United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
Washington, DC 20460
Directive 9200.3-01 H-
PB92 - 963276
June 1992
Superfund Program
Implementation Manual
Fiscal Year 1993
Final
Volume II
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
- Definitions
- Oil Pollution Act (OPA) Targets and Measures
- Chemical Emergency Preparedness and
Prevention (CEPP) Program Planning
Requirements
- Environment Indicators (El)
- Regional Enforcement Extramural Budget
- Federal Facilities Coding Guidance
- NPL Book
- Applicability of the Freedom of Information Act
to SCAP
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Directive 9200.3-01H-1
June 1992
Superfund Program
Implementation Manual
Fiscal Year 1993
Volume II
U.S. Environmental Protection Agency
Region 5.Library (PL-12J)
77 West Jackson Boulevard. 12 Hi Floor
Chicago, IL 60504-3590
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
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OSWER Directive 9200.3-01H-1
APPENDIX A
SUPERFUND COMPREHENSIVE ACCOMPLISHMENTS PLAN (SCAPVSTRATEGIC
TARGETED ACTIVITIES FOR RESULTS SYSTEM (STARS1 TARGETS/MEASURES
AND DEFINITIONS
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OSWER Directive 9200.3-01H-1
APPENDIX A
SCAP/STARS TARGETS/MEASURES AND DEFINITIONS
TABLE OF CONTENTS
ROLE OF SUPERFUND COMPREHENSIVE ACCOMPLISHMENTS
PLAN(SCAP) A-l
SCAP/STARS TARGETS AND MEASURES A-l
FY 93 SCAP/STARS Targets and Measures A-2
SECTION 1: SITE ASSESSMENT DEFINITIONS A-5
INTRODUCTION A-5
PA Completions A-5
SI Completions (S/F-1) A-6
SECTION 2: PIPELINE DEFINITIONS A-9
INTRODUCTION A-9
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
ENFORCEMENT ACTIVITIES AND SETTLEMENTS A-14
NPL PRP Search Starts A-15
NPL PRP Search Completions A-15
Section 104(e) Letters Issued A-15
Section 104(e) Referrals and Orders Issued A-16
Issuance of General Notice Letters A-16
Issuance of Special Notice Letters A-16
RI/FS Negotiation Starts A-17
RI/FS Negotiation Completions A-17
Removal and RI/FS Administrative Orders A-17
De minimis Settlements Prior to ROD and Number
ofPRPs(S/E-3b) A-18
State Order for RI/FS A-18
Interagency Agreements (lAGs) A-18
REMEDIAL INVESTIGATION/FEASIBILITY STUDIES (RI/FS) A-22
Community Relations A-23
Management Assistance/Support Agency Assistance A-23
Technical Assistance A-24
Technical Assistance Grants A-24
Federal Facility Listing to RI/FS Start Duration A-24
RI/FS Start — First and Subsequent A-25
Treatability Study A-27
RI/FS Projects Nominated for SITE Program A-27
RI/FS to Public A-27
Remedies Selected (ROD) — First and Subsequent A-28
RI/FS Duration A-29
REMEDIAL DESIGN (RD)fREMEDIAL ACTION (RA)
ENFORCEMENT ACTIVITIES, SETTLEMENTS AND REFERRALS A-32
Administrative Record Compilation Completion A-32
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OSWER Directive 9200.3-01H-1
Issuance of Special Notice Letters A-33
RD/RA Negotiation Starts A-33
ROD to RD/RA Negotiation
Start Duration A-33
RD/RA Negotiation Completions A-34
ROD to RD/RA Negotiation Completion Duration A-35
RD/RA Negotiation Duration A-35
RD/RA Settlements and Injunctive Referrals (S/E-la and Ib) A-36
Unilateral Administrative Orders (UAO) Issued for RD/RA A-37
Mixed Funding Settlements A-37
De minimis Settlements and Number of PRPs (S/E-3a) A-38
Section 106, 106/107, 107 Case Resolution A-38
State Consent Decree for RD/RA A-39
REMEDIAL DESIGN (RD) A-42
Design Assistance A-42
ROD Signature to RD Start Duration A-43
RD Starts — First and Subsequent A-43
RD Completions — First and Subsequent A-44
Federal Facility RD Start to RD Complete Duration A-45
REMEDIAL ACTION (RA) A-47
ROD Signature to RA Start Duration A-48
RA Start — First and Subsequent A-49
RA Contract Award (S/C-1) A-49
RA On-Site Construction A-50
RA Construction Completion (SC-2) A-50
Final RA NPL Site Construction Completion A-51
Operational and Functional (O &F) A-51
RA Completion A-52
Final RA Completion A-52
Federal Facility RI/FS Start to RA Complete Duration A-53
Federal Facility RA Start to RA Complete Duration A-53
Long-Term Remedial Action (LTRA) A-54
Operation and Maintenance A-55
COST RECOVERY A-59
Issue Demand Letter A-59
Cost Recovery Actions/Decisions Less Than $200,000 A-59
Cost Recovery Actions/Decisions Greater Than $200,000 A-61
Section 106,106/107,107 Case Resolution A-62
Dollars Achieved Toward Cost Recovery MBO Goal (S/E-7a) A-62
SECTION 3: RESPONSE DEFINITIONS A-65
INTRODUCTION A-65
Number of Sites Where Activity has Started, First NPL Removal
Action or RI/FS (S/C-4) A-66
Number of Remedial Program Remedies Selected (ROD) and Action
Memoranda Signed for Removal Actions at NPL Sites (S/C-5) A-66
NPL Site Construction Completions (S/C-3) A-67
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OSWER Directive 9200.3-01H-1
Five Year Reviews Completed A-69
NPL Deletion Initiation A-70
Federal Facility NPL Deletion A-70
Progress Through Environmental Indicators A-71
SECTION 4: REMOVAL DEFINITIONS A-73
INTRODUCTION A-73
REMOVAL ACTIVITIES A-73
Removal Investigations at NPL Sites A-76
Non-NPL PRP Search Starts A-76
Non-NPL PRP Search Completion A-76
Administrative Orders Issued for Removal and RI/FS A-77
Removal Starts — NPL and Non-NPL A-77
Emergency Response Activity A-78
NPL and Non-NPL Removal Completions A-79
NPL Site Completions Through Removal A-80
Administrative Record Compilation A-81
Federal Facility Removal/ERAs (FFE-3(2)) A-81
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OSWER Directive 9200.3-01H-1
APPENDIX A - TARGETS/MEASURES AND DEFINITIONS
ROLE OF SUPERFUND COMPREHENSIVE ACCOMPLISHMENTS PLAN (SCAP}
SCAP and Strategic Targeted Activities for Results System (STARS) targets are the key
device by which program goals are translated into quantifiable program achievements. They
identify performance expectations for the Regions and should not be seen as only a method for
allocating resources. Specific targets are negotiated by Headquarters (HQ) and the Regions. The
Regions are expected to concentrate their resources on achieving these targets.
STARS is used by the Administrator to set and monitor the progress each program is
making toward meeting its environmental goals. STARS targets and measures are reported
quarterly by HQ and the Regions to the Office of Pollution Prevention (OPP) through the OPP
STARS computer system. SCAP is used by the Assistant Administrator for the Office of Solid
Waste and Emergency Response (AA SWER), the Office of Enforcement (OE), and senior
Superfund managers to monitor the progress each Region is making toward achieving its Super-
fund goals. SCAP targets and measures are reported monthly by the Regions through the Com-
prehensive Environmental Response, Compensation and Liability Information System
(CERCLIS).
National and Regional STARS goals are established and tracked through SCAP. STARS
targets are a subset of those contained in SCAP.
SCAP/STARS TARGETS AND MEASURES
A SCAP or STARS target (either quarterly or annual) is a pre-determined numerical goal
that is established prior to the Fiscal Year (FY) to ensure that designated activities will take
place. STARS targets and measures track the priorities set forth in the Operating Guidance. All
STARS targets are SCAP targets. An example of a SCAP and STARS targeted activity is
Remedial Action (RA) Contract Award. Annual budgets are allocated based on STARS and
SCAP targets. In addition, Regions are evaluated on a quarterly basis according to their comple-
tion of activities with established targets.
A SCAP or STARS measure, on the other hand, is used to track an activity that is impor-
tant in monitoring overall program progress. The two types of measures are STARS reporting
and SCAP planning/reporting measures. Planning estimates result in numerical goals being
established prior to the FY, which are used in setting annual budgets. Regions report progress
against the planning estimates. STARS reporting measures have no associated quantitative
goals; only actual accomplishments are tracked (e.g., progress through environmental indicators).
National Priorities List (NPL) sites are the top priority for all response, and many en-
forcement and Federal Facility targets and measures. Regions will receive credit for accomplish-
ments at non-NPL sites only for non-NPL removal starts and non-NPL Potentially Responsible
Party (PRP) searches. The following targets and measures will credit accomplishments at both
NPL and non-NPL sites:
• Progress Through Environmental Indicators;
• Removal Completions;
A-l
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OSWER Directive 9200.3-01H-1
• Emergency Response Activity;
• Cost Recovery Actions/Decisions (< $200,000);
Cost Recovery Actions/Decisions (> $200,000);
• 107 Case Resolution;
• Administrative Record Compilation;
• Dollars Achieved Toward Cost Recovery Management by Objective (MBO)
Goal;
• Administrative Orders (AO) Issued for Removal;
• Federal Facility Removals/Expedited Response Action (ERA); and
• All site assessment, Oil Pollution Act (OPA), and Chemical Emergency Prepared-
ness and Prevention (CEPP) targets and measures.
All other targets and measures accomplishments are credited at NPL sites only.
FY 93 SCAP/STARS Targets and Measures
During the January 1992 Program Management Meeting, HQ and the Regions discussed
the SCAP/STARS targets and measures proposed in the FY 93 Agency Operating Guidance.
Regions expressed concerns that since the budget and workload models are frozen, HQ should
reevaluate and consider dropping some of the SCAP/STARS targets and measures. Based on
this discussion, the Regions voted on the highest priority STARS targets/measures for FY 93.
Seven targets/measures received the greatest number of votes. The information in this Manual
reflects HQ decisions relative to the Regional vote on the STARS targets and measures.
Following are the changes in the STARS targets and measures from FY 92 to FY 93:
• Remedial Remedies Selected (Record of Decision (ROD)) and Action Memo-
randa Signed for NPL Removals is a new STARS target (S/C-5). Separate targets
are negotiated in SCAP for RODs and NPL removal starts;
• NPL Site Construction Completions is a new STARS measure (S/C-3). The
target includes final RA NPL Site Construction Completions, RODs where all
necessary remediation has been completed and removal completions that cleaned
up NPL sites. Separate targets are negotiated in SCAP for final RA NPL Site
Construction Completions, RODs and removal completions;
• RA Construction Completion is a new STARS measure (S/C-2).
• De minimis Settlements and Number of PRPs is a new STARS measure (S/E-3).
The measure includes de minimis settlements (S/E-3a) and de minimis settlements
achieved prior to ROD signature (S/E-3b);
Cost Recovery Actions/Decisions > $200,000 replaces Section 107 or 106/107
Settlements and Referrals as a STARS target (S/E-2a);
A-2
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OSWER Directive 9200.3-01H-1
Cost Recovery Actions/Decisions < $200,000 is a new STARS measure (S/E-2b);
• Federal Facility IAG Starts is a new STARS target;
Federal Facility RA Starts is a new STARS target (FFE-3(1));
• Federal Facility Removal Actions/Expedited Response Actions (ERA) is a new
STARS measure (FFE-3(2));
• RA completions is no longer a STARS target. First, subsequent and final RA
completions are still SCAP targets.
• Site Inspection (SI) Completions is no longer a STARS target. It is still a SCAP
target;
• Remedial Design (RD) Completions is no longer a STARS target. First and
subsequent RD completions are SCAP targets;
• Remedial Investigation/Feasibility Study (RI/FS) Projects Nominated for the
Superfund Innovative Technology Evaluation (SITE) Program is no longer a
STARS reporting measure. It is still a SCAP reporting measure;
The trend analyses - ROD to RD Start Duration, ROD to RA Start Duration, and
ROD to RD/RA Negotiation Completion Duration - are no longer STARS report-
ing measures, however, they are SCAP reporting measures;
• AOs Issued for Removals and RI/FS, Dollars Achieved Toward the Cost Recov-
ery MBO Goal, and 104(e) Referrals/Orders are SCAP reporting measures. All
were STARS reporting measures in FY 92; and
• Resource Conservation and Recovery Act (RCRA) Preliminary Assessments (PA)
under the Environmental Priorities Initiative (EPI) is no longer tracked in STARS
or SCAP.
The definitions contained in this Appendix are those that were available at the time the
Manual went to the printer. Every effort has been made to ensure that the definitions contained
herein for SCAP and STARS targets and measures are consistent. If there are inconsistencies,
the STARS definition is the official definition. If STARS definitions are revised during the year,
an addendum to the Superfund Program Management Manual may be published.
The term "activity" as used in the definitions applies to a specific action. It does not
relate to the CERCLIS use of the term "activity" which is applied to enforcement actions.
The remainder of this Appendix is divided into the following four major sections:
• Section 1: Site Assessment - Includes targets/measures and definitions for PAs
and Sis;
• Section 2: Pipeline - Includes targets/measures and definition for response
events and enforcement activities that are integral to the remedial, enforcement
and Federal Facility programs. The definitions in this section are in remedial
pipeline order and include the following activities:
A-3
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OSWER Directive 9200.3-01H-1
RI/FS Enforcement Activities and Settlements;
RI/FS;
RD/RA Enforcement Activities, Settlements and Referrals;
RD;
RA; and
Cost Recovery.
• Section 3: Response - Includes targets/measures and definitions for response
(removal and remedial) events that occur at sites on the NPL. It also includes
definitions for site completions and NPL deletions; and
• Section 4: Removal - Includes targets/measures and definitions for events and
enforcement activities that are integral to the operation of the removal program.
Removal actions at Federal Facilities are also included in this section.
OPA targets/measures and definitions can be found in Appendix B. CEPP STARS
targets/measures and definitions can be found in Appendix C.
A-4
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OSWER Directive 9200.3-01 H-l
SECTION 1: SITE ASSESSMENT DEFINITIONS
INTRODUCTION
The site assessment targets/measures track the initial events at Superfund sites. Two site
assessment events are projected and tracked through the Superfund Comprehensive Accomplish-
ments Plan (SCAP)/Strategic Targeted Activities for Results System (STARS) process:
• Preliminary Assessment (PA) Completions; and
• Site Inspection (SI) Completions.
SI completions is a SCAP target. PA completions is a SCAP measure. Regions propose
targets for all site assessment activities in the CERHELP data system. Funds for site assessment
activities are included in the other response Advice of Allowance (AOA). Exhibit A-l displays
the SCAP/STARS targets and measures for the site assessment program.
'• v;!XHI&rr A4:' SOT ASSESSMENT SCAP/STARS TARGETS AND MEASURES
PA
COMPLETIONS
SI COMPLETIONS
EPA - PA/SI
COMPLETIONS
STATE - PA/SI
COMPLETIONS
STARS/SCAP
TARGET
X*
STARS
REPORTING
SCAP PLAN
& REPORT
X
X
X
QUARTERLY
X
X
X
X
ANNUAL
X
X
X
X
*SCAP only
PA COMPLETIONS
Definition: A PA is the first stage of site assessment which determines whether a site
should be recommended for further Comprehensive Environmental Response, Compen-
sation and Liability Act (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 PA completion date and the deci-
sion on further activities is shown in the Event Qualifier Field. Although a site can have
multiple PAs, only the first completed PA with an 'S' or 'F' lead counts toward the
target.
A-5
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OSWER Directive 9200.3-01H-1
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: For budget and resource allocations,
separate projections must be made for Environmental Protection Agency (EPA) vs. State
PA completions. Accomplishments are reported site specifically in WasteLAN. This is a
SCAP reporting measure.
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 Hazard Ranking System (HRS) score.
Definition of Accomplishment: This measure includes only screening Sis. A SI is
complete when: 1) a Focused Site Inspection Report has been received by the Region
from the Alternative Remedial Contracting Strategy (ARCS) contractor or the State;
2) the report has been reviewed and approved by the appropriate Regional official;
3) a decision has been made on whether to proceed with further site evaluation work;
and 4) the SI report date and decision on further action has been recorded in WasteLAN.
Changes in Definition FY 92 - FY93:
Special Planning/Reporting Requirements: This is a SCAP target. Commitments are
made based on the sum of the EPA and State conducted Sis. However, for budget and
resource allocations, separate projections must be made for EPA vs. State SI completions.
Regions propose targets in the CERHELP non-site data system. Accomplishments are
reported site specifically in WasteLAN.
A-6
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OSWER Directive 9200.3-01 H-l
i EXHIBIT A4s srr B A^^i^:-^^K^^ , ' :\.. '
PLANNING REQUIREMENTS
STARS?
SCAP?
TARGET OR MEASURE?
QUARTERLY TARGETS?
IF YES, WHEN?
PLANNED SITE SPECIFICALLY?
PLANNED/REPORTED ON
OPERABLE UNIT
OR WHOLE SITE BASIS?
REPORTED ON COMBINED PROGRAM
LEAD OR ON A PROGRAM SPECIFIC
BASIS?
REPORTED SITE SPECIFICALLY OR IN
NON-SITE PORTION OF WASTELAN?
AOA CATEGORY?
BASIS FOR AOA?
PA
NO
YES
MEASURE
NO
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
OTHER
RESPONSE
NON-SITE
PLANS
SI
NO
YES
TARGET
YES
PRIOR
TOFY
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
OTHER
RESPONSE
NON-SITE
PLANS
A-7
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OSWER Directive 9200.3-01H-1
(This page intentionally left blank)
A-8
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OSWER Directive 9200.3-01 H-l
SECTION 2: PIPELINE DEFINITIONS
INTRODUCTION
The pipeline definitions include remedial, enforcement and project support activities at
both Federal Facility and non-Federal Facility Superfund sites. The remedial and support events
and enforcement activities have been placed in this section in the order they occur in the Super-
fund pipeline:
• Remedial Investigation/Feasibility Study (RI/FS) Enforcement Activities and
Settlements;
RI/FS;
» Remedial Design (RD)/Remedial Action (RA) Enforcement Activities, Settle-
ments, and Referrals;
RD;
• RA; and
• Cost Recovery.
Exhibit A-3 presents the SCAP/STARS targets for pipeline activities. Exhibit A-4
displays the SCAP/STARS reporting measures.
A-9
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OSWER Directive 9200.3-01H-1
RI/FS Enforcement
Activities & Settlements
- Interagency Agree-
ments (IAG) Start
- IAG Complete at
National Priorities List
(NPL) or proposed
NPL Sites (FFE-2)
RI/FS
-First RI/FS Start
- Subsequent RI/FS Start
- First Remedy Selected
at NPL Sites-Record of
Decision (ROD)*
- Subsequent Remedy
Selected at NPL Sites -
ROD*
- Federal Facility
Remedy Selection at
NPL Sites (FFE-4)
• First Federal Facility
RODs
• Subsequent Federal
Facility RODs
RD/RA Enforcement,
Settlements & Referrals
- RD/RA Negotiation
Start
- RD/RA Negotiation
Completion
- RD/RA Settlements
and Injunctive Referrals
(S/E-la and Ib)
• RD/RA Settlements
• RD/RA Injunctive
Referrals
RD
- First RD Start
- Subsequent RD Start
- First RD Completions
- Subsequent RD
Completions
Mr A<& mmwE SCAF/STARS TARGETS- • ' '• .-
STARS
TARGET
X
X
X**
X
SCAP TARGET
X
X
X +
X +
X
X
X
X
X
X
X
X
x +
x +
x +
x +
QUARTERLY
TARGET
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ANNUAL
TARGET
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
* Includes F, FE, and SE-lead RODs
* * The STARS target combines first and subsequent, if appropriate, as a single target.
+ Includes projects with the following leads: Federal (F), State (S), PRP action under State order /decree (PS),
In-house RI/FS or RD (EP), Responsible party under Federal order/decree (RP), Mixed funding (MR) and Federal
Facility (FF).
A-10
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OSWER Directive 9200.3-01H-1
BOTBrr A4? IOTLINS SCAP/STARSTARQITS CQ^TJNUBD)
RA
- First RA Start (Fund)
- Subsequent RA Start
(Fund)
- First RA Start
Potentially Responsible
Party (PRP)
- Subsequent RA Start
(PRP)
- RA Start-Federal
Facility (FFE-3(1))
• First RA Start
• Subsequent RA Start
- RA Contract Award
(S/C-1)
• First RA Contract
Award
• Subsequent RA
Contract Award
- RA Completions
• First RA Completion
• Subsequent RA
Completion
• Final RA Completion
Cost Recovery
- Actions /Decisions
(>$200,000) (S/E-2a)
STARS
TARGET
X**
X**
X
SCAP
TARGET
X
X
X
X
X
X
X
X
x +
x +
X
X
QUARTERLY
TARGET
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ANNUAL
TARGET
X
X
X
X
X
X
X
X
X
X
X
X
X
X
* * The STARS target combines first and subsequent, if appropriate, as a single target.
+ Includes projects with the following leads: Federal (F), State (S), PRP action under State order/decree (PS),
In-house RI/FS or RD (EP), Responsible party under Federal order/decree (RP), Mixed funding (MR) and Federal
Facility (FF).
A-11
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OSWER Directive 9200.3-01H-1
• .'! ••' ' ••/'•:' " '•• .'.- ' - -v Exterr A-4: PIPELINE SCAT/STARS MEASURES
RVfS Enforcement
Activities & Settlements
- NPL PRP Search Start
- NPL PRP Search
Completion
- 104(e) Letters Issued
- 104(e) Referrals &
Orders Issued
- Issuance of General
Notice Letters (GNL)
- Issuance of Special
Notice Letters (SNL)*
- RI/FS Negotiation Start
- RI/FS Negotiation
Completion
- De minimis Settlements
Prior to ROD (S/E-3b)
- Administrative Order
(AO) Issued for
Removals & RI/FS
- State Orders for RI/FS
Issued
RI/FS
- Federal Facility Listing
to RI/FS Start Duration
- Treatability Studies
- RI/FS Projects
Nominated for the
Superfund Innovative
Technology Evaluation
(SITE) Program
- RI/FS to Public
- RI/FS Duration
RD/RA Enforcement
Activities, Settlements &
Referrals
- Remedial
Administrative Record
Compilation
- Issuance of SNL*
- ROD to RD/RA
Negotiation Start
Duration
- ROD to RD/RA
Negotiation Completion
Duration
- RD/RA Negotiation
Duration
- Unilateral
Administrative Orders
(UAO) Issued for
RD/RA
STARS
REPORTING
X
SCAT
PLAN/REPORT
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x +
X
X
X
X
X
X
QUARTERLY
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ANNUAL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
+Indudes projects with the following leads: Federal (F), State IS), In-house (EP), PRP action under State order/decree (PS),
Responsible party under Federal order/decree (RP), Mixed Funding (MR) and Federal Facility (FF).
* Activity is listed in two places in the exhibit.
A-12
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OSWER Directive 9200.3-01H-1
''."•'• 1 -:EX13raiTA.4t.PIF!L^
RD/RA Enforcement
Activities, Settlements
& Referrals (continued)
~ Mixed Funding
Settlements Achieved
- De minimis Settlements
(S/E-3a)
- Section 106, 106/107,
107 Case Resolution*
- State Consent Decrees
(CD) for RD/RA Issued
RD
- ROD to RD Start
Duration
- Federal Facility RD
Start to RD Complete
Duration
RA
- ROD to RA Start
Duration
- Federal Facility RA
Contract Award
- RAOn-Site
Construction
~ RA Construction
Completion (S/C-2)
~ NPL Site Construction
Completion (Final RA)
Federal Facility RA
~ Final Completion
Federal Facility RA
- Start to RA Complete
Duration
Cost Recovery
~ Demand Letters Issued
~ Actions /Decisions
(<$200,000) (S/E-2b)
- Section 106, 106/107,
107 Case Resolution*
~ Dollars Achieved
Toward Cost Recovery
Management by
Objective (MBO) Goal
STARS
REPORTING
X
X
X
SCAP
PLAN/REPORT
X
X
X
X
X
X
x +
X
X
X
X
X
X
X
X
X
X
QUARTERLY
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ANNUAL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
•^Includes projects with the following leads: Federal (F), State (S), PRP action under State order/decree (PS), Responsible party
under Federal order/decree (RP), Mixed Funding (MR) and Federal Facility (FF).
* Activity is listed in two places in the exhibit.
A-13
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OSWER Directive 9200.3-01H-1
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS) ENFORCEMENT ACTIVI-
TIES AND SETTLEMENTS
Following are the definitions for the RI/FS search, negotiation and settlement activities,
and Federal Facility Interagency Agreement (IAG) activities that are included in this section:
• National Priorities List (NPL) Potentially Responsible Party (PRP) Search Starts;
NPL PRP Search Completions;
• Section 104(e) Letters Issued;
• Section 104(e) Referrals and Orders;
• Issuance of General Notice Letters (GNL);
• Issuance of Special Notice Letters (SNL);
RI/FS Negotiation Starts;
• RI/FS Negotiation Completions;
• Administrative Orders (AO) Issued for Removals and RI/FS;
• De minimis Settlements Prior to the Record of Decision (ROD) and Number of
PRPs;
State Order for RI/FS Issued;
IAG Start; and
• lAGs Complete at NPL or Proposed NPL Sites.
IAG start and lAGs complete at NPL or proposed NPL sites are SCAP/STARS targets.
De minimis settlements prior to ROD is a STARS reporting measure. NPL PRP search starts
and completions, Section 104(e) letters issued, Section 104(e) referrals and orders, issuance of
GNL, issuance of SNL, RI/FS negotiation starts and completions, AOs issued for removal and
RI/FS, and State orders issued for RI/FS are SCAP measures.
All of the RI/FS enforcement activities and settlements are planned site specifically.
Planning and accomplishment data for these activities are reported in WasteLAN. Funds to
support the non-Federal Facility enforcement activities are contained in the enforcement Advice
of Allowance (AOA). Funds to support Federal Facility LAGs are allocated in the Federal
Facility AOA.
For the definitions below, IAG start and completion definitions have been combined.
The definition for SNLs issued appears in this section and the RD/RA Enforcement Activities,
Settlements and Referrals Section. The definition for AOs issued for RI/FS and removals appear
in this section and Section 4: Removal Definitions.
A-14
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OSWER Directive 9200.3-01H-1
NPL PRP SEARCH STARTS
Definition: The purpose of the PRP search is to identify PRPs. At NPL sites the PRP
search should be initiated at the same time as the Site Inspection (SI) or Expanded Site
Inspection (ESI) or, at the latest, with the listing of 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 a RI/FS.
Definition of Accomplishment: If the search is being conducted by a contractor, the
start date is considered to be the date the work assignment is procured. If it is conducted
by EPA, the start date is the day the EPA staff begins the PRP search activities.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: NPL PRP searches are planned and funds
requested on a site-specific basis. PRP searches should be planned for all sites listed on
the NPL. This is a SCAP reporting measure.
NPL 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 date and the outcome of the search has been determined
and entered into WasteLAN. If no PRPs are found, the date and the outcome of the
search are entered into WasteLAN.
This definition applies to both Phase I (single owner, operator site) and Phase II (multi-
generator site) PRP search accomplishments.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: NPL PRP search completions are planned
on a site-specific basis. This is a SCAP reporting measure.
SECTION 104(e) LETTERS ISSUED
Definition: This is a letter issued under Section 104(e) of the Superfund Amendments
and Reauthorization Act (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: Credit for this activity is given on the date the informa-
tion request letter is signed by the appropriate EPA official.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
recorded at the milestone level.
A-15
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OSWER Directive 9200.3-01H-1
SECTION 104(e) REFERRALS AND ORDERS ISSUED
Definition: Section 104(e)(5) referrals/orders are enforcement actions to compel parties
to respond to EPA requests for information.
Definition of Accomplishment: Report the number of Section 104(e)(5) orders issued or
referrals to Headquarters (HQ) or to the Department of Justice (DOT) to compel PRPs to
comply with information requests. Credit for the referral is the date on the Regional
Administrator's transmittal memo to HQ or to the DOJ as recorded in WasteLAN. Credit
for the order is based on the date it is signed by the Regional Administrator as recorded in
WasteLAN. Due to workload considerations, Regions issuing referrals for non-compli-
ance with a Section 104(e)(5) order will receive credit for both the order and the follow-
up referral.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
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: Credit for this activity is given on the date the GNL is
signed by the appropriate EPA official.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
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 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 (RI/FS, RD/RA) and can be extended if necessary.
Definition of Accomplishment: Credit for this activity is given on the date the SNL is
signed by the appropriate EPA official.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
recorded at the milestone level.
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OSWER Directive 9200.3-01 H-l
RI/FS NEGOTIATION STARTS
Definition: RI/FS negotiations are discussions between EPA and the PRPs on their
liability, willingness, and ability to conduct the RI/FS.
Definition of Accomplishment: RI/FS negotiations start when:
• The first SNL is signed, or
• A waiver of SNL is signed.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: If the Region does not plan to perform
RI/FS negotiations at a site, negotiation dates should not be placed in WasteLAN. The
start of RI/FS negotiations should be planned site specifically. This is a SCAP reporting
measure.
RI/FS NEGOTIATION COMPLETIONS
Definition: RI/FS negotiations end when the Region decides how to proceed with the
RI/FS activities.
Definition of Accomplishment: RI/FS negotiations end when:
• A Unilateral Administrative Order (UAO)* or Administrative Order on Consent
(AOC) for RI/FS is signed by the Regional Administrator;
• A signed Consent Decree (CD) for RI/FS is referred by the Region to HQ or DOJ;
or
• The Region decides to proceed with a Fund-financed RI/FS, terminates negotia-
tions, and obligates funds for the RI/FS.
The negotiations conclusion date is the date the Regional Administrator signs the order,
the date on the transmittal letter referring the CD, or the date funds for RI/FS are obli-
gated.
* A UAO is not the preferred enforcement tool for RI/FS and should be used only under
unique circumstances.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: The activity is planned site specifically in
WasteLAN. This is a SCAP reporting measure.
REMOVAL AND RI/FS ADMINISTRATIVE ORDERS
Definition: Administrative Orders (AOC and UAO) are an enforcement tool to compel
the PRPs to assume responsibility for removal actions and RI/FS projects.
Definition of Accomplishment: Report Section 104/106/122 Administrative Orders
(AOC and UAO) issued by EPA for PRPs to conduct removal actions and/or RI/FSs.
I
A-17
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OSWER Directive 9200.3-01 H-l
Credit for the order is based on the date it is signed by the Regional Administrator as
recorded in WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Projections for AOs for RI/FS are made
site specifically. This is a SCAP reporting measure.
DE MINIMIS SETTLEMENTS PRIOR TO ROD AND NUMBER OF PRPS (S/E-3B)
Definition: Administrative or judicial settlement reached under Section 122(g) of SARA
prior to the first remedy being selected (ROD signature). This settlement involves the
established de minimis portions of the response costs at the site and is embodied as a CD
or in an AOC. If the total response costs at the site exceed $500,000 (excluding interest),
the AOC can only be issued with DOJ's prior written approval. If DOJ does not approve
or disapprove the AO within 30 days, the AOC is considered approved and can be issued.
(DOJ and the Administrator can agree to extend this 30-day period.)
Definition of Accomplishment: Credit for a final settlement is identified when an AOC
is signed by the Regional Administrator (as reported in WasteLAN), and for a CD, when
the Regional Administrator signs the transmittal memo to HQ or to the DOJ (as reported
in WasteLAN). The number of PRP signatories to each settlement must also be reported.
Post ROD de minimis settlements will not count in this measure.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: The remedy qualifier for de minimis must
be entered into WasteLAN Enforcement Remedy Qualifier data elements (C2741 -
C2750 = "DL" or "DG"). This is a STARS reporting measure.
STATE ORDER FOR RI/FS
Definition: AO or CD signed by the State and the PRPs for the PRPs to conduct the
RI/FS.
Definition of Accomplishment: The date the last State official or party 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 date
should be placed in C1717. In addition, the remedy field must denote that the AO/CD
was issued for an RI/FS.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure not a
targeted activity.
INTERAGENCY AGREEMENTS (lAGs)
Definition: Under CERCLA Section 120, Federal agencies are required to enter into an
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
A-18
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OSWER Dkective 9200.3-01H-1
possible. lAGs are legally binding requirements which set forth detailed requirements for
performance of site response activities, as well as appropriate enforcement responses to
non-compliance with the IAG. IAG negotiations provide the Federal agency an opportu-
nity to meet with EPA, and often the State, to discuss key issues and come to a final
agreement.
Definition of Accomplishment:
IAG Start Date: Date notice letter is sent by EPA to the Federal Facility.
IAG Completion Date: Date the Federal agency and all parties sign the IAG, or the date
which the Letter of Intent is signed by all parties, or the date the draft IAG is signed by
all parties (generally prior to the start of a public comment period), or the date the IAG is
elevated to HQ for dispute resolution, or the date the LAG goes to Federal agency HQ, or
the date public comment is initiated.
NOTE: To enable accurate tracking of major milestones, a non-targeted data element,
IAG Effective Date will be added to CERCLIS. This will be the date on which the IAG
becomes effective.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: IAG start and IAG complete are STARS/
SCAP targets.
A-19
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OSWER Dkective 9200.3-01H-1
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A-20
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OSWER Directive 9200.3-01H-1
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A-21
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OSWER Directive 9200.3-01H-1
REMEDIAL INVESTIGATION/FEASIBILITY STUDIES (RI/FS}
Following are the SCAP and STARS events tracked for RI/FS:
• Federal Facility Final Listing to RI/FS Start Duration;
First RI/FS Starts (Fund-financed, PRP and Federal Facility);
Subsequent RI/FS Starts (Fund-financed, PRP and Federal Facility);
• Treatability Studies (Fund-financed and PRP);
• RI/FS Projects Nominated for the Superfund Innovative Technology Evaluation
(SITE) Program (Fund-financed and PRP);
RI/FS to Public (Fund-financed and PRP);
First Remedy Selected (Record of Decision (ROD)) (Fund (F), Federal Enforce-
ment (FE), State Enforcement (SE), and Federal Facility (FF));
Subsequent Remedy Selected (ROD) (F, FE, SE, and FF); and
• RI/FS Duration (Fund-financed, PRP and Federal Facility).
Federal Facility RODs is a STARS/SCAP target. First RI/FS start or first NPL removal
start is a target under STARS measure S/C-4 titled Number of Sites Where Activity Has Started.
The definition for Number of Sites Where Activity Has Started can be found in Section 3: Re-
sponse Definitions. The number of remedies selected and action memoranda signed for removal
actions at NPL sites are a target under STARS measure S/C-5. The definition for Remedies
Selected and Action Memoranda Signed can be found in Section 3: Response Definitions. First
and subsequent RI/FS starts, and F, FE, SE, and FF first and subsequent remedies selected
(RODs) are SCAP targets. RI/FS projects nominated for the SITE program, treatability studies,
Federal Facility final listing to RI/FS start duration, and Fund-financed, PRP and Federal Facility
RI/FS duration are SCAP reporting measures.
RI/FS commitments are made on a combined Fund-financed and PRP basis and there is a
limit on the number of RI/FS starts during the FY. Separate Fund-financed, PRP and Federal
Facility goals for RI/FS starts are set prior to the FY. All RI/FS activities are planned on a site,
OU and project specific basis. Planning and accomplishment information are entered into
WasteLAN. Funds for Fund-financed RI/FS projects are in the RI/FS AOA. Funds for oversight
of PRP and Federal Facility RI/FS projects are available in the enforcement and Federal Facility
AOAs, respectively.
For the definitions below, first and subsequent RI/FS starts have been combined, as have
first and subsequent remedy selections (RODs).
Definitions for RI/FS project support activities are presented at the beginning of this
section.
A-22
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OSWER Dkective 9200.3-01H-1
COMMUNITY RELATIONS
Definition: Community Relations (CR) are the activities conducted in accordance with
SARA, the National Contingency Plan (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 of funds for the devel-
opment of the Community Relations Plan (CRP). For RP-lead sites where the PRP is
preparing the CRP in accordance with an AO or CD, the start of CR is defined as EPA
approval of the CRP. For 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 a
removal action.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: CR activities at PRP sites and Federal
Facilities are paid for by the Regional enforcement extramural budget and Federal Facil-
ity budget, respectively. Planned and actual start and completion dates are not required in
WasteLAN. Funds may be planned site 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 CR activities are in the enforcement, other response or Federal
Facility AOAs.
MANAGEMENT ASSISTANCE/SUPPORT AGENCY ASSISTANCE
Definition: Management assistance/support agency assistance are the activities per-
formed 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 Agree-
ment (CA) to ensure their meaningful and substantial involvement in response activities.
Unless otherwise specified in the CA, all support agency costs, with the exception of RA
support agency costs, may be documented under a single Superfund account number
designated specifically for support agency activities. RA support agency activities must
be documented site specifically and require cost share provisions.
Definition of Accomplishment: The start of management assistance/support agency
assistance is the signature of the CA by the Regional Administrator or his designee. The
completion of management assistance is the completion of all remedial activities at the
site.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Management assistance/support agency
assistance activities for RP and PS-lead projects are paid for by the enforcement program,
are contained in the Regional enforcement extramural budget, and distributed to the
Region in the enforcement AOA. Funds to support MR and F-lead projects are in the
other response AOA. Planned and actual start and completion dates are not required in
WasteLAN. Funds may be planned site or non-site specifically; however, they must be
obligated site specifically. Once funds are obligated, the non-site specific amount must
be reduced.
A-23
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OSWER Directive 9200.3-01H-1
TECHNICAL ASSISTANCE
Definition: Technical assistance is support provided by a third party to EPA in the
conduct of response activities.
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 re-
sponse activities for which technical assistance was requested.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Planned and actual start and completion
dates are not required in WasteLAN. Funds may be planned site 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: Technical Assistance Grants (TAG) are provided under SARA to a commu-
nity 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. The completion of the TAG is the completion of the final RA or the
deletion of the site from the NPL.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Planned and actual start and completion
dates are not required in WasteLAN. Funds may be planned site 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 Facilities are in the Federal Facility AOA.
FEDERAL FACILITY LISTING TO RI/FS START DURATION
Definition: CERCLA/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 count final NPL sites, where the
duration between final NPL listing (publication of final listing in the Federal Register
and the first RI/FS start is less than six months (two quarters). The duration will be
calculated based on the RI/FS start definition contained in this manual.
Changes in Definition FY 92 - FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
A-24
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OSWER Directive 9200.3-01H-1
RI/FS START — 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 prior CERCLA settlement or prior Fund obligation for Remedial
Investigation (RI), Feasibility Study (FS), or combined RI/FS. In order for the Fund-
financed and PRP RI/FS to be counted in the STARS target S/C-4, Number of Sites
Where Activity has Started, First NPL Removal Actions and RI/FS, it must not have had
previous RI/FS QI removal activity at the site.
Obligation of funds for forward planning, community relations and/or other support
activities do not constitute an RI/FS start. A subsequent RI/FS is any RI/FS that starts
after the first one.
Definition of Accomplishment:
Fund-financed (Including F- and S-lead events.) - A Fund RI/FS start is counted when
funds are obligated. Funds are obligated when:
• The contract modification for the RI/FS has been signed by the Contracting
Officer (CO);
• An LAG has been signed by the other Federal agency (U.S. Army Corps of Engi-
neers (USAGE) or Bureau of Reclamation (BUREQ); or
• A CA has been signed by the Regional Administrator or his designee to conduct
an RI/FS; and
• Obligations have been recorded or documented in WasteLAN.
If a subsequent RI/FS or focused FS is initiated without a new obligation of funds, the
start date is defined as EPA approval of the work plan for the subsequent RI/FS.
PRP-financed (Includes RP-, MR-, and PS- lead events) - A Responsible Party (RP or
MR)-lead RI/FS start counts 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 last
signature date by the appropriate official or party (e.g., the Regional Administra-
tor, DOJ, or HQ);
A PS-lead RI/FS start counts when a State order or comparable enforcement document is
signed by the last appropriate official or party and the site is covered by one of the fol-
lowing:
• State enforcement CA;
A-25
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OSWER Directive 9200.3-01H-1
• Superfund Memorandum of Agreement (SMOA) containing a schedule for RI/FS
work at the site; or
• Other State/EPA agreement.
If a 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 approval of the work plan for the subsequent RI/FS.
If an AOC, a State order, or other comparable State enforcement document is amended
for the subsequent RI/FS, the start date is the date the last official signs the amendment.
If an EPA CD is amended, the start date is the last signature date by the appropriate
official or party.
Federal Facility - In general, the RI/FS first start date should coincide with the IAG
effective date. However, for sites where RI/FS work starts prior to the IAG effective
date, the earliest date reportable is the IAG completion date. For sites where RI/FS work
is initiated under a Resource Conservation and Recovery Act (RCRA) order or permit,
the RI/FS first start date should equal the date when the RCRA order or permit becomes
effective. In rare cases, with HQ approval, when the RI/FS has been initiated prior to the
IAG completion date and there has been extensive Regional involvement with the facil-
ity, the RI/FS first start date can be the receipt of the RI/FS work plan.
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 start is the date of the RI/FS first start
(which is generally the IAG effective date or IAG completion date, whichever is earlier).
In rare cases, with HQ approval, when the RI/FS has been initiated prior to the IAG
completion date and there has been extensive Regional involvement with the facility, the
RI/FS subsequent start date can be the receipt of the RI/FS workplan.
EP-lead - An EP-lead RI/FS counts when the Region begins preparation of the
workplans following the initial scoping meeting.
Changes in Definition FY 92 - FY 93: Federal Facility definition is new in FY 93.
Special Planning/Reporting Requirements: First Fund or PRP RI/FS start or first Fund
or PRP NPL removal start is a target under STARS S/C-4, Number of Sites Where
Activity Has Started. The definition for Number of Sites Where Activity Has Started can
be found in Section 3: Response Definitions. Individual targets for first RI/FS starts and
NPL removals are established in SCAP. Separate Fund-financed, RP-lead and Federal
Facility RI/FS start targets will be established in SCAP prior to the FY. A limit will be
placed on the number of Fund-financed, RP and PS lead RI/FS that can be started during
the FY for budget purposes. Targets are established site specifically. For first RI/FS
starts, "to be determined (TBD)" sites are allowed.
Regions cannot receive credit for a site under STARS S/C-4, Number of Sites Where
Activity has Started, First NPL Removal Actions and RI/FS, if an RI/FS or NPL removal
began or was conducted at the site in a previous year. Regions also cannot receive credit
under STARS for both an RI/FS start and an NPL removal if they are started in the same
year. Credit is given for the first activity started and a site can receive credit only once.
Therefore, historical data must be reviewed prior to negotiating commitments and report-
A-26
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OSWER Directive 9200.3-01 H-l
ing accomplishments in STARS. Regions can receive credit for both individual events in
SCAP.
TREAT ABILITY STUDY
Definition: Treatability studies are laboratory or field tests used to evaluate and imple-
ment 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 RI/FS or RD funds are used for the treatability study, the
start date is the date of EPA approval, as reflected in WasteLAN, of the treatability study
work plan. The completion is the approval of the report on the results of the treatability
study.
PRP-financed - The treatability study starts when EPA approves the treatability study
work plan submitted by the PRPs. The completion is the approval of the report on the
results of the treatability study.
Changes in Definition FY 92 - FY 93: Added that the definition also covers treatability
studies to support remedy implementation (i.e., RD/RA treatability studies). Included
Fund-financed and PRP definitions.
Special Planning/Reporting Requirements: Planned and actual start and completion
dates are required in WasteLAN. Funds are planned site specifically and are placed in
the other response AOA. This is a SCAP reporting measure.
RI/FS 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 technolo-
gies are selected, it is necessary to find demonstration sites.
Definition of Accomplishment: An RI/FS project is nominated for the SITE program
when the Region sends a memorandum to HQ formally submitting the site for consider-
ation as a location for a demonstration project.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Accomplishments are reported site specifi-
cally. Fund-financed or RP-lead sites may be submitted for consideration. This is a
SCAP reporting measure.
RI/FS TO PUBLIC
Definition: The RI/FS is released to the public when the contamination at the site has
been characterized and alternatives for remediation have been evaluated.
A-27
-------
OSWER Directive 9200.3-01H-1
Definition of Accomplishment: An RI/FS to public is accomplished the date the pro-
posed plan is available to the public. This date must be recorded in WasteLAN (C3101)
with the RI/FS event under subevent code "CF."
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Accomplishments are based on the first
proposed plan released to the public for each RI/FS regardless of lead. This is a SCAP
reporting measure.
REMEDIES SELECTED (ROD) — FIRST AND SUBSEQUENT
Definition: A remedy is selected at the completion of the RI/FS. Upon completion of
the public comment period on a Fund-financed or RP-lead RI/FS, a ROD which identifies
the Agency's selected remedy for a site or phase of site cleanup is signed by the Assistant
Administrator for the Office of Solid Waste and Emergency Response (AA SWER) or
the Regional Administrator/Deputy Regional Administrator.
Upon completion of a Federal Facility RI/FS, the Federal agency selects a remedy for the
site 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 Office of Enforcement (OE) or the Regional Administrator/Deputy Regional Admin-
istrator.
Definition of Accomplishment:
F. FE. and SE-lead - The date the ROD is signed by the Regional Administrator/Deputy
Regional Administrator or the AA SWER is the remedy selection date.
Federal Facility - Date of EPA approval/concurrence on the clean-up decision document
pursuant to an 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 completions.
Changes in Definition FY 92 - FY 93: Added Federal Facility ROD requirements.
Special Planning/Reporting Requirements: Commitments are made based on F, FE, or
SE lead RODs that result from F, S, EP, MR, RP, or PS lead RI/FS. Federal Facility
RODs are tracked separately. The RI/FS completion date and ROD completion date are
the same. Planned and actual dates must be entered with both events in WasteLAN. The
RA technology type should be entered into WasteLAN in the RA Technology Type data
field (C3401 = RT) and the specific technology type(s) in the Technical Information
Qualifier fields (C3402 - C3411).
Remedies selected (F, FE, or SE lead RODs) and Action Memorandum signed for re-
moval actions at NPL sites is a combined target under STARS S/C-5. F, FE, or SE lead
RODs at the final OU that state that no further remediation is necessary at the final OU
also meet the STARS measure S/C-3 of NPL Site Construction Completion. Definitions
for Remedies Selected and Action Memoranda Signed and NPL Site Construction
Completion can be found in Section 3: Response Definitions.
A-28
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OSWER Directive 9200.3-01H-1
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 RI/FS
or the date the Federal Facility IAG effective date. The RI/FS is complete with the
signature of the ROD or EPA concurrence/approval on the Federal Facility cleanup
decision document.
The objective of this measure is to focus on good project management of critical portions
of the remedial pipeline and establish a methodology which accurately assesses program
performance. The Integrated Timeline for Site Management (Volume I, Chapter I) will
be used for establishing performance expectations. Duration trends provide indicators of
areas that require attention.
Only RI/FS projects that started post-SARA will be used for comparison and evaluation
purposes.
Definition of Accomplishment: This measure includes all RI/FS projects that have a
targeted completion date in FY 93. The RI/FS duration will be calculated based on the
SCAP/STARS RI/FS start and completion definitions specified in this Manual. Regional
performance in FY 93 will be compared to:
• The Regional and national average of RI/FS projects completed in FY 91 and FY
92; and
• The Regional and national average duration of RI/FS projects completed in
previous quarters of FY 93.
Changes in Definition FY 92 - FY 93: Added definition for calculation of Federal
Facility RI/FS duration.
Special Planning/Reporting Requirements: CERCLIS will automatically look at
actual RI/FS start dates, and planned and actual ROD completion dates. HQ will perform
the analysis of the average durations. Trend duration reports are currently being
developed. Fund, PRP, and Federal Facility RI/FS durations will be tracked. At sites
where one site-wide RI is conducted and OU specific FSs and RODs are conducted, links
data will be used. This is a SCAP reporting measure.
A-29
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OSWER Directive 9200.3-01H-1
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A-30
-------
OSWER Directive 9200.3-01H-1
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A-31
-------
OSWER Directive 9200.3-01 H-l
REMEDIAL DESIGN (RDVREMEDIAL ACTION (RA) ENFORCEMENT ACTIVITIES.
SETTLEMENTS AND REFERRALS
Following are the RD/RA negotiations, settlements and referral actions tracked in SCAP
and STARS:
• Administrative Record (AR) Compilation Completion (Remedial);
• Issuance of SNL;
• RD/RA Negotiation Start;
• RD/RA Negotiation Completion;
• ROD to RD/RA Negotiation Start Duration;
• ROD to RD/RA Negotiation Completion Duration;
• RD/RA Negotiation Duration;
• RD/RA Settlements and Injunctive Referrals;
UAO Issued for RD/RA;
• Mixed Funding Settlements Achieved;
• De minimis Settlements and Number of PRPs;
Section 106,106/107, 107 Case Resolution; and
State CDs for RD/RA Issued.
RD/RA settlements and injunctive referrals is a STARS/SCAP target. De minimis
settlements is a STARS reporting measures RD/RA negotiation starts and RD/RA negotiation
completions are SCAP targets. The remaining activities are SCAP reporting measures.
The definition for issuance of SNL can be found in both the following and the RI/FS
Enforcement Activities and Settlements sections. The definition for Section 106, 106/107,107
Case Resolution are in this section and the Cost Recovery section. The definition for AR compi-
lation completion appears in the following section and Section 4: Removal Definitions.
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. SARA
specifies that ARs be compiled at sites where remedial or removal responses 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 start date is entered into WasteLAN. The AR compilation is
complete when the compilation is certified by the program office.
A-32
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OSWER Directive 9200.3-01H-1
Changes in Definition FY 92 - FY 93: Completion definition was modified to match
the December 1990 guidance.
Special Planning/Reporting Requirements: The completion of the compilation of the
AR must be reported site specifically in WasteLAN. A "E" must be recorded in the
Event Qualifier field (C2103) to indicate the AR is for a remedial activity. This is a
SCAP reporting measure.
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 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 (RI/FS, RD/RA) and can be extended if necessary.
Definition of Accomplishment: Credit for this activity is given on the date the SNL is
signed by the appropriate EPA official.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
recorded at the milestone level.
RD/RA NEGOTIATION STARTS
Definition: RD/RA negotiations are discussions between EPA and the PRPs on their
liability, willingness and ability to implement the remedy selected in the ROD for the site
orOU.
Definition of Accomplishment: RD/RA negotiations start when:
• The first SNL is signed, or
• A Section 122(a) waiver of SNL is signed.
Changes in Definition FY 92 - FY 93:
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 nego-
tiations is planned site specifcally. This is a SCAP target.
ROD TO RD/RA NEGOTIATION START DURATION
Definition: A remedy is selected when a ROD is signed by either the Regional Adminis-
trator or the AA SWER. RD/RA negotiations begin when the special notice letter is
issued.
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. It also
results in the establishment of a methodology which accurately assesses program perfor-
mance. The Integrated Timeline for Site Management (Volume I, Chapter I) will be used
A-33
-------
OSWER Directive 9200.3-01H-1
for establishing performance expectations. Duration trends provide indicators of areas
that require attention.
Only RODs that resulted from RI/FS projects started post-SARA will be used for
comparison and evaluation.
Definition of Accomplishment: This measure includes all RD/RA negotiations that
have a scheduled start date in FY 93. Regional performance in FY 93 will be compared
to:
• The Regional and national average duration for ROD to RD/RA negotiation start
duration in FY 91 and FY 92; and
• The Regional and national average duration for ROD to RD/RA negotiation start
duration in previous quarters of FY 93.
The durations will be calculated using the actual ROD completion dates and planned and
actual RD/RA negotiation start dates. The S CAP/STARS definitions for Remedies
Selected (ROD) and RD/RA Negotiation Start contained in this Manual will be used in
the analysis.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will conduct the analysis. CERCLIS trend analysis reports are currently
under development. This is a SCAP reporting measure.
RD/RA NEGOTIATION COMPLETIONS
Definition: RD/RA negotiations end when the Region decides how to proceed with the
RD/RA.
Definition of Accomplishment: RD/RA negotiations end when:
A signed CD (Section 106 or 106/107 referral with settlement) for RD/RA and 10
point analysis are referred by the Region to either DOJ or HQ;
• A Section 106 or 106/107 injunctive referral to compel the PRPs to perform the
RD/RA is referred to DOJ or HQ. (HQ prefers that a UAO be issued prior to
initiating an injunctive referral);
• A UAO for RD/RA or RA only to initiate site work is signed by the Regional
Administrator;
• EPA and PRPs proceed to trial under an existing case;
• Funds are obligated for a Fund-lead RD; or
• If RD funds are not available and the Region decides a UAO is not appropriate;
and HQ concurs with this decision in writing, the negotiation completion date is
the date of the HQ memorandum concurring with the UAO decision.
A-34
-------
OSWER Directive 9200.3-01 H-l
The negotiation conclusion date is: the date on the transmittal letter for the CD, the date
on the transmittal letter with the injunctive referral, the date the UAO is signed by the
Regional Administrator, the date the trial begins, the date funds are obligated, or the date
on HQ memorandum.
Changes in Definition FY 92 - FY 93: Injunctive referrals without a UAO are not
recommended. UAOs are for RD/RA or RA only.
Special Planning/Reporting Requirements: This SCAP target is planned site specifi-
cally in WasteLAN.
ROD TO RD/RA NEGOTIATION COMPLETION DURATION
Definition: A remedy is selected when a ROD is signed by either the Regional Adminis-
trator or AA SWER. RD/RA negotiations end when the Region decides how to proceed
with the RD/RA.
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. It also
results in the establishment of a methodology which accurately assesses program perfor-
mance. The Integrated Timeline for Site Management (Volume I, Chapter I) will be used
for establishing performance expectations. Duration trends provide indicators of areas
that require attention.
Only RODs that resulted from RI/FS projects started post-SARA will be used for com-
parison and evaluation.
Definition of Accomplishment: The purpose of this measure is to evaluate Regional
performance in managing the RD/RA negotiation process. It includes all RD/RA nego-
tiations with a scheduled completion date in FY 93. The SCAP/STARS definitions for
Remedies Selected (ROD) and RD/RA Negotiation Completion contained in this Manual
will be used in the analysis. Regional performance in FY 93 will be compared to:
• The Regional and national average duration for ROD to RD/RA negotiation
completion in FY 91 and FY 92; and
• The Regional and national average duration for ROD to RD/RA negotiation
completion in previous quarters of FY 93.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. The durations will be calculated using the actual ROD completion dates and
planned and actual RD/RA negotiation completion dates. HQ will conduct the analysis.
CERCLIS trend analysis reports are currently under development. This is a SCAP
reporting measure.
RD/RA NEGOTIATION DURATION
Definition: RD/RA negotiations are discussions between EPA and the PRPs on their
liability, willingness and ability to implement the remedy selected in the ROD for the site
orOU.
A-35
-------
OSWER Directive 9200.3-01H-1
The RD/RA negotiations start when the SNL is signed or a Section 122(a) waiver of SNL
is signed. RD/RA negotiations are complete when a signed CD is referred to DOJ or HQ,
a Section 106 or 106/107 referral to enforce a UAO for RD/RA is referred to DOJ or HQ,
a UAO is issued, EPA and the PRPs proceed to trial under an existing case, or funds are
obligated for a Fund-lead RD.
Definition of Accomplishment: This measure includes all RD/RA negotiations that
have a targeted completion date in FY 93. Regional performance in FY 93 will be
compared to:
• The Regional and national average duration of RD/RA negotiations completed in
FY 91 and FY 92; and
• The Regional and national average duration of RD/RA negotiations completed in
previous quarters of FY 93.
The durations will be calculated using the actual RD/RA negotiation start dates and
planned and actual RD/RA negotiation completion dates. The SCAP/STARS RD/RA
negotiation start and completion definitions specified in this Manual will be used in the
analysis.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will perform the analysis. Trend duration reports are currently under
development. This is a SCAP reporting measure.
RD/RA SETTLEMENTS AND INJUNCTIVE REFERRALS (S/E-1A AND IB)
Definition: RD/RA settlements are the enforcement actions when the PRPs agree to
conduct the RD and/or RA. That agreement is embodied in a CD. Injunctive referrals
are actions taken to enforce UAOs for RD/RA.
Definition of Accomplishment:
1) RD/RA Settlements (S/E-la) - This measure includes all CD referrals under Section
106, 107 and 122(d) for PRPs to conduct or pay for RD/RA. It includes mixed funding
and cash out settlements for RD/RA. Credit for the CD referral is the date on the Re-
gional Administrator's transmittal memo to HQ or to the DOJ as recorded in WasteLAN.
Regions also receive credit for this measure for UAOs issued under Section 106 for
RD/RA that are in compliance. Credit for UAOs is the date PRPs provide notice of intent
to comply with the order as recorded in WasteLAN. (Should a PRP initially comply with
a UAO, and later a CD is agreed to for the same work, credit will be for the UAO only.)
Also included in this measure are lAGs with Federal agencies at non-Federal Facility
sites.
2) RD/RA Injunctive Referrals (S/E-lb) - This measure includes injunctive referrals,
under Section 106 or 106/107, to enforce a UAO for RD/RA. Credit for the referral is the
date on the Regional Administrator's transmittal memo to HQ or to the DOJ as recorded
in WasteLAN. (Referrals for preliminary relief or penalties do not count toward this
measure.)
A-36
-------
OSWER Directive 9200.3-01H-1
Changes in Definition FY 92 - FY 93: The measure includes lAGs at non-Federal
Facility sites.
Special Planning/Reporting Requirements: RD/RA settlement and injunctive referrals
are a combined targets in STARS. TBD sites are allowed with an explanation. Credit
will be withdrawn if a case is returned by OE or DOJ for additional work. Credit will be
reinstated upon re-referral and will be based on the quarter of re-referral. In the event a
case is referred in one year and returned to the Region in subsequent years, no credit will
be provided for re-referral.
UNILATERAL ADMINISTRATIVE ORDERS (UAO) ISSUED FOR RD/RA
Definition: UAOs are an enforcement tool to compel the PRPs to conduct the RD and/or
RA.
Definition of Accomplishment: This measure includes UAOs issued under Section 106
to compel PRPs to conduct the RD/RA. Credit is based on the date the UAO is signed by
the Regional Administrator as recorded in WasteLAN. PRPs do not have to comply with
the UAO in order for the Region to receive credit under this measure.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: UAOs are reported separate from RD/RA
settlements and injunctive referrals. This is a SCAP reporting measure.
MIXED FUNDING SETTLEMENTS
Definition: Administrative or judicial settlements under Section 106 or 106/107 and
Section 122(b)(l) of SARA. Mixed funding generically refers to three types of settle-
ments: 1) preauthorization, 2) mixed work, and 3) cash outs. Preauthorization occurs
where PRPs reach a settlement with EPA whereby they agree to perform a share of the
response actions, and the Agency agrees to reimburse some part of their expenses. Mixed
work occurs where PRPs and EPA agree to jointly work on a project or where work may
be divided between the parties. Cash outs are funds received by EPA, a State, or another
PRP to pay for all or part of the future cost for a response action that is or may be imple-
mented at a site.
Definition of Accomplishment: This measure includes mixed funding settlements in the
form of a CD or AOC between EPA and the PRPs. Credit for the CD is the date on the
Regional Administrator's memo transmitting the referral to HQ or DOJ as recorded in
WasteLAN. Credit for the AOC is based on the date it is signed by the Regional Admin-
istrator as recorded in WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure only.
The remedy qualifier for cash out ("CO"), mixed work ("MW"), or preauthorization
("PA") must be entered into WasteLAN Enforcement Remedy Qualifier (C2741 -
C2750).
A-37
-------
OSWER Directive 9200.3-01 H-l
MINIMIS SETTLEMENTS AND NUMBER OF PRPS (S/E-3A)
Definition: This is all administrative or judicial settlements that were reached solely
under Section 122(g) of SARA, with PRPs who qualified as ds minimis PRPs under
Section 122(g). This settlement involves the established de minimis portions of the
response costs at the site and is embodied in a CD or an AOC. If the total response costs
at the site exceed $500,000 (excluding interest), the AOC can only be issued with DOT
prior written approval. If DOJ does not approve or disapprove the AO within 30 days,
the AOC is considered approved and can be issued. (DOJ and the Administrator can
agree to extend this 30-day period.)
Definition of Accomplishment: Credit is given for a final settlement when an AOC is
signed by the Regional Administrator (as reported in WasteLAN) or when the Regional
Administrator signs the memo transmitting the CD to HQ or DOJ (as reported in
WasteLAN). The number of PRP signatories to each settlement must also be reported.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: The remedy qualifier for de minimis must
be entered into WasteLAN Enforcement Remedy Qualifier data elements (C2741 -
C2750 = "DL" or "DG"). This is a STARS reporting measure.
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;
• The case is dismissed; or
• A trial concluded and a judgment entered fully addressing the complaint.
The case resolution date (activity actual completion date) is the same as the milestone
date and is defined as follows:
• Date CD is entered;
• Date case is withdrawn;
• Date case is dismissed; or
• Date judgment is entered.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
A-38
-------
OSWER Directive 9200.3-01H-1
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 or
party. All WasteLAN coding requirements for CDs apply. The enforcement activity
type (C1701) should be State decree ("SD") and the date should be reported in C1717. In
addition, the remedy field must denote that the CD was issued for RD and/or RA.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure not a
targeted activity.
A-39
-------
OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
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A-41
-------
OSWER Directive 9200.3-01H-1
REMEDIAL DESIGN (RD)
RD activities are planned site, OU and project specifically and reported in WasteLAN.
Initial schedules for RD are established when the RI/FS for the site is initiated. These initial
schedules must be updated in WasteLAN as better planning data become available. The funds
for Fund-financed RDs and oversight of RP-lead RDs are pulled directly from WasteLAN and
allocated in the RD AOA. Funds for oversight of Federal Facility RDs are in the Federal Facility
AOA. The following SCAP and STARS activities are tracked:
First RD Start (Fund-financed, PRP and Federal Facility);
• Subsequent RD Start (Fund-financed, PRP and Federal Facility);
ROD Signature to RD Start Duration (Fund-financed and PRP);
• First RD Completions (Fund-financed, PRP and Federal Facility);
• Subsequent RD Completions (Fund-financed, PRP and Federal Facility); and
• Federal Facility RD Start to RD Complete Duration.
RD starts and RD completions are SCAP targets. Separate targets for first and subse-
quent and Fund, PRP and Federal Facility RD starts and first and subsequent, Fund/PRP, and
Federal Facility RD completions are established prior to the FY. Duration from ROD signature
to RD start and Federal Facility RD start to RD complete duration are SCAP measures.
In the definitions below, first and subsequent RD starts and first and subsequent RD
completions have been combined.
DESIGN ASSISTANCE
Definition: Design assistance activities are undertaken by the USAGE in preparation for
initiating RD activities. This includes:
• Synopsize RD requirements in the Commerce Business Daily (CBD);
• Develop architect/engineer (A/E) firm pre-selection list;
• Contact A/E firms on the pre-selection list to ascertain interest in project;
• Develop A/E selection list; and
• Tentative selection of 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 92 - FY 93:
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 or non-site specifically;
A-42
-------
OSWER Directive 9200.3-01H-1
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 other response
AOA.
ROD SIGNATURE TO RD START DURATION
Definition: A remedy is selected when a ROD is signed by either the Regional Adminis-
trator or the AA SWER. An RD is started when funds are obligated for RD or when the
RD contract is awarded by the PRPs.
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. It also
results in the establishment of a methodology which accurately assesses program perfor-
mance. The Integrated Timeline for Site Management (Volume I, Chapter I) will be used
for establishing performance expectations. Duration trends provide indicators of areas
that require attention.
Only RODs where the RI/FS started post-SARA will be used for comparison and evalua-
tion.
Definition of Accomplishment: The purpose of this measure is to evaluate Regional
performance in managing the timeframe between ROD and the start of RD. The SCAP/
STARS definitions for Remedies Selected (ROD) and RD Start contained in this Manual
will be used in the analysis. This measure includes all RDs scheduled to begin in FY 93.
Regional performance will be compared to:
• The Regional and national average duration between ROD and RD start in FY 91
and FY 92; and
• The Regional and national average duration between ROD and RD start in previ-
ous quarters of FY 93.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. CERCLIS will automatically look at actual ROD completion dates and
planned and actual RD start dates. HQ will conduct the analysis. CERCLIS trend analy-
sis reports are currently under development. This is a SCAP reporting measure.
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. The obligation of funds for design assistance or techni-
cal assistance do not constitute an RD start. Under certain circumstances, an RD may be
prepared by other parties (i.e., water lines where the city already prepared plans and
specifications); or the plans developed for one site may be used at a similar site.
Subsequent RD starts occur at NPL sites where previous RD activity has taken place.
A-43
-------
OSWER Directive 9200.3-01H-1
Definition of Accomplishment:
Fund-financed (Includes F and S lead events.) - A Fund RD start is counted when funds
are obligated. An obligation is made when:
• The CO signs the contract modification for the RD;
• A CA is signed by the Regional Administrator or his designee; or
• An LAG is signed by the other Federal agency.
In those instances where RD activities are conducted prior to ROD signature and there is
not a new obligation of funds for a subsequent RD, the start of RD is defined as the
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 an RD has been
prepared by other parties or plans developed for a similar site will be used, the RD start
date is the same as the RA 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 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 appropriate dates for the RD start and the associated enforcement docu-
ment 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 allows the PRPs to proceed.
Federal Facility - If post-ROD, the RD start date is the date of submission of RD work
plan or statement of work. If work begins prior to the ROD, the RD start date will coin-
cide with the ROD date.
Changes in Definition FY 92 - FY 93: Federal Facility RD start definition was added.
The PRP start date is when the Region approves the PRP contractor.
Special Planning/Reporting Requirements: Separate first and subsequent start SCAP
targets are established. Separate Fund, PRP and Federal Facility financed RD start goals
are established prior to the FY.
RD COMPLETIONS - FIRST AND SUBSEQUENT
Definition: An RD is complete when the plans and specifications and, in the case of a
Fund-financed RD, an RA bid package for the selected remedy are developed.
Definition of Accomplishment:
Fund-financed - For F or S lead RD projects, an RD completion is the date that EPA
concurs on or approves and accepts the plans, specifications and RA bid package. When
A-44
-------
OSWER Directive 9200.3-01H-1
the Fund performs the RD and the PRPs will do the RA under a CD, the RD completion
is the date that EPA concurs on or approves and accepts the plans and specifications.
PRP-financed - An RD is complete on the date that EPA concurs on or approves and
accepts the plans and specification. For PS-lead RDs, the RD is complete when the State
concurs on or approves and accepts the plans and specifications.
Federal Facility - The date of EPA approval of the final RD package.
Changes in Definition FY 92 - FY 93: Federal Facility RD completion definition was
added. RDs no longer have to be sent to the Hazardous Site Control Division (HSCD)
for concurrence. A sentence was added that defined the RD completion when the Fund
performed the RD and the PRPs will perform the RA.
Special Planning/Reporting Requirements: Separate SCAP targets are established for
first versus subsequent and Fund/PRP versus Federal Facility RD completions.
FEDERAL FACILITY RD START TO RD COMPLETE 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, onsite 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
remedial timeframes are reduced to the maximum extent possible.
Definition of Accomplishment: This measure will look at Regional performance by
analyzing the average duration from RD start to RD completion for sites scheduled for
RD completion in FY 93. Duration will be calculated using the actual RD start dates and
the planned and actual RD completion dates in WasteLAN. RD start to RD completion
durations that are less than five quarters will be counted. For sites where the ROD leads
to RDs at different OUs, links data will be used. The RD start and RD completion defini-
tions contained in this Manual will be used in the analysis.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. CERCLIS will automatically look at actual RD start dates and planned and
actual RD completion dates. HQ will conduct the analysis. This is a SCAP reporting
measure.
A-45
-------
OSWER Directive 9200.3-01H-1
•'• ; • •• :;: •. '• jJVIHfl
.• : • . • • . ' • : . • . ' ' . *£**«•
PLANNING REQUIREMENTS
STARS?
SCAP?
TARGET OR MEASURE?
QUARTERLY TARGETS?
IF YES, WHEN?
PLANNED SITE SPECIFICALLY?
IF YES, WHEN?
PLANNED/REPORTED ON
OPERABLE UNIT OR WHOLE
SITE BASIS?
REPORTED ON COMBINED
PROGRAM LEAD OR ON A
PROGRAM-SPECIFIC BASIS?
REPORTED SITE SPECIFICALLY
OR IN NON-SITE PORTION OF
WASTE LAN?
AOA CATEGORY IF FUND
FINANCED ACTION?
AOA FOR OVERSIGHT?
BASIS FOR AOA?
DESIGN
ASSIST.
NO
NO
NO
NOT REQ.
OPERABLE
UNIT
N/A
NOT
REQUIRED
OTHER
RESPONSE
N/A
SITE OR
NON-SITE
PLANS
BIT A-8j REMEDIAL E>ESIGN ; " ' '......•/..;•';.•:"
DURATION
ROD TO RD
NO
YES
MEASURE
NO
NO
OPERABLE
UNIT
COMBINED
FUND & PRP
N/A
N/A
N/A
N/A
FIRST RD
START
NO
YES*
TARGET
YES
PRIOR TO
FY
YES
PRIOR TO
FY
OPERABLE
UNIT
COMB. #
FUND & PRP
SEPARATE
FEDERAL
FACILITY
SITE
SPECIFIC
REMEDIAL
DESIGN
REMEDIAL
DESIGN OR
FEDERAL
FACILITY
SITE SPEC.
PLANS OR
FEDERAL
FACILITY
WORKLOAD
MODEL
SUB. RD
START
NO
YES*
TARGET
YES
PRIOR TO
FY
YES
PRIOR TO
FY
OPERABLE
UNIT
COMB. #
FUND & PRP
SEPARATE
FEDERAL
FACILITY
SITE
SPECIFIC
REMEDIAL
DESIGN
REMEDIAL
DESIGN OR
FEDERAL
FACILITY
SITE SPEC
PLANS OR
FEDERAL
FACILITY
WORKLOAD
MODEL
FIRST RD
COMP.
NO
YES*
TARGET
YES
PRIOR TO
FY
YES
PRIOR TO
FY
OPERABLE
UNIT
COMB.
FUND & PRP
SEPARATE
FEDERAL
FACILITY
SITE
SPECIFIC
N/A
N/A
N/A
SUB. RD
COMP.
NO
YES*
TARGET
YES
PRIOR TO
FY
YES
PRIOR TO
FY
OPERABLE
UNIT
COMB.
FUND & PRP
SEPARATE
FEDERAL
FACILITY
SITE
SPECIFIC
N/A
N/A
N/A
FFRD
DURATION
NO
YES
MEASURE
NO
NO
OPERABLE
UNIT
PROGRAM
SPECIFIC
SITE
SPECIFIC
N/A
N/A
N/A
# Goals are established on a program specific basis.
* Includes projects with the following leads: Federal (F), State (S), PRP action under State order/decree (PS), In-house RD
-------
OSWER Directive 9200.3-01H-1
REMEDIAL ACTION (RA)
Following are the SCAP and STARS activities tracked for RA:
• ROD Signature to RA Start Duration (Fund-financed, PRP, and Federal Facility);
First RA Start (Fund-financed, PRP and Federal Facility);
• First RA Contract Award (Fund-financed and PRP);
• Subsequent RA Start (Fund-financed, PRP and Federal Facility);
• Subsequent RA Contract Award (Fund-financed and PRP);
• Award of RA Contract (Federal Facility);
• RA On-Site Construction (Fund-financed and PRP);
• RA Construction Completion (Fund-financed and PRP);
• First RA Completion (Fund-financed, PRP and Federal Facility);
• Subsequent RA Completion (Fund-financed, PRP and Federal Facility);
• Final RA NPL Site Construction Completion (Fund-financed and PRP);
• Final RA Completion (Fund-financed, PRP and Federal Facility);
• Federal Facility RI/FS Start to RA Complete Duration; and
• Federal Facility RA Start to RA Complete Duration.
RAs are planned site, OU and project specifically and reported in WasteLAN. Initial
schedules for RA are established when the RI/FS for the site is initiated. These initial schedules
must be updated in WasteLAN as better planning data become available. Funds for Fund-
financed RAs are allocated site specifically in the RA AOA. Funds for oversight of Federal
Facility RA activities are available in the Federal Facility AOA. Funds for oversight of RP-lead
RAs are placed in the RD AOA.
Federal Facility RA starts, Fund and PRP award of RA contract are SCAP/STARS
targets. Fund and PRP first and subsequent RA starts, first, subsequent and final fund and PRP
RA completions, and first and subsequent Federal Facility RA completions are SCAP targets.
RA construction completion is a STARS measure. Final RA NPL Construction Completion is
contained in the STARS measure S/C-3, NPL Site Construction Completions. The definition for
NPL Site Construction Completions can be found in Section 3: Response Definitions. The
duration from ROD signature to RA start, Federal Facility award of RA contract, RA on-site
construction, final Federal Facility RA completions, RA construction completion, Federal Facil-
ity RI/FS start to RA complete duration, and Federal Facility RA duration are SCAP measures.
In the definitions below, first and subsequent RA starts, first and subsequent award of RA
contract, and first and subsequent RA completions have been combined.
A-47
-------
OSWER Directive 9200.3-01H-1
ROD SIGNATURE TO RA START DURATION
Definition: A remedy is selected when a ROD is signed by either the Regional Adminis-
trator or the AA SWER. A Federal Facility remedy is selected when the EPA approves/
concurs on the Federal Facility decision document. An RA is started when funds are
obligated for RA, EPA approves the PRP RD package, or the CD for RA is referred to
HQ or DOJ. The Federal Facility RA starts when substantial, continuous, physical on-site
remedial actions begin pursuant to SARA Section 120.
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:. It also
results in the establishment of a methodology which accurately assesses program perfor-
mance. The Integrated Timeline for Site Management (Volume I, Chapter I) will be used
for establishing performance Fund-financed and PRP expectations. Duration trends will
provide indicators of areas that require attention.
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 provide a method for tracking compliance
with this key program requirement.
Only RODs that resulted from RI/FS projects started post-SARA will be used for com-
parison and evaluation.
Definition of Accomplishment: This measure will look at Regional performance by
comparing the average duration from ROD signature to RA start for all sites scheduled
for RA start in FY 93 to:
• The Regional and national average duration from ROD signature to RA start in
FY91andFY92;and
• The Regional and national average duration from ROD signature to RA start in
previous quarters of FY 93.
The durations will be calculated using the actual ROD completion dates and the planned
and actual RA start dates in WasteLAN. The ROD completion and RA start definitions
contained in this Manual will be used in the analysis.
Federal Facility ROD signature to RA start durations that are less than five quarters will
be counted.
Changes in Definition FY 92 - FY 93: Added Federal Facility duration analysis.
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will conduct the analysis. Fund, PRP and Federal Facility duration will
be tracked. For sites where the ROD leads to RAs at different OUs, links data will be
used. CERCLIS trend analysis reports are currently under development. This is a SCAP
reporting measure.
A-48
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OSWER Directive 9200.3-01H-1
RA START — FIRST AND SUBSEQUENT
Definition : An RA start is the implementation of the remedy selected in the ROD at
final NPL sites that is intended to ensure protection of human health and the environ-
ment.
Definition of Accomplishment:
Fund-financed (F or S lead events) - Credit for an RA start is given on the date a con-
tract modification for the RA is signed by the CO or the IAG or CA is awarded, and
funds are obligated. This date is entered into WasteLAN with the RA event.
PRP-financed (RP, MR or PS lead events) - Credit for an 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 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 docu-
ment, and the site is covered by a State enforcement cooperative agreement or
SMOA (PS-lead) with a schedule for RA 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 judg-
ment for RA only, the RA start is the date on which the PRPs provide notice of
intent to comply with the UAO (C2801 = "NC") or the date the CD is referred to
HQ or DOJ (as recorded in WasteLAN). 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 Remedial Technol-
ogy of the RA into the RA Technology Type date field (C3401 = RT) and the remedial
technology types data fields (C3402 - C3411) for the RA event.
Federal Facility - Date of which substantial, continuous, physical, on-site, remedial
actions begin pursuant to SARA Section 120.
Changes in Definition FY 92 - FY 93: Federal Facility RA start is included. Added in
the requirement to record the RA technology type. For PS-lead sites, the RA starts when
the State approves the RD package.
Special Planning/Reporting Requirements: Fund and PRP RA starts is a SCAP target.
Federal Facility RA starts is a STARS target. The Region must enter the remedial tech-
nology of the RA into WasteLAN.
RA CONTRACT AWARD (S/C-1)
Definition: Award of RA contract is the initiation of on-site construction activities for
the remedy selected in the ROD.
A-49
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OSWER Directive 9200.3-01 H-l
Definition of Accomplishment:
Fund-financed (F or S lead events) - Sites (as recorded in WasteLAN) where the EPA, a
State, the USAGE or BUREC has awarded a contract to initiate 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 Emergency Response Cleanup
Services (ERCS) contractor will be performing the RA, award of RA contract is defined
as the obligation of funds to the ERCS contractor for the RA.
PRP-financed (RP, MR or PS lead events) - Sites (as recorded in WasteLAN) where 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.
Federal Facility - Date where the Federal agency has begun substantial and continuous
physical action at a site, which is equivalent to an EPA contract award, or the date where
the Federal agency has taken equivalent action with its own work force.
Changes in Definition FY 92 - FY 93: Added Fund-financed situations where ARCS or
ERCS are assigned the RA activities. Added a Federal Facility definition.
Special Planning/Reporting Requirements: First and subsequent, Fund and PRP RA
contract awards are a single STARS target. Individual targets are negotiated in SCAP.
Federal Facility award of RA contract is a SCAP measure. RA contract award triggers the
date for completion of Five Year Reviews. (See new measure for Five Year Reviews in
Section 3: Response Definitions.)
RA ON-SITE CONSTRUCTION
Definition: RA on-site construction begins when the EPA, ARCS, ERCS, USAGE,
BUREC or State contractor for a Fund-financed RA or the PRP or PRP's contractor for a
PRP RA, mobilizes to start implementation of the selected remedy.
Definition of Accomplishment: The date of mobilization must be placed in WasteLAN
against the RA subevent (3101) "RO" (on-site construction).
Changes in Definition FY 92 - FY 93: Added ARCS and ERCS.
Special Planning/Reporting Requirements: The planned completion date for RA on-
site construction must be placed in WasteLAN when the RA contract is awarded. This
date is used for planning cost recovery actions and establishing Statute of Limitation
(SOL) dates. This is a SCAP reporting measure.
RA CONSTRUCTION COMPLpJ^ON (S/C-2)
Definition: RA construction is complete when all construction activities for the OU have
been performed and a final inspection has been conducted. The time period to determine
if the remedy is Operational and Functional (O&F) still remains. This is equivalent to the
definition for Final RA NPL Site Construction Completion.
A-50
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OSWER Directive 9200.3-01 H-l
Definition of Accomplishment: The date the lead and support agencies conduct the final
inspection. This date must be entered into WasteLAN with the RA subevent, Final In-
spection and Certification (C3101=IN).
Changes in Definition FY 92-FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: RA construction completion is reported
site specifically in WasteLAN. This is a STARS reporting measure.
FINAL RA NPL SITE CONSTRUCTION COMPLETION
Definition: Final NPL RA site construction is complete when construction activities for
the final OU are complete, a pre-final inspection has been conducted, and a Preliminary
Close-Out Report prepared. This report documents the completion of physical construc-
tion, summarizes site conditions and construction activities and, as appropriate, provides
the schedule for the joint inspection (required before the start of the O&F phase), ap-
proval of the Operation and Maintenance (O&M) work plan, and the establishment of
institutional controls. The Preliminary Site Close-Out Report is only required for the final
OU.
Definition of Accomplishment: The date that the designated Regional official (Division
Director or above) signs the Preliminary Site Close-Out Report documenting, based on a
pre-final site inspection, that physical construction is complete and only minor inspec-
tion/punch list items remain. The appropriate date must be recorded in WasteLAN with
the RA subevent, Preliminary Close-Out Report Prepared (C3101=CC).
Changes in Definition FY 92-FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: Final RA site construction completion is
reported site specifically in WasteLAN. A new subevent for Preliminary Close-Out
Report Prepared (C3101=CC) has been added to WasteLAN. This will be valid for RA
and ROD events. This is a SCAP reporting measure. Final RA NPL Site Construction
Complete is also included in the STARS measure S/C-3 NPL Site Construction Comple-
tion. The definition for NPL Site Construction Completion can be found in Section 3:
Response Definitions.
OPERATIONAL AND FUNCTIONAL (O&F)
Definition: O&F means the activities required to determine that the remedy is function-
ing properly and is performing as designed. O&F activities are part of RA when a Fund-
financed RA was 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 joint inspection by
EPA and the State, or until EPA and the State jointlyjietermine that the remedy is func-
tioning properly and is performing as designed, whiUfever is earliest. EPA may extend
the one-year period, as appropriate.
Definition of Accomplishment: The completion of O&F is the date upon which the lead
and support agencies agree through a joint inspection that the remedy is operating in
accordance with the standards contained in the ROD and RD. This documentation is
reported in RA Report. Normally, O&F completion will occur within one year following
completion of construction.
A-51
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OSWER Directive 9200.3-01H-1
Changes in Definition FY 92 - FY 93: O&F only has a completion date.
Special Planning/Reporting Requirements:
RA COMPLETION
Definition: A first and subsequent RA is complete when construction activities are
complete, a final inspection has been conducted, the remedy is O&F (see definition for
O&F), and an RA Report has been prepared. 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 contractor's construction manager (ARCS, USAGE, State, PRP, Federal Facility,
etc.) 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 con-
struction manager, the Region must prepare a report to document the completion. The
appropriate date must be recorded in WasteLAN with the RA event.
Changes in Definition FY 92 - FY 93: The RA Report is accepted by the Branch Chief
or above, not the Regional Administrator.
Special Planning/Reporting Requirements: Commitments are made on a combined
Fund and PRP basis. Federal Facility RA completion commitments are made separately.
First and subsequent Federal Facility RA completions is a SCAP target. First, subse-
quent and final Fund and PRP RA completions are SCAP targets. (See following defini-
tion for final RA completion.)
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 (required before the start of the O &
F phase), approval of the O&M work plan, and establishment of institu-
tional control. The date of the Preliminary Close-Out Report must be
reported in WasteLAN with the RA Subevent, Preliminary Close-Out
Report Prepared (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 Re-
gional official. The date of the letter is entered into WasteLAN as the RA
completion date (C2101=RA); and
A-52
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OSWER Directive 9200.3-01 H-l
• An Interim Site Close-Out Report or Final Superfund Site Close-Out
Report has been prepared. An Interim Site Close-Out Report must be
prepared if the only activity remaining is Long Term Response Action
(LTRA).
Definition of Accomplishment: The final RA is complete on the date the Regional
Administrator signs the Interim Site Close-Out Report or Final Superfund Site Close-Out
Report documenting completion of the final RA. The appropriate date must be recorded
in WasteLAN with the Close-Out Report RA subevent (C3101=CL).
Changes in Definition FY 92-FY 93: More details were added to the definition for
clarification.
Special Planning/Reporting Requirements: The date of completion of the Preliminary
Close-Out Report must be entered into WasteLAN with the Preliminary Close-Out
Report Prepared subevent (C3101 = CC). The date of the letter accepting the RA Report
must be entered into WasteLAN with the RA event (C2101=RA). The date the Regional
Administrator signs the Interim or Final Superfund Site Close-Out Report must be en-
tered into WasteLAN with the Close-Out Report subevent (C3101=CL).
First, subsequent and final, Fund and PRP RA completions are SCAP targets. Final
Federal Facility RA completions is a SCAP measure.
FEDERAL FACILITY RI/FS START TO RA COMPLETE DURATION:
Definition: The objective of this measure is to focus on the duration of the essential
components of the remedial pipeline. As an indicator of the project duration, this mea-
sure reflects the success of EPA in reducing the length of time needed to complete reme-
dial activities at Federal Facilities. Duration trends will address the need for continuous
improvements relative to meeting the Office of Federal Facilities Enforcement (OFFE)
goals.
Definition of Accomplishment: This measure will look at Regional performance by
analyzing the average duration from RI/FS start to RA completion for sites scheduled for
RA completion in FY 93. Duration will be calculated using the actual RI/FS start dates
and the planned and actual RA completion dates in WasteLAN. The RI/FS start and RA
completion definitions contained in this Manual will be used in the analysis.
Changes in Definition FY 92 - FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will conduct the analysis. This is a SCAP reporting measure.
FEDERAL FACILITY RA START TO RA COMPLETE DURATION:
Definition: The objective of this measure is to project the success, as well as the com-
plexity, of the Federal Facilities Superfund program. The measure will also enable
management to focus on sites where additional emphasis on enhancing the pace of re-
sponse 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 pos-
sible.
A-53
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OSWER Directive 9200.3-01H-1
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 93. Durations will be calculated using the actual RA start dates
and the planned and actual RA completion dates in WasteLAN. The RA start and RA
completion definitions contained in this Manual will be used in the analysis.
Changes in Definition FY 92 - FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will conduct the analysis. This is a SCAP reporting measure.
LONG TERM RESPONSE ACTION (LTRA)
Definition: LTRA are response actions undertaken for the purpose of restoring ground
or surface water quality. (Guidance is currently under development that will expand the
LTRA definition to include soil vapor extraction and similar remedies.) These actions
require a continuous period of on-site activity before cleanup levels, specified in the ROD
or an Action Memorandum, are achieved.
For Fund-financed RAs involving treatment or other measures to restore contaminated
ground or surface water quality, die 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 jointly deter-
mine 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, which-
ever is earliest.
Changes in Definition FY 92 - FY 93: Deleted the phrase that the source control mea-
sures to prevent contamination of ground or surface water are not considered LTRA.
Deleted acceptance of Interim Site Close Out Report from the definition.
Special Planning/Reporting Requirements: LTRA is planned on a site-specific basis
in WasteLAN and is used for resource allocation purposes only. Funds for LTRA are
issued site specifically in the RA AOA.
A-54
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OSWER Directive 9200.3-01H-1
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 measures to restore ground or surface waters,
continued operation of such measures beyond a period of ten years or when the remedia-
tion 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 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 Report. This report docu-
ments 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, Superfund State Contract (SSC), or CD.
Changes in Definition FY 92 - FY 93: O&M starts when the Region signs a letter
accepting the RA Report.
Special Planning/Reporting Requirements: O&M is planned site specifically in
WasteLAN and is used for resource allocation purposes only. Funds for oversight of
O&M are contained in the RA AOA.
A-55
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OSWER Directive 9200.3-01H-1
SUB.RA
START
FIRST RA
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A-56
-------
OSWER Directive 9200.3-01H-1
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BASIS FOR AOA?
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funding (MR), and Federal Facility (
A-57
-------
OSWER Directive 9200.3-01H-1
BXH1B1T Ar9: RlkEplALACTIOH (CONTINUED)
PLANNING REQUIREMENTS
STARS ?
SCAP?
TARGET OR MEASURE?
QUARTERLY TARGETS SET?
IF YES, WHEN?
PLANNED SITE SPECIFICALLY?
IF YES, WHEN?
PLANNED/REPORTED ON
OPERABLE UNIT OR WHOLE
SITE BASIS?
REPORTED ON COMBINED
PROGRAM LEAD OR ON A
PROGRAM-SPECIFIC BASIS?
REPORTED SITE SPECIFICALLY
OR IN NON-SITE PORTION OF
WASTELAN?
AOA CATEGORY IF FUND
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AOA CATEGORY FOR
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BASIS FOR AOA?
FF RI/FS TO
RACOMP
NO
YES
MEASURE
NO
NO
OPERABLE
UNIT
PROGRAM
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SITE
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N/A
N/A
N/A
FFRA
DURATION
YES**
YES
MEASURE
NO
NO
OPERABLE
UNIT
PROGRAM
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SITE
SPECIFIC
N/A
N/A
N/A 1
O&F
NO
NO
NO
NO
N/A
N/A
N/A
N/A
N/A
N/A
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NO
NO
NO
NO
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UNIT
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NO
NO
NO
NO
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N/A
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SITE
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* First and subsequent are a combined target under STARS and include Fund and PRP action.
** Final RA construction completions are also included in STARS measure S/C-3 NPL Site Construction Completions.
# Goals are established on a program-specific basis.
+ Includes projects with the following leads: Federal (F), State (S), PRP action under State order/decree (PS), Responsible
party under Federal order /decree (RP), Mixed funding (MR), and Federal Facility (FF).
A-58
-------
OSWER Directive 9200.3-01H-1
COST RECOVERY
SCAP and STARS track the following cost recovery activities:
• Issue Demand Letters;
• Cost Recovery Actions/Decisions (<$200,000);
• Cost Recovery Actions/Decisions (>$200,000);
Section 106, 106/107, 107 Case Resolution; and
• Dollars Achieved Toward Cost Recovery Management by Objective (MBO) Goal.
Cost recovery actions/decisions (>$200,000) is a STARS target. Cost recovery action/
decisions (<$200,000) is a STARS measure. The remainder of the cost recovery activities are
SCAP reporting measures.
The definition for Section 106,106/107,107 Case Resolution are in this section and the
RD/RA Enforcement Activities, Settlements and Referrals section.
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: Credit for this activity is given on the date the demand
letter is signed by the appropriate EPA official and recorded in WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
recorded at the milestone level.
COST RECOVERY ACTIONS/DECISIONS LESS THAN $200,000
Definition: Cost recovery actions/decisions taken are defined as 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 Alternative Dispute Resolution (ADR)
(mediation, arbitration, mini-trial), preparation of a decision document not to pursue cost
recovery, settlement for past costs under a CD (with no prior referral), 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 as recorded in WasteLAN.
A-59
-------
OSWER Directive 9200.3-01 H-l
Settlement under CD (with no prior referral) - Credit is given on the date of the Regional
Administrator's transmittal letter to HQ or DOJ as recorded in WasteLAN.
Cash out settlements - Credit is given on the date of the Regional Administrator's trans-
mittal letter to HQ or DOJ or when the Regional Administrator signs the AOC for the
cash out. This date must be recorded in WasteLAN.
Decision documents prepared not to pursue cost recovery claims - Credit is given when
the document is issued by the Regional office and recorded in WasteLAN.
Administrative Settlement - 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.
Initiation of ADR - Credit is given on the date that the Region refers the case to the
Office of Enforcement (OE) for selection of a mediator or arbitrator as reported in
WasteLAN. An activity code or milestone will be added to WasteLAN to track ADRs.
Bankruptcy Filing - Credit is given based on the date that the bankruptcy strategy pack-
age is prepared or on the date that the first creditor committee meeting convenes as
reported in WASTELAN. New bankruptcy filing milestones have been added to
WasteLAN: C2801 = CP (Creditors Committee Meeting) and BS (Bankruptcy Strategy
Package).
Initiation of Debt Collection Procedures - Credit is given on the date the demand letter
indicating use of debt collection procedures is signed by the EPA official as reported in
WasteLAN. New debt collection milestones have been added to WasteLAN: C2801 =
CS (Collection Services); AF (Administrative Offset); and TF (Tax Refund Offset).
These milestones are valid only for activity AV (Administrative/Voluntary Cost Recov-
ery). A new statute code (C2771) will be added to WasteLAN for the Debt Collection
Act.
Changes in Definition FY 92 - FY 93: This definition encompasses the following FY
92 measures: Issue Cost Recovery Decision Document, Use of ADR for Cost Recovery,
Administrative Cost Recovery Settlements and Section 107 Referrals/Settlements
<$200,000. Bankruptcy case filings were added. The WasteLAN codes for reporting
accomplishments were added to the definitions.
Special Planning/Reporting Requirements: This is a STARS reporting measure. All
dates must be entered into WasteLAN. Credit for referrals is based on the referral pack-
age 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. New WasteLAN activity codes were developed for
reporting, debt collection procedures and bankruptcies. A new activity code is still under
development for reporting settlements through ADR.
A-60
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OSWER Directive 9200.3-01 H-l
COST RECOVERY ACTIONS/DECISIONS GREATER THAN $200,000
Definition: Cost recovery actions/decisions taken are defined as 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 not to pursue cost recovery, settlement for past costs
under a CD (with no prior referral), bankruptcy filing, cash out settlement for cost recov-
ery or initiation of debt collection procedures.
This category includes cost recovery actions for reimbursement of Trust Fund amounts of
greater 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 as recorded in WasteLAN.
Settlements under CD (with no prior referral) - Credit is given on the date of the Regional
Administrator's transmittal letter to HQ or DOJ as recorded in WasteLAN.
Cash out settlements - Credit is given on the date of the Regional Administrator's trans-
mittal letter to HQ or DOJ or when the Regional Administrator signs the AOC for the
cash out. This date must be recorded in WasteLAN.
Decision documents prepared not to pursue cost recovery claims - Credit is given when
the document is issued by the Regional office and recorded in WasteLAN.
Administrative Settlement - Credit is given on the date the Regional office or DOJ re-
ceives payment from the PRPs in direct response to a demand letter for voluntary cost
recovery or the date that the Regional Administrator signs the AOC for cost recovery.
The date must be reported 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. An activity code or
milestone will be added to WasteLAN to track ADRs.
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 infor-
mation is reported in WasteLAN. New bankruptcy filing milestones have been added to
WasteLAN: C2801 = CP (Creditors Committee Meeting) and BS (Bankruptcy Strategy
Package).
Initiation of Debt Collection Procedures - Credit is given on the date the demand letter
indicating use of debt collection procedures is signed by the EPA official and reported in
WasteLAN. New debt collection milestones have been added to WasteLAN: C2801 =
CS (Collection Services); AF (Administrative Offset); and TF (Tax Refund Offset).
These milestones are valid only for activity AV (Administrative/Voluntary Cost Recov-
ery). A new statute code (C2771) will be added to WasteLAN for the Debt Collection
Act.
A-61
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OSWER Directive 9200.3-01H-1
Changes in Definition FY 92 - FY 93: This definition encompasses the following FY
92 measures: Issue Cost Recovery Decision Document, Use of ADR for Cost Recovery,
Administrative Cost Recovery Settlements and Section 107 Referrals/Settlements
>$200,000. Bankruptcy case filings were added. The new WasteLAN codes for report-
ing accomplishments were added to the definitions.
Special Planning/Reporting Requirements: This is a STARS target. 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. New WasteLAN activity codes were developed for debt collection
procedures and bankruptcies. A new activity code is still under development for report-
ing settlements through ADR.
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;
• The case is dismissed; or
• A trial concluded and a judgment entered fully addressing the complaint.
The case resolution date (activity actual completion date) is the same as the milestone
date and is defined as follows:
• Date CD is entered;
• Date case is withdrawn;
• Date case is dismissed; or
• Date judgment is entered.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
DOLLARS ACHIEVED TOWARD COST RECOVERY MBO GOAL
Definition: Report the value of administrative cost recovery settlements (including
ADR), cash out settlements, cost recovery CDs (upon lodging), cost recovery judgements
(including bankruptcy judgements) and penalties and fines assessed.
A-62
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OSWER Directive 9200.3-01H-1
Definition of Accomplishment: Credit is given when the value of the settlements/
judgments are entered into WasteLAN. Credit for administrative settlements will be
given when the AOC is signed by the Regional Administrator.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure only.
A-63
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OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
SECTION 3: RESPONSE DEFINITIONS
INTRODUCTION
There are a subset of FY 93 STARS/SCAP targets/measures that reflect the status of
response activities and the accomplishment of cleanup goals at NPL sites. Following are the
response activities tracked in STARS/SCAP:
• Sites Where Activity Has Started, First NPL Removal Actions or RI/FS;
• Remedial Program Remedies Selected (ROD) and Action Memoranda Signed for
Removal Actions at NPL Sites;
• NPL Site Construction Completions;
• Five-Year Reviews Completed;
• NPL Deletion Initiation (Fund, PRP and Federal Facility);
• Federal Facility NPL Deletion Completion; and
• Progress Through Environmental Indicators.
Sites where activity has started, first NPL removal action or RI/FS and Remedial program
remedies selected and action memoranda signed at NPL sites are STARS targets. Progress
through Environmental Indicators and NPL site Construction Completions are STARS measures.
Five-year reviews and NPL deletion starts and completions are SCAP measures. In the follow-
ing sections the definitions for Federal Facility NPL deletion start and completion have been
combined.
EXHIBIT A*lls RESPONSE SCAWST&8S TARGETS ANO MEASURES
ACTIVITIES
NPL SITES ADDRESSED
THROUGH REMOVAL ACTION
OR RI/FS START (S/C-4)
DECISION DOCUMENT
DEVELOPMENT-REMEDIES
SELECTED AND ACTION
MEMORANDA SIGNED (S/C-5)
NPL SITE CONSTRUCTION
COMPLETIONS (S/C-3)
FIVE YEAR REVIEWS
NPL DELETION INITIATION
FEDERAL FACILITY NPL
DELETION COMPLETE
PROGRESS THROUGH
ENVIRONMENTAL INDICATORS
S CAP/STARS
TARGET
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X**
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REPORTING
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X
X
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• Includes projects with OK following leads: federal (F), State (S), PRP Action Under State OrderlDecrec (PS), In-House RI/FS (EP), PRP
Action Under Federal Order/Decree (RP), and Mixed Funding (MR).
** RemediesincludeFederal(F),FederalEnforcement(FE),andStateEnforcement (SE).
+ Includes RA projects with the /allowing leads: Federal (F), State (S), PRP Action Under Slate Order/Decree (PS), PRP Action Under
Federal Order/Decree (RP), Mixed Funding (MR), and Federal Facility (FF).
A-65
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OSWER Directive 9200.3-01H-1
NUMBER OF SITES WHERE ACTIVITY HAS STARTED, FIRST NPL REMOVAL
ACTION OR RI/FS (S/C-4)
Definition: Number of NPL sites (final and proposed) where on-site activity has begun.
On-site activity is characterized by either a removal action under the direction of EPA or
through an AO, CD or judgment; or implementation of a first RI/FS (Fund or PRP) at the
site, but not both.
Definition of Accomplishment: See RI/FS start definitions in Section 2: Pipeline
Definitions and NPL removal start definition in Section 4: Removal Definitions.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: First NPL removal start or first RI/FS start
is a target under STARS. Separate targets are negotiated in SCAP for RI/FS starts and
removal starts. Regions cannot receive credit under STARS if an RI/FS or NPL removal
began or was conducted at the site in a previous year. Similarly, Regions cannot receive
credit for both an RI/FS start and a NPL removal at a site under STARS if they are started
in the same 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 targeting and reporting
accomplishments in STARS.
NUMBER OF REMEDIAL PROGRAM REMEDIES SELECTED (ROD) AND ACTION
MEMORANDA SIGNED FOR REMOVAL ACTIONS AT NPL SITES (S/C-5)
Definition: A remedial program remedy is selected when a ROD has been signed and
the appropriate date has been recorded in WasteLAN.
An Action Memorandum to begin a removal is signed by the On-Scene Coordinator
(OSC), Regional Administrator or AA SWER. For PRP-financed removals, an Action
Memorandum is signed or the PRP begins the removal actions contained in an enforce-
ment document.
Definition of Accomplishment:
Remedies Selected - The date the Regional Administrator/Deputy Regional Administra-
tor or AA SWER signs the ROD represents the ROD completion date. This date must be
reported in WasteLAN. Remedies selected include RODs with a Federal (F), Federal
Enforcement (FE) or State Enforcement (SE) lead designation.
Action Memoranda for Removal (Fund-financed): To receive credit for an Action
Memoranda when a Fund-financed removal will be conducted:
• An Action Memorandum is signed by the OSC, Regional Administrator or AA
SWER; and
• The date of signature is recorded in WasteLAN with the removal subevent Ap-
proval of Action Memo (C3101=AM).
Action Memorandum for Removal (PRP-financed): An Action Memorandum for a
removal will be counted when:
• An Action Memorandum is signed by the OSC, Regional Administrator, or AA
SWER;
A-66
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OSWER Directive 9200.3-01H-1
• The date of the approval of the Action Memorandum is recorded in WasteLAN
with the removal subevent (C3101) "AM" (Approval of Action Memo); and
• When the PRP begins to follow the removal instructions outlined in the AOC,
UAO or CD. The date of the AOC, UAO, or CD and the removal remedy code
(C2731=RV) must be recorded in WasteLAN.
Changes in Definition FY 92 - FY 93: This is a new STARS target in FY 93, however,
the ROD completion and removal start definitions are not new.
Special Planning/Reporting Requirements: Remedial program remedies selected
(RODs) and Action Memoranda for removal is a combined target under STARS. Sepa-
rate targets are negotiated in SCAP for RODs and removal starts. The Action Memoran-
dum signature date should be reported in WasteLAN with the removal subevent Approval
of Action Memorandum (C3101 = AM). For PRP-financed removals the date of the
Action Memo, the date of the AOC, UAO or CD and the remedy code (C2731 = RV)
must be reported in WasteLAN.
NPL SITE CONSTRUCTION COMPLETIONS (S/C-3)
Definition: Starting in FY 93, construction at an NPL site is considered complete when
physical construction of the remedy is complete. Remedial/removal implementation is
complete as a result of a final RA or a ROD for the final OU stating that all necessary
remediation is complete. A removal completion that cleans up an NPL site and is docu-
mented by a ROD that states that all necessary remediation is complete and that the site
meets the requirements for site closeout also qualifies for an NPL site completion.
This is the definition to meet the Administrator's goal of 200 site completions by the end
of FY 93. In order to receive credit for a final RA completion there are other require-
ments that must be met. These requirements are discussed in the definition for final RA
completions. This definition can be found in Section 2: Pipeline Definitions.
Definition of Accomplishment:
RA site construction is complete when:
• RA construction activities at all OUs are complete;
• A pre-final inspection of the site has been conducted;
• A Preliminary Close-Out Report has been prepared. This report documents the
completion of physical construction of the remedy, summarizes site conditions and
construction activities and, as appropriate, provides the schedule for the joint final
inspection (required before the start of O&F), approval of the O&M work plan and
the establishment of institutional controls; and
• The designated Regional official (Division Director or above) signs the Prelimi-
nary Site Close-Out Report. The completion date must be reported in WasteLAN
with the RA subevent, Preliminary Close-Out Report Prepared (C3101 = CC).
Accomplishments are credited based on the completion date of the Preliminary
Close-Out Report Prepared (C3101 = CC).
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OSWER Directive 9200.3-01H-1
RODs that state that no remediation is required are signed by the Regional Administrator/
Deputy Regional Administrator or the AA SWER. The ROD must include a construction
completion certification. There should be no RD or RA activities at this OU.
For sites where EPA has conducted a RA and the ROD at the final OU suites that all
necessary remediation has been completed, the Region is required to either prepare an
Interim or Final Superfund Site Close-Out Report QT_ document compliance with the
statutory requirements for site closeout in the ROD and include a construction completion
certification. The following data must be entered into WasteLAN:
• The RI/FS completion date;
• The ROD completion date;
The Remedial Action Technology Type (C3401 = RT and C3402 == NA); and
The completion date for the ROD subevent, Close-Out Report (C3101 = CL), if a
separate Interim or Final Superfund Site Close-Out Report is prepared.
Accomplishments are credited based on the ROD completion date, or the comple-
tion date in the Close-Out Report data field (C3101 = CL) if a separate Interim or
Final Superfund Site Close-Out Report is prepared.
Removal completion that cleaned up an NPL site (Fund financed) is credited when:
• The contractor has demobilized and left the site as documented in a Pollution
Report (POLREP); and
• A ROD that states that all necessary remediation is complete has been signed. The
ROD must document that the site meets the statutory requirements for site close-
out.
Removal completion that cleaned up an NPL site (PRP-financed) is credited when:
• The Region certifies that the PRPs or their contractor have completed the removal
action and fully met the terms of the AO, CD or judgment; and
• A ROD that states that all necessary remediation is complete has been signed. The
ROD must document that the site meets the statutory requirements for site close-
out.
The removal event qualifier that indicates that the site is cleaned up (C2103 = C) must be
entered into WasteLAN. The date of signature of the ROD that states that all necessary
remediation is complete must be entered in the removal completion and ROD completion
data fields. The RA Technology Type (C3401 = RT and C3402 = NA) must also be
entered into WasteLAN.
Accomplishments are credited based on the ROD completion date.
Changes in Definition FY 92 - FY 93: This is a new STARS measure in FY 93. The
definition encompasses the final RA NPL site construction completion definition from
Section 2: Pipeline Definitions. It also includes RODs where all necessary remediation
has been completed. This measure also credits removals that clean up NPL sites. The
A-68
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OSWER Directive 9200.3-01H-1
definition for removal completions is found in Section 4: Removal Definitions. How-
ever, in order for a removal to qualify under this measure, a ROD that states that all
necessary remediation is complete must be prepared.
Special Planning/Reporting Requirements: The STARS measure NPL site construc-
tion completions includes final RA construction completion, RODs that state that all
necessary remediation is complete, and removal completions at NPL sites as documented
by a ROD stating that all necessary remediation is complete. Separate planning measures
are negotiated in SCAP for each of these events.
RA - The date the designated Regional official signs the Preliminary Close-Out Report
should be entered into WasteLAN with the Preliminary Close-Out Report Prepared
subevent(C3101 =CC).
ROD - The date of signature of the ROD that states that all necessary remediation is
complete and documents that the site meets the statutory requirements for the site close-
out must be entered into WasteLAN in the RI/FS completion and ROD completion data
fields. If a separate Interim or Final Superfund Site Close-Out Report is prepared, the
date the Regional Administrator signs the Interim or Final Superfund Site Close-Out
Report is to be recorded in the Close-Out Report Completion subevent (C3101 = CL).
The RA Technology Type (C3401 = RT and C3402 = NA) must also be entered into
WasteLAN.
Removal - The removal event qualifier that states that the site is cleaned up (C2103 = C)
is to be recorded in WasteLAN. The signature date of the ROD that states that all neces-
sary remediation is complete upon completion of the removal must be entered into
WasteLAN in the removal completion and ROD completion data fields. The RA Tech-
nology Type (C3401 = RT and C3402 = NA) must also be entered.
FIVE-YEAR REVIEWS COMPLETED
Definition: Five-year reviews are intended to evaluate whether the response action
implemented at an 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 cleanup levels, will not allow unlimited use and unrestricted exposure.
Definition of Accomplishment:
Start (Fund-financed) - Obligation of funds for the five-year review.
Start (PRP-financed) - EPA approval of five-year review work plan.
Completion (Fund and PRP) - EPA acceptance of the five-year review report.
The five-year review must start within five years of the RA start (as defined in this
Manual). The five-year review must be complete within five years of award of RA
contract.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: Five-year reviews must be planned and
reported site specifically in WasteLAN. Funds are allocated in the RA AOA. The
WasteLAN event code for five-year reviews is C2101 = FA. This is a SCAP reporting
measure.
A-69
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OSWER Directive 9200.3-01H-1
NPL DELETION INITIATION
Definition: The deletion process is initiated when performance monitoring of the com-
pleted remedy or remedies for the site has verified the integrity of the action and it has
been determined that all necessary remediation has been completed.
Definition of Accomplishment: The deletion process is credited 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 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
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 RA is appropriate to protect
public health and the environment. Pursuant to Section 300.425(e)(l) of the 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;
• All appropriate Fund-financed responses under CERCLA have been implemented
and no further response by the Federal Facility is appropriate; or
• Based on a remedial investigation, it is determined that the release poses no
significant threat to human health or the environment and, therefore, taking reme-
dial 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 Coordi-
nator to prepare the documents necessary to delete a site from the NPL.
Deletion Completion Date: The date the responsive summary is approved by the Re-
gional Administrator. (The Regional Administrator will then publish the notice of dele-
tion in the Federal Register.)
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: Federal Facility deletion start and comple-
tion are SCAP reporting measures.
A-70
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OSWER Directive 9200.3-01H-1
PROGRESS THROUGH ENVIRONMENTAL INDICATORS
Definition: This measure results from the Environmental Indicators program. It docu-
ments the number of sites where the following types of results have been achieved:
• Progress toward final cleanup goals; and
• Reductions of acute threats.
Either of these results may be achieved through implementing removal and/or remedial
projects. Results are reported for each of the media 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 elimi-
nated at both NPL and non-NPL sites by preventing exposure to contaminated materials.
Progress recorded by this indicator should reveal success in closing off exposure path-
ways. (See Volume I, Chapter n and Volume n, Appendix D for additional information
on the Environmental Indicators program.)
Definition of Accomplishment: Same as definition.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a STARS reporting measure.
Accomplishment data will be reported in WasteLAN. The results should be reflected in
the comment field of the STARS data base.
A-71
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OSWER Directive 9200.3-01H-1
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A-72
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OSWER Directive 9200.3-01H-1
SECTION 4: REMOVAL DEFINITIONS
INTRODUCTION
Requirements for the removal program differ from the remedial program due to the
nature of removal activities. The removal program responds to emergency, time critical and non-
time critical situations at NPL and non-NPL sites. Since so much of the removal work cannot be
anticipated in advance, the planning horizon of these activities is significantly shorter than for
remedial activities. Thus, quarterly commitments are not required. All SCAP/STARS targets,
however, are established on an annual basis. Targets are planned site specifically prior to the
quarter the removal is projected to begin. Site-specific removal funding needs are placed in
WasteLAN the quarter prior to the expected obligation date. The annual removal commitments
are placed in the Targets and Accomplishments portion of the CERHELP non-site data system.
Credit will be given for NPL or non-NPL activities depending on the NPL status recorded in
CERCLIS on the date accomplishment reports are pulled.
REMOVAL ACTIVITIES
The following removal activities are tracked in SCAP and STARS:
• Removal Investigations at NPL Sites;
Non-NPL PRP Search Starts;
Non-NPL PRP Search Completion;
AO Issued for Removal and RI/FS;
NPL Removal Starts;
Non-NPL Removal Starts;
• Emergency Response Activity;
• Removal Completions;
• NPL Site Completions Through Removal;
• Administrative Record (AR) Compilation Completion;
• Federal Facility Removals/Expedited Response Actions (ERA) Started; and
• Federal Facility Removals/ERAs Completed.
Federal Facility removals/ERAs started and completed are STARS/SCAP measures.
First NPL removal start or first RI/FS start is a STARS target under S/C-4, Number of Sites
Where Activity has Started, First NPL Removal Actions and RI/FS. Separate RI/FS and removal
targets are established in SCAP. The definition for Number of Sites Where Activity has Started
can be found in Section 3: Response Definitions. Action Memoranda signed for removal actions
at NPL sites and remedial remedies selected are a STARS target under S/C-5. Separate ROD
A-73
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OSWER Directive 9200.3-01H-1
and removal targets are established in SCAP. The definition for Remedial Remedies Selected
and Action Memoranda Signed can be found in Section 3: Response Definitions. NPL site
completions through removal actions are included in the STARS measure S/C-3, NPL Site
Construction Completions, separate planning measures are negotiated in SCAP. The definition
for NPL Site Construction Completions can be found in Section 3: Response Definitions.
Non-NPL and NPL removal starts are SCAP targets. SCAP commitments for removal
starts are made on a combined program basis. Separate goals for Fund-financed and RP-lead
removals are negotiated prior to the FY. Accomplishments are reported on a combined program
basis. Removal investigations, non-NPL PRP search starts and completions, AOs issued for
RI/FS or removal, removal completions, emergency response activity and AR compilation
completion are SCAP measures.
NPL and non-NPL removal start definitions have been combined. The Federal Facility
removal/ERA start and completion definitions have also been combined. The definition for AOs
issued for removal and Rl/FS can be found in the following section and Section 2: Pipeline
Definitions.
Exhibit A-13 contains the SCAP/STARS targets and measures for the removal process.
A-74
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OSWER Directive 9200.3-01H-1
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X
X
X
FEDERAL FACILITY REMOVALS/
ERA START (FF E-3 (2))
X
*
*
X
NPL REMOVAL START
X
X
NON-NPL REMOVAL START
X
X
X
EMERGENCY RESPONSE
ACTIVITY
X
X
X
REMOVAL COMPLETION
X
X
X
X
FEDERAL FACILITY
REMOVAL/ERA COMPLETION
X
X
i
X
NPL SITE COMPLETION
THROUGH REMOVAL
X
X
X
ENFORCEMENT
NON-NPL PRP SEARCH START
X
X
X
NON-NPL PRP SEARCH
COMPLETE
X
X
X
ADMINISTRATIVE ORDER
ISSUED FOR REMOVAL AND
RI/FS
X
X
X
ADMINISTRATIVE RECORD
COMPILATION COMPLETE
c
• 2
"u
TS
-S .0
V3 r^J
^ 1"
£} jj
"•£j O
u '42
•^ u
| 10 ^
E? O S
oj t/i ^i
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£ ^ ^
g ^ crj"
*A vT
1 *- K.
rr, tU ^
i^^
L^ S c^
en 8 ^
•^ 2 "^
•afl
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|| 5;
^ .i 1
!/l i^
^ cs ^
«.•£"*••
* SCAP Target Only.
** SCAP target only. First NPL removal st,
memoranda for removal actions at NPL s:
*** SCAP target only. NPL site completions
A-75
-------
OSWER Directive 9200.3-01H-1
REMOVAL INVESTIGATIONS AT NPL SITES
Definition: A removal investigation at an NPL site is the process of collecting field data
at an NPL site for the purpose of characterizing the magnitude and severity of the prob-
lem to determine if a removal or quick response action is warranted.
Investigations may be conducted by the State, EPA and/or the Technical Assistance
Team (TAT), and must include an on-site component, such as a walk around survey or
sampling to be counted.
Definition of Accomplishment: The start of the removal investigation at NPL sites is
defined as the date of the site visit or the start of the review process if no site visit took
place. The completion is defined as the signature of an Action Memorandum, the date of
a memorandum to the file documenting the decision not to perform a removal action, or
signature of the Site Evaluation Report. The removal investigation completion date must
be entered into WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure. Ac-
complishments are reported site specifically in WasteLAN using event (C2101) type
"RS." Removal investigations at NPL sites are tracked on a calendar year basis.
NON-NPL PRP SEARCH STARTS
Definition: The purpose of the PRP search is to identify PRPs. It should be done prior
to the start of the removal action when possible or very soon after the initiation of the
emergency response.
Definition of Accomplishment: If the search is being conducted by a contractor, the
start date is considered to be the date the work assignment is procured. If it is conducted
by EPA, the start date is the day the EPA staff begins the PRP search activities.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Non-NPL PRP searches should be planned
site specifically to the maximum extent possible. All targeted non-NPL removal starts
should have an associated projection for a non-NPL PRP search. Funds for non-NPL
PRP searches are requested in CERHELP. Projections for non-NPL PRP searches should
be placed in the Targets and Accomplishments portion of CERHELP. This is a SCAP
reporting measure.
NON-NPL PRP SEARCH COMPLETION
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 date and outcome of the search have been entered into
WasteLAN. If no PRPs are found, the date and the outcome of the search are entered
into WasteLAN.
A-76
-------
OSWER Directive 9200.3-01H-1
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Non-NPL searches should be planned site
specifically to the maximum extent possible. All targeted non-NPL removal starts should
have an associated projection for a non-NPL PRP search. These projections should be
placed in the Targets and Accomplishments portion of CERHELP. This is a SCAP
reporting measure.
ADMINISTRATIVE ORDERS ISSUED FOR REMOVAL AND RI/FS
Definition: Administrative Orders (AOC and UAO) are an enforcement tool to compel
the PRPs to assume responsibility for removal actions.
Definition of Accomplishment: Report Section 104/106/122 administrative orders
(AOC and UAO) issued by EPA for PRPs to conduct removal actions and/or RI/FS s.
Credit for the order is based on the date the order is signed by the Regional Administrator
as recorded in WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Projections for AOs for removal actions
are made in the Targets and Accomplishments portion of the CERHELP non-site data
base. This is a SCAP reporting measure.
REMOVAL STARTS — NPL AND NON-NPL
Definition: A removal is a response action taken to prevent or mitigate a threat to public
health, welfare or the environment posed by the release or potential release of a CERCLA
hazardous substance, or an imminent or substantial risk posed by a pollutant or contami-
nant.
In order for the NPL removal to be counted in the STARS target S/E-4, Number of Sites
Where Activity has Started, First NPL Removal Actions or RI/FS, it must not have had
previous Fund-financed or PRP removal or RI/FS activity at the site.
Definition of Accomplishment:
Fund-financed - A Fund-financed removal counts toward this target when on-site re-
moval work is begun as documented in the POLREP. Prior to on-site work beginning,
the following actions usually occur:
• The Action Memorandum is approved by the OSC, Regional Administrator or AA
SWER; and
• A Delivery Order has been issued by EPA under the ERCS contract or a contract
has been signed for a U.S. Coast Guard (USCG) on-site removal; and
• An obligation for the removal has been recorded in WasteLAN and the Integrated
Financial Management System (IFMS) or the OSC activates $50,000; and
• On-site removal work has begun.
The date the on-site work began is the start date for the removal action.
A-77
-------
OSWER Dkective 9200.3-01H-1
PRP-financed - A PRP removal counts when there is on-site removal activity financed by
the PRP in compliance with an AO (unilateral or consent), CD or judgment. The date the
PRPs begin actual on-site work (as entered in WasteLAN) is the start date. If PRPs start
the removal and become in substantial non-compliance and the Fund takes over the
removal, credit will be given for a PRP start but the Fund will be credited for the comple-
tion, because PRPs have not met the terms of the AO or CD. If the PRPs do not comply
with a UAO, credit for the removal is not given. Regions will receive credit under SCAP
for issuing the UAO. No credit will be provided where a PRP is conducting a response
without an enforcement document.
Changes in Definition FY 92 - FY 93: Added that the removal work must be docu-
mented in a POLREP.
Special Planning/Reporting Requirements: Plans are made site specifically prior to
the quarter the removal is expected to begin; TBD sites are allowed. Annual targets for
removals are established in the Targets and Accomplishments portion of the CERHELP
data base. A limit is placed on the number of Fund-financed removal starts. Commit-
ments for non-NPL removals are made based on a combined Fund and PRP financed and
first and subsequent basis. Removal starts is a SCAP target.
First NPL removal start or first RI/FS start is a target under STARS. Separate targets are
established in SCAP for RI/FS starts and removal starts. Regions cannot receive credit
for a site under STARS S/C-4, Number of Sites Where Activity has Started, First NPL
Removal Action or RI/FS, if an RI/FS or NPL removal began or was conducted at the site
in a previous year. Regions also cannot receive credit for both an RI/FS start and a
removal under STARS if they are started in the same year. Credit is given for the first
activity started and a site can receive credit only once. Therefore, historical data need to
be reviewed prior to negotiating commitments and recording accomplishments in
STARS. Regions can receive credit for both activities under SCAP.
Action Memoranda for removal actions at NPL sites and remedial remedies selected
(RODs) are a combined target under STARS S/C-5. Separate targets are established in
SCAP for removal starts and RODs.
Definitions for Number of Sites Where Activity Has Started and Remedies Selected and
Action Memoranda Signed can be found in Section 3: Response Definitions.
EMERGENCY RESPONSE ACTIVITY
Definition: An emergency response activity is an action performed by an EPA OSC
within 24 hours of receipt of an oil or hazardous substance incident notification. Such
actions include OSC field investigations, OSC on-scene monitoring, and the start of a
removal action; or OSC participation in emergency response field simulations.
Note that the time frame of 24 hours for response is used, as opposed to "hours or days,"
in order to capture first responder type activities and "days" is simply too open-ended.
These activities will only be counted when they are performed in the field and an EPA
OSC performs them. This pertains to simulations as well; table-top exercises do not
count. Training activities are purposely omitted. Contractor activities, for example, TAT
investigations, do not count as an accomplishment under this measure. The purpose of
this measure is to identify and track emergency response activities performed by EPA
OSCs to support OSC readiness initiatives.
A-78
-------
OSWER Directive 9200.3-01H-1
Definition of Accomplishment: An Emergency Response Activity must be performed
by an EPA OSC and documented. Appropriate documentation includes the report date in
the Emergency Response Notification System (ERNS) Version 4.0 and the following:
• Entry follow-up component of ERNS. To enter these data, check off "Emergency
Response Activity"; enter the "Emergency Response Activity Date"; enter the
"Responding OSC" name; and check off the appropriate activity (e.g., field simu-
lation, release investigation, etc.).
• Entry in WasteLAN of an emergency removal action start and entry in the follow-
up component of ERNS to tie the removal action to the notification through
supporting comments, including "Responding OSC" name.
The note to the file or POLREP requirement provides backup documentation, as well as
more details for future applications (e.g., lessons learned, technology transfer, etc.).
Changes in Definition FY 92 - FY 93: Changes were made in how the information is
reported in ERNS.
Special Planning/Reporting Requirements: This is a SCAP reporting measure. Ac-
complishments should be reported site specifically in ERNS, entered into WasteLAN at
the Regional level on a quarterly basis, and uploaded to CERHELP.
NPL AND NON-NPL REMOVAL COMPLETIONS
Definition: A removal is complete when the conditions specified in the Action Memo-
randum have been met even if the OSC determines that additional response work may be
necessary.
Temporary demobilization and temporary storage on-site are not considered
completions, unless temporary storage is the only action identified in the Action Memo-
randum to mitigate threats to public health, welfare and the environment. Likewise,
temporary off-site storage of hazardous substances at a Treatment, Storage, and Dis-
posal (TSD) facility other than the facility of ultimate disposal is a continuation of the
removal action, not a completion. In addition, removal action would not be considered
complete if:
• Hazardous substances stored on-site are being monitored by the ERCS contractor
or if any additional ERCS expenditures are anticipated, or
• Hazardous substances are being stored at an off-site facility, other than the ulti-
mate TSD facility.
A removal action would be considered complete if:
• The scope of work for the removal action does not specify final off-site disposal of
hazardous substances, the substances have been stabilized and are stored on-site,
and no additional CERCLA removal program funds are anticipated to be expended
at the site. In this case, hazardous substances may be expected to undergo long-
term storage on-site due to circumstances such as the unavailability of a final
treatment/disposal remedy. In this instance, no CERCLA removal program funds
will be expended for long-term site O&M. Any long-term (greater than 6 months)
site O&M will be performed by the PRP or another agency (e.g., State).
A-79
-------
OSWER Directive 9200.3-01H-1
• Hazardous substances are being stored off-site at the location of final disposal, and
no additional ERGS expenditures are anticipated.
Definition of Accomplishment:
Fund-financed - Completions are counted when the actions specified in the Action
Memorandum are complete, the contractor has demobilized and left the site, as docu-
mented in a POLREP, and no additional ERCS expenditures are anticipated for the
action, as documented in a POLREP and recorded in WasteLAN.
PRP-financed - Completions will count when the Region has certified, by entering a date
in WasteLAN, that the PRPs or their contractors have completed a removal action and
fully met the terms of an AO, CD or judgment.
Changes in Definition FY 92 - FY 93: Added that the completion must be documented
in a POLREP.
Special Planning/Reporting Requirements: This is a SCAP reporting measure. Ac-
complishments are reported based on combined Fund and PRP-financed and first and
subsequent NPL and non-NPL removal completions. Projections on the number of NPL
removal completions are placed in the Targets and Accomplishments portion of the
CERHELP non-site data system. The removal event qualifier (C2103) is to be recorded
in WasteLAN.
NPL SITE COMPLETIONS THROUGH REMOVAL
Definition: An NPL site is completed through a removal action when conditions speci-
fied in the Action Memorandum or ROD have been met and all necessary remediation at
the site has been completed.
Definition of Accomplishment:
Fund-financed - A removal completion that cleaned up an NPL site is credited when:
• The contractor has demobilized and left the site as documented in a POLREP; and
• A ROD that states that all necessary remediation is complete has been signed. The
ROD must document that the site meets the statutory requirements for the site
closeout.
PRP-financed - A removal completion that cleaned up an NPL site is credited when:
• The Region certifies that the PRPs or their contractor have completed the removal
action and fully met the terms of the AO, CD or judgment;
• A ROD that states that all necessary remediation is complete has been signed. The
ROD must document that the site meets the statutory requirements for site close-
out.
The removal event qualifier that states the site is cleaned up (C2103 = C) must be entered
into WasteLAN. The date of the signature of the ROD that states that all remediation is
complete must be entered in the removal completion and ROD completion data fields.
The RA technology type (C3401 = RT and C3402 = NA) must also be entered into
WasteLAN.
A-80
-------
OSWER Directive 9200.3-01H-1
Changes in Definition FY 92 - FY 93: Added requirements for completion of a ROD
that states that all necessary remediation is complete.
Special Planning/Reporting Requirements: This is a SCAP target. It is planned site
specifically and includes Fund-financed and PRP removals. NPL site completions
through removal are included in the STARS measure S/C-3, NPL Site Construction
Completion. The definition for NPL Site Construction Completion can be found in
Section 3: Response Definitions.
ADMINISTRATIVE RECORD COMPILATION
Definition: An AR is a compilation of all documents which EPA used to make a specific
decision on the appropriate response action to be taken at a Superfund site. SARA
specifies that ARs be compiled at sites where remedial or removal responses are planned
or are occurring, or where EPA is issuing a UAO or initiating litigation.
Definition of Accomplishment: The AR compilation is complete when the compilation
is certified by the program office. The AR compilation begins when the AR is received
at the site repository and the start date is entered into WasteLAN.
Changes in Definition FY 92 - FY 93: Completion definition was modified to match
December 1990 guidance.
Special Planning/Reporting Requirements: The completion of the AR must be re-
ported site specifically in WasteLAN. To indicate that the AR is for a removal activity, a
"V" must be recorded in the Event Qualifier field (C2103).
FEDERAL FACILITY REMOVALS/ERAs (FFE-3(2))
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 envi-
ronment. Removal actions and ERAs are conducted in response to emergency, time
critical, and non-time critical situations at NPL and non-NPL sites.
Definition of Accomplishment:
Removal 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.
Removal Completion Date: Actual date the Federal agency has demobilized, completing
the scope of work set forth in the Action Memorandum or other decision document.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: This is a STARS/SCAP reporting measure
and must be planned and reported site specifically.
A-81
-------
OSWER Directive 9200.3-01H-1
•; '^•'••^^•^^::;^^^
PLANNING REQUIREMENTS
STARS?
SCAP?
TARGET OR MEASURE?
QUARTERLY TARGETS SET?
IF YES, WHEN?
PLANNED SITE SPECIFICALLY?
IF YES, WHEN?
PLANNED/REPORTED ON
OPERABLE UNIT OR WHOLE
SITE BASIS?
REPORTED ON COMBINED
PROGRAM LEAD OR ON A
PROGRAM-SPECIFIC BASIS?
REPORTED SITE SPECIFICALLY
OR IN NON-SITE PORTION OF
WASTELAN?
ADA CATEGORY IF FUND
FINANCED?
ADA CATEGORY FOR
OVERSIGHT?
BASIS FOR AOA?
&&fa
NPL REM.
INVEST.
NO
YES
MEASURE
NO
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
REMOVAL
N/A
SITE SPEC.
PLANS &
CONTING-
ENCY
NON-NPL PRP
SEARCH START
NO
YES
MEASURE
NO
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
ENFORCE-
MENT
N/A
NON -SITE
SPECIFIC
PLANS
NON-NPL
SEARCH COMP.
NO
YES
MEASURE
NO
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
N/A
N/A
N/A
AOFOR
REMOVAL
NO
YES
MEASURE
NO
NO
WHOLE SITE
OR OPERABLE
UNIT
N/A
SITE
SPECIFIC
ENFORCE-
MENT
N/A
SITE
SPECIFIC
PLANS
'": •''.; 'I''''-:'": '•'. .''. ]•
EMERG.
RESP. ACT.
NO
YES
MEASURE
NO
NO
WHOLE
SITE
PROGRAM
SPECIFIC
SITE
SPECIFIC
INERNS
REMOVAL
N/A
SITE
SPECIFIC
PLANS &
CONTIN-
GENCY
* First RI/FS start or first NPL removal is a combined target under STARS, S/C-4. Action memoranda for removal actions andRODs are a combined
target under STARS, S/C-5.
** NPL removal site completions, RODs that state that all remediation is complete and final RA construction completions are combined under STARS
S/C-3, NPL Site Construction Completions.
*** "To Be Determined" sites are allowed.
# Separate program specific goals are established prior to FY. A limit is placed on the number of Fund-financed NPL removal starts.
A-82
-------
OSWER Directive 9200.3-01H-1
..:•; ^XHl&lTA4&J
PLANNING REQUIREMENTS
STARS?
SCAP?
TARGET OR MEASURE?
QUARTERLY TARGETS SET?
IF YES, WHEN?
PLANNED SITE SPECIFICALLY?
IF YES, WHEN?
PLANNED/REPORTED ON
OPERABLE UNIT OR WHOLE SITE
BASIS?
REPORTED ON COMBINED
PROGRAM LEAD OR ON A
PROGRAM-SPECIFIC BASIS?
REPORTED SITE SPECIFICALLY
OR IN NON-SITE PORTION OF
WASTELAN?
AOA CATEGORY IF FUND
FINANCED?
AOA CATEGORY FOR
OVERSIGHT?
BASIS FOR AOA?
{iEMOVAl dEHNiTlOMS" jtO^WtaSW""'
FED FAC
REMOVAL
ERA START
YES
YES
MEASURE
NO
YES
PRIOR TO
FY
OPERABLE
UNIT
PROGRAM
SPECIFIC
SITE
SPECIFIC
N/A
FEDERAL
FACILITY
WORK-
LOAD
MODEL
ALLOC.
NPL REM.
START
NO*
YES
TARGET
NO
YES***
PRIOR TO
QUARTER
WHOLE
SITE/
OPER. UNIT
COMBINED
#
SITE
SPECIFIC
REMOVAL
ENFORCE-
MENT
SITE SPEC.
PLANS &
CONTING-
ENCY
NON-NPL
REM. START
NO
YES
TARGET
NO
YES***
PRIOR TO
QUARTER
WHOLE
SITE
COMBINED
#
SITE
SPECIFIC
REMOVAL
ENFORCE-
MENT
SITE SPEC.
PLANS &
CONTING-
ENCY
FED FAC
REMOVAL/
ERA COMP.
YES
YES
MEASURE
NO
YES
PRIOR TO
FY
OPERABLE
UNIT
PROGRAM
SPECIFIC
SITE
SPECIFIC
N/A
N/A
N/A
REM.
COMP.
NO
YES
MEASURE
NO
YES
PRIOR TO
QUARTER
WHOLE
SITE/
OPER. UNIT
COMBINED
SITE
SPECIFIC
N/A
N/A
N/A
NPL REM.
SITE COMP.
NO**
YES
TARGET
NO
YES
PRIOR TO
QUARTER
WHOLE
SITE
COMBINED
SITE
SPECIFIC
N/A
N/A
N/A
* First RI/FS start or first NPL removal is a combined target under STARS, S/C-4. Action memoranda for removal actions and RODs are a combined
target under STARS, S/C-5.
** NPL removal site compktions, RODs that state that all remediation is complete and final RA construction completions are combined under STARS
S/C-3, NPL Site Construction Compktions..
»** "jo ge Determined " sites are allowed.
# Separate program specific goals are established prior to FY. A limit is placed on the number of Fund-financed NPL removal starts.
A-83
-------
OSWER Directive 9200.3-01H-1
APPENDIX B
OIL POLLUTION ACT (OPA)
TARGETS AND MEASURES
-------
OSWER Directive 9200.3-01H-1
OIL POLLUTION ACT (OPA) TARGETS AND MEASURES
INTRODUCTION
Superfund Comprehensive Accomplishments Plan (SCAP) and Strategic Targeted Activi-
ties for Results System (STARS) targets and measures are the key device by which program
goals are translated into quantifiable program achievements. STARS is used by the Administra-
tor to set and monitor the progress each program is making toward its environmental goals.
STARS targets and measures are reported quarterly by Headquarters (HQ) and the Regions to the
Office of Pollution Prevention (OPP) through the OPP STARS computer system. SCAP is used
by the Assistant Administrator for the Office of Solid Waste and Emergency Response (AA
SWER) and senior Superfund managers to monitor the progress made toward achieving its
Superfund goals.
SCAP/STARS targets and measures for the Oil Pollution Act (OPA) can be found in
Exhibit B-l. OPA definitions can be found in Exhibit B-2. OPA accomplishments are reported
through CERHELP.
B-l
-------
OSWER Directive 9200.3-01H-1
EXHIBIT B-l
OPA SCAP/STARS TARGETS AND MEASURES
ACTIVITIES
SPILL PREVENTION
CONTROL &
COUNTERMEASURE
(SPCC) INSPECTION
COMPLETION (OPA -
Ka))
SPILL VIOLATION
FACILITY
INSPECTIONS
COMPLETED
(OPA-l(b))
SPCC VIOLATIONS
(OPA - 2)
EPA RESPONSES TO OIL
SPILLS (OPA -3(a))
RESPONSIBLE PARTY
RESPONSES
CONDUCTED
UNDER OPA ORDER
(OPA-3(b))
NUMBER OF
INCIDENTS WHERE
EPA DIRECTS OR
PARTICIPATES IN
RESPONSES AGAINST
THE TOTAL NUMBER
OF OIL SPILLS
REPORTED
(OPA -4)
VIOLATIONS OF
SECTION 311 (j) AND
311(b)(3)OFTHE
CLEAN WATER ACT
(CWA), AS AMENDED
BY OPA, ADDRESSED
THROUGH
ENFORCEMENT
ACTIONS
STARS/SCAP
TARGET
STARS
REPORTING
X
X
X
X
X
X
X
SCAP
REPORTING
QUARTERLY
X
X
X
X
X
X
X
ANNUAL
X
X
X
X
X
X
1
x I
B-2
-------
OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
APPENDIX C
CHEMICAL EMERGENCY PREPAREDNESS AND PREVENTION (CEPP^
TARGETS AND MEASURES
-------
OSWER Directive 9200.3-01H-1
APPENDIX C - CHEMICAL EMERGENCY PREPAREDNESS AND PREVENTION
TARGETS AND MEASURES
INTRODUCTION
Superfund Comprehensive Accomplishments Plan (SCAP) and Strategic Targeted
Activities for Results System (STARS) targets and measures are the key device by which
program goals are translated into quantifiable program achievements. STARS is used by the
Administrator to set and monitor the progress each program is making toward its environmental
goals. STARS targets and measures are reported quarterly by Headquarters (HQ) and the
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measures are in Exhibit C-2.
EXHIBIT C-1
CEPP STARS TARGETS AND MEASURES
STARS
REPORTING
STARS
TARGET
ACTIVITIES
Technical assistance and
training activities conducted,
sponsored, developed,
assisted in developing,
participated in, or presented
by EPA (CEP-1)
Accidental Release Information
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and returned by facilities
having releases (CEP-2)
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conducted (CEP-3)
Administrative Complaints
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Counsel (C/E-1)
C-l
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OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
APPENDIX D
ENVIRONMENTAL INDICATORS (ED
-------
OSWER Directive 9200.3-01 H-l
APPENDIX D: ENVIRONMENTAL INDICATORS
THE INDICATORS OF ENVIRONMENTAL PROGRESS
EPA has long recognized that ideal measures of environmental progress would capture
and assess the direct impacts of program activities on protecting human health and the environ-
ment. However, the data needed to report progress in terms of these ideal measures have not
been collected, in large part due to the high cost of the sampling and analysis efforts required.
"Environmental progress" has a very strict definition. It is not enough that money was
obligated to start a cleanup action at a site, or that a contract was awarded to perform the
cleanup, or even that a cleanup technology — like an incinerator or groundwater pump-and-
treatment system — is being built. Actual cleanup activities must have occurred at the site (e.g.,
incinerating contaminated soil or treating contaminated groundwater) before any degree of
environmental progress can be reported.
The following "surrogate" indicators of environmental progress are currently being used
to document progress to date:
• INDICATOR A - Reducing Immediate Threats: The degree to which immedi-
ate threats to human health and the environment have been reduced at National
Priorities List (NPL) and non-NPL sites is measured by this indicator.
Immediate threats are reduced through the provision of site security, alternate
water supplies, population relocation, or the treatment, removal, or containment of
hazardous wastes. Progress recorded by this indicator reveals success in closing
off exposure pathways. While a given site's goals for cleanup of a particular
operable unit may not have been met, this indicator records success in eliminating
pathways of exposure.
INDICATOR B - Progress Toward Permanent Cleanup Goals: This indicator
measures the degree to which progress has been made toward meeting permanent
cleanup goals for each contaminated medium (land, surface water, and groundwa-
ter) at NPL sites.
Cleanup goals are generally established in the Record of Decision (ROD) as the
final cleanup goals for the site, or for a particular medium or part of a medium at a
site. Because progress is made in stages, as parts of the site are cleaned up,
environmental indicators provide the means for making distinctions among the
following three levels of cleanup goal achievement:
— Fully Achieved site goals for a medium: All goals established for cleanup
of an affected medium must have been achieved in order to report "Fully
Achieved."
— Partially Achieved site goals for a medium: Partial progress is reported
when one of two things has occurred: (a) a Remedial Action (RA) or
removal is complete and goals for that event were achieved through a final
action such that the material will not be handled again in the future; or, at
a minimum, a response event must have resulted in final cleanup of a
D-l
-------
OSWER Directive 9200.3-01H-1
distinct area of contamination (i.e., lagoon or waste pile); or (b) a Reme-
dial Action is underway, and a "final" waste management action has been
completed to achieve one goal (of multiple goals) contained in the ROD
for cleanup of an affected medium.
— Cleanup Underway: This is the case when contaminated material associ-
ated with a medium have actually been "handled" at a site, but work has
not gone far enough to claim either full or partial achievement of medium
cleanup goals. If neither a medium nor an area of contamination has been
cleaned up, but a removal that preceded a ROD resulted in progress
toward the ultimate cleanup of a medium or an area of contamination, that
would be counted as "Cleanup Underway." In addition, ongoing RAs may
be reported as "Cleanup Underway" if environmental progress has begun
but no goals have been achieved.
• INDICATOR C - Bringing Technology to Bear: This indicator measures the
amount of contaminated materials that have been treated, stabilized, or disposed
of at NPL and non-NPL sites by bringing to bear on-site and off-site contain-
ment and/or treatment technologies.
Reporting on Environmental Indicators
Progress information generated to support these environmental indicators comes di-
rectly from the results of cleanup activities at completed removals (both at NPL and non-NPL
sites), and during the course of long-term RAs. These are the universe of environmental indica-
tor sites. Progress information is organized into the following five categories:
• The Media and Goal Achievement information category describes the degree to
which cleanup goals have been achieved for each contaminated site medium.
• Materials documents the amount of contaminated materials addressed.
• Technology documents the waste management methods used to address the
volumes of contaminated materials handled.
• Population Protected (Receptors) indicate the number and type of people
provided an alternate water supply, relocated, or protected from contamination
through site security measures.
• Chemicals track the primary contaminant categories in the materials being
cleaned up.
No single information category necessarily supports any one indicator. In fact, each of
these categories are building blocks that, when combined in different ways, construct each of the
three indicators.
Updates to environmental indicator information are compiled in data entry/turnaround
reports such as the Site Detail Report (Exhibit D-l). This report shows the most recent adminis-
trative data (start and completion dates) and existing environmental indicator information in
WasteLAN/Comprehensive Environmental Response, Compensation and Liability Information
System (CERCLIS). The report is marked up by the Region with current progress information
(even if no environmental indicator information has been recorded). This marked-up report
D-2
-------
OSWER Directive 9200.3-01 H-l
can be used to enter updated information into the Environmental Indicators module in
WasteLAN. The Site Information Form and Comprehensive Removal Information Form also
have been revised to allow reporting of environment indicator information. These reports also
will provide the back-up for checking that the data was entered accurately in the system.
D-3
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OSWER Directive 9200.3-01 H-l
APPENDIX E
REGIONAL ENFORCEMENT EXTRAMURAL BUDGET
-------
OSWER Directive 9200.3-01H-1
APPENDIX E
REGIONAL ENFORCEMENT EXTRAMURAL BUDGET
TABLE OF CONTENTS
REGIONAL ENFORCEMENT EXTRAMURAL BUDGET CODING AND DATA
ENTRY INSTRUCTIONS E-l
FINANCIAL PLANNING REQUIREMENTS E-l
WasteLAN Coding Instructions E-l
Remedial Events E-l
Enforcement Activities E-3
Non-Site Specific Incidents E-3
Mainframe CERCLIS Coding Instructions E-4
Remedial Events E-4
Enforcement Activities E-4
Non-Site Specific Incidents E-4
OBLIGATING FUNDS TO COVER REGIONAL TES 5+
PROGRAM MANAGEMENT WORK ASSIGNMENTS E-5
WasteLAN CERHELP Coding Instructions E-5
CERHELP Mainframe Coding Instructions E-6
OBLIGATING FUNDS GENERICALLY TO COVER ALL
SITE SPECIFIC WORK ASSIGNMENTS E-6
WasteLAN CERHELP Coding Instructions E-6
Mainframe CERHELP Coding Instructions E-7
OBLIGATING FUNDS TO COVER CONTRACT BUY IN
WORK ASSIGNMENTS E-7
WasteLAN Coding Instructions E-8
Remedial Events E-8
Enforcement Activities E-8
Non-Site Specific Incidents E-8
Mainframe CERCLIS Coding Instructions E-9
Remedial Events E-9
Enforcement Activities E-10
Non-Site Specific Incidents E-10
ENTERING TES WORK ASSIGNMENT AMOUNTS (TASKING) E-ll
WasteLAN Coding Instructions E-ll
Remedial Events E-ll
Enforcement Activities E-ll
Non-Site Specific Incidents E-12
Mainframe CERCLIS Coding Instructions E-12
Remedial Events E-13
Enforcement Activities E-13
Non-Site Specific Incidents E-13
-------
OSWER Dkective 9200.3-01H-1
APPENDIX E - REGIONAL ENFORCEMENT EXTRAMURAL BUDGET
REGIONAL ENFORCEMENT EXTRAMURAL BUDGET CODING AND DATA
ENTRY INSTRUCTIONS
This appendix outlines the required data for regional enforcement extramural budget
financial records and provides detailed data entry instructions. Exhibit E-l should be referenced
to determine the financial data requirements for each type of financial record being entered. For
example, if a planned obligation is being entered, only those data elements with a check mark
applies to the financial record for planned obligation. Failure to enter a valid code for the data
element will result in an error to appear on the ENFR49 report.
FINANCIAL PLANNING REQUIREMENTS
This section reviews the Comprehensive Environmental Response, Compensation and
Liability Information System (CERCLIS)/WasteLAN data entry instructions for planned obliga-
tions (requests). Activity-specific financial planning is required to clearly identify extramural
Regional enforcement funding requirements. This guidance is provided to assist the Regions in
carrying out the Regional enforcement extramural budget strategy and accurately entering
financial plans.
The list of enforcement activities and events with their corresponding codes, that are
funded with regional enforcement extramural budget appears in Volume I, Chapter VII, Exhibit
VII-I. It is important to note that additional coding requirements exist in order for any of these
planned activities to be considered as a Regional request.
WasteLAN Coding Instructions
A: Remedial Events
Al. Select Remedial from the main menu.
A2. Choose the event type (RI/FS, RD, RA, etc.) from the remedial menu.
A3. Specify the site by entering the WasteLAN reference number and verify that the
information is correct.
A4. Choose the correct operable unit by selecting next/previous operable unit until the
screen information matches the desired operable unit. Select 'View/Edit Events'.
If the event is not found then select 'Add' to add a new event.
A5. Choose the correct event by viewing the next/previous events until the informa-
tion matches the desired event.
A6. Choose'Edit Event'.
A7. Enter a lead of 'MR','RP' or 'PS'.
A8. Enter the current planned start date.
A9. Enter the current planned completion date.
A10. Enter the actual start date.
All. Update/Add the record and then choose 'Financial System'.
A12. Choose the financial type for planned obligation.
A13. Choose 'A' to add a new financial record.
A14. Enter the planned obligation date.
A15. Enter the planned amount.
A16. Enter an 'E' for the Enforcement budget source.
A17. Enter 'APR', 'ALT', or 'CON' for the funding priority status.
A18. Enter the contract vehicle (e.g. TES##, IAG##, MSC##, ARC##).
E-l
-------
OSWER Dkective 9200.3-01H-1
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E-2
-------
OSWER Directive 9200.3-01H-1
A19. Enter contractor name (optional).
A20. Enter financial comments if necessary.
A21. Choose 'A' to add record.
B: Enforcement Activities
B1. Select Enforcement from the main menu.
B2. Choose the activity group (RP Search, Negotiations, Litigation, etc.) from the
Enforcement menu.
B3. Choose the activity type.
B4. Specify the site by entering the WasteLAN reference number and verify that the
information is correct.
B5. Choose 'Add' to add an activity if it does not already exist.
B6. Choose the correct event by viewing the next/previous events until the informa-
tion matches the desired activity.
B7. Choose 'Edit' activity.
B8. Enter a lead of 'FE' or 'SE'.
B9. Enter the current planned start date.
BIO. Enter the current planned completion date.
B11. Enter the actual start date.
B12. Update/Add the record and then choose 'Budget Financial'.
B13. Choose financial type for planned obligation.
B14. Choose 'A' to add a new financial record.
B15. Enter the planned amount.
B16. Enter the planned obligation FYQ.
B17. Enter an 'E' for the Enforcement budget source.
B18. Enter 'APR', 'ALT', or 'CON' for the budget status.
B19. Enter the contract vehicle (e.g. TES##, IAG##, MSCM, ARC##).
B20. Enter financial comments in the 'Note' area if necessary.
B21. Choose 'A' to add record.
C: Non-Site Specific Incidents
Cl. From Main Menu select CERHELP System.
C2. Select Non-Site/Incident from CERHELP Program screen.
C3. Select Modify/View Activitites from the non-site/incident menu.
C4. Enter the activity in the Non-Site/Incident Activity Code field.
C5. WasteLAN system generates the current fiscal year (FY), but the user can over-
write the data in this field if desired. If the correct activity already exists in
WasteLAN, then proceed with step 6, otherwise do steps 5a - 5d.
5a. Select Add New Activity.
5b. Enter 'FE','SE','MR','RP',or 'PS' as the Lead.
5c. Enter any activity comment desired.
5d. Select A to add the record.
C6. Select the specific activity record needed, e.g., OH01.
C7. Select Financial System.
C8. Choose financial type for planned obligation.
C9. Select Add New Record.
CIO. Enter the planned obligation FYQ.
Cl 1. Enter financial comments if necessary.
C12. Enter the planned amount.
C13. Enter the contract vehicle (e.g. TES##, IAG##, MSC##, ARC##).
C14. Enter contractor name (optional).
C15. Enter an 'E' for the Enforcement budget source.
E-3
-------
OSWER Directive 9200.3-01H-1
C16. Enter 'APR', 'ALT', or 'CON' for the budget status.
C17. Enter the number of sites expected to have TES work assignments during the
fiscal year.
CIS. Choose 'A' to add record.
Mainframe CERCLIS Coding Instructions
A: Remedial Events
Al. Access main menu for data entry and choose Remedial/Removal.
A2. Choose the event information screen.
A3. Select 'A' to add an event or 'C' to update an event.
A4. Enter the EPA ID, operable unit, and event code.
A3. Enter a lead of 'MR','RP' or 'PS'.
A4. Enter the current planned start date.
A5. Enter the current planned completion date.
A6. Enter the actual start date.
A7. Update/Add the record.
A8. Select Event Financial Info. Screen to add or update an event financial record.
A9. Select 'A' to add a new event financial record.
A10. Enter the EPA ID Number.
All. Enter the operable unit number.
A12. Enter the event type and sequence number and press enter.
A13. Enter 'P' for a planned obligation.
A14. Enter 'APR', 'ALT' or 'CON' for the funding priority status.
A15. Enter the planned obligation FYQ.
A16. Enter 'E' for the Enforcement budget source.
A17. Enter the planned obligation amount.
Al8. Enter the contract vehicle (e.g., TES##, IAG##, MSC##, ARC##).
B: Enforcement A ctivities
B1. Access main menu for data entry and choose Enforcement.
B2. Choose the activity screen.
B3. Select 'A' to add or 'C' to update an activity.
B4. Enter the EPA ID and the activity code.
B6. Enter a lead of'FE', or'SE'.
B7. Enter the current planned start date.
B8. Enter the current planned completion date.
B9. Enter the actual start date.
BIO. Update/Add the record.
B11. Select the Enforcement FMS Financial Information Screen.
B12. Select 'A' to add a new financial record and enter the EPA ID, and the Activity
Type with the sequence number.
B13. Enter 'P' for a planned obligation.
B14. Enter 'E' for the Enforcement budget source.
B15. Enter the planned obligation amount.
B16. Enter the planned obligation FYQ.
B17. Enter the contract vehicle (e.g., TES##, IAG##, MSC##, ARC##).
B18. Enter 'APR', 'ALT', or 'CON' for the budget status.
C: Non-Site Specific Incidents
Cl. Access main menu for data entry and choose non-site/incident.
E-4
-------
OSWER Directive 9200.3-01 H-l
C2. Select non-site/incident screen from the non-site menu.
C3. Enter 'A' to add a new record.
C4. Enter Region number.
C5. Enter activity type and press enter.
C6. Enter activity lead as 'FE','SE','MR', 'RP', or 'PS'.
C7. Enter current FY.
C8. Enter any activity comment (e.g., Funds to cover all TES work assignments).
C9. Confirm the activity.
CIO. Enter 'A' to add financial information and enter Region, activity type including
the sequence number and press^ enter.
Cl 1. Enter financial type 'P' for a planned obligation.
C12. Enter the contract vehicle (e.g., TES##, IAG##, MSC##, ARC##).
C13. Enter 'E' for the funding source.
C14. Enter the estimated number of sites expected to be funded from the non-site-
specific plan.
C15. Enter 'APR', 'ALT', or 'CON' for the budget status.
C16. Enter the planned obligation FYQ.
C17. Enter the planned obligation amount.
OBLIGATING FUNDS TO COVER REGIONAL TECHNICAL ENFORCEMENT SUP-
PORT (TES) 5+ PROGRAM MANAGEMENT WORK ASSIGNMENTS
At the beginning of each Fiscal Year (FY), Regional Project Officers (RPO) will write
work assignments to provide contract management and administrative support for the contrac-
tors' Regional offices. Funds for these management work assignments should be obligated
independently of generic funds that cover site specific work assignments.
WasteLAN CERHELP Coding Instructions
A1. From Main Menu select CERHELP System.
A2. Select Non-Site/Incident from CERHELP Program screen.
A3. Select Modify/View Activitites from the non-site/incident menu.
A4. Enter TM' in the Non-Site/Incident Activity Code field, for TES 5+ Program
Management.
A5. WasteLAN system generates the current FY, but the user can overwrite the data in
this field if desired. If the correct PM activity already exists in WasteLAN, then
proceed with step 6, otherwise do steps 5a - 5d.
5a. Select Add New Activity.
5b. Enter 'FE' as the Lead.
5c. Enter any activity comment desired.
5d. Select A to add the record.
A6. Select the specific activity record needed (e.g., TM01).
A7. Select Financial System.
A8. Choose financial type, i.e., Option 4 is commitment or Option 5 is decommitment.
A9. Select Add New Record.
A10. Do not enter data into the date or amount fields, unless you have the correct FMS
amount and commitment date, in order to avoid creating duplicate records during
the financial download procedure.
All. Enter any activity comments (e.g., 'work assignment amount'or 'approved work
plan amount').
A12. Enter the Document Control Number (DCN) from the PR.
A13. Enter the Account Number (ACN) from the PR.
E-5
-------
OSWER Directive 9200.3-01H-1
A14. Enter 'TES05', 'TES06', etc., for the TES contract number into the Vehicle field.
A15. Enter the contractor's name in the Contractor field (optional).
A16. Enter '2535' in the Object/Subobject Class field.
A17. Enter 'E' for the Enforcement Funding Source.
Al 8. Enter the estimated number of sites expected to have TES work assignments
during the FY.
A19. Enter'A' (default) in order to add this financial record to the data base.
CERHELP Mainframe Coding Instructions
B1. Access main menu for data entry and select non-site/incident.
B2. Select non-site/incident screen from the non-site menu.
B3. Enter 'A' to add a new record.
B4. Enter Region number.
B5. Enter activity type as 'TM' (TES 5+ Program Management) and press enter.
B6. Enter activity lead as 'FE'.
B7. Enter current FY.
B8. Enter any activity comment (e.g., work assignment amount or approved work plan
amount).
B9. Press Enter and confirm the activity.
BIO. Enter 'A' to add financial information and then proceed to enter Region, activity
type with the sequence number and press enter.
Bl 1. Enter financial type 'C' for a commitment (positive amount), or 'M' for a
decommitment (negative amount).
B12. Enter the IFMS account number (ACN) from the PR.
B13. Enter the IFMS document control number (DCN) from the PR.
B14. Enter 'TES05', 'TES06', etc., identifying the specific TES contract.
B15. Enter '2535' for the Object/Subobject Class.
B16. Enter 'E' for Enforcement Funding Source.
B17. Enter the estimated number of sites expected to have TES work assignments for
the FY in the 'NBR SITES' field.
B18. Enter the date the Funds Control Clerk signed the PR in the actual financial date
field.
B19. Enter the amount from the PR.
B20. Confirm the record.
OBLIGATING FUNDS GENERICALLY TO COVER A 1.1. ft/TI? {SPECIFIC WORK AS-
SIGNMENTS
RPOs will obligate funds to a non-site specific (also referred to as generic) account to
cover the value of their site specific work assignments (including award fees) each FY. The
contractors will be paid by work assignment from the generic PRs by identifying the PR docu-
ment control number and site specific account number to be charged on their invoices. The
generic PRs will be entered much the same as contract program management PRs.
WasteLAN CERHELP Coding Instructions
A1. From Main Menu select CERHELP System.
A2. Select Non-Site/Incident from CERHELP Program screen.
A3. Select Modify/View Activities from the non-site/incident menu.
A4. Enter 'TG' in the Non-Site/Incident Activity Code field (TES Generic Obliga-
tion).
E-6
-------
OSWER Directive 9200.3-01H-1
A5. WasteLAN system generates the current FY, but the user can overwrite the data in
this field if desired.If the correct TG activity already exists in WasteLAN, then
proceed with step 6, otherwise do steps 5a - 5d.
5a. Select Add New Activity.
5b. Enter 'FE' as the Lead.
5c. Enter any activity comment desired.
5d. Select A to add the record.
A6. Select the specific activity record needed, e.g., TG01.
A7. Select Financial System.
A8. Choose financial type, i.e., Option 4 is commitment or Option 5 is decommitment.
A9. Select Add New Record.
A10. Do not enter data into the date or amount fields, unless you have the correct FMS
amount and commitment date, in order to avoid creating duplicate records during
the financial download procedure.
All. Enter any activity comments .
A12. Enter the Document Control Number (DCN) from the PR.
A13. Enter the Account Number (ACN) from the PR.
A14. Enter 'TES05', 'TES06', etc. into the Vehicle field for the TES contract number.
A15. Enter the contractor's name in the Contractor field (optional).
A16. Enter '2535' in the Ob. Subob. Class field.
A17. Enter 'E' for the Enforcement Budget Source.
A18. Enter the number of expected work assignments against the generic obligation.
A19. Enter 'A' (default) in order to add this financial record to the data base.
Mainframe CERHELP Coding Instructions
Bl. Access main menu for data entry and select non-site/incident.
B2. Select non-site/incident screen from the non-site menu.
B3. Enter 'A' to add a new record.
B4. Enter Region number.
B5. Enter activity type as 'TG' for TES generic obligation and press enter.
B6. Enter activity lead as 'FE'.
B7. Enter current FY.
B8. Enter any activity comment (e.g., Funds to cover all TES work assignments).
B9. Confirm the activity.
BIO. Enter 'A' to add financial information and then proceed to enter region, activity
type including the sequence number and press enter.
Bl 1. Enter financial type 'C' for a commitment (positive amount), or 'M' for a
decommitment (negative amount).
B12. Enter the IFMS account number (ACN) from the PR.
B13. Enter the IFMS document control number (DCN) from the PR.
B14. Enter 'TES05', 'TES06', etc., identifying the specific TES contract.
B15. Enter '2535' for the Object/Subobject Class.
B16. Enter 'E' for Enforcement Funding Source.
B17. Enter the estimated number of sites expected to have TES work assignments
against the generic obligation in the NBR SITES field.
B18. Enter the date the Funds Control Clerk signed the PR in the ACTUAL FIN.
DATE field.
B19. Enter the amount from the PR.
E-7
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OSWER Directive 9200.3-01H-1
OBLIGATING FUNDS TO COVER CONTRACT BUY IN WORK ASSIGNMENTS
Buy-in commitments/obligations are of two types: 1) enforcement funds used to buy into
one of the non-TES contracts, and 2) remedial, removal, or Federal Facility funds used to buy
into one of the TES contracts. Both types of buy-ins must be entered into the data base. The
budget source code should be used to indicate the source of funds.
WasteLAN Coding Instructions
A: Remedial Events
Al. Select Remedial from the main menu.
A2. Choose the event type (RVFS, RD, RA, etc.) from the remedial menu.
A3. Specify the site by entering the WasteLAN reference number and verify that the
information is correct.
A4. Choose the correct operable unit (OU) by selecting next/previous OUuntil the
screen information matches the TES WA form. Then choose 'View/Edit Events'.
If there is no event then choose 'Add' to add a new event.
A5. Choose the correct event by viewing the next/previous events until the informa-
tion matches the TES WA form. Then choose 'Financial System.'
A6. Choose financial type of commitment or decommitment.
A7. Choose 'A' to add a new financial record.
A8. Enter date the Funds Control Officer signed the PR.
A9. Enter the amount from the PR.
A10. Enter an 'E', 'R', 'V, or 'F' based on Funding Source.
All. Enter the ACN from the PR.
A12. Enter the DCN from the PR.
A13. Enter the contract vehicle number (e.g., TES 12).
A14. Enter contractor name (optional).
A15. Enter '2535' for the object class.
Al6. Enter financial comments if necessary.
A17. Choose 'A' to add record.
B: Enforcement A ctivities
B1. Select Enforcement from the main menu.
B2. Choose the activity group (RP Search, Negotiations, Litigation, etc.) from the
Enforcement menu.
B3. Choose the activity type.
B4. Choose 'Add' to add an activity if one does not already exist.
B5. Specify the site by entering the WasteLAN reference number and verify that the
information is correct.
B6. Choose 'Budget Financial' from the activity menu.
B7. Choose financial type for commitment or decommitment.
B8. Choose 'Add' to add a new financial record.
B9. Enter the amount from the PR unless the financial download has been imple-
mented.
BIO. Enter date the Funds Control Officer signed the PR.
Bl 1. Enter an 'E', 'R', 'V, or 'L' based on Funding Source.
B12. Enter the contract vehicle number (e.g., TES 12).
B13. In the financial note field, enter ACN in the first 10 characters. Then enter a
single space and enter the DCN.
B14. Choose 'A' to add record.
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OSWER Directive 9200.3-01H-1
C: Non-Site Specific Incidents
Cl. From Main Menu select CERHELP System.
C2. Select Non-Site/Incident from CERHELP Program screen.
C3. Select Modify/View Activitites from the non-site/incident menu.
C4. Enter 'TG' in the Non-Site/Incident Activity Code field.
C5. WasteLAN system generates the current FY, but user can overwrite the data in
this field if desired. If the correct TG activity already exists in WasteLAN, then
proceed with step 6, otherwise do steps 5a - 5d.
5a. Select Add New Activity.
5b. Enter 'FE' as the Lead.
5c. Enter any activity comment desired.
5d. Select A to add the record.
C6. Select the specific activity record needed, e.g., TG01.
C7. Select Financial System.
C8. Choose financial type, i.e., Option 4 is commitment or Option 5 is decommitment.
C9. Select Add New Record.
CIO. Do not enter data into the date or amount fields, unless you have the correct IFMS
amount and commitment date, in order to avoid creating duplicate records during
the financial download procedure.
Cl 1. Enter any activity comments.
C12. Enter the Document Control Number (DCN) from the PR.
C13. Enter the Account Number (ACN) from the PR.
C14. Enter contract vehicle and number into the Vehicle field.
C15. Enter the contractor's name in the Contractor field (optional).
C16. Enter '2535' in the Object/Subobject Class field.
C17. Enter an 'E', 'R', 'V, or 'L' based on Funding Source.
CIS. Enter 'A' (default) in order to add this financial record to thedata base.
Mainframe CERCLIS Coding Instructions
I. Determine whether the assignment is for a remedial event, enforcement activity, or
non-site specific function. The event or activity type will be coded on the
TESWATS form in: Item 10A, 10B, or IOC, respectively.
II. Access the appropriate side of the database, remedial site information, enforce-
ment site information, or non-site specific information.
in. At this point, instructions vary between remedial events, enforcement activities,
and non-site specific assignments. Use part A below for remedial event coding,
part B below for enforcement activity coding, and part C below for non-site
specific coding.
A: Remedial Events
Al. Access main menu for data entry and choose Remedial/Removal
A2. Select Financial Info. Screen to add or update an event financial record.
A3. Select 'A' to add a new event financial record.
A4. From the work assignment form, Item 7, enter the EPA ID Number
[LAD000239814]. (The RPO may verify Site Name and Number with a CER-
CLIS Site Alias Location Listing, report L.4.)
A5. From the work assignment form, Item 9, enter the operable unit number.
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OSWER Directive 9200.3-01H-1
A6. From the work assignment form, Item IDA, enter the event type and sequence
number and press enter.
A7. The PR amount will be positive or negative. For a positive number, enter 'C for
commitment; for a negative number, enter 'M' for decommitment as the Financial
Type.
A8. Enter an 'E', 'R', 'V, or 'L' based on Funding Source.
A9. From the PR, or work assignment form, Item 11, enter the financial amount.
A10. From the PR, enter the date the Funds Control Officer signed the PR to make the
IFMS commitment in the FIN DATE field.
All. From the work assignment form, Item 1, enter the TES contract number as the
Financial Vehicle.
A12. From the work assignment form, Item 5, enter the contractor's name.
A13. From the PR, or work assignment form, Item 4, enter the IFMS account number
in the ACCOUNT field.
A14. From the PR, enter the IFMS document control number in the DCN field.
B: Enforcement Activities
B1. Access main menu for data entry and choose Enforcement.
B2. Select the Enforcement FMS Financial Info. Screen.
B3. Select 'A' to add a new financial record and enter the EPA ID, and the Activity
Type with the sequence number.
B4. The PR amount will be positive or negative. For a positive number, enter 'A' for
obligation; for a negative number, enter 'D' for deobligation as the Financial
Type.
B5. From the PR, or work assignment form, Item 11, enter the financial amount.
B6. From the PR, enter the date the Funds Control Officer signed the PR to make the
IFMS obligation.
B7. From the work assignment form, Item 1, enter the TES contract number as the
Financial Vehicle.
B8. Enter an 'E', 'R', 'V, or 'F' based on Funding Source.
B9. From the PR or work assignment form, Item 4, enter the FMS account number in
the Enforcement Financial Note field.
BIO. From the PR, enter the FMS document control number in the Enforcement Finan-
cial Note field.
C: Non-Site Specific Incidents
Cl. Access main menu for data entry and choose non-site/incident.
C2. Select non-site/incident screen from the non-site menu.
C3. Enter 'A' to add a new record.
C4. Enter Region number.
C5. Enter activity type as 'OH' and press enter.
C6. Enter activity lead as 'FE'.
C7. Enter current FY.
C8. Enter any activity comment (e.g., Funds to cover all TES work assignments).
C9. Confirm the activity.
CIO. Enter 'A' to add financial information and enter Region, activity type including
the sequence number and press enter.
Cl 1. Enter financial type 'C' for a positive commitment, or 'M' for a decommitment
(negative amount on PR).
Cl2. Enter the FMS account number (ACN) from the PR.
C13. Enter the FMS document control number (DCN) from the PR.
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OSWER Directive 9200.3-01H-1
C14. Enter 'TES05', 'TES06', etc., for the TES contract number, Contract Vehicle.
C15. Enter '2535' for the Object/Subobject Class.
C16. Enter an 'E', 'R', 'V, or 'L' based on Funding Source.
C17. Enter the estimated number of sites expected to have TES work assignments
against the generic obligation in the NBR SITES field.
CIS. Enter the date the Funds Control Clerk signed the PR in the FIN. DATE field.
C19. Enter the amount from the PR.
ENTERING TES WORK ASSIGNMENT AMOUNTS (TASKING]
Each TES work assignment (both buy-ins and non buy-ins) will be entered into CER-
CLIS/WasteLAN using the codes for TES Work Assignment Amount, 'H', and detasking,'W.
Once the Contracting Officers have approved a work assignment, the Region should enter the
work assignment into CERCLIS. RPOs and Information Management Coordinators should work
together to make sure that all TES financial data is entered in a timely manner.
WasteLAN Coding Instructions
A; Remedial Events
Al. Select Remedial from the main menu.
A2. Choose the event type (RI/FS, RD, RA, etc.) from the remedial menu.
A3. Specify the site by entering the WasteLAN reference number and verify that the
information is correct.
A4. Choose the correct OU by selecting next/previous OU until the screen information
matches the TES WA form. Then choose'View/Edit Events'. If there is no event
then choose 'Add' to add a new event.
A5. Choose the correct event by viewing the next/previous events until the informa-
tion matches the TES WA form. Then choose 'Financial System'.
A6. Choose financial type of TES work assignment amount (tasking) or detasking.
A7. Choose 'A' to add a new financial record.
A8. Enter date the CO signed the WA.
A9. Enter the amount from the WA.
A10. Enter an 'E', 'R', 'V', or 'L' based on Funding Source.
All. Enter the last two digits of the work assignment amendment number.
A12. Enter the six digit work assignment number.
A13. Enter the contract vehicle number (e.g. TES 12).
A14. Enter contractor name (optional).
A15. Enter financial comments if necessary.
A16. Choose 'A' to add record.
B: Enforcement Activities
B1. Select Enforcement from the main menu.
B2. Choose the activity group (RP Search, Negotiations, Litigation, etc.) from the
Enforcement menu.
B3. Choose the activity type.
B4. Choose 'Add' to add an activity if one does not already exist.
B5. Specify the site by entering the WasteLAN reference number and verify that the
information is correct.
B6. Choose 'Budget Financial' from the activity menu.
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OSWER Directive 9200.3-01 H-l
B7. Choose financial type for TES work assignment amount (tasking) or detasking.
B8. Choose 'Add' to add a new financial record.
B9. Enter the amount from the WA.
BIO. Enter date the COsigned theWA.
Bl 1. Enter an 'E', 'R', 'V, or 'F based on Funding Source.
B12. Enter the six digit work assignment number.
B13. Enter the last two digits of the work assignment amendment number.
B14. Enter the contract vehicle number (e.g. TES 12).
B15. Choose 'A' to add record.
C: Non-Site Specific Incidents
Cl. From Main Menu select CERHELP System.
C2. Select Non-Site/Incident from CERHELP Program screen.
C3. Select Modify/View Activitites from the non-site/incident menu.
C4. Enter the Non-Site/Incident Activity Code field.
C5. WasteLAN system generates the current FY, but user can overwrite the data in
this field if desired. If the correct activity already exists in WasteLAN, then
proceed with step 6, otherwise do steps 5a - 5d.
5a. Select Add New Activity.
5b. Enter the Lead.
5c. Enter any activity comment desired.
5d. Select A to add the record.
C6. Select the specific activity record needed.
C7. Select Financial System.
C8. Choose financial type for TES work assignment amount (tasking) or detasking.
C9. Select Add New Record.
CIO. Enter the date the CO signed the WA.
Cl 1. Enter any activity comments .
C12. Enter contract vehicle and number into the Vehicle field.
C13. Enter the six digit work assignment number in the Work Assignment field.
C14. Enter the last two digits from the work assignment amendment number into the
Amendment Number field.
C15. Enter the contractor's name in the Contractor field (optional).
C16. Enter an 'E', 'R', 'V, or 'L' based on Funding Source.
C17. Enter 'A' (default) in order to add this financial record to the data base.
Mainframe CERCLIS Coding Instructions
I. Determine whether the assignment is for a remedial event,enforcement activity, or
non-site specific function. The event or activity type will be coded on the
TESWATS form in: Item 10A, 10B, or IOC, respectively.
II. Access the appropriate side of the database, remedial site information, enforce-
ment site information, or non-site specific information.
in. At this point, instructions vary between remedial events, enforcement activities,
and non-site specific assignments. Use part A below for remedial event coding,
part B below for enforcement activity coding, and part C below for non-site
specific coding.
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OSWER Directive 9200.3-01H-1
A; Remedial Events
Al. Access main menu for data entry and choose Remedial/Removal.
A2. Select Financial Info. Screen to add or update an event financial record.
A3. Select 'A' to add a new event financial record.
A4. From the work assignment form, Item 7, enter the EPA ID Number
[LAD000239814]. (The RPO may verify Site Name and Number with a CER-
CLIS Site Alias Location Listing, report L.4.)
A5. From the work assignment form, Item 9, enter the OU number.
A6. From the work assignment form, Item 10A, enter the event type and sequence
number and press enter.
A7. The work assignment amount will be positive or negative. For a positive number,
enter 'H' for work assignment amount; for a negative number, enter 'W to
decrease the work assignment amount.
A8. Enter an 'E', 'R', 'V, or 'L' based on Funding Source.
A9. From the work assignment form, Item 11, enter the financial amount.
A10. From the work assignment form, Item 14, enter the CO signature date in the FIN.
DATE field.
All. From the work assignment form, Item 1, enter the TES contract number as the
Financial Vehicle.
A12. From the work assignment form, Item 5, enter the contractor's name.
A13. From the work assignment form, Item 2, enter the work assignment number in the
WKASGN field.
A14. From the work assignment form, Item 3, enter the last two digits of the amend-
ment number in the AMEND # field.
B: Enforcement Activities
B1. Access main menu for data entry and choose Enforcement.
B2. Select the Enforcement FMS Financial Info. Screen.
B3. Select 'A' to add a new financial record and enter the EPA ID, and the Activity
Type with the sequence number.
B4. The work assignment amount will be positive or negative. For a positive number,
enter 'H' for work assignment amount; for a negative number, enter 'W to
decrease the work assignment amount.
B5. From the work assignment form, Item 11, enter the financial amount.
B6. From the work assignment form, Item 14, enter the CO signature date in the FIN.
DATE field.
B7. From the work assignment form, Item 1, enter the TES contract number as the
Financial Vehicle.
B8. Enter an 'E', 'R', 'V, or 'L' based on Funding Source.
B9. From the work assignment form, Item 2, enter the work assignment number in the
WA NUMBER field.
BIO. From the work assignment form, Item 3, enter the last two digits of the amend-
ment number in the W/A AMEND NBR. field.
C: Non-Site Specific Incidents
Cl. Access main menu for data entry and choose non-site/incident.
C2. Select non-site/incident screen from the non-site menu.
C3. Enter 'A' to add a new record.
C4. Enter Region number.
C5. Enter activity type and press enter.
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OSWER Directive 9200.3-01H-1
C6. Enter activity lead.
C7. Enter current FY.
C8. Enter any activity comment.
C9. Confirm the activity.
CIO. Enter 'A' to add financial information and enter Region, activity type including
the sequence number and press enter.
Cl 1. Enter financial type 'H' a positive work assignment amount, or 'W for a decrease
(negative work assignment amount).
C12. Enter TES05', 'TES06', etc., for the TES contract number.
C13. Enter an 'E', 'R', 'V, or 'L' based on Funding Source.
C14. Enter the estimated number of sites expected to have TES work assignments
against the generic obligation in the NBR SITES field.
CIS. From the work assignment form, Item 14, enter the CO signature date in the FIN.
DATE field.
C16. From the work assignment form, Item 11, enter the financial amount.
C17. Enter the six digit work assignment number from the TES work assignment form
in the IAG/WK ASGN field.
CIS. Enter the last two digits of the amendment number from the TES work assign-
ment form in the IAG/WK ASGN AMEND field.
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OSWER Directive 9200.3-01H-1
APPENDIX F
FEDERAL FACILITIES CODING GUIDANCE
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OSWER Directive 9200.3-01H-1
FEDERAL FACILITY CODING GUIDANCE
INTRODUCTION
This document presents a standard approach to coding Federal Facilities events and
activities in the Comprehensive Environment Response, Compensation, and Liability Informa-
tion System (CERCLIS). Federal Facilities are to be coded in a similar manner to private sites.
However, because of the unique nature of Federal Facilities, some coding requirements may be
different. How a Federal Facility is coded at the site level may be unique; however, coding at the
operable unit level at the event/activity level should follow standard WasteLAN coding
guidance. Therefore, this guidance will focus primarily on definitions and site coding
characteristics that are unique to Federal Facilities.
DEFINITIONS
Site
A Federal Facility is coded as a single WasteLAN site, referring to all areas of remedia-
tion/removal activity at the facility. Each facility listed on the National Priorities List (NPL)
should be tracked as one WasteLAN site. In a small number of historical cases, a single Federal
Facility will be listed on the NPL more than once, or a discrete portion of a Facility may have
been listed on the NPL. Each listing is coded as a WasteLAN site. In the future, each Federal
Facility will be listed only once and this listing will, to the extent possible, address the entire
facility.
Operable Unit
An Operable Unit (OU) is one of the following:
• A separate geographic area of treatment. For example, a site may have two OUs
with two sets of Remedial Investigation/Feasibility Study (RI/FS), Record of
Decision (ROD), Remedial Design (RD) and Remedial Action (RA) events, one
addressing the northern end of the site, and one addressing the southern end,
which are separated by a lake.
• A separate treatment technology in the same geographic area. For example, at the
RI/FS stage at a site, it may be determined that both a waterline and soil treatment
technologies are required. That site would then have two OUs. One OU, the
waterline, would have the full RI/FS - ROD - RD - RA sequence, and the second,
the soil treatment, would have either the RD - RA event sequence or the ROD -
RD - RA sequence.
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OSWER Directive 9200.3-01H-1
Phase
According to the draft document "Operable Unit Guidance To Be Used In Implementing
Links," dated 9/5/90, " At the RD and RA stages, an OU may be phased or time-sequenced to
accelerate the cleanup effort. Phasing is the division of a project into meaningful work elements
that can progress on different schedules resulting in the acceleration of the RD and RA. "Large,
complex projects (or OUs) may be broken down into smaller, more manageable response ele-
ments. Elements may be worked in unison, but each individual element has its own schedule and
moves at its own rate through the remediation process." (OSWER Directive #9200.2-02 page 6).
The availability of sequence numbers allows the Regions to code and track this phasing.
CODING ISSUES AND RESOLUTIONS
Site Assessment
In general at a Federal Facility, site assessment events follow this pattern:
• Discovery Date;
• Preliminary Assessment (PA);
• Site Inspection (SI);
• Hazard Ranking System (HRS) Package Development;
Proposed to NPL;
• Removed from Proposed NPL (only if pubic comments warrant removal from the
proposed NPL); and
• Final Listing on NPL.
Sometimes, multiple PAs can occur at a Federal Facility. In processing reports, however,
CERCLIS/WasteLAN reads only the first PA event record. For this reason, only one PA event
should be coded per site in WasteLAN.
Remedial Coding
In general at a Federal Facility, remedial events follow this pattern:
RI/FS;
ROD;
RD;
RA;
• Operations and Maintenance (O&M)
• Long-Term Response Action (LTRA); and
• Deletion from NPL.
For the first OU, the RI/FS start date is defined as the Interagency Agreement (LAG)
signature date, or the date of receipt of an RI/FS workplan if received after the IAG signature.
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OSWER Directive 9200.3-01H-1
For subsequent RI/FSs, the start date is defined as the receipt of the RI/FS workplan
within the context of an executed IAG. In no case should RI/FS work begin at the OU prior to
IAG signature unless the work had been initiated pursuant to an enforceable agreement such as a
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section
106 Administrative Order on Consent (AOC), or a Resource Conservation and Recovery Act
(RCRA) 3008 (H) order. A ROD record in WasteLAN should not represent multiple Feasibility
Studies (FSs) that happen to conclude at the same time, even if only one decision document is
signed that encompasses several decisions. Instead, a ROD should be coded for each decision.
Removal Coding
Since litigative or cost recovery activities are rarely pursued at Federal Facilities, removal
event sequences typically consist only of the removal event itself. If a removal is not specific, it
should be coded at operable unit 00 (zero-zero). If, however, a removal is conducted in support
of specific remediation, it should be coded at the OU of that remediation.
Enforcement Coding
Usually, enforcement activity at a Federal Facility consist of IAG negotiations and the
resulting IAG. lAGs that cover more than one facility or WasteLAN site should be coded at all
applicable sites. The IAG signature date, which is the actual completion date, usually defines the
RI/FS start date, so the two should usually match in WasteLAN.
Financial Coding
In the past, Federal Facility activities have been funded and managed from the Superfund
Enforcement budget. With the move of Federal Facilities from the Office of Waste Program
Enforcement (OWPE) to the Office of Enforcement (OE), Regions will receive a separate Ad-
vice of Allowance (AOA) from OE.
Specific procedures for the planning and execution of Federal Facilities monies will not
change significantly. The budget source code for Federal Facilities, 'L' has been implemented in
WasteLAN. Regions should enter 'L' in the C3239, C2629, and C1416 fields in WasteLAN
where previously 'E' was entered.
To assist Regions in budget planning, three reports have been developed and placed on
CEREVAL. These reports are ENFR- 31, ENFR-32, and ENFR-33. Functionally, these reports
are analogous to OWPE's ENFR-46, 47 and 48. These reports are used to measure Regional
planned dollars against AOA amounts.
Information that was previously coded as direct Technical Enforcement Support (TES)
work assignment (tasking) amounts should now be coded as TES buy-ins. The Superfund
Program element, which is coded in the Account Number (AN)/Document Control Number
(DCN) field (C3204, C2604, and C1405) is TYPY3A. The C2604, C3204 and C1405 fields
should be coded using this. In all cases, 'L' will be the budget source. (Instructions for coding
TES buy-ins and non-TES buy-ins can be found in Appendix E.) Regions should plan to write
Procurement Request (PR) committing funds to the contract for each specific event or activity.
Please address questions to Nick Morgan, Office of Federal Facilities Enforcement (OFFE), at
FTS 260-4846.
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OSWER Directive 9200.3-01H-1
APPENDIX G
NPL BOOK
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LEMON LAN
INDIANA
EPA ID# IND980794341
EPA REGION 5
CONGRESSIONAL DIST. 09
Monroe County
Bloomington
Site Description
The Lemon Lane Landfill site is located on the western edge of Bloomington. The site encompasses
10 acres, 3 of which are owned by a private citizen. From 1950 to 1964, the landfill, which had no
liner or runoff controls, accepted both municipal and industrial wastes. Allegedly, wastes were
incinerated on site. No records were kept of the types or quantities of wastes received. Of primary
concern were large quantities of exposed and leaking capacitors containing polychlorinated
biphenyls (PCBs). Starting in 1980, the State of Indiana and the EPA sampled the area several
times. No PCBs were detected in nearby residential wells at the time, nor were any surface
discharges observed. However, the geology of the area suggests that groundwater contamination is
possible. Westinghouse Electric Corporation, the party potentially responsible for contamination at
the site, is handling cleanup of Lemon Lane Landfill, as well as three other NPL sites, one
authorized landfill, and an inactive, City-owned wastewater treatment plant in the Bloomington area
(Neal's Landfill, Neal's Dump, Bennett Stone Quarry, the Anderson Road Landfill, and the
Winston-Thomas Treatment Plant). Westinghouse is planning to construct an incinerator that will
comply with all applicable local, State, and Federal laws.
Site Responsibility:
This site is being addressed through
Federal and potentially responsible
parties' actions.
NPL LISTING HISTORY
Proposed Date: 12/30/82
Final Date: 09/08/83
Threats and Contaminants
The groundwater and soils are contaminated with PCBs. Direct contact with and
accidental ingestion of contaminated soil or groundwater are potential health threats.
Capping the landfill has reduced the opportunity for contaminants to reach the
groundwater.
Cleanup Approach
The site is being addressed in two stages: immediate actions and a long-term remedial phase
directed at cleanup of the entire site.
April 1991
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Response Action Status
Immediate Actions: In 1983, the EPA constructed a fence around the site to prevent
access to the area. The EPA also removed exposed PCS capacitors, graded and covered
the southern slopes of the site, regraded and contoured the land to prevent ponding or
erosion, and capped the site. In 1988, a low-flow dye trace study of the groundwater system around
the landfill was conducted to determine the hydrologic connection of springs to the site and to better
define the groundwater system. On the basis of this study, the EPA concluded that effects on the
local groundwater wells are minimal.
Entire Site: An alternate water supply was provided to a resident whose wells showed
signs of contamination. One nearby residence was connected to the city water supply in
1988, after the dye trace study determined that its well water supply was. contaminated. A
synthetic cap was placed on the landfill in 1988. In 1990, Westinghouse concluded high-flow dye
trace studies of the flow and presence of contaminated groundwater. Westinghouse will conduct the
remaining remedies for the site: (1) excavation of approximately 176,000 cubic yards of soil and
material from the landfill to a pre-Westinghouse depth plus 3 feet of buffer zone; (2) incineration of
excavated materials in an approved facility; and (3) periodic groundwater monitoring. The
excavation and incineration activities are contingent on the approval of the permit applications for
the incinerator and a landfill for ash disposal. The permit applications are expected to be submitted
in 1991.
Environmental Progress
By constructing a fence to restrict site access, removing the PCB capacitors, and grading and
installing a synthetic liner cap over the site to limit movement of contaminants from the property, the
potential for exposure to hazardous materials at the Lemon Lane Landfill site has been greatly
reduced while cleanup activities continue.
April 1991 LEMON LANE LANDFILL
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OSWER Directive 9200.3-01 H-l
APPENDIX H
APPLICABILITY OF THE FREEDOM OF INFORMATION ACT TO SCAP
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OSWER Directive 9200.3-01H-1
APPENDIX H
APPLICABILITY OF THE FREEDOM OF INFORMATION ACT TO SCAP
TABLE OF CONTENTS
CERCLIS REPORTS RELEASABLE UNDER FOIA H-l
SENSITIVE SCAP-RELATED INFORMATION H-l
Exemption 7 — Records or Information Compiled
For Law Enforcement Purposes H-2
Exemption 5 — Privileged Interagency or
Intra-Agency Memoranda H-3
AD HOC REPORTING H-4
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OSWER Directive 9200.3-01 H-l
APPENDIX H
APPLICABILITY OF THE FREEDOM OF INFORMATION ACT TO SCAP
COMPREHENSIVE ENVIRONMENTAL RESPONSE. COMPENSATION. AND
LIABILITY INFORMATION S YSTEM (CERCLIS) REPORTS RELEASABLE UNDER
FREEDOM OF INFORMATION ACT fFOIA}
There is a set of CERCLIS-generated reports that have sensitive information (records or
information that are protected under FOIA and cannot be released to the public) removed and
may be released under FOIA. It includes:
• SCAP-11 (Public Superfund Comprehensive Accomplishments Plan (SCAP)
National Priorities List (NPL) Site Summary);
SCAP-12 (Public SCAP Non-NPL Site Summary);
SCAP-22 Target Candidate List;
• List-1 (Site Location);
• List-3 (Site/Alias Crosswalk);
• List-4 (Site/Alias Location);
List-8 (Site/Event Status);
ENFR-10 (Settlement Report);
AUDT-11 (Final and Proposed NPL Sites); and
• STAT-3 (Program/Event Plans and Accomplishments).
SENSITIVE SCAP-RELATED INFORMATION
FOIA is intended as a disclosure law, not a withholding law. In handling all FOIA
requests, there should be a presumption in favor of releasing information. There are certain
types of information, particularly enforcement information, that have been designated as confi-
dential and therefore not releasable to the public because disclosure could cause significant harm
to the Agency. The following information fits into this category:
• Section 106 and 107 litigation and Consent Decrees (CD) and all related informa-
tion where the planning information indicates that the action has or will be re-
ferred to Headquarters (HQ) or to the Department of Justice (DOT). If the case is
filed, the information may be released.
• Potentially Responsible Party (PRP) lead Remedial Investigation/Feasibility Study
(RI/FS) projects and all related information where only planning data exist. If
there is an actual PRP RI/FS start, the planned completion date (Fiscal Year/
Quarter) can be released. However, no subsequent response dates are releasable.
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• Remedial Design (RD)/Remedial Action (RA) -Administrative Order/CD and all
related information where only planning data exist. This information is only
releasable where an actual completion date exists.
• Planned obligation amounts related to Regional enforcement extramural budget
activity associated with the following activities:
Litigation (106, 106/107,107) support;
Removal negotiations;
Non-NPL and NPL PRP search;
RI/FS negotiations;
RD/RA negotiations; and
Cost recovery negotiations.
• RD and RA planned events where the lead is the RP with no actual starts. When
there is an actual start, the planned completion can be released.
• RI/FS and RD/RA negotiations planned start and completion dates. When there is
an actual start, the planned completion can be released.
• Compliance code and status indicator.
• Planned removal/remedial obligations.
• All planned activities for sites that have not been designated as final or proposed
NPL sites in the Federal Register.
• Information of the financial viability of PRPs.
This information is protected from mandatory disclosure by the following FOIA exemp-
tions and provisions:
• EXEMPTION 7: Records or information compiled for law enforcement purposes.
Specifically, EXEMPTION 7 (a) - Could reasonably be expected to interfere with
enforcement proceedings.
Exemption 7—Records or Information Compiled For Law Enforcement Purposes
This exemption provides that records or information compiled for law enforce-
ment purposes need not be disclosed in six specific instances. Even though a
document falls under Exemption 7, the Agency, in its discretion, encourages
release of the document unless release would significantly harm the Agency.
Under this section, records or information can be exempted if:
• Exemption 7(a) — Disclosure could reasonably be expected to interfere
with enforcement proceedings. Harm to the government's case in court by
premature release of evidence or information or damage to the Agency's
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ability to conduct an investigation constitutes interference under the
exemption.
• Exemption 7(b) — Disclosure would deprive a person of a right to fair
trial.
* Exemption 7(c) — Disclosure could reasonably be expected to constitute
an unwarranted invasion of personal privacy.
• Exemption 7(d) — Disclosure could reasonably be expected to disclose
the identity of a confidential source. This includes protection of informa-
tion provided by the source on a criminal law enforcement investigation.
• Exemption 7(e) — Disclosure would reveal a special technique or proce-
dure for law enforcement investigations or prosecutions.
• Exemption 7(f) — Disclosure could reasonably be expected to endanger
the life or safety of any person.
As a result of 1986 Amendments to FOIA Exemption 7, the general coverage of
Exemption 7 is no longer investigatory records but records or information com-
piled for law enforcement purposes. As long as some law enforcement authority
exists and the record meets the threshold test for Exemption 7, the record need no
longer reflect or result from specifically focused inquiries by the Agency.
EXEMPTION 5: Privileged Interagency or Intra-Agency Memoranda. Specifi-
cally, EXEMPTION 5, Privilage 1- Deliberate Process Privilege, and EXEMP-
TION 5, Privilege 4 - Government Commercial Information Privilege.
Exemptions — Privileged Interagency or Infra-Agency Memoranda
Intra-agency records include reports prepared by outside consultants at the request
of the Agency. Recommendations from State officials to Environmental Protec-
tion Agency (EPA) may be considered intra-agency records when EPA has
solicitedState comments, has a formal relationship with the State, and the records
concern a specific deliberative process.
This exemption allows the Agency to withhold from disclosure interagency or
intra-agency memoranda or letters which fall under the following privileges:
• The Deliberative Process Privilege protects the quality of the Agency's
decision-making process (i.e., to protect against premature disclosure of
proposed policies before they are adopted), to encourage candid and frank
discussions among Agency officials, and to avoid premature disclosure
which could mislead the public.
Only pre-decisional, deliberative documents may be withheld. These are
written prior to the Agency's final decision, and are not likely to be those
that are written by a person with final decision-making authority. Drafts
of documents usually fall under this category, and documents transmitted
between the government and third parties during settlement negotiations
are occasionally protected under this privilege.
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The deliberative process privilege does not allow the withholding of
purely factual portions of documents. These portions must be released if
they can be segregated from the remainder of the document (partial de-
nial). This requirement presents a problem where the facts themselves
reflect on the Agency's deliberative process; in this instance, the factual
portions may be withheld.
• The Attorney-Work Product Privilege allows the withholding of docu-
ments prepared in anticipation of possible litigation. Litigation need not
have commenced but it must be reasonably contemplated. This privilege
does not extend to purely factual documents unless they reflect the results
of an attorney's evaluation.
• The Attorney-Client Privilege applies to confidential communications
between attorney and client, including communications between an
Agency attorney and an Agency employee.
• The Government Commercial Information Privilege is available to the
government for information it generates in the process leading up to the
award of a contract. This privilege expires once the contract is awarded or
upon withdrawal of the contractual offer. An example of this privilege is
cost estimates prepared by the government and used to evaluate the con-
struction proposals of private contractors.
• The Expert Witness Privilege is commonly invoked to allow the withhold-
ing of records generated by an expert witness.
• The Confidential Witness Statement Privilege allows statements obtained
from confidential witnesses to be withheld.
The Agency encourages the discretionary release of documents falling under any
of the privileges, unless release would significantly harm the Agency's decision-
making process. All of the privileges may be waived if the Agency has disclosed
the document to third parties.
The sensitive information listed above covers the information restricted from public
disclosure as of the compilation of this Manual. Additional information may be added to this
category and information may be restricted in specific instances (though the prior disclosure rule
must be satisfied). If requested information is potentially able to be restricted under a FOIA
provision (in this case, under Exemptions 5, or 7), the official receiving the request should
contact the appropriate FOIA office to determine whether the information should be restricted.
AD HOC REPORTING
In general, all Regional requests for ad hoc reporting — a special request for records or
information that is not part of the approved public SCAP reports — should be referred to the
Office of Waste Programs Enforcement (OWPE) CERCLA Enforcement Division Director
immediately. The Regional official receiving the request should inform the requestor of this
policy and advise the requestor to contact HQ for a decision on whether this information may be
released. If the requested information is only available from a specific Region, and HQ has
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decided to release this information, HQ will inform the responsible Region that the information
should be compiled and disclosed to the requestor.
Ad hoc reporting requests should be treated like FOIA requests. This includes the fol-
lowing:
• If the information is protected under one of the FOIA exemptions, the information
will not be disclosed (except in cases of discretionary release).
• Absent FOIA exemption protection, the information will be disclosed if it can be
compiled or obtained in a reasonable amount of time by an Agency employee
familiar with the subject area.
• Fees for ad hoc reporting requests will be charged in accordance with the fee
structure used for FOIA requests.
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* U.S. G.P.O.:1992-341-835:60755
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