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NUMBER:
TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
UORKPLAN
l.A
Removal Assessments at NPL Sites
Effective immediately, the Administrator will direct each
Regional office to do an environmental and public health
assessment at each NPL site. This assessment will look at
the environmental and public health impacts of each site,
and will be used to determine what action, including an
immediate removal action or enforcement action where viable
and liable responsible parties have been identified, must be
taken to render each site safe from immediate hazards to the
public health and the environment. (p. 1-10)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Send memo to Regions from Headquarters mandating removal
assessments - 7/89
- Assure that all NPL sites have been reviewed for presence
of immediate hazards
2. Complete NPL site assessments - 9/89
- Verify that no NPL site poses an immediate endangerment
to human health and the environment
3. Take immediate removal actions at all NPL sites where
assessments indicate need - 9/90
- Eliminate near-term threats to human health and environment
FINAL COMPLETION DATE: 9/90
-------
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
l.B
Address Worst Sites, Worst Problems First
After abating the immediate threat, EPA will initiate the
earliest remedial work to address those problems that
retain high priority when compared with competing
problems, (p. 1-10)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue procedures for ranking unplanned "quick" response
activities - 10/89
2. Issue final RA prioritization of FY 90 sites - 3/90
- Complete prioritization of previously unranked 4th quarter
constructions, and those projects in quarters 1-3 that have
slipped into 4th quarter
3. Issue final procedures for prioritization of FY 91 sites - 6/90
- Publish RA prioritization procedures to be used in FY 91
FINAL COMPLETION DATE: 6/90
-------
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
Five-Year Review of Sites
EPA will carefully monitor sites over the long-term to ensure
that the remedy at each site is fully protective of human health
and the environment. As part of our effort to monitor site
conditions, EPA will conduct a review of all sites at least
every five years after the initiation of the remedial action
where hazardous substances remain on site to ensure that human
health and the environment are being protected as required by
the statute. EPA will also maintain the effectiveness of the
remedy over the long-term by promptly correcting any additional
problems that may arise at sites where our monitoring indicates
that further response actions are necessary to protect human
health and the environment.
To assure the public that EPA is carefully monitoring and
maintaining each site, EPA will report annually the results of
all five year reviews that were conducted during the preceding
twelve month period. EPA will also modify Agency policy so that
no site, where hazardous substances remain, will be deleted from
the NPL until at least one five year review is conducted and the
review indicates that the remedy remains protective of human
health and the environment, (p. 1-11)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Determine the applicability of the policy on 5-year reviews to
deletions initiated prior to the policy - 10/89
- Options include suspending all pending del etions
2. Complete update of the Completion/Deletion Guidance - 12/89
- Modify April 1989 Directive to reflect new policy
3. Issue "short sheet" on 5-year reviews - 3/91
- Including processes, timing, and responsibilities
FINAL COMPLETION DATE: 3/91
-------
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TEXT:
FULL TEXT:
3.A, B, E
LEAD OFFICE:
Unilateral Administrative Orders(UAO) for Remedial
Design/Remedial Action (RD/RA)
EPA will increase its use of unilateral administrative orders,
particularly for remedial design and remedial action. Our
objective will be to either rapidly achieve enforceable
agreements by PRPs to carry out cleanups or, where such
agreements are not reached, to order PRPs to carry out cleanups
at every NPL site where responsible parties can be found. EPA
will routinely issue orders to PRPs who are legally liable and
financially viable if settlement is not reached after com-
pletion of negotiations. Orders will therefore be routinely
issued before a case is referred to the Department of Justice
for judicial action, or before the Fund is used for remedial
design or construction, (p. 2-6) Before Fund-financed
response can proceed at a site, a Region must issue an
administrative order, or provide a justification for its
decision not to issue an order. If PRPs do not comply with the
order, the Regions should have the flexibility to determine
whether to proceed with Fund-financed response or judicial
enforcement action to compel compliance and exact penalties.
Regions will consult with Headguarters where PRPs do not comply
with an administrative order, (p. 2-8)
OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue Strategy for FY 89 - 6/90
- Create standard national procedures
2. Negotiate targets for FY 90 - 8/89
- Set aggressive goals
3. Issue Strategy for FY 90 - 1/90
- Improve procedures based on late 1989, early 1990
experience
4. Issue Guidance on Unilateral Administrative Orders for Remedial
Design/Remedial Action - 2/90
- Create standard national policy & procedure
5. Issue Model UAO for RD/RA - 2/90
- Assure consistent approaches
6. Complete Training for Regional Staff - 5/90
- Establish shared, case-study expertise
-------
7. Implement Automated Reporting Systems - 1/90
- Create standard presentation of data
FINAL COMPLETION DATE: 5/90
-------
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 3.C
TITLE: Prompt Enforcement Against Calcitrants
FULL TEXT: Where the government has reached a partial settlement with
cooperating PRPs, it will take prompt enforcement action against
viable and liable recalcitrants who have not participated in
settlements. This action may be an administrative order under
section 106, judicial action when section 106, or an action under
section 107 to recover costs incurred by the government. Such
action should.generally be commenced within 90 days of entering
the consent decree before the court, (p. 2-6)
LEAD OFFICE: OECM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue a Strategy and Guidance for Pursuing Non-Settlors - 6/90
- Will include establishing a non-settlor tracking system
2. Issue Guidance on Bringing and Settling Enforcement Claims Against
Administrative Order (AO) Violators - 7/90
- Covers how to develop and resolve cases for civil penalties or
treble damages for violating administrative orders
3. Establish AO/Consent Decree Compliance Tracking System - 1/90
4. Develop a Strategy for Special Litigation Support for CERCLA section
106 Actions - 6/90
- Includes a plan for mobilizing EPA enforcement resources to support
cases with intensive discovery or trial preparation demands
5. Implement a Nationally Sponsored Training Program for EPA Superfund
Attorneys - 11/90
- Will help develop EPA capabilities to pursue Superfund enforcement
more effectively in support of this recommendation and others
and will be designed in coordination with analogous programs for
EPA's technical personnel
FINAL COMPLETION DATE: 11/90
-------
SUPERFUNO MANAGEMENT REVIEW
WORKPLAN
NUMBER: 3.D
TITLE: Settlement Incentives/Disincentives
FULL TEXT: In both the structure of the settlement terms and in its pursuit
of enforcement, the government will clearly establish incentives
to encourage those PRPs who are willing to assume responsibilities
and disincentives for those who are not. (p. 2-6)
LEAD OFFICE: OECM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue a Strategy and Guidance for Pursuing Non-Settlors - 6/90
- Include establishing a non-settlor tracking system
2. Issue Guidance on Bringing and Settling Enforcement Claims against
Administrative Order Violators - 7/90
- Cover how to develop and resolve cases for civil penalties or
treble damages for violating administrative orders
3. Develop a Strategy for Special Litigation Support for CERCLA section
106 Actions - 6/90
- Include a plan for mobilizing EPA enforcement resources to support
cases with important discovery or trial preparation demands
4. Deliver Training on De Minimis to all Regions - 9/90
5. Dedicate Funds to Support Mixed Funding - 2/90
6. Establish Special Accounts within the Trust Fund - 12/89
7. Establish Incentives in the Resource Distribution System - 3/90
8. Establish Goals for Use of mixed Funding and De Minimis
Authorities - 3/90
9. Issue Model Consent Decree for Remedial Response - 12/89
- Provide standard consent decree language to promote strong
settlement terms and consistent Agency action
FINAL COMPLETION DATE: 9/90
-------
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 3.E
SEE RECOMMENDATION: 3.A
-------
NUMBER:
TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
4.A
Settlement Tools - Provide Training
EPA will take the following steps to encourage the use of the
settlement tools in the Superfund statute without comprising
environmental goals:
First, Headquarters will provide additional assistance
specialized training in the use of these authorities.
assistance should emphasize information transfer among
Regions based on their actual experiences in using or
attempting to use these tools, (p. 2-12)
OWPE
and
The
the
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Deliver training on de minimis and mixed funding to all
Regions - 9/90
- Increase Regional skill and create case-based information
sharing.
FINAL COMPLETION DATE: 9/90
-------
NUMBER:
TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
4.B
Settlement Tools - incentive Systems for Regions To Use Tools
EPA will take the following steps to encourage the use of the
settlement tools in the superfund statute without compromising
environmental goals:
Second, EPA will develop an incentive system that provides
additional support for Regions to use these settlement tools.
For example, when a Region indicates that a de minimis
settlement is appropriate, additional support in FTE and
contract dollars might be provided. Specific amounts could be
based on past experience and workload model data. (p. 2-12)
OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Establish a funding reserve to support mixed funding - 12/89
- Relieve financial constraints on use of settlement tools
2. Establish incentives in the resources distribution system - 5/90
- Encourage careful planning for de minimis by providing additional
resource
FINAL COMPLETION DATE: 5/90
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4.C
LEAD OFFICE:
Settlement Tools - Goals for de minimis and Mixed Funding
EPA will take the following steps to encourage the use of the
settlement tools in the Superfund statute without compromising
environmental goals: ...
Third, EPA will establish specific goals for the use of de
minimis and mixed funding authorities. EPA should
determine if it is possible to set up special accounts in
the Regions to cover anticipated mixed needs and to allow
the Regions to retain de minimis cash-out dollars for the
site in which the settlement is reached, (p. 2-12)
OWPE
IMPLEMENTATION PRODOUTS AND DUE DATES:
1. Include goals in target setting and accountability systems for
FY 91 - 3/90
- Establish realistic national expectations for de minimis and mixed
funding settlements
2. Change Regional Review criteria - 3/90
- Incorporate settlement goals in general management review
priorities
3. Clarify the option for use of "special accounts" within the Trust
Fund for receipt of Responsible Party cashouts - 12/89
FINAL COMPLETION DATE: 3/90
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WORKPLAN
NUMBER: 4.0
TITLE: Settlement Tools
FULL TEXT: EPA will establish an integrated enforcement and response
program. EPA will encourage or compel PRPs to conduct the
response action at all sites with viable PRPs before using the
Fund, except in emergencies, (p. 2-14)
LEAD OFFICE: OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Increase level of Regional resources for Responsible Party Removal
Initiation and Oversight - 10/89
- Create Regional capability to negotiate and oversee Responsible
Party removals
FINAL COMPLETION DATE: 10/89
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WORKPLAN
5, 15
Integrated Fund and Response Program
EPA will establish a single integrated timeline for both
enforcement and Fund-financed activities. The timeline will
include deadlines for completing negotiations and following up
with enforcement or response action. The timeline will also
reflect program goals for completing phases of the response
action, and serve as a benchmark for assessing progress at
sites. This timeline will also be the basis of the case
management planning process, (p. 2-15)
EPA, in consultation with the Department of Justice, will
establish a single timeline for the Superfund remedial program
that sets out expected time frames and results for each of the
critical stages of the enforcement and remedial process.
(p. 2-30)
OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Establish Pre-referral Negotiations Procedures - 12/89
- Establish coherent, coordinated procedures for timely agreement on
Responsible Party Settlements
2. Complete the Overall Remedial Action Timeline - 11/89
- Create consistent national understanding about critical decision
points and timing of management planning to ensure appropriate
action at those points.
3. Complete the detailed explanations of the timeline - 5/90
FINAL COMPLETION DATE: 5/90
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WORKPLAN
6.A
Skill Mix
EPA must ensure a proper skill mix for case management and
support of enforcement actions. EPA will encourage the
creation of specialized Regional units for enforcement support
activities, such as searching for responsible parties,
assessing their ability to pay and corporate relationships,
coordinating information exchange among PRPs, supporting
cost recovery efforts, and developing administrative records.
(p. 2-16)
OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue models of skill mixes for different types of sites - 6/90
- Create flexible, informed basis for resource use
2. Complete analysis of appropriate resource levels - 10/89
- Assure proper
distribution
skill mix "pricing" for Budget planning and resource
FINAL COMPLETION DATE: 6/90
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6.B
Regional Superfund Enforcement Support Units
EPA will encourage the creation of specialized Regional units
for enforcement support activities, such as searching for
responsible parties, assessing their ability to pay and
corporate relationships, coordinating information exchange
among PRPs, supporting cost recovery efforts, and
developing administrative records, (p. 2-16)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Identify specific administrative actions needed to strengthen
Regional enforcement support - 8/90
2. Document management decisions - 9/90
FINAL COMPLETION DATE: 9/90
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NUMBER:
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FULL TEXT:
Enforcement of Information Requests
EPA will develop specific goals and timelines to improve
enforcement of information requests. The Agency will provide
for use of administrative orders and judicial referrals to compel
answers to information requests, and to secure civil penalties
or criminal sanctions where appropriate. The Agency will also
provide for increased use of its administrative subpoena authority
under Section 122(e)(3)(B). (p. 2-18)
LEAD OFFICE: OECM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue National Call for Enforcement to Regions - 9/89
- Emphasize national interest in demonstrating EPA's ability and
willingness to enforce against violations of information requests
2. Issue Final Model Pleadings and Settlement Guidance - 5/90
- Encourage and aid Regional offices in initiating and completing
effective enforcement cases against parties not complying
with information requests
3. Implement Strategy for Tracking Non-Respondents to Information
Requests - 1/90
FINAL COMPLETION DATE: 5/90
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WORKPLAN
NUMBER: 8
TITLE: Information Release to Potentially Responsible Parties (PRP)
FULL TEXT: EPA will prepare a directive that emphasizes the importance of
releasing available information as soon as possible to facili-
tate settlements. Improvements will reguire guidance, enhanced
data bases, and additional resources, (p. 2-19)
LEAD OFFICE: OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue directive to Regions - 10/89
- Establish importance of consistent national approach
2. Specify procedures for suggested approaches - 6/90
- Clarify issues relating to releasability, timing, and Regional
recordkeeping
FINAL COMPLETION DATES: 6/90
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NUMBER:
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LEAD OFFICE:
Oversight of Private Party Remedial Investigation/Feasibility
Studies(RI/FS)
The Agency will expand efforts to promote closer oversight of
private party RI/FS, recognizing that the level of oversight
will vary depending on the PRP's experience and willingness to
assume accountability for their actions. Specific steps should
include reducing the workload of RPMs who oversee these
studies. The report of the task group on Community Relations
has further recommendations concerning citizen involvement in
response actions conducted by responsible parties, (p. 2-21)
OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Correct pricing and distribute resources to Regions - 10/89
- Assure proper level of resources devoted to oversight
2. Complete RI/FS Evaluation - 3/90
- Provide analytical basis for strengthening support to oversight
3. Issue Model Statement of Work - 6/90
- Provide labor saving tool for Regional Staff
4. Issue Model Administrative Order - 1/90
- Provide labor saving nationally consistent tool for Regional Staff
5. Complete RI/FS Oversight Manual - 6/90
- Provide standard protocols
6. Evaluate Responsible Party conduct of risk assessments - 9/90
- Provide basis for strengthening guality and public confidence
FINAL COMPLETION DATE: 9/90
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HORKPLAN
10, 43.D
Flexible Funding Policy
EPA should maximize Regional flexibility in shifting funds
among sites, consistent with Congressional constraints and
notification requirements. Fund scarcity is a recognized
limitation on Regional flexibility. If additional
resources become available because of a settlement,
Regions should have the opportunity to apply these
resources to other high priority sites within that
Region. To the extent practicable, the Regions should
also be able to move resources among categories of
activities, such as remedial design and PRP oversight, as
long as accountability commitments and notification
requirements are met.... Regions should have a
discretionary fund that they could use to fund additional
work necessary to respond to citizen concerns.
(p. 2-22, 5-7)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1.
2.
Issue FY 90 Flexible Funding Policy document - 11/89
- OSWER directive to Regions
Issue FY 91 Flexible Funding Policy document - 6/90
- Incorporate into FY 91 Program Management (SCAP) Manual
FINAL COMPLETION DATE: 6/90
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WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
11
LEAD OFFICE:
Cost Documentation
EPA will strengthen methods for identifying and documenting
costs. To support cost recovery efforts, EPA will initiate
rulemaking to identify the types of expenditures appropri-
ate for cost recovery, documents sufficient to prove government
costs, and documents to be made available to PRPs, among other
purposes, (p. 2-25)
OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete draft rulemaking package - 2/90
- Provide comprehensive articulation of the Agency position on
identifying and documenting appropriate costs
2. Begin OMB review - 5/90
3. Issue proposed rule - 7/90
- Provide public forum for resolution of concerns
4. Issue final rule - 7/91
FINAL COMPLETION DATE: 7/91
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NORKPLAN
NUMBER: 12
TITLE: Cost Recovery Goals
FULL TEXT: EPA should immediately undertake a study to identify ambitious
and realistic goals for the cost recovery program, and
communicate them to Congress and the public, (p. 2-26)
LEAD OFFICE: OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete analysis of cost recovery "universe" and establish
goals - 2/90
2. Revise database and reports - 6/90
- To reflect study recommendations
3. Complete Communications Strategy - 4/90
- Establish understandable, commonly held measures of program
performance
4. Issue Revenue Projection Model - 6/90
- Provide stronger analytical basis for projecting cost recovery
performance
FINAL COMPLETION DATE: 6/90
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NUMBER:
TITLE:
FULL TEXT:
13
LEAD OFFICE:
Removal Cost Recovery
EPA will develop an improved approach for recovery of costs for
removal actions. This approach will include a standard
Alternative Dispute Resolution (ADR) opportunity, a real
threat of litigation against recalcitrant parties, and
increased efforts to have PRPs conduct future removal actions,
to reduce the need for subseguent cost recovery actions by
the government, (p. 2-27)
OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Implement Arbitration Procedures for Small Superfund Cost Recovery
Claims final rulemaking - 3/90
- Establish basis for use of ADR
2. Complete Alternative Dispute Resolution Strategy - 4/90
3. Correct pricing factors for Regional resources to improve timeliness
and quality of responsible party search - 10/90
- Establish appropriate resource allocation for removal actions
FINAL COMPLETION DATE: 10/90
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WORKPLAN
14
Top-Level EPA/DOJ Conference
EPA and the Department of Justice should convene a top-level
conference to ensure a consensus on goals for the program and
procedures for addressing Superfund settlement and litigation
issues. Issues that may be addressed include methods for
assuring national consistency, and the management process for
cost recovery, (p. 2-30)
OECM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Conduct top-level conference - 11/89
FINAL COMPLETION DATE: 11/89
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WORKPLAN
NUMBER: 15
SEE RECOMMENDATION: 5
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NORKPLAN
16
Case/Site Management Planning
Case Management Planning: Each Region will institute a case or
site management planning process that will include provisions
for coordination among the different offices and organizations
at critical stages in the enforcement process Regions
will have flexibility in establishing the level of detail of
their own planning process, (p. 2-30)
OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Deliver Model Site Management Plan Materials to Regions - 6/90
2. Deliver Regional training and incorporate site management plans
into Superfund Academy to ensure implementation of planning
procedures - 6/90
FINAL COMPLETION DATE: 6/90
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WORKPLAN
17.A
Organization and Functions of Headquarters Superfund
Enforcement Program
This study should address, among other things, the questions of
relationships between the Office of Waste Programs Enforcement
(OWPE) and the Office of Enforcement and Compliance Monitoring
(OECM); ... and questions of overlapping responsibilities
among OECM, the Office of General Counsel, Regional Counsel,
and the Department of Justice, (p. 2-31)
OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Present Organizational Conclusions - 6/90
-Identify overlapping responsibilities and options for restructuring
2. Document decisions by senior management - 7/90
FINAL COMPLETION DATE: 7/90
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HORKPLAN
NUMBER: 17.B
TITLE: Consolidation of OWPE and OERR Budget Functions
FULL TEXT: EPA will undertake a formal study of the organization of the
Super-fund enforcement program to evaluate whether a reorgan-
ization among Headquarters offices is appropriate. This study
should address, among other things,...suggestions that the
planning and budget functions of OWPE and OERR be
consolidated;... (p. 2-31)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Decide organizational placement of Superfund budget function -
5/90
- Base decision on pros and cons of various organizational options
FINAL COMPLETION DATE: 5/90
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WORKPLAN
NUMBER: 17.C
TITLE: Superfund Enforcement Delegations of Authority
FULL TEXT: EPA should assess implementation of existing delegations of
authority to the Regional offices, (p. 2-31)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete analysis of enforcement delegations of authority - 6/90
- Identify overlapping responsibilities and recommended changes to
existing delegations
2. Document management decisions - 7/90
FINAL COMPLETION DATE: 7/90
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WORKPLAN
NUMBER: 17.D
TITLE: Referrals to DOJ
FULL TEXT: Study organization of enforcement program to evaluate the need
for reorganization at EPA Headquarters. Assess waivers of HQ
concurrence on referrals to DOJ. (p. 2-31)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue summary report on current waiver policy - 10/89
- Review and describe current authorities, criteria, and
procedures for waivers
2. Issue evaluation report on waiver issues - 2/90
- Present advantages and disadvantages of existing waiver
policy
3. Submit recommendations for modifying waiver policy - 5/90
- Suggest mechanisms for improvements in current policy, if
necessary
4. Issue implementation plan - 6/90
- Initiate changes in waiver policy, if necessary
FINAL COMPLETION DATE: 6/90
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WORKPLAN
NUMBER: 18.A
TITLE: Communication of Rapid Response Goals
FULL TEXT: The Administrator should... communicate and regularly
reinforce to Superfund managers and staff that the primary
mission of the program is to take responsible action at
sites as rapidly as possible, (p. 3-5)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue memorandum on rapid action - 9/89
- Assure that all Superfund personnel are aware of need to
respond to acute threats quickly and effectively
FINAL COMPLETION DATE: 9/89
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UORKPLAN
NUMBER: 18.B
TITLE: Accelerating and Improving Remedial Action
FULL TEXT: The Administrator should... communicate the same message to the
Attorney General and the heads of other Federal agencies
involved in the Superfund program and secure their personal
commitment to support EPA's Superfund mission, (p. 3-6)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Discuss at OECM/OSWER/DOJ Summit - 9/89
- Communicate the need for early action at sites
2. Modify Interagency Agreement with DOJ to incorporate program
emphasis - 9/89
3. Meet with ATSDR - 9/89
- Communicate program goals around health assessments at
Superfund sites
4. Incorporate program goals into joint EPA-State plan for
long-term State strategy - 10/89
5. Meet with NRT members - 10/89
- Communicate program goals to other Federal agencies involved
in Superfund program
6. Meet with DO I and with FWS - 11/89
- Communicate program goals around environmental evaluation at
Superfund sites
7. Send letter to State natural resource trustees - 11/89
- Communicate program goals and invite their participation in
environmental evaluations Superfund sites
8. Incorporate program goals in annual interagency budget process - 5/90
- Secure commitment from other Federal agencies
involved in the Superfund process
FINAL COMPLETION DATE: 5/90
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WORKPLAN
NUMBER: 19
TITLE: Manager Accountability
FULL TEXT: Hold EPA line managers accountable for managing the program in
accordance with its primary mission and track their performance
in so doing. For example, direct each Regional Administrator
to identify and eliminate avoidable delays in Superfund
decision-making in his office, (p. 3-6)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue EPA order directing that all EPA line managers whose
performance affects Superfund outputs have performance standards
which relate to those Superfund outputs - 10/89
- Establish requirement
2. Review FY 1990 Performance Agreements of EPA line managers whose
performance affects Superfund outputs to ensure that appropriate
standards have been developed relating to Superfund outputs - 2/90
- Ensure that baseline requirement is set
FINAL COMPLETION DATE: 2/90
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WORKPLAN
NUMBER: 20
TITLE: Reward Innovation, Risk-Taking, and Decisive Action
FULL TEXT: Direct the development of formal and informal mechanisms to
reward innovation, risk-taking and decisive action in the
Superfund program, (p. 3-6)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Determine Agency strategy - 12/89
- Ways and means to foster and reward innovation, risk-taking, and
decisive action
2. Incorporate mechanisms into Agency management systems - 4/90
- Communications, training, performance management, and awards
FINAL COMPLETION DATE: 4/90
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WORKPLAN
NUMBER: 21
TITLE: Reduce RPM Workload
FULL TEXT: EPA should take steps to reduce RPM's workloads. Possible
approaches include expanding the Superfund workforce,
modifying expected accomplishments, and providing RPMs with
additional administrative and technical support, (p. 3-13)
LEAD OFFICE: Region III
IMPLEMENTATION PRODUCTS AND DATES:
1. Issue 285 FTE to Regions to increase number of RPMs - 7/89
- Reduce number of sites for each RPM
2. Assign appropriate workload to RPMs - 10/89
3. Provide additional support to RPMs - 12/89
- Furnish technical and administrative assistance
4. Provide additional FTE to Regions or adjust expected
accomplishments - 4/90
- Permit appropriate workload assignment by Regions
FINAL COMPLETION DATE: 4/90
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UORKPLAN
NUMBER: 22
TITLE: Use of Expedited Cleanup Approaches
FULL TEXT: Encourage Regional Offices to take expedited approaches to
site cleanup whenever possible—for example, by using
removal contractors during the remedial phase, dividing
sites into operable units that facilitate fast action, and
encouraging PRPs to finance early remedial measures.
Headquarters should monitor the extent to which such
approaches are being used and quickly take steps to remove
any identified barriers to their use. (p. 3-13)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue guidance on using removal approaches to speed up remedial
projects - 7/89
- Inform Regions of procedures set in place to expedite
remedial actions
2. Issue directive on expedited cleanup of NPL sites - 11/89
- Assist Regions in making NPL sites safe and in accelerating
responses at NPL sites
3. Issue rapid remedial construction short sheet - 10/89
- Inform Regions of alternatives to conventional remedial
construction contracting procedures
4. Improve rapid remedial construction procedures as
necessary - 10/90
- Provide mechanisms to refine and evaluate performance of
construction procedures
FINAL COMPLETION DATE: 10/90
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HORKPLAN
NUMBER: 23
TITLE: Develop prototype RI/FS and remedy selection models.
FULL TEXT: Proceed as rapidly as possible with the development of proto-
type RI/FS and remedy-select ion models for recurring types of
sites already identified (municipal landfills, battery-cracking
sites and wood-treatment facilities) and ask Regional Offices
to identify other types of sites for which prototypes would be
useful . (p. 3-13)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue "short sheet" on status of efforts underway to develop
prototypes for different categories of sites. Request Regions
to identify other prototypes that would be useful - 11/89
- Assess scope of need for prototype documents
2. Complete guidance and "short sheet" for addressing PCB sites - 3/90
- Standardize PCB requirements at NPL sites
3. Complete prototype RI/FS for municipal landfills - 7/90
- Includes "short sheet" summary and standard plans (e.g., workplan
and QAPP)
4. Complete prototype RI/FS for wood treatment facilities in
conjunction with ORD - 9/90
- May be reprioritized based on Regional input
- Includes "short sheet" summary
FINAL COMPLETION DATE: 9/90
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WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
24
Quickly narrow remedial alternatives
Emphasize to Superfund staff and managers and to remedial
contractors the existing policy that the number of remedial
alternatives considered during the RI/FS should be narrowed as
quickly as possible to those with clear potential applicability
to the site. (p. 3-14)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue RI/FS "short sheets" that reflect concept - 10/89
- Covers Scoping and Development of Alternatives
2. Issue ROD Update - 11/89
- Show how to streamline projects
3. Issue NCP reflecting concept in preamble - 2/90
- Establishes policy framework
FINAL COMPLETION DATE: 2/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
25.A, B, C, F, 33
Consistency in Remedy Selection and Use of Treatment
Technologies
Provide real-time feedback on proposed remedy-selection
decisions by ensuring that Regional Coordinators have time to
review drafts of Proposed Plans—which identify the remedial
alternative likely to be chosen for a Superfund site—and
Records of Decision. Examine remedy-selection decisions from a
national perspective by conducting regular reviews to identify
any trends that run counter to statutory requirements or EPA's
expectations and by clearly communicating the results of these
reviews to EPA's Regional Administrators. Ensure that Regional
Offices have information on previous remedy-selection decisions
by keeping the Record of Decision database updated; ensure that
all RPMs are trained to use it and have access to it. Ensure
that RPMs check the Record of Decision database before making
any recommendations on remedy selection. OERR should work with
the Regions to provide national consistency on procedures for
selection of treatment technologies, (p. 3-19, 4-6)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue directive on use of ROD data base - 11/89
- Promote consistency among Regions
2. Load FY89 RODS into ROD data base - 1/90
- Maintain quality and utility of system
3. Conduct quality analysis of FY89 RODs - 3/90
- Improve consistency of RODs
4. Develop framework for HQ quality assurance program - 5/90
- Provide procedures and criteria for quality reviews of RODs and
other important deliverabies
5. Provide feedback to Regions on ROD analysis - 6/90
- ROD Forums to assist Regions with quality
6. Complete review of selected Proposed Plans and RODs - 9/90
- Regional Coordinator support to RPMs
FINAL COMPLETION DATE: 9/90
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WORKPLAN
NUMBER: 25.D
TITLE: ROD Database Training
FULL TEXT: Ensure that the Regional Offices have information on previous
remedy-selection decisions ...; ensure that all RPMs are
trained to use it and have access to it. (p. 3-19)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete delivery of training - 12/90
- Use revised ROD workshop to deliver training
FINAL COMPLETION DATE: 12/90
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WORKPLAN
NUMBER: 25.E
TITLE: Peer Review
FULL TEXT: Within those Regional Offices that have not done so, establish
peer review processes for drafts of Proposed Plans and draft
Records of Decision, (p. 3-20)
LEAD OFFICE: Region II
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Prepare matrix of peer review activities used by Regional Offices
for review - 10/89
- Evaluate activities used by Regional Offices and prepare a
listing of recommended activities for national guidance
2. Prepare initial draft of Recommended Peer Review Guidance for
review - 1/90
3. Complete final draft of Recommended Peer Review Guidance - 2/90
- Incorporate comments in guidance or addendum to guidance
4. Final Recommended Peer Review Guidance approved by Assistant
Administrator for Solid Waste and Emergency Response - 6/90
FINAL COMPLETION DATE: 6/90
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WORKPLAN
NUMBER: 25.F
SEE RECOMMENDATION: 25.A
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HORKPLAN
NUMBER: 26
TITLE: Clarification of ARARs Policy
FULL TEXT: Resolve all outstanding questions about the applicability
or relevance and appropriateness of Federal Standards and
regulations, especially those promulgated under the
Resource Conservation and Recovery Act. (p. 3-20)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Distribute ARARs Q's & A's on selected issues - 5/89
2. Distribute short sheets on RCRA land ban issues - 7/89
3. Send memo to Regions requesting most pressing issues that have
not been resolved by the final NCP - 8/89
4. Set priorities for issue resolution based on Regional
needs - 10/89
5. Begin issuing guidance on priority issues identified by
Regional solicitation - 12/89
6. Resolve remaining issues - 6/90
FINAL COMPLETION DATE: 6/90
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HORKPLAN
NUMBER: 27.A
TITLE: Upgrade Regional Coordinators
FULL TEXT: To increase the retention of Regional Coordinators and to
improve the quality of the services they provide, upgrade
these positions,... (p. 3-22)
LEAD OFFICE: OPNT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Reclassify appropriate Regional Coordinator positions - 2/90
- Increase the grade structure for selected Regional Coordinators
FINAL COMPLETION DATE: 2/90
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LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
27.B, E
Role and Effectiveness of Regional Coordinators (RCs)
To strengthen the role and effectiveness of Regional
Coordinators...assign experienced staff to them, and
assure that Regional Coordinators have sufficient time
to be responsive to requests from the Regional Offices.
Publicize within EPA the existence and role of Regional
Coordinators and aggressively encourage RPMs to call on
Regional Coordinators for assistance, (p. 3-22)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Evaluate Regional needs based on OPPE study and OERR briefing - 8/89
- Define role and priorities of Regional Coordinators for FY 90
2. Develop plan to provide effective Regional Coordination and
communicate plan to Regions - 11/89
FINAL COMPLETION DATE: 11/89
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SUPERFUND NANAGENEMT REVIEW
HORKPLAN
NUMBER: 27. C
TITLE: Answering Technical and Legal Questions
FULL TEXT: Direct technical and procedural questions relating to the
planning and conduct of remedial activities to Regional
Coordinators in the Office of Emergency and Remedial Response
and legal and enforcement questions to Regional Coordinators in
the Office of Waste Programs Enforcement, (p. 3-22)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue guidance on the roles and functions of Regional Coordinators
in each office - 12/89
FINAL COMPLETION DATE: 12/89
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FULL TEXT:
SUPERFUND MANAGEMENT REVIEW
HORKPLAN
27.D
Consolidate Regional Coordinators
Consider an eventual merger of the two groups of Regional
Coordinators at EPA Headquarters, (p. 3-22)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Decide organizational placement of Regional Coordinators - 3/90
- Base decision on pros and cons of various organizational options
FINAL COMPLETION DATE: 3/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 27.E
SEE RECOMMENDATION: 27.B
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 28.A
TITLE: Technical Support Services Directory
FULL TEXT: Prepare and publish a directory of technical support services,
update it frequently, and ensure that every Remedial Project
Manager promptly receives the initial and all updated editions.
(p. 3-34)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Publish directory of technical support services - 1/90
- Pull together existing information into one document
2. Provide directory to every Remedial Project Manager - 2/90
- Do individual mailings
3. Establish procedures for updating and redistributing
directory - 3/90
- Ensure frequent updates
FINAL COMPLETION DATE: 3/90
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TITLE:
FULL TEXT:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
28. B
Improving Information Management
Ensure that all RPMs know how to use automated databases
containing information relevant to their work and that they
have access to computers configured for data communication.
(p. 3-25)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Develop functional requirements for software to access EPA
databases - 1/90
- Develop software tools and training
2. Deliver software to RPMs - 6/90
- OSWER delivers software tools to access EPA databases
3. Complete training of RPMs - 9/90
- Implement training on use of software tools
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 29.A
TITLE: Technical Support Services Group
FULL TEXT: Designate an existing group, or establish a new one, to be
responsible for EPA-wide management of technical support
services to RPMs. (p. 3-25)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Convene Technical Support Services Group - 10/89
- Find or create group representing all affected offices
FINAL COMPLETION DATE: 10/89
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SUPERFUND MANAGEMEHT REVIEW
WORKPLAN
NUMBER: 29.B
TITLE: Technical Support Master Plan
FULL TEXT: Direct this group to develop and implement a master plan for
assessing and meeting RPMs' needs for technical support.
(p. 3-25)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Approve charter of the Technical Support Services Group - 10/89
- Charter includes direction from Administrator to develop and
implement Master Plan
FINAL COMPLETION DATE: 10/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 30, E.I
TITLE: State Role in Superfund
FULL TEXT: EPA should begin now to resolve the fundamental policy question
of what States' long-term role in the Superfund program will
be. Based on that policy decision, EPA and States should
jointly develop short- and long-term strategies to enhance
State program capability, improve State performance at State-
lead Superfund sites, and foster State remedial activity at
sites not on EPA's National Priorities List. (p. 3-27)
EPA will convene a conference of key State and Federal
officials to examine the evolving State/Federal relationship
and to make further recommendations to the Administrator on
this issue. EPA will also work with the States to develop a
plan for State participation in the Superfund enforcement
program.
LEAD OFFICE: OSWER
IMPLEMENTATION PRODUCTS AND DUE DATES;
1. Convene organizational meeting with State representatives from
ASTSWMO, NAAG, and NGA to set framework for further policy forums
and working level group meetings between EPA and States - 8/89
2. Establish formally an EPA-State senior level policy group
with a schedule of five or six meetings - 10/89
FINAL COMPLETION DATE: 10/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 31.A
TITLE: Short Sheet Development
FULL TEXT: Continue to develop and issue "short sheets" that
summarize existing guidance, ask the Regional Offices to
suggest candidates for additional "short sheets", and
issue new guidance first as "short sheets" and later, as
necessary, as longer reference documents, (p. 3-29)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue list and schedule of "short sheets" - 3/90
- Identify responsible office and planned schedule
FINAL COMPLETION DATE: 3/90
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SUPERFUND MANAGEMEMT REVIEW
HORKPLAN
NUMBER: 31.B
TITLE: Guidance Conflict Official
FULL TEXT: Designate in each office a single official to take
responsibility for overseeing the planning and development of
all technical and policy guidance and ensuring that guidance
issued by the various offices does not conflict, (p. 3-29)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Name official in each office - 10/89
- Require each office to name official immediately
2. Issue directive on coordinating all technical and policy
guidance - 12/90
- Delineate functions and responsibilities of officials
FINAL COMPLETION DATE: 12/90
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SUPERFUND MANAGEMENT REVIEW
HORKPLAN
NUMBER: 31.C
TITLE: Program Guidance Updates
FULL TEXT: Establish procedures to ensure that guidance Is prepared and
updated In a timely fashion and systematically distributed to
all Superfund managers and staff In the Regional Offices.
(p. 3-29)
LEAD OFFICE: OPHT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue directive on updating and distributing program
guidance - 5/90
- Ensure timely updating and systematic distribution
FINAL COMPLETION DATE: 5/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 31.D
TITLE: Prescriptive and Advisory Guidance
FULL TEXT: Explain how Regional Offices and other interested parties can
distinguish between prescriptive and advisory elements of
Superfund guidance, (p. 3-29)
LEAD OFFICE: OECM/OGC
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue "Do's and Don'ts" Checklist for drafting and interpreting
guidance - 4/90
2. Develop training module on subject; include in Superfund Academy
and Superfund Attorney Training Institute training curricula - 9/90
FINAL COMPLETION DATE: 9/90
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TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
UORKPLAN
32 .A, 35
Treatment Technology and Cost Recovery
Superfund policies and guidance should be reviewed and revised
to ensure that use of treatment technologies is given stronger
emphasis in accordance with SARA's directions. Guidance should
emphasize the use of treatment technologies in early actions to
mitigate significant threats at sites, as well as in later
actions to fully clean up the sites.
EPA should develop guidance that balances the goal of advancing
innovative technologies against the need to minimize challenges
during cost recovery actions, (p. 4-9)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue policy statement that innovative technology costs are
recoverable (OWPE lead) - 11/89
- Eliminates barrier to use of innovative technologies
2. Issue selection of remedy guidance to convey program expectations
regarding the use of treatment technologies - 4/90
- Clarify appropriate use of treatment
FINAL COMPLETION DATE: 4/90
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TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
32. B
Technologies Czar
A senior program manager in the Office of Solid Waste and
Emergency Response should serve as "Technologies Czar" and
should be responsible for working with other offices to develop
and implement actions necessary to remover barriers to use of
treatment technologies, (p. 4-6)
OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Select "Technologies Czar" - 11/89
- Identify senior program manager
FINAL COMPLETION DATE: 11/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 33
SEE RECOMMENDATION: 25.A
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
34
LEAD OFFICE:
Regulatory and Policy Barriers to the Use of Treatment
Technologies
The impact of RCRA land ban or other rules on use of alter-
native technologies should be carefully evaluated to identify
technologies that may be precluded by the rules. The Office of
Emergency and Remedial Response and Office of Solid Waste must
jointly explore ways to apply these rules that preserve their
intent and spirit without restricting use of viable treatment
approaches for Superfund sites, (p. 4-9)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue "short sheets" on Land Disposal Restrictions - 7/89
- Show how to comply with Land Disposal Restrictions
2. Provide Support to OSW to issue supplemental notice to NCP soliciting
comment on alternative interpretations of "placement" for
contaminated media - 9/89
- Promote use of effective treatment and innovative technologies to
remediate sites
3. Summarize treatability data that indicates which technologies cannot
consistently achieve BOAT for contaminated soil, debris, and sludges
- 11/89
- Assess effectiveness of non-BDAT technologies
4. Issue interim final guidance on Superfund Compliance with Land
Disposal Restrictions - 11/89
- Show how to comply with Land Disposal Restrictions
5. Provide support to OSW to develop soil and debris regulation that
permits use of range of effective technologies - 9/91
- Promote use of effective treatment and innovative technologies to
remediate sites
FINAL COMPLETION DATE: 9/91
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 35
SEE RECOMMENDATION: 32.A
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 36.A
TITLE: Evaluate FAR Provisions
FULL TEXT: EPA should evaluate provisions of the FAR [Federal Acquisition
Regulation] to determine where latitude exists to eliminate
procurement constraints to utilizing treatment technologies.
(p. 4-10)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue report on procurement barriers to the use of new
technologies - 2/90
- Establish justification for regulatory changes
2. Transmit recommendations to the FAR Councils - 7/90
- Request regulatory changes
FINAL COMPLETION DATE: 7/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 36.B
TITLE: Procedures for Proprietary Treatment Technologies
FULL TEXT: Procedures should be developed to allow greater flexibility
in performing treatability studies and in how "proprietary"
technologies are defined for purposes of these [Federal
Acquisition] regulations, (p. 4-10)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Develop draft procedures - 3/90
- Identify potential mechanisms for making Superfund
technologies available
2. Issue final Agency procedures - 7/90
- Identify and make mechanisms known within the Agency
FINAL COMPLETION DATE: 7/90
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SUPERFUND MANAGEMENT REVIEW
UORKPLAN
NUMBER: 37.A
TITLE: Nationwide Technology Support Teams
FULL TEXT: EPA should establish nationwide technology support teams within
the Office of Research and Development, to provide on-site,
project-by-project technical advice to regional project
managers on treatment technologies, (p. 4-12)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Set up interim organization and begin assistance to the
Regions - 9/89
- Initial team in place
2. Complete discussions with all ten Regions on initial program and
future Technology Support Team Needs - 3/90
- Determine Regions' Technology Support Needs
3. Complete Staffing and Organization of Team - 9/90
- Team staffed'at allocated level and fully operational
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 37.B
TITLE: Specific Technologies
FULL TEXT: These (nationwide technology) support teams should work in
conjunction with regional coordinators in the Superfund program
office to identify specific technologies or combinations of
technologies to respond to generic site situations, (p. 4-12)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete selection of initial site classes - 12/89
- Generic sites with common technology responses
2. Issue Generic Site Technology Report - 12/90
- Technology summary for generic site class
FINAL COMPLETION DATE: 12/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 38.A
TITLE: Treatability Assistance Program
FULL TEXT: EPA should establish a treatability assistance program within
the Office of Research and Development to perform tests,
develop standard testing protocols, and maintain a data base of
test results. This program should work closely with the
Technology Czar and Regional Coordinators in the Office of
Solid Waste and Emergency Response, and with the regional
offices, (p. 4-14)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Set up interim organization and begin assistance - 9/89
- Initial Program in Place
2. Complete First Treatability Protocol - 3/90
- Proper Testing Procedures for Various Technologies
3. Complete Staffing/Organization of Program - 9/90
- Program staffed at allocated level and fully operational
4. Complete Requested FY 90 Treatability Tests - 9/90
- Tests requested by Regions to support technology selection
FINAL COMPLETION DATE: 9/90
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TITLE:
FULL TEXT:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
38.B
Guidance to Encourage Treatability Tests
The Office of Emergency and Remedial Response (OERR) should
provide policy guidance to the Regions to ensure that
treatability tests are emphasized, and should also provide
guidance on how to use treatability tests in selection of a
clean-up technology, (p. 4-14)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue "short sheet" on treatability studies - 12/89
- Emphasize importance of treatability studies and provide guidance
to facilitate performance of studies
FINAL COMPLETION DATE: 12/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
39.A
Information Clearinghouse on Evaluations of Technology
Performance
The Agency should establish an information clearinghouse,
within the Office of Research and Development (ORD) containing
data, reports and references from EPA, State and other
evaluations of technology performance. The clearinghouse
should include a computerized data base that allows access
through telephone inquiry, on-line computer access, and printed
material. (p. 4-16)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Set up Information Clearinghouse within ORD - 12/89
- Computerized clearinghouse fully operational
2. Complete Orientation Program to all EPA Regions and
States - 3/90
- Explain capability/use of clearinghouse
3. Complete On-Line Computer Access - 9/90
- Facilitate user access
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
UORKPLAN
NUMBER: 39.B
TITLE: Current Technology Transfer Efforts
FULL TEXT: ORD should continue, and expand as necessary, its current
technology-transfer activities of dissemination of technical
reports, technology forums, seminars and conferences and should
ensure that this transfer is effectively directed at Regional
Project Managers and their contractors, (p. 4-16)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete Workshops on Immobilization Technology - 2/90
- Series of ten workshops nationwide
2. Complete establishment of ORD Electronic Bulletin Board - 3/90
- Display the most recent ORD publications, project abstracts,
technical assistance centers, and other information sources
3. Complete Two Workshops on Physical/Chemical Treatment of Hazardous
Waste - 9/90
- Series of five technical workshops
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 40.A.I
TITLE: Evaluate Performance and Cost of Technologies
FULL TEXT: Evaluate performance and cost of technologies already being
used at Superfund sites, (p. 4-19)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Develop evaluation scope/protocol - 12/89
- To provide needed performance data
2. Identify sites/technologies to be evaluated - 3/90
3. Begin first evaluation - 9/90
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 40.A.2
TITLE: Demonstrations of Innovative Technologies
FULL TEXT: Conduct additional demonstration of innovative technologies,
(p. 4-19)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Initiate cooperative effort with DOE - 9/89
- Conduct SITE demonstration on radioactive waste
2. Hold forum with technology developers - 1/90
- Identify technologies of interest for expanded SITE solicitation,
3. Conduct joint EPA/DOE demonstration - 6/90
FINAL COMPLETION DATE: 6/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 40.A.3
TITLE: Emerging Laboratory and Pilot Scale Technologies
FULL TEXT: Support development of emerging laboratory and pilot scale
technologies, (p. 4-19)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Solicit proposals for new emerging technologies - 7/89
- Provide for funding an expanded number of technologies
2. Receive proposals for new emerging technologies - 9/89
3. Award cooperative agreements - 6/90
FINAL COMPLETION DATE: 6/90
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SUPERFUND MANAGEMENT REVIEW
NORKPLAN
NUMBER: 40.A.4
TITLE: Test and Evaluation Center
FULL TEXT: Establish a fully permitted and licensed test and evaluation
center, (p. 4-19)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Conduct public hearing on EIS - 2/90
- For Environmental Technology and Engineering Center to be located
at Edison, N.J.
2. Complete architectural plans and specifications - 5/90
- Final plans and specifications ready for bidding
3. Initiate construction of the facility - 9/90
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 40.A.5
TITLE: Combinations of Technologies
FULL TEXT: Evaluate combinations of technologies in addition to individual
technologies, (p. 4-19)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete revision of SITE solicitation notice - 12/89
- To emphasize combinations of technologies
2. Issue SITE solicitation - 1/90
- Including focus on combinations
3. Complete selection of technologies for demonstration - 9/90
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
NORKPLAN
NUMBER: 40.A.6
TITLE: Rapid Reporting of Demonstration Results
FULL TEXT: Provide rapid reporting of demonstration results through
performance bulletins and by placing results in an information
clearinghouse. Reduce production time for full reports.
(p. 4-19)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete review of information transfer process - 10/89
- To identify ways to speed reporting
2. Complete implementation of revised reporting system - 1/90
FINAL COMPLETION DATE: 1/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 40.A.7
TITLE: Elimination of Internal Barriers
FULL TEXT: Suggest ways to eliminate internal barriers to the introduction
of new technologies into the Superfund program, (p. 4-20)
LEAD OFFICE: ORO
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Meet with developers who have completed SITE demos - 1/90
- To identify internal constraints they have experienced
2. Identify changes to SITE - 6/90
- To facilitate demonstration and commercialization
FINAL COMPLETION DATE: 6/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
41
LEAD OFFICE:
In-House and University Research Programs
In-house and university research programs should be expanded in
a few, targeted areas where private research is lacking. The
Office of Research and Development should convene an advisory
group of industry and academia to develop a priority list of
areas where expanded EPA research is needed and where the
private sector is not currently engaged. EPA should actively
conduct or support research in areas where there is limited
private sector involvement, (p. 4-21)
ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete selection of advisory group - 1/90
- To recommend areas of research
2. Issue advisory group report - 4/90
- List of priority targeted research areas
3. Complete modification of research plans - 7/90
- To focus on targeted areas of advisory group
FINAL COMPLETION DATE: 7/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
42
LEAD OFFICE:
National Environmental Technology Applications Corporation
(NETAC)
The Office of Research and Development has recently
established a partnership of government, industry, and
academia called the National Environmental Technology
Applications Cooperation that is dedicated to
commercialization of new technologies and products. It should
receive strong support and emphasis within the Agency to
ensure rapid, full implementation, (p. 4-22)
ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Establish High Level EPA Steering Committee - 9/89
- To advise and assist NETAC
2. Complete NETAC Model Commercialization Approach - 2/90
- For use by developers
3. Initiate Experimental Testing at NETAC - 6/90
- Complete modifications and installation of equipment
for initiation of testing
4. Complete Market Analysis - 9/90
- Identify types of environmental technologies needed
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 43 .A
TITLE: Increase Citizen Involvement
FULL TEXT: The Administrator should strongly support increased citizen
involvement in Superfund decisions, dedicating resources
necessary for greater citizen involvement and accepting
occasional delays as a result, (p. 5-7)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue letter to Regional Administrators on dedicating resources to
community relations - 10/89
- Stress resources needed to increase citizen involvement
2. Complete development of "short sheet" guidelines on planning for
sufficient community relations activities - 2/90
- Stress need to plan adequately and anticipate del ays
3. Issue "short sheet" on innovative methods to increase
involvement - 11/90
- Convene a workgroup to develop recommendations to be included in
short sheet
4. Fund Regional Office projects that describe general and site-specific
experiences - 3/90
- Assist Regional efforts and make available nationally
5. Design method to measure progress in increasing citizen
involvement - 8/90
- Include planning and resource issues
FINAL COMPLETION DATE: 11/90
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SUPERFUND MANAGEMENT REVIEW
UORKPLAN
NUMBER: 43.B
TITLE: Listen to Citizens and Change Actions Where Merited
FULL TEXT: EPA managers and staff should listen carefully to what citizens
are saying, take the time necessary to deal with their concerns,
change planned actions where citizen suggestions have merit, and
then explain to citizens what EPA has done and why. (p. 5-7)
LEAD OFFICE; OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Ensure community relations training is offered in OSWER
Course calendars - 12/89
- Include courses on active listening and conflict resolution and
existing courses on communications
2. Issue "short sheet" on successfully incorporating citizen
concerns - 12/90
- Provide tools for successfully incorporating citizen concerns
FINAL COMPLETION DATE: 12/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 43.C
TITLE: Public Comment Time
FULL TEXT: Regional managers should factor adequate time for public
comment and response into their planning for ROD
deadlines. The standard public comment period on EPA's
proposed plans should be 60 days (rather than 30),
whenever citizens or PRPs request it. (p. 5-7)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete revision of National Contingency Plan - 2/90
- Allow an additional 30 days upon request for public review of
proposed plan of remedial action
FINAL COMPLETION DATE: 2/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 43.D
SEE RECOMMENDATION: 10
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NUMBER:
TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
UORKPLAN
43 .E
Clear Explanation of Decisions
Whether EPA can do what citizens ask or not, we should always
provide them a clear explanation of the basis for our decision
A responsiveness summary should reflect a genuine attempt to
come to grips with citizens' questions and concerns; it should
not appear to be an advocacy brief piling up evidence for why
EPA's original decision was the only possible one. (p. 5-7)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue "short sheet" on responsiveness summaries - 5/90
- Clarify content and purpose of document
FINAL COMPLETION DATE: 5/90
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SUPERFUND MANAGEMENT REVIEW
HORKPLAN
NUMBER:
TITLE:
FULL TEXT:
43 .F
Citizen Involvement at Each Stage
EPA managers and staff should plan for citizen involvement at
each stage of the Superfund process beginning with the initial
investigations at a site. (p. 5-8)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Modify National Contingency Plan to strongly encourage additional
community relations - 2/90
- Extend commitment to communicate through the RD/RA stage
2. Develop "short sheet" guidances on planning for sufficient community
relations activities - 2/90
- Build community relations into each stage of process
FINAL COMPLETION DATE: 2/90
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LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
UORKPLAN
43.G, H, Q, R, T
Discuss Site Findings Early and Make Documents More Readily
Available Throughout Process
EPA should discuss site findings and decisions as they are
developed, not only at the end of the Feasiblity Study. While a
formal commit period is required only at the Proposed plan
stage, EPA should make documents available to citizens and to
PRPs throughout the cleanup process, and be open to receiving
comments continually as well.... EPA should be more aggressive
about supplying information to citizens and their technical
advisors. Citizens' access to information should be comparable
to that of PRPs. Neither citizens nor PRPs should have to wait
until the end of the Remedial Investigation and Feasibility
Study to learn the results of the studies. EPA should ensure
access to information by (1) establishing information
repositories that are convenient to the affected public; (2)
completing any necessary review of documents quickly, so the
documents can be released; (3) placing documents in the
administrative record and the information repositories as soon
as possible; and (4) notifying citizens of the availability of
that information through fact sheets and other mailings.
(p. 5-8, 5-14, 5-15).
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue memorandum on coordination between Administrative Record
Coordinators and Community Relations Coordinators - 9/89
- Include roles and responsibilities
2. Complete modification of NCP as appropriate - 2/90
- Goal is to encourage release of documents in more timely manner
3. Issue "short sheet" on discussing site findings and releasing
information - 10/90
- Include recommendations for program improvements
FINAL COMPLETION DATE: 10/90
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SUPERFUND MANAGEMENT REVIEW
UORKPLAN
NUMBER:
TITLE:
FULL TEXT:
43.1
Number of Site Managers and Community Relations Staff
The Administrator should increase the number of site
managers and community relations staff to allow more
frequent communication with the affected public.
(p. 5-11)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Submit FY 91 budget increase to OMB - 9/89
2. Allocate additional resources to regional Waste Management
Divisions - 9/89
- Part of 500 newly allocated positions
FINAL COMPLETION DATE: 9/89
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SUPERFUND MANAGEMENT REVIEW
UORKPLAN
NUMBER: 43J
TITLE: Communication as High Priority
FULL TEXT: EPA should firmly establish communication as a high
priority for Superfund managers, site managers, and
community relations staff, (p. 5-11)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue instructions to include in performance standards of
staff - 10/89
FINAL COMPLETION DATE: 10/89
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TITLE:
FULL TEXT:
SUPERFUND MANAGEMENT REVIEW
UORKPLAN
43 .K, L
Use of Senior Environmental Employees (SEE) and State and Local
Officials
Regions should experiment with using Senior Environmental
Employees more extensively in Superfund . Where sites are some
distance from EPA offices, Regions can hire retirees who live in
the communities near the sites to take questions and provide
information. EPA should consider using State or local
officials to represent EPA at sites as another way of coping
with the limits to EPA resources and distance problems.
(p. 5-11)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue memorandum on use of SEE - 8/90
- Include current experiences
2. Include examination of EPA's ability to use State/local officials for
community relations in plan to determine State's long-term role in
Superfund - 9/90
- Identify opportunities and constraints
FINAL COMPLETION DATE: 9/90
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NUMBER:
TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
43.M, N, 0
Problems Staff Turnover Creates for Community
EPA should be sensitive to the problems that staff turnover
create for a community and should preserve the continuity of
staff assignments as much as possible. For example, these
problems should be considered as costs in deciding whether to
reorganize. EPA managers should try to keep continuity and site
history on the team if one team member must be replaced. For
example: if the site manager is new, the community relations
coordinator probably should not be switched. EPA should educate
new staff about the site's history and the community's
involvement and concerns, and the importance of these concerns.
EPA should communicate staff changes to the community and
demonstrate that their concerns are understood.
(p. 5-12)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue memorandum identifying materials, techniques, and procedures
for transitions - 12/90
- Emphasize the importance of continuity and planning for a smooth
transition
FINAL COMPLETION DATE: 12/90
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SUPERFUND MANAGEMENT REVIEW
HORKPLAN
NUMBER: 43.P
TITLE: Train Staff in Communications
FULL TEXT: EPA should provide communications training (both speaking and
listening) to all Superfund staff who deal directly with the
public, (p. 5-12)
LEAD OFFICE: OPNT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue directive making the existing course on community relations
mandatory for anyone who attends public meetings - 10/89
- Mandate training
2. Identify new training needs in comuunications for managers and
staff - 12/89
- Determine training needs universe
3. Organize existing courses into a curriculum based on skill
level - 2/90
- Consolidate available training
4. Advertize courses in OSWER Training Course catalog and bulletin
board - 3/90
- Publicize training
FINAL COMPLETION DATE: 3/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 43.Q, R
SEE RECOMMENDATION: 43.G
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SUPERFUND MANAGEMENT REVIEW
HORKPLAN
NUMBER: 43.S
TITLE: Ensuring citizen access to information
FULL TEXT: EPA should require PRPs and its own contractors to write
clear, understandable summaries of complex technical
documents. EPA should provide copies of those summaries
directly to citizens, (p. 5-14)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Amend current contracts and require future contracts to contain
requirement for contractors to write clear, understandable summaries
of complex technical documents - 12/89
- Create requirement for contractors
2. Issue directions to Department of Justice and Regional negotiators
to include development of summaries of complex technical documents
in enforcement agreements and settlements with PRPs - 2/90
- Create requirement for PRPs
FINAL COMPLETION DATE: 2/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 43. T
SEE RECOMMENDATION: 43.G
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 43.U, V
TITLE: PRP Grants to Communities
FULL TEXT: The Agency should also encourage PRPs to provide grants to
communities to enable them to acguire independent technical
assistance. EPA should provide information and advice to PRPs
and citizens regarding the successful use of such grants at
other Superfund sites, (p. 5-15)
LEAD OFFICE: OWPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue Directive on encouraging PRP to provide grants to
communities - 12/89
2. Conduct Regional workshops on PRP grants to communities - 4/90
FINAL COMPLETION DATE: 4/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 44 .A .1, 2, 3
TITLE: Amend TAG Interim Final Rule
FULL TEXT: EPA should amend the interim final rule immediately to (1)
reduce the match requirement from 35% to 20%, (2) eliminate the
15% cap on administrative in-kind services, and (3) modify the
reincorporation requirement, (p. 5-22)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue Revised Interim Final Rule - 11/89
- Rule will reduce match, eliminate administrative cap, and modify
reincorporation requirement
FINAL COMPLETION DATE: 11/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 44 .A .4, F.3
TITLE: TAG Application Process and Procurement Requirements
FULL TEXT: EPA should simplify the application process, simplify
the procurement requirements,^., (p. 5-22)
EPA should address revamping the TAG application process to give
more weight to the NRDC recommendation of considering health
effects from site contamination that may have been suffered by
TAG applicants .
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue revised and simplified forms and support
materials - 3/90
- Include the Citizens Guidance Manual
2. Compl ete development of TAG-specific procurement procedures and
requirements - 4/90
- Include streamlining measures
3. Issue amended TAG Rule - 9/90
- Promulgate improvements to TAG process
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 44 .A .5
TITLE: Establish Guidelines for TAG Renewal
FULL TEXT: EPA should... establish guidelines for grant renewal in cases
where circumstances warrant, (p. 5-22)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue memorandum on waivers and renewals - 1/90
- Policy and criteria on deviations from current TAG ceiling rule
FINAL COMPLETION DATE: 1/90
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NUMBER:
TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
44.A .6
Reduce Red Tape in TAG Application Process
EPA should encourage citizen groups to apply, not discourage
them with red tape, so long as they demonstrate a willingness to
manage TAG grants responsibly and a reasonable ability to do so.
The Administrator should acknowledge and accept the financial
risks of fewer and less rigid controls, flexibly applied by
Regions, (p.'5-22)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue "short sheet" to Regions to encourage application - 10/89
- Include steps they can take to simplify and facilitate process
FINAL COMPLETION DATE: 10/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
45.A.I
Raise On-Scene Coordinator (OSC)/Remedial Project Manager (RPM)
Full Performance Levels
The Agency should take immediate steps to offer a competitive
compensation and incentive package to its key Superfund
frontline personnel. Immediately raise the full performance
level of Remedial Project Managers (RPM's) and On-Scene
Coordinators (OSC's) from GS-12 to GS-13. (p. 6-3)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Publish revised OSC/RPM classification guidance - 12/89
- Establish basis for higher grade levels
2. Issue an Office of Solid Waste and Emergency Response (OSWER)
directive on use of classification guidance - 1/90
- Assure implementation in the Regions
3. Complete communications and assistance visits to Regional
offices - 4/90
- Assure complete use of classification guidelines
4. Evaluate Regional application of new classification
guidelines - 12/90
- Follow up on completeness and consistency of implementation
FINAL COMPLETION DATE: 12/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 45.A.2
TITLE: Promotion Policy for Superfund Enforcement Attorneys
FULL TEXT: Develop a uniform policy to open up the possibility of
promoting Regional Superfund Enforcement Attorneys from GS-13
to GS-14. (p. 6-3)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1.
2.
Complete job analysis of Regional Superfund Site-Specific
Enforcement Attorney Positions and issue decision paper - 4/90
If promotion potential should be GS-14, publish revised Regional
attorney classification guidance - 8/90
FINAL COMPLETION DATE: 8/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
45.A.3
LEAD OFFICE:
Legislative Initiatives/Demonstration Projects to Attract,
Retain, and Train Key Field Staff.
Pursue initiatives with Congress, the Office of Management and
the Budget (OMB) and the Office of Personnel Management (0PM)
to allow the Agency to: pay salaries competitive with the
private sector in certain high cost geographic areas;
accelerate the promotion process; design more flexible leave
and working hour policies; award bonuses to staff who remain
with EPA; provide high-cost, specialized training outside the
federal family in exchange to additional government service;
and offer early retirement rights, (p. 6-3/4)
OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Request higher pay rates from 0PM under the special salary rate
program - 2/90
- Pay higher salaries to the extent authorized by 0PM
2. Draft legislative or demonstration proposals - 8/90
- Prepare request to Congress on objectives which cannot be
accomplished under current law
3. Submit proposal for enactment by Congress and/or 0PM
approval - 11/90
FINAL COMPLETION DATE: 11/90
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SUPERFUND MANAGEMENT REVIEW
HORKPLAN
NUMBER: 45.B.I
TITLE: Mandatory Training
FULL TEXT: Implement a mandatory training requirement for field staff
at all levels: Basic, Intermediate, Advanced, and Master.
This should serve as an incentive leading to certification
of EPA field staff at various levels, (p. 6-5)
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue directive establishing 80 hour annual training requirement
for all OSCs and RPMs - 9/89
- Establish requirement
2. Establish mentoring program and issue directive requiring all new
employees to spend three months with a formal mentor - 10/89
- Establish requirement
3. Publish guidance on Structured Training and Evaluation Program
(STEP) criteria to establish four levels of OSCs and
RPMs - 12/89
- Establish various levels for certification
FINAL COMPLETION DATE: 12/89
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TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
HORKPLAN
45.B.2
In-House RI/FSs
Implement pilots in all regions encouraging EPA field
staff to perform remedial investigation and feasibility
studies in-house. Reward outstanding achievement in this
area. This practice will improve the ability of front-
line staff to better oversee contractors in the field.
(p. 6-5)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete negotiations of FY 90 Regional SCAP targets for
undertaking in-house RI/FS - 9/89
2. Allocate resources for conduct of in-house RI/FS - 10/89
FINAL COMPLETION DATE: 10/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 45.C.I
TITLE: Adequate Regional Support
FULL TEXT: The Assistant Administrator for Solid Waste and Emergency
Response and the Assistant Administrator for Administration and
Resources Management should work out a format for assigning
certain administrative tasks to the appropriate Management and
Waste Management Divisions in the Regions. These two Assistant
Administrators should then solicit the agreement of the
Regional Administrators on the assignment of these adminis-
trative tasks in a regional Memorandum of Understanding.
Should this approach prove successful, it should be extended to
include key activities of Environmental Services Divisions and
lawyers in the Office of Regional Counsel. Ultimately,
Regional Administrators have the principal responsibility for
assuring successful cooperation among the various offices
responsible for implementing Superfund in the Regions.
(p. 6-7)
LEAD OFFICE: Region III
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Assign technical and administrative tasks to other staff within and
outside the Division - 12/89
- Provide additional support to RPMs
2. Sign MOUs assigning appropriate tasks to Management and Waste
Divisions - 2/90
- Assign certain tasks to appropriate staff in other divisions
3. As appropriate, sign MOUs between Waste Management Divisions and
ESDs and ORCs - 2/90
4. Review Skill Mix Study and make needed changes in task
assignments - 7/90
FINAL COMPLETION DATE: 7/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 45.C.2
TITLE: Provide Personal Computers to Superfund Field Personnel
FULL TEXT: Ensure that all key field staff have immediate access to
personal computers, portable computers for the field, related
hardware and software, and E-mail capabilities to access the
OSWER information systems, (p. 6-7)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Initiate Procurement Requests for Equipment, Software, and
Peripherals - 9/89
- Begin first phase of procurement for On-Scene Coordinators
(OSCs)/Remedial Project Managers (RPMs) within resource
constraints in FY 89
2. Initiate Additional Procurement Requests for Equipment,
Software, and Peripherals - 12/89
- Begin second phase of procurement for OSC/RPMs
3. Establish Training Program - 12/89
- Identify specific Regional training needs for OSC/RPMs and begin
training to the Regional field staff
FINAL COMPLETION DATE: 12/89
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TITLE:
FULL TEXT:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
45.C.3
Delegation and Exercise of Administrative Authorities
The Assistant Regional Administrators and Waste Management
Division Directors should examine administrative authorities
such as approval of travel authorizations and vouchers,
acquisition or the lease of motor vehicles for site-specific
work, purchase of necessary site equipment and property,
approval of overtime, compensatory time, hazardous and stand-by
duty pay and delegate them to the most appropriate and
efficient level, (p. 6-8)
LEAD OFFICE: Region III
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Submit implementation plan for delegations - 4/90
- Each Region evaluate individual delegations and policies as they
pertain to the Waste Management Divisions
2. Issue delegations and revised policies for each Region - 9/90
- Increase efficiency of support to RPMs/OSCs
FINAL COMPLETION DATE: 9/90
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TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUNO MANAGEMENT REVIEW
WORKPLAN
46.A
Contractor Dependency and Conflict-of-interest
Avoidance
To protect the integrity of the program and to preserve the
reputations of participating contractors who are to important
to Superfund's success, EPA should begin immediately to develop
guidance proceedings and award criteria to preclude firms from
holding both policy and regulatory support contracts as well as
response action contracts under the Superfund program.
(p. 6-10)
OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Develop preliminary criteria - 10/89
- Develop documentation to preclude response action
contractors from holding both policy and response
action contracts
2. Develop draft final criteria - 1/90
- Utilize comments from internal EPA and industry to
refine documentation and award criteria
3. Produce final award criteria - 5/90
FINAL COMPLETION DATE: 5/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 46.B
TITLE: Contractor Disclosure of Potential Conflict-of-interest (COI)
FULL TEXT: Contractors currently involved in such arrangements [policy and
regulatory support contracts and response action contracts]
should be asked to make voluntary disclosures of potential
conflict situations and to refrain from executing policy and
regulatory analysis or guidance preparation on work they are
also charged with carrying out in the field, (p. 6-10)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue letter to contractors - 12/89
- Reiterate contractors' obligation to avoid COI in accepting
assignments and to disclose potential conflicts
FINAL COMPLETION DATE: 12/89
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SUPERFUND MANAGEMENT REVIEW
UORKPLAN
NUMBER: 46.C
TITLE: Contractor Conflicts of Interest
FULL TEXT: Superfimd program staff should also exercise appropriate
care in issuing work assignments, (p. 6-10)
LEAD OFFICE:
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete standards for work assignment conflict of interest
problems - 10/89
- Create standards and criteria by which future work
assignments will be judged for conflict of interest problems
2. Prepare and disseminate procedures for contractors to identify
conflicsts of interest and for work assignments to adequately
address potential conflicts - 2/90
- Document and implement selected procedures
FINAL COMPLETION DATE: 2/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 46.D
TITLE: Additional Conflict-of-interest (COI) Procedures
FULL TEXT: EPA should immediately develop additional procedures for
detecting and avoiding conflict. This should include issuing
clear guidance to Superfund contractors on what constitutes a
conflict-of-interest, and requiring a corporate executive to
certify that no conflict-of-interest exists, (p. 6-10)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Draft interim EPA Acquisition Regulations rule - 12/89
- Propose new contract clauses and guidance on what constitutes a
COI
2. Issue new Guidance - 1/90
- Provide Superfund contractors with clearer guidance
3. Publish interim EPA Acquisition Regulations change - 3/90
- Promulgate new Superfund COI clauses for immediate use
4. Modify Superfund contracts - 8/90
- Incorporate clauses required by interim regulations
5. Publish final EPA Acquisition Regulations change - 1/91
- Mandate use of new clauses and guidance
FINAL COMPLETION DATE: 1/91
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 46.E
TITLE: Conflict-of-interest (COI) Procurement Reviews
FULL TEXT: EPA should also send procurement review teams to examine
Superfund contractors' conflict-of-interest prevention systems,
(p. 6-10)
LEAD OFFICE: OARM
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Report on survey findings - 1/90
- Assess current Superfund industry practices
2. Establish minimum standard - 3/90
- Define acceptable standard for Superfund contractors' COI
avoidance system
3. Establish schedule for reviews - 4/90
- Regular compliance reviews of Superfund contractors' systems
4. Begin COI avoidance reviews - 5/90
FINAL COMPLETION DATE: 5/90
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SUPERFUND MANAGEMENT REVIEW
HORKPLAN
NUMBER:
TITLE:
FULL TEXT:
46.F
LEAD OFFICE:
Reduce Dependence on Contractors
To fully mitigate the serious perception problem that
exists with regard to contractors assisting the program
with policy and regulatory development, EPA should begin
increasing in-house staff to reduce dependence on
contractors. EPA staff should analyze which portions of
the current contractor workload should be performed in-
house and establish a timetable for phasing manageable
portions of this work from contractor to EPA staff.
(p. 6-10)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue document decision on selected strategy - 7/90
- Documentation of senior management decision on appropriate
strategy
2. Establish timetable for phased implementation - 8/90
- A schedule to phase in implementation in accordance with
schedule for hiring FTE and with award of new contracts or
exercise of new options within contracts
FINAL COMPLETION DATE: 8/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 47
TITLE: National Communications Strategy
FULL TEXT: Develop and implement a national plan to inform the public at
large about the Superfund program and its achievements. Seek
help from the program's many constituencies in developing this
plan and in carrying it out. (p. 7-4)
LEAD OFFICE: OCPA
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Publish and begin implementation of a national Superfund
communications strategy - - 12/89
FINAL COMPLETION DATE: 12/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 47.A
TITLE: Commitment to Communication
FULL TEXT: Reaffirm a commitment to communication that
includes:
- involving the public as a legitimate partner;
- listening to public's specific concerns;
- being honest and open; and
- meeting the needs of the media, (p. 7-5)
LEAD OFFICE: OCPA
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue memo from Administrator to Regional Administrators - 10/89
- Stress importance of Superfund communications and listening,
both site-specifically and programmatically
2. Incorporate commitment to communication into existing performance
standards for HQ Superfund managers - 10/89
- Ensure HQ management accountability
3. Identify forums for discussion with media environmental reporters,
newspaper editors, and radio/tv producers - 10/89
- Provide opportunity to confer with major creators of
public perception
4. Obtain introduction by Administrator to replace community relations
video introduction by Lee Thomas - 12/89
FINAL COMPLETION DATE: 12/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 47. B
TITLE: Timely and Accurate Dissemination of Information
FULL TEXT: Identify those who influence public opinion nationally and
locally, including the media, elected officials, and public
interest groups, and provide them with timely, accurate
information, (p. 7-5)
LEAD OFFICE: OSWER
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Provide Superfund HQ staff with mailing list of key constituents
of the national program - 8/89
- Provide timely notification of national policy and
management activities
2. Publish current information package for media and interested
publics - 11/89
- Provide up-to-date information on the Superfund
program
3. Revise Communications Planning Process - 1/90
- Ensure communications strategies are developed in
line with a national plan
4. Modernize and make current the existing mechanism for mass
distribution and availability of documents - 9/90
- Define roles and procedures for development and
distribution of documents
FINAL COMPLETION DATE: 9/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
47.C
Existing Communications Techniques and New Methods of
Public Education
Evaluate existing communications techniques and public
information materials to intended audiences and identify
new methods for public education, including increased use
of stand-alone approaches, such as videotapes, to describe
general or actual Superfund site experiences, (p. 7-5)
LEAD OFFICES: OSWER
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Ensure Congressional 5-day courtesy notification period is
initiated for work assignments for remedial construction
contracts - 1/90
- Reinforce partnership role with Congress
2. Convene a workshop of outside experts on communicating contro-
versial, complex issues - 3/90
- Gain ideas from successful efforts outside government
FINAL COMPLETION DATE: 3/90
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NUMBER:
TITLE:
FULL TEXT:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
47.D
Journalists Guide to Superfund
Work with reporters to develop a
Superfund" which would provide a
program, describe steps in the
where public interest is high,
technologies, (p. 7-5)
"Journalists Guide to
national context for the
process, identify points
and describe remedial
LEAD OFFICE: OCPA
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue "Journalists Guide to Superfund" - 1/90
- Survey reporters and develop a reference guide
FINAL COMPLETION DATE: 1/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 47.E
TITLE: Superfund Jargon
FULL TEXT: Address language and definition problems in Superfund by
eliminating jargon from our Superfund lexicon. This may be
difficult, but the Agency needs to make the effort.
(p. 7-5)
LEAD OFFICE: OSWER
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Provide in OSWER training course catalogue a HQ course on
communicating clearly - 3/90
2. Use Superfund University Training Institutes and Superfund
Academy to reinforce need to communicate clearly - 3/90
3. Issue matrix of alternative terms to use - 3/90
FINAL COMPLETION DATE: 3/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
47.F
LEAD OFFICE:
Communication is Everyone's Responsibility
Make public education a Superfund priority for all front-
line managers and staff. Specific actions include:
provide appropriate communications assistance to Superfund
staff and managers to make communications and outreach
successful, provide communications skill training to all
staff and managers, and reward communication successes in
ways that serve as positive examples to all employees.
(p. 7-7)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Provide Superfund staff with mailing list of key constituents
of the national program - 8/89
- Provide tools for outreach
2. Issue memo to Division Directors on Spot awards - 9/89
- Reinforce use of spot awards for communications efforts
3. Provide HQ training in communications in OSWER Training Course
Catalogue - 3/90
- Develop needed communication tools
4. Fund Regionally developed training courses in community
relations - 5/90
- Provide support and National distribution of Regionally
developed training courses
FINAL COMPLETION DATE: 5/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER:
TITLE:
FULL TEXT:
48
Expanding Public Participation in National Program
Oversight
At the national and/or Regional level, immediately convene
a forum(s) representing varying perspectives on the program.
The initial forum(s) should be designed to begin an ongoing
dialogue with follow up sessions to address specific policy
and/or implementation issues. The preparation of authoritative
reports is not an explicit goal of this exercise. Dialogue and
discussion among Superfund's diverse constituencies is the
principal objective.
Use communication tools, such as focus groups or surveys,
to assess our constituency groups' opinions of Superfund
and use this information to more effectively involve these
groups in oversight and decision making, (p. 7-6)
LEAD OFFICE: OSWER
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue memo from the Administrator to Regional Administrators
stressing the importance of dialogue and encouraging them to
convene forums - 10/89
2. Complete a series of initial forums to discuss Superfund
issues - 11/89
- Identify audience and issues; convene meeting with industry,
environmental groups, trade associations, intergovernmental
organizations and others
3. Convene an ongoing dialogue with senior policy officials from
outside organizations - 11/89
- Discuss policy and implementation issues with key external
organizations
FINAL COMPLETION DATE: 11/89
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SUPERFUND MANAGEMENT REVIEW
UORKPLAN
NUMBER: 49.A.I
TITLE: Environmental Results Indicators
FULL TEXT: By October 1, 1989 begin collection of data to report
environmental results indicators for:
- the number of sites where exposure from air, surface
water
and/or ground water releases of hazardous substances
have
been controlled.
- progress towards meeting the human health and/or
ecological goals at sites.
- the amount of hazardous materials treated or removed and
area of material contained, (p. 7-11)
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue Semi-Annual Report - 4/90
- Summarize Superfund progress in environmental terms in short
report
2. Issue Semi-Annual Report - 11/90
- Reporting mechanism on-line; successful completion of project
FINAL COMPLETION DATE: 11/90
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NUMBER:
TITLE:
FULL TEXT:
LEAD OFFICE:
SUPERFUND MANAGEMENT REVIEW
WORKPLAN
49.A.2
Timeliness of Site Remediation
By October 1, 1989 begin collecting data to report:
- the timeliness of moving a site through the various
stages of site remediation, measured against
preestablished criteria.
- the extent of PRP's participation in the program.
(p. 7-11)
OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue an integrated Fund/Enforcement timeline - 8/89
- Document time goals for the various phases of Superfund
remedial activities
2. Complete assessment of available information on PRP
participation in Superfund cleanup activities - 10/89
- Summarize available information on PRP participation in the
program
3. Issue Reports - 1/90
- Timeliness of Superfund remedial activities
- PRP participation in the Superfund program
FINAL COMPLETION DATE: 1/90
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SUPERFUND MANAGEMENT REVIEW
UORKPLAN
49.A.3
Additional Reporting Measures
Accelerate the development of additional measures for
reporting:
- the types of technologies used to control and cleanup sites,
including alternative and innovative technologies.
- additional environmental indicators for 1) the number of
people protected from exposures to hazardous substances, and
2) changes in concentrations of contaminants at sites.
(p. 7-11/12)
OPPE
IMPLEMENTATION PRODUCTS AND DUE DATES
1. Issue report on environmental data - 10/89
- Analyze existing data on concentrations of contaminants for pilot
Region(s)
2. Issue report on additional indicators - 4/90
- Examine data on populations and technologies and evaluate need for
additional concentration data
3. Complete development of data collection - 6/90
- Recommend data collection and site monitoring for FY 91
FINAL COMPLETION DATE: 6/90
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SUPERFUND MANAGEMENT REVIEW
NORKPLAN
NUMBER: 50
TITLE: Internal Management Measures Review
FULL TEXT: Begin a process to review Superfund's internal management
measures with an eye toward eliminating unnecessary or
redundant reporting and focusing more directly on improving
performance. Pilot test alternative approaches to increase
Superfund performance and achieve environmental results.
(p. 7-14)
LEAD OFFICE: OPPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete summary of existing management measures in Headquarters and
Regional reporting systems - 1/90
- Collect database information on all systems which collect
Superfund data (SPMS, CERCLIS, etc), conduct Regional interviews,
develop measures schematic (what information is required, what
information is not)
- Identify problem measures, missing measures, excessive or
redundant measures
2. Issue Recommendations and Implementation Plan, if necessary - 5/90
- Resolve remaining measures issues and address the development of
pilot projects or alternative processes to implement final
recommendations
FINAL COMPLETION DATE: 5/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: E.I
SEE RECOMMENDATION: 30
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SUPERFUND MANAGEMENT REVIEW
UORKPLAN
NUMBER: E.2
TITLE: Long-Term Contractor Needs
FULL TEXT: Undertake an analysis of the long-term contract needs of
the Superfund program to project how EPA will meet the
workforce demands of the future using a combination of
available technically competent contractors and in-house
expertise to ascertain what in-house expertise EPA should
build.
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Issue report on decisions made on long-term contracting
strategy - 7/90
- Document senior management decisions on a long-term
contracting strategy
2. Complete timeline for phased implementation - 8/90
- Prepare a schedule to phase in implementation of the long-
term strategy in accordance with award of new contracts
FINAL COMPLETION DATE: 8/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
E.3
Direct and Indirect Benefits of Superfund
Identify and communicate the direct and indirect benefits of
the Superfund program beyond those associated with the
remediation of sites listed on the National Priorities List.
LEAD OFFICE: OPPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete Final Report and communicate results - 5/90
- Report describes direct and indirect benefits
- Implement plan to communicate direct and indirect
benefits
FINAL COMPLETION DATE: 5/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: F.I
TITLE: Deadline Compliance
FULL TEXT: Follow up on deadline compliance: Share with Congress and
public more routinely deadline compliance information; prepare
"regular periodic report" on compliance.
i
LEAD OFFICE: OPPE
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete development of criteria for Periodic Report - 10/89
- Decide whether existing reports and systems are appropriate
and adequate for use as reports to Congress on deadline compliance
2. Issue Periodic Report - 12/89
- Modifify existing reports/systems, if necessary
- Begin periodic report to Congress
FINAL COMPLETION DATE: 12/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: F.2
TITLE: Health Assessments
FULL TEXT: In terms of systematic analysis of the health consequences of
the sites, it is something we did not really address in this
management review and perhaps ought to be a major charge to what
we do in the future.
LEAD OFFICE: OERR
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Complete solicitation of commitment from ATSDR agreeing to provide
report - 9/89
2. Issue report provided by ATSDR - 3/90
FINAL COMPLETION DATE: 3/90
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: F.3
SEE RECOMMENDATION: 44.A.4
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SUPERFUND MANAGEMENT REVIEW
HORKPLAN
NUMBER: F.4
TITLE: Reprogram Funds
FULL TEXT: Reprogram funds in Superfund to support more employees for
enforcement, policy/regulatory analysis, community relations,
and site management.
LEAD OFFICE: OPMT
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Provide Regions with immediate authority to hire - 7/89
- Reprogram funding to support limited hiring in FY 89
2. Reprogram funding to support 500 additional FTE - 10/89
- Obtain Congressional approvals
FINAL COMPLETION DATE: 10/89
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SUPERFUND MANAGEMENT REVIEW
WORKPLAN
NUMBER: 40.A.7
TITLE: Elimination of Internal Barriers
FULL TEXT: Suggest ways to eliminate internal barriers to the introduction
of new technologies into the Superfund program, (p. 4-20)
LEAD OFFICE: ORD
IMPLEMENTATION PRODUCTS AND DUE DATES:
1. Meet with developers who have completed SITE demos - 1/90
- To identify internal constraints they have experienced
2. Identify changes to SITE - 6/90
- To facilitate demonstration and commercialization
FINAL COMPLETION DATE: 6/90
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