United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9202.1-10-1
EPA540-R-93-053
PB93-963271
March 1993
Superfund
vvEPA Compendium of Good Ideas
Models of Success and
Lessons Learned
Volume 1
Highlights
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Publication 9202.1-10-1
March 1993
SUPERFUND
COMPENDIUM OF GOOD IDEAS
Models of Success and Lessons Learned
Volume 1
Highlights
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
Superfund Revitalization Office
U.S. Environmental Protection Agency
Washington, DC 20460
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NOTICE
The policies and procedures described in this document are intended solely for the guidance
of government personnel. They are not intended, and cannot be relied upon, to create any
rights, substantive or procedural, enforcezible by any party in litigation with the United
States. The Agency reserves the right to act at variance with these policies and procedures
and to change them at any time without public notice.
Additional copies of this document may be obtained from the National Technical Information
Service (NTIS) at:
NTIS
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650
11
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCV
WASHINGTON, D.C. 20460
MAK
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT:
FROM:
Compendium of Good Ideas^
TO:
Richard J. Guimond
Assistant Surgeon Genera
Acting Assistant Administrator
Addressees
i
This memorandum transmits the Compendium of Good Ideas
I Compendium), a compilation of Regional solutions to the
challenges of implementing the Superfund program.
I am proud to send you the Compendium because it
demonstrates the creative energy of the Superfund program. Last
year, I challenged all of us to suggest ways to make Superfund
more efficient, effective, and equitable. The Superfund
Revitalization Office (SRO) sent teams to each Regional office
gathering innovative ideas, which are presented here in two
volumes: Volume 1, a showcase of Superfund ideas; and Volume 2,
a reference source with descriptions of almost 250 items.
The C7mp?n
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-2-
Addressees:
Deputy Regional Administrators
Assistant Regional Administrators
Waste Management Division Directors
Environmental Services Division Directors
Regional Counsels
Scott Fulton, OE
OSWER Office Directors
Lisa Friedman, OGC
Bill White, OE
Mike Bower, 0AM
All Superfund Employees
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COMPENDIUM OF GOOD IDEAS
Models of Success and Lessons Learned
VOLUME 1
TABLE OF CONTENTS
SECTION PAGE
EXECUTIVE SUMMARY vi
Introduction vi
Volume 1 vi
Volume 2 viii
Communication viii
INTRODUCTION 1
Organization of the Compendium , 1
Volume 1 1
Volume 2 1
BACKGROUND 3
Formation of the Superfund Revitalization Office 3
Regional Visits 3
HIGHLIGHTS OF REGIONAL INITIATIVES 4
ARCS Contracts Management Procedures 4
Door-to-Door Congressional Briefings 5
Region 2/New Jersey ROD Forum 6
Cost Recovery Documentation 7
EPA/DOJ Relationship 7
Field Administrative Support Personnel 8
Disaster Response Procedures 9
In-House RI Preparation 10
Compliance Oversight Procedures 11
IGCE Coordination 12
State Involvement 12
Streamlining Initiatives/Lightning ROD
Pilot Project 13
Innovative Community Involvement Techniques 14
Budget Planning Using IGCEs 15
Targeted Industry PA/SIs 16
iii
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COMPENDIUM OF GOOD IDEAS
Models of Success and Lessons Learned
VOLUME 1
TABLE OF CONTENTS
(continued)
SECTION PAGE
Bureau of Reclamation Removal Support 17
Plug-In ROD 18
Alternative Contracting for Rapid Response 19
Property Values and Lender Liability
Outreach Activities 20
LIST OF ACRONYMS 21
GOOD IDEA TEAR SHEET
IV
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ACKNOWLEDGEMENT
The Superfiind Revitalization Office would like to thank the Regional staff and
management that participated in the SRO's Regional office visits and
contributed the good ideas for inclusion in this Compendium. Although too
numerous to thank individually, this compendium presents their good ideas.
Appreciation is also extended to the individuals that participated in the Regional
visits. These individuals include Sue Andersen, Barbara Bach, Bruce Bakaysa,
Felicia Barnett, Tai-Ming Chang, Filomena Chau, Lance Elson, Peter Feldman,
Tim Fields, Awilda Fuentes, Linda Garczynski, Lois Gartner, Mike Gifford,
Trish Gowland, Tim Grier, JoAnn Griffith, Ann Hamann, Ben Hamm, Pat
Hawkins, Robert Heffernan, Loren Henning, Stan Hitt, Ronald Jackson, Terri
Johnson, Ika Joiner, Sven-Erik Kaiser, Carolyn Kenmore, Amy Legare, Ken
Lovelace, Jim Maas, Shahid Mahmud, Jennifer Maloney, Richard Nalesnik,
Charles Openchowski, Pam Phillips, Ceil Price, Earl Salo, Joe Santarella, Ken
Skahn, Bill Steuteville, Chris Thomas, Patricia Tidwell, Jan Young, Stuart
Walker, Kay Waters, Ron Wiley, Candace Wingfield, and Kerry Wolferts.
This Compendium would not have been possible without the generous
assistance provided by all involved. Special thanks is also extended to Beth
Aschinger, Barb Dean-Hendricks, Pat Martz Kessler, and Cathy O'Connell for
their support in this effort.
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EXECUTIVE SUMMARY
Introduction
In October 1991, the Environmental Protection Agency announced a series of Superfund
revitalization initiatives, with the mandate to seek ways to increase the efficiency,
effectiveness, and equity of the Superfund program. As one element of this agenda, the
Superfund Revitalization Office (SRO) embarked upon a series of visits to each of EPA's ten
Regional offices seeking innovative ideas, successfully implemented policies and practices,
and lessons learned from past actions. During the Regional visits, the SRO spoke to both
staff and managers involved in implementing the Superfund program, thus ensuring that the
full scope of Superfund experiences was represented. This Compendium of Good Ideas.
Volumes 1 and 2, presents some of the innovative or good ideas, successes, and lessons
learned discussed during these visits.
The entries selected for inclusion in this Compendium of Good Ideas reflect several over-
arching themes that are common among many of the Regional offices. While the individual
entries range from procedural tools to community involvement activities, these over-arching
themes indicate the broad array of Superfund initiatives that are being undertaken. These
themes can be summarized as follows:
• Cooperative streamlining initiatives;
• Enforcement streamlining practices;
• Removal program procedures and activities;
• Remedial program challenges and efforts to improve program performance;
• Contract management and process enhancements;
• Internal communications efforts;
• External communications (e.g., community relations); and
• State activities and relationships with EPA.
Within these categories, the majority of the entries deal with methods to promote
consistency, reduce duplication, conduct training, share information, build teams, and
support EPA staff.
Volume 1
The entries in Volume 1 illustrate, in some detail, measures undertaken in each Regional
office to improve the implementation of the Superfund program. The entries provided in
Volume 1 are in no way intended to imply that this is the only activity the Regional office is
pursuing to achieve program improvements or that these are the best ideas identified by the
SRO. Rather, the entries in Volume 1 are highlights of the unique, innovative, or
transferable initiatives identified. A brief description of the 19 Volume 1 entries, organized
by the above-specified categories, is provided below.
VI
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Three cooperative streamlining initiatives undertaken by the Regions are included in Volume
1: Plug-In ROD, Targeted Industry PA/SIs, and Streamlining Initiatives/Lightning RODs.
Region 9 designed a "Plug-In" Record of Decision that preserves the flexibility of the
Superfund process while accelerating site cleanups. Region 8 implemented a pro-active site
discovery program whereby sites are grouped for screening and preliminary sampling in
order to focus Regional resources on the most hazardous sites. Region 6 formalized case
teams and implemented a "Lightning ROD" pilot project that saves time and resources while
improving the quality of Superfund work.
Entries relating to enforcement streamlining initiatives include Cost Recovery
Documentation, EPA/DOJ Relationship, and Compliance Oversight Procedures. The Cost
Recovery Documentation entry provides information on Region 3's development and
implementation of cost recovery documentation packages, while the EPA/Department of
Justice Relationship entry outlines the initiatives that contribute to the positive working
relationship between Region 3 and the Department of Justice. Region 5's compliance
oversight entry highlights procedures for monitoring and enforcing administrative and judicial
orders and decrees.
Several Regions presented initiatives concerning the Removal and Remedial program
procedures and activities. These initiatives include the widely acclaimed Field
Administrative Support Personnel concept developed and implemented by Region 3, the
Disaster Response Procedures used by Region 4 in the wake of Hurricane Andrew, the
Bureau of Reclamation Removal Support that Region 8 receives, and the In-House RI
Preparation program implemented by Region 4.
Four Volume 1 entries relate to contracts management: ARCS Contracts Management
Procedures used successfully by Region 1, two Independent Government Cost Estimate
entries, and an alternative contracting entry. The IGCE Coordination entry describes the
systems and materials developed by Region 5 to improve the quality of cost estimates, while
the Budget Planning Using IGCEs entry details Region 7's implementation and application
of Independent Government Cost Estimates. The Alternative Contacting for Rapid Response
entry outlines the strategies successfully used by Region 10 to expedite Removal and
Remedial actions.
Three external communication ideas are presented in Volume 1. Region 2 implemented a
program of Door-to-Door Congressional Briefings that increased the awareness and
understanding on the part of the Congressional members regarding the Superfund process and
specific sites in their States. Region 6 initiated a number of Innovative Community
Involvement Techniques including store-front offices, a toll-free Superfund information line,
and a "Superfund 101" class. Region 10 performed Property Values and Lender Liability
Outreach Activities in an effort to educate and address the concerns of people regarding the
effect of Superfund on property values.
Two State-related initiatives are included as Volume 1 entries: New Jersey ROD Forum and
State Involvement. Region 2 held a forum with the State of New Jersey to discuss the
required elements of a Record of Decision and the parameters under which New Jersey
VII
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Superfund staff operate. Region 5 is participating in several ongoing initiatives directed at
encouraging a greater level of State participation.
Volume 2
The entries in Volume 2 are more numerous than the entries in Volume 1, but less detail is
provided on these entries. Approximately 250 entries are included in Volume 2. Volume 2
is designed to be a reference document for Superfund staff. It presents initiatives and
innovations across the spectrum of Superfund program areas. The entries in Volume 2 are
organized by the eight theme categories referenced previously and provide a short definition
of a problem, the action taken, and any benefits associated with each initiative. The entries
are designed to provide enough information to determine if a particular initiative merits
further investigation and provides a contact name and telephone number to obtain additional
information.
Communication
Distribution of the Compendium of Good Ideas is the first step in sharing successful
Superfund program management ideas across the Regional offices and Headquarters.
Additional mechanisms will be developed to continue communicating and updating the ideas
presented in the compendium and to gather new ideas. Possible approaches include national
meetings, fact sheets, newsletters, demonstrations, presentations, a speakers bureau,
electronic bulletin boards, teleconferences, and other training methods. A Good Idea Tear
Sheet is attached at the end of each volume; of the Compendium of Good Ideas, to invite
continued participation in the sharing of id^as.
Vlll
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INTRODUCTION
This Compendium presents the results of a series of Regional office visits conducted to
solicit information on innovative and unique ideas to improve the Superfund program. The
Superfund Revitalization Office (SRO), with support from several Headquarters offices,
identified a multitude of initiatives implemented by the Regional offices to enhance Superfund
program practices. These initiatives increased the speed and consistency of site cleanup,
improved community and internal communications, and enhanced the overall performance of
the Superfund program. The SRO identified many ideas that may be transferrable from one
Regional office to another to strengthen the Superfund program.
Organization of the Compendium
The Compendium of Good Ideas is organized in two volumes. Volume 1 is intended
primarily for Superfund program managers and presents a sampling of the best ideas
discussed during the SRO Regional visits, while Volume 2 is designed as a resource tool for
Superfund program staff. Volume 1 contains descriptions of some Regional initiatives that
the SRO found unique, innovative, or transferrable. Volume 2 presents additional Superfund
program initiatives identified during the SRO's Regional visits, however, less information is
provided on these entries.
Volume 1
Volume 1 introduces the organization of the Compendium with sections providing
background information on the SRO and the Regional visit process. Highlights of Regional
innovations are presented in some detail in Volume 1 and are organized by Regional office.
Volume 2
Volume 2 is designed to be a reference document for Superfund staff. It presents initiatives
and innovations across the spectrum of Superfund program areas. The entries in Volume 2
do not provide all of the information required to implement an initiative, but are designed to
provide an overview of each initiative. The descriptions provide a short definition of the
problem, the action taken, and any benefits associated with each initiative. The entries are
designed to provide enough information to determine if a particular initiative merits further
investigation and provides a contact name and telephone number to obtain additional
information.
The entries selected for inclusion in the Compendium reflect several themes that the SRO
found are common among many of the Regional offices. These over-arching themes indicate
the broad scope of initiatives undertaken by the Regional offices. Volume 2 is organized into
the following categories or over-arching themes:
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• Cooperative Streamlining
• Enforcement Streamlining
• Removal
• Remedial
• Contracts
• Internal Communications
• External Communications
• States
Within each category, entries are divided into subcategories to make Volume 2 of the
Compendium more useable. For example, the Enforcement Streamlining category includes
subjects such as Enforcement Models, Settlement Strategy, and Information Collection (as
well as others) as subcategories. This allows the Compendium user to locate all entries
related to a specific subject contained within a category.
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BACKGROUND
Formation of the Superfund Revitalization Office
On October 2, 1991, the Environmental Protection Agency (EPA) named the Office of Solid
Waste and Emergency Response Deputy Assistant Administrator Richard Guimond to the
new post of National Superfund Director and announced the formation of the SRO. The
SRO was given the responsibility for seeking ways to improve the efficiency, effectiveness,
and equity of the Superfund program.
The SRO is comprised of staff from EPA's Regional program offices and several
Headquarters offices to provide representation across the broad breadth of Superfund
experience. Regional representatives include Remedial Project Managers (RPMs), On-Scene
Coordinators (OSCs), and Office of Regional Counsel (ORC) attorneys. SRO members from
the Office of Solid Waste and Emergency Response, the Office of Emergency and Remedial
Response, the Office of Waste Programs Enforcement, the Office of Solid Waste, the Office
of Enforcement, the Office of General Counsel, the Office of Administration and Resources
Management, the Office of Research and Development, the Office of Federal Facilities
Enforcement, and the Environmental Response Team (ERT) represent the Headquarters
Superfund program. In addition, the SRO has representatives from the DOJ, the Bureau of
Reclamation (BuRec), the Department of Defense, and the Agency for Toxic Substances and
Disease Registry.
Regional Visits
In late 1991 and early 1992, Rich Guimond visited all of EPA's ten Regional offices to
discuss Regional views regarding the challenges confronting the Superfund program and
possible approaches to those challenges. The SRO formed a team to follow up on those trips
by visiting the Regional offices to continue exploring opportunities to improve the Superfund
program. The Regional visits were conducted during July through November 1992 with the
SRO Team spending two days in each Region. These trips were not audits, Regional
reviews, or training sessions; rather, the SRO Team listened to each Region's ideas regarding
how to improve Superfund.
Teams consisting of SRO members and other Headquarters personnel traveled to each EPA
Regional office to seek innovative ideas, successes, and lessons learned from staff and
managers working in and with the Superfund program. While in each Region, the SRO
Team conducted a series of focus group sessions with Regional personnel and conducted an
entry and exit meeting with senior Regional managers. The focus group sessions were held
with both staff and program managers and included the entire scope of Superfund activities:
removal/site assessment, remedial, internal communication, information management,
contracts, potentially responsible party (PRP) searches, cost recovery, and community and
governmental affairs.
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HIGHLIGHTS OF REGIONAL INITIATIVES
The 19 entries presented below highlight some of the best initiatives identified.
Approximately 250 Regional ideas are presented in an abbreviated format in Volume 2 of the
Compendium.
ARCS CONTRACTS MANAGEMENT PROCEDURES
Contact: Hilary Kelley, Chief, Super!und Contracting Section, Region 1
617/565-4880
Maggie Leshen, Chief, Contracts Management Section, Region 1
617/573-5795
Region 1 is a leader in Alternative Remedial Contracts Strategy (ARCS) contract
management. A combination of initiatives is the basis for success in the Region. These
efforts include developing successful working relationships between the project officers (POs)
and the contracting officers (COs), the staff and the ARCS contractors, and the Region and
the United States Army Corps of Engineers (USAGE), as well as developing tools to
facilitate effective ARCS contract management.
The POs and COs have an excellent working relationship, with their roles and responsibilities
defined in formal Memoranda of Understanding (MOU) addressing award fees, subcontracts,
new work assignments, and future work. The POs and COs share a mutual respect for each
others' expertise, objectives, and deadlines. The COs attend health and safety training, are
familiar with the sites, and understand the nature of the work. Communication between the
POs and COs in all Region 1 offices is facilitated by the local area network (LAN). In the
absence of one CO, other COs can access floppy disks containing contract information. The
types of contract information that may be electronically accessed include contract status,
current work assignments, and modifications.
A key element in managing ARCS contracts has been an active ARCS Regional Management
Team, consisting of Branch Chiefs representing the Waste Management Division (WMD) and
Planning & Management Division and supported by the Superfund Contracting Section and
the Contracts Management Section. Regional managers and the contracts program staff met
with the ARCS contractors in the spring of 1992 to discuss the Region's priorities and goals
and to exchange information with the ARCS contractors. The Region followed up with each
contractor individually to obtain their feedback and ideas. The Region is planning to repeat
this process annually because Regional interaction with the ARCS contractors during the
planning stage results in better contractor understanding of Regional expectations and the
work to be undertaken, hence better contractor performance.
In addition to the Regional Management Team, the New England Division of the USAGE
provides the Region with technical assistance for ARCS design and construction activities and
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Independent Government Cost Estimates (IGCEs). A MOU is being developed among the
Region's POs, COs, and RPMs to address IGCE roles and responsibilities.
Another contracts management tool used by the Region is the "Seven-Day Scoping Letter."
This tool is used by RPMs to ensure that the contractor shares an understanding of the
project's scope. All contractors are required to submit a "ball-park" cost estimate within
seven days following the work assignment kick-off meeting. This requirement ensures that
the contractor does not spend too much time developing a work plan without a clear
understanding of the project's scope.
In addition, the Region developed a system to track program management costs to achieve
the fiscal year (FY) 1992 15 percent program management cost goal. This system requires
that all ARCS contractors submit estimates of program management costs for FY 1993,
which were either approved or reduced, without negotiation. Oversight of contractor
performance includes evaluation of the contractor's success in meeting their program
management goal.
Finally, a database system also was developed to track payments for and movement of
government-purchased equipment, so equipment can be more easily shared among
contractors. This system has been distributed to the other Regions.
DOOR-TO-DOOR CONGRESSIONAL BRIEFINGS
Contact: Peter Brandt, Congressional Liaison, Region 2
212/264-7834
Region 2 implemented a program of door-to-door Congressional visits to brief members of
Congress and their staff in Washington, D.C. on the status of Superfund sites in their States
and districts. This effort was initiated by the Region in 1992 and was very well received by
Congressional members and their staff. All Senate and House members representing districts
in Region 2 chose to participate in the individual briefings. A total of 30 briefings were
presented in 1992 and the Region plans to continue these in the future. The Region not only
provides information on the current status of existing sites, but also educates Congressional
members that currently do not have existing sites in their districts on what they can expect if
a site is identified in their State or district. These briefings increased awareness and
understanding on the part of Congressional members regarding the Superfund process and
sites in their State or districts.
The briefings were conducted by teams comprised of the Director or Deputy Director of
Superfund, Branch Chiefs, Section Chiefs, and Congressional Liaison staff. They spoke to
Congressional members and staffers including Legislative Assistants, Administrative
Assistants, and Press Secretaries. The personalized briefings addressed the individual needs
of Congressional offices. For example, the Puerto Rico delegation appreciated the personal
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attention and the Region's ability to address the language and cultural needs of the
delegation.
For each briefing, the Region prepared a book that provided an overview of all Superfund
sites in Region 2 and the current status of each Superfund site in the respective member's
State or district. The door-to-door briefings allowed the Region to provide information and
updates on all sites within a State or district, not just the high profile sites. The Region's
ability to provide specific information on each site is very helpful to Congressional staff since
many are not familiar with the sites in their State or districts or the current status of the sites.
These briefings keep the Congressional offices apprised of the status of Superfund sites and
allow them to respond to questions raised by their constituents.
REGION 2/NEW JERSEY ROD FORUM
Contact: Charles Tenerella, Chief, Central New Jersey Section, Region 2
212/264-9382
At the request of New Jersey's Superfund program director, the Region held a two-day
Record of Decision (ROD) forum with the State. The forum provided an opportunity for the
Region to communicate to State officials the essential and critical elements that must be
included in a ROD per Federal regulations contained in the National Contingency Plan
(NCP). In turn, Regional staff were made: aware of the parameters under which the New
Jersey Superfund staff must operate, especially concerning the application of State applicable
and relevant requirements (ARARs) and the preparation of RODs. The forum was an
extremely useful and successful event, and will be held again in FY 1993.
The Region distributed packets of information to State staff containing a "checklist" (i.e.,
basic outline) of the ROD format and other applicable materials. J-ectures, working sessions,
and EPA/State team discussions were held at the forum. The project teams were able to
communicate the differences between Federal and State regulations and systems and
differentiate between real and procedural difficulties.
Total quality management (TQM) exercises were held to discover the procedural issues
restraining both the Region and the State. When an issue could not be resolved by the teams
(e.g., cleanup levels), it was escalated to management and a presentation was given on the
issue. The managers listened to the presentations and if the issue was able to be resolved at
that time, decisions were made accordingly.
The forum provided an environment for suff to identify ROD issues and to work toward
resolution together. The Region and State: worked together to create a scenario that would
allow RODs to move forward without delays. For one ROD, an interim remedy was chosen
until the remaining issues could be resolved. On another site, the ROD was divided into
operable units to allow site cleanup to proceed.
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COST RECOVERY DOCUMENTATION
Contact: Leslie Vassallo, Environmental Protection Specialist, Region 3
215/597-3171
The cost recovery documentation packages developed by Region 3 are national models in this
area. As a result of the process they created, Region 3 maintains and provides to DOT
documents demonstrating the amount of money expended and the specific work activities that
are undertaken at a particular site. Complete packages of cost information, including both
financial and "work performed" documentation, are available to the Region and DOJ in a
user-friendly format.
In 1984, the Region began dedicating resources to provide DOJ with a detailed breakdown of
site-specific tasks and the costs associated with these tasks. In addition to providing DOJ
with a summary of financial information, the Region describes and explains each task
undertaken at a site through the use of "work performed" documents. These documents
include work assignments, technical direction documents, acknowledgments of completion,
and delivery orders. It is difficult and time intensive for DOJ to find this information,
especially for old contracts. Because the Region houses and maintains the "work performed"
documents in a central file room, Regional staff have easy access to the task-by-task
reporting information. As a result of Region 3 providing this information, DOJ is able to
focus on successfully litigating cases, rather than gathering the necessary documentation.
Preparation of the Region's cost recovery documentation packages is a team effort. The
Regional Finance Office compiles and reconciles the payroll, travel documents, and
contractor invoices. The Cost Recovery Section compiles and summarizes the "work
performed" information in the cost summary report. Finally, the Region works closely with
DOJ to continuously improve the cost packages.
EPA/DOJ RELATIONSHIP
Contact: Seth Low, Associate Chief, RCRA/CERCLA Remedial Branch, Region 3
215/597-3977
Region 3 and DOJ have developed a very positive working relationship. This relationship
developed as a result of a number of initiatives, including encouragement from EPA
management for staff to work directly with DOJ when problems arise. Improved working
relations helped speed up the enforcement process and fostered mutual respect between the
Region and DOJ.
The proximity of Region 3 and DOJ offices in Philadelphia allows Regional and DOJ staff to
meet in person as needed. In addition, the Region and DOJ have a MOU outlining roles,
responsibilities, and turnaround time on referrals. Regional and DOJ management are
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committed to making their relationship work. Regional management encourages staff to
work towards building solid relationships, to solve problems when they arise, and to take
extra steps to meet DOJ's needs. For instance, DOJ experienced difficulty obtaining
Regional phone directories for staff use. In response to DOJ's need, Region 3 collected
directories and delivered them to DOJ.
A key mechanism for building and maintaining close relations has been the monthly docket
reviews conducted by the WMD, the ORC, and DOJ. Attendance by DOJ increased the
sense of teamwork and accelerated the enforcement process since all relevant parties are
present at the docket reviews. The Region and DOJ prevent problems before they occur by
providing early warnings to each other on volatile issues.
Additional communication improvements resulted from DOJ extending the Amicus system,
an internal DOJ word processing system, to Region 3. The system provides access to legal
research tools and allows the Region to send word processing documents directly to DOJ
attorneys for review. As a result, both the Region and DOJ save time and resources by
working in the same format.
FIELD ADMINISTRATIVE SUPPORT PERSONNEL
Contact: Chris Thomas, Enforcement On-Scene Coordinator, Region 3
215/597-4458
Region 3 developed and implemented the widely acclaimed Field Administrative Support
(FAS) personnel concept to provide support to the Removal program. The FAS personnel
provide the OSCs with administrative record and contract management oversight support. In
response to the tremendous need for FAS, the Region re-allocated resources to increase
removal support staff. There are currently five FAS full-time equivalents, and the Region
plans to implement a program that assigns a lead FAS person to each site. The lead FAS
person will be dedicated from the start to the finish of the site project. The success of this
cross-divisional group consisting of FAS, site assessment officer, CO, PO, and contracts
specialist (CS) staff was recognized with an award as Superfund Regional Team of the Year.
The FAS staff provide on-site support that relieves a huge burden from OSCs and allows
them to focus on the physical site work. The FAS staff set up and maintain site
administrative record files which are color coded and maintained together at all times. The
FAS staff also track removal site cost documentation through a cost management tracking
system. Because several FAS staff were previously Office of Inspector General finance staff,
they have expertise in handling cost documentation. Docket preparation assistance is also
provided by FAS staff. Improved cost documentation and case preparation resulting from
FAS staff efforts directly contributes to successful cost recovery aclions.
Contract management oversight support by FAS staff includes maintaining invoice review
documentation, conducting "friendly" audits, and "sampling" sites to assess vulnerabilities.
8
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Emergency Response Cleanup Services (ERGS) invoices, progress reports, and routine
paperwork are reviewed by FAS staff. In addition to setting up management controls, FAS
staff track equipment and flag daily charges on EPA Form 1900-55. FAS staff follow
procedures and practices contained within a Regional handbook, which promotes consistency.
FAS staff also monitor Technical Assistance Team (TAT) hours and help with invoice
review. To provide continuity between site activities and the Regional contracts staff, the
FAS staff interact with COs and CSs on a regular basis. The contract support provided by
FAS staff decreases the Region's dependence on contractors for ERCS cost documentation.
DISASTER RESPONSE PROCEDURES
Contact: Mike Norman, Chief, Emergency Response Section, Region 4
404/347-3931
Region 4 mobilized their Disaster Field Office (DFO) prior to Hurricane Andrew's assault on
South Florida. The Region's response to Hurricane Andrew was based on their experiences
with Hurricane Hugo and the newly enacted Federal Response Plan. The DFO, two OSCs,
and several TAT contractors were mobilized to Florida prior to the arrival of Hurricane
Andrew. Once the storm passed, emergency response crews were ready for action. A
helicopter was used to survey those areas hit by the hurricane to identify large spills and
releases. Seventeen spill sites involving oil and/or chemicals were cleaned up in the wake of
Hurricane Andrew.
Region 4 coordinated their emergency response as part of the Federal Response Plan. The
Federal Emergency Management Agency (FEMA) notified the Region of a possible landfall
for Hurricane Andrew five days prior to the hurricane strike. Early notification by FEMA
allowed the Region to be proactive in its disaster response preparation. The Region
immediately began checking on the availability of OSCs, what current sites needed to go
forward, and what sites could be postponed. The Region mobilized the DFO, a 37-foot
trailer equipped with computer and communications equipment, two OSCs, and several TATs
to Florida the day before the hurricane so that they would be on location to begin immediate
cleanup. In addition, prior to the hurricane strike, the Region made arrangements through an
existing contract to have access to a helicopter and pilot immediately after the strike to look
for spill sites. After the hurricane landfall, two additional OSCs were deployed to Florida to
assist in cleanup activities.
The day after the hurricane strike, the OSCs used the helicopter to look at large known tank
sites to identify releases that would be immediately dangerous to public health and the
environment. The air surveillance allowed the OSCs to cover more area than would
otherwise be possible. The OSCs identified two large spills (100,000 gallons of Fuel Oil
No. 6 and 150,000 gallons of JP-4 jet fuel) and arranged for cleanup. In addition, the DFO
inspected 34 sites in Dade County. Nineteen sites either needed no cleanup or responsible
parties had already initiated cleanup. Fifteen sites were cleaned up by the DFO crew. The
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U.S. Coast Guard Strike Team, which was already on location with experienced spill cleanup
personnel and resources, assisted in the cleanup of four sites.
Cleanups performed by EPA primarily consisted of three activities: (1) overpack leaking
drums; (2) remove and stockpile contaminated soil on site; and (3) pump large spills back
into tanks. In addition, the OSCs identified seven drums of material of unknown origin and
arranged for the disposal of these drums. The Region took a "service-oriented" approach to
cleanup. They took care of immediate problems and left the disposal of contaminated
material to the property owners. The emphasis was on cleanup following the hurricane, not
enforcement, which allowed the DFO to focus on human health concerns.
IN-HOUSE RI PREPARATION
Contact: Don Hunter, Environmental Scientist/Regional Expert, Region 4
706/546-3171
Bill Bokey, Chief, Hazardous Waste Section, Region 4
706/546-3299
The in-house remedial investigation (RI) program is a great success in Region 4. Since
1985, Region 4 initiated/completed 14 in-house RIs (an average of two RIs per year), which
ranged from simple to complex. The staff enjoy the opportunities presented by the program
and benefit from the training experience. The program is cost effective and provides Region
4 with the ability to either take back or complete RI work initiated by others when necessary.
Overall, the in-house RI program gives the Region increased control over and impact on the
remediation of Region 4 Superfund sites.
The in-house RI program was developed by the Region 4 Remedial Branch and the
Environmental Services Division (ESD). It includes the combined efforts of ESD staff,
RPMs, and risk assessors. The applicable Division Directors agreed to work together in the
RI program without formal procedural documents. There are no established rules for the
division of labor in the RI work plan, rather the division of labor is decided on a site-by-site
basis. Region 4 has a structured approach for interdisciplinary peer review for the quality
assurance of the work product. The Region uses a TQM approach to meet their needs in the
absence of formal procedural documents. Under the Region's approach, ESD is responsible
for field coordination and data gathering. EiSD also supplies the RPMs with the field
investigation reports.
Prior to work plan development, scoping m^tings are held by the peer review group staff to
provide quality assurance up front. During the work plan development stage, scoping
meetings are held that include all staff with data needs, including the site risk assessors. The
ground water and soil data gathered during the RI are used for modeling purposes and the
modeling results are used in the risk assessment. Region 4 conducts multiple in-house RIs
simultaneously and coordinates field work deadlines. Coordination of field work activities is
accomplished without formal coordination protocols.
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There are many benefits resulting from the Region 4 in-house RI program. A study was
undertaken on the costs of conducting in-house RIs versus contracting for RI work. The
study findings confirmed an in-house RI cost savings of one-third to one-half over a
contractor-conducted RI. The in-house RI program is a morale builder and excellent training
for new and established Region 4 staff. Staff obtain hands-on experience in RI tasks and
how they should be performed. This improves their ability to provide high quality oversight
of RI work performed by contractors. The in-house RI experience also provides RPMs with
a more realistic perspective of contracts management, IGCE preparation, and the collective
aspects of field investigation.
COMPLIANCE OVERSIGHT PROCEDURES
Contact: Jim Mayka, Chief, Michigan/Wisconsin Remedial Response Branch, Region 5
312/353-9229
Region 5 established procedures for monitoring and enforcing Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) administrative and judicial orders and
decrees to ensure that expeditious, effective, and consistent enforcement actions are taken.
These procedures assist staff in determining and documenting the appropriate enforcement
response to violations of terms and schedules stipulated in orders and decrees. The Region
developed clear guidance and procedures, for the effective use of statutory authorities and
enforcement mechanisms in settlement documents, in response to an Office of Inspector
General audit report recommendation.
According to the Region's procedures, all non-compliance by PRPs of schedules or other
conditions established in an order or decree must result in an appropriate enforcement action,
accompanied by written documentation of that action. The procedures outline the elements
necessary to ensure timely, effective, and consistent enforcement responses. Upon
determining that a violation of the decree/order occurred, an appropriate enforcement
response is formulated by the RPM, OSC and Assistant Regional Counsel. The procedures
provide specific instructions for responding to each violation and include a range of potential
appropriate enforcement responses and detailed implementation instructions.
The procedures also institute an obligation on the part of the assigned RPM/OSC to report to
their supervisor and case attorney on a monthly basis as to the whether or not the PRPs are
in violation of the order or decree. The reporting format will allow the RPM/OSC to simply
indicate the PRP status of either "in compliance" or "in violation." Model formats for the
initial letter to the PRPs describing the non-compliance and the Recommendation of Action in
Response to Violation will be developed as violations are acted upon, pursuant to the outlined
procedures. New guidance is also being developed by Region 5 for preparation of Section
109(c) penalty action referrals, which will include a model litigation report and complaint.
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IGCE COORDINATION
Contact: Tom Short, Project Officer, Region 5
312/353-8826
Region 5 provides IGCE preparation support and training to all applicable staff through the
IGCE coordinator. In addition to developing systems and material for Region 5, the
coordinator has provided national leadership in improving Superfund's cost estimates. The
coordinator's primary role is to develop database systems on which to base cost estimates,
support Work Assignment Managers (WAMs) in IGCE preparation, and maintain and modify
the databases. The level of support and training is gauged by each sections' needs. A
separate database is developed for each type of work (e.g., RIs, PRP searches), with one
database for enforcement-lead sites and one for Fund-lead sites. These databases are based
upon historical information, listing the contractors and their past costs on work performed.
The databases are written in dBase III Plus, a user friendly software program, and are LAN
accessible.
The Region's IGCE coordinator began by creating a database to assist the RPMs and to be
used for training purposes for all groups that prepare IGCEs. Initially, all RPMs go through
the coordinator for assistance. Once the RPMs are up-to-speed, they can access the database
system directly, and the level of IGCE support will depend on the individual needs of the
RPMs. The process has helped the WAMs plan expenditures, write more detailed Statements
of Work (SOWs), and negotiate with contractors more effectively, resulting in EPA receiving
a higher quality of performance from its contractors.
Certain groups (e.g., Community Relations) have very specific scopes of work, allowing for
the development of a standardized SOW and database of information. Eventually, the
standard SOW and database will provide sufficient IGCE information to those groups,
diminishing the need to go through the IGCE coordinator. At that point, the coordinator's
role will consist of maintaining the databases and providing additional training and support
for specialty needs.
STATE D4VOLVEMENT
Contact: Jim Mayka, Chief, Michigan;Wisconsin Remedial Respionse Branch, Region 5
312/353-9229
Region 5 is participating in a number of ongoing initiatives directed at fostering a greater
level of State participation. Region 5 currently has a Superfund Memorandum of Agreement
(SMOA) with 5 of the 6 States in the Region and will have a SMOA with all 6 States by the
end of FY 1993. A SMOA between the Region and a State helps resolve disputes, promotes
understanding, and clarifies the issues and roles of both parties. In addition, under a TQM
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effort, the Region held training sessions with States to improve the level of understanding of
each other's position.
Under one initiative, the Region 5 State liaison staff are developing a policy on assigning
State leads at Superfund sites. The policy will be implemented in FY 1993 and will define
when and under what conditions it is appropriate for the States to take the lead at National
Priorities List (NPL) sites. The States' past performance and current work load will be taken
into consideration under the policy. Implementation of this policy will promote consistency
and certainty in the process of designating site leads.
Another Region 5 initiative involves including the States on the Regional Decision Teams
(RDTs) for SACM pilot studies undertaken at sites in their respective States. The inclusion
of the States on the RDTs will result in a joint EPA/State strategy, allow for the use of State
resources, and alleviate potential disputes that might otherwise arise.
In an effort to increase the opportunity for State participation, the Region held its annual
Removal program retreat at one of the Region 5 State's capital each year for the past two
years. The retreats included training sessions and provided a forum for informal information
exchange. The location of the retreat at States' capitals allows a greater number of State
employees to attend. The Region plans to continue holding the annual retreat at State
capitals, extending the opportunity to States not yet visited.
In addition to recent initiatives, Region 5 has a history of aggressively awarding CORE
Grants to States for the development of the infrastructures, data systems, and accounting
systems needed to develop and implement State Superfund programs. The Region also
continues to provide States with training and participation in EPA work groups (e.g.,
Biological Technical Assistance Group), policies, and guidance, especially when the subject
matter involves a particular State.
STREAMLINING INITIATIVES/LIGHTNING ROD PILOT PROJECT
Contact: Carl Edlund, Chief, Superfund Program Branch, Region 6
214/655-6715
Region 6 developed several initiatives to streamline the Superfund process. Among the
streamlining initiatives are case management teams and the Lightning ROD pilot project.
The Region formalized the case management team with an internal MOU. The Region 6
Lightning ROD pilot project is the first streamlining pilot project developed by EPA. The
pilot project pre-dates SACM and all other SACM-like pilot projects developed by other
Regions are based on the Lightning ROD pilot. Streamlining initiatives speed up the
Superfund process, while improving the quality of deliverables and reducing project costs.
The Region developed one general MOU among all participating programs involved in the
Superfund process and created a case management team approach to sites. The case team
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decides site priorities and assigns a lead office. The Region holds interdivisional as well as
Branch Chief meetings to involve all programs in site decisions. A case team approach also
is used to determine what constitutes "imminent and substantial endangerment," which may
require a shift in site priorities. In addition., the Region has a successful peer review
program in a variety of program areas to streamline the Superfund process.
Region 6 initiated the Lightning ROD pilot project for three sites (i.e., 2 creosote sites and 1
abandoned dump) in November 1991 to improve the quality and speed of site remediation.
As part of the Lightning ROD pilot, the Region completed planning and budgeting for the
sites prior to NPL proposal. The Lightning ROD pilot combines the RI, feasibility study
(FS), and remedial design (RD) concurrently to shorten the time spent in preconstruction
study and design. The Region reviewed pasit RI/FSs, RODs, and treatability studies to focus
the studies and long-term goals for the pilot sites. Additional techniques include the use of
expedited analytical data, standardized risk assumptions, expanded use of historical aerial
photographs, well-defined contract deliverables to reduce redundancy, and an emphasis on
waste quantification.
Region 6 involved the community relations staff at the beginning of the Lightning ROD pilot.
Open houses were held the day of NPL proposal for the sites to provide information to the
affected communities. The same opportunities for public interaction occurred for the pilot
project sites as for traditional Superfund sites, however within a shorter time frame. For one
of the sites, the community thought the Region was proceeding too quickly at the site so a
second public hearing was scheduled to explain the Region's activities.
Benefits of streamlining initiatives include saving time and resources and improving the
quality of Superfund work. The Region is 3 to 5 years ahead of the schedule for the three
sites included in the Lightning ROD pilot in comparison to an average, traditional Superfund
site. While a complete analysis of cost savings from the Lightning ROD process cannot be
conducted until completion of the RD, the Region is projecting a cost savings of up to 50
percent of the costs that would be incurred under the traditional Superfund process. In
addition to the projected cost savings, a number of the initiatives included in the pilot project
are likely to improve the quality of decision documents developed for these sites.
INNOVATIVE COMMUNITY INVOLVEMENT TECHNIQUES
Contact: Verne McFarland, Chief, Su]3erfund Information Manaigement Section, Region 6
(214) 655-6617
Region 6 initiated a number of innovative community involvement procedures including
store-front offices, a toll-free Superfund information line, a "Superfund 101" class, and
quarterly Superfund progress reports and ujxlates.
The concept of a store-front (or satellite) office was originally developed for the Vertec
Chemical site in Jacksonville, Arkansas. The Region now has three operational satellite
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offices and another one is scheduled to open in early 1993. These offices provide Region 6
with a surrogate presence in the community, which reduces travel cost and maximizes staff
time to devote to site cleanup. Satellite offices are effective as a local information resource,
community liaison mechanism, and a tangible symbol of EPA's commitment to community
involvement at Superfund sites.
In response to community concerns and information needs, Region 6 implemented a toll-free
Superfund information line that provides direct, no cost access to the Agency. The toll-free
line addresses a common concern that citizens cannot afford to call the Region for the
information they need. The toll-free line provides access to Superfund program staff for site-
specific information, provides general Superfund program information, access to reference
and guidance materials, a means to report suspected trespassing on Superfund sites, and a
means to report new and suspected hazardous waste sites. In addition, the Region conducts
follow up "quality service calls" to determine if Superfund information line met the users'
needs to their satisfaction.
Another innovative community involvement effort is the 3-hour "Superfund 101" training
sessions offered by the Region to citizens and local residents at newly listed Superfund sites
that explain the Superfund listing and remedial processes. During this training, role playing
is used to acquaint citizens with the various issues involved in the Superfund process and the
complexities associated with site cleanups. Shortly after the training session, a citizens'
scoping meeting is held to describe the general scope of the planned RI and to obtain the
public's input.
In addition, the Region prepares and circulates quarterly reports on progress at Superfund
sites to approximately 10,000 people on the Region 6 Community Relations mailing list.
These reports contain concise summaries of the background and remedial status of each NPL
site and give contact names in Region 6. The quarterly reports are being expanded to
include selected SACM and removal sites in addition to high profile Comprehensive
Environmental Response, Compensation, and Liability Information System (CERCLIS) sites
undergoing assessment. The reports also are useful as periodic updates to the print and
broadcast media on Superfund activities in Region 6.
BUDGET PLANNING USING IGCES
Contact: Mary Jo Wallerstedt, Chief, Resources and Contract Administration Section,
Region 7
913/551-7648
The implementation and application of IGCEs is an integral part of the continuous
improvements achieved within the Region 7 contracts management program. Approximately
$2.3 million in projected cost reductions resulted from the process improvements
implemented by the Region. These reductions are a direct result of the combined efforts of
POs, COs, and RPMs and the improvements made in writing the SOW, developing IGCEs,
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conducting scoping meetings, and negotiating work plans. In recognition of contributions to
the IGCE process and the resulting impacts on contracts management as a whole, cash
awards and certificates for excellence have been awarded to Regional staff.
The Region's IGCEs are prepared by RPMs and reviewed by POs. To assist the RPMs,
zone administrative procedures (ZAPs) were written and a Lotus 123 spreadsheet was created
by a CO. The ZAPs define the rules on roles and responsibilities and the spreadsheet
provides for a task-by-task budget projection with the appropriate multipliers that
automatically adjust costs. The spreadsheet was placed on the LAN to provide accessibility
to the RPMs, and a user-friendly operating manual was prepared.
The IGCE is based on the SOW for the tofcil project, not by the different phases of the
project. This enhances the Region's ability to determine appropriate adjustments to the
project's budget and the incremental funding plan after reviewing the IGCE. The funding
may not exceed the IGCE, which increases the value of the Superfund Comprehensive
Accomplishments Plan as a budgetary tool.
Developing IGCEs is beneficial in identifying Regional project performance objectives.
These objectives are clearly communicated to the contractor at the start of the project. Team
meetings (i.e., PO/CO/RPM) are held with the contractor to clarify the expectations and
scope of the project. As a result, a more comprehensive SOW is written. The work plan
negotiations also lead to a clear understanding of the SOW and are conducted within the
IGCE parameters for the project.
TARGETED INDUSTRY PA/Sfc
Contact: Steve Hawthorne, On-Scene Coordinator, Region 8
303/293-1224
Region 8 used a SACM initiative to group sites for screening and preliminary sampling.
Working with State agencies, the Region screened large numbers of similar facilities to focus
their resources on the most hazardous sites. This process was used twice by Region 8: for
wood treatment facilities in Montana and for lead smelters in Utah.
The State of Montana requested assistance from Region 8 in assessing two wood treatment
facilities. During the course of the assessment, the Region identified approximately 60
similar facilities within the State. Instead of conducting 60 separate Preliminary
Assessments/Site Inspections (PA/SIs), the Region conducted a screening based on site
location and length of operation. Using this screening tool, the Region determined that
surface sampling was required at 75 percent of the facilities. The Region used the ERT and
TAT to conduct site sampling and the results were used to target and prioritize sites.
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Similarly, the State of Utah requested assistance from the Region in assessing former lead
smelter sites. The State identified 34 abandoned smelter sites in Salt Lake County that
operated during the late 1800's to the early 1900's. The Region investigated the smelters
and identified 16 smelters of high priority for immediate assessment. The Region
coordinated 50 people from the ERT, U.S. Coast Guard, and TAT and conducted an
intensive surface sampling campaign over a period of three weeks. Approximately 1,600 soil
samples were collected as part of the sampling effort. The results targeted several areas with
higher risk of lead contamination for children.
BUREAU OF RECLAMATION REMOVAL SUPPORT
Contact: John Giedt, Chief, Emergency Response Branch, Region 8
303/294-7129
Gerry Bowles, Chief, Hazardous Waste Technical Assistance Office, Bureau
of Reclamation, Region 8
303/236-8646
The Department of Interior's BuRec has been utilized extensively by Region 8 since 1988 to
enhance its Removal program capabilities. Technical assistance to the Region 8 Removal
program by BuRec has been provided on more than 75 sites through Interagency Agreements
(IAGs). The relationship between the two organizations has worked well because of good
communications, good cost accounting, and quick response to requests.
The BuRec provides the Region with support in emergency response situations as well as
support in the form of design and construction activities throughout the Removal program
process. Through its original mission of water resource development, BuRec has experience
and in-house capabilities in hydrology, geology, all types of engineering, drilling, ground
water, geophysics, construction management and safety, value engineering, water treatment
systems, independent government cost estimating, and soil cleanup, particularly at
contaminated mine sites. When requested, BuRec provides a critical review of proposed
removal activities in addition to the critique of specific technical documents. The Region
also enlisted BuRec's assistance in advising States within the Region on the scoping and
conduct of State procurements for removal activities. The BuRec also has emergency
response capabilities that the Region relies upon. Utilizing BuRec's expertise, the Region
decreased its reliance on contractors while still increasing its Removal program capacity.
The Region has found that by using BuRec they are able to rely upon BuRec's construction
management experience in areas ranging from procurements to general contract
administration and construction oversight. In addition, BuRec performs inherently
governmental functions for EPA that are not easily performed by contractors and the
necessary contracting services associated with these functions. As a recent example, BuRec
undertook the technical and contracting response at the largest Removal action ever taken in
Region 8, the Summitville Mine site. This was a multi-million dollar Removal action,
involving the detoxification of a cyanide leach pad, reclamation of site mining waste, and
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correction of ongoing acidic mine water diainage. Total cleanup cost for this site is
estimated at over $60 million.
The Region attributes an increase of 25 percent of its Removal program capacity to the
assistance provided by BuRec. The Region and BuRec use lAGs to formalize their working
relationship and the lAGs range from general, broad technical assistance to site-specific
lAGs. The BuRec's services are available to all EPA Regional offices.
PLUG-IN ROD
Contact: Jeff Dhont, Remedial Project Manager, Region 9
415/744-2363
Region 9 designed an approach, the Plug-In ROD, for use at mega-sites with multiple,
similar operable units. Under this approach, a standardized remedy is selected that is
applicable to several source areas within a mega-site. Use of this type of ROD is appropriate
in cases where the site contains a significant number of source areas, the source areas are
similar in physical characteristics, and a technical remedy is available that will apply to the
majority of source areas. One unique feature is that the Plug-In ROD does not apply to a
specific site at the time it is signed. Sites will be subject to the ROD as RIs are completed
and the criteria for applying the ROD are met.
This innovative approach selects a remedy for the "basic" source area at a mega-site. The
basic site is defined by the site characteristics, including contaminants, soil characteristics,
and groundwater characteristics, for which the remedy is applicable, Characteristics outside
these boundaries must be addressed by an amendment to the ROD, a Removal action, or
another ROD altogether. The Plug-In ROD approach selects a remedy and develops the
process by which source areas are determined to be subject to that remedy. The process for
plugging in sites is based on ARARs and risk calculations. Included in the ROD is the
framework for the risk calculations to determine if a source area may "plug in."
Once a decision is made to use the plug-in approach, one of three actions will be taken 1) the
source area characteristics are directly addressed by the ROD, in which case the source area
can directly plug in; or 2) the remedy is mostly applicable, but there are special
considerations not addressed by the ROD, in which case the ROD must be amended; or 3)
the source area is completely different than the operable unit in the ROD, in which case the
source area must be addressed by a Removal action or a separate ROD prepared.
The benefits associated with this approach are numerous. The Plug-In ROD eliminates the
need for a separate FS, ROD, and administrative record for each source area. In addition,
the PRPs are able to move straight from the RI to remedial work or into negotiations.
Because the FS and ROD are separated from the RI, the process can proceed while RI work
on other source areas is ongoing. Similarly, RD work can occur at some source areas while
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the RI is ongoing at others, providing a sense of progress to PRPs and the public. Under
this approach data collection also is more easily focused and provides data that is directly
usable in the RD for the site. Additionally, the Plug-In ROD ensures consistency with the
NCP and preserves flexibility in the Superfund process while accelerating site cleanup.
ALTERNATIVE CONTRACTING FOR RAPID RESPONSE
Contact: Jim Everts, Chief, Emergency Response Branch, Region 10
206/553-1677
Region 10 has successfully implemented alternative contacting strategies and accomplished
expedited cleanup activities using these strategies. The Region uses several alternative
methods for both Removal and Remedial actions. These methods include the Region
interacting with the USAGE, the Superfund Innovative Technology Evaluation (SITE)
program, and the blending of ARCS capabilities with emergency removal activities.
At the Allied Plating site, a pre-ROD Removal action was performed, completing the site
cleanup significantly earlier than if the normal Superfund process were followed and at a
lower cost. The Region entered into an IAG with the USAGE to have its Rapid Response
program contract and oversee the removal at the site due to a lack of capacity in the Region
10 ERGS contract. This was the Region's first experience with a USAGE performed Fund-
lead removal. In addition to carefully watching the technical process, the Region also
compared the ERGS and USAGE contractors' cost estimates. The Removal action was
completed, finished under budget, and achieved the site remediation goals for the project.
The Region plans to issue a Completed Action ROD, qualifying the site as a construction
completion, followed by deletion from the NPL.
Following the completion of the RI at a battery recycling site in Alaska, the SITE program
was contacted by a vendor requesting to demonstrate an innovative treatment technology
designed to reduce the volume of lead contaminated soils. A technology demonstration plan
was developed and implemented. As a result, the volume of contaminated soils was reduced,
the soils were excavated and all soils remaining above the action level were treated and/or
transported to a hazardous waste landfill. This pre-ROD activity completed the RA and
saved a minimum of 12 to 18 months in comparison to the normal Superfund cleanup
process. The proposed plan for this site was received favorably and a Completed Action
ROD will be issued.
The Region also saved time and money on post-ROD activity at a site due to the combined
teamwork and interaction of the ARCS and TAT contractors. Due to the limited availability
of TAT resources, the Region retained the ARCS and TAT contractors from the same firm.
The TAT team assisted in removal and sampling activities and the ARCS team provided the
sampling procedure, final documentation of the cleanup, and the final report. The level of
cooperation and information exchange was enhanced since the teams were from the same
consulting firm. The contractors shared equipment and data, and interaction was simplified
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by team members knowing each other and l>eing familiar with each others work style. This
practice has been used at only one site, however, the Region intends to use this "model"
again if the opportunity arises.
PROPERTY VALUES AND LENDI1R LIABILITY OUTREACH ACTIVITIES
Contact: Michelle Pirzadeh, Community Relations Coordinator, Region 10
206/553-1272
The residents and business community in Tacoma, Washington expressed concerns regarding
property values and liability for the cleanup costs of their property. To address these
concerns, Region 10 held a Property Transactions Seminar and prepared a fact sheet entitled,
"Informational Fact Sheet for Property Owners, Lenders, Brokers, Realtors, and
Appraisers." These efforts helped reduce the tensions of property owners and lenders in the
Tacoma area.
Region 10 joined with the Washington Department of Ecology, the City of Tacoma, and the
Town of Ruston to sponsor the property transactions seminar for local realtors, appraisers,
bankers, and lawyers. The seminar discussions and the panel dialogue provided an
opportunity for Regional staff and local people to exchange ideas and concerns. Several
good ideas were raised during the seminar; for example, the inclusion of mortgage insurance
companies on the Region's mailing lists. The realtors, appraisers, and lenders also asked the
Region for guidance on disclosure language that is consistent, concise, and legally protective,
but does not unduly alarm buyers. The Region is working with the different groups that
were present at the seminar to develop appropriate disclosure language. Following the
seminar, the Region put together a four-page document explaining to the public the purpose
of the seminar, the attendees, and a summary of the discussions.
The exchange of ideas and concerns, through the seminar and the fact sheets, helped the
Region identify the major community concerns and target approaches to address them. In
this case, education was effective in alleviating the fears of the affected community.
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