United States Environmental Protection Agency Superfund Office of Solid Waste and Emergency Response Washington DC 20460 HIGHLIGHTS: Superfund Program Management Fiscal Year 1993 FY93 Program Themes Superfund Accelerated Cleanup Model (SACM) Setting Integrated Priorities Integrated Timeline for Site Management Relationship of SCAP to Other Management Tools Overview of the SCAP Process Accomplishment Reporting and Performance Evaluation SCAP/STARS Adjustments and Amendments The FY 93 Regional Budget Advice of Allowance and Financial Management Procedures Overview of the FTE Distribution Process ------- Directive 9200.3-01 H-3 October 1992 HIGHLIGHTS: Superfund Program Management Fiscal Year 1993 U.S. Environmental Promotion Agency Retfon 5, Libraty (r> r '' ' ' -st Jsckson c \ . < 19th ci .-i-.-oO.IL 60604:3590" ^ Fi°0f Office of Emergency and Remedial Response U.S. Environmental Protection Agency Washington, DC 20460 ------- DISCLAIMER The policies and procedures established in this document are intended solely for the guidance of employees of the U.S. Environmental Protection Agency. They are not intended and cannot be relied upon to create any rights, substantive or procedural, enforceable by any party in litigation with the United States. EPA reserves the right to act at variance with these policies and procedures and to change them at any time without public notice. ------- OSWER Directive 9200.3-01H-3 FORWARD The information contained in Highlights: Superfund Program Management is targeted to Division Directors. It is intended to provide an overview of FY 93 Superfund program goals and management initiatives. Specifically, this document contains information on: Strategic planning goals and themes; Program planning and budgeting; and Manager's schedule of significant events. In FY 93, for the first time two other documents have been developed to support the program management and information needs of the Regional Information Management Coordinators, Remedial Project Managers and On-Scene Coordinators (Superfund Program Implementation Manual) and Unit, Section and Branch Chiefs (Superfund Program Management Manual). For more in-depth information, these documents should be read. ------- OSWER Directive 9200.3-01 H-3 HIGHLIGHTS: SUPERFUND PROGRAM MANAGEMENT TABLE OF CONTENTS SECTION I: OVERVIEW OF FY 93 STRATEGIC PLANNING GOALS 1 FY 93 Program Themes 1 Superfund Accelerated Cleanup Model (SACM) 1 Site Assessment 4 Regional Decision Team 4 Early Actions 4 Long-Term Actions 5 Involvement of Enforcement 5 Setting Integrated Priorities 5 SECTION II: IMPLEMENTING THE PROGRAM PLANNING & BUDGETING PROCESS 8 Integrated Timeline for Site Management 8 Relationship of SCAP to Other Management Tools 10 Overview of the SCAP Process 13 Accomplishment Reporting and Performance Evaluation 14 SCAP/STARS Adjustments and Amendments 15 The FY 93 Regional Budget 15 Response Budget 15 Enforcement Budget 15 Federal Facilities Budget 16 Advice of Allowance & Financial Management Procedures 16 Regional Allowances 16 The AOA Process 16 Overview of the FTE Distribution Process 17 ------- OSWER Directive 9200.3-01 H-3 LIST OF EXHIBITS Exhibit 1 - The Superfund Accelerated Cleanup Model (SACM) 2 Exhibit 2 - SACM Implementation Within the NCP Framework 3 Exhibit 3 - Integrated Priority Setting Matrix 6 Exhibit 4 - Integrated Timeline 9 Exhibit 5 - STARS Targets and Measures 11 Exhibit 6 - SCAP Planning Year 13 Exhibit 7 - Accomplishment Reporting and Performance Evaluation 14 ------- OSWER Directive 9200.3-01H-3 ONE MINUTE PROGRAM MANAGER RULES This document provides highlights of key FY 93 Superfund program goals and management initiatives. Following is a quick summary of the information presented in this document. The key principles of efficiency, effectiveness and equity have been proposed in FY 93 to embody the Agency's vision for the future of the Superfund program. All program priorities and goals can be encapsulated under these three principles. The SACM has been developed to streamline and accelerate the Superfund program. In FY 93, high priority will be given to continuing the phased implementation of the SACM concept. The results will be used to develop and refine the concept, with a goal of nationwide implementation in FY 94. t/ The Integrated Priority Setting Matrix has been reorganized to reflect the three key program principles. The matrix provides a framework for establishing, testing and adjusting resource levels during FY 94 budget formulation; FY 93 operating plan development, target setting and negotiation; and FY 93 mid-year adjustment. Superfund Federal Facilities enforcement remains a key Agency issue. Program activities and resources should be planned to accelerate cleanup at closing military bases and expediting property transfer, achieve improved efficiencies by accelerating response time, and complying with statutory timeframes. In FY 93, the Integrated Timeline will continue to be utilized to establish performance expectations. To embody the concept of good timeline management, the average duration will be measured - by Region - for sites with planned RD/RA negotiation starts or completions, or RD or RA starts in FY 93. ------- OSWER Directive 9200.3-01H-3 ONE MINUTE PROGRAM MANAGER RULES (continued) The formal SCAP negotiation process is implemented on a semi-annual basis. The dates for pulling from CERCLIS the information used for negotiations is found in the Manager's Schedule of Significant Events presented at the end of this document. The strategy for assessing the performance of the Superfund program is comprised of monthly accomplishments reporting, quarterly SCAP/STARS performance evaluation based on CERCLIS data, and mid-year and end of year detailed management evaluations. After targets have been finalized and funding levels developed, there is the flexibility to modify plans through the SCAP/STARS adjustment or amendment process. Amendments require HQ concurrence and approval. Adjustments do not require HQ approval, but may require HQ notification. Since there are insufficient resources in the FY for ongoing activities plus the new activities the Regions planned to begin, resource decisions were made based on the FY 93 program priorities and consistent with the Integrated Priority Setting Matrix. For those Regions that have low commitment/obligation/tasking rates, OSWER or OE will renegotiate the Regions operating plan for the remainder of the year during June. This may result in a reduction in the Region's annual budget. In FY 93, each Region's response and enforcement Superfund FTEs will be frozen at FY 90 levels. Federal Facility FTEs will be frozen at the FY 92 level. However, shifting of resources within the Region among the different program areas may occur, consistent with the national budget and the Integrated Priority Setting Matrix. 11 ------- OSWER Directive 9200.3-01 H-3 SECTION I: OVERVIEW OF FY 93 STRATEGIC PLANNING GOALS The focus of the Superfund program is to maximize the protection of human health and the environment through fast, effective cleanup of priority hazardous waste sites and releases. Maximizing appropriate participation of Potentially Responsible Parties (PRPs) and timely remediation of sites, including Federal Facilities, are two of the Superfund program's highest priorities. FY 93 PROGRAM THEMES Fiscal Year 1993 (FY 93) is a critical year for the Superfund program as the Environmental Protection Agency (EPA) approaches the final year of the three-year extension to the Superfund Amendments and Reauthorization Act of 1986 (SARA). Accomplishments in FY 93 will be the most significant indicators of the program's performance. New initiatives are being proposed that embody the Agency's vision for the future and reflect the application of three key principles: efficiency, effectiveness, and equitability. Efficiency and effectiveness initiatives will reduce the timeframe for moving sites through the remedial pipeline and increase the number of site completions/National Priorities List (NPL) deletions. An increase in the number of de minimis settlements, the allocation of equitable costs to municipalities, and the pursuit of non-settlors will improve the Superfund program's equity in dealing with the PRPs. SUPERFUND ACCELERATED CLEANUP MODEL (SACM) The Office of Solid Waste and Emergency Response (OSWER), through its continued investigation of ways to make the Superfund program more efficient, has developed a model for streamlining and accelerating the Superfund program. (See OSWER Directive 9203.1-03, Guidance on Implementation of the Superfund Accelerated Cleanup Model (SACM) under CERCLA and the NCP, July 7,1992.) This model concept is designed to make the Superfund program work better, eliminate redundancies, and accelerate cleanup. The model will deliver results the public will value: Quick reduction of acute risks at all Superfund sites (removal and remedial); and Restoration of the environment over the long term. The SACM, which is presented in Exhibit 1 (page 2), includes: Instituting a one-step site screening and risk assessment at the front end of the process to expedite cleanup and blend removal and remedial cultures; Establishing multi-disciplinary Regional Decision Teams (RDTs) to serve as "traffic cops" for moving sites to early response action or long-term action. This team will also develop standards for remediation levels and technologies; Reducing immediate risk by performing early actions; ------- OSWER Directive 9200.3-01 H-3 EXHIBIT 1 - THE SUPERFUND ACCELERATED CLEANUP MODEL (SACM) PRP Search/ Notification Public Notification of Early Action Start Issue Order/ Negotiate Public Notification of Completion Issue Order/ Negotiate Regional Decision/ Managemen Team Enforcement Activities Long- Term Action for Media Restoration (>5 years) Delete State/Public Participation/Community Relations Implementing long-term actions to restore the environment/media. These sites will require years to clean up but pose no immediate threat; and Involving enforcement, community relations initiatives and the public throughout the process. The compressed schedule of the SACM initiative will require early and continuous consultations with the State and local communities. For many site assessment and early action activities, this interaction will be essential to the success of SACM projects. Each of the elements of the SACM are discussed in the following sections and presented in Exhibit 2 (page 3). In FY 93, continuing the phased implementation of the SACM concept will be a high priority. The results of the pilots will be used to develop and refine the procedures for implementing SACM to cleanup sites. Nationwide implementation of the SACM is expected in FY 94. The information in this document does not address the unique issues associated with implementation of the SACM at Federal Facility sites. Supplemental guidance on those issues is under development. ------- OSWER Directive 9200.3-01H-3 EXHIBIT 2 - SACM IMPLEMENTATION WITHIN THE NATIONAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY PLAN (NCP) FRAMEWORK. ------- OSWER Directive 9200.3-01 H-3 Site Assessment One of the major initiatives of SACM is to break down institutional barriers within the Agency, and to establish an operational scheme under which data are collected and used to serve multiple purposes. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) contemplates that the Agency will sequentially perform (as warranted) a removal Preliminary Assessment (PA) and Site Inspection (SI), a remedial PA and SI, and ultimately a Remedial Investigation (RI). These various studies can be consolidated in appropriate cases under the SACM model such that one site assessment can be performed and one site assessment report written. The report should, however, include findings required by the NCP for moving from one phase of site assessment to another. Regional Decision Team (RDT) The RDT is the cornerstone of the day-to- day implementation of SACM. It is envisioned that there will be one or several RDTs functioning simultaneously to provide adequate coverage for all sites in the remedial pipeline. The RDTs will have decision responsibility for select activities, such as site "triage" (i.e., determining the initial responses required to minimize risk) and helping to set response priorities. In addition, the RDT will be responsible for developing and recommending alternatives to upper management to support the signature of the Action Memorandum and/or Record of Decision (ROD). True emergency situations may be initiated outside the RDT structure when required to accelerate on-site response. Early Actions The purposes of early actions are to respond to emergencies and to eliminate or achieve a quick reduction of risks. The EPA will continue to use the removal authorities in the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and the NCP to respond to emergency and time critical situations (actions that must be initiated in less than six months). In non- time critical situations, where a planning period of at least six months exists, both non-time critical removal and early action remedial authorities could be used to reduce risk. A non-time critical removal action must include an analysis of alternatives in an Engineering Evaluation/Cost Analysis (EE/CA) and the public must be afforded 30 days to comment on the proposed alternative before it is selected. It is also anticipated that it generally will be practicable for non-time critical removal actions to attain most Applicable or Relevant and Appropriate Requirements (ARARs). An early remedial action may be either a final or interim remedial action. An early remedial action can be taken during scoping or at other points during the Remedial Investigation/Feasibility Study (RI/FS) process. Due to its use early in the remedy evaluation process, less documentation is required for the ROD for an interim remedial action than for a final ROD; however, adequate documentation must be provided to justify the action. (See OSWER Directive No. 9355.3-02FS-3, "Guide to Developing Superfund No Action, Interim Action, and Contingency Remedy RODs," April 1991.) ------- OSWER Directive 9200.3-01 H-3 Long-Term Actions The purposes of long-term actions are site remediation activities including ground water restoration and other resource and time intensive activities. The Agency will continue to use its remedial action authorities to respond to most long-term contamination problems. Involvement of Enforcement The SACM goal of accelerating cleanups is not intended to replace other important goals, such as the Agency's general policy of enforcement first. Therefore, it will be necessary to carry out PRP searches early in the site assessment process. An early and effective PRP search will allow the Agency to pursue an effective enforcement strategy for non-time critical early actions. In addition, early identification and notice to the PRPs will strengthen EPA's cost recovery case in Fund-financed situations. SETTING INTEGRATED PRIORITIES One of the tools used by the Agency to reconcile the competing Superfund priorities is the Integrated Priority Setting Matrix. The Matrix was initially developed in 1989 by the Office of Waste Programs Enforcement (OWPE), the Office of Emergency and Remedial Response (OERR), and the Regions. It is evaluated on a yearly basis to ensure that the latest program priorities are accurately reflected. The Matrix is used by OERR, OWPE, the Office of Federal Facilities Enforcement (OFFE), and the Office of Enforcement (OE) to allocate resources in Superfund to the highest priority activities. The Integrated Priority Setting Matrix shown in Exhibit 3 (pages 6-7) has been reorganized to reflect the key principles in FY 93 of efficiency, effectiveness and equity. The new Matrix is designed to: Identify the most significant program priorities that support the three key principles; List the major activities or tools that receive resources, grouped according to their contribution to a program priority; and Arrange the program priorities and major tools in order of importance, where possible. The Matrix provides a framework for establishing, testing and adjusting resource levels. This Matrix will be used by Headquarters (HQ) and the Regions in making trade off decisions during: FY 94 budget formulation; FY 93 operating plan development, target setting and negotiation; and FY 93 mid-year adjustment. The overall organization of the Matrix is governed by the following concepts: All of the activities listed in the Matrix contribute in a significant manner to Superfund program success. Therefore, priority setting must be couched in terms of maintenance of an essential minimum baseline of activity across the board; and A baseline of activities must be supported to ensure that a constant flow of projects is maintained across the remedial and removal pipelines, and that the entire program maintains its operating integrity. ------- OSWER Directive 9200.3-01 H-3 EXHIBIT 3 - INTEGRATED PRIORITY SETTING MATRIX PROGRAM THEME PROGRAM PRIORITIES TOOLS Reduce risks by performing quick response actions at Federal Facility and non-Federal Facility sites; Ensure that resources are available for time critical removals Emphasize enforcement first in Superfund actions; Regions should be prepared to take action promptly after the negotiation moratorium deadlines Accelerate and streamline the Superfund pipeline; Accelerate cleanup at closing military bases and expedite property transfer Increase the number of site completions and NPL deletions Consider use of all relevant enforcement tools and apply these tools to given situations Classic Emergencies (Fund and PRP) National Priorities List (NPL) Removals/ Expedited Response (Fund, PRP and Federal Facility) Remedial Design (RD)/Remedial Action (RA) Negotiations Section 106 Settlement Referrals Section 106 Unilateral Administrative Orders (UAOs)forRD/RA Mixed Funding for RD/RA Administrative Orders (AO) for Removals Federal Facility Interagency Agreements (LAG) Remedial Investigations/Feasibility Study (RI/FS) Negotiations AOs for Non-NPL Time Critical Removals NPL Base Closures Superfund Accelerated Clean-up Model (SACM) RA Starts (Fund, PRP and Federal Facility) RD Starts (Fund, PRP, and Federal Facility) RI/FS Starts (Fund, PRP, and Federal Facility) Site Assessment (Preliminary Assessment (PA)/Site Inspection (SI), Listing) Non-NPL Time Critical Removals Complete Ongoing RAs Prepare and Approve RA Reports, Preliminary Site Close-Out Reports, Interim Site Close-Out Reports and Final Superfund Site Close-Out Reports Delete Sites from the NPL Five Year Reviews Complete Ongoing RDs Complete Ongoing RI/FSs Section 104 Access Section 106 Litigation to Enforce UAOs Compliance Enforcement Section 106/107 Litigation Section 106 Litigation ------- OSWER Directive 9200.3-01H-3 EXHIBIT 3 - INTEGRATED PRIORITY SETTING MATRIX (CONTINUED) PROGRAM THEME PROGRAM PRIORITIES Effectively communicate progress in the Superfund program Ensure effective management of activities that support the Superfund program; Further the use of innovative technologies to permanently clean up sites Achieve early and appropriate settlements with collateral PRPs Select the best cases to ensure cost effective litigation and to maximize recovery to the Trust Fund Take actions to identify PRPs Enter into Cooperative Agreements, Superfund Memoranda of Agreement or other management assistance agreements TOOLS Pilot Projects to Support Efficiency, Effectiveness and Equity Environmental Indicators Technical Assistance Grants Community Relations Administrative Record (Removal and Remedial) Innovative Technologies Contract Management Contract Laboratory Program Removal Support Remedial Project Support Comprehensive Environmental Response, Compensation and Liability Information System (CERCLIS) Data Base Management Records Management Program Management De minimis Settlements Settlements with Municipalities Section 107 Statute of Limitation (SOL) Cost Recovery Referrals Section 122 Administrative Settlements Section 104(e) Referrals NPL PRP Searches Non-NPL PRP Searches Core Program Cooperative Agreement (CPCA) State Program Support ------- OSWER Directive 9200.3-01 H-3 SECTION II: IMPLEMENTING THE PROGRAM PLANNING & BUDGETING PROCESS Successful planning in the Superfund program requires the translation of program priorities into a site management process that supports the goals established in the Agency Operating Guidance. These program goals must be reflected in the budget and workload models, and translated into quantifiable program commitments in the Superfund Comprehensive Accomplishments Plan (SCAP) and the Strategic Targeted Activities for Results System (STARS). Candid evaluation of performance against these commitments is essential to assessing the viability of program priorities, resource requirements, and overall program effectiveness. This section describes the key components and responsibilities of the Regions in supporting the program planning and budgeting process. INTEGRATED TIMELINE FOR SITE MANAGEMENT Success in implementing the Superfund program depends in large part on identifying critical decision points and timeframe goals for moving from one phase of activity to the next. In 1989, the Agency developed a timeline that provides an overview of the major remedial and enforcement activities required in the Superfund site cleanup process. The Integrated Timeline (Exhibit 4, page 9) is a multi-step site management process that, in the ideal situation, spans 24 quarters. The Integrated Timeline will be evaluated in the upcoming year in light of the SACM. Implementation of the SACM may result in the elimination of a number of steps and a reduction in the duration of activities in the timeline. In FY 93, the Integrated Timeline will continue to be utilized to establish performance expectations. Performance improvements will be tracked against the Timeline. To embody the concept of good timeline management, trends analyses will be undertaken. The average duration will be measuredby Regionfor sites where Remedial Design (RD)/Remedial Action (RA) negotiation starts or completions, RD starts or RA starts, are planned in FY 93 as follows: ROD to RD/RA negotiation starts; ROD to RD/RA negotiation completions; ROD to RD start; and ROD to RA start. Each of these averages will be reported relative to prior years (FY 91 and FY 92) and prior quarters performance. In addition, RI/FS start to completion timeframes and RD/RA negotiation timeframes also will be tracked. The durations in the Integrated Timeline are goals that should be used if more accurate estimates are not available. When better planning data and schedules are developed, the Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) must be revised to reflect these schedules. ------- OSWER Directive 9200.3-01H-3 EXHIBIT 4 - INTEGRATED TIMELINE ------- OSWER Directive 9200.3-01 H-3 RELATIONSHIP OF SCAP TO OTHER MANAGEMENT TOOLS The SCAP process is used by the Superfund program to plan, budget, track, and evaluate progress toward Superfund site cleanup. The SCAP planning process is a dynamic, ongoing effort that has a significant impact on Superfund resource allocation and program evaluation. SCAP planning is a day-to-day responsibility of the Regions. A semi-annual process has been established through which HQ and the Regions formally negotiate plans for the future. SCAP and STARS targets are the key devices by which program goals are translated into quantifiable program achievements. Exhibit 5 (page 11-12) contains the STARS targets and measures for the remedial, removal, enforcement and Federal Facility program areas. As the Superfund program's central planning mechanism, SCAP is interrelated with the following Agency and Superfund program specific planning and management systems: Agency Operating Guidance - This defines Superfund goals for the upcoming year. SCAP tar gets/measures are designed to reflect the Agency Operating Guidance. Superfund Budget - The operating year's budget is developed 18 months prior to its beginning. For example, the SCAP existing in the third quarter of FY 93 will be used to formulate the FY 95 budget. The site schedules reflected in the SCAP serve as the foundation for determining outyear budget priorities. Agency Operating Plan - The Operating Plan, which is finalized prior to the FY, establishes the funds available to the Regions for performing Superfund work. STARS - This system is used by EPA to set and monitor the environmental objectives identified in the Agency's Operating Guidance. STARS targets are a subset of those contained in SCAP. STARS targets and measures are reported quarterly by HQ and the Regions to the Office of Pollution Prevention (OPP). OPP tracks Regional progress toward STARS goals on a quarterly basis as part of the overall Agency performance evaluation process. HQ will not recognize a STARS accomplishment unless it is correctly recorded in CERCLIS. Superfund Workload Models - The three Superfund Program models distribute Full Time Equivalents (FTE) for each program and Region: the Hazardous Site and Spill Response model; the Technical Enforcement model; and the Federal Facilities Superfund Workload model. SCAP plans form the basis of the workload models. In FY 93, each Region's response and enforcement FTEs will be frozen at the FY 90 levels. Federal Facility FTEs will be frozen at the FY 92 level. While the freeze ensures that total Regional Superfund resources will not be affected, shifting of resources within the Region among the different program areas may occur. This includes shifts between the response and enforcement programs. All shifts must be made in accordance with the FY 93 national budget and the Integrated Priority Setting Matrix. OFFE will coordinate with OERR and OWPE throughout the SCAP process. OFFE will rely on CERCLIS data in 10 ------- OSWER Directive 9200.3-01H-3 EXHIBIT 5 - STARS TARGETS AND MEASURES STARS REPORTING MEASURE STARS TARGET ACTIVITIES RI/FS ENFORCEMENT ACTIVITIES & SETTLEMENTS De minimis Settlements prior to ROD and Number of PRPs (S/E-3b) lAGs Signed at NPL or Proposed NPL Federal Facility Sites (FFE-2) Federal Facility Remedy Selection at NPL Sites (First and Subsequent) (FFE-4) RDIRA ENFORCEMENT ACTIVITIES. SETTLEMENTS AND REFERRALS Settlements and Injunctive Referrals (S/E-1) De minimis Settlements and Number of PRPs (S/E-3a) Federal Facility RA Starts (FFE-3) RA Contract Award (S/C-1) RA Construction Completions (S/C-2) 11 ------- OSWER Directive 9200.3-01 H-3 EXHIBIT 5 - STARS TARGETS AND MEASURES (CONTINUED) STARS REPORTING MEASURE ACTIVITIES STARS TARGET COST RECOVERY Cost Recovery Actions/ Decisions > $200,000 (S/E-2a) Cost Recovery Actions/ Decisions < $200,000 (S/E-2b) RESPONSE NPL Sites Addressed Through Removal Start 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) Progress Through Environmental Indicators REMOVAL Federal Facility Removals/ Expedited Response Actions (ERA) Starts (FFE-3) Federal Facility Removals/ ERAs Completed 12 ------- OSWER Directive 9200.3-01H-3 planning, budgeting, tracking, and evaluating progress at Superfund Federal Facility sites. CERCLIS data is used, in part, to feed the Federal Facilities workload model. In addition to CERCLIS, OFFE and the Regions will also utilize information gathered in conjunction with the A-106 Pollution Abatement Planning Process to evaluate the adequacy of other Federal agency budgeting for Superfund sites and Federal Facility compliance rates under other environmental statutes. These data will enable OFFE and the Regions to evaluate actual outlays and accomplishments at Superfund sites in relationship to budget authorities, obligations and performance under other environmental programs. OVERVIEW OF THE SCAP PROCESS The SCAP process generates data that fulfill the following functions: EXHIBIT 6 - SCAP PLANNING YEAR Tracking of accomplishments against targets / measures; Updating planning data (schedules and funds) for the current FY; Developing planning data for the upcoming FY; and Providing data for outyear budget planning purposes. The SCAP formal negotiation cycle is a semi-annual process. The focus of the two formal negotiations is slightly different as shown in Exhibit 6 (below). The process for the development of SCAP and STARS targets/measures for a FY begins with the SCAP developed during the second quarter of the previous FY. The dates for pulling the information from CERCLIS that will be used for negotiations can be found in the Manager's Schedule of Significant Events presented at the end of this document. SECOND QUARTER (JAMJARY/FEBRUARY/MARCH 19931 Regional program office consults with States, ORC and responsible Federal agencies on plans and schedules for the upcoming year Revise FY 93 annual budget ceilings to reflect first and second quarter performance and revised plans for the remainder of the year Update and negotiate planning information in CERCLIS for the third and fourth quarter FY 93 Negotiate third and fourth quarter enforcement AOAs Negotiate preliminary FY 94 SCAP/STARS targets and measures Negotiate preliminary annual Regional budgets for FY 94 Provide complete site schedules including planned RA obligations to allow HQ to project the outyear budget (FY 95) FOURTH QUARTER (JULY/AUGUST 1993) Establish final SCAP/STARS commitments for FY 94 Establish FY 94 annual Regional budget 13 ------- OSWER Directive 9200.3-01 H-3 ACCOMPLISHMENT REPORTING AND PERFORMANCE EVALUATION Accomplishments data are entered into WasteLAN by the Region. Data on accomplishments should be entered into WasteLAN as soon as they occur, but no later than within five working days of the event or activity. Only accomplishments correctly reported in CERCLJS will be recognized by HQ. The Superfund evaluation process provides managers with an opportunity to meet program objectives by: Examining program accomplishments; Analyzing and discussing issues that affect the successful operation of the Superfund program; and Initiating changes in program operations or reallocating resources. The strategy for assessing the performance of the Superfund program is comprised of monthly accomplishments reporting, quarterly SCAP/STARS performance evaluation based on CERCLIS data, and mid-year and end of year detailed management evaluations. (See Exhibit 7, below). This strategy enables management to recognize high performance, concentrate Superfund resources in those EXHIBIT 7 - ACCOMPLISHMENT REPORTING AND PERFORMANCE EVALUATION PULL DATE DATA PULLED PURPOSE PROVIDED TO MONTHLY Close of Business (COB) - 5th working day of each month Key indicators of progress - removals, negotiations, RI/FS starts, RODs, RDs, RAs, RD/RA Consent Decrees (CDs), cost recovery referrals Reporting Superfund progress Administrator, Deputy Administrator (DA), AA SWER, AA OE, OWE OFFE, and OERR Office Directors, Congress, and the mflriia QUARTERLY COB - 5th working day of each quarter SCAT/STARS accomplishments Track Regional progress toward meeting SCAP/ STARS targets Identify/assess performance problems Develop HQ/Regional action plans for meeting/ exceeding targets Identify trends in performance Adjust program management strategies OPP STARS system, Administrator, DA, AA SWER, AA OE, OWPE, OFFE, and OERR Office Directors, Congress, and the media SEMI-ANNUAL COB - 5th working day of April SCAP/STARS accomplishments; key indicators of progress Track Regional progress toward meeting SCAP/ STARS targets Identify/assess performance problems Develop HQ/Regional action plans for meeting/ exceeding targets Determine if resource reallocab'on is needed Results impact targets and resources for next FY DA, AA SWER, OWPE, OFFE, and OERR Office Directors ANNUAL COB - 5th working day of September (preliminary) COB - 5th working day of October (official) SCAP/STARS accomplishments Analysis of yearly P*Mf"niHW-P Track progress toward implementing action plans Identify Regions with missed targets. These targets are added to next year's commitments Results impact targets and resources for next FY DA, AA SWER, OWPE, OFFE and OERR Office Directors 14 ------- OSWER Directive 9200.3-01H-3 Regions that demonstrate success, and provide training and technical assistance to those Regions that are experiencing difficulties. e^AD/cTAt>c AT^TTTCTii>rt7XTTc A XT SCAP/STARS ADJUSTMENTS AND AMENDMENTS After targets have been finalized and funding levels developed, the SCAP process provides the flexibility to modify plans during the year. Modifications to planned targets are termed either adjustments or amendments. Amendments require HQ concurrence and approval. Adjustments do not require HQ approval, but may require HQ notification, Changes to STARS commitments should not be made simply because targets will not be met. However, in some cases, amendments to targets may be necessary and may be changed under the following conditions: Major, unforeseen contingencies arise that alter established priorities (i.e., Congressional action, natural disasters); Major contingencies arise to alter established Regional commitments (i.e., State legislative action); Measure or definition in system is creating an unanticipated negative impac , or Implementation of SACM pilot . r projects. OSWER and OE require that all STARS amendments be submitted to HQ by April 15 in order to meet the April 30 deadline for changing targets imposed by OPP. STARS amendments must be approved by the Assistant Administrator for the Office of Solid Waste and Emergency Response (AA SWER) or the AA OE. The Office of Program Management (OPM) and program offices in OERR, the CERCLA Enforcement Division (CED) in OWPE, and me ^ogram Operations Division (POD) in O^E pro£de input on STARS amendment approval decisions. THE FY 93 REGIONAL BUDGET In FY 93 there are insufficient resources for all ongoing activities plus the new activities the Regions planned to begin. As a result, resource decisions were made based on the FY 93 program priorities and consistent with the Integrated Priority Setting Matrix. Response Budget _ The 9J President's response budget contains $8% million for direct cleanuP activities, including RI/FS, RD, RA, RD/RA PRP oversight, removals, and laboratory support for response actions. $295.7 million is available to support other response actions, policy support, information management, laboratory anal is fof ^ assessment activities, the Technical Assistance Team (TAT), and the Alternative Remedial Contract Strategy (ARCS) and Emergency Response Cleanup Services (ERCS) contracts. Enforcement Budget ~, . L , , The current projected enforcement extramural budget for FY 93 is $58 million. The enforcement budget provides support for PRP searches, PRP removals, PRP RI/FS starts and oversight, response negotiations, referrals, litigation, judicial and administrative cost recovery actions, and project support activities. Mega-site funding requests will be fully funded in FY 15 ------- OSWER Directive 9200.3-01H-3 93. The remainder of the extramural budget will be allocated to the Regions based on the workload model. Federal Facilities Budget The Federal Facilities extramural budget for FY 93 is approximately $14 million. It covers oversight of all phases of response work (RI/FS through deletion) at Federally-owned sites, as well as negotiations for and implementation of Interagency Agreement (lAGs) and special Congressional requirements (i.e., base closures). Funding distribution will be based on Regional needs as requested through CERCLIS. The OFFE will plan, negotiate, monitor and distribute funds. OFFE plans to fully fund all basic SCAP commitments as agreed upon during final negotiations. It is highly likely that not all projects can be funded within the requested budget. Consequently, the highest priority should be given to base closure projects, projects that will address the highest risks at a site, and projects accelerating cleanups. ADVICE OF ALLOWANCE & FINANCIAL MANAGEMENT PROCEDURES The planned obligations identified through the SCAP process are the basis for the Advice of Allowance (AOA) approved by the Office of the Comptroller (OC) and AA SWER or the Deputy Assistant Administrator (DAA) in OFFE. Regional Allowances In FY 93, the OC will issue seven allowances to the Regions. They are: RA, which also includes funds for Operation and Maintenance (O&M), Long Term Response Action (LTRA), and five-year reviews. RAs are funded on a first ready/first funded basis. RD, which also includes RD/RA oversight funding; RI/FS; Removal Other response, which contains funds for site assessments and response program and project support, including ARCS program management, treatability studies, the Technical Assistance Grant (TAG) program, Core Program Cooperative Agreement (CPCA) funds, and pollution liability insurance; Enforcement; and Federal Facilities The following sections explain how these allowances are developed and the flexibility available in the AOA structure. The AOA Process The AOA identifies projected obligations for each quarter of the FY. The AOA for FY 93 is based on the final SCAP plans developed in the fourth quarter of FY 92. Funds available for obligation, however, are limited to projected needs for the upcoming quarter identified in CERCLIS. In the past, the AOA obligation rate through the first two quarters of the FY has been low. As a result, HQ has implemented the following measures to improve performance: Regions will not receive their third quarter AOA for a specific response category unless the commitment/ 16 ------- OSWER Directive 9200.3-01H-3 obligation rate is 50 percent or greater in that AOA category. If the commitment/obligation rate for one response allowance (e.g., RDs) is 35 percent while the rate for another (e.g., removals) is 65 percent, the third quarter removal AOA would be issued but the RD AOA would not be issued. Regions must obligate and task 60-65 percent of the enforcement Regional extramural funds received in their first and second quarter enforcement AOA in order to receive their third quarter AOA. If a Region does not receive its third quarter enforcement AOA due to such an obligation shortfall, it is required to produce a site specific spending plan in WasteLAN for both the third and fourth quarters by mid- May. For those Regions that continue to have a low rate of commitment/obligation/ tasking, OSWER or OE will renegotiate the Region's operating plan for the remainder of the year during June. This may result in a reduction in the Region's annual budget. OVERVIEW OF THE FTE DISTRIBUTION PROCESS Regional FTE allocations are made through the Hazardous Spill and Site Response Model, the Technical Enforcement Model and the Federal Facilities Superfund Workload Model. Resources for the site assessment, remedial and removal programs are contained in the Spill and Site Response Model. Enforcement resources are in the Technical Enforcement Model and resources for oversight of Federal Facilities Superfund activities are distributed by the Federal Facilities Workload Model. The Federal Facilities Workload Model is currently being revised. The workload models are designed to reflect priorities and policies contained in both the budget and planning processes. For the most part, the workload models are a straightforward applications of FTE pricing factors from the national budget to Region-specific SCAP/STARS targets and ongoing activities in the remedial pipeline. Regional FTE allocations usually occur in two stages. An initial allocation is made in April based on preliminary negotiated SCAP/STARS targets and schedules in CERCLIS. A final distribution is made in September. This distribution reflects the final SCAP and STARS targets negotiated in August as reflected in CERCLIS and any adjustments to the budget as a result of Congressional action. As noted earlier, in FY 93 each Region's response and enforcement Superfund FTEs will be frozen at the FY 90 levels. The Federal Facilities program received an increase in resources in FY 92. The FTE available in FY 93 will be the same as FY 92. While the freeze ensures that total Regional Superfund resources will not be affected, shifting of resources within the Region among the different program areas may occur. This includes shifts between the response and enforcement programs. All shifts will be based on the national budget and the Integrated Priority Setting Matrix. During negotiations of preliminary and final SCAP/STARS targets, Regions may propose changes to the targets to match the total Regional Superfund resource level. These proposals must be made in accordance with the Integrated Priority Setting Matrix. HQ will ensure that the 17 ------- OSWER Directive 9200.3-01H-3 cumulative Regional targets meet national budget commitments. It is anticipated that FY 94 workload models will be unfrozen, and FY 93 mid- year negotiations will be particularly important. At this time, the process for distributing resources (preliminary allocation in April, final in September) will be the same as in FY 90. Additional guidance will be issued, pending Agency decisions. 18 ------- OSWER Directive 9200.3-01H-3 MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS ------- OSWER Directive 9200.3-01H-3 MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS JULY QUARTER 4 (FISCAL YEAR (FY) 92) 6 Fourth quarter Advice of Allowance (AOA) approved by the Assistant Adminis- trator for the Office of Solid Waste and Emergency Response (AA SWER) and the Office of the Comptroller (OC) 8 Headquarters (HQ) pulls 3rd quarter accomplishments data from the Comprehen- sive Environmental Response, Compensation, and Liability Information System (CERCLIS) and provides for: 1) Entry into the Office of Pollution Prevention (OPP) Strategic Targeted Activi- ties for Results System (STARS); 2) Special program reports; and 3) Assistant Administrator (AA) report 13-17 Regions verify accomplishments data contained in the OPP STARS system (third quarter accomplishments) 15 HQ/Regions pull data from CERCLIS to support negotiation of: 1) Final Superfund Comprehensive Accomplishments Plan (SCAP)/STARS FY 93 targets; 2) First quarter FY 93 removals; and 3) Final FY 93 operating plan 17 OPP STARS system closes (third quarter accomplishments) 31 HQ distributes final FY 93 Superfund Program Implementation Manual for IMCs/ RPMs/OSCs AUG. 6-25 HQ/Regions conduct negotiations on final FY 93 SCAP/STARS targets and budget 7 HQ pulls accomplishments data from CERCLIS 31 HQ sends memorandum to Regions on final budgets, targets and measures SEPT. 4 Regions revise CERCLIS to reflect final budgets, targets and measures 8 HQ pulls data from CERCLIS for first quarter (FY 93) AOA 8 HQ pulls accomplishments data from CERCLIS 21 HQ makes final FY 93 Full Time Equivalent (FTE) distribution ------- OSWER Directive 9200.3-01 H-3 MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued) SEPT. (continued) 25 HQ submits FY 93 first quarter AOA request to the AA SWER and places it in CERHELP 29 HQ/Regional conference call on final Remedial Action (RA) appropriation 30 HQ distributes final FY 93 Superfund Program Management Manual for Branch/ Section/Unit Chiefs 30 HQ distributes final FY 93 Highlights: Superfund Program Management for Division Directors 30* Regions input AOA to the Integrated Financial Management System (IFMS) OCT. QUARTER 1 (FY 93) 5* First quarter AOA approved by the AA SWER and OC 7 HQ pulls fourth quarter FY 92 accomplishments data from CERCLIS and pro- vides for: 1) AA report; 2) Special Program reports; 3) End-of-year assessment for FY 92; and 4) Entry into OPP system for FY 92 STARS end-of-year accomplishments NOV. 6 HQ/Regions set FY 93 final targets, including open season changes in CERHELP 6 HQ pulls accomplishments data from CERCLIS 16-20 Regions verify accomplishment data contained in OPP STARS system (fourth quarter FY 92) 20 30 DEC. 1 OPP STARS system closes (fourth quarter FY 92) Regions complete evaluation of Remedial Investigation/Feasibility Study (RI/FS) start candidates HQ sends draft FY 94 Operating Guidance and STARS measures to Regions for review * Dependent on approval of final appropriation II ------- OSWER Directive 9200.3-01H-3 MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued) Dec. (continued) 7 HQ pulls CERCLIS data for: 1) Second quarter AOA; and 2) FY 94 Congressional Budget 18 31 JAN. 6 8 8 8 12 15 15 21-27 27 28-29 29 FEB. 5 HQ submits second quarter AOA request submitted to AA SWER and places it in CERHELP Regions input AOA to IFMS QUARTER 2 (FY 93) Second quarter AOA approved by the AA SWER and OC Regions submit list of non-Federal Facility proposed and final National Priorities List (NPL) sites that did not receive a removal investigation during calendar year 1992 HQ pulls SCAP data from CERCLIS and baseline FY 94 targets and measures are developed using SCAP Methodologies HQ pulls first quarter accomplishments data from CERCLIS and provides for: 1) Entry into OPP STARS system for first quarter review; 2) Special Program reports; and 3) AA report HQ performs a preliminary run of workload model based on methodologies HQ sends call memorandum containing schedules for semi-annual negotiations and baseline targets and measures to Regions Regional comments on FY 94 Operating Guidance due Regions verify accomplishments data contained in the OPP STARS system OPP STARS system closes HQ/Regional Program Management meeting (SCAP/Workload Model) Regions submit Fund mega-site Management Plans for FY 94 to the Hazardous Site Control Division (HSCD) HQ pulls accomplishments data from CERCLIS in ------- OSWER Directive 9200.3-01 H-3 MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued) FEB. (continued) 5 HQ/Regions pull data from CERCLIS to support negotiation of: 1) FY 93 RA schedules; 2) Preliminary SCAP/STARS FY 94 targets; 3) Preliminary FY 94 annual Regional budget; and 4) Budget projections for FY 95 projects 5 HQ pulls national Environmental Indicators (El) data from CERCLIS 18 HQ/Regions begin negotiation of: 1) FY 93 third and fourth quarter targets and budget; 2) FY 94 SCAP/STARS targets and annual Regional budget; and 3) Preliminary FY 95 outyear budget 19 HQ prepares El questions and answers to send to the Regions 26 HQ submits NPL proposed rule to the Office of Management and Budget (OMB) 19 HQ issues final FY 94 Operating Guidance HQ/Regions complete preliminary negotiations of FY 94 targets HQ pulls accomplishments data from CERCLIS HQ pulls data from CERCLIS for enforcement extramural mid-year evaluation and third-quarter AOA HQ distributes draft FY 94 Superfund Program Implementation Manual for Re- gional review HQ pulls data from CERCLIS for mid-year assessment HQ pulls CERCLIS data for third quarter AOA Regions revise CERCLIS to reflect negotiated FY 94 preliminary targets and measures HQ runs workload model for preliminary FY 94 FTE distribution HQ submits third quarter AOA request to the AA SWER and places it in CERHELP IV ------- OSWER Directive 9200.3-01H-3 MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued) March (continued) 30 HQ sends memorandum to Regions on preliminary targets and FTEs 31 Regions input AOA to IFMS 31 Regional response to HQ El questions and answers APRIL QUARTER 3 (FY 93) 1 HQ issues Addendum for FY 94 Operating Guidance 5 Third quarter AOA approved by the AA SWER and OC 6 Regional comments on FY 94 Superfund Program Implementation Manual due 7 HQ pulls accomplishments data from CERCLIS and provides for: 1) Entry into OPP system for second quarter review; 2) AA report; and 3) Special Program reports 12-16 Change Management Council Meeting 14 Regions submit current FY STARS amendment requests to HQ 20-26 Regions verify accomplishments data contained in OPP STARS system (second quarter accomplishments) 22 Regions submit data sheets on Remedial Design (RD) projects that will lead to a FY 94 RA start 26 OPP STARS system closes (second quarter accomplishments) 30 HQ distributes FY 92 El analysis to HQ/Regional managers MAY 7 HQ pulls accomplishments data from CERCLIS 7 HQ pulls SCAP planning data for outyear budget (FY 95) 15 All Regional NPL site fact sheets must be updated by the Regions in NPL-PAD 21 HQ distributes final FY 94 Superfund Program Implementation Manual 31 HQ submits NPL final rule to OMB ------- OSWER Directive 9200.3-01 H-3 MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued) JUNE 7 HQ pulls CERCLIS data for fourth quarter AOA 7 HQ pulls accomplishments data from CERCLIS 9 HQ distributes draft FY 94 Superfund Program Management Manual 11 HQ/Regions complete negotiations on FY 93 fourth quarter AOAs for RD/RA, removal, and enforcement 11 HQ sends call memorandum and FY 94 proposed Regional budget to the Regions for semi-annual negotiations 18 HQ submits fourth quarter AOA request to the AA SWER and places it in CERHELP 25 Regional comments on FY 94 Superfund Program Management Manual due 30 Regions submit enforcement mega-site management plans to the Office of Waste Programs Enforcement (OWPE) 30 Regions input AOA to IFMS JULY QUARTER 4 (FY 93) 6 Fourth quarter AOA approved by the AA SWER and OC 8 HQ pulls accomplishments data from CERCLIS and provides for: 1) Entry into OPP STARS; 2) Special Program reports; and 3) A A report 8 HQ/Regions pull data from CERCLIS to support negotiation of: 1) Final SCAP/STARS FY 94 targets; 2) First quarter FY 94 removals; and 3) Final FY 94 operating plan 9 HQ distributes final FY 94 Superfund Program Management Manual 22-27 Regions verify accomplishments data contained in OPP STARS system (third quarter accomplishments) 23 HQ distributes final FY 94 Superfund Program Management Highlights 27 OPP STARS system closes (third quarter accomplishments) VI ------- OSWER Directive 9200.3-01H-3 MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued) AUG. 6 HQ pulls accomplishments data from CERCLIS 9-20 HQ/Regions conduct negotiations on final FY 94 SCAP/STARS targets and budget HQ sends memorandum to Regions on final budgets, targets and measures HQ submits NPL proposed rule to OMB 31 31 SEPT. 8 Regions revise CERCLIS to reflect final budgets, targets and measures 8 HQ pulls data from CERCLIS for first quarter FY 94 AOA HQ pulls accomplishments data from CERCLIS HQ performs final FY 94 FTE distribution 8 20 24 HQ submits FY 94 first quarter AOA request to the AA SWER and places it in CERHELP HQ/Regions set FY 94 final targets, including open season changes in CERHELP OPP STARS system closes (fourth quarter FY 93) 30* Regions input AOA to IFMS OCT. QUARTER 1 (FY 94) 5* First quarter AOA approved by the AA SWER and OC 7 HQ pulls accomplishment data from CERCLIS and provides for: 1) Special Program reports; 2) AA report; 3) Entry into OPP system for FY 93 STARS end-of-year; and 4) FY 93 end-of-year assessment NOV. 5 HQ pulls accomplishment data from CERCLIS 18-24 Regions verify accomplishments data contained in OPP STARS system (fourth quarter FY 93) 24 * Dependent on approval of final appropriation VII ------- OSWER Directive 9200.3-01H-3 MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued) Nov. (continued) 24 Regions complete evaluation of FY 95 RI/FS start candidates 30 HQ submits NPL final rule to OMB HQ sends draft FY 95 Operating Guidance and STARS measures to Regions for review HQ pulls CERCLIS data for: 1) Second quarter AOA; and 2) FY 95 Congressional budget HQ pulls accomplishments data from CERCLIS HQ submits second quarter AOA request to AA SWER and places it in CERHELP Regions input AOA to IFMS vm ------- |