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
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Directive 9200.3-01 H-3
October 1992
HIGHLIGHTS:
Superfund Program Management
Fiscal Year 1993
U.S. Environmental Promotion Agency
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Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
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DISCLAIMER
The policies and procedures established in this document are intended
solely for the guidance of employees of the U.S. Environmental
Protection Agency. They are not intended and cannot be relied upon to
create any rights, substantive or procedural, enforceable by any party in
litigation with the United States. EPA reserves the right to act at
variance with these policies and procedures and to change them at any
time without public notice.
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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.
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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
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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
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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.
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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
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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;
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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.
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OSWER Directive 9200.3-01H-3
EXHIBIT 2 - SACM IMPLEMENTATION WITHIN THE
NATIONAL OIL AND HAZARDOUS SUBSTANCES
POLLUTION CONTINGENCY PLAN (NCP) FRAMEWORK.
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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.)
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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.
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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
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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
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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.
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OSWER Directive 9200.3-01H-3
EXHIBIT 4 - INTEGRATED TIMELINE
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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
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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
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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
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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
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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
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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
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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
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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
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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
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