public. HQ relies heavily on SCAP/STARS data to develop and
report on these measures. The FY 93 measures are presented in Exhibit II-8.
Similar data will be reported in FY 94.
SCAPISTARS ADJUSTMENTS AND AMENDMENTS
After targets have been finalized and funding levels developed, the SCAP
process provides the flexibility to modify plans during the year. Modifications to
planned targets are termed either adjustments or amendments. Regional
requests for amendments must be provided in writing to the appropriate HQ
office. Amendments require HQ concurrence and approval. Adjustments do
not require HQ approval, but may require HQ notification. Any exceptions to the
SCAP/STARS accomplishment definitions contained in the Volume II,
Appendix are considered an amendment. These exceptions will be reviewed on
a case-by-case basis.
Amendments or adjustments that modify the Region's AOA require a change
request. In these situations, the change request becomes the SCAP amendment.
Chapter III outlines the change request procedures. Exhibit II-9 lists the major
types of Super fund amendments and adjustments. Exhibit 11-10 describes the
procedures that must be followed when processing amendments.
April 1994 11-18
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OSWER Directive 9200.3-14-2
EXHIBIT II-8
CFO PERFORMANCE MEASURES
The ratio of NPL sites where cleanup started to the number of sites on
theNPL
The number of non-NPL sites where EPA has begun cleanup action
The ratio of the number of NPL sites where a decision was made (ROD)
on how to cleanup at least a significant portion of the site to the total
number of NPL sites
The ratio of the number of NPL sites where a significant portion of the
site (OU) has been cleaned up to the total number of NPL sites
The ratio of the number of NPL sites where cleanup has been completed
to the number of NPL sites
The ratio of the number of enforcement actions EPA has taken at NPL
sites to the total number of NPL sites
The number of major enforcement actions (>$200K)
The ratio of the amount of money EPA has collected from PRPs to the
total amount achieved in settlements and judicial actions
The ratio of the amount of money PRPs have agreed to spend on
cleanup to the total amount spent on site cleanup by the Superfund
SCAP/STARS amendments should contain the following information:
Site name and Site/Spill Identification number (S/S ID);
Event/activity affected;
Justification/purpose;
Funding amount (if the amendment requests an increase in the annual
budget or is a change request);
Allowance that is being increased and/or allowance that is being decreased, if
the amendment is a change request; and
Program element (TGB-enforcement, TFA-response, or TYP-Federal Facility),
if the amendment is also a change request.
11-19 April 1994
-------
OSWER Directive 9200.3-14-2
Although Regions have the flexibility to alter plans, they are still accountable
for meeting the targets negotiated at the beginning of the FY. Changes to STARS
commitments should not be made simply because targets will not be met.
However, in some cases, amendments to targets may be necessary and may be
changed under the following conditions:
Major, unforeseen contingencies arise that alter established priorities (i.e.,
Congressional action, natural disasters);
Major contingencies arise to alter established Regional commitments (i.e.,
State legislative action);
Measure or definition in system is creating an unanticipated negative impact;
Major shifts in project approach associated with SACM and the need to
conduct early response actions; or
Need to address newly identified site which represents a significant human
health or ecological risk.
OSWER and OECA require that all STARS amendments be submitted to HQ
by April 15 in order to meet the April 30 deadline for changing targets imposed
by OPPE. STARS amendments must be approved by the Deputy Assistant
Administrator OSWER or OECA.
April 1994 11-20
-------
EXHIBIT II-9
AMENDMENTS AND ADJUSTMENTS
T5
Change Request
Required
Amendment
or Adjustment
See Exhibit 11-13 or Chapter 111
Kxhibit III-3
Yes, If
Approver
Increase Annual Budget
Revise WasteLAN/CERCI.IS; Notify HQ
Program Development and Budget Staff
(PDBS), OERR, or Contracts and Planning
Branch (CPB), OWPE, or POD, OFFE
Decrease Annual Budget
See Exhibit 11-13 or Chapter III
Exhibit III-3
Increase Total (OECA and OERR)
AOA After Issuance Within Annual Budget
See Chapter III, Exhibit III-3
Decrease Total (OECA and OERR)
AOA After Issuance
Revise WasteLAN/CERCI.IS
Increase/Decrease RA'or Early Actions under Remedial
Authority Funding Before AOA Issued
See Chapter III, Exhibit III-3
Decrease RA or Early Actions under Remedial Authority
Funding After AOA Issued
See Exhibit 11-13 or Chapter III
Exhibit III-3
Increase RA or Early Actions under Remedial Authority
Funding After AOA Issued
Revise Wastel .AN/CERCI .IS
Shift Funds Within Allowance
After AOA Issued
See Chapter III, Exhibit III-3
Shift Funds Between Allowances
After AOA Issued
See Exhibit 11-13
Change Annual SCAP Target
See Exhibit 11-13
Change STARS Quarterly or Annual Target;
Revise WasteLAN/CERCI.IS
Target Site Substitutions
See Exhibit II-3
Definition Exceptions
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OSWER Directive 9200.3-14-2
EXHIBIT 11-10
SCAP AMENDMENT PROCESS
/
\
r ~\
Quarterly or Annual
STARS Targets
V J
*
Memorandum from
Waste Management
Division Director to
Deputy Assistant
Administrator OSWER
or OECA explaining
reason for change
*
^ \
WasteLAN and
CERCLIS are
updated
*
DA OSWER or
OECA approves/
disapproves
amendment
request
1
Region is
notified of
outcome
^ s
( \
Annual SCAP
Target or
Definition
Exceptions
V J
f
E-mail from Regional
Branch Chief to HQ
Director, PDBS/
OERR or Chief,
CPB/OWPE, or
Director, POD/ OFFE
explaining reason for
change
*
WasteLAN and
CERCLIS are
updated
V J
y
Director, PDBS/OERR
or Chief CPB/OWPE
or Director,
POD /OFFE approves/
disapproves
amendment request
*
f \
Region is
notified of
outcome
V J
r ^\
Increase
Annual Budget
V J
f
E-mail from Regional
Branch Chief to
Director, PDBS/OERR,
or Chief, CPB/OWPE
or Director,
POD /OFFE. Copy
sent to the Regional
finance office and HQ
PDBS, CPB, or POD
staff
*
WasteLAN and ]
CERCLIS are
updated
V J
*
AA SWER or AA
OECA reviews request
and, if approved, sends
E-mail to Regional
program and finance
offices and HQ Office
of the Comptroller
(OC)
*
r "\
Regional
finance office
updates IFMS
V J
1
HQOC |
approves
revised AOA in
v IFMS J
^Increase Total AOA^
or Increase Funding of
RAs/ Early Actions
Under Remedial
Authority After AOA
^ Issued J
t
E-mail from IMC to
HQ PDBS or CPB or
POD staff. Copy
sent to AA SWER or
AA OECA and
Regional finance
office
|
' WasteLAN and
CERCLIS are
updated
^ J
j
AA SWER or AA
OECA approves SCAP
amendment/change
request and sends E-
mail to Regional
program and finance
offices and HQ OC
^
/ N
Regional
finance office
updates IFMS
V J
\
HQOC
approves
revised AOA in
^ IFMS j
April 1994
11-22
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OSWER Directive 9200.3-14-2
CHAPTER III
SUPERFUND FINANCIAL MANAGEMENT
AND FTE DISTRIBUTION
April 1994
-------
-------
OSWER Directive 9200.3-14-2
CHAPTER III - SUPERFUND FINANCIAL MANAGEMENT AND
FTE DISTRIBUTION
This chapter discusses the impact of the SCAP process on the development of
the outyear budget, the Regional operating budget and AOA, outlines Superfund
financial management responsibilities and provides an overview of the FTE
distribution process. General information on the FY 94 Response budget,
Enforcement budget, and Federal Facility budget as well as a general discussion of
each workload model is provided in this chapter. It is anticipated that new
Superfund workload models will be used to distribute resources beginning in FY
95.
Like the program planning and reporting requirements, the enforcement-
specific financial management procedures may be affected by the OWPE
reorganization. If necessary, an addendum to the Manual may be issued to
reflect any changes that are a result of the reorganization.
OUTYEAR BUDGET DEVELOPMENT
The preliminary outyear budget request is developed in May, 18 months
before the operating year begins. This means that SCAP data existing in the third
quarter of FY 94 is used to formulate the FY 96 budget request. The schedules for
all response, enforcement, and Federal Facilities activities, and the planned
obligations for RAs and early actions under remedial authority reflected in
CERCLIS serve as the foundation for determining the dollar levels to be
requested in the budget and the total level of FTEs to be made available for
distribution through the workload model process. Exhibit III-l contains the
procedures for developing the outyear budget.
FY 95 BUDGET DEVELOPMENT
The process for developing the FY 95 budget is essentially the same as the
process being followed for the development of the outyear budget. The base
budget process that is being used to develop the FY 95 budget consists of three
phases and builds on the budget that was developed for FY 94, the Agency's
strategic plans, and investments for the future. Exhibit III-l contains the
procedures for developing the FY 95 budget.
ffl-1 April 1994
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OSWER Directive 9200.3-14-2
EXHIBIT III-l
PROCESS FOR DEVELOPING THE OUTYEAR AND FY 95
BUDGET
Month
Outyear Budget (FY 96)
FY 95 Budget
May
Program characterization
identified statutory basis
for activities, resources,
outputs, environmental
results, and strategic
choices
Budget review - Discuss
strategies and goals with
Administrator
June
Update strategic plans
Present goals and priorities
to the Administrator
Ensure dollar levels in
CERCLIS reflect goals
Budget formulation -
A A /Regional
Administrator forum to
discuss budget, priorities,
and long-term direction
Develop budget
July
Budget request developed
Administrator passback
Presentations on program
priorities to Administrator
Administrator passback
September
Revise budget request
and submit to OMB
October
Revise budget and submit
to OMB
November
OMB passback
December
EPA appeal process
January
Prepare and submit
President's budget request
April 1994
III-2
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OSWER Directive 9200.3-14-2
DEVELOPMENT OF THE FY 94 NATIONAL BUDGET
In FY 94 there are insufficient resources for all ongoing activities plus the new
activities the Regions planned to begin. As a result, resource decisions were
made that address the implementation of SACM and are consistent with the
Integrated Priority Setting Matrix.
Reducing imminent threats to human health and the environment and
optimizing site completions (and deletions where feasible) are the highest
program priorities while using enforcement tools to ensure maximum but
equitable PRP involvement. However, those activities that contribute to other
program goals, and more generally contribute to the long-term effectiveness of
the program, need to be supported to the maximum extent possible. Examples of
such activities are those that meet equity goals (de minimis and municipal
settlements, PRP compliance oversight, and pursuing non-settlors) and worst
sites first initiatives.
Applying these criteria and long-term goals, the response/ enforcement, and
Federal Facilities programs made specific budget decisions. These budgets and
program decisions are discussed in this chapter.
FY 94 REGIONAL BUDGET
A Region will not receive funds above its annual Regional budget unless a
SCAP amendment/change request has been approved by HQ. Each quarter, the
approved planned and actual obligations and actual commitments must be less
than or equal to the annual Regional budget or the AOA will not be approved.
In the case of enforcement, the Regional budget refers to new current year
operating plan dollars plus prior year enforcement support contract carryover.
Response Budget
The FY 94 response budget (President's Budget) contains $983.5 million for
direct cleanup activities, including site screening and assessment, early actions,
long-term actions, PRP oversight, and laboratory support. Approximately $47.9
million is available to support other response actions, program support,
information management, and contract management. In light of this and
consistent with the Integrated Priority Setting Matrix (see Chapter I), resources
will be provided for:
Early actions under removal authority at historical rates and within the
budget constraints;
Ongoing RA projects to construction completion;
All long-term action and early action under remedial authority starts;
III-3 April 1994
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OSWER Directive 9200.3-14-2
Oversight of all RP-lead RD, RA, NTC removal, and early action under
remedial authority projects;
Ongoing RI/FS projects started as part of the "full funding strategy";
All RD starts; and
Five-year reviews.
The first priority for response funding are classic emergencies and activities at
sites that will be used to meet the national construction completion goals.
Enforcement Budget
The enforcement extramural budget for the Regions in FY 94 is $47.8 million.
As with the response budget, decisions on which activities will be funded are
based on the Integrated Priority Setting Matrix (see Chapter I). Within the
matrix, the following activities are priorities:
Maintaining ongoing PRP oversight of removals and RI/FSs and compliance
enforcement of all response actions;
Negotiating PRP response actions;
Negotiating settlements with collateral PRPs, including de_ minimis and
municipal solid waste contributors;
Maintaining ongoing litigation for response and cost recovery; and
Referring removal and remedial cost recovery cases greater than $200K with
SOLs that will expire during the budget year.
Within this context, it is important to consider that the enforcement program
has changed significantly to take into account a greater PRP participation, dealing
with recalcitrant PRPs, and addressing collateral PRPs, with an emphasis on de_
minimis parties and municipalities. Therefore, activities that reinforce these
criteria need to be supported to the maximum extent possible within available
resources.
Federal Facilities Budget
The Federal Facilities extramural budget for FY 94 is approximately $13.46
million. As with the response and enforcement budgets, decisions on which
activities will be funded are based on the Integrated Priority Setting Matrix
April 1994 III-4
-------
OSWER Directive 9200.3-14-2
(see Chapter I). Within the matrix, the following activities are priorities:
Targeting activities at bases to be closed;
Maintaining ongoing oversight activities; and
Expediting response where possible.
No funds are available for projects at non-NPL sites. Oversight activities at
non-NPL sites are the responsibility of the State.
RELATIONSHIP BETWEEN SCAP AND THE ANNUAL REGIONAL BUDGET
The SCAP process is the planning mechanism used by the Superfund
program to identify site screening and assessment, early action, long-term action,
enforcement, and Federal Facility funding needs for the FY. The final annual
Regional operating plan and the associated budget are a result of the August HQ
and Regional negotiations on the proposed outputs and program budgets.
Though Regions are required to operate within their final negotiated annual
operating budgets, adjustments within this budget can be made during the FY.
Prior to the beginning of the FY, each Region will be given a proposed budget
allocation for removal, remedial, enforcement, and Federal Facility programs.
The criteria discussed below were used to develop the FY 94 budgets. These
criteria will also be used to prepare the initial FY 95 budgets.
The FY 94 Regional response budgets were allocated as follows:
90 percent of a Region's budget was based on its FY 90, FY 91, and FY 92 actual
response obligations; and
The remaining 10 percent was allocated to the Region based on the final
negotiated targets.
For enforcement, FY 94 initial operating plans were based on the relative
percentage of the FY 93 budget and will be adjusted in first quarter FY 94 based on
FY 93 utilization rate, including FY 93 Technical Enforcement Support (TES)
contract carryover. Regional targets should be developed consistent with initial
operating plans.
The FY 94 Regional Federal Facility budget was allocated based on a Region's
percentage of NPL sites, with an initial reserve of $500,000 per Region to fund
emergencies.
Regions are required to plan their obligations within the program-specific
allocations. Final budgets will be developed upon completion of the fourth
IH-5 April 1994
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OSWER Directive 9200.3-14-2
quarter negotiations between HQ and the Regions. For enforcement, the
operating funds will be adjusted in first quarter of FY 94 based on end-of-year
FY 93 utilization rates, including consideration of TES carryover. Planned
obligations for Regional activities must fall within the total identified budget
levels, and should be shown by entering "approved" (APR) in the Funding
Priority Status data field (C2625, C3225, or P1419). Funding needs above the HQ
proposed total budget level must be designated as "alternate" (ALT). This will
allow HQ to see the Regional funding priorities, the activities the Region would
like to conduct with the budget reserve, the activities that will not be performed
as a result of lack of funds, and provide the information needed for any
supplemental funding requests. HQ will not initiate negotiations with a Region
until the "approved" funds requested are within the proposed total Regional
budget levels.
In the past, the AOA obligation rate through the first two quarters of the FY
has been low. As a result, HQ has implemented the following measures to
improve performance:
Regions will not receive their third quarter AOA for a specific response
category unless the commitment/obligation rate is 50 percent or greater in
that AOA category. For example, if the commitment/obligation rate for one
response allowance (i.e., RDs) is 35 percent while the rate for another (i.e.,
removals) is 65 percent, the third quarter removal AOA would be issued but
the RD AOA would not be issued.
Regions must obligate and task 60 - 65 percent of the enforcement Regional
extramural funds received in their first and second quarter AOA and task 60-
65 percent of TES obligations including FY 93 carryover in order to receive
their third quarter enforcement AOA. If a Region does not receive its third
quarter enforcement AOA due to such an obligation shortfall, it is required to
produce a site specific spending plan in WasteLAN for both the third and
fourth quarters by mid-May.
Regions must obligate 60 - 65 percent of their current year Federal Facility
AOA in the first and second quarter in order to receive their third quarter
AOA. The Region's annual budget may be reduced by the third quarter
amount if 60 - 65 percent of the first and second quarter AOAs have not been
obligated by the start of the fourth quarter.
For those Regions that continue to have a low rate of commitment/
obligation/tasking, OSWER and OECA will renegotiate the Region's operating
plan for the remainder of the year during June. This may result in a reduction in
the Region's annual budget.
April 1994 IH-6
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OSWER Directive 9200.3-14-2
ADVICE OF ALLOWANCE PROCEDURES AND FINANCIAL REPORTING
REQUIREMENTS
The planned obligations identified through the SCAP process are the basis for
the AOA approved by the OC and AA SWER or AA OECA.
Regional Allowances
For FY 94, OERR proposed a restructuring of the AOAs. Based on this
restructuring, the OC would issue the following allowances to the Regions in
FY94:
Site Characterization (non-site specific "site" allowance), which includes
funds for:
PAs, Sis, ESI/RI, FS, RD, treatability studies, EE/CAs, design assistance,
community relations, support agency assistance, technical assistance, and
ground water monitoring; and
- Oversight of RDs, RAs, early actions under remedial authority, NTC
removals, five year reviews, O&M, and LTRA;
RA (site-specific "site" allowance), which includes funds for RAs, early
actions under remedial authority, LTRA, and five year reviews;
Removal (non-site specific "site" allowance), which includes funds for
emergencies, time critical, and NTC early actions under removal authority;
Other Response (non-site specific "regular" allowance), contains funds for
response program and project support including ARCS program
management, Technical Assistance Grants (TAG), Core Program Cooperative
Agreement (CPCA), and pollution liability insurance;
Enforcement (non-site specific "regular" allowance); and
Federal Facilities (non-site specific "regular" allowance).
The AOA Process
The AOA is based on the Phase III Operating Plan which identifies projected
obligations for each quarter of the FY. The Phase III Operating Plan for FY 94 is
based on the final SCAP plans developed in the fourth quarter of FY 93. In the
case of enforcement, operating plans are adjusted after the start of the FY based
on prior year contract utilization.
III-7 April 1994
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OSWER Directive 9200.3-14-2
Approximately four weeks before the end of each quarter, HQ will generate
AOA reports (SCAP-4, SCAP-4E, and SCAP-4F) that reflect the approved planned
obligations in CERCLIS. After discussions with the Regions to clarify questions
or issues and after ensuring that the Regional budget was not exceeded, HQ will
enter the AOAs into the CERHELP Budget Control/Advice of Allowance
(BC/AOA) system two weeks before the end of the quarter. Regions must pull
these reports from CERHELP and enter these amounts into Integrated Financial
Management System (IFMS).
The AAs and the OC review the funding levels entered into IFMS by the
Region and compare them to the AOA amounts generated by the HQ program
offices. If the two agree, within three working days after the start of the quarter,
the HQ OC Budget Division and the AAs approve the AOA in IFMS and the
funds are available for obligation. If the AOA entered into IFMS by the Regions
does not agree with the AOA in CERHELP, IFMS will not be approved and the
Automated Document Control Register (ADCR) will not work. Only projects
planned in CERCLIS can be funded by the AOA. Exhibit III-2 illustrates the AOA
process. Regional IMCs should work closely with their Regional finance office
on the entry of the correct AOA into IFMS.
If a Region receives funds in their AOA which were not obligated during the
quarter received, the relevant planned obligation data in WasteLAN must be
changed or the amount placed in the contingency account. At the end of each
quarter HQ will review the AOA funds remaining, commitments and
obligations made, the contingency account, and planned obligation data. If AOA
funds were not committed or obligated and the planned obligation data were not
changed, HQ will take the following actions:
Reduce the next quarter's AOA for other response, site characterization,
enforcement or Federal Facility by the amount that was not committed or
obligated; or
Request that Regions follow the OC's change request procedures to return
early action under remedial authority or RA funds to HQ.
AOA Flexibility
Regions are required to operate within their quarterly AOA and their annual
Regional budget. Each Region will receive a RA and early action under remedial
authority budget based on the schedules in CERCLIS for implementing these
actions. Regions are responsible for managing the funds issued in the AOA and
for operating within budget ceilings, floors, and other restrictions.
April 1994 III-8
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OSWER Directive 9200.3-14-2
Some flexibility exists within the AOA structure to shift funds both within
and between allowances. Regions may:
Shift funds between projects within the other response, site characterization,
removal, Federal Facility or enforcement allowances. HQ approval is not
required;
Shift existing funds between certain allowances (site characterization and
enforcement allowances). HQ approval of a change request is required.
Funds cannot be shifted into the other response allowance, out of the RA or
removal allowance, or into or out of the Federal Facility allowance; and
Move future planned obligations to the current quarter (increase total
allowance after issuance within the annual budget). HQ approval of a change
request/SCAP amendment is required.
Shifting funds between projects within the other response, site
characterization, removal, enforcement, or Federal Facility allowance is a SCAP
adjustment. It does not require HQ approval or a change request, but WasteLAN
must be revised to reflect the shift. Allowable shifts between allowances are also
SCAP adjustments; however, HQ approval of a change request is required before
the funds can be used. The change must be reflected in CERCLIS prior to HQ
approval. Based on Regional priorities, funds may also be reprogrammed
between response and enforcement. These shifts require a change request and
Congressional notification if the funds proposed for reprogramming exceed
$500,000. Federal Facility funds cannot be reprogrammed.
RA Allowance
RAs and early actions under remedial authority will be funded on a first
ready/first funded basis. The Regions' ability to redirect RA and early action
under remedial authority funds is limited. Approval from the A A for
Administration and Resources Management (ARM) and AA SWER is
required. Given the constraints in RA funding, HQ approval is highly
unlikely.
In situations where the PRPs settle after the AOA is issued, Regions may
retain the funds needed for oversight. The remaining funds in the AOA
must be sent back to HQ through a change request.
Non-Site Specific Funding Flexibility
Regions may redirect funds within the other response, removal, site
characterization, enforcement, and Federal Facility allowances to meet site or
activity priorities. It is important to note that, generally, funds cannot be
shifted out of the removal allowance because Congress specifically added
April 1994 111-10
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OSWER Directive 9200.3-14-2
resources to this area. Regions may shift funds more easily into the removal
allowance from other non-site specific allowances. Funds also cannot be
shifted into or out of the Federal Facility allowance.
Funds saved within the site characterization account as a result of a
settlement or where actual costs are lower than estimated will generally stay
within the Region. These funds may be used within the allowance for other
site characterization projects.
HQ approval will generally be given for the redirection of unused funds to
the following priorities:
Classic emergencies;
Ongoing RA projects;
Early actions to make NPL sites safe; and
Funds necessary to oversee PRP activities.
Response funds may be used to address deficient PRP projects. Regions are
allowed to redirect funds to accommodate this need. Funds for PRP projects
that will require substantial Fund involvement should be transferred to the
appropriate response AOA category. For projects requiring limited Fund
involvement, funds should be transferred to the enforcement AOA. Again, a
change request will be necessary for transfers between AOA categories.
If a Region has a funding request during the year that was unplanned, the
following approach should be followed in identifying funding sources:
As a first step, Regions should determine if funds are available within the
AOA that can be redirected within or between allowances to perform the
action;
If no AOA funds are available, funds planned for obligation in future
quarters (within the Region's annual budget) that will not be used as
originally planned should be tapped;
After mid-year, funds made available within the annual Regional budget
as a result of the mid-year or third/fourth quarter adjustment process
should be used; and
If necessary, Regions may request an increase in their annual budget
through the redirection of funds made available as a result of mid-year or
third/fourth quarter adjustments in other Regions.
IH-11 April 1994
-------
OSWER Directive 9200.3-14-2
AOA Change Request Procedures
In some situations, a change request is required as a result of Regional
changes to SCAP. Exhibit III-3 discusses flexible funding and other situations
where an AOA change request is required. Exhibit III-4 describes the procedures
to be followed in each of these situations. HQ will not approve a change request
unless CERCLIS is revised to reflect the change.
Under IFMS, change requests are electronically transferred to HQ. The
following information should be provided for a change request:
Purpose/justification;
Amount;
Site name and S/S ID if allowance is issued site specifically;
Program element(s) (TGB - enforcement, TEA - response or TYP - Federal
Facility); and
Allowance that is being increased and/or allowance that is being decreased.
Regions should not initiate any obligations against the change until the OC
and AAs approve the revised AOA.
Financial Management and Funding Processes
Regional financial authority consists of three distinct, but interrelated, parts:
approvals, commitments, and obligations. The payment and deobligation
processes result in drawdowns from obligated funds. Due to limited resources to
fund FY 94 activities, it is essential that Regions deobligate unneeded prior-years
funds so they can be used to close the funding gap. The funding processes are
outlined in Exhibit III-5. Exhibit III-6 indicates the process by which the Regions
commit and obligate funds.
OVERVIEW OF THE FTE DISTRIBUTION PROCESS
Regional FTE allocations are made through the Hazardous Spill and Site
Response Model for site assessments, early actions, long-term actions, and
program and project support, the Technical Enforcement Model for enforcement
activities, and the Federal Facilities Superfund Workload Model for Federal
Facilities activities. The workload models are currently designed to reflect
priorities and policies contained in both the budget and planning processes. For
the most part, the existing workload models are a straight forward application of
FTE pricing factors from the national budget to Region-specific SCAP/STARS
April 1994 111-12
-------
OSWER Directive 9200.3-14-2
targets and ongoing activities. No FTEs are given to projects that are incorrectly
coded and scheduled in CERCLIS.
In FY 94, each Region's Superfund FTEs are frozen at the FY 90 levels. While
the freeze ensures that total Regional Superfund resources will not be affected,
shifting of resources within the Region among the different program areas may
occur as described earlier in this chapter. This includes shifts between the
response and enforcement programs. All shifts will be based on the national
budget and the Integrated Priority Setting Matrix (see Chapter I).
During August negotiations of SCAP/STARS targets, Regions may propose
changes to the targets to match the Regional Superfund resource level. These
proposals also must be made in accordance with the Integrated Priority Setting
Matrix. HQ will ensure that the cumulative Regional targets meet national
budget commitments.
The three workload models are under review and will be revised based on
SACM, changing program priorities, and the desire to simplify the workload
allocation process. It is anticipated that the FY 95 resources will be distributed
based on the revised Superfund workload model. The revisions being discussed
for the response and enforcement models include distribution of resources based
on the number of "active sites," not STARS/SCAP targets and measures; FTEs
specifically allocated for fiscal and contract management; and pricing factors for
specific activities within the following categories:
Site assessment;
Removal;
Remedial; and
Enforcement.
IH-13 April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT III-3
CHANGE REQUEST REQUIRED
Change Request Situation
Allocation transfer lAGs
Transfer fund to the Environmental
Monitoring Systems Laboratory
(EMSL) or other entity within EPA
Shifting funds where allowable
between allowances after issuance
Increase total quarterly allowance
after issuance (within annual budget)
Decrease total quarterly allowance
after issuance
Increase RA or early action under
remedial authority funding after
allowance is issued
Decrease RA or early action under
remedial authority funding after
allowance is issued
Decrease RA or early action under
remedial authority funding as a result
of PRP takeover
New RA or early action under
remedial authority funding after
allowance is issued
Procedures in Exhibit III-3 to
Be Followed:
Decrease allowance after issuance
Decrease allowance after issuance
Shifting funds between allowances
after issuance
Increase total allowance after
issuance (within annual budget)
Decrease allowance after issuance
Increase total allowance after
issuance within annual budget
Decrease allowance after issuance
Decrease allowance after issuance
Increase total allowance after
issuance within annual budget
April 1994
111-14
-------
OSWER Directive 9200.3-14-2
EXHIBIT III-4
AOA CHANGE PROCESS PROCEDURES
Decrease Allowance
!\
After Issuance
J
i
IMC sends E-mail
change request to the
Regional finance office,
with copies to OERR
PDBS staff, OECA staff,
or OFFE POD staff
Revise
WasteLAN/CERCLIS
1
Change request is
electronically transmitted
to HQ through IFMS
AOA in IFMS is revised to
reflect the change
Increase Total Allowance After
Issuance Within Annual
Budget
1
IMC sends E-mail
change request to OERR
PDBS staff, OECA staff,
or OFFE POD staff with
copies to AA SWER or
AA OECA and Regional
. finance office ,
Revise
WasteLAN/CERCLIS
/'AA SWER or AA OECA
sends E-mail approval
memorandum to Regional
program and finance office
^ and HQ OC y
I
f Shifting Funds Between 1
I Allowances After
\^ Issuance }
I
IMC sends E-mail
change request to the
Regional finance office,
with copies to OERR
PDBS staff and/or
OWPE CPB staff and
AA SWER or AA
OECA
I
Revise
WasteLAN/CERCLIS
I
The change request is electronically transmitted to HQ through IFMS
AOA in IFMS is revised to reflect the change
OSWER or OECA and the OC review the request
^» Revised AOA is approved in IFMS by the HQ OC and AA SWER or AA OECA
m-15
April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT III-5
FINANCIAL MANAGEMENT AND FUNDING PROCESSES
Activity
Discussion
Approvals
An approval by the AA SWER, AA OECA, Regional Administrator or official
designee is authorization to undertake a CERCLA-funded response action.
Early Actions Under Removal Authority:
- Regional Administrator approves actions costing up to $2 million, grants
exemptions to twelve month and $2 million statutory limits based on
consistency with the long-term action, and may re-delegate to the OSC the
authority to approve actions costing up to $50,000 in emergency situations.
- Except in emergency situations, before taking action, an Action
Memorandum must be approved. The Action Memorandum documents
the release meets the criteria of CERCLA and the NCP, and includes an
estimated total project ceiling. The OSC uses the estimate of duration and
cost in order to determine the proper approval authority.
- In extreme emergencies, the OSC may initiate activities without preparing
the necessary documentation in advance. The OSC must document the
decision within 24 hours of initiating the response.
Early Actions Under Remedial Authority, RD, RA, Site Screening and
Assessment, Enforcement, and Federal Facilities:
- Planning is accomplished through SCAP. Funds cannot be committed or
obligated unless the project is in SCAP.
- Obligation planned and executed on an OU or site basis. Outlays
(payments) should be attributed to the appropriate OU.
- ROD is required for all early actions under remedial authority and long-
term actions. ROD is signed by the Regional Administrator/Deputy
Regional Administrator, the AA SWER or AA OECA. ROD documents the
alternative decision-making process, demonstrates that the requirements of
CERCLA and the NCP have been met, and provides the basis for future
cost recovery actions.
Commitments
Commitments are a reservation of funds but not a legal promise to pay a
supplier. Once the Regional FCO certifies the availability of funds, a
spending action becomes a commitment. Funds that are committed but
not obligated are called open commitments.
Two types of commitment documents: PR and CN. PRs commit funds
for contracts; CNs commit funds for CAs and reimbursable lAGs.
April 1994
111-16
-------
OSWER Directive 9200.3-14-2
EXHIBIT III-5 (continued)
FINANCIAL MANAGEMENT AND FUNDING PROCESSES
Activity
Discussion
Obligations
Obligations legally bind the government to pay a supplier for
goods or services. Obligated funds can no longer be used for
another purpose.
A contractor, another Federal agency, or State cannot start work
until funds have been obligated. Funds can only be used for the
purpose for which they were obligated, unless they are
deobligated.
Obligating documents must be processed in accordance with
guidance issued by OAM, GAD, and FMD. Some contracts are
awarded by OAM and entered into IFMS by the SFO/RTP,
others are handled by the Regions. Obligations for CAs are
entered into IFMS by the Regions; LAGs are entered by FMC-Ci.
Payments
(Outlays)
Invoices from contractors/suppliers are submitted to proper
SFO for payment. Before payment, there must be an obligating
document and a receiving report to verify that the work was
completed or the goods received were satisfactory. Unpaid
obligations remain in IFMS until paid or until the allowance
holder or obligating official notifies the SFO that no further
payments will be made.
Deobligations
Handled similarly to obligations. Same commitment and
obligation documents and procedures are used, except that the
dollar amount is a reduction. Availability of funds after
deobligating depends on when the funds were obligated.
Current year funds are available as soon as the deobligation is
effective. Prior year funds revert back to HQ for redistribution.
In order to reuse prior year funds, allowance holders must
request a recertification of funds to their allowance.
Regions should regularly review the status of all contracts,
LAGs, and CAs. If all activities have been completed, remaining
funds should be deobligated immediately to make them
available for other activities.
111-17
April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT III-6
HANDLING FINANCIAL DATA IN THE CERCLIS ENVIRONMENT
Funding Document prepared
by Program Office in appropriate area
(Site Assessment, Remedial, Removal,
Federal Facilities, Enforcement)
Approval of Funding Document J
.-_.
FMO reviews the Funding
Document, assigns a unique
AN/DCN pair and enters
information into IFMS
±
Funds are now committed
I
Regional IMC or designee
enters the commitment
data into
WasteLAN/CERCLIS
Contracts signed
by CO
CAs signed by
Regional Administrator
LAGs signed by
Participating Parties
Funds are now obligated
I
Regions enter obligation data into WasteLAN/CERCLIS. Regions j
or HQ enter obligation data into IFMS J
April 1994
m-is
-------
OSWER Directive 9200.3-14-2
ACRONYMS
-------
-------
OSWER Directive 9200 3-14-2
AA
AAOE
AA SWER
AAU
ADCR
ADR
ALT
AN
AO
AOA
AOC
AOG
APR
AR
ARAR
ARCS
ARIP
ARM
ASU
ATSDR
ATSDR HAZDAT
BC/AOA
BLM
BTAG
BUREC
CA
CADD
CAS No.
CD
CED
CEPP
CEPPO
CERCLA
CERCLIS
CERFA
CERHELP
CFO
CLP
CN
CO
CORA
CPB
CPCA
CR
Assistant Administrator
Assistant Administrator for the Office of Enforcement
Assistant Administrator for the Office of Solid Waste and Emergency
Response
Administrative Assistance Unit
Automated Document Control Register
Alternative Dispute Resolution
Alternate
Account Number
Administrative Order
Advice of Allowance
Administrative Order on Consent
Agency Operating Guidance
Approved
Administrative Record
Applicable or Relevant and Appropriate Requirements
Alternative Remedial Contracting Strategy
Accidental Release Information Program
Administration and Resources Management
Administrative Support Unit
Agency for Toxic Substances and Diseases Registry
-Agency for Toxic Substances and Diseases Registry Hazardous Data
System
Budget Control/Advice of Allowance
Bureau of Land Management
Biological Technical Assistance Group
Bureau of Reclamation
Cooperative Agreement
Corrective Action Decision Document
Chemical Abstract Number
Consent Decree
CERCLA Enforcement Division (OWPE)
Chemical Emergency Preparedness and Prevention Program
Chemical Emergency Preparedness and Prevention Office (OSWER)
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980
Comprehensive Environmental Response, Compensation, and Liability
Information System
Community Environmental Response Facilitation Act
CERCLIS non-site specific data base
Chief Financial Officer
Contract Laboratory Program
Commitment Notice
Contracting Officer
Cost of Remedial Action
Contracts and Planning Branch (OWPE)
Core Program Cooperative Agreement
Community Relations
-------
OSWER Directive 9200.3-14-2
CRCR
CRP
CWA
3DB
DA
DAS
DCN
DNAPL
DOD
DOE
DOI
DOJ
DPO
BBS
EE/CA-
EI
EMSL
ENRD
EPA
EPA-ACH
EPA ID
EPI
EPCRA
ERA
ERGS
ERD
ERNS
ERRS
ESAT
per1
l_jwJV_--
ESD
ESF
ESI
ESI/RI
ESS
FCO
FE
FEMA
FFA
FFCA
FFIS
FFS
FINDS
FMC-Ci
FMD
FMFIA
FMO
FOIA
FR
FS
FSC
Cost Recovery Category Report
Community Relations Plan
Clean Water Act
Decision Document Database
Deputy Administrator
Delivery of Analytical Services
Document Control Number
Dense Non-Aqueous Phase Liquids
Department of Defense
Department of Energy
Department of the Interior
Department of Justice
Deputy Project Officer
Environmental Baseline Survey
Engineering Evaluation/Cost Analysis
Environmental Indicators
Environmental Monitoring Systems Laboratory
Environment and Natural Resources Division (DOJ)
Environmental Protection Agency
EPA Automated Clearing House
EPA Identification Number
Environmental Priorities Initiative
Emergency Planning and Community Right to Know Act of 1986
Early Remedial Action
Emergency Response Cleanup Services
Emergency Response Division (OERR)
Emergency Response Notification System
Emergency and Rapid Response Services
Environmental Services Assistance Team
Enforcement Support Contract
Explanation of Significant Differences
Emergency Support Function
Enhanced Site Inspection
Expanded Site Inspection/Remedial Investigation
Enforcement Support Services
Funds Certifying Officer
Federal Enforcement
Federal Emergency Management Agency
Federal Facility Agreement
Federal Facility Compliance Agreement
Federal Facilities Information System
Focused Feasibility Study
Facility Index System
Financial Management Center - Cincinnati
Financial Management Division
Federal Managers Financial Integrity Act
Financial Management Office
Freedom of Information Act
Federal Register
Feasibility Study
First and Subsequent Completion
II
-------
OSWER Directive 9200.3-14-2
FSS
FTE
FUDS
FY
FY/Q
GAD
GAO
GFO
GIGS
GNL
HAZDAT
HQ-
HRS
HSCD
HWC
IAG
IFMS
IMC
IOTV
IRM
ISIF ,
LAN
LEPC
LOG
LOE
LTCS
LIRA
MARS
MBO
MM/DD/YY -
MOU
MSCA
NAPL-
NBAR
NCP
NOAA
NPL
NPL-PAD
NRC
NRT
NSEP
NTC
OAM
OC
OE
OECA
OERR
O&F
OFFE
OIG
First and Subsequent Start
Full-time Equivalent
Formerly Used Defense Sites
Fiscal Year
Fiscal Year/Quarter
Grants Administration Division
Government Accounting Office
Good Faith Offer
Grants Information Control System
General Notice Letter
Hazardous Data System
Headquarters
Hazard Ranking System
Hazardous Site Control Division (OERR)
Hazardous Waste Collection
Interagency Agreement
Integrated Financial Management System
Information Management Coordinator
Interoffice Transfer Voucher
Initial Remedial Measure
Integrated Site Information Form
Local Area Network
Local Emergency Planning Committee
Letter of Credit
Level of Effort
Long Term Contracting Strategy
Long Term Response Action
Management and Accounting Reporting System
Management by Objectives
Month/Day/Year
Memorandum of Understanding
Multi-Site Cooperative Agreement
Non-Aqueous Phase Liquid
Non-Binding Allocation of Responsibility
National Oil and Hazardous Substances Pollution Contingency Plan or
National Contingency Plan
National Oceanic and Atmospheric Administration
National Priorities List
National Priorities List - Production Assistance Database
National Response Center
National Response Team
National Security Emergency Preparedness
Non-Time Critical
Office of Acquisition Management
Office of the Comptroller
Office of Enforcement
Office of Enforcement and Compliance Assurance
Office of Emergency and Remedial Response (OSWER)
Operational and Functional
Office of Federal Facilities Enforcement (OE)
Office of the Inspector General
III
-------
OSWER Directive 9200 3-14-2
O&M
OMB
OPA
OPAC
0PM
OPPE
ORC
ORD
OSC
OSW
OSWER
OU
OUST
OWPE
PA
PAH
PC
PCB
PDBS
ppc
1 .LjO
PMSO
PNRS
PO
POD
POLREP
PQOP
PR
PRP
PRSC
QA-
QAPP
QAT
RA
RAC
RADS
RCMS
RCRA
RCRC
RD
RDT
RELAI
REMT
RESAT
RFP
RI
RIDS
RI/FS
ROD
RODEIS
RP
RP2M
Operation and Maintenance
Office of Management and Budget
Oil Pollution Act
On-line Payment and Collections
Office of Program Management (OERR)
Office of Policy, Planning, and Evaluation
Office of Regional Counsel
Office of Research and Development
On-Scene Coordinator
Office of Solid Waste
Office of Solid Waste and Emergency Response
Operable Unit
Office of Underground Storage Tanks (OSWER)
Office of Waste Programs Enforcement (OSWER)
Preliminary Assessment
Polyaromatic Hydrocarbons
Personal Computer
Polychlorinated biphenyls
Program Development and Budget Staff (OERR)
Planning and Evaluation Section (OERR)
Program Management Support Office (OWPE)
Preliminary Natural Resource Surveys
Project Officer
Program Operations Division (OFFE)
Pollution Report
Pre-Qualified Officers Procurement
Procurement Request
Potentially Responsible Party
Post Removal Site Controls
Quality Assurance
Quality Assurance Project Plan
Quality Action Team
Remedial Action
Response Action Contracts
Risk Assessment Data System
Removal Cost Management System
Resource Conservation and Recovery Act
Regional Cost Recovery Coordinator
Remedial Design
Regional Decision Team
Responsive Electronic Link and Access Interface
Regional Emergency Preparedness Team
Regional Environmental Services Assistance Team
Request for Proposal
Remedial Investigation
ROD Information Data System
Remedial Investigation and Feasibility Study
Record of Decision
ROD and Enforcement Information System
Responsible Party
Remedial Pipeline Project Management
IV
-------
OSWER Directive 9200.3-14-2
RPM
RPO
RRT
RTF
SACA
SACM
SAM
SARA
SCAP
SEA
SERC
SETS
SFO
SI
SIBAC
SIF
SIP
SITE
SMARTech
SMOA
SMP
SMRS
SMSA
SNAP
SNL
SOL
SOW
SPCC
SRIS
SSA
SSAB
SSC
S/S ID
SSP
STARS
START
TAG
TAT
TBD
TES
TESWATS
TSCA
TQM
TRC
UAO
USAGE
USCG
USFWS
USGS
WA
WAM
ZPO
Remedial Project Manager
Regional Project Officer
Regional Response Team
Research Triangle Park
Site Assessment Cooperative Agreement
Superfund Accelerated Cleanup Model
Site Assessment Manager
Superfund Amendments and Reauthorization Act of 1986
Superfund Comprehensive Accomplishments Plan
Site Evaluation Accomplished
State Emergency Response Commissions
Superfund Enforcement Tracking System
Servicing Finance Office
Site Inspection
Simplified Interagency Billing and Collection
Site Information Form
Site Inspection Prioritization
Superfund Innovative Technology Evaluation
Superfund Management and Reporting Technology
State Memorandum of Agreement
Site Management Plan
SCAP Management Reporting System
Standard Metropolitan Statistical Area
Superfund National Assessment Program
Special Notice Letter
Statute of Limitations
Statement of Work
Spill Prevention Control and Countermeasure
Superfund Report Information System
Site Screening and Assessment
Site Specific Advisory Board
Superfund State Contracts
Site/Spill Identification Number
Site Safety Plan
Strategic Targeted Activities for Results System
Superfund Technical Assistance and Response Team
Technical Assistance Grants
Technical Assistance Team
To Be Determined
Technical Enforcement Support
Technical Enforcement Support Work Assignment Tracking System
Toxic Substances Control Act
Total Quality Management
Technical Review Committees
Unilateral Administrative Order
United States Army Corps of Engineers
United States Coast Guard
United States Fish and Wildlife Service
United States Geological Survey
Work Assignment
Work Assignment Manager
Zone Project Officer
V
-------
-------
OSWER Directive 9200.3-14-2
ORGANIZATIONAL CHARTS
-------
-------
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
Outreach and Special
Projects Staff
I
Office of Program
Management
>
Policy and Contracts
Assessment Staff
Management Systems
Contracts Staff
Program Management
and Services Staff
Program Development
and Budget Staff
Office of the Director
Special Assistant
I
Hazardous Site
Evaluation Division
I
Hazardous Site
Control Division
Site Assessment
Branch
Analytical Operations
Branch
Toxics Integration
Branch
State and Local
Coordination Branch
Remedial Operations
and Guidance Branch
Design and
Construction Branch
I
Emergency
Response Division
Response Operations
Branch
Response Standards
and Criteria Branch
Environmental
Response Branch
tfl
Oil Pollution Response | ~
and Abatement Branch
-------
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
Office of Program Management
Office o
Mana
Immed]
f Program
ate Office 1
Special Assistant
Policy and Contracts
assessment Staff
Policy Analysis Section I
Contracts Oversight
Section
Management
Systems Staff
Program
Management and
Services Staff
Headquarters
Contract
Management Section
Management Systems |
Coordination Section
Customer Service
Section
1
Program
Development and
Budget Staff
O
tn
tr)
ft)
n
N)
O
O
Planning and
Evaluation Section
J
Resource
Management Section
-------
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
Emergency Response Division
JL
Response Operations
Branch
Eastern Section
Western Section
Emergency Response Division
Special Assistants
J
Environmental Respons
Branch
Safety & Air
Surveillance Section
Site Investigation Section
Operations Section
Alternative Technology
Section
Contracts & Data
Management Section
_L
Response Standards &
Criteria Branch
Oil Pollution Response &
Abatement Branch
Response Policy Guidance
& Support Section
Response
Regulations Section
Oil Pollution
Prevention Team
Oil Pollution
Response &
Guidance Team
0>
n
O
O
-------
T5
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
Hazardous Site Evaluation Division
Site Assessment
Branch
NPL Criteria Section
Site Evalutaion Section
NPL Operation Section
I
Hazardous Site
Evaluation Division
Director
Analytical
Operations Branch
Analytical Services
Guidance Team
Analytical Methods
Implementation
Section
Regional Operations
Section
Special Assistants
Toxics Integration
Branch
Health Effects
Program
Toxics Integration
Program
O
C/5
trt
n
n
K)
O
O
-------
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
Hazardous Site Control Division
Hazardous Site Control!
Division Director
Special Assistant
Remedial Operations
and Guidance Branch
Design and
Construction
Management Branch
Remedial Guidance
Section
Remedial Operation
Section
State and Local
Coordination
Branch
Remedial Action and
Contracts Section
Remedial Construction |
Management Section
State Involvement
Section
State Requirements | a
Section
f"
K>
-------
OSWER Directive 9200.3-14-2
The Office of Waste Programs Enforcement (OWPE), CERCLA Enforcement
Division (CED), Office of Federal Facilities Enforcement (OFFE), and Superfund
Revitalization Office (SRO) are currently undergoing a reorganization. Also
included is a proposed organization chart of the new Office of Enforcement and
Compliance Assurance (OECA). The following organization charts illustrate
how these offices currently exist. Headquarters will keep the Regions informed
of any further organizational changes as reorganization continues.
April 1994
-------
OFFICE OF WASTE PROGRAMS ENFORCEMENT
Settlement
Expediter
Director/
Deputy Director
Policy Coordinator
RCRA Enforcement
Division
CERCLA
Enforcement
Division
Program
Management and
Support Office
Technical
Assistance and
Training Branch
Policy and
Regulatory
Operations Branchl
Budget and
Analysis Section
Information
Management
Section
13
Compliance
Branch
Cost Recovery
Branch
Contracts and
Planning Branch
Guidance and
Evaluation
Branch
o
tn
q
8
n
p
OJ
-------
>
OFFICE OF WASTE PROGRAMS ENFORCEMENT
CERCLA Enforcement Division
w
n
n
n
O
O
oo
Guidance and Evaluation
Branch
Enforcement Support
Section
Enforcement Action
section
Technical Oversight
Section
Contracts and Planning
Branch
Regional Planning
Section
Contract Management
Section
Compliance Branch
Cost Recovery Branch
-------
OFFICE OF FEDERAL FACILITIES ENFORCEMENT
>
I-J
L
Office Director
Program Operations
Division
Program Management
-Budget Analysis and Execution
-Contract Management
-Workload Model
-Docket
Program Analysis
-OMB A-106 Evaluation and
Implementation
-OMB A-ll Implementation
Program Coordination
Information Management
-CERCLIS
-Other Media Data Systems
-Reporting Systems
-Organization and management
special projects
Enforcement and
Compliance Division
Enforcement Policy and Guidance
-Cleanup Agreements
-Compliance Analysis, Strategy and
Agreements
-Dispute Resolution Policy
-Legislative Initiatives
Regional Coordination
Multimedia Program
Accomplishment Planning and
Tracking
Compliance and Enforcement Actions
Special Program Initiatives
Strategic Planning
and Prevention
Division
-Policy Development
-Inspection Oversight
Strategic Planning
-National Priorities
-Operating Guidance
Outreach
Training
Technology Development
DOE Compliance
Expedited Claims
O
a>
w
fD
p
w
-------
TS
SUPERFUND REVITALIZATION OFFICE
o
tn
w
National Superfund Director
Office Director
m
O
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Acquisition Group
Program and Enforcement Group
1 ARCS Task Force Implementation
CLP Task Force Implementation
Long-Term Contracts Strategy
Implementa tion
1 Response Action Contracts
(RACs) Indemnification
Guidelines Implementation
1 Contracts Management Issues
' Contracts Management Training
1 Regional Contract Management
Reviews
Construction Completions
30-Day Study Implementation
Risk Assessment and Risk
Management Issues
Department of Justice Issues
Other Enforcement Issues
State Issues
Streamlining Issues
Federal Facilities Issues
Site-Specific Issues
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OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE
ASSISTANT ADMINISTRATOR
OFFICE OF ENFORCEMENT AND COMPLIANCE
ASSURANCE
Office
of Site
Remediation
Enforcement
1
Program Suppor
Office
Program § Regional 1
Evaluation and I Support 1
Policy Division I Division I
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Federal
Facilities
Enforcement
Division
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OSWER Directive 9200.3-14-2
EPA REGIONAL MAP
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U.S. EPA REGIONS
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OSWER Directive ^200.3-14-2
APPENDIX A
SCAP/STARS TARGETS AND MEASURES
April 1994
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OSWER Directive 9200.3-14-2
APPENDIX A
FY 94 SCAP/STARS
TARGETS AND MEASURES
APPENDIX A FY 94 SCAP/STARS TARGETS AND MEASURES A-l
OVERVIEW OF FY 94 TARGETS AND MEASURES A-l
TARGETS AND MEASURES A-l
DEVELOPMENT OF FY 94 STARS/SCAP TARGETS/MEASURES A-2
STARS/SCAP ICONS A-3
SITE SCREENING AND ASSESSMENT/REGIONAL DECISION
DEFINITIONS A-5
SSA-1 Site Characterization Starts A-7
PA Completions A-8
SI Completions A-9
Site Inspection Prioritization A-10
SSA-2 Site Screening and Assessment Decisions A-10
Regional Decisions A-12
RI Starts A-13
ESI/RI Completion A-14
FS Starts A-15
Combined RI/FS Start A-17
FS Report to Public A-19
RI/FS Duration A-19
RDT-1 Decision Document Developed A-20
EARLY AND LONG-TERM ACTION FY 94 TARGETS AND MEASURES A-25
ACT-1 Duration From Site Discovery To Site Construction
Completion A-30
ACT-2 Duration From Cleanup Decision to RD
Completion A-31
ACT- 3 Duration From Cleanup Decision to Each Cleanup
Action Completion A-32
ACT-4 Percent of Sites with Early Actions A-33
RD Starts A-35
RD Completion A-36
Remedial Action Start A-36
RA Contract Award A-37
ACT-5 Sites Addressed Through Early or Long-Term
Action On-Site Construction Starts A-38
ACT-6 Early or Long-Term Action Completions A-41
ACT-7 NPL Site Construction Completions Through Early
or Long-Term Actions A-43
ACT-8 Non-NPL and NPL Caliber Site Construction
Completions Through Early or Long-Term Actions A-48
Operational and Functional (O&F) A-52
April 1994
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OSWER Directive 9200.3-14-2
Long Term Response Action (LIRA) A-53
NPL and Non-NPL Site Completions A-54
Ground Water Monitoring A-58
Operation and Maintenance (O&M) A-59
ACT - 9 Five-Year Reviews Started A-60
Five-Year Review Completions A-60
NPL Deletion Initiation A-61
El -1 Progress Through Environmental Indicators A-62
PROGRAM SUPPORT ACTIVITIES DEFINITIONS A-69
Community Relations A-71
Support Agency Assistance A-71
Technical Assistance A-72
Technical Assistance Grants A-73
Treatability Studies A-73
Projects Nominated for SITE Program A-74
Design Assistance A-74
ENFORCEMENT FY 94 SCAP/STARS TARGETS AND MEASURES A-79
PRP Search Starts A-84
PRP Search Completions A-84
Section 104(e) Letters Issued A-85
Section 104(e) Referrals and Orders Issued A-85
Issuance of General Notice Letters A-86
Issuance of Special Notice Letters A-86
ENF-1 Duration from Regional Decision or ROD to PRP
Cleanup Negotiation Completion A-87
ESI/RI/FS Negotiation Starts A-89
RD/RA Negotiation Starts A-90
ENF-2* Cleanup Negotiation Completions A-91
State Order for ESI/RI/FS A-93
State Consent Decree for RD/RA A-93
ENF-3* Settlements For Cleanup Actions A-94
ENF-4 De minimis Settlements and Number of PRPs A-96
ENF-5 Percentage of PRP Lead Cleanup Actions to all
Cleanup Actions A-97
Section 106,106/107,107 Case Resolution A-98
Administrative Record Compilation Completion A-99
Issue Demand Letter A-100
Cost Recovery Actions/Decisions Less Than $200,000 A-100
ENF-6 Past Costs Addressed > $200,000 A-102
FEDERAL FACILITIES FY 94 SCAP/STARS TARGETS AND MEASURES A-109
FF-1 Base Closure Decision A-113
FF-2 Federal Facility Agreements/IAG Start A-113
FF-3 Federal Facility Agreements/1 AG Completion A-114
FF-4 Federal Facility Dispute Resolution A-115
FF-5 RI/FS Starts First and Subsequent A-115
FF-6 Timespan From NPL Listing To RI/FS Start A-116
April 1994 ii
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OSWER Directive 9200.3-14-2
FF-7 RI/FS Completions (RODs) - First and Subsequent A-117
FF-8 RI/FS Duration A-117
FF-9 RD Starts First and Subsequent A-118
FF-10 RD Completions - First and Subsequent A-119
FF-11 RD Duration A-119
FF-12 RA Starts First and Subsequent A-120
FF-13 Timespan from ROD Signature to RA Start A-121
FF-14 RA Completions - First and Subsequent A-122
FF-15 Final RA Completion A-122
FF-16 RA Duration A-123
FF-17 Timespan from RI/FS Start to RA Complete A-124
FF-18 Removal/ERA/RCRA Corrective Actions - Start and
Completion A-124
FF-19 Federal Facility NPL Deletion A-126
iii April 1994
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OSWER Directive 9200.3-14-2
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April 1994 iv
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OSWER Directive 9200.3-14-2
APPENDIX A
LIST OF EXHIBITS
A-l Site Screening and Assessment/Regional Decision
Activities A-6
A-2 Site Screening and Assessment/Regional Decision
Target/Measure Crosswalk A-7
A-3 Site Screening and Assessment/Regional Decision
Planning Requirements A-22
A-4 Early and Long-Term Action Activities A-26
A-5 Early and Long-Term Action Target/Measure Crosswalk A-28
A-6 Early and Long-Term Action Planning Requirements A-63
A-7 Program Support Activities A-70
A-8 Program Support Activities Planning Requirements A-76
A-9 Enforcement Activities A-80
A-10 Enforcement Target/Measure Crosswalk A-82
A-ll Enforcement Planning Requirements A-105
A-12 Federal Facilities Activities A-110
A-13 Federal Facilities Target/Measure Crosswalk A-lll
A-14 Federal Facilities Planning Requirements A-127
A-15 Long-Term Action Flow Chart A-131
April 1994
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April 1994 vi
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OSWER Directive 9200.3-14-2
APPENDIX A
FY 94 SCAP/STARS TARGETS AND MEASURES
OVERVIEW OF FY 94 TARGETS AND MEASURES
Superfund cleanup results are measured through targets and measures that track
progress on three distinct levels: STARS, SCAP, and internal.
SCAP and STARS targets are the tools by which program goals are translated
into quantifiable program achievements. Regions should concentrate their resources
on achieving targets negotiated and set by HQ and the Regions.
STARS is used by the Administrator to set and monitor the progress each
program is making toward meeting its environmental goals. SCAP is used by the
AA SWER, OE, OFFE, and senior Superfund managers to monitor the progress each
Region is making toward achieving its Superfund goals. National and Regional
STARS goals are established and tracked through SCAP. STARS targets are a subset
of those contained in SCAP.
Those Superfund activities not tracked at the STARS or SCAP level are
monitored by HQ for internal management purposes.
TARGETS AND MEASURES
A SCAP or STARS target (either semi-annual or annual) is a pre-determined
numerical goal that is negotiated by HQ and the Regions prior to the FY to ensure
that designated activities will take place. All STARS targets are SCAP targets. Ten
percent of a Region's annual budget is established based on STARS and SCAP
targets.
A STARS and/or SCAP measure is used to track an activity that is important in
monitoring overall program progress. The two types of measures are STARS
reporting and SCAP planning/reporting measures. Planning estimates result in
numerical goals established prior to the FY that are used in setting annual budgets.
Regions report progress against the planning estimates. STARS/SCAP reporting
measures have no associated quantitative goals; only actual accomplishments are
tracked.
HQ has developed internal management planning and reporting measures to
monitor activities not currently tracked at the STARS/SCAP level. These measures
are used by HQ for trend analyses and to evaluate progress through the cleanup
pipeline.
A-l April 1994
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OSWER Directive 9200.3-14-2
STARS/SCAP accomplishments will be pulled from CERCLIS on a quarterly
basis. Regions are evaluated semi-annually according to their completion of
activities within established target areas.
DEVELOPMENT OF FY 94 STARS/SCAP TARGETS/MEASURES
STARS/SCAP targets and measures for FY 94 are broader in scope than in FY 93.
A concerted effort has been made to combine targets and measures that in the past
were tracked separately to provide maximum flexibility to the Regions for program
implementation and provide incentives for conducting actions at NPL caliber sites
prior to NPL proposal. By incorporating and tracking on a broader level, the FY 94
targets and measures provide more program-wide measures of progress being made
towards site cleanup not just those activities at NPL sites. In addition, the trend
established a few years ago not to develop lead-specific or event-specific targets and
measures has been maintained. However, these subgroups will continue to be
tracked for internal management purposes in order to assess, among other things,
the level of PRP participation.
Every attempt has been made to equate SACM activities and definitions to pre-
SACM activities and definitions. Many of the targets/measures and definitions in
FY 94 embody the FY 93 targets/measures. For example, the FY 93 Number of
Remedial Program Remedies Selected (ROD) and Action Memoranda Signed for
Removal Actions at NPL Sites is characterized in FY 94 as RDT -1 Decision
Document Developed.
The following pages contain the definitions of the FY 94 site screening and
assessment/Regional decision, early and long-term action, enforcement, and Federal
Facility STARS/SCAP targets and measures (with the prefix SSA, RDT, ACT, ENF,
or FF and an identifying icon), internal management planning and reporting
measures, and project support activities grouped by pipeline category. Each of the
following sections begins with a full list of activities identifying each activity as
STARS/SCAP OR internal planning, followed by an exhibit that provides a
crosswalk of the FY 94 targets and measures grouped by pipeline category (there are
no targets and measures within the Program Support Activities section, therefore
this exhibit is not included). At the end of each pipeline category definition section,
exhibits are included that describe the planning and reporting requirements for
activities contained in that section. FY 94 targets and measures that are similar to
those in FY 93 are identified.
April 1994 A-2
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OSWER Directive 9200.3-14-2
STARSISCAP ICONS
For easy identification of STARS/SCAP targets and measures, each
STARS/SCAP activity or duration is identified by an easily recognizable icon. Each
icon identifies an activity or duration as a target or measure, and whether it is
tracked through STARS and/or SCAP. The icons are as follows:
STARS/SCAP
Target
STARS/SCAP
Measure
SCAP Target
SCAP Measure
A-3
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OSWER Directive 9200.3-14-2
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April 1994 A-4
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OSWER Directive 9200.3-14-2
SITE SCREENING AND ASSESSMENT/REGIONAL DECISION
DEFINITIONS
A-5 April 1994
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OSWER Directive 9200.3-14-2
EXHIBIT A-l
SITE SCREENING & ASSESSMENT/REGIONAL
DECISION ACTIVITIES
INTERNAL
SSA-1 Site
Characterization Starts
PA Completions
SI Completions
Site Inspection
Priori tizations
SSA-2 Site Screening &
Assessment Decisions
Regional Decisions
ESI/RI Completion
Combined RI/FS Starts
FS Report to Public
RI/FS Duration
RDT-1 Decision Document
Developed
Semi-annual targets are established in SCAP/STARS .
Accomplishments are pulled from CERCLIS on a quarterly basis.
Internal measures are reported semi-annually.
April 1994
A-6
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OSWER Directive 9200.3-14-2
EXHIBIT A-2
SITE SCREENING AND ASSESSMENT/REGIONAL
DECISION
TARGET/MEASURE CROSSWALK
FY 94 Target/Measure
Similar FY 93
Target/Measure
Comments
SSA-1 - Site
Characterization Starts
(SCAP measure)
None
New
SSA-2 - Site Screening
and Assessment
Decisions (STARS/
SCAP measure)
None
New
RDT-1 - Decision
Document Developed
(STARS/SCAP target)
Decision Document
Development -
Remedies Selected and
Action Memoranda
Signed (SCAP/STARS
target)
First Remedy Selected
at NPL Sites - ROD
(SCAP target)
Subsequent Remedy
Selected at NPL Sites -
ROD (SCAP target)
Deleted special
reporting requirements
for PRP-lead removals.
This measure will
include NPL, non-NPL, |
and NPL caliber sites.
A Technical
Information Type will
be required for sites
where presumptive
remedies are selected.
SSA-1 Site Characterization Starts
Definition of Target/Measure:
Site characterization involves collection of field data from a hazardous substance site
for the purpose of characterizing the magnitude and severity that the hazard at the
site poses to human health and the environment. A site characterization start is
defined as the first Superfund financed SI, ESI/RI, or removal assessment at a site.
A-7
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OSWER Directive 9200.3-14-2
Definition of Accomplishment:
The Region will receive credit for a site characterization start when:
EPA or the State approves, in writing, the sampling plan (work plan) at a site for
the first SI (C2101=SI) or removal assessment (C2101=EA) and the actual start
date is reported in WasteLAN; or
Funds are obligated for the first ESI/RI (C2101 = SS) and the actual start date is
reported in WasteLAN. Funds are obligated when the Contracting Officer (CO)
signs the contract modification, the Regional Administrator or his/her designee
signs the Cooperative Agreement (CA), or an IAG is signed by the other Federal
agency (i.e., USAGE or BUREC).
Regions will only receive credit for the first site characterization event started
at a site.
Changes in Definition FY 93 - FY 94:
This is a new SCAP measure for FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. Accomplishments are reported site-specifically
in WasteLAN as the actual start date of the appropriate event. This is a SCAP
measure. Funds for Sis, ESI/RIs, and removal assessments are contained in the site
characterization AOA.
PA Completions
Definition:
A PA is the first stage of site assessment which determines whether a site should be
recommended for further CERCLA action. Federal, State, and local government
files, geological and hydrological data, and data concerning site practices are
reviewed to complete the PA report. A site reconnaissance is also conducted.
Definition of Accomplishment:
A PA is complete when the report is reviewed and approved by the Region and
WasteLAN contains the actual PA completion date, a valid event lead (C2117), and
the decision on whether further activities are necessary is shown in the Event
Qualifier Field (C2103).
Changes in Definition FY 93 - FY 94:
PA Completions will no longer be tracked as a SCAP reporting measure in FY 94;
however, the first PA completion at a site will continue to be reported for internal
management purposes.
April 1994 A-8
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OSWER Directive 9200.3-14-2
Special Planning/Reporting Requirements:
For budget and resource allocations, a projection must be made in CERHELP for
State PA completions. PA completions (C2101=PA) are reported site specifically in
WasteLAN. Only the first PA completion at a site will be tracked. PAs at Federal
Facilities will be tracked separately.
SI Completions
Definition:
The SI involves collection of field data from a hazardous substance site for the
purpose of characterizing the magnitude and severity of the hazard posed by the site
and/or to support enforcement. An SI should provide adequate data to determine
the site's HRS score.
NOTE: SI start dates are also required (see SSA-1, Site Characterization Starts).
Definition of Accomplishment:
A SI is complete when:
A Site Inspection Report has been received by the Region from the ARCS
contractor or the State;
The report has been reviewed and approved by the appropriate Regional official;
The appropriate Regional official decides whether further site evaluation work is
necessary; and
The following has been recorded in WasteLAN: the SI report approval date as
the actual SI complete date, a valid event lead (C2117), and a decision on the
need for further action in the Event Qualifier data field (C2103).
Changes in Definition FY 93 - FY 94:
SI Completions will no longer be tracked as a SCAP target in FY 94; however, the
first SI completion will continue to be planned and reported for internal
management purposes.
Special Planning/Reporting Requirements:
For budget and resource allocations, separate projections must be made in
CERHELP for EPA vs. State SI completions. SI completions (C2101=SI) are reported
site specifically in WasteLAN. Only the first SI completion at a site will be tracked.
Sis at Federal Facilities will be tracked separately.
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OSWER Directive 9200.3-14-2
Site Inspection Prioritization
Definition:
The SIP requires the gathering of data to update the site evaluation and determine
whether the HRS score is greater than 28.5, if the site should be designated SEA or
deferred to another authority.
Definition of Accomplishment:
A SIP is complete when a revised HRS score is generated, the SIP report is accepted
by the Region, and a decision has been made to:
Designate the site SEA;
High or low priority to conduct an ESI/RI and NPL listing; or
Defer the site to another authority (i.e., RCRA Title C or NRC personnel).
The following information must be entered into WasteLAN:
Enter the SIP as a subevent to the last SI (C2101 = SI and C3101 = SP);
Enter the actual completion date when the SIP report (including revised HRS
score) is accepted by the Region in writing; and
Delete the event qualifier (C2103) for the SI and enter the decision made upon
completion of the SIP in the Event Qualifier data field (C2103).
Changes in Definition FY 93 - FY 94:
This is a new internal planning measure.
Special Planning and Reporting Requirements:
See Definition of Accomplishment. SIPs are reported site-specifically in WasteLAN.
SSA-2 Site Screening and Assessment Decisions
Definition of Target/Measure:
Site screening and assessment decisions are made at all Superfund sites and identify
how to proceed with site response. These decisions include: SEA, perform an early
action, prepare the HRS package, perform a response action as part of a "parent NPL
site," and deferral to another authority (NRC or RCRA Subtitle C).
April 1994 A-10
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OSWER Directive 9200.3-14-2
Definition of Accomplishment:
Credit is given for each site screening and assessment decision at a site that
identifies how to proceed with the site or Operable Unit (OU), including when:
Superfund site assessment activities are suspended and a SEA determination is
made when the site assessment report (i.e., PA, SI, etc.) is reviewed and
approved by the appropriate Regional official. No further Superfund actions will
be taken at a site with a SEA determination. The date of the SEA determination
must be entered as the actual completion date of the appropriate site screening
and assessment event when the decision was made. In addition, a valid lead
(C2117) and the event qualifier for no further remediation planned (C2103 = N)
must be entered into WasteLAN; or
The RDT or other Regional personnel determines that a time critical or NTC early
action under removal authority or an early action under remedial authority is
necessary. This decision must be documented in a memo to the file. The date of
the Regional decision (C2101 = DT) as the actual completion date, and the
appropriate early action Event Qualifier (C2103 = R, V, or J) must be entered into
WasteLAN; or
The RDT or other Regional personnel determine that sufficient data exist to
indicate the site may require long-term action and a decision is made to begin
preparation of the HRS package. This decision must be documented in a memo
to the file. The date of the Regional decision to begin preparing the HRS package
(C2101 = DT) as the actual completion date and the Hazard Ranking System
Package Development Event Qualifier (C2103 = G) must be entered into
WasteLAN; or
A decision is made to collapse or combine a site into another "parent NPL site"
(C0305 = A, "Aggregate"). This would be done when contamination at a non-
NPL site is being addressed by cleanup actions at a NPL site. This type of action
would typically be taken at Federal Facilities or an area-wide ground water
contamination problem that results from multiple sources. In this situation, the
parent site EPA ID number must be entered into WasteLAN (C0306) with the
child site. Upon completion of the site assessment activity that led to the
decision to aggregate the site, the Region should enter "A" (Aggregate) in the
Event Qualifier data field (C2101= PA, SI, ES, or SS and C2103=A). This decision
should be documented in the form used to approve the site assessment report.
After a site is collapsed into the parent site, no further work is recorded with the
original site. Any further response work performed at these collapsed sites is
recorded as a separate OU and assigned to the parent site. The changes in the
data base to allow this coding are currently under development; or
A determination is made that the site is excluded from Superfund consideration
under policy, regulatory, or legislative restrictions and it is deferred to another
authority (NRC or RCRA Subtitle C). The date of the decision must be entered as
A-ll April 1994
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OSWER Directive 9200.3-14-2
the actual completion date of the appropriate site screening and assessment event
when the decision was made. The decision is documented in the form used by
the Region to approve the site assessment report. In addition, a valid lead
(C2117) and the event qualifier (C2103 = D) must be entered into WasteLAN with
the applicable event at which the decision is made.
Changes in Definition FY 93 - FY 94:
This is a new STARS/SCAP measure for FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. The date of the Regional decision to begin an
early action, list the site on the NFL or aggregate the site with a parent site; the date
of the determination that the site is excluded from Superfund; or the date of the SEA
are to be entered into WasteLAN. Also enter the appropriate qualifiers with the site
screening and assessment event (i.e., C2101= PA, SI, ES, or SS). Accomplishments
are reported site-specifically in WasteLAN. This is a STARS/SCAP measure.
Regional Decisions
Definition:
This measure will track decisions made by the Region (including the RDT) on
whether to perform site assessment and enforcement activities and early and long-
term actions. The RDT is empowered by the Region to make those decisions that are
delegated to its level. This body serves as a tool to ensure early and effective
communication and should provide input for the traditional line decision-making
authorities. Though the structure and responsibilities of the RDT vary from Region
to Region, the RDT generally should provide policy and strategic direction to
designated site managers.
Definition of Accomplishment:
The following information on Regional decisions must be entered into WasteLAN:
The dates of the Region's decisions on appropriate response actions (C2101 = DT)
as the actual completion dates. Each decision must be documented in a memo to
the file and reported separately.
The response or enforcement decision made in the Event Qualifier data field
(C2103).
Changes in Definition FY 93 - FY 94:
This is a new internal reporting measure in FY 94.
April 1994 A-12
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OSWER Directive 9200.3-14-2
Special Planning/Reporting Requirements:
This is an internal reporting measure. See Definition of Accomplishment for
information on the WasteLAN reporting requirements.
Rl Starts
Definition:
The RI is an investigation designed to characterize the site, assess the nature and
extent of the contamination and evaluate potential risk to human health and the
environment.
Obligation of funds for forward planning, community relations and/or other
support activities do not constitute a RI start.
Definition of Accomplishment:
Fund-financed (Including F- and S-lead events.) - A Fund RI starts when funds are
obligated. Funds are obligated when:
The contract modification for the RI has been signed by the EPA CO; or
An LAG has been signed by the other Federal agency (USAGE or BUREC); or
A CA has been signed by the Regional Administrator or his designee to conduct
a RI; and
Obligation and actual start dates have been recorded in WasteLAN.
If a subsequent RI is initiated without a new obligation of funds, the start date is
defined as EPA's written approval of the work plan for the subsequent RI.
PRP-financed (Includes RP-, MR-, and PS- lead events) - A Responsible Party (RP or
MR)-lead RI start counts when one of the following enforcement actions occurs:
An AOC is signed by the Regional Administrator. The RI start date is the AOC
completion date (Regional Administrator signature date); or
A CD is referred by the Region to DOJ or HQ. The RI start date is the date the
Regional Administrator signs the memo transmitting the CD to HQ or DOJ.
A PS-lead RI start counts when a State order or comparable enforcement document
is signed by the last appropriate State official or party and the site is covered by one
of the following:
State enforcement CA;
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OSWER Directive 9200.3-14-2
Superfund Memorandum of Agreement (SMOA) containing a schedule for RI
work at the site; or
Other State/EPA agreement.
If a subsequent RI is initiated without a new or amended AOC, CD, State order, or
other comparable State enforcement document, the start date for the RI is defined as
EPA's or the State's written approval of the work plan for the subsequent RI.
If an AOC, State order, or other comparable State enforcement document is
amended for the subsequent RI, the start date is the date the last State official or
Regional Administrator signs the amendment. If an EPA CD is amended, the start
date is the date of signature by the Regional Administrator on the memo
transmitting the CD to HQ or DOJ.
EP-lead - An EP-lead RI start counts when the Region has the initial scoping
meeting. The start is documented by preparing and placing the minutes from the
meeting in the file.
Changes in Definition FY 93 - FY 94:
The EP-lead start definition was revised. RI starts are included to show a separation
from the traditional combined RI/FS under SACM. RI/FS starts will no longer be
tracked as a SCAP target in FY 94. The start of a RI or combined RI/FS will continue
to be planned and reported for internal management purposes.
Special Planning/Reporting Requirements:
Regions are not required to enter the RI start date if the RI is being conducted as part
of a combined ESI/RI, RI/FS, or ESI/RI/FS. The RI (C2101 = RI), combined RI/FS
(C2101 = CO) or combined ESI/RI (C2101 = SS) actual start date is reported site
specifically in WasteLAN. Funds for RIs are found in the site characterization AOA.
ESI/RI Completion
Definition:
An ESI/RI characterizes the magnitude and severity of a hazardous waste site.
ESI/RI activities will be conducted at sites where conditions indicate that the HRS
score will be above 28.5 and a remedial response will be needed.
The ESI/RI start is defined in SSA-1, Site Characterization Starts.
April 1994 A-14
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OSWER Directive 9200.3-14-2
Definition of Accomplishment:
The ESI/RI is complete when:
An ESI/RI report has been received by the Region from the ARCS contractor or
the State;
The report has been reviewed and approved, in writing, by the appropriate
Regional office; and
A decision is made to:
- Perform a FS and HRS scoring;
- Perform an early action under removal or remedial authority; or
Designate the site SEA.
The following must be recorded in WasteLAN:
The actual ESI/RI completion date (C2101 = SS); and
The decision on further action in the Event Qualifier data field (C2103).
Changes in Definition FY 93 - FY 94:
This is a new definition in FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment.
FS Starts
Definition:
The FS is used to develop and evaluate all potential remediation alternatives to clean
a hazardous waste site.
Obligation of funds for forward planning, community relations and/or other
support activities do not constitute a FS start.
Regions are not required to enter the FS start date if the FS is being conducted as
part of a combined RI/FS or ESI/RI/FS.
A-15 April 1994
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OSWER Directive 9200.3-14-2
Definition of Accomplishment:
Fund-financed (Including F- and S-lead events.) - A Fund FS starts when funds are
obligated. Funds are obligated when:
The contract modification for the FS has been signed by the EPA CO; or
An IAG has been signed by the other Federal agency (USAGE or BUREC); or
A CA has been signed by the Regional Administrator or his designee to conduct
a FS; and
The obligation and actual FS start dates have been recorded in WasteLAN.
If a first or subsequent FS is initiated without a new obligation of funds, the start
date is defined as the date of EPA's written approval of the work plan for the FS.
PRP-financed (Includes RP-, MR-, and PS- lead events) - A Responsible Party (RP or
MR)-lead FS starts when one of the following enforcement actions occurs:
An AOC that addresses FS activities is signed by the Regional Administrator.
The FS start date is the AOC completion date (Regional Administrator signature
date); or
A CD is referred by the Region to DOJ or HQ. The FS start date is the date of
signature by the Regional Administrator on the memo transmitting the CD to
DOJ or HQ.
A PS-lead FS starts when a State order or comparable enforcement document is
signed by the last appropriate State official or party and the site is covered by one of
the following:
State enforcement CA;
SMOA containing a schedule for FS work at the site; or
Other State/EPA agreement.
If a first or subsequent FS is initiated without a new or amended AOC, CD, State
order, or other comparable State enforcement document, the start date for the FS is
defined as EPA's or the State's written approval of the work plan for the subsequent
FS.
If an AOC, State order, or other comparable State enforcement document is
amended for the first or subsequent FS, the start date is the date the last State official
or the Regional Administrator signs the amendment. If an EPA CD is amended, the
April 1994 A-16
-------
OSWER Directive 9200.3-14-2
start date is the date the Regional Administrator signs the memo transmitting the
CD to HQ or DOJ.
EP-lead - An EP-lead FS start counts when the Region has the initial scoping
meeting. The start date is documented by preparing and placing the minutes from
the meeting in the file.
Changes in Definition FY 93 - FY 94:
The EP-lead start definition was revised. The FS Start definition has been separated
from the traditional combined RI/FS to show its new identity under SACM. RI/FS
starts will no longer be tracked as a SCAP target in FY 94. The start of a FS or
combined RI/FS will continue to be planned and reported for internal management
purposes.
Special Planning/Reporting Requirements:
Regions are not required to enter the FS start date if the FS is being conducted as
part of a combined RI/FS or ESI/RI/FS. The FS (C2101 = FS) or combined RI/FS
(C2101 = CO) actual start date is entered into WasteLAN site-specifically. Funds for
FS projects are found in the site characterization AOA.
Combined RI/FS Start
Definition:
The RI/FS is an investigation designed to characterize the site, assess the nature and
extent of the contamination, evaluate potential risk to human health and the
environment, and develop and evaluate potential remediation alternatives.
Obligation of funds for forward planning, community relations and/or other
support activities do not constitute a RI/FS start.
Definition of Accomplishment:
Fund-financed (Including F- and S-lead events.) - A Fund RI/FS starts when funds
are obligated. Funds are obligated when:
The contract modification for the RI/FS has been signed by the EPA CO; or
An IAG has been signed by the other Federal agency (USACE or BUREC); or
A CA has been signed by the Regional Administrator or his designee to conduct
a RI/FS; and
The obligation and actual RI/FS start dates have been recorded in WasteLAN.
A-17 April 1994
-------
OSWER Directive 9200.3-14-2
If a first or subsequent RI/FS is initiated without a new obligation of funds, the start
date is defined as the date of EPA's written approval of the work plan for the RI/FS.
PRP-financed (Includes RP-, MR-, and PS- lead events) - A Responsible Party (RP or
MR)-lead RI/FS starts when one of the following enforcement actions occurs:
An AOC is signed by the Regional Administrator. The RI/FS start date is the
AOC completion date (Regional Administrator signature date); or
A CD is referred by the Region to DOJ or HQ. The RI/FS start date is the date
the Regional Administrator signs the memo transmitting the CD to HQ or DOJ;
A PS-lead RI/FS starts when a State order or comparable enforcement document is
signed by the last appropriate State official or party and the site is covered by one of
the following:
State enforcement CA;
SMOA containing a schedule for RI/FS work at the site; or
Other State/EPA agreement.
If a first or subsequent RI/FS is initiated without a new or amended AOC, CD, State
order, or other comparable State enforcement document, the start date for the RI/FS
is defined as EPA's or the State's written approval of the work plan for the
subsequent RI/FS.
If an AOC, State order, or other comparable State enforcement document is
amended for the first or subsequent RI/FS, the start date is the date the last State
official or Regional Administrator signs the amendment. If an EPA CD is amended,
the start date is the date of signature by the Regional Administrator on the memo
transmitting the CD to HQ or DOJ.
EP-lead - An EP-lead RI/FS start counts when the Region has the initial scoping
meeting. The start is documented by preparing and placing the minutes from the
meeting in the file.
Changes in Definition FY 93 - FY 94:
The EP-lead start definition was revised. Combined RI/FS starts will no longer be
tracked as a SCAP target in FY 94. The start of ESI/RI, FS, or combined RI/FS will
be planned and reported for internal management purposes.
April 1994 A-18
-------
OSWER Directive 9200.3-14-2
Special Planning/Reporting Requirements:
Regions are not required to report a combined RI/FS start if an ESI/RI or separate RI
and FS are being conducted. The combined RI/FS (C2101 - CO), or ESI/RI (C2101 =
SS) or RI (C2101 = RI) and FS (C2101 = FS) actual start dates are entered into
WasteLAN site-specifically. Funds for RI/FSs are found in the site characterization
AOA.
FS Report to Public
Definition:
The FS or RI/FS report is released to the public when the contamination at the site
has been characterized and alternatives for remediation have been evaluated.
Definition of Accomplishment:
A FS report to public is accomplished the date the RI/FS reports and the proposed
plan are placed in the site repository and are available for public review. This date
must be recorded as an actual completion date in WasteLAN with the FS or
combined RI/FS subevent, RI/FS to public (C2101=FS or CO and C3101=CF).
Changes in Definition FY 93 - FY 94:
FS to Public will no longer be tracked as a SCAP reporting measure in FY 94;
however, it will continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
Accomplishments are based on the first proposed plan released to the public for
each FS or RI/FS, regardless of lead.
RI/FS Duration
Definition:
The RI/FS is an investigation designed to characterize the site, assess the nature and
extent of contamination, evaluate potential risk to human health and the
environment, and develop and evaluate potential remediation alternatives.
The RI/FS starts with the obligation of Fund monies or the signature of an AO for
the RI or combined RI/FS. The RI/FS or FS is complete with the signature of the
ROD.
The objective of this measure is to focus on good project management of critical
portions of the traditional remedial pipeline and establish a methodology which
accurately assesses program performance. Duration trends provide indicators of
areas that require attention.
A-19 April 1994
-------
OSWER Directive 9200.3-14-2
Only RI/FS projects that started post-SARA will be used for comparison and
evaluation purposes.
Definition of Accomplishment:
This measure includes all combined RI/FS projects that have a targeted completion
date in FY 94. The RI/FS duration will be calculated based on the RI or combined
RI/FS Start and Decision Document Developed (FS or RI/FS completion) definitions
specified in this Manual. Regional performance in FY 94 will be compared to:
The Regional and national average duration of RI/FS projects completed in FY 92
and FY 93; and
The Regional and national average duration of RI/FS projects completed in
previous quarters of FY 94.
Changes in Definition FY 93 - FY 94:
RI/FS durations will no longer be tracked as a SCAP reporting measure in FY 94;
however, they will continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
CERCLIS will automatically look at actual RI or combined RI/FS start dates and
actual ROD completion dates. HQ will perform the analysis of the average
durations. Fund and PRP durations will be tracked. At sites where one site-wide RI
and OU specific FSs and RODs are conducted, Links data will be used to calculate
durations.
STARS
RDT-1 Decision Document Developed
Definition of Target/Measure:
A "Decision Document" is developed to identify each decision (at NPL, non-NPL,
and NPL caliber sites) to:
Perform an emergency or time critical early action under removal authority;
Perform a NTC early action under remedial or removal authority; or
Perform a long-term action.
*
April 1994 A-20
-------
OSWER Directive 9200.3-14-2
Definition of Accomplishment:
Early Actions under Removal Authority - Emergency, Time Critical, or Non-Time
Critical - The date the OSC, Regional Administrator/Deputy Regional
Administrator, AA SWER, or designated Regional official signs the Action
Memorandum is the date the cleanup decision is made. The date of the signature is
recorded as an actual completion date in WasteLAN for the removal subevent,
Approval of Action Memo (C2101 = RV and C3101 = AM). If a presumptive remedy
is used, it must be recorded in the Technical Information Type (C3401 = PR) in
WasteLAN.
Early or Long-Term Actions under Remedial Authority - The date the Regional
Administrator/Deputy Regional Administrator or the A A SWER signs the ROD
must be reported in WasteLAN as the actual RI/FS or FS and ROD completion date
(C2101 = CO or FS and C2101 = RO). Final RODs will be tracked as a component of
this target. If a presumptive remedy is used, it must be recorded in the Technical
Information Type (C3401 = PR) in WasteLAN.
For State-lead, State signed RODs, where the ROD is also signed by EPA,
accomplishments are reported as the date EPA signs the ROD.
These decisions will be tracked separately but reported on a combined basis.
Changes in Definition FY 93 - FY 94:
This definition is equivalent to the FY 93 SCAP/STARS target "Number of Program
Remedies Selected (ROD) and Action Memoranda Signed for Removal Actions at
NPL Sites." State-lead, State signed RODs were included.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. Accomplishments are reported site-specifically
in WasteLAN. For RODs, the following additional information must be recorded in
WasteLAN: if a presumptive remedy is employed, the Presumptive Remedy
Technical Information Type (C3401 = PR) or, if a presumptive remedy is not used,
the Remedial Technology Technical Information Type (C3401 = RT) and the
appropriate Technical Information Qualifier (C3402 - C3411). This is a
SCAP/STARS target.
A-21 April 1994
-------
>
N->
EXHIBIT A-3
SITE SCREENING AND ASSESSMENT/REGIONAL DECISION
PLANNING REQUIREMENTS
SSA-2 Site
Screening &
Assessment
Decisions
SSA-1 Site
Characterization
Starts
PA
Completions
Site Inspection
Prioritization
Completions
Planning Requirements
Internal Management?
Planned Site-Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Reported Site-Specifically or in
Non-Site Portion of
WasteLAN?
AOA Category, if Fund
Financed?
AOA Category for
Oversight?
Basis for AOA?
a
m
53
a
O
S3
emi-annual targets are established in SCAP/STARS. Accomplishments are pulled from i
are planned and reported semi-annually.
on a quarterly basis. Internal measures
-------
EXHIBIT A-3 (continued)
SITE SCREENING AND ASSESSMENT/REGIONAL DECISION
PLANNING REQUIREMENTS
Combined RI/FS
Start
ESI/RI
Completions
Regional
Decisions
Planning Requirements
Internal Management?
Planned Site-Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Operable
Unit
Operable
Unit
Operable
Unit
Operable
Unit
Operable
Unit
Reported Site-Specifically or
in Non-Site Portion of
WasteLAN?
AOA Category, if Fund
Financed?
AOA Category for
Oversight?
Site
Specific
Plans
Site
Specific
Plans
Site
Specific
Plans
Basis for AOA?
v£J
* "To be determined" sites are allowed for first starts.
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a quarterly basis. Internal measures are
planned and reported semi-annually.
m
53
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n
N>
8
OJ
N)
-------
>
>-t
EXHIBIT A-3 (continued)
SITE SCREENING AND ASSESSMENT/REGIONAL DECISION
PLANNING REQUIREMENTS
RDT-l
Decision
Document
Developed
RI/FS
Duration
FS Report
To Public
Planning Requirements
Internal Management?
Planned Site-Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Operable
Unit
Operable
Unit
Operable
Unit
Reported Site-Specifically or in
Non-Site Portion of
WasteLAN?
AOA Category, if Fund
Financed?
AOA Category for
Oversight?
Basis for AOA?
O
t/>
w
re
O
p
w
>»
*»
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS
on a quarterly basis. Internal measures are planned and reported semi-annually.
-------
OSWER Directive 9200.3-14-2
EARLY AND LONG-TERM ACTION
FY 94 TARGETS AND MEASURES
A-25 April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-4
EARLY AND LONG-TERM ACTION ACTIVITIES
STARS
SCAP
Internal
ACT-1 Duration from
Site Discovery to Site
Construction Completion
Measure
ACT-2 Duration from
Cleanup Decision to RD
Completion
Measure
ACT-3 Duration from
Cleanup Decision to Each
Cleanup Action Completion
Measure
ACT-4 Percent of Sites
with Early Actions
Measure
RD Starts
Planning
RD Completions
Planning
RA Starts
Planning
RA Contract Award
Planning
ACT-5 Sites Addressed
Through Early or
Long-Term Action Starts
Measure
Measure
ACT-6 Early and
Long-Term Action
Completions
Measure
Measure
ACT-7 NPL Site
Construction Completions
Through Early or
Long-Term Actions
Target
Target
Semi-annual targets are established in SCAP/STARS. Accomplishments are
pulled from CERCLIS on a quarterly basis. Internal measures are planned
and reported semi-annually.
April 1994
A-26
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-4 (continued)
EARLY AND LONG-TERM ACTION ACTIVITIES
STARS
ACT-8 Non-NPL and
NPL Caliber Site
Construction Completions
Through Early or
Long-Term Actions
Operational and
Functional
Long Term Response
Action
NPL and Non-NPL
Site Completions
Ground Water
Monitoring
Operation and
Maintenance
ACT-9 Five-Year
Reviews Started
Five-Year Review
Completions
NPL Deletion Initiation
EI-1 Progress Through
Environmental Indicators
Measure
Semi-annual targets are established in SCAP/STARS. Accomplishments are
pulled from CERCLIS on a quarterly basis. Internal measures are planned
and reported semi-annually.
A-27
April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-5
EARLY AND LONG-TERM ACTION
TARGET/MEASURE CROSSWALK
FY 94 Target/Measure
Equivalent FY 93
Target/Measure
Comments
ACT-1 Duration From
Site Discovery to Site
Construction Completion
(SCAP measure)
None
New
ACT-2 Duration From
Cleanup Decision to RD
Completion (SCAP
measure)
None
New
ACT-3 Duration From
Cleanup Decision to Each
Cleanup Action
Completion (SCAP
measure)
None
New
ACT-4 Percent of Sites
with Early Actions (SCAP
measure)
None
New
ACT-5 Sites Addressed
Through Early or
Long-Term Action
(SCAP/STARS measure)
NPL Removal Start
(SCAP target)
Non-NPL Removal Start
(SCAP target)
RA On-Site Construction
(SCAP measure)
NPL Sites Addressed
Through Removal Action
or RI/FS (SCAP/STARS
target)
This measure includes
NPL, non-NPL, and NPL
caliber sites.
ACT-6 Early and
Long-Term Action
Completions
(SCAP/STARS measure)
Removal Completion
(SCAP measure)
RA Completion (SCAP
target)
This measure counts each
action completed at NPL,
non-NPL, and NPL caliber
sites.
April 1994
A-28
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-5 (continued)
EARLY AND LONG-TERM ACTION TARGET/MEASURE
CROSSWALK
FY 94 Target/Measure
Equivalent FY 93
Target/Measure
Comments
ACT-7 NPL Site
Construction Completions
Through Early or
Long-Term Actions
(SCAP/STARS target)
Final RA NPL Site
Construction
Completion (SCAP
measure)
NPL Site Construction
Completions (STARS
measure)
NPL Site Completions
Through Removal
(SCAP target)
This measure includes
NPL sites, and will track
the 650 construction
completion goal. In order
for early actions under
removal authority to
count, a Preliminary
and/or Final Close-Out
Report or a ROD with a
construction completion
certification must be
prepared.
ACT-8 Non-NPL and
NPL Caliber Construction
Completions Through
Early or Long-Term
Actions (SCAP measure)
None
This measure includes
non-NPL, and NPL caliber
sites.
ACT-9 Five-Year
Reviews Started
(SCAP measure)
None
No Change
ENV-1 Progress Through
Environmental Indicators
(SCAP/STARS measure)
Progress Through
Environmental Indicators
(STARS/SCAP measure)
No Change
A-29
April 1994
-------
OSWER Directive 9200.3-14-2
ACT-1 Duration From Site Discovery To Site
Construction Completion
Definition of Target/Measure:
This measure shows the average duration from site discovery to site cleanup
through a final early or long-term action.
Definition of Accomplishment:
A site is discovered when a site, spill, release or potential threat of a release is given
an EPA Identification number (EPA ID), or when the discovery event (C2101=DS) is
entered into WasteLAN.
A site is considered cleaned up when physical construction is complete at NPL, non-
NPL or NPL caliber sites as a result of one or several early or long-term actions. (See
ACT-7, NPL Site Construction Completions Through Early or Long-Term Actions,
and ACT-8 Non-NPL and NPL Caliber Site Construction Completions Through
Early or Long-Term Actions, for a more complete definition of site construction
completion.)
The duration will be calculated based on the site discovery date as recorded in
WasteLAN and the SCAP/STARS site construction completion definitions found in
ACT-7 and ACT-8. All sites where construction is completed in FY 94 will be used
in the analysis.
Changes in Definition FY 93 - FY 94:
This is a new SCAP reporting measure for FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. Regions should ensure that Links data are
accurate and up-to-date in order to calculate durations. Duration trends will be
developed using CERCLIS and will continue to focus on good project management
of critical events, and address the need for continuous improvements relative to
meeting the program's goal of accelerating cleanups and reducing risks. HQ will
couple duration data with specific analyses of problem factors to determine the
causes of delays. New SACM trend reports are currently under development. This
measure will not be used for performance evaluation purposes. This is a SCAP
reporting measure.
April 1994 A-30
-------
OSWER Directive 9200.3-14-2
ACT-2 Duration From Cleanup Decision to RD
Completion
Definition of Target/Measure:
This measure shows the average duration from cleanup decision to the completion
of each RD.
Definition of Accomplishment:
A cleanup decision is made at a site when a ROD is signed for each long-term action.
A RD is complete when:
Fund-financed - For Federal (F) or State (S) lead projects, EPA approves, in
writing, the final design package.
PRP-financed - EPA approves, in writing, the final design package. For state
enforcement-lead (PS) RDs, the RD is complete when the State approves the final
design.
The duration will be calculated based on the STARS/SCAP definition for Decision
Document Developed (RDT-1) (see Appendix A) and the RD Completion definition
above. This duration will be calculated for all sites where a RD actually is completed
in FY 94.
Changes in Definition FY 93 - FY 94:
This is a new SCAP reporting measure for FY 94. The definitions for Decision
Document Developed and RD Completions have not changed between FY 93
and FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. Regions should ensure that Links data are up-to-
date and accurate in order to perform duration calculations. Duration trends will be
developed using CERCLIS and will continue to focus on good project management
of critical events and address the need for continuous improvements relative to
meeting the program's goal of accelerating cleanups and reducing risks. HQ will
couple duration data with specific analyses of problem factors to determine the
causes of delays. New SACM trend reports are currently under development. This
measure will not be used for performance evaluation purposes. This is a SCAP
reporting measure.
A-31 April 1994
-------
OSWER Directive 9200.3-14-2
QfAD
ACT- 3 Duration From Cleanup Decision to Each
Cleanup Action Completion
Definition of Target/Measure:
This measure analyzes the average duration from cleanup decision to the completion
of each early or long-term action.
Separate durations will be calculated for each type of cleanup completion: ACT-3A,
Duration from Cleanup Decision to Early Action Completion, will measure the
duration from cleanup decision to each early action completion in FY 94 under
remedial or removal authority; ACT-3B, Duration from Cleanup Decision to Each
Long-Term Action Completion, will measure the duration from cleanup decision to
each long-term action completed in FY 94.
Definition of Accomplishment:
A cleanup decision is made at a site when a remedy is selected for early or long-term
action (e.g., Action Memorandum or ROD).
An early action is a response performed under removal or remedial authority that
eliminates or reduces threats to public health or the environment from the actual or
potential release of hazardous substances. These risk reduction activities can be
conducted as emergency response, time-critical or NTC removal actions, or as early
actions under remedial authority.
An early action under removal authority is complete when the actions specified in
the Action Memorandum and enforcement document (if RP-lead) are met as
documented in a Pollution Report (POLREP).
An early action under remedial authority is complete when the Region signs a letter
accepting the Early Action Report.
Long-term actions are responses taken under remedial authority intended to achieve
the completion of more extensive site remediation activities, such as restoration of
surface and ground water resources.
A long-term action is considered complete when the Region signs a letter accepting
the RA report.
The duration will be calculated based on the STARS/SCAP definitions for Decision
Document Developed (RDT-1) (see Appendix A) and Early and Long-Term Action
Completions (ACT-6). This measure will calculate the duration for all sites where an
early or long-term action is actually completed in FY 94.
April 1994 A-32
-------
OSWER Directive 9200.3-14-2
Changes in Definition FY 93 - FY 94:
This is a new SCAP reporting measure for FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. Regions should ensure that Links data are up-to-
date and accurate in order to perform duration calculations. Separate durations will
be calculated for each cleanup completion: ACT-3A, Duration from Cleanup
Decision to Early Action Completion, will measure the duration from cleanup
decision to each early action completion in FY 94 under remedial or removal
authority; ACT-3B, Duration from Cleanup Decision to Each Long-Term Action
Completion, will measure the duration from cleanup decision to each long-term
action completed in FY 94. Duration trends will be developed using CERCLIS and
will continue to focus on good project management of critical events, and address
the need for continuous improvements relative to meeting the program's goal of
accelerating cleanups and reducing risks. HQ will couple duration data with
specific analyses of problem factors to determine the causes of delays. New SACM
trend reports are currently under development. This measure will not be used for
performance evaluation purposes. This is a SCAP reporting measure.
ACT- 4 Percent of Sites with Early Actions
Definition of Target/Measure:
This measure will compare the number of sites with early action starts under
remedial or removal authority to the total universe of sites where a cleanup decision
has been made under SACM, or a cleanup decision has been made at a NPL, non-
NPL, or NPL caliber site pre-SACM.
Definition of Accomplishment:
A cleanup decision is made at a site when a remedy is selected for early or long-term
action (e.g., Action Memorandum or ROD).
An early action is a response performed under removal or remedial authority that
eliminates or reduces threats to public health or the environment from the actual or
potential release of hazardous substances. These risk reduction activities can be
conducted as emergency response, time-critical or NTC removal actions, or as early
actions under remedial authority.
This measure will examine both current and former NPL, non-NPL, and NPL caliber
sites. It will include the following:
All current and former NPL or non-NPL sites where WasteLAN indicates that an
Action Memorandum resulted in a removal (actual start date) being started in
A-33 April 1994
-------
OSWER Directive 9200.3-14-2
FY 92 or FY 93 (C2101=RV); or
All current and former NPL sites where WasteLAN shows a ROD (actual
completion date) led to the implementation (actual start date) of a quick response
action or Expedited Response Action (ERA) in FY 92 or FY 93 (C2101=RO and
C2101=RA and C2118=EA or C2101=ER).
The total number of removals and ERAs will be compared to the total number of
current and former NPL or non-NPL sites where an Action Memorandum or a
ROD (excluding RODs that state that no remediation is required, RODs that state
that all remediation is complete, or RODs that state that the only action necessary
is institutional controls) was signed between FY 92 and FY 93; and
Those sites (NPL, non-NPL, or NPL caliber) where a cleanup decision (actual
ROD or Action Memorandum completion date) resulted in the start of an early
action (C2101=RV, C3101=AM, and C2118=EM, TC or NT or C2101=RO,
C2101=RA, and C2118=EA) in FY 93 and FY 94 compared to the total number of
sites where cleanup decisions were made in FY 93 and FY 94.
The STARS/SCAP definition for Decision Document Developed (RDT-1) (See
Appendix A) and the early action starts definition contained in ACT-5, Sites
Addressed Through Early and Long-Term Action Starts, will be used to
determine a site's eligibility.
This measure will look at the total number of sites (not the total number of actions)
with early actions (regardless of lead) compared to the total number of sites where
cleanup decisions have been made. A site is counted in the universe of sites with
early actions if either a removal, an ERA, or an early action under remedial authority
started at the site in FY 92, FY 93, or FY 94. A site is counted in the total universe of
sites where a cleanup decision has been made if either an Action Memorandum or a
ROD was signed at the site. A site can only be counted once in the universe of sites
where cleanup decisions have been made and can only be counted once in the
universe of sites with an early action start.
Changes in Definition FY 93 - FY 94:
This is a new SCAP reporting measure for FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. SN and SR-lead sites will not be included in the
calculation. Data on cleanup decisions and early actions will be developed using
CERCLIS. HQ will conduct the analysis. This is a SCAP reporting measure.
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RD Starts
Definition:
The RD converts the remedy selected in the ROD into a final design package for RA.
The obligation of funds for design assistance or technical assistance does not
constitute a RD start.
Pre-design activities will not be counted as a RD start.
Definition of Accomplishment:
Fund-Financed (Includes F- and S- lead events.) - A Fund RD is started when funds are
obligated. An obligation is made when:
The EPA CO signs the contract modification for the RD;
A CA is signed by the Regional Administrator or his designee; or
An IAG is signed by the other Federal agency.
In those instances where design assistance is conducted prior to ROD signature, and
there is not a new obligation of funds for a subsequent RD, the start of KD is defined
as the written approval of the work plan to conduct these activities. If there is a new
obligation of funds, the start of RD is defined as the date funds are obligated. When
a RD has been prepared by other parties (e.g., water lines where the city already
prepared plans and specifications) or plans developed for a similar site will be used,
the RD actual start date is the same as the RA actual start date.
PRP-financed (Includes MR-, RP-, and PS-lead events) - For MR and RP lead, the start is
credited on the date the Region approves, in writing, the PRP design contractor and
an enforcement document, which clearly spells out EPA's expectations with respect
to the RD, exists or is planned. The actual date for the RD start and the planned or
actual completion date for the associated enforcement document must be entered in
WasteLAN.
For PS-lead sites, credit will be given based on the issuance of a State order or other
comparable State enforcement document for RD (or RD/RA) or, if the RD is covered
by a pre-existing State order, the RD notice to proceed date.
If PRPs are doing the work "in-house" pursuant to an enforcement settlement
document, the start date is when EPA authorizes the PRPs to proceed, as
documented in a memorandum to the file.
Changes in Definition FY 93 - FY 94:
RD Starts will not be tracked as a SCAP target in FY 94; however, they will continue
to be planned and reported for internal management purposes.
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Special Planning/Reporting Requirements:
Accomplishments are reported as an actual start date site-specifically (C2101=RD) in
WasteLAN. Funds for RDs are in the site characterization AOA. This is an internal
planning measure.
RD Completion
Definition:
The RD converts the remedy selected in the ROD into a final design package for RA.
Definition of Accomplishment:
A RD is complete when:
Fund-financed Federal (F) or State (S) lead - EPA approves, in writing, the final
design package.
PRP-financed - EPA approves, in writing, the final design package. For state
enforcement-lead (PS) RDs, the RD is complete when the State approves the final
design package.
Changes in Definition FY 93 - FY 94:
RD Completions will not be tracked as a SCAP target in FY 94; however, they will
continue to be planned and reported for internal management purposes.
Special Planning/Reporting Requirements:
Accomplishments are reported as actual completion dates site-specifically in
WasteLAN (C2101=RD). This is an internal planning measure.
Remedial Action Start
Definition:
A RA is the implementation of the remedy selected in the ROD.
Definition of Accomplishment:
Fund-financed (F- or S-lead events) - Credit for a RA start is given on the date a
contract modification for the RA is signed by the EPA CO or the IAG or CA is
awarded, and funds are obligated. The actual start date is entered into WasteLAN
with the RA (C2101=RA).
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OSWER Directive 9200.3-14-2
PRP-financed (RP-, MR- or PS-lead events) - Credit for a RA start is given when one of
the following occurs and has been recorded in WasteLAN:
If work is performed by the PRPs under the same CD or Unilateral
Administrative Order (UAO) as the RD, the RA start is the date EPA approves
the PRP RD package (RD completion);
If the PRP is doing work under a State order or comparable enforcement
document, and the site is covered by a State enforcement cooperative agreement
or State Memorandum of Agreement (SMOA) (PS-lead) with a schedule for long-
term action work at the site, and EPA approved the ROD, the RA start is the date
the State approves the PRP RD package; or
Where the Fund performed the RD or the RD was done under a settlement/order
for RD and the PRPs are doing the RA under the terms of a CD, UAO or
judgment for RA only, the RA start date is the date on which the PRPs provide
written notice of intent to comply with the UAO (C1701=UA and C2801=NC) or
the date the CD is transmitted by the Regional Administrator to HQ or DOJ (as
recorded in WasteLAN as the actual CD start (C1701=CD)). Where the PRP is in
significant non-compliance with the UAO, credit will be withdrawn.
For both Fund- and PRP-financed actions - The Region must enter the technology of the
RA into the Technology Information Type data field (C3401 = RT or PR). If the
Technology Information Type is Remedial Technology (RT), the remedial technology
information qualifier (C3402 - C3411) also must be entered.
Changes in Definition FY 93 - FY 94:
RA Starts will not be tracked as a SCAP target in FY 94; however, they will continue
to be planned and tracked for internal management purposes.
Special Planning/Reporting Requirements:
The Region must enter the remedial technology information type and qualifiers
(C3400 record) associated with the RA into WasteLAN. Funds for Fund-financed
RAs are planned on a site-specific basis and are placed by name in the RA AOA.
Funds for oversight of RP-lead RAs are planned on a site-specific basis and are
found in the site characterization AOA. See Long-Term Action Flow Chart at the
end of this Appendix (Exhibit A-15).
RA Contract Award
Definition:
Award of RA contract is the date a contract for construction of the remedy is
awarded.
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OSWER Directive 9200.3-14-2
Definition of Accomplishment:
Fund-financed (F- or S-lead events) - Date (recorded in WasteLAN as an actual
completion date) when the EPA, a State, USAGE, or BUREC awards a contract to
initiate a Fund-financed RA.
If the ARCS contractor is assigned RA responsibility, the award of RA contract is
defined as the date the RA subcontract is awarded. If the ERCS or ERRS contractor
will be performing the RA, award of RA contract is defined as the date of obligation
of funds to the ERCS or ERRS contractor for the RA.
PRP-financed (RP-, MR- or PS-lead events) - Date (recorded in WasteLAN as an actual
completion date) when the PRP has begun substantial and continuous physical
action, which is equivalent to an EPA contract award, or where the PRP has taken
equivalent action with its own work force. The date of substantial and continuous
physical action must be documented in a memorandum to the file. A copy of the
mobilization report from the contracting party is also acceptable.
Changes in Definition FY 93 - FY 94:
The PRP RA contract award must be documented in a memo to the file or a report
from the PRP's contractor. RA Contract Award will not be tracked as a STARS
target in FY 94; however, it will continue to be planned and reported for internal
management purposes.
Special Planning/Reporting Requirements:
The actual completion date must be placed in WasteLAN with the RA subevent,
Award of RA Contract (C2101=RA and C3101=AC). See Long-Term Action Flow
Chart at the end of this Appendix (Exhibit A-15).
ACT-5 Sites Addressed Through Early or Long-Term
Action On-Site Construction Starts
Definition of Target/Measure:
This measure counts all sites (NPL, non-NPL, or NPL caliber) where either early or
long-term cleanup actions have been initiated to address risks to human health and
the environment.
Definition of Accomplishment:
Long-Term Action (RA On-Site Construction) - A site is addressed by a long-term
action when the EPA, ARCS, USAGE, BUREC, State or PRP, or their contractors,
have mobilized for on-site construction of the long-term action remedy selected in
the ROD.
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OSWER Directive 9200.3-14-2
Fund-financed (F- and S-lead) - The following data must be entered into WasteLAN:
The date of on-site construction as the RA on-site construction subevent
(C2101=RA and C3101=RO) actual completion date; and
A "final" NPL status indicator (C305=F).
PRP-financed (RP-, MR- or PS-lead events) - The work must be in compliance with an
AOC, UAO, CD, or judgment. The date of on-site construction must be documented
in a memorandum to the site file stating when the contractor mobilized on site to
commence substantial and continuous remedial activity. A copy of a report of
mobilization from the contracting party is also acceptable. The date of on-site
construction must be entered into WasteLAN as the RA on-site subevent (C2101=RA
and C3101=RO) actual completion date.
Early Action - A site is addressed by an early action when the EPA, ARCS, ERRS,
ERCS, State, or PRP, or their contractors, have mobilized for construction of the early
action specified in the ROD or Action Memorandum.
Early Action Under Removal Authority - The following data must be entered into
WasteLAN:
- The date of on-site construction as the early action (C2101=RV) actual start
date;
- The early action category code (C2118), classifying the early action as time-
critical (TC), NTC (NT), or emergency (EM); and
- The NPL status indicator (C305) as Proposed (P), NPL caliber (S), Final (F), or
Non-NPL (N).
If a PRP is doing the work, it must be in compliance with an AOC, UAO, CD, or
judgment.
Early Action Under Remedial Authority
Fund-financed (F- and S-lead) - The following data must be entered into WasteLAN:
- The date of obligation of funds for the early action under remedial authority
as the actual RA (C2101=RA) start date. Funds are obligated when the CO
signs the contract modification, the LAG is signed by the other Federal agency,
or a CA is signed by the Regional Administrator or his/her designee;
- The date of early action under remedial authority on-site construction as the
RA on-site construction subevent (C2101=RA and C3101=RO) actual
completion date;
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OSWER Directive 9200.3-14-2
- The early action category code (C2118=EA); and
- The NPL status indicator as Proposed or Final (C305=P or F).
PRP-financed (RP-, MR-, or PS-lead) - The work must be in compliance with an AOC,
UAO, CD, or judgment. The following information must be entered into
WasteLAN:
- The date of early action under remedial authority on-site construction as the
RA on-site construction subevent (C2101=RA and C3101=RO) actual
completion date; and
- The early action category code (C2118=EA).
Changes in Definition FY 93 - FY 94:
This is a new SCAP reporting measure for FY 94 and incorporates the following FY
93 targets/measures:
NPL Removal Start;
Non-NPL Removal Start;
RA On-Site Construction; and
NPL Sites Addressed Through Removal Action or RI/FS.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. Only the first early or long-term action will be
counted in this measure. Regions cannot receive credit if an early action (removal
or ERA) or RA began or was conducted at the site in a previous year. Credit is given
for the first activity started, and a site can only receive credit once. Therefore,
historical data must be reviewed prior to reporting accomplishments. This is a
SCAP/STARS reporting measure. Early and long-term action starts will be tracked
separately for internal management purposes. Accomplishments under this
measure will count toward the SARA RA start mandate.
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OSWER Directive 9200.3-14-2
ACT-6 Early or Long-Term Action Completions
Definition of Target/Measure:
Early actions are responses performed at NPL, non-NPL or NPL caliber sites under
removal or remedial authority that eliminate or reduce threats to public health or the
environment from the release, or potential release, of hazardous substances. These
risk reduction activities can be conducted as emergency responses, time-critical or
NIC removal actions, or as early actions under remedial authority. This measure
tracks each early action completion at a site.
Long-term actions are cleanup responses intended to achieve the completion of more
extensive site remediation such as restoration of surface and ground water
resources. This measure tracks each long-term action completion at a site.
Early and long-term action completions will be tracked separately but
accomplishments will be reported on a combined basis.
Definition of Accomplishment:
Early Action Under Removal Authority
A Fund-financed early action under removal authority is considered complete
when the actions specified in the Action Memorandum are met, the contractor
has demobilized and left the site (as documented in the POLREP and recorded as
the removal (C2101=RV) actual completion date in WasteLAN), and no
additional expenditures are anticipated for that action.
A PRP-financed early action under removal authority is considered complete
when the Region has certified that the PRPs or their contractors have completed
the actions specified in the Action Memorandum and fully met the terms of an
AOC, UAO, CD, or judgment (as documented in the POLREP and recorded as
the removal (C2101=RV) actual completion date in WasteLAN).
Exceptions:
Temporary demobilization and temporary storage on-site are not considered
completions, unless temporary storage is the only action specified in the Action
Memorandum to mitigate threats to public health, welfare, and the environment.
Likewise, temporary off-site storage of hazardous substances at a Treatment,
Storage, and Disposal (TSD) facility other than the facility of ultimate disposal is a
continuation of the action, not a completion, unless temporary off-site storage at a
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OSWER Directive 9200.3-14-2
TSD is the only action specified in the Action Memorandum. In addition, an early
action would not be considered complete if:
The Action Memorandum requires the EPA contractor to monitor the hazardous
substances stored on-site or additional contractor expenditures are anticipated;
or
Hazardous substances are being stored at an off-site facility, other than the
ultimate TSD facility required in the Action Memorandum.
An early action would be considered complete if:
The scope of work for the action does not specify final off-site disposal of
hazardous substances; the substances have been stabilized and are stored on-site
due to circumstances such as the unavailability of a final treatment/disposal
remedy; and no additional CERCLA removal authority funds are anticipated to
be expended on this action. In this instance, no CERCLA removal authority
funds will be expended for long-term site O&M. Any long-term site O&M
(greater than 6 months) should be performed by the PRP or another agency (e.g.,
the State); or
Hazardous substances are being stored off-site at the location of final disposal,
and no additional contractor expenditures are anticipated for this action.
A Long-Term Action or Early Action Under Remedial Authority
These actions are considered complete (Fund- or PRP-financed) when:
Construction activities are complete;
A final inspection has been conducted;
The remedy is O&F; and
The designated Regional or State (PS-lead) official (Branch Chief or above) signs
a letter accepting the RA or Early Action Report certifying that construction is
complete.
Accomplishments are credited based on the date the designated Regional (or State)
official signs a letter accepting the RA or Early Action Report. The date of the
acceptance of the RA or Early Action Report must be entered into WasteLAN with
the RA event (C2101=RA or C2101=RA and C2118=EA). The date must be entered
as an actual completion date (C2141) into WasteLAN.
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OSWER Directive 9200.3-14-2
Changes in Definition FY 93 - FY 94:
This is a new SCAP/STARS reporting measure for FY 94 and incorporates the
following FY 93 Targets/Measures:
Removal Completion; and
RA Completion.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. This is a SCAP/STARS reporting measure.
Early and long-term action completions will be tracked separately but
accomplishments will be reported on a combined basis. See Long-Term Action Flow
Chart at the end of this Appendix (Exhibit A-15).
ACT-7 NPL Site Construction Completions Through
Early or Long-Term Actions
Definition of Target/Measure:
Construction at a NPL site is considered complete when:
Physical construction under removal or remedial authority is complete for the
entire site as a result of one or several early or long-term actions; or
A ROD is signed for the only OU stating that no remediation is required; or
A ROD is signed for the final OU stating that all necessary remediation was
previously completed; or
A ROD is signed for the final OU stating that the only remediation necessary is
the implementation of an institutional control(s).
Sites that receive credit under this measure will have no further response actions,
other than the ongoing "long-term response action" (LTRA) component of the
cleanup actions being performed.
Accomplishments under this measure will count toward the goal of 650 site
construction completions by the end of the year 2000.
Definition of Accomplishment:
Early or Long-Term Construction Under Remedial Authority is complete when:
Construction activities at all OUs are complete;
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OSWER Directive 9200.3-14-2
A pre-final inspection for the final OU has been conducted;
A Preliminary Site Close-Out Report has been prepared. This report documents
the completion of physical construction, summarizes site conditions and
construction activities and, as appropriate, provides the schedule for the joint
final inspection (required before the start of the Operational and Functional
(O&F) phase), approval of the O&M work plan, and establishment of
institutional controls. (Note: A Preliminary Site Close-Out Report is not
required if the Region immediately prepares a Final Superfund Close-Out
Report); and
The designated Regional official signs the Preliminary or Final Site Close-Out
Report. The completion date of the report must be entered into WasteLAN as the
actual completion of the subevent, Preliminary Close-Out Report Prepared
(C2101=RA and C3101=CC or C2101=RA, C2118=EA, and C3101=CC), or Final
Superfund Site Close-Out Report Prepared (C2101=RA and C3101=CL or
C2101=RA, C2118=EA, and C3101=CL).
Accomplishments are credited based on the actual completion date of the
Preliminary Site Close-Out Report Prepared (C2101=RA and C3101=CC or
C2101=RA, C2118=EA, and C3101=CC) or the Final Superfund Site Close-Out
Report Prepared (C2101=RA and C3101=CL or C2101=RA, C2118=EA, and
C3101=CL).
RODs that Document Construction Completion
ROD for the only OU that states that no remediation is required is signed by the
Regional Administrator/Deputy Regional Administrator. The ROD must
include a construction completion certification. This ROD is equivalent to a Final
Superfund Site Close-Out Report and must be coded as such in WasteLAN.
There should be no future early or long-term actions, including LTRA, at the
site. Regions must enter the date of ROD signature as the actual ROD and Close-
Out Report (C2101=RO and C3101=CL) completion date, the Tech Information
Type (C3401 = RT), and the Actions Deemed Unnecessary technical qualifier
(C3402 = AC) into WasteLAN.
ROD that states that all necessary remediation is complete is signed for the final OU
by the Regional Administrator/Deputy Regional Administrator. There should
be no further early or long-term actions conducted at the site after this ROD is
signed. Regions may receive credit under this measure if the LTRA required
by a previous ROD at another OU is ongoing. The ROD must document
compliance with the statutory requirements for site close-out and include a
construction completion certification. This ROD is equivalent to a Final
Superfund Site Close-Out Report and must be coded as such in WasteLAN. If
the ROD does not document compliance with the statutory requirements for site
close-out and have a construction completion certification a Final Superfund Site
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OSWER Directive 9200.3-14-2
Close-Out Report must also be prepared and signed by the Regional
Administrator. Regions must enter the date of ROD signature as the actual
completion date of the ROD and Close-Out Report (C2101=RO and C3101=CL),
the Tech Information Type (C3401 = RT), and the Necessary Actions Complete
technical qualifier (C3402 = NA) into WasteLAN. If a separate Final Superfund
Site Close-Out Report is prepared, the completion date also must be entered into
WasteLAN as the actual completion date of the ROD subevent, Final Close-Out
Report (C2101=RO and C3101=CL).
ROD that states the only necessary remediation is the implementation of an institutional
control(s) is signed for the final OU by the Regional Administrator/Deputy
Regional Administrator. There should be no further early or long-term actions
conducted at the site after this ROD is signed. Regions may receive credit
under this measure if the LTRA required by a previous ROD at another OU is
ongoing. The ROD must document compliance with the statutory requirements
for site close-out and include a construction completion certification. This ROD
is equivalent to a Final Superfund Site Close-Out Report and must be coded as
such in WasteLAN. If the ROD does not document compliance with the
statutory requirements for site close-out and include a construction completion
certification a Final Superfund Site Close-Out Report must also be prepared and
signed by the Regional Administrator. Regions must enter the date of ROD
signature as the actual completion date of the ROD and Close-Out Report
(C2101=RO and C3101=CL), the Tech Information Type (C3401 = RT), and the
Institutional Controls Implemented technical qualifier (C3402 = 1C) into
WasteLAN. If a separate Final Superfund Site Close-Out Report is prepared, the
completion date also must be entered into WasteLAN as the actual completion
date of the ROD subevent, Final Close-Out Report (C2101=RO and C3101=CL).
For State-lead, State signed RODs, where the ROD is also signed by EPA,
accomplishments are reported as the date EPA signs the ROD. As with EPA
RODs, the State ROD must document compliance with the statutory
requirements for site close-out and include a construction completion
certification. This ROD is equivalent to a Final Superfund Site Close-Out Report
and must be coded as such in WasteLAN. If the ROD does not document
compliance with the statutory requirements for site close-out and include a
construction completion certification, a Final Superfund Site Close-Out Report
must also be prepared and signed by the Regional Administrator. Regions must
enter the date EPA signs the ROD as the actual ROD and close-out report
signature date (C2101=RO and C3101=CL), the Tech Information Type
(C3401=RT) and the appropriate technical qualifier (C3402=NA, AC, or 1C). If a
separate Final Superfund Site Close-Out Report is prepared, the completion date
also must be entered into WasteLAN as the actual completion date of the ROD
subevent, Final Close-Out Report (C2101=RO and C3101=CL).
Accomplishments are credited based on the date the Regional
Administrator/Deputy Regional Administrator signs the ROD or Final Superfund
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Site Close-Out Report. These dates must be reported in WasteLAN (C2101=RO
and C3101=CL).
Time-Critical and NTC Early Action Construction Under Removal Authority at
NPL sites is complete when:
Fund-financed:
- The contractor has demobilized and left the site as documented in a POLREP;
- The removal (C2101=RV) completion date has been entered into WasteLAN
as the actual completion date;
- The early action event qualifier that indicates that the site is cleaned up
(C2103=C) is entered into WasteLAN; and
- A Final Superfund Site Close-Out Report has been prepared and signed by
the Regional Administrator/Deputy Regional Administrator OR a ROD that
states that all necessary remediation is complete, documents compliance with
the statutory requirements for site close-out, and includes a construction
completion certification is signed by the Regional Administrator/Deputy
Regional Administrator. This ROD is equivalent to a Final Superfund Close-
Out Report and must be recorded as such in WasteLAN. There should be no
further early or long-term actions conducted at the site after this ROD or
Close-Out Report is signed. Regions may receive credit under this measure
if the LTRA required at another OU is ongoing. The signature date of the
ROD (C2101=RO and CL) that states that all remediation is complete must be
entered into WasteLAN as the actual ROD and close-out report completion
date. The Tech Information Type (C3401=RT) and the Necessary Actions
Complete technical qualifier (C3402=NA) also must be entered into
WasteLAN. If a separate Final Superfund Site Close-Out Report is prepared,
the completion date must be reported in WasteLAN as the actual completion
date of the removal subevent, Final Close-Out Report (C2101=RV and
C3101=CL).
PRP-financed:
- The Region certifies that the PRPs or their contractor have completed the
early action specified in the Action Memorandum and fully met the terms of
the AO, CD, or judgment, as documented in the POLREP;
- The removal (C2101=RV) completion date has been entered into WasteLAN
as the actual completion date;
- The early action event qualifier that indicates that the site is cleaned up
(C2103=C) is entered into WasteLAN; and
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- A Final Superfund Site Close-Out Report has been prepared and signed by
the Regional Administrator OR a ROD that states that all necessary
remediation is complete, documents compliance with the statutory
requirements for site close out, and includes a construction completion
certification is signed by the Regional Administrator/Deputy Regional
Administrator. This ROD is equivalent to a Final Superfund Site Close-Out
Report and must be coded as such in WasteLAN. There should be no further
early or long-term actions conducted at the site after this ROD or Close-Out
Report is signed. Regions may receive credit under this measure if the
LTRA required at another OU is ongoing. The signature date of the ROD
that states that all remediation is complete must be entered into WasteLAN as
the actual ROD and close-out report (C2101=RO and C3101=CL) completion
date. The Tech Information Type (C3401=RT) and the Necessary Actions
Complete technical qualifier (C3402=NA) also must be entered into
WasteLAN. If a separate Final Superfund Site Close-Out Report is prepared,
the completion date must be reported in WasteLAN as the actual completion
date of the removal subevent, Final Close-Out Report (C2101=RV and
C3101=CL).
Accomplishments are credited based on the date Regional Administrator/Deputy
Regional Administrator signs the ROD or Final Superfund Close-Out Report.
These dates must be reported in WasteLAN (C2101=RO and C3101=CL).
Changes in Definition FY 93 - FY 94:
This is a new STARS/SCAP target for FY 94 and incorporates the following FY 93
Targets/Measures:
Final RA NPL Site Construction Completion;
NPL Site Construction Completion; and
NPL Site Completions Through Removals.
For early actions, a Final Superfund Site Close-Out Report or ROD that states that all
necessary remediation is complete is required. Institutional RODs have been added
and the necessary ROD qualifiers have been revised.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. This is a STARS/SCAP target.
Accomplishments under this measure will count toward the goal of 650 NPL
Construction Completions by the end of the year 2000. See Long-Term Action Flow
Chart at the end of this Appendix (Exhibit A-15).
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ACT-8 Non-NPL and NPL Caliber Site Construction
Completions Through Early or Long-Term Actions
Definition of Target/Measure:
Construction at NPL caliber sites is considered complete for RP-lead sites when:
Physical construction under remedial or removal authority is complete at a site
as a result of one or several early or long-term actions; or
A ROD is signed at the only OU at a site stating that no remediation is required;
or
A ROD is signed at the final OU at a site stating that all necessary remediation is
complete; or
A ROD is signed at the final OU stating that the only necessary remediation is
the implementation of an institutional control(s).
Construction at NPL caliber sites is considered complete for Fund-lead sites when:
Physical construction under removal authority is complete at a site as a result of
one or several early actions;
A ROD is signed at the only OU at a site stating that no remediation is required;
A ROD is signed at the final OU at a site stating that all necessary remediation is
complete; or
A ROD is signed at the final OU stating that the only necessary remediation is
the implementation of an institutional control(s).
Construction at non-NPL sites is considered complete (PRP- or Fund-lead) when:
Physical construction/cleanup of a hazardous substance release under removal
authority is complete at the site as a result of one or several early actions.
Sites that receive credit under this measure will have achieved final cleanup goals
or have no further response actions, other than the ongoing LTRA component of
the cleanup actions being performed.
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Definition of Accomplishment:
Construction at NPL caliber sites is complete for RP-lead sites when:
Time Critical and Non-Time Critical Removal Actions
- Construction activities under removal authority are complete at all OUs;
- The contractor has demobilized and left the site, as documented in a final
POLREP;
- The removal (C2101=RV) completion date has been entered into WasteLAN
as the actual completion date; and
- The early action event qualifier that indicates that the site has been cleaned up
(C2103=C) is entered into WasteLAN.
Accomplishments are credited based on the actual removal (C2101=RV)
completion date with the "cleaned up" event qualifier (C2103=C).
Early or Long-Term Action Under Remedial Authority:
- Construction activities under remedial authority are complete at all OUs;
- A pre-final inspection of the site has been conducted;
- A Preliminary Site Close-Out Report has been prepared. This report
documents the completion of physical construction, summarizes site
conditions and construction activities and, as appropriate, provides the
schedule for the joint final inspection (required before the start of the
Operational and Functional (O&F) phase), approval of the O&M work plan,
and establishment of institutional controls. (Note: A Preliminary Site Close-
Out Report is not required if the Region immediately prepares a Final
Superfund Site Close-Out Report); and
- The designated Regional official signs the Preliminary or Final Site Close-Out
Report. The completion date of the report must be entered into WasteLAN as
the actual completion of the subevent, Preliminary Close-Out Report
Prepared (C2101=RA and C3101=CC or C2101=RA, C2118=EA, and
C3101=CC) or Final Superfund Site Close-Out Report Prepared (C2101=RA
and C3101=CL or C2101=RA, C2118=EA, and C3101=CL).
Accomplishments are credited based on the actual completion date of the RA
subevent, Preliminary Close-Out Report Prepared (C2101=RA and C3101=CC or
C2101=RA, C2118=EA, and C3101=CC) or Final Superfund Site Close-Out Report
Prepared (C2101=RA and C3101=CL or C2101=RA, C2118=EA, and C3101=CL).
A-49 April 1994
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OSWER Directive 9200.3-14-2
RODs that Document Construction Completion:
- ROD for the only OU that states that no remediation is required is signed by the
Regional Administrator/Deputy Regional Administrator. The ROD must
include a construction completion certification. There should be no future
early or long-term actions at the site. Regions must enter the date of ROD
(C2101=RO) signature as the actual completion date, the Tech Information
Type (C3401 = RT), and the Actions Deemed Unnecessary technical qualifier
(C3402 = AC) into WasteLAN.
- ROD that states that all necessary remediation is complete is signed for the final
OU by the Regional Administrator/Deputy Regional Administrator. The
ROD must document compliance with the statutory requirements for site
close-out and include a construction completion certification. There should
be no further early or long-term actions conducted at the site after this ROD
is signed. Regions may receive credit under this measure if the LTRA
required by a previous ROD or Action Memorandum is ongoing. Regions
must enter the date of ROD (C2101=RO) signature as the actual completion
date, the Tech Information Type (C3401 = RT), and the Necessary Actions
Complete technical qualifier (C3402 = NA) into WasteLAN.
- ROD that states the only necessary remediation is the implementation of an
institutional control(s) is signed for the final OU by the Regional
Administrator/Deputy Regional Administrator. The ROD must document
compliance with the statutory requirements for site close-out and include a
construction completion certification. There should be no further early or
long-term actions conducted at the site after this ROD is signed. Regions
may receive credit under this measure if the LTRA required by a previous
ROD or Action Memorandum is ongoing. Regions must enter the date of
ROD (C2101=RO) signature as the actual completion date, the Tech
Information Type (C3401 = RT), and the Institutional Controls Implemented
technical qualifier (C3402 = 1C) into WasteLAN.
- For State-lead, State signed RODs, where the ROD is also signed by EPA,
accomplishments are reported as the date EPA signs the ROD. The ROD
should include a construction completion certification and document
compliance with the statutory requirements for site close-out.
Accomplishments are credited based on the actual ROD (C2101=RO) signature
date.
Construction at NPL caliber sites is complete for Fund-lead sites when:
Time Critical and Non-Time Critical Removal Actions
- Construction activities under removal authority are complete at all OUs;
April 1994 A-50
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OSWER Directive 9200.3-14-2
- The contractor has demobilized and left the site, as documented in a final
POLREP;
- The removal (C2101=RV) completion date has been entered into Waste LAN
as the actual completion date; and
- The early action event qualifier that indicates that the site has been cleaned up
(C2103=C) is entered into WasteLAN.
Accomplishments are credited based on the actual removal (C2101=RV)
completion date with the "cleaned up" event qualifier (C2103=C).
RODs that Document Construction Completion:
- ROD for the only OU that states that no remediation is required is signed by the
Regional Administrator/Deputy Regional Administrator. There should be
no future early or long-term actions at the site. Regions must enter the date
of ROD (C2101=RO) signature as the actual completion date, the Tech
Information Type (C3401 = RT), and the Actions Deemed Unnecessary
technical qualifier (C3402 = AC) into WasteLAN.
- ROD that states that all necessary remediation is complete is signed for the final
OU by the Regional Administrator/Deputy Regional Administrator or the
AA SWER. There should be no further early or long-term actions
conducted at the site after this ROD is signed. Regions may receive credit
under this measure if the LTRA required by a previous ROD or Action
Memorandum is ongoing. Regions must enter the date of ROD (C2101=RO)
signature as the actual completion date, the Tech Information Type (C3401 =
RT), and the Necessary Actions Complete technical qualifier (C3402 = NA)
into WasteLAN.
- ROD that states the only necessary remediation is the implementation of an
institutional control(s) is signed for the final OU by trie Regional
Administrator/Deputy Regional Administrator. There should be no further
early or long-term actions conducted at the site after this ROD is signed.
Regions may receive credit under this measure if the LTRA required by a
previous ROD or Action Memorandum is ongoing. Regions must enter the
date of ROD (C2101=RO) signature as the actual completion date, the Tech
Information Type (C3401 = RT), and the Institutional Controls Implemented
technical qualifier (C3402 = 1C) into WasteLAN.
- For State-lead, State signed RODs, where the ROD is also signed by EPA,
accomplishments are reported as the date EPA signs the ROD. The ROD
should include a construction completion certification and document
compliance with the statutory requirements for site close-out.
A-51 April 1994
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OSWER Directive 9200.3-14-2
Accomplishments are credited based on the actual ROD (C2101=RO) signature
date.
Construction at non-NPL sites is complete when:
Construction activities specified in the Action Memorandum (removal authority)
are complete;
The contractor has demobilized and left the site, as documented in a final
POLREP;
The removal (C2101=RV) completion date has been entered into WasteLAN as
the actual completion date; and
The early action event qualifier that indicates that the site has been cleaned up
(C2103=C) is entered into WasteLAN.
Accomplishments are credited based on the actual removal (C2101=RV)
completion date with the "cleaned up" event qualifier (C2103=C).
Changes in Definition FY 93 - FY 94:
This is a new SCAP/STARS reporting measure for FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. This is a SCAP reporting measure.
Operational and Functional (O&F)
Definition:
O&F means the activities required to determine that the remedy is functioning
properly and is performing as designed. O&F activities are part of RA when a Fund-
financed RA is conducted. Physical construction may be complete before the start of
O&F. EPA funds O&F activities for a period up to one year after the final inspection,
or until EPA and the State jointly determine that the remedy is functioning properly
and is performing as designed, whichever is earliest. EPA may extend the one-year
period, as appropriate.
Definition of Accomplishment:
The completion of O&F is the date on which the lead and support agencies (F- or S-
lead RA) or the EPA and/or State official and PRPs (RP-, MR-, or PS-lead RA) agree
through an inspection that the remedy is operating in accordance with the standards
contained in the ROD and RD. This documentation is presented in the RA Report.
Normally, O&F completion will occur within one year following completion of
April 1994 A-52
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OSWER Directive 9200.3-14-2
construction. The actual completion date is reported with the RA subevent, O&F
(C2101=RA and C3101=OF).
Changes in Definition FY 93 - FY 94:
Added PRP information.
Special Planning/Reporting Requirements:
Since it is a subevent, O&F only has a completion date. See Long-Term Action Flow
Chart at the end of this Appendix (Exhibit A-15).
Long Term Response Action (LTRA)
Definition:
LTRAs are response actions undertaken for the purpose of restoring ground or
surface water quality. These actions require a continuous period of on-site activity
before cleanup levels, specified in the ROD or Action Memorandum, are achieved.
For Fund-financed RAs involving treatment or other measures to restore
contaminated ground or surface water quality, the operation of such treatment or
measures for a period up to 10 years after the construction or installation and
commencement of operation will be considered part of RA.
Activities required to maintain the effectiveness of such treatment or measures
following the 10-year period, or after RA is complete, whichever is earlier, shall be
considered O&M. Ground or surface water measures initiated for the primary
purpose of providing drinking water, not for the purpose of restoring ground or
surface water shall not be considered treatment.
Definition of Accomplishment:
LTRA begins when EPA and the State (Fund-financed LTRA) or EPA and/or the
State and the PRPs (RP-, MR-, or PS-lead) determine that the RA is O&F. (See
definition of O&F.) Typically, this is when the letter accepting the RA Report is
signed by the designated Regional official. The completion date is the point at
which the levels specified in the ROD or Action Memorandum have been achieved
and all necessary Superfund response required to protect human health or the
environment has been completed, or ten years after the remedy becomes O&F,
whichever is earliest.
Changes in Definition FY 93 - FY 94:
Added RP-lead definition.
Special Planning/Reporting Requirements:
LTRA is planned on a site-specific basis (C2101=LR) in WasteLAN and is used for
resource allocation purposes only. Funds for LTRA are issued site-specifically in the
A-53 April 1994
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OSWER Directive 9200.3-14-2
RA AOA. Funds for oversight of RP-lead LTRA are contained in the site
characterization AOA. See Long-Term Action Flow Chart at the end of Appendix
(Exhibit A-15).
NPL and Non-NPL Site Completions
Definition of Target/Measure:
A NPL or non-NPL site is completed when:
Cleanup goals are reached as a result of one or several early or long-term actions;
A ROD is signed for the only OU at a site stating that no remediation is required;
A ROD is signed for the final OU at a site stating that all necessary remediation is
complete;
A ROD is signed for the final OU stating that the only necessary remediation is
the implementation of an institutional control(s); or
Site Evaluation Accomplished (SEA) is determined as a result of site screening
and assessment activities.
Sites that receive credit under this measure will have achieved final cleanup goals
or have no further response actions, including LTRA.
Definition of Accomplishment:
A final long-term action RA or early action under remedial authority is complete
when:
Construction activities at all OUs are complete;
LTRA at all OUs is complete;
A pre-final inspection of the site has been conducted;
A Preliminary Site Close-Out Report has been prepared and signed by the
designated Regional official. This report documents the completion of physical
construction; summarizes site conditions and construction activities; and, as
appropriate, provides the schedule for the joint final inspection (required before
the start of the O&F phase), approval of the O&M work plan, and establishment
of institutional controls. The date of the Preliminary Close-Out Report must be
reported in WasteLAN as the actual completion date of the RA subevent,
Preliminary Close-Out Report Prepared (C2101=RA and C3101=CC or
C2101=RA, C2118=EA, and C3101=CC). (Note: A Preliminary Close-Out Report
April 1994 A-54
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OSWER Directive 9200.3-14-2
is unnecessary if the Region immediately prepares a Final Superfund Site Close-
Out Report);
A final inspection has been conducted (C2101=RA and C3101=PQ or C2101=RA/
C2118=EA/ and C3101=PQ);
The remedy is O&F (C2101=RA and C3101=OF or C2101=RA, C2118=EA, and
C3101=OF);
A letter accepting the RA or Early Action Report has been signed by the
designated Regional official (Branch Chief or above). The date of the letter is
entered into WasteLAN as the actual RA (C2101=RA) or early action under
remedial authority (C2101=RA and C2118=EA) completion date; and
A Final Superfund Site Close-Out Report has been prepared and the actual
completion date reported in WasteLAN with the RA subevent, final Close-Out
Report (C2101=RA and C3101=CL or C2101=RA, C2118=EA, and C3101=CL).
Accomplishments are credited based on the date the Regional Administrator signs
the Final Superfund Site Close-Out Report. The date of acceptance must be
entered into WasteLAN as the actual completion of the Final Superfund Site
Close-Out Report subevent (C2101=RA and C3101=CL or C2101=RA, C2118=EA,
and C3101=CL).
RODs that Document Completion
ROD for the only OU that states that no remediation is required is signed by the
Regional Administrator/Deputy Regional Administrator. The ROD must
include a construction completion certification. There should be no future early
or long-term actions at the site. Regions must enter the date of ROD
(C2101=RO) signature as the actual completion date, the Tech Information Type
(C3401 = RT), and the Actions Deemed Unnecessary technical qualifier (C3402 =
AC) into WasteLAN.
ROD that states that all necessary remediation is complete is signed for the final OU
by the Regional Administrator/Deputy Regional Administrator. The ROD must
document compliance with the statutory requirements for site close-out and
include a construction completion certification OR a Final Superfund Site Close-
Out Report must be prepared and signed by the Regional Administrator. There
should be no further early or long-term actions, including LTRA, conducted at
the site after this ROD is signed. If LTRA is ongoing at another OU, the
signature of the ROD will not be credited as an accomplishment. Regions
must enter the date of ROD (C2101=RO) signature as the actual completion date,
the Tech Information Type (C3401 = RT), and the Necessary Actions Complete
technical qualifier (C3402 = NA) into WasteLAN. If a separate Final Superfund
Site Close-Out Report is prepared, the completion date also must be entered into
A-55 April 1994
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OSWER Directive 9200.3-14-2
WasteLAN as the actual completion date of the ROD subevent, Final Close-Out
Report (C2101=RO and C3101=CL).
ROD that states the only necessary remediation is the implementation of an institutional
control(s) is signed for the final OU by the Regional Administrator/Deputy
Regional Administrator. The ROD must document compliance with the
statutory requirements for site close-out and include a construction completion
certification OR a Final Superfund Site Close-Out Report must be prepared and
signed by the Regional Administrator. There should be no further early or
long-term actions, including LTRA, conducted at the site after this ROD is
signed. If LTRA is ongoing at another OU, the signature of the ROD will not
be credited as an accomplishment. Regions must enter the date of ROD
(C2101=RO) signature as the actual completion date, the Tech Information Type
(C3401 = RT), and the Institutional Controls Implemented technical qualifier
(C3402 = 1C) into WasteLAN. If a separate Final Superfund Site Close-Out
Report is prepared, the completion date also must be entered into WasteLAN as
the actual completion date of the ROD subevent, Final Close-Out Report
(C2101=RO and C3101=CL).
For State-lead, State signed RODs, where the ROD is also signed by EPA,
accomplishments are reported as the date EPA signs the ROD. With EPA RODs,
the State ROD must document compliance with the statutory requirements for
site close-out and include a construction completion certification, OR a Final
Superfund Site Close-Out Report must be prepared and signed by the Regional
Administrator.
Accomplishments are credited based on the actual ROD (C2101=RO) signature
date or the date the Regional Administrator signs the Final Superfund Site Close-
Out Report (C2101=RO and C3101=CL), if a separate document is prepared.
Time-Critical or NTC Early Actions Under Removal Authority are complete when:
Fund-financed:
- The contractor has demobilized and left the site, as documented in a POLREP;
- The removal (C2101=RV) completion date has been entered into WasteLAN
as the actual completion date; and
- The early action event qualifier that indicates that the site has been cleaned up
(C2103=C) is entered into WasteLAN; and
- LTRA has been completed at all OUs.
- If the site is a NPL site, a Final Superfund Site Close-Out Report must be
prepared and signed by the Regional Administrator/Deputy Regional
April 1994 A-56
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OSWER Directive 9200.3-14-2
Administrator OR a ROD that states that all necessary remediation is
complete, documents compliance with the statutory requirements for site
close-out, and includes a construction completion certification is signed by
the Regional Administrator/Deputy Regional Administrator. There should
be no further early or long-term actions conducted at the site after this ROD
or Close-Out Report is signed. If LTRA is ongoing at another OU, the
signature of the ROD or Close-Out Report will not be credited as an
accomplishment The signature date of the ROD (C2101=RO) must be entered
into WasteLAN as the actual completion date. The Tech Information Type
(C3401=RT) and the Technical Information Qualifier (C3402=NA) also must
be entered. If a separate Final Superfund Close-Out Report is prepared, the
signature date should be entered as the actual completion date of the removal
subevent, Final Close-Out Report (C2101=RV and C3101=CL).
PRP-financed:
- The Region certifies that the PRPs or their contractor have completed the
early action specified in the Action Memorandum and fully met the terms of
the AO, CD, or judgment, as documented in the POLREP;
- The removal (C2101=RV) completion date has been entered into WasteLAN
as the actual completion date; and
- The early action event qualifier that indicates that the site has been cleaned up
(C2103=C) is entered into WasteLAN; and
- LTRA has been completed at all OUs.
- If the site is a NPL site, a Final Superfund Site Close-Out Report must be
prepared and signed by the Regional Administrator/Deputy Regional
Administrator OR a ROD that states that all necessary remediation is
complete or that the only remediation necessary is the implementation of an
institutional control(s), documents compliance with the statutory
requirements for site close out, and includes a construction completion
certification is signed by the Regional Administrator/Deputy Regional
Administrator. There should be no further early or long-term actions
conducted at the site after this ROD or Close-Out Report is signed. If
LTRA is ongoing at another OU, the signature of the ROD or Close-Out
Report will not be credited as an accomplishment The following
information must be entered into WasteLAN: ROD signature date as the
actual ROD (C2101=RO) completion date, the Tech Information Type
(C3401=RT), and the Technical Information Qualifier (C3402=NA). If a
separate Final Superfund Close-Out Report is prepared, the signature date
should be entered as the actual completion date of the removal subevent,
Final Close-Out Report (C2101=RV and C3101=CL).
A-57 April 1994
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OSWER Directive 9200.3-14-2
Accomplishments are credited based on the actual removal completion date
(C2101=RV) with the "cleaned up" event qualifier (C2103=C) or, if the site is an
NFL site, the actual ROD (C2101=RO) date or the date of the Final Close-Out
Report (C2101=RV and C3101=CL).
Site Evaluation Accomplished (SEA) determination is made when the site
assessment report (e.g., PA, SI, etc.) is reviewed and approved, in writing, by the
appropriate Regional official. The date of the SEA determination must be entered as
the actual completion date of the appropriate site screening and assessment event
when the decision is made. In addition, the event qualifier for "no further
remediation planned" (C2103=N) must be entered into WasteLAN.
Accomplishments are credited based on the actual completion date of the site
screening and assessment event (C2101=PA, SI, ES, or SS) with a "no further
remediation planned" event qualifier (C2103=N).
Changes in Definition FY 93 - FY 94:
This is a new internal management planning/reporting measure for FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. See Long-Term Action Flow Chart at the end of
this Appendix (Exhibit A-15).
Ground Water Monitoring
Definition:
Ground water monitoring is defined as the collection and analysis of ground water
samples as a result of a ROD that addresses ground water contamination at a site.
The ROD will specify that 1) ground water monitoring is the only action that will be
taken at the site, or 2) ground water monitoring is the only action that will be
implemented during a ground water cleanup.
Definition of Accomplishment:
Ground water monitoring start is the date of obligation of funds for the ground
water monitoring. The date of the start should be entered into WasteLAN with the
Ground Water Monitoring event (C2101=GM).
Ground water monitoring completion is defined as the date of a memorandum that
determines that ground water monitoring is no longer necessary. This
memorandum should be included in the Final Superfund Close-Out Report or five-
year review. If this memorandum is not included in these documents, credit will be
given on the date the memorandum is approved by EPA management. The date of
the completion should be entered into WasteLAN with the Ground Water
Monitoring event (C2101=GM).
April 1994 A-58
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OSWER Directive 9200.3-14-2
Changes in Definition FY 93 - FY 94:
This is a new definition for FY 94.
Special Planning/Reporting Requirements:
See Definition of Accomplishment.
Operation and Maintenance (O&M)
Definition:
O&M means the activities required to maintain the effectiveness or the integrity of
the remedy, and, in the case of Fund-financed measures to restore ground or surface
waters, continued operation of such measures beyond a period of ten years or when
the remediation levels are achieved, whichever is earlier. Except for ground or
surface water actions covered under Section 300.435(f)(3) of the NCP, O&M
measures are initiated after the remedy has achieved the RA or early action under
remedial authority objectives and remediation goals in the ROD or CD, and is
determined to be O&F. The State or PRP is totally responsible for these activities for
the time period specified in the ROD or other appropriate documents.
Definition of Accomplishment:
The start of O&M is defined as the date upon which the designated Regional official
signs a letter accepting the RA or Early Action Report. This report documents that
work has been performed within desired specifications and that the remedy is O&F.
The completion (where appropriate) of O&M is defined as the date specified in a
CA, SSC, or CD.
Changes in Definition FY 93 - FY 94:
Added early actions under remedial authority.
Special Planning/Reporting Requirements:
O&M is planned site specifically (C2101=OM) in WasteLAN and is used for resource
allocation purposes only. Funds for oversight of O&M are contained in the site
characterization AOA. See Long-Term Action Flow Chart at the end of this
Appendix (Exhibit A-15).
A-59 April 1994
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OSWER Directive 9200.3-14-2
ACT-9 Five-Year Reviews Started
Definition of Target/Measure:
Five-year reviews are intended to evaluate whether the response action
implemented at a NPL site remains protective of public health and the environment.
EPA will conduct five-year reviews of any site at which a remedy, upon attainment
of the ROD or Action Memorandum cleanup levels, will not allow unlimited use and
unrestricted exposure.
Definition of Accomplishment:
Credit is given for a five-year review start when:
Fund-financed (F- or S- lead) - Funds are obligated for the five-year review;
PRP-financed (RP-, MR-, or PS- lead) - The PRP or the PRP's contractor mobilizes
to begin the five-year review, as documented by a memo to the file; or
EP-lead - EPA begins the five-year review by a site visit as documented by the
trip report for the site visit.
The five-year review should start within five years of the RA or early action under
remedial authority start (as defined in this Manual). The five-year review must be
complete within five years of the start of on-site construction.
Changes in Definition FY 93 - FY 94:
Five-Year Reviews Started is a SCAP measure in FY 94. Revised the RP-lead five-
year review and added EP lead.
Special Planning/Reporting Requirements:
Five-year review starts must be planned and reported site-specifically (C2101=FA) in
WasteLAN. Funds are allocated in the RA AOA. Funds for oversight of RP five-
year reviews are in the site characterization AOA. See Long-Term Action Flow
Chart at the end of this Appendix (Exhibit A-15).
Five-Year Review Completions
Definition:
Five year reviews are intended to evaluate whether the response action
implemented at a NPL site remains protective of human health and the
environment.
April 1994 A-60
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OSWER Directive 9200.3-14-2
Definition of Accomplishment:
The five-year review is complete when:
PRP-Financed (RP-, MR-, or PS-lead) - EPA or the State approves, in writing, the
five-year review report; or
Fund-Financed (F- or S-lead) - EPA reviews and approves, in writing, the five-year
review report; or
EP-lead - EPA completes the five-year review report and places it in the site file.
Changes in Definition FY 93 - FY 94:
New definition in FY 94.
Special Planning/Reporting Requirements:
Five-year review completions are planned and reported site-specifically (C2101=FA)
in WasteLAN.
NPL Deletion Initiation
Definition:
The NPL deletion process is initiated when no further response is appropriate.
Definition of Accomplishment:
The deletion process starts when a notice of intent to delete the site is published in
the Federal Register. The deletion process is completed when the notice of deletion is
published in the Federal Register.
Changes in Definition FY 93 - FY 94:
NPL Deletion Initiation is no longer a SCAP reporting measure; however, it will
continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
The actual start and actual completion date are to be reported in WasteLAN with the
"ND" event (C2101=ND). This is an internal reporting measure. See Long-Term
Action Flow Chart at the end of this Appendix (Exhibit A-15).
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OSWER Directive 9200.3-14-2
El -1 Progress Through Environmental Indicators
Definition of Target/Measure:
This measure results from the Environmental Indicators program. It documents the
number of sites where the following types of results have been achieved:
Progress toward final cleanup goals; and
Reduction of acute threats.
Either of these results may be achieved through implementing early and/or long-
term action projects. Results are reported for each medium affected at a site. These
media include contaminated land, surface water, and ground water.
Progress toward final cleanup goals is reported as three levels of progress at NPL
sites:
Full achievement of site goals for a medium;
Partial achievement of goals for a medium; and
Cleanup underway.
Reduction of acute threats measures how often threats to human health have been
eliminated at NPL, NPL caliber, and non-NPL sites by preventing exposure to
contaminated materials. Progress recorded by this indicator should reveal success in
closing off exposure pathways.
Definition of Accomplishment:
Same as definition.
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
This is a STARS reporting measure. Accomplishment data will be reported through
the El module in WasteLAN. The results will be reflected in the comment field of
the STARS data base.
April 1994 A-62
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O\
OJ
EXHIBIT A-6
EARLY AND LONG-TERM ACTION PLANNING REQUIREMENTS
ACT-4
Percent of Sites
With Early
Actions
ACT-3
Duration from
Cleanup
Decision to Each
Cleanup Action
Completion
ACT-2
Duration from
Cleanup
Decision to RE
Completion
ACT-1
Duration from
Site Discovery
to Site
Construction
Completion
Planning Requirements
Internal Management?
Planned Site
Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Operable
Unit
Operable
Unit
Reported Site Specifically or in
Non-Site Portion of WasteLAN?
Site
Specific
Site
Specific
Site
Specific
Site
Specific
AOA Category, if
Fund-Financed?
AOA Category for
Oversight?
Basis for AOA?
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a
quarterly basis. Internal measures are planned and reported semi-annually.
w
n
ft
p
lo
-------
>
EXHIBIT A-6 (continued)
EARLY AND LONG-TERM ACTION PLANNING REQUIREMENTS
RD
Completions
RA Contract
Award
Planning Requirements
Internal Management?
Planned Site
Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Operable
Unit
Operable
Unit
Operable
Unit
Operable
Unit
Site
Specific
Site
Specific
Site
Specific
Site
Specific
Reported Site Specifically or in
Non-Site Portion of WasteLAN?
Remedial
Action
Site
Characterization
AOA Category, if
Fund-Financed?
AOA Category for
Oversight?
Site
Characterization
Site
Characterization
Site Specific
Site
Specific Plans
Basis for AOA?
O
en
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n
N>
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a quarterly basis.
Internal measures are planned and reported semi-annually.
-------
EXHIBIT A-6 (continued)
EARLY AND LONG-TERM ACTION PLANNING REQUIREMENTS
o\
Ol
Planning Requirements
STARS?
SCAP?
Internal Management?
Planned Site
Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Reported Site Specifically or in
Non-Site Portion of WasteLAN?
AOA Category, if
Fund-Financed?
AOA Category for
Oversight?
Basis for AOA?
ACT-5 Sites
Addressed
Through Early
or Long-Term
Actions
Measure
Measure
-
No
Whole
Site
Site
Specific
Removal or
Remedial Action
Enforcement or Site
Characterization
Site or Non-site
Specific Plans
ACT-6 Early
or Long-Term
Action
Completions
Measure
Measure
-
Yes
Operable
Unit
Site
Specific
N/A
N/A
N/A
ACT-7 NPL Site
Construction
Completions
Through Early or
Long-Term Actions
Target
Target
-
Yes
Whole
Site
Site
Specific
N/A
N/A
N/A
ACT-8 Non-NPL anc
NPL Caliber Site
Construction
Completions
Through Early or
Long-Term Actions
-
Measure
-
Yes
Whole
Site
Site
Specific
N/A
N/A
N/A
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a quarterly basis.
Internal measures are planned and reported semi-annually.
w
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-------
>
I-J
>
ON
EXHIBIT A-6 (continued)
EARLY AND LONG-TERM ACTION PLANNING REQUIREMENTS
o
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o
p
lo
K)
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a quarterly basis.
Internal measures are planned and reported semi-annually.
-------
ON
XI
>
1-4
EXHIBIT A-6 (continued)
EARLY AND LONG-TERM ACTION PLANNING REQUIREMENTS
EI-1 Progress
Through
Environmenal
Indicators
ACT-9
Five-Year
Reviews
Started
NPL Deletion
Initiation
Five-Year
Review
Completion
Operation
and
Maintenance
(O&M)
Planning Requirements
Internal Management?
Planned Site
Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Whole
Site
Whole
Site
Operable
Unit
Whole
Site
Site
Specific
Site
Specific
Site
Specific
Site
Specific
Reported Site Specifically or in
Non-Site Portion of WasteLAN?
Site
Specific
Remedial
Action
AOA Category, if
Fund-Financed?
AOA Category for
Oversight?
Site
Characterization
Site
Characterizatior
Basis for AOA?
Site Specific
Plans
Site Specific
Plans
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a quarterly basis.
Internal measures are planned and reported semi-annually.
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K)
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OSWER Directive 9200.3-14-2
This Page Intentionally
Left Blank
April 1994 A-68
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OSWER Directive 9200.3-14-2
PROGRAM SUPPORT ACTIVITIES
DEFINITIONS
A-69 April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-7
PROGRAM SUPPORT ACTIVITIES
Community Relations
Support Agency
Assistance
Technical Assistance
Technical Assistance
Grants
Treatabihty Studies
Reporting
Projects Nominated for
SITE Program
Design Assistance
Reporting
Semi-annual targets are established in SCAP/STARS. Accomplishments are
pulled from CERCLIS on a quarterly basis. Internal measures are planned
and reported quarterly.
April 1994
A-70
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OSWER Directive 9200.3-14-2
Community Relations
Definition:
Community Relations (CR) are the activities conducted in accordance with SARA,
the NCP, and the Community Relations Handbook to involve the community in
response activities conducted at a site.
Definition of Accomplishment:
The start of CR is the obligation or tasking of funds for the development of the
Community Relations Plan (CRP) or when EPA initiates work on the CRP. For RP-
lead or Federal Facility sites where the PRP or other Federal agency is preparing the
CRP in accordance with an AO, CD or IAG, the start of CR is defined as EPA's
written approval of the CRP. When EPA is preparing the CRP at a RP-lead site or at
EP-lead sites, CR begins when EPA initiates work on the CRP.
The completion of CR is the deletion of the site from the NPL or the conclusion of an
early removal action at non-NPL or NPL caliber sites.
Changes in Definition FY 93 - FY 94:
Added non-NPL and NPL caliber sites.
Special Planning/Reporting Requirements:
CR activities at PRP sites or Federal Facilities are paid for by the Regional
enforcement extramural budget or Federal Facility budget, respectively. Planned
and actual start and completion dates are not required in WasteLAN. Funds may be
planned site (C2101 = CR) or non-site specifically; however, they must be obligated
or tasked site specifically. Once funds are obligated, the non-site specific amount
must be reduced. Funds for CR activities are in the enforcement, Federal Facility, or
site characterization AOAs.
Support Agency Assistance
Definition:
Support agency assistance are the activities performed by another entity in support
of EPA. The support agency furnishes necessary data to EPA, reviews response data
and documents, and provides other assistance to EPA.
EPA may provide States, political subdivisions, and Indian Tribes with funding to
carry out a variety of management responsibilities via a support agency Cooperative
Agreement (CA) to ensure their meaningful and substantial involvement in response
activities.
A-71 April 1994
-------
OSWER Directive 9200.3-14-2
Unless otherwise specified in the CA, all support agency costs, with the exception of
RA or early action under remedial authority support agency costs, may be
documented under a single Superfund account number designated specifically for
support agency activities. RA or early action under remedial authority support
agency activities must be documented site-specifically and require cost share
provisions.
Definition of Accomplishment:
The start of support agency assistance is the signature of the CA by the Regional
Administrator or his designee. The completion of support agency assistance is the
completion of all remedial activities at the site.
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
Support agency assistance for RP- and PS-lead site assessment projects are paid for
by the enforcement extramural budget, and are distributed to the Region in the
enforcement AOA. Funds to support MR- and F-lead site assessment projects and
all RD/RA projects are paid for by the response program and are contained in the
site characterization AOA. Planned and actual start and completion dates are not
required in WasteLAN. Funds may be planned site (C2101 = MA) or non-site
specifically; however, they must be obligated site-specifically. Once funds are
obligated, the non-site specific amount must be reduced.
Technical Assistance
Definition:
Technical assistance is support provided by a third party to EPA to conduct
response activities. Third parties that may provide assistance include USAGE, U.S.
Fish and Wildlife Service, and ARCS and RAC contractors.
Definition of Accomplishment:
The start of technical assistance is the obligation of funds for technical assistance.
The completion is defined as the completion of the response activities for the stage at
which technical assistance was requested.
Changes in Definition FY 93 - FY 94:
This year's definition provides examples of entities that may provide technical
assistance.
April 1994 A-72
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OSWER Directive 9200.3-14-2
Special Planning/Reporting Requirements:
Planned and actual start and completion dates are not required in WasteLAN.
Funds may be planned site (C2101 = TA) or non-site specifically; however, they must
be obligated site-specifically. Once funds are obligated, the non-site specific amount
must be reduced. Funds for technical assistance are contained in the other response
AOA.
Technical Assistance Grants
Definition:
TAGs are provided under SARA to a community for technical assistance in dealing
with Superfund issues at NPL sites.
Definition of Accomplishment:
The start of the TAG is the signature of the CA to the community group which is the
obligation of funds for the TAG. The completion of the TAG is the completion of the
final RA or early action, or the deletion of the site from the NPL.
Changes in Definition FY 93 - FY 94:
Added early actions.
Special Planning/Reporting Requirements:
Planned and actual start and completion dates are not required in WasteLAN.
Funds may be planned site (C2101 = TG) or non-site specifically; however, they must
be obligated site specifically. Once funds are obligated, the non-site specific amount
must be reduced. Funds for TAGs at non-Federal Facility sites are contained in the
response budget and found in the other response AOA. Funds for TAGs at Federal
Facility sites are contained in the Federal Facility budget and found in the Federal
Facility AOA.
Treatability Studies
Definition:
Treatability studies are laboratory or field tests used to evaluate and implement one
or more remedial alternatives. This definition also covers post-ROD treatability
studies.
Definition of Accomplishment:
Fund-financed - The start of the treatability study is the obligation of funds
specifically for the study. If unexpended ESI/RI, FS or RD funds are used for the
treatability study, the start date is the date of EPA's written approval, as reflected in
WasteLAN, of the treatability study work plan. The completion is the written
approval of the report on the results of the treatability study.
A-73 April 1994
-------
OSWER Directive 9200.3-14-2
PRP-financed - The treatability study starts when EPA approves, in writing, the
treatability study work plan submitted by the PRP(s). The completion is the
approval of the report on the results of the treatability study.
Changes in Definition FY 93 - FY 94:
Treatability Studies will not be tracked as a SCAP reporting measure in FY 94;
however, they will be reported for internal management purposes.
Special Planning/Reporting Requirements:
Treatability study (C2101 = TS) planned and actual start and completion dates are
required in WasteLAN. Funds are planned site-specifically and are placed in the site
characterization AOA.
Projects Nominated for SITE Program
Definition:
The SITE program assesses new technologies for the treatment of hazardous waste.
Technologies enter the program through an annual solicitation. Once technologies
are selected, it is necessary to find demonstration sites.
Definition of Accomplishment:
A project is nominated for the SITE program when the Region sends a
memorandum to HQ formally submitting the site for consideration as a location for
a demonstration project.
Changes in Definition FY 93 - FY 94:
Projects Nominated for SITE Program will no longer be tracked as a SCAP reporting
measure in FY 94; however, these projects will continue to be reported for internal
management purposes.
Special Planning/Reporting Requirements:
These projects are reported site-specifically. Fund-financed or RP-lead sites may be
submitted for consideration. The coding requirements can be found in the General
Planning and Reporting Requirements section of this Appendix.
Design Assistance
Definition:
Design assistance activities are undertaken by the USAGE in preparation for
initiating RD activities. This includes:
Synopsizing RD requirements in the Commerce Business Daily (CBD);
April 1994 A-74
-------
OSWER Directive 9200.3-14-2
Developing architect/engineer (A/E) firm pre-selection list;
Contacting A/E firms on the pre-selection list to ascertain interest in project;
Developing A/E selection list; and
Tentatively selecting A/E firm.
Definition of Accomplishment:
The initiation of design assistance is the obligation of funds. The completion of
design assistance is the start of RD.
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
Funds for design assistance should be obligated prior to the signature of the ROD.
Planned and actual start and completion dates are not required in WasteLAN.
Funds may be planned site (C2101=DA) or non-site specifically; however, they must
be obligated site-specifically. Once funds are obligated the non-site specific amount
must be reduced. Funds for design assistance are in the site characterization AOA.
A-75 April 1994
-------
>
EXHIBIT A-8
PROGRAM SUPPORT ACTIVITIES
PLANNING REQUIREMENTS
D
n
n
N>
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a quarterly basis.
Internal measures are planned and reported semi-annually.
-------
>
>-(
EXHIBIT A-8 (continued)
PROGRAM SUPPORT ACTIVITES
PLANNING REQUIREMENTS
Treatability
Studies
Planning Requirements
Projects
Nominated for
SITE Program
STARS?
SCAP?
Internal Management?
Reporting
Reporting
Planned Site-Specifically?
Yes
Planned/Reported on
Operable Unit or Whole
Site Basis?
Operable
Unit
Reported Site-Specifically or in
Non-Site Portion of
WasteLAN?
AOA Category, if Fund
Financed?
AOA Category for
Oversight?
Design
Assistance
Site or Non-Site
Specific Plans
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS
on a quarterly basis. Internal measures are planned and reported semi-annually.
tn
3
n
--
NJ
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OSWER Directive 9200.3-14-2
This Page Intentionally
Left Blank
April 1994 A-78
-------
OSWER Directive 9200.3-14-2
ENFORCEMENT
FY 94 SCAP/STARS TARGETS AND MEASURES
A-79 April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-9
ENFORCEMENT ACTIVITIES
PRP Search Starts
PRP Search
Completions
Section 104(e) Letters
Issued
Section 104(e) Referrals
and Orders Issued
Issuance of General
Notice Letter
Issuance of Special Notice
Letter
ENF-1 Duration from
Regional Decision or ROD to
PRP Cleanup Negotiation
Completion
ESI/RI/FS Negotiation
Starts
RD/RA Negotiation Starts
ENF-2 Cleanup Negotiation
Completions
State Orders for ESI/RI/FS
Semi-annual targets are established in SCAP/STARS. Accomplishments
are pulled from CERCLIS on a quarterly basis. Internal measures are
planned and reported quarterly.
April 1994
A-80
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-9 (continued)
ENFORCEMENT ACTIVITIES
State Consent Decree for
RD/RA
ENF-3 Settlements for
Cleanup Actions
(including dollar value)
ENF-4 De minimis
Settlements and Number
of Parties
ENF-5 Percentage of PRP
Lead Cleanup Actions to
All Cleanup Actions
Section 106,106/107,
107 Case Resolution
Administrative Record
Compilation Completion
Reporting
Reporting
Issue Demand Letter
Cost Recovery
Actions/Decisions <$200K
Reporting
ENF-6 Past Costs
Addressed >$200,000
Semi-annual targets are established in SCAP/STARS. Accomplishments are
pulled from CERCLIS on a quarterly basis. Internal measures are planned
and reported quarterly.
A-81
April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-10
ENFORCEMENT TARGET/MEASURE CROSSWALK
FY 94 Target/Measure
Equivalent FY 93
Target/Measure
Continents
ENF-1 Duration from
Regional Decision or
ROD to PRP Cleanup
Negotiation Completion
(SCAP measure)
Duration from ROD to
RD/RA Negotiation
Completion (SCAP
measure)
This measure will include
NPL and NPL caliber sites
and will report both early
and long-term actions.
This measure will use the
Regional decision as the
starting point for calculating |
durations for early actions
rather than the Action
Memo or ROD.
ENF-2 Cleanup
Negotiation Completions
(SCAP/STARS target)
RD/RA Negotiation
Completions (SCAP
target)
This measure will report
negotiation completions for
NPL and NPL caliber sites.
Includes negotiations for
both early and long-term
actions.
ENF-3 Settlements
for Cleanup Actions
(including dollar value)
(SCAP/STARS
measure)
UAOs for RD/RA (SCAP
measure)
RD/RA Settlements and
Injunctive Referrals
(SCAP/STARS target)
Mixed Funding
Settlements (SCAP
measure)
AO Issued for Removal
and RI/FS (SCAP
measure)
Reports all settlements for
response actions (including
ESI/RI/FS) separately by
NPL, NPL caliber, and
non-NPL sites.
ENF-4 De minimis
Settlements and
Number of PRPs
(SCAP/STARS target)
De minimis Settlements
prior to ROD and
Number of PRPs
(SCAP/STARS
measure)
De minimis Settlements
and Number of PRPs
(SCAP/STARS
measure)
This measure will report
both the total number of de
minimis and de micromis
settlements.
This is a SCAP/STARS
target instead of a
SCAP/STARS measure.
ENF-5 Percentage of
PRP Lead Cleanup
Actions to All Cleanup
Actions (SCAP/STARS
measure)
None
New measure.
Reported separately for
NPL, NPL caliber, and
non-NPL sites.
April 1994
A-82
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-10 (continued)
ENFORCEMENT TARGET/MEASURE CROSSWALK
FY 94 Target/Measure
Equivalent FY 93
Target/Measure
Comments
ENF-6 Past Costs
Addressed >$200,000
(number of actions
and dollar value)
(SCAP/STARS target)
Cost Recovery
Actions /Decisions
> $200K
(SCAP/STARS target)
This measure will report
past costs addressed for
NPL, non-NPL, and NPL
caliber sites.
A-83
April 1994
-------
OSWER Directive 9200.3-14-2
Note: WasteLAN coding requirements contained in the definitions are only for key
data elements. For a full list of requirements and suggested data elements, see the
Enforcement Data Quality Manual.
PRP Search Starts
Definition:
The purpose of the PRP search is to identify PRPs. At all sites the PRP search
activities should be initiated as soon as possible after the Region decides that a
response action is likely to be required at the site. It should be completed in time to
send a GNL which should be approximately two months before the SNL date and at
least 90 days prior to the obligation of funds for an ESI/RI/FS or early or long-term
action.
Definition of Accomplishment:
If the search is being conducted by a contractor, the actual start date is considered to
be the date the work assignment is procured. If it is conducted by EPA in-house, the
actual start date is the day the EPA staff develops the PRP search plan.
Changes in Definition FY 93 - FY 94:
PRP search starts will not be tracked as a SCAP reporting measure in FY 94;
however, they will continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
PRP searches are planned and funds requested on a site (C1701=RP (non-NPL PRP
search) or NS (NPL PRP search)) or non-site specific basis. Non-site specific
projections for PRP searches should be placed in CERHELP.
PRP Search Completions
Definition:
A PRP search is the action taken by the Region to identify the responsible parties at a
site.
Definition of Accomplishment:
The PRP search is complete when PRPs at a site have been identified, all applicable
activities described in the Agency's PRP Search Manual have been completed, and
the actual completion date and the outcome of the search has been determined and
entered into WasteLAN (C1719). If no PRPs are found, the actual completion date
and the outcome of the search also are entered into WasteLAN (C1719). This
definition applies to both Phase I (single owner, operator site) and Phase II (multi-
generator site) PRP search accomplishments.
April 1994 A-84
-------
OSWER Directive 9200.3-14-2
Changes in Definition FY 93 - FY 94:
PRP search completions will not be tracked as a SCAP reporting measure in FY 94;
however, they will continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
PRP search completions are planned on a site (C1701=RP (non-NPL PRP search) or
NS (NPL PRP search)) or non-site specific basis. The outcome of the search and the
number of PRPs found are to be entered into WasteLAN C1719 (Activity Outcome)
and C1720 (No. RP/Defendants). Non-site specific projections for PRP searches
should be placed in CERHELP.
Section 104(e) Letters Issued
Definition:
This is a letter issued under Section 104(e) of SARA. It requests information from
PRPs on matters such as: the nature and extent of a release or threatened release at a
site; nature and quantity of materials; indemnification; financial ability of PRP to pay
for response actions.
Definition of Accomplishment:
This activity is accomplished on the date the information request letter is signed by
the appropriate EPA official and entered into WasteLAN as a milestone under an
enforcement activity, with an actual milestone completion date.
Changes in Definition FY 93 - FY 94:
Section 104(e) letters issued will not be tracked as a SCAP reporting measure in FY
94; however, they will continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
Issuance of 104(e) letters will continue to be recorded at the milestone level
(C1701=RP or NS or other enforcement activities and C2801=IL).
Section 104(e) Referrals and Orders Issued
Definition:
Section 104(e) referrals/orders are enforcement actions to compel parties to respond
to EPA requests for information or to obtain site access.
Definition of Accomplishment:
The date of the memo from the Regional Administrator transmitting the Section
104(e) referral to HQ or to the DOJ is recorded in WasteLAN as the actual start date.
The date a Section 104(e) order (generally UAO) is signed by the Regional
Administrator is recorded in WasteLAN as the actual completion date.
A-85 April 1994
-------
OSWER Directive 9200.3-14-2
Changes in Definition FY 93 - FY 94:
Orders for access were added. Section 104(e) referrals and orders issued will not be
tracked as a SCAP reporting measure in FY 94; however, they will continue to be
reported for internal management purposes.
Special Planning/Reporting Requirements:
This is an internal reporting measure. The actual start date of the referral is entered
into WasteLAN site specifically (C1701=SF). The actual completion date of the order
is entered into WasteLAN site specifically (C1701=UA).
Issuance of General Notice Letters
Definition:
Letter sent by EPA under Section 122 of SARA informing recipients of their potential
liability for cleanup actions at the site. It is usually sent out during the PRP search or
during preparation for negotiations.
Definition of Accomplishment:
This activity is accomplished on the date the GNL is signed by the appropriate EPA
official and the actual completion date is recorded in WasteLAN at the milestone
level (C1701=RP or NS and C2801=NI).
Changes in Definition FY 93- FY 94:
Issuance of general notice letters will not be tracked as a SCAP measure; however,
they will continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
General Notice Letters are recorded at the milestone level.
Issuance of Special Notice Letters
Definition:
A SNL is a letter from EPA to the PRPs informing them of their potential liability
and inviting them to offer to conduct the planned response action(s) at the site. This
letter, under Section 122(e) of SARA, triggers a negotiation moratorium allowing the
PRPs to consider EPA's invitation to negotiate. The moratorium period varies
depending on the response action (ESI/RI/FS, RD, RA, early action under remedial
authority) and can be extended if necessary.
April 1994 A-86
-------
OSWER Directive 9200.3-14-2
Definition of Accomplishment:
This activity is accomplished on the date the SNL is signed by the appropriate EPA
official. The date of the letter is reported in WasteLAN as the actual completion date
of the SNL milestone (C2801=SN and C2807=date). Issuance of a SNL officially
starts cleanup negotiations (C1701=FN, AN, NG).
Changes in Definition FY 92 - FY 93:
Issuance of special notice letters will not be tracked as a SCAP measure; however,
they will continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
Special Notice Letters are recorded at the milestone level.
ENF-1 Duration from Regional Decision or ROD to PRP
Cleanup Negotiation Completion
Definition of Target/Measure:
This measures the duration from the Regional decision to proceed with an early
action under removal or remedial authority, or a ROD for a long-term action under
remedial authority (for NPL and NPL caliber sites) to negotiation completion.
Definition of Accomplishment:
Early Action
The duration is measured from the date of the Regional decision recommending
early action under removal or remedial authority to the negotiation completion date.
The decision actual completion date and decision event qualifier must be reported in
WasteLAN (C2101 = DT, C2103=J (early remedial action), R (time critical removal),
or V (NTC removal).
Negotiations for early actions under removal authority are considered complete
when:
- An AOC or a UAO is signed by the Regional Administrator/Deputy Regional
Administrator; or
Funds are obligated for a Fund-financed removal. If funds are not available
and the Region determines a UAO is not appropriate, and HQ concurs in
writing, the negotiation complete date is the date of the HQ memorandum
concurring with the Regional decision.
Note: The remedy type (C2731) for removals is "RV".
A-87 April 1994
-------
OSWER Directive 9200.3-14-2
Negotiations for early actions under remedial authority are considered complete
when:
- A signed Consent Decree (CD) under Section 106 or Section 106/107 and a 10
point analysis is referred by the Regional Administrator to DOJ or HQ; or
- A Section 106 or 106/107 complaint without settlement is referred by the
Regional Administrator to DOJ; or
- EPA and the PRPs proceed to trial under an existing case; or
- A UAO is issued for an early action under remedial authority; or
Funds are obligated for a Fund-financed early action under remedial
authority. If funds are not available and the Region determines a UAO is not
appropriate, and HQ concurs in writing, the negotiation complete date is the
date of the HQ memorandum concurring with the Regional decision.
Note: The remedy type (C2731) for early actions under remedial authority is
"RA" with an enforcement remedy qualifier (C2741) of "EA".
Long-Term Action
The duration is measured from the date the ROD is signed by the Regional
Administrator/ Deputy Regional Administrator or the A A SWER to the negotiation
completion date.
Negotiations for long-term action are complete when:
A signed CD under Section 106 or Section 106/107 and a 10 point analysis is
referred by the Regional Administrator to DOJ or HQ; or
A UAO for RD or RA is issued by the Regional Administrator; or
A Section 106 or 106/107 referral to compel the PRPs to perform the cleanup (RD,
RA) as specified in a UAO is transmitted by the Regional Administrator to DOJ
or HQ; or
EPA and the PRPs proceed to trial under an existing case; or
Funds are obligated for a Fund-financed RD or RA. If funds are not available
and the Region determines a UAO is not appropriate, and HQ concurs in writing,
the negotiation complete date is the date of the HQ memorandum concurring
with the Regional decision.
April 1994 A-J
-------
OSWER Directive 9200.3-14-2
Durations will be calculated for all PRP cleanup negotiations completed in FY 94.
The durations for NPL and NPL caliber sites will be tracked separately but reported
as a combined total.
Changes in Definition FY93 - FY94:
This measure is similar to the FY 93 SCAP measure ROD to RD/RA Negotiation
Duration definition. It will report both early and long-term actions. The Regional
decision is used as the starting point for early removal actions rather than the
removal decision document. A new event code and event qualifiers were added to
WasteLAN to track Regional cleanup decisions (C2101=DT). A new generic
negotiations code (C1701=NG) also was added to WasteLAN to provide coding
flexibility. Either code (C1701=NG or AG) can be used.
Special Planning/Reporting Requirements:
Data on durations will be developed using CERCLIS. The durations will be
calculated using actual ROD completion (C2101=RO) or actual Regional decision
date (C2101=DT) and actual cleanup negotiation (C1701=NG or AN) completion
dates (C1717). HQ will conduct the analysis. Regions must be sure their Links data
is up-to-date and accurate in order for durations to be calculated. Duration trends
will continue to focus on good project management of critical events, and address
the need for continuous improvement relative to meeting the program's goal of
accelerating cleanups and reducing risks. Duration data will be coupled with
specific analyses of problem factors to determine the causes of delays. This measure
will not be used for performance evaluation purposes. For additional reporting
requirements see Definition of Accomplishments. This is a SCAP measure.
ESI/RI/FS Negotiation Starts
Definition:
ESI/RI/FS negotiations are discussions between EPA and the PRPs on their liability,
willingness, and ability to conduct the ESI/RI/FS.
Definition of Accomplishment:
ESI/RI/FS negotiations start when:
The first SNL is issued, or
A Section 122 (a) waiver of SNL is issued with the intent to pursue negotiations
without moratorium procedures.
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Changes in Definition FY 93 - FY 94:
Added ESIs to the activities to be negotiated. RI/FS negotiation starts will not be
tracked as a SCAP measure; however, they will continue to be reported for internal
management purposes.
Special Planning/Reporting Requirements:
If the Region does not plan to perform ESI/RI/FS negotiations at a site, negotiation
dates should not be placed in WasteLAN. The start of ESI/RI/FS negotiations
(C1701=FN or NG) should be planned site specifically. The actual start date (C1716)
and the enforcement remedy codes (C2731=SS, CO, RI, FS) are to be entered into
WasteLAN.
RD/RA Negotiation Starts
Definition:
RD/RA negotiations are discussions between EPA and the PRPs on their liability,
willingness, and ability to implement the long-term remedy selected in the ROD for
the site or OU.
Definition of Accomplishment:
RD/RA negotiations start when:
The first SNL is issued, or
A Section 122(a) waiver of SNL is issued with the intent to pursue negotiations
without moratorium procedures.
Changes in Definition FY 93 - FY 94:
RD/RA negotiation starts will not be planned and reported as a SCAP target in
FY 94; however, they will continue to be planned and reported for internal
management purposes.
Special Planning/Reporting Requirements:
If the Region does not plan to conduct RD/RA negotiations, dates should not be
entered into WasteLAN. The start of RD/RA negotiations is planned site specifically
(C1701=AN or NG). The actual start date (C1716) and the enforcement remedy
codes (C2731=RD or RA) are to be entered into WasteLAN.
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STABSJ
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ENF-2* Cleanup Negotiation Completions
Definition of Target/Measure:
Total number of cleanup negotiations completed. Negotiations are complete (for
NPL and NPL caliber sites) when a decision has been made as to how the Region
will proceed with the cleanup.
Definition of Accomplishment:
Credit is given at NPL sites when:
A signed CD under Section 106 or Section 106/107 for RD, RA, early action under
remedial authority (C2101=RA and C2118=EA), or a NIC removal and a 10 point
analysis is referred by the Regional Administrator to either DOJ or HQ. The
actual negotiation completion date is the date on the Regional Administrator's
transmittal memo, which is the actual CD start date; or
A UAO for RD, RA, early action under remedial authority (C2101=RA and
C2118=EA), or a NTC removal is signed by the Regional Administrator/ Deputy
Regional Administrator. The actual negotiation completion date is the date the
UAO is signed; or
A Section 106 or Section 106/107 injunctive referral to compel the PRP to perform
the cleanup (RD, RA, early action under remedial authority (C2101=RA and
C2118=EA), or a NTC removal) as specified in a UAO is referred by the Regional
Administrator to DOJ or HQ. The actual negotiation completion date is the date
of the Regional Administrator's transmittal memo; or
EPA and PRPs proceed to trial under an existing case. The actual negotiation
completion date is the date the trial begins; or
An AOC is signed by the Regional Administrator/Deputy Regional
Administrator for a RD only, or an existing AOC for RI/FS is amended for RD.
The Region must notify HQ of its intent to issue a SNL for RA negotiations
within a specified period from the AOC signature date (no credit will be given
for the subsequent RA negotiation starts and completions). The actual
negotiation completion date is the date the AOC (new or amended) is signed by
the Regional Administrator/Deputy Regional Administrator.
For amended AOCs, the Enforcement Activity Judicial Civil Type (C1718) must
be coded as "A" (amended) and the amendment date tracked under the AOC
milestone (C2801) "AA" (activity amended) with an actual milestone date; or
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An AOC for a NTC removal is signed by the Regional Administrator/Deputy
Regional Administrator. The actual negotiation completion date is the date the
AOC is signed by the Regional Administrator/Deputy Regional Administrator;
or
Funds are obligated for a Fund-financed NTC removal, early action under
remedial authority (C2101=RA and C2118=EA) or long-term action terminating
negotiations. The actual negotiation completion date is the date funds are
obligated. If funds are not available and the Region decides a UAO is not
appropriate and HQ concurs (in writing), the actual negotiation completion date
is the date of the HQ memorandum concurring with the decision not to issue the
UAO.
Credit is given at NFL caliber sites when:
A signed Consent Decree under Section 106 or Section 106/107 for RD, RA, early
action under remedial authority (C2101=RA and C2118=EA), or a NTC removal
and a 10 point analysis is referred by the Regional Administrator to either DOJ or
HQ. The actual completion date is the date on the Regional Administrator's
transmittal memo; or
A UAO or an AOC to initiate a NTC removal is signed by the Regional
Administrator/Deputy Regional Administrator. The actual negotiation
completion date is the date the order is signed by the Regional
Administrator/Deputy Regional Administrator; or
Funds are obligated for a Fund-financed NTC removal. The actual negotiation
completion date is the date funds are obligated. If funds are not available and
the Region decides a UAO is not appropriate and HQ concurs (in writing), the
actual negotiation completion date is the date of the HQ memorandum
concurring with the decision not to issue the UAO.
This measure will track separately NPL and NPL caliber sites but accomplishments
are reported as a combined total.
Changes in Definition FY 93 - FY94:
This target is equivalent to the FY 93 SCAP target RD/RA Negotiation Completions.
It includes negotiations for both early and long-term actions at both NPL and NPL
caliber sites.
Special Planning/Reporting Requirements:
This is a SCAP target. Cleanup negotiation completions are planned site specifically.
The actual completion date is reported in WasteLAN with either the new generic
negotiation activity code (C1701=NG) or the RD/RA negotiation activity code
(C1701=AN). The enforcement remedy codes (C2731) must also be reported in
WasteLAN.
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State Order for ESI/RI/FS
Definition:
AO or CD signed by the State and the PRPs for the PRPs to conduct the ESI/RI/FS.
Definition of Accomplishment:
The date the last State official signs the order or CD. All WasteLAN coding
requirements for AOs and CDs apply. The enforcement activity type (C1701) should
be State decree ("SD") or State order ("SO") and the actual completion date should
be placed in C1717. In addition, the remedy field (C2731) must denote that the
AO/CD was issued for an ESI/RI/FS (C2731=CO, RI, FS, SS).
Changes in Definition FY 93 - FY 94:
The ESI activity was added. State orders for RI/FS will not be tracked as a SCAP
reporting measure in FY 94; however, they will continue to be reported for internal
management purposes.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. Projections for AOs for ESI/RI/FS are made site
specifically.
State Consent Decree for RD/RA
Definition:
Judicial agreement between the State and the PRPs fully or partially settling a claim
under CERCLA. The settlement may be for response work, or both response and
cost recovery work.
Definition of Accomplishment:
Date the State CD is signed by the last State official. All WasteLAN coding
requirements for CDs apply. The enforcement activity type (C1701) should be State
decree ("SD") and the actual completion date should be reported in C1717. In
addition, the remedy field (C2731) must denote that the CD was issued for RD
and/or RA.
Changes in Definition FY 93 - FY 94:
State consent decree for RD/RA will not be tracked as a SCAP reporting measure in
FY 94; however, it will continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
See Definition of Accomplishment.
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ENF-3* Settlements For Cleanup Actions
Definition of Target/Measure:
Settlements are the enforcement actions through which the PRP agrees to conduct
the cleanup work. This measure will require reporting of both the number of
settlements as well as the value of each of those settlements.
Definition of Accomplishment:
Settlements at NPL sites include:
A CD under Section 106 or 106/107 for PRPs to conduct or pay for the response
action (ESI/RI, FS, RD, RA, NTC removal or early action under remedial
authority (C2101=RA and C2118=EA) and a 10 point analysis is transmitted by
the Regional Administrator to either DOJ or HQ. Mixed funding and cash out
settlements for long-term actions (RD, RA) are also included. The remedy
qualifier for cash out (CO), mixed work (MW), or preauthorization (PA) must be
entered into WasteLAN Enforcement Remedy Qualifier (C2741-C2750) data field.
Credit for the CD referral (C1701=CD) is the date on the Regional
Administrator's or Deputy Regional Administrator's transmittal memo to HQ or
to the DOJ as recorded in WasteLAN as the actual start date (C1716); or
A UAO is issued by the Regional Administrator/Deputy Regional Administrator
and PRPs provide written notice of intent to comply with the UAO. Credit for
UAOs is given on the date the PRPs first provide notice of intent to comply with
the order. The order actual completion date is the date it is issued. Credit is
given on the date the notice of intent to comply (C2801=NC) is received by EPA
and is reported in WasteLAN as the actual milestone completion date (C2807). If
a PRP initially complies with a UAO, and later a CD is agreed to for the same
work, credit will be given for the UAO only. The compliance status code (C1726)
for UAO must be changed to "V" (converted to CD). A financial type (C2903) of
"W" (estimated value of work actually performed) must be added with a financial
amount (C2907) to track the estimated value (or actual, if dollar amount is
known) of the work performed by the PRP under the UAO. (The original
financial type of "R" (estimated RP work to be performed) tracked the total
estimated value of the work). The subsequent CD tracks the value of the
additional estimated RP work to be done. (The total estimated value of the RP
work is the sum of the dollars associated with the UAO (C2903=W) and the
dollars associated with the CD (2903=R).) If the PRPs did not conduct any work
under the UAO, the dollars associated with the estimated value of work actually
performed (C2903=W) should be "O"; or
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A Section 106 or 106/107 injunctive referral to compel the PRP to perform the
cleanup (RD, RA, early action under remedial authority (C2101=RA and
C2118=EA), or NTC removal) as specified in a UAO is transmitted by the
Regional Administrator to DOJ or HQ. Credit for the referral (C1701=CL, SX or
LT) is based on the date the Regional Administrator/Deputy Regional
Administrator signs the transmittal letter as recorded in WasteLAN as the actual
start date. Remedies for the litigation should be the same as those in the UAO; or
An AOC is signed by the Regional Administrator/Deputy Regional
Administrator for an ESI/RI, FS, NTC removal or RD, or an existing AOC for
ESI/RI, FS is amended for RD only. The Region must notify HQ in writing of its
intent to issue SNLs to initiate cleanup negotiations within a specified period
after the AOC signature date. The date the Regional Administrator/ Deputy
Regional Administrator signs the AOC (C1701=AC) is reported in WasteLAN as
the actual completion date (C1717). For amended AOCs, the Enforcement
Activity Judicial Civil Type (C1718) must be coded as "A" (amended) and the
amendment date reported with the AOC milestone "AA" (activity amended).
Settlements at non-NPL and NPL caliber sites include:
A CD under Section 106 or 106/107 for PRPs to conduct or pay for the response
action (ESI/RI, FS, RD, RA, NTC removal or early action under remedial
authority, (C2101=RA and C2118=EA) and a 10 point analysis is transmitted by
the Regional Administrator to either DOJ or HQ. Credit for the CD referral
(C1701=CD) is the date on the Regional Administrator's/ Deputy Regional
Administrator's transmittal memo to HQ or to the DOJ as recorded in WasteLAN
as the actual start date; or
An AOC under Section 106 for a NTC removal, ESI/RI, or FS is signed by the
Regional Administrator/Deputy Regional Administrator. The date the Regional
Administrator signs the AOC (C1701=AC) is reported in WasteLAN as the actual
completion date; or
A UAO for a NTC removal, ESI/RI, or FS is issued by the Regional
Administrator/Deputy Regional Administrator and the PRPs have notified the
Agency in writing of their intent to comply with the order. The order actual
completion date is the date it is issued. Credit is given on the date the notice of
intent to comply (C2801=NC) is received by EPA and is reported in WasteLAN
as the actual milestone completion date (C2807). If a PRP initially complies with
a UAO, and later a CD is agreed to for the same work, credit will be given for the
UAO only. The compliance status code (C1726) for UAO must be changed to "V"
(converted to CD). A financial type (C2903) of "W" (estimated value of work
actually performed) must be added with a financial amount (C2907) to track the
estimated value (or actual, if dollar amount is known) of the work performed by
the PRP under the UAO. (The original financial type of "R" (estimated RP work
to be performed) tracked the total estimated value of the work). The subsequent
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CD tracks the value of the additional estimated RP work to be done. (The total
estimated value of the RP work is the sum of the dollars associated with the UAO
(C2903=W) and the dollars associated with the CD (2903=R).) If the PRPs did not
conduct any work under the UAO, the dollars associated with the estimated
value of work actually performed (C2903=W) should be "O".
Settlements will be reported as a combined total for CDs, AOCs, and UAOs where
the PRPs have provided written notice of their intent to comply.
Accomplishments will be reported separately for:
All settlements for NTC early removal actions at NPL and non-NPL sites; and
All settlements for response action (early action under remedial authority
(C2101=RA and C2118=EA), RD, RA, ESI/RI, FS) at NPL and NPL caliber sites.
Changes in Definition FY 93 - FY 94:
This measure will replace the FY 93 SCAP measures UAOs for RD/RA, Mixed
Funding Settlements, AO Issued for Removal and RI/FS, and the SCAP/STARS
target RD/RA Injunctive Referrals. Value of each settlement will also be reported in
WasteLAN.
Special Planning/Reporting Requirements:
For special planning /reporting requirements see Definition of Accomplishments.
The dollar value of each settlement must be reported in WasteLAN (C2907 = amount
and C2903=R or W for converted UAOs), the remedy type (C2731), and remedy OU
(C2733) must be reported in WasteLAN. This is a SCAP/STARS measure.
ENF-4 De minimis Settlements and Number of PRPs
Definition of Target/Measure:
Total number of administrative or judicial settlements that were reached solely
under Section 122(g) of SARA, with PRPs who qualified as de minimis or de
micromis under Section 122(g). This type of settlement results in PRPs paying a
small portion of the estimated response costs at the site and is embodied in a CD or
AOC. If the total response costs at the site exceed $500,000 (excluding interest), the
AOC can only be issued (signed by the Regional Administrator/ Deputy Regional
Administrator) with DOJ prior written approval. If DOJ does not approve or
disapprove the AO within 30 days, the AOC is considered approved and can be
signed by the Regional Administrator/Deputy Regional Administrator. DOJ and
the Regional Administrator can agree to extend this 30-day period if necessary.
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This target counts the total number of de minimis settlements and the total number of
de micromis settlements.
Definition of Accomplishment:
Credit is given for a de minimis settlement when an AOC (C1701=AC) is signed by
the Regional Administrator/Deputy Regional Administrator (as reported in
WasteLAN as the actual completion date C1717) or when the Regional
Administrator/ Deputy Regional Administrator signs the memorandum
transmitting the CD to HQ or DOJ (as reported in WasteLAN as the actual start date
(C1716) of the CD C1701=CD).
Credit is given for a de micromis settlement if the Regional Administrator signed an
AOC, or referred a CD to DOJ. Credit is based on the AOC (C1701=AC) signature
date (actual completion date C1717) or CD transmittal memo (actual CD (C1701=
CD) start date (C1716).
The remedy qualifier for de_ minimis must be entered into WasteLAN Enforcement
Remedy Qualifier data elements (C2741- C2750 = DL or DG) and statute (C2771)
must be Section 122g.
The number of PRP signatories to each settlement must also be reported (C1720).
Changes in Definition FY 93 - FY 94:
The de_ minimis settlement definition has been modified to include de micromis
settlements.
Special Planning/Reporting Requirements:
For special planning/reporting requirements see Definition of Accomplishments.
De minimis and de micromis settlement will be reported as a combined
SCAP/STARS target for FY 94.
ENF-5 Percentage of PRP Lead Cleanup Actions to all
Cleanup Actions
Definition of Target/Measure:
This measure is expressed as the percentage of RP-lead cleanup actions (early and
long-term to all cleanup actions (early and long-term).
A RP-lead cleanup action is defined as those actions where PRPs or their
contractor(s) have mobilized for implementation of the removal action selected by
the Region and reflected in the Action Memorandum (C2101=RV and C3101=AM);
or the early action under remedial authority (C2101=RA and C2118=EA) or long-
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term action (C2101=RD or RA) remedy selected in the ROD (C2101=RO). The
cleanup action must be performed in compliance with a Federal AOC, UAO, CD or
judgment or State (PS-lead only) order or decree. A cleanup action that is taken over
by the Fund due to substantial non-compliance will not be counted as a RP-lead
cleanup action.
"All cleanup actions" is defined as those actions where EPA or EPA contractors, State
or State contractors, PRP or PRP contractors have mobilized for construction of the
removal actions specified in the Action Memorandum (C2101=RV and C3101=AM),
or the response actions specified in the ROD (C2101=RO) for early actions under
remedial authority (C2101= RA and C2118=EA) or long-term actions (C2101=RD or
RA). Orphan sites where no viable PRPs have been identified (C1719=NV or NP),
would be excluded from the calculation of this percentage.
The percentage of RP-lead early and long term actions will be tracked separately (by
removal and remedial categories as well as by NPL and NPL caliber) but reported as
a combined total.
Definition of Accomplishment:
See Definition of Target/Measure.
Changes in Definition FY 93 - FY 94:
This is a new SCAP/STARS measure for FY 94.
Special Planning/Reporting Requirements:
For special planning/reporting requirements, see Definition of Target/Measure.
Data for this measure will be obtained using CERCLIS. HQ will perform the
analysis. RP-lead cleanup must have an event lead code in WasteLAN (C2117) of
"RP", "PS", or "MR".
Section 106, 106/107, 107 Case Resolution
Definition:
Case resolution is the conclusion of a Section 106,106/107, or 107 judicial action by a
full settlement, a final judgment, a case dismissal, or a case withdrawal.
Definition of Accomplishment:
Credit for case resolution is given when:
A CD is entered in the court fully addressing the complaint with all parties;
The case is withdrawn;
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The case is dismissed; or
A trial concluded and a judgment entered fully addressing the complaint.
The case resolution (C1701=CL, SV, SX, or LT) actual completion date (C1717) is the
same as the milestone or activity actual completion date and is defined as follows:
* Date full settlement CD is entered. This is the CD completion and the litigation
completion date;
Date case is withdrawn (C2801=WD) as the milestone and litigation completion
date;
Date case is dismissed (C2801=DI) as the milestone and litigation completion
date; or
Date judgment is entered (C1701=JG), as the judgment completion and the
litigation completion date.
Changes in Definition FY 93 - FY 94:
Section 106,106/107,107 case resolution will not be tracked as a SCAP reporting
measure in FY 94; however, it will continue to be reported for internal management
purposes.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. The enforcement remedy code (C2731), remedy
OU (C2733), financial type (C2903=F or R), and financial amount (C2907) must be
entered into WasteLAN.
Administrative Record Compilation Completion
Definition:
An AR is a compilation of all documents that EPA used to make a specific decision
on the appropriate response action to be taken at a Superfund site, whether the
document supports or opposes the Agency's selected action. SARA specifies that
ARs be compiled at sites where responses under remedial or removal authority are
planned or are occurring, or where EPA is issuing a UAO or initiating litigation.
Definition of Accomplishment:
The AR compilation begins when the AR is received at the site repository and the
actual start date is entered into WasteLAN. The AR compilation is complete when
the compilation is certified by the program office and the actual completion date is
entered into WasteLAN.
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Changes in Definition FY 93 - FY 94:
Administrative Record Compilation Completion will not be tracked as a SCAP
reporting measure in FY 94; however, it will continue to be reported for internal
management purposes.
Special Planning/Reporting Requirements:
The completion of the compilation of the AR must be reported site specifically
(C2101=AR) in WasteLAN. It is recorded at the event level. An "E" or "V" must be
recorded in the Event Qualifier field (C2103) to indicate the AR is for a remedial or a
removal activity, respectively.
Issue Demand Letter
Definition:
A Section 122(e) letter issued pursuant to Section 107 from EPA to the PRP
requesting that the PRP reimburse the Fund for a specific amount associated with
one or more response activities. Demand letters are typically sent for each separate
response activity.
Definition of Accomplishment:
This milestone is accomplished on the date the demand letter is signed by the
appropriate EPA official and recorded in WasteLAN as a milestone (C2801=DL)
under negotiations, litigation, Alternative Dispute Resolution (ADR), CD or other
enforcement activities. The actual completion date is reported in C2807.
Changes in Definition FY 93 - FY 94:
Issue Demand Letters will not be tracked as a SCAP reporting measure in FY 94;
however, they will continue to be reported for internal management purposes.
Special Planning/Reporting Requirements:
Demand letters are recorded at the milestone level (C2801=DL).
Cost Recovery Actions/Decisions Less Than $200,000
Definition:
Cost recovery actions/decisions taken are decisions to take cost recovery action by
use of administrative cost recovery settlement, Section 106/107 or 107 judicial
referral for cost recovery, initiation of ADR (mediation, arbitration, mini-trial),
preparation of a decision document not or 10 point settlement analysis document to
pursue cost recovery, settlement for past costs under a CD (with no prior referral),
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bankruptcy filing, cash out settlement for cost recovery or initiation of debt
collection procedures.
This category only includes cost recovery actions for reimbursement of Trust Fund
amounts of less than $200,000.
Definition of Accomplishment:
Section 107 or 106/107 referrals - Credit is given on the date of the Regional
Administrator's transmittal letter to HQ or DOJ (C1701=SV, CL or LT) as recorded in
WasteLAN as the actual start date.
Settlement under CD (with no prior referral) - Credit is given on the date of the
Regional Administrator's transmittal letter to HQ or DOJ (C1701=CD) as recorded in
WasteLAN as the actual start date.
Cash out Settlements - Credit is given on the date of the Regional Administrator's
transmittal letter to HQ or DOJ or when the Regional Administrator signs the AOC
for the cash out. This date must be recorded in WasteLAN as the actual CD
(C1701=CD) start date or the actual AOC (C1701=AC) completion date. The remedy
qualifier for a cash-out must also be reported in WasteLAN in the Enforcement
Remedy Qualifier data fields (C2741-C2750=CO).
Decision Documents prepared not to pursue cost recovery claims - Credit is given when
the document (C1701=DD) is issued by the Regional office and recorded in
WasteLAN as the actual completion date. The decision not to pursue cost recovery
may also be documented in a 10-point settlement analysis. This decision is coded in
WasteLAN as "DD" as well. There is no requirement to write a separate document;
the 10-point analysis supports the "DD" entry in WasteLAN.
Administrative Settlements - Credit is given on the date that the Regional office or DOJ
receives payment from the PRPs in direct response to a demand letter for voluntary
cost recovery or the date the Regional Administrator signs the AOC for cost
recovery. The date must be reported in WasteLAN as the actual completion date of
the administrative/voluntary cost recovery (C1701=AV) or the actual completion
date of the AOC (C1701=AC).
Initiation of ADR - Credit is given on the date that the Region refers the case to OE for
selection of a mediator or arbitrator as reported in WasteLAN as the actual start
date. The activity code (C1701) for ADR is "AD" (Alternative Dispute Resolution).
ADR has the same coding requirements as negotiations or litigation.
Bankruptcy Filing - Credit is given based on the date that the bankruptcy strategy
package is prepared or on the date that the first creditor committee meeting
convenes as reported in WasteLAN as actual milestone completion dates. The
bankruptcy filing milestones are: C2801 = CP (Creditors Committee Meeting) and
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BS (Bankruptcy Strategy Package). These milestones are valid for activity C1701=CB
(Claim in Bankruptcy).
Initiation of Debt Collection Procedures - Credit is given on the date the initial demand
letter is signed by an EPA official invoking use of debt collection procedures. The
date the letter is signed is reported in WasteLAN as the actual completion date.
Debt collection milestones in WasteLAN are: C2801 = CS (Collection Services); AF
(Administrative Offset); and TF (Tax Refund Offset). These milestones are valid
only for activity C1701=AV (Administrative/Voluntary Cost Recovery). The statute
code in WasteLAN for the Debt Collection Act is C2771=DCA.
Changes in Definition FY 93 - FY 94:
Cost recovery actions/decisions less than $200,000 will not be tracked as a
SCAP/STARS reporting measure in FY 94; however, they will continue to be
reported for internal management purposes.
Special Planning/Reporting Requirements:
All dates must be entered into WasteLAN. Credit for referrals is based on the
referral package not on the number of sites. Credit will be withdrawn if a case is
returned to the Region by HQ or DOJ for additional work, but will be reinstated
upon re-referral and will be based on the quarter of re-referral. The enforcement
financial code (C2903=F) and the amount recovered (C2907) and the appropriate
remedy codes (C2731) must be entered into WasteLAN.
ENF-6 Past Costs Addressed > $200,000
Definition of Target/Measure:
Past costs addressed >$200,000 is the decision to take cost recovery action by use of
administrative cost recovery settlement, Section 106/107 or 107 judicial referral for
cost recovery, initiation of ADR (mediation, arbitration, mini-trial), preparation of a
decision document or 10 point settlement analysis not to pursue cost recovery,
settlement for past costs under CD (with no prior referral), bankruptcy filing, cash
out settlement for cost recovery, or initiation of debt collection procedures.
This measure includes cost recovery actions (at NPL, NPL caliber, and non-NPL
sites) for reimbursement of Trust Fund amounts of greater than $200,000. Regions
should give priority to Statute of Limitations (SOL) cases.
Definition of Accomplishment:
Section 107 or 106/107 Referrals - Credit is given on the date of the Regional
Administrator's/Deputy Regional Administrator's transmittal letter to HQ and DOJ
as recorded in WasteLAN as the actual start date (C1701=SV, CL or LT). This
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OSWER Directive 9200.3-14-2
includes CD settlements under Section 106/107 with a cost recovery component.
The actual CD (C1701=CD) start date must be reported in WasteLAN.
Administrative Settlements- Credit is given on the date the Regional office or DOJ
receives payment from the PRPs in direct response to a demand letter for voluntary
cost recovery or the date that the Regional Administrator/Deputy Regional
Administrator signs the AOC that recovers 100 percent of the Trust Fund
expenditures or settles a claim where the total response costs are less than $500,000.
The accomplishment of the administrative settlement is recorded in WasteLAN as
the actual completion date of the administrative/voluntary cost recovery
(C1701=AV) or the actual completion date of the AOC (C1701=AC). If the settlement
is compromised and total response costs are more than $500,000, the AOC must be
sent to DOJ for concurrence.
Cash out Settlements - Credit is given on the date of the Regional Administrator's/
Deputy Regional Administrator's transmittal letter (i.e. with a CD) to HQ or DOJ or
when the Regional Administrator/Deputy Regional Administrator signs the AOC
for the cash out settlement with a cost recovery component of greater than $200,000
as recorded in WasteLAN. The actual CD (C1701=CD) start date or the actual AOC
(C1701=AC) completion date and the remedy qualifier for the cash out (C2741-
C2750=CO) must be entered into WasteLAN. The AOC must be sent to DOJ for
approval if total site costs exceed $500,000. Credit is given for only those cash out
settlements which include a cost recovery component. Settlement dollars that will
be used for future response work are reported as "R" dollars in C2903. Settlement
dollars for past costs are reported as "F" dollars in C2903.
Decision Documents prepared not to pursue cost recovery claims - Credit is given when
the document (C1701=DD) is issued by the Regional office and recorded in
WasteLAN as the actual completion date. The decision not to pursue cost recovery
may also be documented in a 10-point settlement analysis. This decision is coded in
WasteLAN as "DD" as well. There is no requirement to write a separate document;
the 10-point analysis supports the "DD" entry in WasteLAN.
Initiation of ADR - Credit is given on the date that the Region refers the case to OE
for selection of a mediator or arbitrator as reported in WasteLAN as the actual start
date. The activity code (C1701) for ADR is "AD" (Alternative Dispute Resolution).
ADR has the same coding requirements as negotiations or litigation.
Bankruptcy Filing- Credit is given on the date that the bankruptcy strategy package is
prepared or on the date that the first creditor committee meeting convenes and the
information is reported in WasteLAN as the actual milestone completion dates.
Bankruptcy filing milestones in WasteLAN are C2801=CP (Creditors Committee
Meeting) and C2801=BS (Bankruptcy Strategy Package). These milestones are valid
for activity C1701=CB.
A-103 April 1994
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OSWER Directive 9200.3-14-2
Initiation of Debt Collection Procedures- Credit is given on the date the initial demand
letter is signed by an EPA official invoking use of debt collection procedures. The
date the letter is signed is reported in WasteLAN as the actual completion date.
Debt collection milestones in WasteLAN are C2801=CS (Collection Services); AF
(Administrative Offset); and TF (Tax Refund Offset). These milestones are valid
only for activity C1701=AV (Administrative/Voluntary Cost Recovery). The statute
code in WasteLAN for the Debt Collection Act is C2771=DCA.
Changes in Definition FY 93 - FY 94:
This measure replaces the FY 93 SCAP/STARS target, Cost Recovery
Actions/Decisions >$200/000.
Special Planning/Reporting Requirements:
For special planning/reporting requirements see Definition of Accomplishments.
The financial code (C2903=F) and the financial amount (C2907) also are to be entered
into WasteLAN. This is a SCAP/STARS target. Regions should diligently track SOL
cases.
April 1994 A-104
-------
EXHIBIT A-ll
ENFORCEMENT PLANNING REQUIREMENTS
Planning Requirements
STARS?
SCAP?
Internal Management ?
Planned Site-Specifically?
Planned/Reported on Operable
Unit or Whole Site Basis?
Reported Site-Specifically or
in Non-site Portion of
WasteLAN?
AOA Category, if Fund
Financed?
AOA Category for Oversight?
Basis for AOA?
PRP Search
Starts
-
-
Reporting
Yes
Whole Site
Site Specific
Enforcement
N/A
Site Specific
Plans
PRP Search
Completions
-
-
Reporting
Yes
Whole Site
Site Specific
N/A
N/A
N/A
Section
104(e)
Letters
Issued
-
-
Reporting
No
Whole Site
Site Specific
N/A
N/A
N/A
Section 104(e)
Referrals and
Orders Issued
-
-
Reporting
No
Whole Site
Site Specific
Enforcement
N/A
Site Or Non-Site
Specific Plans
Issuance of H
General
Notice Letters 1
1
1
Reporting
No 1
Operable Unit M
Site Specific H
Enforcement 1
N/A I
Site Or Non-Site 1
Specific Plans I
I1
o
>
O
en
w
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a
quarterly basis. Internal measures are planned and reported quarterly.
N>
-------
T3
EXHIBIT A-ll (continued)
ENFORCEMENT PLANNING REQUIREMENTS
Planning Requirements
Issuance of
Special Notice
Letters
ENF-l Duration from
Regional Decision
or ROD to PRP
Cleanup Negotiation
Completion
Internal Management?
Planned Site-Specifically?
Planned/Reported on Operable
Unit or Whole Site Basis?
Operable Unit
Operable Unit
Operable Unit
Operable Unit
Operable Unit
Reported Site-Specifically or
in Non-site Portion of
WasteLAN?
Site Specific
Site Specific
Site Specific
Site Specific
Site Specific
AOA Category, if Fund
Financed?
Enforcement
Enforcement
Enforcement
AOA Category for Oversight?
Site Specific
Plans
Site Specific
Plans
Site Or Non-Site
Specific Plans
Basis for AOA?
ESI/RI/FS
Negotiation
Starts
RD/RA
Negotiation
Starts
ENF-2
Cleanup
Negotiation
Completions
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a
quarterly basis. Internal measures are planned and reported quarterly.
8
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3
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O
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-------
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o
>
1-1
EXHIBIT A-ll (continued)
ENFORCEMENT PLANNING REQUIREMENTS
Planning Requirements
STARS?
SCAP?
Internal Management ?
Planned Site-Specifically?
Planned/Reported on Operable
Unit or Whole Site Basis?
Reported Site-Specifically or
in Non-site Portion of
WasteLAN?
AOA Category, if Fund
Financed?
AOA Category for Oversight?
Basis for AOA?
State
Orders
for
ESI/RI/FS
-
-
Reporting
No
Operable
Unit
Site Specific
Enforcement
N/A
Site or Non-Sit
Specific Plans
State Consent
Decrees for
RD/RA
-
-
Reporting
No
Operable
Unit
Site Specific
Enforcement
N/A
; Site Or Non-Site
Specific Plans
ENF-3
Settlements
For Cleanup
Actions
Measure
Measure
-
Yes
Operable
Unit
Site Specific
Enforcement
N/A
Site Specific
Plans
ENF-4 De
Minimis
Settlements
and Number
of PRPs
Target
Target
-
Yes
Whole Site
Site Specific
Enforcement
N/A
Site Specific
Plans
ENF-5
Percentage Of
PRP Lead
Cleanup
Actions To All
Cleanup
Actions
Measure
Measure
-
No
Operable
Unit
Site Specific
N/A
N/A
N/A
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a
quarterly basis. Internal measures are planned and reported quarterly.
8
8
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*
-------
>
O
oo
EXHIBIT A-ll (continued)
ENFORCEMENT PLANNING REQUIREMENTS
Planning Requirements
STARS?
SCAP?
Internal Management?
Planned Site-Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Reported Site-Specifically or
in Non-site Portion of
WasteLAN?
AOA Category, if Fund
Financed?
AOA Category for Oversight?
Basis for AOA?
Section
106,106/107,
107 Case
Resolution
-
-
Reporting
No
Whole Site
Site Specific
N/A
N/A
N/A
Administrative
Record
Compilation
Completion
-
-
Reporting
No
Operable
Unit
Site Specific
Enforcement or
Other Response
N/A
Site Or
Non-Site
Specific Plans
Issue
Demand
Letter
-
-
Reporting
No
Operable
Unit or
Whole Site
Site Specific
Enforcement
N/A
Site Or Non-Site
Specific Plans
Cost
Recovery
Action/
Decisions
<200K
-
-
Reporting
No
Whole Site
Site Specific
Enforcement
N/A
Site Specific
Plans
ENF-6 Past |
Costs I
Addressed B
>200,000 I
Target 1
Target I
1
Yes 1
Whole Site I
Site Specific 1
Enforcement
N/A 1
Site Specific 1
Plans
Semi-annual targets are established in SCAP/STARS. Accomplishments are pulled from CERCLIS on a
quarterly basis. Internal measures are planned and reported quarterly.
m
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vo
K)
O
O
OJ
-------
OSWER Directive 9200.3-14-2
FEDERAL FACILITIES FY 94 SCAP/STARS TARGETS AND
MEASURES
A-109 April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-
FEDERAL FACILITIES
12
ACTIVITIES
Targeted /Reported
Semi-Annual Annual
FF-1 Base Closure Decisions
FF-2 FFA/IAG
FF-3 FFA/IAG Completions
FF-4 Federal Facility
Dispute Resolution
FF-5 RI/FS Starts (First
and Subsequent)
FF-6 Timespan from NPL
Listing to RI/FS Start
FF-7 RI/FS Completions
(RODs) (First and Subsequent)
RI/FS Duration
FF-9 RD Starts (First
and Subsequent)
FF-10 RD Completions
(First and Subsequent)
FF-11 RD Duration
FF-12 RA Starts
(First and Subsequent)
FF-13 Timespan from ROD
Signature to RA Start
FF-14 RA Completions
(First and Subsequent)
FF-15 Final RA Completion
FF-16 RA Duration
FF-17 Timespan from RI/FS
Start to RA Complete
FF-18 Removal/ERA/RCRA
Corrective Action Starts &
Completions
FF-19 Federal Facility NPL Deletior
April 1994
A-110
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-13
FEDERAL FACILITY TARGET/MEASURE CROSSWALK
FY 94 Target/Measure
Equivalent FY 93
Target/Measure
Comments
FF-1 Base Closure
Decisions (STARS/SCAP
measure)
None
New
FF-2 FFA/IAG Start
(SCAP measure)
IAG Start
(STARS/SCAP target)
This activity is changed
from a STARS/SCAP
target to a SCAP
measure.
FF-3 FFA/IAG
Completions (SCAP
measure)
IAG Completions at NPL
or Proposed NPL Sites
(STARS/SCAP target)
This activity is changed
from a STARS/SCAP
target to a SCAP
measure. This definition
has been revised.
FF-4 Dispute Resolution
(STARS/SCAP measure)
None
New
FF-5 RI/FS Starts - First
and Subsequent (SCAP
target)
First RI/FS Start (SCAP
target)
Subsequent RI/FS Start
(SCAP target)
No change.
FF-6 Timespan from
NPL Listing to RI/FS
Start (SCAP measure)
Federal Facility Listing
to RI/FS Start Duration
(SCAP measure)
No change.
FF-7 RI/FS
Completions (RODs)
First and Subsequent
(STARS/SCAP target)
Federal Facility
Remedy Selection at
NPL Sites - First and
Subsequent
(STARS/SCAP target)
First Federal Facility
RODs (SCAP target)
Subsequent Federal
Facility RODs (SCAP
target)
No change.
FF-8 RI/FS Duration
(SCAP measure)
RI/FS Duration (SCAP
measure)
No change.
FF-9 RD Starts First
and Subsequent (SCAP
measure)
First RD Start (SCAP
target)
Subsequent RD Start
(SCAP target)
This activity has been
changed from a SCAP
target to a SCAP measure.
The RD start date for work
beginning prior to the
ROD has changed.
A-lll
April 1994
-------
OSWER Directive 9200.3-14-2
EXHIBIT A-13 (continued)
FEDERAL FACILITY TARGET/MEASURE CROSSWALK
FY 94 Target/Measure
Equivalent FY 93
Target/Measure
Comments
This activity is changed
from a SCAP target to a
SCAP measure.
FF-10 RD Completions
First and Subsequent
(SCAP measure)
First RD Completions
(SCAP target)
Subsequent RD
Completions (SCAP
target)
FF-11 RD Duration
(SCAP measure)
Federal FAcility RD
Start to RD Complete
Duration (SCAP
measure)
No change.
FF-12 RA Starts First
and Subsequent
(STARS/SCAP measure)
RA Start
(STARS/SCAP target)
First RA Start (SCAP
target)
Subsequent RA Start
(SCAP target)
This activity is changed
from a STARS/SCAP
target to a STARS/SCAP
measure.
FF-13 Timespan from
ROD signature to RA
Start (SCAP measure)
ROD to RA Start
Duration (SCAP
measure)
No change.
FF-14 RA Completions
First and Subsequent
(STARS/SCAP target)
First RA Completion
(SCAP measure)
This activity is changed
from a SCAP measure to
a STARS/SCAP target.
This activity is changed
from a SCAP measure to a
SCAP target.
No change.
FF-15 Final RA
Completion (SCAP target)
Final RA Completion
(SCAP measure)
FF-16 RA Duration
(SCAP measure)
Federal Facility RA
Start to RA Complete
Duration (SCAP
measure)
FF-17 Timespan from
RI/FS Start to RA
Completion (SCAP
measure)
Federal Facility RI/FS
Start to RI/FS
Complete Duration
(SCAP measure)
No change.
FF-18 Removal/ERA/
RCRA Corrective Action
Starts and Completions
(STARS/SCAP measure)
Federal Facility
Removal/ER As
(STARS/SCAP
measure)
Addition of RCRA
Corrective Action starts
and completions.
FF-19 Federal Facility
NPL deletion (SCAP
measure)
Federal Facility NPL
Deletion (SCAP measure)
No change.
April 1994
A-112
-------
OSWER Directive 9200.3-14-2
FF-1 Base Closure Decision
Definition:
A base closure decision is when EPA is involved with land transfer decisions
and clean parcel determinations at closing or realigning military bases.
Definition of Accomplishment:
Base Closure Decision Start Date: Date a facility or a parcel is identified as a
candidate to be transferred by deed or lease (e.g., Environmental Baseline
Survey (EBS) submitted) or a clean parcel is identified as required by the
Community Environmental Response Facilitation Act (CERFA), or the other
Federal agency submits a written request for concurrence on suitability to
transfer or lease.
Base Closure Decision Completion Date: Date EPA responds to the Facility after
review of a proposed lease or other land transfer document or date EPA
concurs on a clean parcel identified under CERFA.
Changes in Definition FY 93 - FY 94:
New SCAP/STARS measure for FY 94.
Special Planning/Reporting Requirements:
This information cannot be collected through CERCLIS/WasteLAN. Regions
should submit a memo outlining Base Closure Decision accomplishments to the
OFFE at the end of the second and fourth quarter.
FF-2 Federal Facility Agreements/lAG Start
Definition:
FFAs/IAGs are legally binding documents that set forth detailed requirements
for performance of site response activities, as well as, appropriate enforcement
responses to non-compliance with the FFA/IAG. Under CERCLA Section 120,
Federal agencies are required to enter into an FFA/IAG with EPA within six
months of completing the RI/FS. However, as a matter of policy, HQ
encourages the Regions to enter into an IAG as soon after NPL listing as
possible.
A-113 April 1994
-------
OSWER Directive 9200.3-14-2
Definition of Accomplishment:
FFA/IAG Start Date: Date notice letter is sent by EPA to the Federal Facility,
reported in WasteLAN as the actual start date.
Changes in Definition FY 93 - FY 94:
This activity is changed from a STARS/SCAP target to a SCAP measure.
Special Planning/Reporting Requirements:
FFA/IAG negotiations will be tracked as LAG Negotiations (C1701 = IN). This is a
SCAP reporting measure.
FF-3 Federal Facility Agreements/lAG Completion
Definition:
FFA/IAGs are legally binding documents that set forth detailed requirements for
performance of site response activities, as well as appropriate enforcement responses
to non-compliance with the FFA/IAG.
Definition of Accomplishment:
FFA/IAG Completion Date: Date the Federal agency, EPA, and/or State sign the IAG,
the date the Letter of Intent is signed by all parties, or the date the IAG is signed by
all parties (generally prior to the start of a public comment period), whichever is
earliest. This date must be reported in WasteLAN as the actual completion date.
Changes in Definition FY 93 - FY 94:
Omitted many accomplishment dates. This activity is changed from a STARS/SCAP
target to a SCAP measure.
Special Planning/Reporting Requirements:
FFA/IAG negotiations will be tracked as LAG Negotiations (C1701 = IN). Also, for
those FFAs/IAGs that are elevated for dispute resolution, record the date elevated
as the milestone date, Civil Litigation Referred to HQ (C2801 = PH), and not as the
FFA/IAG completion date. This is a SCAP reporting measure.
April 1994 A-114
-------
OSWER Directive 9200.3-14-2
FF-4 Federal Facility Dispute Resolution
Definition:
When the Federal agency, State, and/or EPA make an effort to resolve an
IAG/FFA dispute, informally or formally.
Definition of Accomplishment:
Dispute Resolution Start Date: Date that any party to the FFA/IAG sends a letter
to the other parties notifying them as to the issue in dispute. This is reported in
WasteLAN as the actual start date.
Dispute Resolution Completion Date: Date the document resolving the issue is
signed (e.g., letter of agreement, agreement document). This is reported in
WasteLAN as the actual completion date.
Changes in Definition FY 93 - FY 94:
New STARS/SCAP measure for FY 94.
Special Planning/Reporting Requirements:
Federal Facility Dispute Resolution is reported in WasteLAN as Alternative Dispute
Resolution (C1701=AD). This is a SCAP/STARS reporting measure.
FF-5 RI/FS Starts First and Subsequent
Definition:
The RI/FS is an investigation designed to characterize the site, assess the nature
and extent of the contamination, evaluate potential risk to human health and
the environment, and develop and evaluate potential remediation alternatives.
In order for the RI/FS to be counted as a first start it must not have had
previous RI/FS activity at the site. A subsequent RI/FS is any RI/FS that starts
after the first one.
Definition of Accomplishment:
The RI/FS start is defined as follows:
Sites where there has been no RI/FS work started prior to the effective date of the
FFA/IAG, the actual start date is receipt of final work plan.
A-115 April 1994
-------
OSWER Directive 9200.3-14-2
Sites where RI/FS work has been started prior to the FFA/IAG effective date and
there has been substantial EPA involvement (EPA has reviewed and commented,
approved/concurred or accepted the workplan), the actual start date is also the
date of receipt of final RI/FS work plan.
Sites where RI/FS work starts prior to the FFA/IAG effective date and there has
been limited EPA involvement, the date of the RI/FS actual start is the date of the
FFA/IAG completion.
Sites where RI/FS work is initiated under a RCRA order or permit, the RI/FS
actual start date should equal the date when the RCRA order or permit becomes
effective.
Subsequent RI/FS starts count on the date of receipt of the work plan which
addresses the subsequent RI/FS. For cases where the subsequent RI/FS is
described in the same work plan as the first RI/FS start, the subsequent RI/FS
actual start date is the same as the first RI/FS actual start date.
Changes in Definition FY 93 - FY 94:
The start date for sites where work begins prior to the FFA/IAG, and/or where
there has been substantial EPA involvement, has been changed.
Special Planning/Reporting Requirements:
This is a SCAP target. RI/FS start dates are reported site specifically
(C2101 = CO) in WasteLAN.
FF-6 Timespan From NPL Listing To RI/FS Start
Definition:
CERCLA/Superfund Amendments and Reauthorization Act (SARA) Section
120(e) states "not later than six months after the inclusion of any facility on the
NPL, the department, agency, or instrumentality shall... commence a RI/FS for
such facility."
Definition of Accomplishment:
This measure will calculate by site the interval between final NPL listing
(publication of final listing in the Federal Register) and the first RI/FS start. The
timespan will be calculated based on the RI/FS start definition outlined in this
Manual and the final NPL listing date (C2101 = NF).
April 1994 A-116
-------
OSWER Directive 9200.3-14-2
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
This is a SCAP reporting measure. Data in CERCLIS will be used to calculate the
timespan. HQ will perform the analysis.
FF-7 RI/FS Completions (RODs) - First and Subsequent
Definition:
Upon completion of a Federal Facility RI/FS, the Federal agency selects a
remedy for the OU that is presented in a cleanup decision document (i.e., ROD,
Corrective Action Decision Document). This document is concurred upon or
approved by either the AA for the OF or the Regional Administrator/Deputy
Regional Administrator.
Definition of Accomplishment:
Date of EPA approval/concurrence on the clean-up decision document
pursuant to an FFA/IAG or other enforceable decision document, or the date of
EPA's Letter of Concurrence.
This date must be entered in WasteLAN as both the RI/FS and ROD actual
completion date (C2101 = CO and C2101 = RO).
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
See Definition of Accomplishment. This is a STARS/SCAP target.
FF-8 RI/FS Duration
Definition:
The RI/FS is an investigation designed to characterize the site, assess the nature
and extent of contamination, evaluate potential risks to human health and the
environment, and develop and evaluate potential remediation alternatives.
The objective of this measure is to focus on good project management of a
critical portion of the remedial pipeline and establish a methodology which
accurately assesses program performance. Duration trends provide indicators
A-117 April 1994
-------
OSWER Directive 9200.3-14-2
of areas that require attention. Only RI/FS projects that started post-SARA will
be evaluated.
Definition of Accomplishment:
The RI/FS duration is calculated based on the SCAP/STARS RI/FS start and
completion definitions specified above. All sites where the RI/FS is actually
completed in FY 94 will be used in the analysis. Performance will be assessed
by comparing:
The Regional and national average duration of RI/FS projects completed in
FY 91, FY 92 and FY 93.
The Regional and national average duration of RI/FS projects completed in
previous quarters of FY 94.
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
This is a SCAP reporting measure. Data in CERCLIS will be used to calculate
durations. HQ will perform the analysis.
FF-9 RD Starts First and Subsequent
Definition:
The RD establishes the general size, scope, and character of a project, and
details and addresses the technical requirements of the RA selected in the ROD.
The RD may include, but is not limited to, drawings, specification
documentation, and statement of bidability and constructability.
Subsequent RD starts occur at NPL sites where previous RD activity has taken
place.
Definition of Accomplishment:
If post-ROD, the RD start date is the date of submission of the RD work plan or
other appropriate documents or statement of work (reported in WasteLAN as
an actual start). If work begins prior to the ROD, the RD actual start date will
be the same as the ROD date or the submission date of RD work plan or any
other major deliverable (e.g., 30% design complete).
Changes in Definition FY 93 - FY 94:
Changes were made to the start date when work begins prior to the ROD. This
activity is a SCAP measure instead of a SCAP target.
April 1994 A-118
-------
OSWER Directive 9200.3-14-2
Special Planning/Reporting Requirements:
This is a SCAP reporting measure. RD starts are reported site specifically (C2101
RD) in CERCLIS.
FF-10 RD Completions - First and Subsequent
Definition:
An RD is complete when the plans and specifications for the selected remedy
are developed.
Definition of Accomplishment:
The date of EPA approval of the final RD package or when the design package
goes out to bid if EPA does not "approve" the entire final RD package. This
date is reported in WasteLAN as the actual completion date.
Changes in Definition FY 93 - FY 94:
Credit is also given when the design package goes out to bid if EPA does not
approve the final RD package. This activity is a SCAP measure instead of a
SCAP target.
Special Planning/Reporting Requirements:
This is a SCAP reporting measure. RD completions are reported site
specifically (C2101 = RD) in WasteLAN.
FF-11 RD Duration
Definition:
The RD is an essential component of the remedial pipeline which links the
execution of a decision document with the initiation of remedial construction
activities. Initiation of the RA depends upon completion of an acceptable RD
which reflects the chosen remedy. Additionally, CERCLA/SARA Section
120(e) states that "substantial, physical, on-site RA shall be commenced at each
facility not later than 15 months after completion of the investigation and
study." Hence, it is necessary to manage the duration of the RD to ensure that
the statutory requirement described above is met and that overall the remedial
timeframes are minimized.
A-119 April 1994
-------
OSWER Directive 9200.3-14-2
Definition of Accomplishment:
This measure examines performance at a Federal Facility by analyzing the
average length of a RD for sites with actual RD completion in FY 94. Duration
will be calculated using the actual RD start date and actual RD completion
dates in CERCLIS. For sites where the ROD leads to RDs at different OUs,
Links data will be used. The RD start and RD completion definitions contained
in this Manual will be used for the analysis.
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
This is a SCAP reporting measure. CERCLIS will be used to calculate durations.
HQ will perform the analysis.
FF-12 PA Starts First and Subsequent
Definition:
An RA start is the implementation of the remedy selected in the ROD at NPL
sites to ensure protection of human health and the environment.
Definition of Accomplishment:
Date on which substantial, continuous, physical, on-site, remedial actions begin
pursuant to SARA Section 120(e). This date is reported in WasteLAN as the
actual RA start date.
Changes in Definition FY 93 - FY 94:
This activity is a STARS/SCAP measure instead of a STARS/SCAP target.
Special Planning/Reporting Requirements:
This is a STARS/SCAP reporting measure. RA starts are reported site
specifically (C2101 = RA) in WasteLAN.
April 1994 A-120
-------
OSWER Directive 9200.3-14-2
FF-13 Timespan from ROD Signature to RA Start
Definition:
The objective of this measure is to focus on good project management of critical
portions of the remedial pipeline, particularly the period between ROD and RA
start.
CERCLA/SARA Section 120(e) states that "substantial, physical, on-site
remedial action shall be commenced at each Federal Facility no later than 15
months after completion of the investigation and study." This measure will
track compliance against CERCLA Section 120 statutory requirements.
Definition of Accomplishment:
This measure will look at Regional performance by comparing the average
timespan from ROD signature to RA start for all sites where an RA actually
started in FY 94 to:
The Regional and national average timespan from ROD signature to RA
start in FY 91, FY 92 and FY 93; and
The Regional and national average timespan from ROD signature to RA
start in previous FY 94 quarters.
The durations will be calculated using the actual ROD completion dates and
the actual RA start dates in CERCLIS. The ROD signature (RI/FS Completion)
and RA start definition contained in this Manual will be used in the analysis.
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
This is a SCAP reporting measure. Data in CERCLIS will be used to calculate the
timespan. HQ will perform the analysis.
A-121 April 1994
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OSWER Directive 9200.3-14-2
FF-14 PA Completions - First and Subsequent
Definition:
A first and subsequent RA is complete when construction activities are
complete, a final inspection has been conducted, and a RA Report has been
prepared and approved by the EPA. This report summarizes site conditions
and construction activities for the OU.
Definition of Accomplishment:
The date that the designated Regional official (Branch Chief or above) signs a
letter accepting the RA Report for the first or subsequent RA. The Federal
Facility's construction manager submits a signed RA report to document the
completion of all construction activities for that OU, and that the remedy is
O&F. In lieu of a report from the contractor's construction manager, the Region
must prepare a report to document the completion. The appropriate date must
be recorded in WasteLAN as the actual completion of the RA event.
Changes in Definition FY 93 - FY 94:
This is a SCAP/STARS target instead of a SCAP measure.
Special Planning/Reporting Requirements:
This is a STARS/SCAP target. RA completions are reported site specifically
(C2101 = RA) in WasteLAN.
FF-15 Final RA Completion
Definition:
A final RA is complete when:
Construction for all OUs is complete;
A pre-final inspection has been conducted;
A Preliminary Site Close-Out Report has been prepared. This report
documents the completion of physical construction, summarizes site
conditions and construction activities and, as appropriate, provides the
schedule for the joint final inspection, approval of the O&M work plan, and
establishment of institutional control. The date of the Preliminary Close-
April 1994 A-122
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OSWER Directive 9200.3-14-2
Out Report must be reported in WasteLAN as the actual completion of the
RA Subevent, "Preliminary Close-Out Report Prepared" (C2101 = RA and
C3101 = CC);
A final inspection has been conducted;
The remedy is O&F;
A letter accepting the RA report has been signed by the designated Regional
official. The date of the letter is entered into WasteLAN as the RA
completion date (C2101 = RA); and
A Final Superfund Site Close-Out Report has been prepared.
Definition of Accomplishment:
The final RA is complete on the date the Regional Administrator signs the Final
Superfund Site Close-Out Report documenting completion of the final RA. The
appropriate date must be recorded in WasteLAN as the actual completion date
of the "Close-Out Report" RA subevent (C2101 = RA and C3101=CL).
Changes in Definition FY 93 - FY 94:
This activity is now a SCAP target instead of a SCAP measure.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. This is a SCAP target.
FF-16 RA Duration
Definition:
The objective of this measure is to project the success, as well as the complexity,
of the Federal Facility enforcement Superfund program. The measure will also
enable management to focus on sites where additional emphasis on enhancing
the pace of response activities may be required. Duration trends will provide a
basis for evaluating the progress Federal agencies are making in performing
RAs in as timely a manner as possible.
Definition of Accomplishment:
This measure will look at Regional performance by analyzing the average
duration from RA start to RA completion for sites scheduled for RA completion
in FY 94. Durations will be calculated using the actual RA start dates and the
actual RA completion dates in CERCLIS. The RA start and RA completion
definitions are contained in this Manual.
A-123 April 1994
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OSWER Directive 9200.3-14-2
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
This is a SCAP reporting measure. CERCLIS will be used to calculate durations.
HQ will perform the analysis.
FF-17 Timespan from RI/FS Start to RA Complete
Definition:
The objective of this measure is to focus on the timespan of essential
components of the remedial pipeline. This measure reflects success in reducing
the length of time needed to complete remedial activities at Federal Facilities.
Trends analyses will address the need for continuous improvements relative to
meeting OFFE goals.
Definition of Accomplishment:
This measure will look at Regional performance by analyzing the average
duration from RI/FS start to RA completions for Federal Facility OUs
scheduled for RA completion in FY 94. The timespan will be calculated using
the actual RI/FS start date and actual RA completion dates in CERCLIS. The
RI/FS start and RA completion definitions contained in this Manual will be
used in the analysis.
Changes in Definition FY 93 - FY 94:
Special Planning/Reporting Requirements:
This is a SCAP reporting measure. Data from CERCLIS will be used to calculate the
timespan. HQ will perform the analyses.
FF-18 Removal/ERA/RCRA Corrective Actions - Start
and Completion
Definition:
Removal actions and ERAs are defined in CERCLA as the cleanup or removal
of released hazardous substances from the environment, and the necessary
actions taken in the event of the threat of release of hazardous substances into
the environment. Removal actions and ERAs are conducted in response to
emergency, time critical, and non-time critical (NTC) situations at NPL and
April 1994 A-124
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OSWER Directive 9200.3-14-2
non-NPL sites. Long-term O & M should not be conducted under the
removal.
Definition of Accomplishment:
Removal/ERA Start Date: Date the Federal agency begins actual on-site removal
work, or the date of Action Memorandum signature, or other decision
document signature/approval (C2101=RV). EPA must document the work
start with a memorandum to the file with the Pollution Report (POLREP) or
other documentation from the facility attached. The date must be reported in
WasteLAN as the actual start date.
Removal/ERA Completion Date: Actual date the Federal agency has demobilized,
completing the scope of work set forth in the Action Memorandum or other
decision document (C2101=RV). EPA must document the completion with a
memorandum to the file with the final POLREP or other documentation from
the facility. The date must be reported in WasteLAN as the actual completion
date.
RCRA Corrective Action Start, Section 3008 (H): For RCRA Section 3008(H) under
a unilateral order, the start date is the date the order is signed by the designated
Regional official. For starts under an order on consent, the start date is the date
the order is filed with the Regional Hearing Clerk. For starts under a permit,
the start date is the date the permit is issued as final by the State or Region,
whoever has permitting authority.
RCRA Corrective Action Start, Section 7003: For corrective actions initiated under
RCRA Section 7003, the start date for both unilateral and consent orders is the
effective date of the order.
RCRA Corrective Action Completion Both Sections 3008(H) and 7003: The
completion date is the date the facility has certified to EPA that it has
completed all the activities required by the order and EPA has reviewed and
approved the certification.
Changes in Definition FY 93 - FY 94:
Addition of RCRA Corrective Action starts and completions. Included
documentation requirements.
Special Planning/Reporting Requirements:
See Definition of Accomplishments. RCRA Orders are reported in WasteLAN
as C1701=RR (RCRA Order) and C2771=3008H or 7003. This is a STARS/SCAP
reporting measure.
A-125 April 1994
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OSWER Directive 9200.3-14-2
FF-19 Federal Facility NPL Deletion
Definition:
Site completion (another name for a deletion candidate) is the point at which all
response actions have been completed and no further response action is
appropriate to protect public health and the environment. Pursuant to Section
300.425(e)(l) of the National Oil and Hazardous Substance Pollution
Contingency Plan (NCP), sites can be deleted or recategorized on the NPL, in
consultation with the State, if one or more of the following criteria are met:
Federal agency has implemented all appropriate response actions required
by EPA;
Based on the RI, it is determined that the release poses no significant threat
to human health or the environment and, therefore, taking remedial
measures are not appropriate.
Deleting a site from the NPL does not eliminate the site's eligibility for future
actions. The deletion process can be divided into three phases: initiation
phase, public notice and comment phase, and the final (deletion) phase.
Definition of Accomplishment:
Deletion Start Date: The date the Regional Administrator approves the Final
Superfund Site Close-out Report. Regions and HQ should work closely with
the Deletion Coordinator to prepare the documents necessary to delete a site
from the NPL. This is reported in WasteLAN as the actual start date (C2101 =
ND).
Deletion Completion Date: The date the responsive summary is approved by the
Regional Administrator. (The Regional Administrator will then publish the
notice of deletion in the Federal Register.) This is reported in WasteLAN as the
actual completion date (C2101 = ND).
Changes in Definition FY 93 - FY 94:
Special Planning/ Reporting Requirements:
See Definition of Accomplishment. This is a SCAP reporting measure.
April 1994 A-126
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H-»
N>
EXHIBIT A-14
FEDERAL FACILITY PLANNING REQUIREMENTS
Planning Requirements
STARS?
SCAP?
FF-5
RI/FS Starts -
First and
Subsequent
FF-2
FFA/IAG
FF-4
Federal
Facility
Dispute
Resolution
FF-3
FFA/IAG
Completions
FF-1
Base Closure
Decisions
Operable
Unit
Whole
Site
Operable
Unit
Whole
Site
Site
Specific
Site
Specific
Site
Specific
Site
Specific
Planned/Reported Semi-
Annually, Annually or Both ?
Planned Site-Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Reported Site-Specifically or
in Non-Site Portion of
WasteLAN?
8
tn
-------
>
OO
EXHIBIT A-14 (continued)
FEDERAL FACILITY PLANNING REQUIREMENTS
FF-9
RD Starts -
First and
Subsequent
FF-7
RI/FS
Completions
(RODs) - First
and Subsequent
FF-8
RI/FS
Duration
FF-6
Timespan
From NPL
Listing to
RI/FS Start
FF-10
RD
Completions
- First and
Subsequent
Planning Requirements
Planned/Reported Semi-
Annually, Annually or Both?
Planned Site-Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Operable
Unit
Operable
Unit
Operable
Unit
Operable
Unit
Reported Site-Specifically or
in Non-Site Portion of
WasteLAN?
Site
Specific
Site
Specific
Site
Specific
Site
Specific
Site
Specific
m
3
n
--
K)
O
O
OJ
I
t i
*
-------
(>
K)
EXHIBIT A-14 (continued)
FEDERAL FACILITY PLANNING REQUIREMENTS
>
FF-11
RD
Duration
FF-12
RA Starts -
First and
Subsequent
FF-14
RA
Completions
- First and
Subsequent
FF-15
Final RA
Completions
FF-13
Timespan
From ROD
Signature to
RA Start
Planning Requirements
Planned/Reported Semi-
Annually, Annually or Both?
Planned Site-Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Operable
Unit
Operable
Unit
Operable
Unit
Operable
Unit
Reported Site-Specifically or
in Non-Site Portion of
WasteLAN?
Site
Specific
Site
Specific
Site
Specific
Site
Specific
Site
Specific
o
~
w
q
to
-------
>
>-t
EXHIBIT A-14 (continued)
FEDERAL FACILITY PLANNING REQUIREMENTS
Planning Requirements
STARS?
SCAP?
Planned/Reported Semi-
Annually, Annually or Both?
Planned Site-Specifically?
Planned/Reported on
Operable Unit or Whole
Site Basis?
Reported Site-Specifically or
in Non-Site Portion of
WasteLAN?
FF-16
RA Duration
Measure
Annual
No
Operable
Unit
Site
Specific
FF-17
Timespan
From RI/FS
toRA
Completions
Measure
Annual
No
Operable
Unit
Site
Specific
FF-18
Removal/ERA/
RCRA
Corrective
Action Starts
and Completes
Measure
Measure
Both
Yes
Whole
Site
Site
Specific
FF-19
Federal Facility |
NPL Deletion
Measure
Both
Yes
Whole
Site
Site
Specific
O
tn
g
8
r-f
fD
-------
I
1
o
o
£ OJ
EXHIBIT A-15
LONG-TERM ACTION FLOW CHART
Associated RA Activities
RA Start
C2101=RA
RA On-Site
Construction
ACT-5
C2101=RA,
C3101=RO
Final RA Activities
Operational and
Functional Completion
C2101=RA, C3101=OF
and
RA Complete (RA
Report)
ACT-6
C2101=RA
Final RA Construction
Completion (Preliminary
Close-Out Report)*
ACT-7
C2101=RA, C3101=CC
Five-Year Review
Start
ACT-9
C2101=FA
Five-Year Review
Completion
C2101=FA
Site Completion
(Final Close-Out Report)
C2101=RA, C3101=CL
f
n
IT.
ft
* NOTE: A Preliminary Close-Out Report is not required if the Region immediately prepares a Final Superfund Site
Close-Out Report.
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