United States
Environmental Protection
Agency
Supertund
Office of Solid Waste
and Emergency Response
Washington DC 20460
Publication 9200.3-01H-2
PB93-963260
October 1992
Superfund Program
Management Manual
Fiscal Year 1993
540R92505
Program Goals and Priorities
Program Planning and Reporting Requirements
Superfund Financial Management and FTE Distribution
SCAP/STARS Targets/Measures and Definitions
EPA-540/R
92-505
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Directive 9200.3-01H-2
October 1992
Superfund Program
Management Manual
Fiscal Year 1993
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
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DISCLAIMER
The policies and procedures established in this document are intended
solely for the guidance of employees of the U.S. Environmental
Protection Agency. They are not intended and cannot be relied upon to
create any rights, substantive or procedural, enforceable by any party in
litigation with the United States. EPA reserves the right to act at
variance with these policies and procedures and to change them at any
time without public notice.
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OSWER Directive 9200.3-01H-2
USE AND STRUCTURE OF THE MANUAL
The information in this Manual is targeted to Unit, Section and Branch Chiefs. Its pri-
mary purpose is to provide:
The primary program goals and priorities for FY 93; and
An overview of the Superfund program management processes (planning, accom-
plishment reporting and program evaluation, and resource allocation).
The FY 93 Superfund Program Mangement Manual consists of information on:
Manager's schedule of significant events;
Program goals and priorities;
Program planning and reporting requirements; and
Financial management and FTE distribution.
The Appendix contains the definitions for Federal Facility and non-Federal Facility site
assessment, response, removal and remedial/enforcement pipeline activities.
In FY 93, for the first time, two other documents have been developed to support the
program management needs of the Regional Information Management Coordinators, Remedial
Project Managers and On-Scene Coordinators (Superfund Program Implementation Manual)
and Division Directors (Highlights: Superfund Program Management).
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OSWER Directive 9200.3-01H-2
FY 93 SUPERFUND PROGRAM MANAGEMENT MANUAL
TABLE OF CONTENTS
CHAPTER I - PROGRAM GOALS AND PRIORITIES 1-1
OVERVIEW OF PROGRAM GOALS 1-1
FY 93 Themes 1-1
A Framework for Setting Priorities 1-2
Integrated Priority Setting Matrix 1-2
EFFICIENCY 1-6
Superfund Accelerated Cleanup Model (SACM) 1-6
Site Assessment 1-7
Regional DecisionTeam(RDT) 1-7
Early Actions 1-10
Long-Term Actions Ml
Involvement of Enforcement 1-11
Quick Response 1-11
Financial Considerations 1-12
Authorities and Contract Strategies 1-13
Procedures for Quick Response 1-13
Integrated Timeline for Site Management 1-13
Supporting Program Goals 1-15
Removal 1-15
Enforcement 1-16
Site Assessment 1-16
Federal Facilities 1-17
EFFECTIVENESS 1-18
Completions/Deletions 1-18
Five Year Reviews 1-19
STARS Targets and Measures 1-19
Supporting Program Goals 1-20
Removal 1-20
Enforcement 1-20
Remedial 1-20
Site Assessment 1-20
Federal Facilities 1-23
Management Initiatives 1-23
EQUITY 1-24
CHAPTER II - PROGRAM PLANNING AND REPORTING
REQUIREMENTS IM
INTRODUCTION II-l
RELATIONSHIP OF SCAP TO OTHER MANAGEMENT TOOLS II-1
OVERVIEW OF THE SCAP PROCESS II-2
PROCEDURES FOR ANNUAL TARGET SETTING II-2
Planning for Negotiations II-3
ACCOMPLISHMENT REPORTING AND PERFORMANCE
EVALUATION II-5
Superfund Management Reports II-7
SCAP/STARS ADJUSTMENTS AND AMENDMENTS II-8
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OSWER Directive 9200.3-01H-2
CERCLIS DATA QUALITY II-9
Audit Reports II-9
Data Sponsors 11-12
CHAPTER III - SUPERFUND FINANCIAL MANAGEMENT
AND FTE DISTRIBUTION ffl-1
DEVELOPMENT OF THE FY 93 NATIONAL BUDGET IH-1
THE FY 93 REGIONAL BUDGET ffl-1
Response Budget ffl-1
Enforcement Budget IE-1
Federal Facilities Budget III-l
RELATIONSHIP BETWEEN SCAP AND THE ANNUAL
REGIONAL BUDGET ffl-4
ADVICE OF ALLOWANCE PROCEDURES AND
FINANCIAL REPORTING REQUIREMENTS ffl-4
Regional Allowances ffl-4
The AOA Process ffl-5
Financial Planning for Response AOA III-5
Financial Planning for Enforcement AOA ffl-6
AOA Flexibility and Change Request Procedures ffl-6
OVERVIEW OF THE FTE DISTRIBUTION PROCESS ffl-8
ACRONYMS I
ORGANIZATIONAL CHARTS 1
Office of Waste Programs Enforcement 1
CERCLA Enforcement Division 2
Office of Emergency and Remedial Response 3
Office of Program Management 4
Emergency Response Division 5
Hazardous Site Evaluation Division 6
Hazardous Site Control Division 7
Office of Federal Facilities Enforcement 8
U.S. EPA REGIONS MAP 9
INDEX A
APPENDIX: SCAP/STARS Targets/Measures and Definitions A-l
11
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OSWER Directive 9200.3-01H-2
LIST OF EXHIBITS
CHAPTER I
I-1 Integrated Priority Setting Matrix 1-4
1-2 The Superfund Accelerated Cleanup Model (S ACM) 1-8
1-3 S ACM Implementation Within NCP Framework 1-9
1-4 Integrated Timeline 1-14
1-5 STARS Targets and Measures 1-21
CHAPTER H
II-l SCAP Planning Year II-3
II-2 Procedures for Annual Target Setting II-4
II-3 Accomplishment Reporting and Performance Evaluation II-6
II-4 Evaluation Responsibilities II-7
II-5 OWPE Management Reports II-9
II-6 Amendments and Adjustments 11-10
II-7 SCAP Amendment Process 11-11
CHAPTER HI
in-1 Criteria for Regional Response Budget Development in-2
III-2 FY 93 Regional Enforcement Extramural Budget Funded Activities
Required to Achieve Program Outputs in-3
Ifl-3 Planning Budget Amounts for Federal Facilities in-4
ffl-4 AOA Change Process ffl-7
111
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OSWER Directive 9200.3-01H-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS
JULY QUARTER 4 (FISCAL YEAR (FY) 92)
6 Fourth quarter Advice of Allowance (AOA) approved by the Assistant Adminis-
trator for the Office of Solid Waste and Emergency Response (AA SWER) and
the Office of the Comptroller (OC)
8 Headquarters (HQ) pulls 3rd quarter accomplishments data from the Comprehen-
sive Environmental Response, Compensation, and Liability Information System
(CERCLIS) and provides for:
1) Entry into the Office of Pollution Prevention (OPP) Strategic Targeted Activi-
ties for Results System (STARS);
2) Special program reports; and
3) Assistant Administrator (AA) report
13-17 Regions verify accomplishments data contained in the OPP STARS system (third
quarter accomplishments)
15 HQ/Regions pull data from CERCLIS to support negotiation of:
1) Final Superfund Comprehensive Accomplishments Plan (SCAP)/STARS FY
93 targets;
2) First quarter FY 93 removals; and
3) Final FY 93 operating plan
17 OPP STARS system closes (third quarter accomplishments)
31 HQ distributes final FY 93 Superfund Program Implementation Manual for IMCs/1
RPMs/OSCs
AUG.
6-25 HQ/Regions conduct negotiations on final FY 93 SCAP/STARS targets and
budget
7 HQ pulls accomplishments data from CERCLIS
31 HQ sends memorandum to Regions on final budgets, targets and measures
SEPT.
4 Regions revise CERCLIS to reflect final budgets, targets and measures
8 HQ pulls data from CERCLIS for first quarter (FY 93) AOA
8 HQ pulls accomplishments data from CERCLIS
21 HQ makes final FY 93 Full Time Equivalent (FTE) distribution
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OSWER Directive 9200.3-01H-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
SEPT. (continued)
25 HQ submits FY 93 first quarter AOA request to the AA SWER and places it in
CERHELP
29 HQ/Regional conference call on final Remedial Action (RA) appropriation
30 HQ distributes final FY 93 Superfund Program Management Manual for Branch/
Section/Unit Chiefs
30 HQ distributes final FY 93 Highlights: Superfund Program Management for
Division Directors
30* Regions input AOA to the Integrated Financial Management System (IFMS)
OCT. QUARTER 1 (FY 93)
5* First quarter AOA approved by the AA SWER and OC
7 HQ pulls 4th quarter FY 92 accomplishments data from CERCLIS and provides
for:
1) A A report;
2) Special Program reports;
3) End-of-year assessment for FY 92; and
4) Entry into OPP system for FY 92 STARS end-of-year accomplishments
NOV.
6 HQ/Regions set FY 93 final targets, including open season changes in CERHELP
6 HQ pulls accomplishments data from CERCLIS
16-20 Regions verify accomplishment data contained in OPP STARS system (fourth
quarter FY 92)
20 OPP STARS system closes (fourth quarter FY 92)
30 Regions complete evaluation of Remedial Investigation/Feasibility Study (RI/FS)
start candidates
HQ sends draft FY 94 Operating Guidance and STARS measures to Regions for
review
Dependent on approval of final appropriation
VI
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OSWER Directive 9200.3-01H-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
Dec. (continued)
7 HQ pulls CERCLIS data for:
1) Second quarter AOA; and
2) FY 94 Congressional Budget
18 HQ submits second quarter AOA request submitted to AA SWER and places it in
CERHELP
31 Regions input AOA to IFMS
JAN. QUARTER 2 (FY 93)
6 Second quarter AOA approved by the AA SWER and OC
8 Regions submit list of non-Federal Facility proposed and final National Priorities
List (NPL) sites that did not receive a removal investigation during calendar year
1992
8 HQ pulls 1 st quarter SCAP data from CERCLIS and baseline FY 94 targets and
measures are developed using SCAP Methodologies
8 HQ pulls accomplishments data from CERCLIS and provides for:
1) Entry into OPP STARS system for first quarter review;
2) Special Program reports; and
3) AA report
12 HQ performs a preliminary run of workload model based on methodologies
15 HQ sends call memorandum containing schedules for semi-annual negotiations
and baseline targets and measures to Regions
15 Regional comments on FY 94 Operating Guidance due
21-27 Regions verify accomplishments data contained in the OPP STARS system
27 OPP STARS system closes
28-29 HQ/Regional Program Management meeting (SCAP/Workload Model)
29 Regions submit Fund mega-site Management Plans for FY 94 to the Hazardous
Site Control Division (HSCD)
FEB.
5 HQ pulls accomplishments data from CERCLIS
Vll
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OSWER Directive 9200.3-01H-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
FEB. (continued)
5 HQ/Regions pull data from CERCLIS to support negotiation of:
1) FY 93 RA schedules;
2) Preliminary SCAP/STARS FY 94 targets;
3) Preliminary FY 94 annual Regional budget; and
4) Budget projections for FY 95 projects
5 HQ pulls national Environmental Indicators (El) data from CERCLIS
18 HQ/Regions begin negotiation of:
1) FY 93 third and fourth quarter targets and budget;
2) FY 94 SCAP/STARS targets and annual Regional budget; and
3) Preliminary FY 95 outyear budget
19 HQ prepares El questions and answers to send to the Regions
26 HQ submits NPL proposed rule to the Office of Management and Budget (OMB)
19
HQ issues final FY 94 Operating Guidance
HQ/Regions complete preliminary negotiations of FY 94 targets
HQ pulls accomplishments data from CERCLIS
HQ pulls data from CERCLIS for enforcement extramural mid-year evaluation
and third-quarter AOA
HQ distributes draft FY 94 Superfund Program Implementation Manual for Re-
gional review
HQ pulls data from CERCLIS for mid-year assessment
HQ pulls CERCLIS data for third quarter AOA
Regions revise CERCLIS to reflect negotiated FY 94 preliminary targets and
measures
HQ runs workload model for preliminary FY 94 FTE distribution
HQ submits third quarter AOA request to the AA SWER and places it in
CERHELP
vui
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OSWER Directive 9200.3-01H-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
March (continued)
30 HQ sends memorandum to Regions on preliminary targets and FTEs
31 Regions input AOA to IFMS
31 Regional response to HQ El questions and answers
APRIL QUARTER 3 (FY 93)
1 HQ issues Addendum for FY 94 Operating Guidance
5 Third quarter AOA approved by the AA SWER and OC
6 Regional comments on FY 94 Superfund Program Implementation Manual due
7 HQ pulls accomplishments data from CERCLIS and provides for:
1) Entry into OPP system for second quarter review;
2) AA report; and
3) Special Program reports
12-16 Change Management Council Meeting
14 Regions submit current FY STARS amendment requests to HQ
20-26 Regions verify accomplishments data contained in OPP STARS system (second
quarter accomplishments)
22 Regions submit data sheets on Remedial Design (RD) projects that will lead to a
FY 94 RA start
26 OPP STARS system closes (second quarter accomplishments)
30 HQ distributes FY 92 El analysis to HQ/Regional managers
MAY
7 HQ pulls accomplishments data from CERCLIS
7 HQ pulls SCAP planning data for outyear budget (FY 95)
15 All Regional NPL site fact sheets must be updated by the Regions in NPL-PAD
21 HQ distributes final FY 94 Superfund Program Implementation Manual
31 HQ submits NPL final rule to OMB
IX
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OSWER Directive 9200.3-01H-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
JUNE
HQ pulls CERCLIS data for fourth quarter AOA
HQ pulls accomplishments data from CERCLIS
HQ distributes draft FY 94 Superfund Program Management Manual
7
7
9
11
HQ/Regions complete negotiations on FY 93 fourth quarter AOAs for RD/RA,
removal, and enforcement
11 HQ sends call memorandum and FY 94 proposed Regional budget to the Regions
for semi-annual negotiations
18 HQ submits fourth quarter AOA request to the AA SWER and places it in
CERHELP
25 Regional comments on FY 94 Superfund Program Management Manual due
30 Regions submit enforcement mega-site management plans to the Office of Waste
Programs Enforcement (OWPE)
30 Regions input AOA to IFMS
JULY QUARTER 4 (FY 93)
6 Fourth quarter AOA approved by the AA SWER and OC
8 HQ pulls accomplishments data from CERCLIS and provides for:
1) Entry into OPP STARS;
2) Special Program reports; and
3) AA report
8 HQ/Regions pull data from CERCLIS to support negotiation of:
1) Final SCAP/STARS FY 94 targets;
2) First quarter FY 94 removals; and
3) Final FY 94 operating plan
9 HQ distributes final FY 94 Superfund Program Management Manual
22-27 Regions verify accomplishments data contained in OPP STARS system (third
quarter accomplishments)
23 HQ distributes final FY 94 Superfund Program Management Highlights
27 OPP STARS system closes (third quarter accomplishments)
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OSWER Directive 9200.3-01H-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
AUK.
6 HQ pulls accomplishments data from CERCLIS
9-20 HQ/Regions conduct negotiations on final FY 94 SCAP/STARS targets and
budget
HQ sends memorandum to Regions on final budgets, targets and measures
HQ submits NPL proposed rule to OMB
31
31
SEPT.
8 Regions revise CERCLIS to reflect final budgets, targets and measures
8 HQ pulls data from CERCLIS for first quarter FY 94 AOA
HQ pulls accomplishments data from CERCLIS
HQ performs final FY 94 FTE distribution
8
20
24
HQ submits FY 94 first quarter AOA request to the AA SWER and places it in
CERHELP
30* Regions input AOA to IFMS
OCT. QUARTER 1 (FY 94)
5* First quarter AOA approved by the AA SWER and OC
7 HQ pulls accomplishment data from CERCLIS and provides for:
1) Special Program reports;
2) AA report;
3) Entry into OPP system for FY 93 STARS end-of-year; and
4) FY 93 end-of-year assessment
NOV.
5
5
HQ pulls accomplishment data from CERCLIS
HQ/Regions set FY 94 final targets, including open season changes in CERHELP
18-24 Regions verify accomplishments data contained in OPP STARS system (fourth
quarter FY 93)
24 OPP STARS system closes (fourth quarter FY 93)
Dependent on approval of final appropriation
XI
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OSWER Directive 9200.3-01H-2
MANAGER'S SCHEDULE OF SIGNIFICANT EVENTS (continued)
Nov. (continued)
24 Regions complete evaluation of FY 95 RI/FS start candidates
30 HQ submits NPL final rule to OMB
HQ sends draft FY 95 Operating Guidance and STARS measures to Regions for
review
HQ pulls CERCLIS data for:
1) Second quarter AOA; and
2) FY 95 Congressional budget
HQ pulls accomplishments data from CERCLIS
HQ submits second quarter AOA request to AA SWER and places it in CERHELP
Regions input AOA to IFMS
xu
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OSWER Directive 9200.3-01H-2
CHAPTER I
PROGRAM GOALS AND PRIORITIES
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OSWER Directive 9200.3-01H-2
CHAPTER I - PROGRAM GOALS AND PRIORITIES
ONE MINUTE PROGRAM MANAGER RULES
Following are the actions Regional managers must take to comply with the
requirements described in this Chapter. In order to acquire a more in-depth
understanding of these requirements, the Chapter itself should be read.
Efficiency
Regions should submit projects to pilot the new Superfund Accelerated
Cleanup Model (S ACM) to the Superfund Revitalization Office.
In Fiscal Year 1993 (FY 93), incentives have been established for performing
quick response actions at National Priorities List (NPL) sites.
- The scope of site evaluations should include a determination of whether
there are opportunities for quick response.
- Regions must review half of their NPL sites each calendar year to ensure no
immediate threats have arisen.
- By January 7,1993, each Region needs to submit documentation on the
proposed or final non-Federal Facility NPL sites that were evaluated during
calendar year 1992.
- A $50 million set aside from the Remedial Action (RA) budget can be used
for quick response projects. Projects under $2 million and projects up to $5
million that contribute to substantial risk reduction, constitute a significant
interim action, or lead to site completion/NPL deletion may be funded.
Trend measures to assess time efficiency of the remedial pipeline in each
Region are being implemented.
The standard planning durations for response and enforcement activities
contained in the Integrated Timeline should only be used if more accurate
timeframes are not available. When better planning data and schedules are
developed, the Comprehensive Environmental Response, Compensation and
Liability Information System (CERCLIS) must be revised.
Regions are urged to use Site Management Plans (SMPs) to ensure that proper
funding, enforcement activities, and management responsibilities are laid out
for a site.
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OSWER Directive 9200.3-01H-2
CHAPTER I - PROGRAM GOALS AND PRIORITIES (Cont.)
ONE MINUTE PROGRAM MANAGER RULES
Effectiveness
In FY 93, site construction completions and NPL deletions are a high
priority.
- Prepare the Preliminary Site Close-Out Report as soon as
possible after construction is complete at the final OU.
- Prepare Interim and Final Superfund Site Close-Out Reports as
soon as possible after accepting the RA Report for the final RA.
- Shift sites into the Construction Complete category following
approval of Interim or Final Superfund Site Close-Out Reports.
- Removals that complete all remediation necessary at NPL sites
require completion of an Action Memoranda and a Record of
Decision (ROD) that documents that the site meets the statutory
requirements for site closeout.
Conduct five year reviews for appropriate sites so they are completed
within five years of award of RA contract.
Regions are required to develop and submit Mega-site Management
Plans for Fund-financed Remedial Investigation/Feasibility Study
(RI/FS) projects if their costs exceed or are expected to exceed $3
million, or for enforcement projects where management costs are more
than $200,000 per year for removal oversight and litigation support and
$500,000 per year for RI/FS oversight.
Establish and enter into CERCLIS site assessment decisions/priority
recommendations at each step of the evaluation process.
Regions should continue efforts to accelerate site cleanup and transfer
of property at Federal Facility closing bases.
Eauitv
Regions should evaluate sites and the Potentially Responsible Parties
(PRPs) to determine if an early de minimis settlement is appropriate.
The President has set a goal of recovering $300 million in FY 93 in his
Management by Objectives (MBO) system.
I-ii
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OSWER Directive 9200.3-01H-2
CHAPTER I - PROGRAM GOALS AND PRIORITIES
OVERVIEW OF PROGRAM GOALS
The focus of the Superfund program is to maximize the protection of human health and the
environment through fast, effective cleanup of priority hazardous waste sites and releases.
Maximizing appropriate participation of Potentially Responsible Parties (PRPs) and timely
remediation of sites, including Federal Facilities, are two of the Superfund program's highest
priorities.
FY 93 Themes
Fiscal Year 1993 (FY 93) is a critical year for the Superfund program as the Environmental
Protection Agency (EPA) enters the final year of the three-year extension to the Superfund
Amendments and Reauthorization Act of 1986 (SARA). Accomplishments in FY 93 will be the
most significant indicators of the program's performance. New initiatives are being proposed that
embody the Agency's vision for the future and reflect the application of three key principles:
efficiency, effectiveness, and equitability.
Efficiency and effectiveness initiatives will reduce the timeframe for moving sites through
the remedial pipeline and increase the number of site completions/National Priorities List (NPL)
deletions. An increase in the number of d£ minimis settlements, the allocation of equitable costs to
municipalities, and the pursuit of non-settlors will improve the Superfund program's equity in
dealing with the PRPs.
The following themes are highlighted in FY 93 in order to achieve these program goals and
principles:
Accelerate and streamline the Superfund pipeline to mitigate risk and produce an
increase in the number of construction completions and NPL deletions;
Accelerate cleanup at closing military bases on the NPL and expedite property
transfer;
Reduce risks by performing quick response actions at priority sites, including
effective pilot testing of the Superfund Accelerated Cleanup Model (S ACM);
Achieve early and appropriate settlements with collateral PRPs, including dfi
minimis parties and municipalities;
Regions should consider use of all relevant enforcement tools and apply these tools
to given situstions, e.g., Administrative Order on Consent (AOC), Consent Decree
(CD), Unilateral Administrative Order (UAO), use of the Fund, cost recovery, de_
minimis or mixed funding;
Select the best cases for cost recovery so as to ensure cost effective litigation (both
administrative and judicial) to maximize cost recovery to the Trust Fund;
Effectively communicate program progress through Environmental Indicators (El)
and other related initiatives;
Ensure effective management of contracts; and
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OSWER Directive 9200.3-01H-2
Further the use of innovative treatment technologies to permanently cleanup sites.
Use Federal Facilities to develop innovative technologies that reduce the cost and
time of cleanup.
A Framework for Setting Priorities
Over the past few years, Regional personnel have been told that "enforcement first," worst
sites/worst problems first, and completions/deletions are each the highest program priority.
Although it is frequently possible to address all priorities, it is not always possible to optimize
them. This section will address the reconciliation of the competing priorities of the Superfund
program.
The highest priority of the Superfund program is the management of imminent risk to
human health and the environment. Once it is determined that the site poses no imminent
risk, the Agency moves on to other priorities. All other activities in the Superfund program are
directed toward optimizing completion of construction at sites (and deletion where
feasible), while using enforcement tools to ensure maximum PRP involvement.
Addressing worst sites/worst problems first is a guiding principle within
the context of the goal of optimizing the number of completions, as well as when
the choices made do not affect the number of completions. When cleaning up sites,
decisions should be focused on ensuring risk reduction and addressing the worst problems at the
worst sites first. Records of Decisions (RODs) that will document completion of site remediation
will often have priority over sites that have been stabilized, but will take longer to bring to
completion. Although imminent threats have been addressed, and the site is "under control," there
may be times where the tentativeness of the control warrants that the problem or site be given a
higher priority than a site moving toward completion. Common sense and public welfare must
guide the manner in which the priority given to completions is reconciled with the emphasis on
reducing risk at the worst sites first.
Enforcement first should remain an objective while balancing the need to expedite
completions/deletions. When PRPs are recalcitrant, the Region must determine what mix of Fund
and enforcement tools should be used to move the site expeditiously to cleanup. Both a UAO and
Fund-financed action should be considered. If UAOs are issued and the PRPs do not comply, a
Fund-financed cleanup should be considered as appropriate to ensure that the site moves forward
quickly, and then treble damages pursued.
One of the tools used by the Agency to reconcile the competing Superfund priorities is the
Integrated Priority Setting Matrix. The Matrix was initially developed in 1989 by the Office of
Waste Programs Enforcement (OWPE), the Office of Emergency and Remedial Response
(OERR), and the Regions. It is evaluated on a yearly basis to ensure that the latest program
priorities are accurately reflected. The Matrix is used by OERR, OWPE, the Office of Federal
Facilities Enforcement (OFFE), and the Office of Enforcement (OE) to allocate resources in
Superfund to the highest priority activities. The Integrated Priority Setting Matrix is described in
the following section.
Integrated Priority Setting Matrix
The Integrated Priority Setting Matrix shown in Exhibit 1-1 has been reorganized to reflect
the key principles in FY 93 of efficiency, effectiveness and equity. The new Matrix is designed to:
Identify the most significant program priorities that support the three key principles;
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OSWER Directive 9200.3-01H-2
List the major activities or tools that receive resources, grouped according to their
contribution to a program priority; and
Arrange the program priorities and major tools in order of importance, where
possible.
The Matrix provides a framework for establishing, testing and adjusting resource levels.
This Matrix will be used by Headquarters (HQ) and the Regions in making trade off decisions
during:
FY 94 budget formulation;
FY 93 operating plan development, target setting and negotiation; and
FY 93 mid-year adjustment.
The overall organization of the Matrix is governed by the following concepts:
All of the activities listed in the Matrix contribute in a significant manner to
Superfund program success. Therefore, priority setting must be couched in terms
of maintenance of an essential minimum baseline of activity across the board; and
A baseline of activities must be supported to ensure that a constant flow of projects
is maintained across the remedial and removal pipelines, and that the entire program
maintains its operating integrity.
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OSWER Directive 9200.3-01H-2
EXHIBIT 1-1
INTEGRATED PRIORITY SETTING MATRIX
PROGRAM
THEME
PROGRAM PRIORITIES
TOOLS
Reduce risks by performing
quick response actions at Federal
Facility and non-Federal Facility
sites; Ensure that resources are
available for time critical
removals
Classic Emergencies (Fund and PRP)
National Priorities List (NPL) Removals/
Expedited Response (Fund, PRP and Federal
Facility)
Emphasize enforcement first in
Superfund actions; Regions
should be prepared to take action
promptly after the negotiation
moratorium deadlines
Remedial Design (RD)/Remedial Action (RA)
Negotiations
Section 106 Settlement Referrals
Section 106 Unilateral Administrative Orders
(UAOs)forRD/RA
Mixed Funding for RD/RA
Administrative Orders (AO) for Removals
Federal Facility Interagency Agreements (LAG)
Remedial Investigations/Feasibility Study (RI/FS)
Negotiations
AOs for Non-NPL Time Critical Removals
Accelerate and streamline the
Superfund pipeline; Accelerate
cleanup at closing military bases
and expedite property transfer
NPL Base Closures
Superfund Accelerated Clean-up Model (SACM)
RA Starts (Fund, PRP and Federal Facility)
RD Starts (Fund, PRP, and Federal Facility)
RI/FS Starts (Fund, PRP, and Federal Facility)
Site Assessment (Preliminary Assessment
(PA)/Site Inspection (SI), Listing)
Non-NPL Time Critical Removals
Increase the number of site
completions and NPL deletions
Complete Ongoing RAs
Prepare and Approve RA Reports,
Preliminary Site Close-Out Reports,
Interim Site Close-Out Reports and Final
Superfund Site Close-Out Reports
Delete Sites from the NPL
Five Year Reviews
Complete Ongoing RDs
Complete Ongoing RI/FSs
Consider use of all relevant
enforcement tools and apply
these tools to given situations
Section 104 Access
Section 106 Litigation to Enforce UAOs
Compliance Enforcement
Section 106/107 Litigation
Section 106 Litigation
1-4
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OSWER Directive 9200.3-01H-2
EXHIBIT 1-1 (Continued)
INTEGRATED PRIORITY SETTING MATRIX
PROGRAM
THEME
PROGRAM PRIORITIES
TOOLS
co
Effectively communicate
progress in the Superfund
program
Pilot Projects to Support Efficiency,
Effectiveness and Equity
Environmental Indicators
Technical Assistance Grants
Community Relations
Administrative Record (Removal and
Remedial)
Ensure effective management
of activities that support the
Superfund program; Further
the use of innovative
technologies to permanently
clean Up Sites
Innovative Technologies
Contract Management
Contract Laboratory Program
Removal Support
Remedial Project Support
Comprehensive Environmental Response,
Compensation and Liability Information
System (CERCLIS) Data Base
Management
Records Management
Program Management
Achieve early and appropriate
settlements with collateral
PRPs
Select the best cases to ensure
cost effective litigation and to
maximize recovery to the Trust
Fund
Take actions to Identify PRPs
De minimis Settlements
Settlements with Municipalities
Section 107 Statute of Limitation (SOL) Cost
Recovery Referrals
Section 122 Administrative Settlements
Section 104(e) Referrals
NPL PRP Searches
Non-NPL PRP Searches
Enter into Cooperative
Agreements, Superfund
Memoranda of Agreement or
other management assistance
agreements
Core Program Cooperative Agreement
(CPCA)
State Program Support
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EFFICIENCY
A major theme of the Superfund program is an aggressive, well planned and tightly
coordinated system for moving sites to completed remediation, while maximizing the participation
of the PRPs. This has led to the development and implementation of a number of program
initiatives. These initiatives, as well as the supporting response and enforcement goals and
priorities, are discussed in this section.
Superfund Accelerated Cleanup Model (S ACM)
The Office of Solid Waste and Emergency Response (OSWER), through its continued
investigation of ways to make the Superfund program more efficient, has developed a model for
streamlining and accelerating the Superfund program. (See OSWER Directive 9203.1-03,
Guidance on Implementation of the Superfund Accelerated Cleanup Model (S ACM) under
CERCLA and the NCP, July 7,1992.) This model concept is designed for a dual purpose: to
make the Superfund program work better and to communicate success in risk reduction to the
public. The model:
Combines and eliminates steps in the Superfund process;
Identifies all sites/releases at which Superfund takes action as "Superfund sites";
Shortens timeframes for performing cleanup actions at all Superfund sites; and
Achieves immediate risk reduction by tackling the worst sites first using removal
and/or remedial authority.
The model will deliver results the public will value:
Quick reduction of acute risks at all Superfund sites (removal and remedial); and
Restoration of the environment over the long term.
The SACM, which is presented in Exhibit 1-2, includes:
A one-step site screening and risk assessment at the front end of the process to
expedite cleanup and blend removal and remedial cultures;
Establishment of multi-disciplinary Regional Decision/Management Teams to serve
as "traffic cops" for moving sites to early response action or long-term action. This
team will also develop standards for remediation levels and technologies;
Reduction of immediate risk by performing early actions;
Implementation of long-term actions to restore the environment/media. These sites
wifi require years to clean up but pose no immediate threat; and
Involvement of enforcement, community relations and the public throughout the
process.
The compressed schedule for the SACM initiative will require early and continuous
consultations with the State and local communities. For many site assessments and early action
activities, this interaction will be essential to the success of SACM projects.
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Each of the elements of the S ACM are discussed in the following sections and presented in
Exhibit 1-3. The information in this Manual does not address the unique issues associated with
implementation of the S ACM at Federal Facilities. Supplemental guidance on those issues is under
development. In FY 93, continuing the phased implementation of the S ACM concept will be a
high priority. The results of the pilots will be used to develop and refine the procedures for
implementing S ACM to cleanup sites. Nationwide implementation of the SACM is expected in FY
94. As a result, the information in this Manual will not reflect the concepts of SACM.
Site Assessment
One of the major initiatives of SACM is to break down institutional barriers within the
Agency, and to establish an operational scheme under which data are collected and used to
serve multiple purposes. The National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) contemplates that the Agency will sequentially perform (as
warranted) a removal Preliminary Assessment (PA) and Site Inspection (SI), a remedial PA
and SI, and ultimately a Remedial Investigation (RI). These various studies can be
consolidated in appropriate cases under the SACM model such that one site assessment can
be performed and one site assessment report written. The report should, however, include
findings required by the NCP for moving from one phase of site assessment to another.
By using data for multiple purposes, economies can be achieved in terms of the amount of
sampling needed, expertise and learning can be shared among officials responsible for the
various tasks undertaken at a site, and the time between data collection and action (if
deemed necessary) can be shortened. Specifically, if and when sufficient information is
gathered during the combined site assessment, the Agency may commence an early action,
a Hazard Ranking System (HRS) scoring package, or ultimately a long-term action. This
consolidation could save years in the site evaluation phase of the Superfund process.
Regional Decision Team (RDT)
The RDT is cornerstone to the day-to-day implementation of SACM. It is envisioned that
there will be one or several RDTs functioning simultaneously to provide adequate coverage
for all sites in the remedial pipeline. The RDTs will have decision responsibility for select
activities, such as site "triage" (i.e., determining the initial responses required to minimize
risk), and follow up actions (i.e., site sampling strategy). In addition, the RDT will be
responsible for developing and recommending alternatives to upper management for
signature of the Action Memorandum and/or ROD.
True emergency situations may be initiated outside the RDT structure when required to
accelerate on-site response.
While it is expected that RDTs will have some features that are standard, there is Regional
flexibility. The following is a general discussion of the make-up and role of the RDT that
may be implemented:
Make-up of the RDT - The RDT is expected to be composed of a Core Group, with
a Team Leader, and a Support Group. During the initial start-up of SACM, the
Team Leaders for the RDTs are expected to be Branch Chiefs. The remainder of
the Core Group includes the Remedial Project Manager (RPM)/On-Scene
Coordinator (OSC), Office of Regional Counsel (ORC) and a site assessment
representative. The Core Group will identify the make-up of the Support Group. It
is strongly encouraged that all Support Groups include a State representative.
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Role of the RDT - The RDT will guide the project from site discovery through site
close-out. Decision authority for specific key milestones of the project (i.e.,
determining appropriate initial responses required to minimize risk and helping to
set response priorities) will generally be the responsibility of the Core Group and
more specifically the Team Leader. The Support Group will provide information
and consultation to the Core Group as needed. It is the responsibility of the Team
Leader to ensure the RDT expedites the site process and the goals of the S ACM are
realized on a site specific basis.
Early Actions
The purposes of early actions are to respond to emergencies and to eliminate or achieve a
quick reduction of risks. The EPA will continue to use the removal authorities in the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA) and the NCP to respond to emergency and time critical situations (actions must
be initiated in less than six months). In non-time critical situations, where a planning
period of at least six months exists, both non-time critical removal and early action remedial
authorities could be used to reduce risk.
A non-time critical removal action must include an analysis of alternatives in an Engineering
Evaluation/Cost Analysis (EE/CA) and the public must be afforded 30 calendar days to
comment on the proposed removal alternative before it is selected. It is also anticipated that
it will generally be practicable for non-time critical removal actions to attain most Applicable
or Relevant and Appropriate Requirements (ARARs). Finally, in order to assure the public
that the non-time critical removal action will be of high quality, Agency policy will be to
implement a preference for treatment and conduct a baseline risk assessment, where
appropriate, before selecting a response action.
An early remedial action may be either a final or interim remedial action. An early remedial
action can be taken during scoping or at other points during the Remedial Investigation/
Feasibility Study (RI/FS) process. Due to its use early in the remedy evaluation process,
less documentation is required for the ROD for an interim remedial action than for a final
ROD; however, adequate documentation must be provided to justify the action. (See
OSWER Directive No. 9355.3-02FS-3, "Guide to Developing Superfund No Action,
Interim Action, and Contingency Remedy RODs," April 1991.)
In making a decision as to which authority to use in the non-time critical situation, the
following issues should be considered:
NPL status - Non-time critical removal actions can be performed at both NPL and
non-NPL sites. However, Fund financed remedial construction can only be
performed at final NPL sites.
Site complexity - Sites with complex sources of contamination should be addressed
under remedial authority.
Cost and duration - Fund-financed removal actions exceeding $2 million or 1 year
must be accompanied by an analysis supporting an exemption. The exemption will
most likely be based on a finding that the removal action is consistent with the
remedial action to be taken at a NPL site.
State cost share - Although State cost share is not required for a removal action, the
absence of a State's financial participation may limit EPA's ability to fully fund
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OSWER Directive 9200.3-01H-2
certain actions. Regions may want to seek voluntary State funding on a site-by-site
basis.
Operation and Maintenance (Q&M^ Where a proposed Fund-financed removal
action would require the performance of measures to maintain the effectiveness of
the action, the State's willingness to perform these measures should be evaluated.
PRP involvement - Non-time critical removal actions may be performed by the
PRPs under an AOC. If the PRPs seek judicial approval of a settlement (CD) or
there are multiple parties, an early remedial action may be more appropriate.
Public involvement - High visibility sites are more likely to require the use of
remedial authorities to ensure community and State involvement in the remedy
selection process. In non-time critical removal situations, the public must be given
not less than 30 calendar days to comment on the proposed removal alternative
before it is selected. The remedial action proposed plan is also available to the
public for no less than 30 calendar days prior to remedy selection. In addition, the
EPA conducts a public meeting on the proposed plan.
Resource availability - Resource (dollars, Full Time Equivalents (FTEs),
contractual) availability within the Region may dictate the use of one type of
authority over the other.
Long -Term Actions
The purposes of long-term actions are site remediation activities including groundwater
restoration and other resource and time intensive activities. The Agency will continue to
use remedial action authorities to respond to most long-term contamination problems. Key
considerations for using long-term actions are:
The sites must be listed on the NPL to expend Federal dollars on Remedial Action
(RA);
Response actions require significant resources;
Long term O&M;
Permanent relocation and/or the acquisition of real estate by EPA is required; or
Other factors, such as cost recovery or enforcement strategy considerations.
Involvement of Enforcement
The SACM goal of accelerating cleanups is not intended to replace other important goals,
such as the Agency's general policy of enforcement first. Therefore, it will be necessary to
carry out PRP searches early in the site assessment process. An early and effective PRP
search will allow the Agency to pursue an effective enforcement strategy for non-time
critical early actions. In addition, early identification and notice to the PRPs will strengthen
EPA's cost recovery case in Fund-financed situations.
Quick Response
Two of the goals of the SACM, streamlining cleanup actions and reducing risk using
remedial and/or removal authorities, are not new. In the past, the Agency has encouraged the use
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OSWER Directive 9200.3-01H-2
of removal authorities to perform quick response actions (i.e., Initial Remedial Measures (IRMs)
and Expedited Response Actions (ERAs)). In FY 91 and FY 92, a variety of contracting
mechanisms were implemented that provided the capability to perform these actions.
During site evaluation phases, including the PA and SI, removal assessment or scoping for
the RI/FS, the RPM or OSC should determine if the site is safe. A part of the site evaluation is a
determination of the need for surface cleanup that will reduce risk and can be accomplished quickly
through the use of removal/remedial authorities.
Quick response actions are designed to eliminate surface waste/chemicals, barrels, tanks,
pits, ponds, and lagoons. They also serve to develop information for use in the RI/FS scoping.
When evaluating the potential for a quick response, the following criteria should be considered:
The cleanup actions should be well defined, of low to moderate technical
complexity, use a proven technology, have existing field information readily
available, and have a low to moderate cost to complete. Examples are surface
cleanup, soil excavation, interim groundwater plume controls, tank or structure
demolition, and impoundment closure.
A project should not be divided up and expedited just to "turn dirt" The decision to
perform a quick response should be based on an attempt to reduce risks and
compress the critical path for pipeline remedial activities. The actions must be
consistent and appropriate to the other response actions being performed at the site.
Before an action is taken, certain enforcement issues need to be addressed - Are
willing and viable PRPs that are able to produce quality products involved? Are
these PRPs interested in conducting quick response actions?
These criteria will assist the Region in a decision as to whether to conduct a quick response
action at the site.
Financial Considerations
To provide incentives for quick response actions at remedial sites, the following
management procedures are in place:
$50 million dollars is set aside in the RA budget to be used for quick response
projects. This funding is available on a first ready, first funded basis. It is not for
emergencies or time critical actions, but for getting a head start or fast start on
remedial work.
Quick response projects should be less than $2 million, but projects up to
$5 million may be approved by HQ. These projects must demonstrate one or more
of the following:
Substantial contribution to risk reduction;
Significant interim action; or
Activities lead to completion or deletion.
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OSWER Directive 9200.3-01H-2
Authorities and Contracting Strategies
A separate determination needs to be made on which authority and contract vehicle will be
employed. EPA is planning to award several new Emergency Response Cleanup Services
(ERCS) contracts that may have the capability and capacity to perform rapid response
actions. Under the remedial program, the Alternative Remedial Contracting Strategy
(ARCS) contractor performing RI/FS activities may be tasked by the RPM to conduct quick
response actions. Typically, the ARCS contractor will be able to subcontract for work of
this nature. EPA has also developed a Prequalified Offerers Procurement Strategy, which
provides a list of prequalified contractors that have the capability to perform specified
technologies. The U.S. Army Corps of Engineers (USACE) has rapid response contracts
for demolition actions, closures, point source contamination controls, and site stabilization
for use by EPA. Finally, separate site-specific contracts should be considered.
Procedures for Quick Response
Projects for quick response funding must be identified by the third quarter in order to
guarantee funding. At that point, unplanned and unobligated funds remaining in the quick
response set aside will be placed back in the RA budget and used to fund priority RAs or
quick response projects identified after the third quarter. A Region may request funding for
quick response actions by writing the Director, Emergency Response Division (ERD). The
ERD Director is responsible for coordinating the request with the Hazardous Site Control
Division (HSCD), the Office of Program Management (OPM), and OWPE. The request to
the ERD Director should address the relevant criteria listed earlier in this section to justify
the need for the quick response. The request should be supported by relevant documents.
If the quick response is a rapid remedial response, Regions are encouraged to conduct a
focused Feasibility Study (FS) that will lead to a "thin" or interim action ROD. Guidance
on preparing these RODs was issued in April 1991 ("Guide to Developing Superfund No
Action, Interim Action and Contingency Remedy RODs," OSWER Directive 9355.3-02FS-
3). The ROD must be signed and the Superfund State Contract (SSC) in place prior to
initiating the action. In the event the Region targeted a ROD at a site and a removal will be
performed instead, and there are no other sites available to substitute for the ROD target,
the request for quick response funding should include a request for relief from the ROD
target.
Integrated Timeline for Site Management
Success in implementing the Superfund program depends in large part on identifying
critical decision points and timeframe goals for moving from one phase of activity to the next In
1989, the Agency developed a timeline that provides an overview of the major remedial and
enforcement activities required in the Superfund site cleanup process. The Integrated Timeline
(Exhibit 1-4) is a multi-step site management process that, in the ideal situation, spans 24 quarters.
The Integrated Timeline will be evaluated in the upcoming year in light of the S ACM.
Implementation of the S ACM may result in the elimination of a number of steps and a reduction in
the duration of activities in the timeline.
In FY 93, the Integrated Timeline will continue to be utilized to establish performance
expectations. Performance improvements will be tracked against the Timeline. To embody the
concept of good timeline management, trends analyses will be undertaken. The average duration
will be measuredby Regionfor sites where Remedial Design (RD)/RA negotiation starts or
completions, RD starts or RA starts are planned in FY 93 as follows:
ROD to RD/RA negotiation starts;
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OSWER Directive 9200.3-01H-2
ROD to RD/RA negotiation completions;
ROD to RD start; and
ROD to RA start.
Each of these averages will be reported relative to prior years (FY 91 and FY 92) and prior
quarters performance. In addition, RI/FS start to completion timeframes and RD/RA negotiation
timeframes will also be tracked. (See the Appendix for more information.)
Regions are strongly urged to develop a Site Management Plan (SMP) for a site shortly
after proposal for the NPL. The plan should lay out important enforcement activities that are
essential at the site (PRP searches, issuance of RI/FS special notice, issuance of RD/RA special
notice, RD/RA negotiations, development and finalization of CD, issuance of UAO). These
enforcement activities should be integrated with response events at the site or Operable Unit (OU).
The plan can be used to ensure that funding is requested for the activities and that the proper people
in all affected offices have been brought into the process at the appropriate points. The Agency is
developing guidance to assist the Regions in the preparation of SMPs.
The durations in the Integrated Timeline are goals that should be used if more accurate
estimates are not available. When better planning data and schedules are developed,
the Comprehensive Environmental Response, Compensation, and Liability
Information System (CERCLIS) must be revised to reflect these schedules.
Supporting Program Goals
The following sections described the specific goals that support a more efficient Superfund
program.
Removal
In FY 93, as in the past, the key goal of the removal program is to ensure that resources
are available for time critical removals and not diverted to less critical removal actions.
Regions should prioritize time critical removals in the following order:
Classic emergencies at NPL or non-NPL sites;
Removals at NPL sites; and
Time critical removals at non-NPL sites posing major environmental and
public health threats that can not be addressed by other authorities.
Non-time critical removals at non-NPL sites should be undertaken only as resources allow
and to expedite cleanup in conformance with the worst problems first policy. Non-time
critical removals at NPL sites should be planned and budgeted site specifically. For all
non-time critical removals, Regions should involve States and PRPs to the maximum extent
practicable. In classic emergencies, PRPs should be notified orally and given up to 24
hours to respond, depending on the situation. Oral notification should be followed up in
writing. For time critical removals, enforcement activities (PRP searches, negotiations and
issuance of an order) should be initiated as soon as the site is identified, and scheduled for
completion based on the timing of the removal start.
Regions have the responsibility of reviewing half their NPL sites each calendar year to
ensure no immediate threats have arisen. By January 7,1993, each Region needs to
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OSWER Directive 9200.3-01H-2
submit documentation on the completed evaluations of those non-Federal Facility proposed
and final NPL sites that were evaluated during calendar year 1992. The documentation that
must be submitted includes memoranda signed by a Regional Division Director and sent to
the Regional Administrator with a copy to the Director ERD, along with a copy of the
CERCLIS report RMVL-12, Summary of NPL Site Evaluations Conducted in Calendar
Year. This CERCLIS report is to be used to document sites where a biennial NPL site
evaluation was conducted in the last calendar year.
Enforcement
One of the goals of the enforcement program is to maximize efficient use of PRP resources.
To reach this goal, the following priorities have been identified for FY 93:
Aggressively seek settlement for PRP response with more parries Regions are
encouraged to use SMPs to lay out negotiations responsibilities among the parties
involved and timeframes for deliverables. Well planned negotiations need to be
initiated and completed within the special notice moratoria or schedules presented in
general notice letters.
RD/RA Negotiation process Regions should manage the RD/RA negotiation
process within the timeframes established under Section 122. Special Notice
Letters (SNLs) should be issued in a timely manner. Regional Administrator or
Assistant Administrator (AA) extensions should be used only where settlement
appears likely.
Section 106 Settlements Regions should be prepared to issue a UAO promptly
after the negotiation moratorium deadlines if there are viable PRPs and a settlement
has not been reached. UAOs with delayed effective dates should also be considered
in order to encourage the successful conclusion of negotiations. If a Fund-financed
response is initiated, all steps should be taken to seek treble damages against
recalcitrant PRPs during cost recovery.
Removal enforcement Regions should work to maintain or increase the
percentage of removals conducted by PRPs, particularly time critical and non-time
critical removals. In this effort, Regions should commence PRP searches early to
assess whether there are viable and liable PRPs. Where this is the case and an AOC
can not be negotiated, Regions should issue UAOs and, in cases of non-
compliance, pursue cost recovery. Regions are required to support their removal
enforcement decisions in action memos and other appropriate documents. A sound
administrative record will be the Agency's key to defending itself against Section
106(b) claims from PRPs seeking reimbursement for their removal costs. As the
Superfund program uses more UAOs to compel response, there are likely to be
more claims.
Site Assessment
Site assessment demands are expanding and Regions are encountering more requirements
in screening sites and making worst sites first decisions. To ensure that the worst sites
enter the cleanup process first, the site assessment program has established the following
goals:
Renewed and expanded emphasis on the removal program coordination. State,
ARCS, and EPA staff conducting PAs, site reconnaissance and Sis should consider
the need for removal activities at all sites evaluated. Removal personnel must be
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OSWER Directive 9200.3-01H-2
notified in all instances where evidence of potential fire, explosion, or direct
exposure hazards exist or where removal activities may substantially improve a
hazardous situation. Also, new policies on consideration of removals in HRS
scoring increases the need for removal and site assessment coordination.
Make substantial progress on SI priorities. Resources will be provided in FY 93 to
collect data as needed to determine a priority for sites that have had an SI in the
past, but require further work in order to 1) make a decision on whether to proceed
with HRS ranking and NPL proposal, or 2) make a determination that the site
evaluation is complete. Over 6,000 sites have completed Sis and need to be
evaluated for inclusion on the NPL. The overreaching site assessment goal is to set
priorities for screening and listing the highest priority sites first. Each Region will
need to work with HQ to determine its most balanced priorities/workload and
division of labor with its States.
Continue EPA's policy of conducting PAs within one year of CERCLIS listing in
order to prevent the build-up of a PA backlog.
Perform PAs and HRS scoring at Federal Facilities to achieve SARA goals.
Implement the revised HRS. Use the HRS to rank sites for proposal to the NPL.
An update to the NPL is scheduled for publication in the Federal Register (FR)
semi-annually.
Federal Facilities
Superfund Federal Facilities enforcement remains a key Agency issue because of the high
visibility and significant threat posed by military sites; the impact of military base closings;
the significant resources needed to oversee Department of Defense (DoD)/Department of
Energy (DOE) efforts at NPL sites; and heightened public interest. Federal Facilities
program goals for FY 93 are based on a number of interacting factors, including overall
Superfund program goals, anticipated resource constraints, Congressional interest, and
statutory requirements. Program activities and resources should be planned to achieve the
following goals:
Facilitating property transfer at military base closure sites;
Improving program efficiencies through accelerated response (including the use of
removal authorities);
Continuing integration of the Resource Conservation and Recovery Act (RCRA)
and CERCLA through the use of Interagency Agreements (lAGs);
Using of innovative technologies and pollution prevention principles;
Compliance with statutory timeframes (i.e., LAG, ROD and RA);
Enhanced oversight of base closure actions; and
Improved formal and informal HQ/Regional interaction, including workgroups.
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OSWER Directive 9200.3-01H-2
EFFECTIVENESS
There are a number of program priorities that focus on the effectiveness of the Superfund
program in cleaning up hazardous waste sites and releases. The highest priority in FY 93 is the
completion of construction activities and the subsequent deletion of sites from the NPL. The
Strategic Targeted Activities for Results System (STARS) is one of the tools used by the Agency to
track progress toward Superfund site cleanup.
Completions/Deletions
The Preamble to the NCP describes the "Construction Completion" category of the NPL.
The category consists of:
Sites awaiting deletion; and
Sites undergoing Long Term Response Action (LTRA).
EPA shifts sites into the NPL Construction Completion category only after approval of
Interim Site or Final Superfund Site Close-Out Reports (final RA completion). Approval of an
Interim Site Close-Out Report indicates that construction of the remedy is complete and that it is
operating properly, but that the remedy must operate for a period of time before achieving cleanup
levels specified in the ROD. Approval of the Final Superfund Site Close-Out Report indicates that
the remedy has achieved protectiveness levels specified in the ROD, and that all site activities
except O&M are complete.
On October 2,1991, the EPA Administrator announced targets for sites where all
construction has been completed. The target includes 130 sites by the end of FY 92,200 sites by
the end of FY 93, and 650 sites by the end of FY 2000. In order to meet this goal, construction
activities for the final OU must be complete, a pre-final inspection conducted, and a Preliminary
Close-Out Report must be signed by the designated Regional official (final RA NPL site
construction completion). The Preliminary Close-Out Report documents the completion of
physical construction, summarizes site conditions and construction activities, and provides, as
appropriate, the schedule for the final inspection, Operational and Functional (O&F) phase,
approval of the O&M work plan, and the establishment of institutional controls.
LTRA sites may be recategorized in the awaiting deletion category upon attainment of the
final remediation goals. A site requiring only O&M at the time of construction completion may be
recategorized as awaiting deletion until the process of reviewing the site for deletion from the NPL
has been completed.
Section 300.425(e) of the NCP states that "Releases may be deleted from or re-categorized
on the NPL where no further response is appropriate." It further states that in making a
determination to delete a release from the NPL, EPA shall consider, in consultation with the State,
whether any of the following criteria has been met:
PRPs or other persons have implemented all appropriate response actions required;
All appropriate Fund-financed responses under CERCLA has been implemented
and no further response actions by the PRPs are appropriate; or
The RI has shown that the release poses no significant threat to public health or the
environment and, therefore, taking of remedial measures is not appropriate.
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While the current focus remains on site completions, a priority remains to delete sites from
the NPL when appropriate. Close-Out Reports and Federal Register notices for sites eligible for
recategorization as completions or for deletion from the NPL should be prepared and submitted
promptly to ensure that progress is accurately conveyed to those outside the Agency. Interim and
Final Superfund Site Close-Out Reports should be completed no later than the quarter following
EPA acceptance of the RA Report for the final RA. NPL sites that have been completed and RA
completions are targeted in the STARS in FY 93.
Five Year Reviews
SARA requires EPA to review those remedial actions that result "...in any hazardous
substances, pollutants, or contaminants remaining at the site..." no less often than every five years
after implementation. The NCP states that RAs that result in hazardous substances, pollutants, or
contaminants remaining at the site "...above levels that allow for unlimited use and unrestricted
exposure..." shall be reviewed no less than every five years after initiation of the selected RA. In
the Superfund Management Review, the Administrator decided that EPA would not delete from the
NPL sites that require SARA reviews until at least one review had been completed. This policy
was later rescinded by a notice in the Federal Register (56FR 6601, December 24,1991).
The Agency must report to Congress on five-year reviews and actions taken in response to
such reviews. On May 23,1991, OERR issued OSWER Directive 9355.7-02, entitled "Structure
and Components of Five-Year Reviews." This guidance defines the scope of five-year reviews
and identifies two types of reviews: statutory reviews (i.e., reviews required by CERCLA and the
NCP) and policy reviews (i.e., reviews that EPA will implement as a matter of policy). Each
Region must schedule statutory reviews to assure that they are completed within five years of
award of the RA contract In addition, Regions must determine whether to conduct the review in-
house (EP-lead), under a CD (PRP-lead), or through a contract (e.g., ARCS) or assistance
agreement (e.g., U.S. Army Corps of Engineers (USAGE), Bureau of Reclamation (BUREC),
State).
Since five-year reviews for appropriate sites are to be completed within five years of RA
contract award, reviews may be conducted during phases of the RA, during LTRA, and during
O&M. Where appropriate, additional reviews may be conducted after a site has been deleted from
the NPL. Each ROD attempts to identify when a five-year review is necessary based on the nature
of the remedy. Regions should identify sites where a five-year review is required and develop
workplans. HQ has established a mechanism to provide extramural funds for such reviews on a
site-specific basis and has projected completing 50 five-year reviews per year. The President's FY
93 budget would redirect 15 FTEs and provide $1.5 million for five-year reviews. Funds for five-
year reviews are contained in the RA Advice of Allowance (AOA).
STARS Targets and Measures
Superfund Comprehensive Accomplishment Plan (SCAP) and STARS targets are the key
devices by which the program goals discussed in this Chapter are translated into quantifiable
program achievements. During the Program Management Meeting in January 1992, HQ and the
Regions discussed the SCAP/STARS targets and measures that were proposed in the FY 93
Agency Operating Guidance. Regions expressed concerns that since the budget and workload
models were frozen, HQ should reevaluate and consider dropping some of the SCAP/STARS
targets and measures. Based on this discussion, the Regions voted on the highest priority
Superfund STARS targets/measures for FY 93. The information contained in this Manual reflects
HQ decisions relative to the Regional vote on the SCAP/STARS targets and measures.
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OSWER Directive 9200.3-01H-2
Exhibit 1-5 contains the STARS targets and measures for the remedial, removal,
enforcement and Federal Facility program areas. Definitions for the STARS targets and measures
can be found in the Appendix to this Manual.
In FY 93, a number of Regions will be participating in the pilot efforts for testing the
SACM prior to full scale implementation. HQ will renegotiate any Regional SCAB/STARS targets
and measures affected by the pilot projects.
Supporting Program Goals
The following sections describe the specific goals that support a more effective Superfund
program.
Removal
Removals that result in NPL site completions are a priority. In addition to the Action
Memorandum, these actions require a ROD that states that all necessary
remediation has been completed. The ROD must document that the site
meets the statutory requirements for site closeout.
Enforcement
Following settlement for RI/FS, or RD/RA, or professed intent by a PRP to comply with a
UAO for RD/RA, the Region must ensure PRP compliance with the terms of the settlement
or UAO. EPA must ensure that PRP responses are timely, thorough, and do not
compromise environmental goals. Regions should assess penalties in situations where
PRPs clearly have not submitted major deliverables of acceptable quality by the dates
specified in the AO, CD or UAO.
If PRP's fail to comply with a UAO, consideration should be given to referring a Section
106 judicial action to enforce compliance.
Remedial
The remedial program's highest priority is moving projects/sites toward construction
completion and NPL deletion in a timely and cost effective manner. The number of PRP-
lead RDs and RAs must be maximized. However, lead changes from EPA to the PRPs in
the middle of a phase of the Superfund process will be limited.
Greater emphasis will be placed on the evaluation and selection of alternative technologies
and the employment of the technologies on-site. Treatability studies will be an important
part of the RI/FS, ensuring that adequate data exist to evaluate each technology prior to
remedy selection. Regions should provide technical oversight of all treatability study
activities.
Site Assessment
To facilitate program planning and expedite response to Congressional and public inquiries,
Regions should enter into WasteLAN all site assessment decisions/priority
recommendations at each step of the evaluation process and all appropriate identifiers
(Federal Facility, Indian lands, etc.) as rapidly as possible.
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OSWER Directive 9200.3-01H-2
EXHIBIT 1-5
STARS TARGETS AND MEASURES
ACTIVITIES
STARS TARGET
STARS REPORTING
RIIFS ENFORCEMENT
ACTIVITIES A SETTLEMENTS
De minimis Settlements pnor to
ROD and Number of PRPs
(S/E-3b)
lAGs Signed at NPL or
Proposed NPL Federal
Facility Sites (FFE-2)
Federal Facility Remedy
Selection at NPL Sites (First
and Subsequent) (FFE-4)
RD/RA ENFORCEMENT
ACTIVITIES, SETTLEMENTS
AND REFERRALS
RD/RA Settlements and
Injunctive Referrals (S/E-1)
De. minimis Settlements and
Number of PRPs (S/E-3a)
Federal Facility RA Starts
(FFE-3)
RA Contract Award (S/C-1)
RA Construction Completion
(S/C-2)
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OSWER Directive 9200.3-01H-2
EXHIBIT 1-5 (Continued)
STARS TARGETS AND MEASURES
ACTIVITIES
STARS TARGET
STARS REPORTING
COST RECOVERY
Cost Recovery Actions/
Decisions > $200,000
(S/E-2a)
Cost Recovery Actions/
Decisions < $200,000
(S/E-2b)
RESPONSE
NPL Sites Addressed Through
Removal Start or RI/FS Start
(S/C-4)
Decision Document
Development - Remedies
Selected and Action
Memoranda Signed (S/C-5)
NPL Site Construction
Completions (S/C-3)
Progress Through
Environmental Indicators
REMOVAL
Federal Facility Removals/
Expedited Response Actions
(ERA) Starts (FFE-3)
Federal Facility Removals/
ERAs Completed
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OSWER Directive 9200.3-01H-2
Federal Facilities
OE has initiated a national effort to develop cleanup priorities for Federal Facilities based on
the judgment of EPA, States, Indian Tribes, citizen groups and other Federal agencies to
target limited government resources.
Management Initiatives
The following initiatives have been implemented in recent years to ensure the effectiveness
of the Superfund program:
Implementation of a well managed program by continuing the strategy of fully
funding all RI/FS projects. The program has set the goal of reducing Fund-
financed RI/FS costs to a national average of $750,000 per OU and $1,100,000 per
site (exclusive of treatability studies). Every effort should be made to ensure that
the trend of RI/FS costs is toward the overall national goal. Regions are strongly
encouraged to focus RI/FS projects on principal threats, even if this does require
additional OU(s) to complete site remediation. A Region's RI/FS budget is
developed based on the full funding strategy. "Mega-sites" are excluded from the
OU and site level cost reduction goals described above.
The Superfund enforcement budget has remained the same for the past two years
and is not expected to increase in FY 93. As a result, Regions are required to
manage their extramural budgets to ensure that current year needs are fully
addressed. Forward funding of activities is a lower priority.
Implement a mega-site management strategy that insures cost-effective
environmental management of these significant sites. Response mega-sites are
defined as sites where Fund-financed RI/FS work at the site reaches or exceeds $3
million. Regions are required to develop and submit to the HSCD a response
Mega-site Management Plan that characterizes site problems and management
options. Response mega-site funding requests will be reviewed and resources
allocated on a site by site basis.
An enforcement mega-site has projects that require more than $200,000 per year for
enforcement actions or over $500,000 per year for RI/FS oversight Regions are
required to develop and submit enforcement mega-site plans to the CERCLA
Enforcement Division (CED). Enforcement mega-site requests will be fully funded
wherever possible.
The dates for submittal of response and enforcement mega-site plans can be found
in the Manager's Schedule of Significant Events at the beginning of this Manual.
Contract Management During FY93, program emphasis should be placed on
ensuring contract management. Full implementation of the ARCS and Contract
Laboratory Program (CLP) task force recommendations remains a high priority.
Also, HQ and Regions must continue to focus on the management and control of
the ARCS program management costs to achieve Congressionally mandated goals.
Implementation of the Long Term Contracting Strategy (LTCS) will focus on the
phase-in of new contracts, most of which are delegated to the Regions for
management.
Enforcement oversight support, currently provided under the Technical
Enforcement Support (TES) contract vehicle should be shifted to the ARCS contract
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OSWER Directive 9200.3-01H-2
EQUITY
early in FY 93. Regions should begin transferring assignments or assigning new
work to the ARCS contract, especially those that will exceed the TES period of
performance.
Make effective use of other agency expertise It is important that EPA make full
use of construction management expertise available from the USAGE and the
BUREC, and that EPA staff avoid duplicative oversight of projects assigned to
these agencies. The USAGE has a mission assignment from EPA to provide
technical assistance, review RI/FS projects, oversee PRP RDs and RAs, and
conduct RDs and RAs depending on their estimated cost. Pursuant to OSWER
Directive 9242.3-08, RD assignments can be made to the ARCS contractors or the
USACE/BUREC at the Region's discretion. RA assignments with an estimated
cost over $15 million must be issued to the USAGE.
Information management Continue the efforts toward making CERCLIS/
WasteLAN more of a management tool for the Regions. This includes integrating
the information needs external to OSWER (e.g., ORC, OE and Department of
Justice (DOJ)) into the CERCLIS information management environment,
implementing and integrating project and program management tools (e.g., the
Superfund Management and Reporting Technology (SMARTech), and the
Remedial Pipeline Project Management (RP2M) System), and reporting technical
data using WasteLAN (e.g., El and RA information). HQ will continue to work
with the Regions to expand the use of CERCLIS/WasteLAN for these and other
management initiatives.
Building public confidence In the past three years the Agency has taken major
steps in improving the communication of the ongoing efforts of the Superfund
program and the progress being made in site cleanup. These efforts started in FY 90
with the implementation of the El program and the publishing of the NPL Books.
In FY 92, OWPE initiated a communication and outreach effort. Working closely
with OERR, OWPE developed a format for telling site specific stories of Superfund
at Work. The Superfund at Work success stories, which will continue to be
prepared in FY 93, demonstrate both the effort and results of the program to key
external audiences. In FY 93 and beyond, the Agency will also look to the S ACM
as a means to communicate the successes in risk reduction.
Better communication of this type of information to Congress and the public will
help build confidence in the Agency and the Superfund program.
The third key principle, equity, focuses on two key players in the Superfund arena - the
PRPs and the State. With respect to the PRP involvement in the Superfund program, the
following goals have been established:
Equitably seek settlement for PRP response earlier in the process;
Achieve early and appropriate settlement with collateral PRPs;
Maximize cost recovery to the Trust Fund; and
Send a clear message to the PRP community that recalcitrance is costly.
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OSWER Directive 9200.3-01H-2
To reach these goals, the following priorities have been identified for FY 93:
PRP search/compliance enforcement A high-caliber PRP search is the
foundation of EPA's enforcement process. It must focus on obtaining the
necessary evidence of the liability and financial viability of all PRPs for Section 106
and 107 litigation. Regions should consider starting the PRP search earlier (i.e., at
the SI phase). The focus should continue to be on thorough PRP searches with the
assistance of civil investigators. Also, Regions are encouraged to use
administrative subpoena authorities in cases of non-compliance with information
requests issued under Section 104(e) and, if necessary, use statutory penalty
provisions to enforce compliance. PRP search activities should continue even if
Regions are unable to start the RI/FS as planned. If the start of the RI/FS is
delayed, the actions that follow the RI/FS start should also be delayed.
Achieve early and appropriate settlement with collateral PRPs The main objective
of the early d£ minimis settlement strategy is to reduce PRP transaction costs,
preserve government resources, and settle with eligible d£ minimis parties quickly.
Regions should use the data derived from waste-in lists, volumetric ranking and
Section 104(e) information to perform an allocation of responsibility. Regions may
also consider preparation of a Non-Binding Allocation of Responsibility (NEAR) if
it would assist in settlement. Regions should use an AOC for early d£ minimis
settlements.
Under EPA policy, the Agency generally will not pursue a generator or transporter
of municipal solid waste without site specific evidence that hazardous substances
were contained in the municipality's contribution of waste. However, an increasing
number of third party suits have been instituted against municipalities. As a result,
HQ is preparing guidelines to be used by the Regions in reaching settlements with
municipalities.
Cost recovery Cost recovery actions recover revenues to the Fund. An active
cost recovery program also will encourage voluntary PRP cleanup action by
eliminating incentives for PRPs to allow the government to conduct the response
action. In FY 93, the Agency will be re-examining its cost recovery strategy. The
focus of the cost recovery program will be on selecting and developing the best cost
recovery cases that will maximize recovery of Trust Fund monies. The President
has set a goal of recovering $300 million in FY 93 in his Management By
Objectives (MBO) system. The most significant step the Regions can take to meet
this goal is to initiate each cost recovery negotiation with a demand for 100 percent
of all eligible costs. Ensuring timely completion of cost documentation, issuing
demand letters and addressing Statute of Limitation (SOL) sites will also help EPA
reach the President's goal. Regions must also pursue viable non-settlors where a
partial settlement was reached. In some cases, Regions may consider deferral or
waiver of past costs against settlors for response work and pursue non-settlors for
recovery of past costs. Such actions will reinforce the perception that recalcitrance
is costly.
States continue to play an important role in the Superfund enforcement process. Regions
are encouraged to enter into Cooperative Agreements (CAs), Superfund Memoranda of Agreement
(SMOA), or other management assistance agreements when the State expects to play a significant
role. State roles in the RD/RA negotiation process should be clearly defined prior to the
negotiations. Use of SMPs will ensure that all parties are aware of their roles, the timeframe for
negotiations, and the strategy that will be employed.
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OSWER Directive 9200.3-01H-2
CHAPTER II
PROGRAM PLANNING AND REPORTING REQUIREMENTS
-------
OSWER Directive 9200.3-01H-2
CHAPTER II - PROGRAM PLANNING AND
REPORTING REQUIREMENTS
ONE MINUTE PROGRAM MANAGER RULES
Following are the actions Regional managers must take to comply with the
requirements described in this Chapter. In order to acquire a more in-depth
understanding of these requirements, the Chapter itself should be read.
Regions have complete responsibility for maintaining WasteLAN,
CERCLIS, and selected portions of the CERHELP data base.
On the fifth working day of February and July, HQ pulls Superfund
Comprehensive Accomplishments Plan (SCAP) data from CERCLIS
for negotiation of preliminary and final SCAP/Strategic Targeted
Activities for Results System (STARS) targets.
During negotiations, Regions may propose changes in targets to
match the total Regional Superfund resource level.
The preliminary and final SCAP/STARS targets are established in
March and August, respectively.
Response and enforcement funding needs identified in January form
the basis for the annual Regional budgets.
Final "approved" funding requests must be within the annual
Regional budget proposed by HQ.
Planning and accomplishment data should be updated in WasteLAN
within five days of the occurrence, or schedule/funding change, or at
least monthly.
HQ will not recognize a SCAP/STARS accomplishment unless it is
correctly recorded in CERCLIS by the specified pull date. HQ bases
its evaluation of Regional performance on CERCLIS data.
At the close of business on the fifth working day of each month, HQ
pulls accomplishment data from CERCLIS to support a variety of
official reporting requirements.
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OSWER Directive 9200.3-01H-2
CHAPTER II - PROGRAM PLANNING AND
REPORTING REQUIREMENTS (CONTINUED)
ONE MINUTE PROGRAM MANAGER RULES
Changes to STARS should not be made simply because a target
cannot be met.
Report STARS accomplishments in the Office of Pollution Prevention
(OPP) STARS system.
SCAP/STARS amendments require HQ concurrence and approval.
STARS amendments should be submitted by the Regional
Administrator to the Assistant Administrator for the Office of Solid
Waste and Emergency Response (AA SWER) by April 15.
Regions, as data owners, are responsible for entering data, and ensuring
the data accurately reflects actual plans and accomplishments. Source
documents to support accomplishments must be in official site records
maintained in the Region.
HQ program offices, as data sponsors, are responsible for entering
targets, reviewing the accuracy of the data Regions enter, and pulling
planning and accomplishment data for negotiations, Advice of
Allowance (AOA) generation, and program evaluation purposes.
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OSWER Directive 9200.3-01H-2
CHAPTER II - PROGRAM PLANNING AND REPORTING REQUIREMENTS
INTRODUCTION
The SCAP process is used by the Superfund program to plan, budget, track, and evaluate
progress toward Superfund site cleanup. The SCAP planning process is a dynamic, ongoing
effort that has a significant impact on Superfund resource allocation and program evaluation.
Planned obligations and STARS targets and measures are generated through SCAP and influence
the Superfund budget and evaluation process. SCAP planning is a day-to-day responsibility of the
Regions. A semi-annual process has been established through which HQ and Regions formally
negotiate plans for the future. CERCLIS serves as the conduit for the SCAP process. CERCLIS
provides both HQ and Regions with direct access to the same data. Reports can be produced
allowing for daily, interactive updates of planning and site cleanup progress information.
RELATIONSHIP OF SCAP TO OTHER MANAGEMENT TOOLS
As the Superfund program's central planning mechanism, SCAP is interrelated with the
following Agency and Superfund program specific planning and management systems:
Agency Operating Guidance. - This defines Superfund goals for the upcoming year.
SCAP targets/measures are designed to reflect the Agency Operating Guidance.
Superfund Budget - The operating year's budget is developed 18 months prior to
its beginning. For example, the SCAP existing in the third quarter of FY 93 will be
used to formulate the FY 95 budget The site schedules reflected in the SCAP serve
as the foundation for determining outyear budget priorities.
Agency Operating Plan - The Operating Plan, which is finalized prior to the FY,
establishes the funds available to the Regions for performing Superfund work.
STARS - This system is used by EPA to set and monitor the environmental
objectives identified in the Agency's Operating Guidance. STARS targets are a
subset of those contained in SCAP. STARS targets and measures are reported
quarterly by HQ and the Regions to the Office of Pollution Prevention (OPP). OPP
tracks Regional progress toward STARS goals on a quarterly basis as part of the
overall Agency performance evaluation process. With the exception of CEPP
measures, HQ will not recognize a STARS accomplishment unless it is correctly
recorded in CERCLIS.
Superfund Workload Models - The models distribute FTEs for each program and
Region. There are three Superfund program models: the Hazardous Site and Spill
Response model, which distributes resources for the site assessment, remedial and
removal programs; the Technical Enforcement model which distributes enforcement
FTEs; and the Federal Facilities Superfund Workload model, which distributes
Superfund resources for response and enforcement activities at Federal Facilities.
SCAP plans form the basis of the workload models. In FY 93, each Region's
response and enforcement FTEs will be frozen at the FY 90 levels. The Federal
Facility FTEs will be frozen at the FY 92 level. While the freeze ensures that total
Regional Superfund resources will not be affected, shifting of resources within the
Region among the different program areas may occur. This includes shifts between
the response and enforcement programs. All shifts must be made in accordance
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OSWER Directive 9200.3-01H-2
with the FY 93 national budget and the Integrated Priority Setting Matrix (see
Chapter I).
OFFE will coordinate with OERR and OWPE throughout the SCAP process. OFFE will
rely on CERCLIS data in planning, budgeting, tracking, and evaluating progress at Superfund
Federal Facility sites. CERCLIS data is used, in part, to feed the Federal Facilities workload
model. In addition to CERCLIS, OFFE and the Regions will also utilize information gathered in
conjunction with the A-106 Pollution Abatement Planning Process to evaluate the adequacy of
other Federal agency budgeting for Superfund sites and Federal Facility compliance rates under
other environmental statutes (e.g. Air, Water, RCRA). These data will enable OFFE and the
Regions to evaluate actual outlays and accomplishments at Superfund sites in relationship to budget
authorities, obligations and performance under other environmental programs. Changes to the A-
106 data base, also known as the Federal Facilities Information System (FFIS), and to the
information collection procedures will enable improved planning and coordination with Federal
agencies, and post-funding evaluation of accomplishments. A-106 data will complement
information provided in CERCLIS and will provide OFFE and the Regions with additional insight
into Federal agency planning and cleanup support.
OVERVIEW OF THE SCAP PROCESS
The SCAP process generates data that fulfill the following functions:
Tracking of accomplishments against targets/measures;
Updating planning (schedules and funds) for the current FY;
Developing planning data for the upcoming FY; and
Providing data for outyear budget planning purposes.
Regions are required to keep the SCAP data in WasteLAN and CERCLIS up-to-date and
accurate. Changes in planning information (schedules and funds) should be entered into
WasteLAN within five days and accompli shments should be reported as soon as they occur. If
changes affect a SCAP or STARS target or measure or the approved funding level for a site, the
appropriate fields in WasteLAN must also be updated. Regions should note that changes made in
WasteLAN or CERCLIS to site schedules and other planning data will not automatically result in
changes to SCAP/STARS targets. Although Regions have the flexibility to alter plans, they are
still accountable for meeting the targets negotiated prior to the beginning of the FY. (See the
section later in this Chapter on SCAP/STARS Adjustments and Amendments.)
The SCAP formal negotiation cycle is a semi-annual process. The focus of the two formal
negotiations is slightly different as shown in Exhibit II-1. The remainder of this Chapter will
discuss the procedures for target setting, accomplishment reporting and evaluation, and the efforts
to improve CERCLIS data quality.
PROCEDURES FOR ANNUAL TARGET SETTING
The process for the development of SCAP and STARS targets/measures for a FY begins
with the SCAP developed during the second quarter of the previous FY. All targets/measures are
negotiated and numbers are established only after discussions between OERR, OWPE, OFFE, and
the Regions. In the Regions, a review of the status of projects should be undertaken by the
program office, ORC, and the State. For Federal Facility sites, the Region may want to consult
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OSWER Directive 9200.3-01H-2
with the responsible Federal agency to ensure site schedules in WasteLAN are accurate. Final
SCAP and STARS targets are negotiated in the fourth quarter (August) between HQ and the
Region. The procedures for setting targets for the upcoming FY can be found in Exhibit II-2. The
dates for pulling the information from CERCLIS that will be used for negotiations can be found in
the Manager's Schedule of Significant Events presented at the beginning of this Manual.
The negotiation of preliminary and final SCAP/STARS targets and measures has become
complicated as a result of the freeze in Regional FTEs. During negotiations, Regions may propose
changes in targets to match the total Regional Superfund resource level. The changes in targets
must be made in accordance with the Integrated Priority Setting Matrix and the overall budget HQ
will work to ensure that the cumulative Regional targets meet national budget commitments.
EXHIBIT II-l
SCAP PLANNING YEAR
SECOND QUARTER (JANUARY/FEBRUARY/MARCH 1993)
Regional program office consults with States, ORC and responsible Federal
agencies on plans and schedules for the upcoming year
Revise FY 93 annual budget ceilings to reflect first and second quarter
performance and revised plans for the remainder of the year
Update and negotiate planning information in CERCLIS for the third and fourth
quarter FY 93
Negotiate third and fourth quarter enforcement AOAs
Negotiate preliminary FY 94 SCAP/STARS targets and measures
Negotiate preliminary annual Regional budgets for FY 94
Provide complete site schedules including planned RA obligations to allow HQ
to project the outyear budget (FY 95)
FOURTH QUARTER (JULY/AUGUST 1993)
Establish final SCAP/STARS commitments for FY 94
Establish FY 94 annual Regional budget
Planning for Negotiations
To adequately plan for the year, a Region must make decisions on the status of projects and
funding needs. Remedial, enforcement, and Federal Facilities projects should be identified as
either "Primary" or "Alternate." Primary projects represent those mat have the greatest likelihood
of meeting the schedules in WasteLAN. Alternate projects represent sites that can be substituted
for primary targets. The negotiated number of primary projects will be used to determine
SCAP/STARS commitments.
Similar to the project status, funding for remedial events or enforcement activities are
identified as either "Approved" or "Alternate." Funds for events/activities that have the greatest
likelihood of requiring funding during the FY are labeled "Approved." Projects with alternate
funding status may be substituted for approved projects that experience slippage or are deferred
due to changing priorities. Activities/events identified as alternate will also form the basis for any
requests for supplemental funding.
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OSWER Directive 9200.3-01H-2
For all remedial pipeline events scheduled to begin during the FY, funds are approved only
for those projects that are "primary" targets. For example, only RI/FS starts that are
SCAP/STARS targets will be used by HQ to establish the RI/FS budget. The total of all
approved funding must not exceed the HQ established Regional budget ceilings or
HQ will not initiate negotiations.
At the close of business on the fifth working day of February and July, HQ pulls SCAP
reports from CERCLIS. The data in these reports serve as the basis for HQ/Regional mid-year and
final negotiations. HQ will perform all negotiations based on the information in CERCLIS on
these pull dates. To ensure consistency in the negotiation phase, the CERCLIS data bases are
frozen prior to pulling the reports used for negotiations. As a result, all parties (HQ and the
Regions) will have identical data for use during the negotiation process.
EXHIBIT II-2
PROCEDURES FOR ANNUAL TARGET SETTINGS
HQ Develops Initial Targets/Measures Based on SCAP
Methodologies and Budget
Initial Targets/Measures Sent to Regions
After Consultation with States, ORC and Responsible Federal
Agencies, Regions Update Site Schedules and Funding Needs in
WasteLAN
HQ/Regional Negotiation of Preliminary SCAP/STARS
Targets/Measures
Preliminary Targets/Measures Set
HQ Develops Proposed Regional Budget Ceilings for Removal,
Remedial, Enforcement and Federal Facilities
Proposed Regional Budgets Sent to Regions
January
January
January-February
February - March
March
Regions Update Site Schedules and Funding Needs in WasteLAN June-July
August
September
HQ/Regional Negotiation of Final SCAP/STARS Targets and
Annual Regional Budgets
Targets/Measures and Budgets Sent to AA SWER for Approval
and Submitted to OPP; Federal Facility Targets/Measures
Submitted to OPP
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OSWER Directive 9200.3-01H-2
ACCOMPLISHMENT REPORTING AND PERFORMANCE EVALUATION
Accomplishments data are entered into WasteLAN by the Region. Data on
accomplishments should be entered into WasteLAN as soon as they occur, but no later than within
five working days of the event or activity. Only accomplishments correctly reported in
CERCLIS will be recognized by HQ.
The Superfund evaluation process provides managers with an opportunity to meet program
objectives by:
Examining program accomplishments;
Analyzing and discussing issues that affect the successful operation of the
Superfund program; and
Initiating changes in program operations or reallocating resources.
The strategy for assessing the performance of the Superfund program is comprised of
monthly accomplishments reporting, quarterly SCAP/STARS performance evaluation based on
CERCLIS data, and mid-year and end of year detailed management evaluations. (See Exhibit II-3)
This strategy enables management to recognize high performance, concentrate Superfund resources
in those Regions that demonstrate success, and provide training and technical assistance to those
Regions that are experiencing difficulties.
HQ and the Regions have different roles and responsibilities in Superfund program
evaluation and management, as shown in Exhibit n-4.
HQ divisions in OSWER are tasked, usually through a memorandum, to provide a
narrative of activities taking place in the Regions. The primary purpose of this memo is to provide
a routine opportunity for top Agency managers to share their candid assessment of the program
goals and initiatives, highlighting where the Regions are experiencing success and where there are
problems, and the actions HQ can take to improve Regional performance. These narratives, in
conjunction with the quarterly performance numbers, are placed in a memorandum to the Deputy
Administrator (DA), giving a more balanced and thorough view of program status and issues. The
memoranda contain the most significant issues/activities and performance highlights from the
previous quarter, and may include information on removal actions in the news, emergency
response activities, a Total Quality Management (TQM) project taking place in a Region, and the
like. It gives OERR and OWPE the opportunity to convey important issues, instead of merely
presenting SCAP/STARS numbers.
In addition to reporting accomplishments through CERCLIS, Regions must verify the
accuracy of a subset of data entered by HQ into the OPP STARS system. The STARS
accomplishments discrepancy resolution deadline is usually the 18th business day following the
end of the quarter. After the Regions have finalized their CERCLIS entries and the DA Memo has
been distributed throughout OERR, OWPE and the Regions (between 20 and 30 business days
following the end of the quarter), OERR and OWPE evaluation staff brief the AA's office on
response and enforcement program accomplishments made in that quarter.
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OSWER Directive 9200.3-01H-2
SC
s
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OSWER Directive 9200.3-01H-2
EXHIBIT II-4
EVALUATION RESPONSIBILITIES
REGIONAL
RESPONSIBILITIES
Meet quarterly SCAP and STARS targets and
solve performance problems when they arise
Provide quarterly SCAP and STARS data to
HQ through CERCLIS
Maintain CERCLIS data quality at high levels
for Superfund program and project management
Negotiate performance standards that provide
individual accountability for targets
Develop plans for meeting targets
Assess Federal agency needs identified during
the OMB A-106 process
im
RESPONSIBILITIES
Provide guidance to the Regions for the
quarterly review, the mid-year assessment,
the year-end assessment
Implement and report on follow-up action
items from the Superfund mid-year assessment
Review quarterly performance data reported
by the Regions and negotiate plans with
Regions for meeting targets
Continually assess program performance and
analyze timeliness and quality of work
Recommend resource reallocation based on
Regional needs and performance
Assure that all staff are informed of the
results of performance reporting
Compare Federal agency budget authorities,
obligations and outlays to monitor cleanup
activities
The following sections provide a brief description of the reports available to support
Superfund program management.
Superfund Management Reports
The implementation of an integrated CERCLIS database and the improvement of CERCLIS
data quality led to the development of a series of senior management reports. These management
tools are designed to supplement conventional quarterly SCAP/STARS accomplishment reporting
by providing a more comprehensive examination of program activity. The format and content of
the reports package has evolved over time to address a variety of project needs. The INSITE n
system was created to ease the process of generating the Superfund Management Reports and to
reduce calculation errors that arose from constructing these reports by hand. Using data that is
downloaded from CERCLIS, INSITE n provides EPA senior managers with summary graphic
reports and backup site detail information.
In 1990, OERR and OWPE began producing expanded Quarterly Reports. The quarterly
packages produced by OERR are divided into three distinct reports:
Report I: Targets and Accomplishments - This section graphically displays specific
SCAP/STARS program targets and accomplishments by Region, the percent of
annual targets achieved in the major site assessment and remedial program areas,
n-7
-------
OSWER Directive 9200.3-01H-2
and annual target and accomplishment totals by SCAP/STARS activity for each
Region.
Report II: Trends Analysis - These graphs present the duration analyses of pipeline
events, including RI/FS start to RA start and ROD to RD start. Users can request
that the duration reports be run for a given FY or Region.
Report HI: Superfund Historical Performance - These reports provide graphical
presentations of progress made at NPL and non-NPL sites. Various information,
including site, enforcement, budget and project data, are used to present an overall
picture of the Superfund program activities.
Additional management reports produced by OWPE are presented in Exhibit II-5.
SCAP/STARS ADJUSTMENTS AND AMENDMENTS
After targets have been finalized and funding levels developed, the SCAP process provides
the flexibility to modify plans during the year. Modifications to planned targets are termed either
adjustments or amendments. Amendments require HQ concurrence and approval.
Adjustments do not require HQ approval, but may require HQ notification. Exhibit II-6 lists the
major Superfund amendments and adjustments. Exhibit n-7 describes the procedures that must be
followed when processing amendments.
OPM coordinates change requests/SCAP amendments for the program offices in OERR.
OPM and CED of OWPE provide input on SCAP amendment approval decisions. The Program
Operations Division (POD) of OFFE will coordinate change requests/SCAP amendments involving
Federal Facilities.
Changes to STARS commitments should not be made simply because targets will not be
met. However, in some cases, amendments to targets may be necessary and may be changed
under the following conditions:
Major, unforeseen contingencies arise that alter established priorities (i.e.,
Congressional action, natural disasters);
Major contingencies arise to alter established Regional commitments (i.e., State
legislative action); or
Measure or definition in system is creating an unanticipated negative impact.
OSWER and OE require that all STARS amendments be submitted to HQ by April 15 in
order to meet the April 30 deadline for changing targets imposed by OPP. STARS amendments
must be approved by AA SWER or the AA OE. The OPM and program offices in OERR, the CED
in OWPE, and the POD in OFFE provide input on STARS amendment approval decisions.
H-8
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OSWER Directive 9200.3-01H-2
EXHIBIT II-5
OWPE MANAGEMENT REPORTS
Cost Recovery Category
Report
SOL Management
Report
Settlements Master
Report
Litigation Master Report
Negotiation Master
Report
Adminstrative/
Unilateral Orders Issued
Enforcement Data Audit
Report
Lists Removals, RA Starts and Pre-RA Activities
that are Candidates for Cost Recovery.
Lists Planned and Actual Completion Dates and
Planned and Actual Obligations for Removals,
RI/FSs, and Remedial Activities
Lists Settlements Program-to-Date by Settlement
Category
Lists Litigation Cases Program-to-Date by
Litigation Type
Lists Ongoing and Completed Negotiations
Program-to-Date by Negotiation Category
Lists all issued AOs and UAOs
Used to Monitor Enforcement Data Quality
CERCLIS DATA QUALITY
All data base users are concerned with the quality of the data that they enter and analyze.
Data entry screens, data entry edits, upload programs, and documentation that summarize required
data base elements support the users' data quality efforts. The Regions, as data owners, enter
data, ensure that data accurately reflect actual plans and accomplishments, and obtain credit for
accurate planning and for accomplishments. Source data to support accomplishments must be in
official site records maintained in the Regions. The HQ offices, as data sponsors, enter targets,
review the accuracy of the data that the Regions enter, and pull planning and accomplishment data
for negotiations, AOA generation, and program evaluation.
Audit Reports
Focused data quality studies identified key data problems that made it difficult to interpret
data. The Audit-26 report was developed to identify errors within record types, such as pipeline
event records. The report was run each month and a summary prepared for each Region to track
improvements in data quality. Regions were successful in reducing the number of problems that
this report identified.
H-9
-------
OSWER Directive 9200.3-01H-2
EXHIBIT II-6
AMENDMENTS AND ADJUSTMENTS
SITUATION
INCREASE ANNUAL BUDGET
DECREASE ANNUAL BUDGET
INCREASE TOTAL (OWPE AND OERR) AOA
AFTER ISSUANCE WITHIN ANNUAL BUDGET
DECREASE TOTAL (OWPE AND OERR) AOA
AFTER ISSUANCE
INCREASE/DECREASE RA FUNDING BEFORE
AOA ISSUED
DECREASE RA FUNDING AFTER AOA ISSUED
INCREASE RA FUNDING AFTER AOA ISSUED
SHIFT FUNDS WITHIN ALLOWANCE AFTER
AOA ISSUED
SHIFT FUNDS BETWEEN ALLOWANCES
AFTER AOA ISSUED
CHANGE ANNUAL SCAP TARGET
CHANGE STARS QUARTERLY OR ANNUAL
TARGETS
TARGET SITE SUBSTITUTIONS
AMENDMENT
OR
ADJUSTMENT
AMENDMENT
ADJUSTMENT
AMENDMENT
ADJUSTMENT
ADJUSTMENT
ADJUSTMENT
AMENDMENT
ADJUSTMENT
ADJUSTMENT
AMENDMENT
AMENDMENT
ADJUSTMENT
PROCEDURES
SEE EXHIBIT II-7
REVISE WASTELAN/CERCLIS; NOTIFY
HQ PROGRAM DEVELOPMENT AND
BUDGET STAFF (PDBS), OERR
CONTRACTS AND PLANNING BRANCH
(CPB), OWPE OR POD, OFFE
SEE EXHIBIT II-7
SEE CHAPTER HI, EXfflBrr HI-4
REVISE WASTELAN/CERCLIS
SEE CHAPTER HI, EXHIBIT HI-4
SEE EXHIBIT II-7
REVISE WASTELAN/CERCLIS
SEE CHAPTER HI. EXHIBIT HI-4
SEE EXHIBIT II-7
SEE EXHIBIT II-7
REVISE WASTELAN/CERCLIS g
The Office of Program Management (OPM) commenced an initiative in mid-FY 92 to
address data quality issues in frequently used CERCLIS data elements. A primary goal of the
initiative is to develop data quality tools that identify errors between records. Slated to be
completed by early FY 93, this project relies upon the coordination between HQ and Regional
Information Management Coordinators (IMCs) to identify and prioritize problematic data, as well
as to test and implement correctional tools.
The ENFR-8 report is sorted site-specifically, and lists all enforcement and response
activities at a site that contain enforcement data entry errors. If there are no enforcement data errors
at a site, the site will not be displayed on the report. The meaning of each audit code is listed at the
bottom of each site summary.
The ERD is in the process of developing an audit report that checks for the existence of key
data for removal starts and completions.
11-10
-------
OSWER Directive 9200.3-01H-2
EXHIBIT II-7
SCAP AMENDMENT PROCESS
Quarterly or Annual
STARS Targets
Annual SCAP
Target
Increase
Annual Budget
V t t
Memorandum
from Regional
Administrator to
AASWERor
Deputy Assistant
Administrator
(DAA)OFFE
explaining reason
for the change.
E-mail from
Regional Branch
Chief to HQ
Director, PDBS,
OERR or Chief,
CPB, OWPE or
memo to Director,
POD, OFFE
explaining reason
for change.
E-mail from
Regional Branch
Chief to Director,
PDBS, OERR, or
Chief, CPB,
OWPE or memo
to Director, POD,
OFFE. Copy sent
to the Regional
finance office and
HQ PDBS or
CPB staff.
Increase Total AOA
or Increase RA
Funding After AOA
Issued
^ J
E-mail from IMC
to HQ PDBS or
CPB staff or
memo to Director,
POD, OFFE.
Copy sent to AA
SWERorDAA
OFFE and
Regional finance
office.
WasteLAN and
CERCLIS are
updated.
WasteLAN and
CERCLIS are
updated.
WasteLAN and
CERCLIS are
updated.
*
AA SWERorDAA
OFFE reviews
request and, if
approved, sends
E-mail to Regional
program and finance
offices and HQ
Office of the
Comptroller (OC).
t
AA SWERorDAA
OFFE approves
SCAP amendment/
change request and
sends E-mail to
Regional program
and finance offices
and HQ OC.
[ Regional finance |
[office updates IFMSJ
| Regional finance |
^office updates IFMSJ
' '
HQ OC approves
revised AOA in
IFMS.
HQ OC approves
revised AOA in
IFMS.
II-11
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OSWER Directive 9200.3-01H-2
Data Sponsors
HQ program offices have taken a more active role in identifying their data needs and in
checking data through either the audit reports described above or through focused data studies.
Data sponsors identify and define allowable data element values and develop coding guidance or
rules for each sponsored element or element group. This includes eliminating duplicate data entry
through either using report select logic to calculate related values, or developing system
specifications to system generate the related value. Data sponsors perform periodic audits or data
quality reviews of data entered and maintained by the Regions to ensure coding guidance is being
properly followed. Sponsors work directly with the Regional IMC or program offices to resolve
and correct data errors or problems. Formal data quality processes and procedures are developed
and implemented, and training is provided to Regions and HQ program offices on these processes
and procedures.
11-12
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OSWER Directive 9200.3-01H-2
CHAPTER III
SIJPERFUND FINANCIAL MANAGEMENT AND FTE DISTRIBUTION
-------
OSWER Directive 9200.3-01H-2
CHAPTER in- SUPERFUND FINANCIAL
MANAGEMENT AND FTE DISTRIBUTION
ONE MINUTE PROGRAM MANAGER RULES
Following are the actions Regional managers must take to comply with
the requirements described in this Chapter. In order to acquire a more
in-depth understanding of these requirements, the Chapter itself should
be read.
Relationship Between SCAP and Annual Regional Budget
Regions are required to plan their obligations within the program
specific budget allocations given to the Regions prior to the August
negotiations.
Funding needs within the budget allocation should have a funding
priority status of "Approved." Funding needs above the budget
allocation should have a funding priority status of "Alternate."
HQ will not initiate negotiations with a Region until the "Approved"
funds requested are within the budget allocations.
Advice of Allowance Procedures and Requirements
Regions are required to operate within their quarterly AOA and final
negotiated annual operating budget.
No monies will be issued to the Region through the AOA process
unless the appropriate project specific obligation and commitment
data are reflected in CERCLIS.
The third quarter AOA for a specific response category will not be
issued unless the commitment/obligation rate is 50 percent or greater
in that AOA category.
Regions must obligate and task 60-65 percent of their first and
second quarter AOA in order to receive their third quarter
enforcement AOA. If a Region does not receive its third quarter
AOA, a site specific spending plan is required.
Regions will not receive RA funds in their AOA unless the remedy
technology type is in CERCLIS.
Regions should request enforcement extramural budget funds the
quarter in which they will be utilized.
HQ approval is not required to shift funds between projects within
the other response, RI/FS, RD, removal, enforcement or Federal
Facility AOA.
ffl-i
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OSWER Directive 9200.3-01H-2
CHAPTER III - SUPERFUND FINANCIAL MANAGEMENT AND FTE
DISTRIBUTION
This chapter discusses the Regional operating budget and AOA, outlines Superfund
financial management responsibilities, and provides an overview of the FTE distribution process.
DEVELOPMENT OF THE FY 93 NATIONAL BUDGET
In FY 93 there are insufficient resources for all ongoing activities plus the new activities the
Regions planned to begin. As a result, resource decisions were made based on the following
program priorities and consistent with the Integrated Priority Setting Matrix presented in Chapter 1.
THE FY 93 REGIONAL BUDGET PROCESS
Prior to the beginning of the FY, each Region will be given a proposed budget allocation
for the site assessment, remedial, removal, enforcement and Federal Facility programs. The
budget allocations are developed using the program/activity-specific criteria discussed in
subsequent sections of this Chapter. Final budgets will be developed upon completion of the
fourth quarter negotiations between HQ and the Regions. Funds requested for Regional activities
must fall within the total identified budget levels for each program. Funding needs above the HQ
proposed total budget level must be designated as "alternate". This will allow HQ to see the
Regional funding priorities, what activities will not be performed as a result of lack of funds, and
provide the information needed for any supplemental funding requests. HQ will not initiate
negotiations with a Region until the "approved" funds requested are within the proposed total
Regional budget levels.
Response Budget
The FY 93 President's response budget contains $896 million for direct cleanup activities,
including RI/FS, RD, RA, RD/RA PRP oversight, removals, and laboratory support for response
actions. $295.7 million is available to support other response actions, policy support, information
management, laboratory analysis for site assessment activities, the Technical Assistance Team
(TAT), and the ARCS and ERGS contracts.
The criteria for establishing the Regional budget is presented in Exhibit ffl-1.
Enforcement Budget
The current projected enforcement budget for FY 93 is $58 million. The enforcement
budget provides support for PRP searches, PRP removals, PRP RI/FS starts and oversight,
response negotiations, referrals, litigation, judicial and administrative cost recovery actions, and
project support activities. Mega-site funding requests will be fully funded in FY 93. The
remainder of the extramural budget will be allocated to the Regions based on the workload model.
Exhibit ni-2 displays all the activities and events eligible for funding. Funding requests for
activities not on this exhibit will not be accommodated.
Federal Facilities Budget
The Federal Facilities extramural budget for FY 93 is approximately $14 million. It covers
oversight of all phases of response work (RI/FS through deletion) at Federally-owned sites, as
well as negotiations for and implementation of lAGs and special Congressional requirements (i.e.,
base closures). Exhibit III-3 presents the pricing factors for Federal Facility activities.
in-i
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OSWER Directive 9200.3-01H-2
EXHIBIT III-1
CRITERIA FOR REGIONAL RESPONSE BUDGET DEVELOPMENT
ACTIVITY
CRITERIA
$6,840 per completion
$22,800 per completion
$57,500 per start
Negotiate mega-sites and
ongoing actions
$750,000 per new start
$700,000 per start
Based on dollars and
schedules in CERCLIS
Funded on a first ready/
first funded basis
$37,500 per quarter
PRP RD/RA Oversight
Removal
90% of the FY 92
Regional budget for removal
Funding distribution will be based on Regional needs as requested through CERCLIS.
The OFFE will plan, negotiate, monitor and distribute funds. OFFE plans to fully fund all basic
SCAP commitments as agreed upon during final negotiations.
It is highly likely that not all projects can be funded within the requested budget.
Consequently, the highest priority should be given to base closure projects, projects which will
address the highest risks at a site and projects accelerating cleanup. Regions are encouraged to use
innovative oversight techniques (e.g. tiered oversight) provided they can carryout their
responsibilities under the TAG.
m-2
-------
OSWER Directive 9200.3-01H-2
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-------
OSWER Directive 9200.3-01H-2
EXHIBIT m-3
PLANNING BUDGET AMOUNTS FOR FEDERAL FACILITIES
IAG Negotiations
Removal Oversight
RI/FS and RD/RA Oversight
(includes Community Relations)
State Support
Information Management
Contract Management
Technical Assistance/Training/Capacity Building
Base Closure Support
$25,000/negotiation
$25,000/removal
$25,000/quarter
$20,000/State
$50,000/Region
$20,000/Region
$50,000/Region
$20,000/Closing Base
RELATIONSHIP BETWEEN SCAP AND THE ANNUAL REGIONAL BUDGET
The SCAP process is the planning mechanism used by the Superfund program to identify
site assessment, remedial, removal, enforcement and Federal Facility funding needs for the FY.
The planned obligations included in the second quarter SCAP update (February) form the basis for
the Regional budgets for the next FY. The final annual Regional operating plan, and the associated
budget, are a result of the August HQ and Regional negotiations on the proposed outputs and
program budgets. Though Regions are required to operate within their final negotiated annual
operating budgets, adjustments within this budget can be made during the FY.
ADVICE OF ALLOWANCE PROCEDURES AND FINANCIAL REPORTING
REQUIREMENTS
The planned obligations identified through the SCAP process are the basis for the AOA
approved by the Office of the Comptroller (OC) and AA SWER or the Deputy Assistant
Administrator (DAA) OFFE.
Regional Allowances
In FY 93, the OC will issue seven allowances to the Regions. They are:
RA (site-specific "site" allowance), which also includes funds for O&M, LTRA,
and five-year reviews;
RD (non-site specific "site" allowance), which also includes RD/RA oversight
funding;
ffl-4
-------
OSWER Directive 9200.3-01H-2
RI/FS (non-site specific "site" allowance);
Removal (non-site specific "site" allowance);
Other response (non-site specific "regular" allowance) contains funds for site
assessments and response program and project support, including ARCS program
management, treatability studies, the Technical Assistance Grant (TAG) program,
Core Program Cooperative Agreement (CPCA) funds, and pollution liability
insurance;
Enforcement (non-site specific "regular" allowance); and
Federal Facility (non-site specific "regular" allowance).
The following sections explain how these allowances are developed and the flexibility
available in the AOA structure.
The AOA Process
The AOA identifies projected obligations for each quarter of the FY. The AOA for FY 93
is based on the final SCAP plans developed in the fourth quarter of FY 92. Funds available for
obligation, however, are limited to projected needs for the upcoming quarter. Regions enter the
quarterly AOA into the Integrated Financial Management System (EFMS). The AA SWER or the
DAA OFFE and the OC review the funding levels entered by the Region and compare them to the
AOA amounts generated by the HQ program offices or POD. If the two agree, within three
working days after the start of the quarter, the HQ OC Budget Division and the AA SWER or the
DAA OFFE approve the AOA in IFMS and the funds are available for obligation.
In the past, the AOA obligation rate through the first two quarters of the FY has been low.
As a result, HQ has implemented the following measures to improve performance:
Regions will not receive their third quarter AOA for a specific
response category unless the commitment/obligation rate is 50
percent or greater in that AOA category. If the commitment/obligation rate
for one response allowance (i.e., RDs) is 35 percent while the rate for another
(i.e.., removals) is 65 percent, the third quarter removal AOA would be issued but
the RD AOA would not be issued.
Regions must obligate and task 60-65 percent of the enforcement regional
extramural funds received in their first and second quarter enforcement AOA. If a
Region does not receive its third quarter enforcement AOA, it is required to produce
a site specific spending plan in WasteLAN for both the third and fourth quarters by
mid-May.
For those Regions that continue to have a low rate of commitment/obligation/tasking,
OSWER or OE will renegotiate the Region's operating plan for the remainder of the year during
June. This may result in a reduction in the Region's annual budget.
Financial Planning for Response AOA
The RI/FS, RD and other response AOAs are the total of the approved site specific or non-
site specific planned obligations at NPL sites in CERCLIS.
ffl-5
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OSWER Directive 9200.3-01H-2
The AOA for RAs is pulled directly from the approved site specific planned obligation in
CERCLIS and is issued by site name, S/S ID and dollar amount. Regions will not receive
RA funds in their AOA unless the remedy technology type is reflected in
CERCLIS. RAs are funded on a first ready/first funded basis.
A Region will not receive funds above its annual Regional budget unless a SCAP
amendment/change request has been approved by HQ. Each quarter, the actual and
approved planned obligations and actual commitments must be less than or equal
to the annual Regional budget or the AOA will not be approved.
Financial Planning for Enforcement AOA
Quarterly AOAs will be issued based on Regional quarterly planned obligations reflected in
CERCLIS. It is also recognized that Regions will have TES obligated untasked funds (carryover)
from one FY to the next Since these funds represent tasking authority, the use and planned use of
these funds will exceed the annual Regional budget. To ensure that the budget is balanced and the
availability of resources when they are needed, Regions should plan on obligating approximately
40 percent of their negotiated budget plus carryover funds in the first quarter, 18 percent in the
second and 21 percent in the third and fourth quarters. Regions may receive a higher percentage of
funds in a quarter only after discussions with HQ. Also, as budget utilization will be measured
against quarterly plans, Regions should request extramural budget funds the quarter in which they
will be utilized.
AQA Flexibility and Change Request Procedures
Regions are required to operate within their quarterly AOA and their annual Regional
budget. Each Region will receive an RA budget based on the schedule for the RA. Regions are
responsible for managing the funds issued in the AOA and for operating within budget ceilings,
floors and other restrictions. Regions may:
Shift funds between projects within the other response, RI/FS, RD, removal,
Federal Facility or enforcement allowances. HQ approval is not required;
Shift existing funds between certain allowances, e.g., the RI/FS and RD
allowances. HQ approval of a change request is required. However, funds cannot
be shifted into the other response allowance, out of the RA allowance, or into or out
of the Federal Facility allowance;
Use response funds to address deficient PRP projects. If substantial fund
involvement will be required, the funds should be transferred to the appropriate
response AOA; and
Move future planned obligations to the current quarter (increase total allowance after
issuance within the annual budget). HQ approval of a change request/SCAP
amendment is required.
In some situations, a change request is required as a result of Regional changes to the
SCAP. Chapter II identifies SCAP amendments and adjustments and when a change request is
needed. Exhibit IH-4 describes the procedures to be followed for an AOA change request.
m-6
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OSWER Directive 9200.3-01H-2
EXHIBIT m-4
AOA CHANGE PROCESS
AOA CHANGES
Decrease Allowance
After Issuance
Increase Total Allowance
After Issuance Within
Annual Budget
Shifting Funds Between
Allowances After
Issuance
IMC sends E-mail change
request to the Regional
Finance office, with copies U
OERR PDBS staff, OWPE
CPB or POD, OFFE staff
IMC sends E-mail change
request to OERR PDBS staff,
OWPE CPB or POD, OFFE
staff with copies to AA
SWER or DAA OFFE and
Regional finance office
IMC sends E-mail change
request to the Regional
finance office, with copies tc
OERR PDBS staff and/or
OWPE CPB staff and AA
SWER
Revise
WasteLAN/CERCLIS
Revise
WasteLAN/CERCLIS
Revise
WasteLAN/CERCLIS
Change request is
electronically transmitted
to HQ through IFMS
AOA in IFMS is revised
to reflect the change
AA SWER or DAA OFFE
sends E-mail approval
memorandum to Regional
program and finance office
andHQOC
The change request is electronically transmitted to HQ through IFMS
AOA in IFMS is revised to reflect the change
OSWER, OFFE and the OC review the request
Revised AOA is approved in IFMS by the HQ OC and AA SWER or DAA OFFE
m-7
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OSWER Directive 9200.3-01H-2
OVERVIEW OF FTE DISTRIBUTION PROCESS
Regional FTE allocations are made through the Hazardous Spill and Site Response Model,
the Technical Enforcement Model and the Federal Facilities Superfund Workload Model.
Resources for the site assessment, remedial and removal programs are contained in the Spill and
Site Response Model. Enforcement resources are in the Technical Enforcement Model and
resources for oversight of Federal Facilities Superfund activities are distributed by the Federal
Facilities Workload Model. The Federal Facilities Workload Model is currently being revised.
The workload models are designed to reflect priorities and policies contained in both the
budget and planning processes. For the most part, the workload models are a straight forward
applications of FTE pricing factors from the national budget to Region-specific SCAP/STARS
targets and ongoing activities in the remedial pipeline. No FTEs are given to projects that
are incorrectly coded and scheduled in CERCLIS.
Regional FTE allocations usually occur in two stages. An initial allocation is made in April
based on preliminary negotiated SCAP/STARS targets and schedules in CERCLIS. A final
distribution is made in September. This distribution reflects the final SCAP and STARS targets
negotiated in August as reflected in CERCLIS and any adjustments to the budget as a result of
Congressional action.
In FY 93, each Region's Superfund response and enforcement FTEs will be frozen at the
FY 90 levels. The Federal Facilities program received an increase in FTEs in FY 92. The
resources available in FY 93 will be the same as FY 92. While the freeze ensures that total
Regional Superfund resources will not be affected, shifting of resources within the Region among
the different program areas may occur. This includes shifts between the response and enforcement
programs. All shifts will be based on the national budget and the Integrated Priority Setting
Matrix.
During negotiations of preliminary and final SCAP/STARS targets, Regions may propose
changes to the targets to match the total Regional Superfund resource level. These proposals must
be made in accordance with the Integrated Priority Setting Matrix. HQ will ensure mat the
cumulative Regional targets meet national budget commitments.
It is anticipated that FY 94 workload models will be unfrozen, and FY 93 mid-year
negotiations will be particularly important. At this time, the process for distributing resources
(preliminary allocation in April, final in September) will be the same as in FY 90. Additional
guidance will be issued, pending Agency decisions.
in-8
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OSWER Directive 9200.3-01H-2
ACRONYMS
-------
OSWER Directive 9200.3-01H-2
AA
AA SWER
AT f
iVJLj J.
AO
AOA
AOC
APR
AR
ARAR
ARCS
ATSDR
BC/AOA
BLM
BUREC
GA-
GAS
CD
CERCLA
CERCLIS
CERHELP
CR
CWA
DA
DAA
DoD
DOE
DOI
DOJ
EE/CA
El
EPA
ERA
ERCS
ERD
ERNS
ESAT
ESF
ESI
FEMA
FFIS
FINDS
FMD
FMFIA
FMO
FR
ACRONYMS
Assistant Administrator
Assistant Administrator for the Office of Solid Waste and Emergency
Response
Alternate
Administrative Order
Advice of Allowance
Administrative Order on Consent
Approved
Administrative Record
Applicable or Relevant and Appropriate Requirements
Alternative Remedial Contracting Strategy
Agency for Toxic Substances and Diseases Registry
Budget Control/Advice of Allowance
Bureau of Land Management
Bureau of Reclamation
Cooperative Agreement
Chemical Abstract Number
Consent Decree
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980
Comprehensive Environmental Response, Compensation, and Liability
Information System
CERCLIS non-site specific data base
Community Relations
Clean Water Act
Deputy Administrator
Deputy Assistant Administrator
Department of Defense
Department of Energy
Department of the Interior
Department of Justice
Engineering Evaluation/Cost Analysis
Environmental Indicators
Environmental Protection Agency
Expedited Response Action
Emergency Response Cleanup Services
Emergency Response Division
Emergency Response Notification System
Environmental Services Assistance Team
Emergency Support Function
Expanded Site Inspection
Federal Emergency Management Agency
Federal Facilities Information System
Facility Index System
Financial Management Division
Federal Managers Financial Integrity Act
Financial Management Office
Federal Register
-------
OSWER Directive 9200.3-01H-2
FS
FTE
FY
FY/Q
GFO
GNL
HQ-
HRS
HSCD
IAG
IFMS
IMC
IRM
LAN
LOE
LTRA
MBO
MM/DD/YY
MSCA
NEAR
NCP
NOAA
NPL
NRC
NRT
OC
OFFE
O&M
OE
OERR
OIG
OMB
OPM
OPP
ORC
OSC
OSW
OSWER
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PC
PCB
PCMD
PDBS
PO
POD
POLREP
PRP
QAPP
Feasibility Study
Full-time Equivalent
Fiscal Year
Fiscal Year/Quarter
Good Faith Offer
General Notice Letter
Headquarters
Hazard Ranking System
Hazardous Site Control Division
Interagency Agreement
Integrated Financial Management System
Information Management Coordinator
Initial Remedial Measure
Local Area Network
Level of Effort
Long Term Response Action
Management by Objectives
Month/Day/Year
Multi-Site Cooperative Agreement
Non-Binding Allocation of Responsibility
National Oil and Hazardous Substances Pollution Contingency Plan or
National Contingency Plan
National Oceanic and Atmospheric Administration
National Priorities List
National Response Center
National Response Team
Office of the Comptroller
Office of Federal Facilities Enforcement
Operations and Maintenance
Office of Enforcement
Office of Emergency and Remedial Response
Office of the Inspector General
Office of Management and Budget
Office of Program Management
Office of Pollution Prevention
Office of Regional Counsel
On-Scene Coordinator
Office of Solid Waste
Office of Solid Waste and Emergency Response
Operable Unit
Office of Underground Storage Tanks
Office of Waste Programs Enforcement
Preliminary Assessment
Personal Computer
Polychlorinated biphenyls
Procurement and Contracts Management Division
Program Development and Budget Staff
Project Officer
Program Operations Division
Pollution Report
Potentially Responsible Party
Quality Assurance Project Plan
II
-------
OSWER Directive 9200.3-01H-2
QAT
RA
RCRA
RD
RDT
REPT
RFP
RI
RI/FS
ROD
RP
RPM
RPO
RRT
SAGA
SACM
SARA
SCAP
SEA
SERC
SI
SMP
SMOA
SNL
SOL
SOW
SRIS
SSC
S/SID
SSP
STARS
TAT
TSCA
TQM
UAO
USAGE
USCG
USFWS
USGS
WAM
ZPO
Quality Action Team
Reme«iial Action
Resource Conservation and Recovery Act
Remedial Design
Regional Decision Team
Regional Emergency Preparedness Team
Request for Proposal
Remedial Investigation
Remedial Investigation and Feasibility Study
Record of Decision
Responsible Party
Remedial Project Manager
Regional Project Officer
Regional Response Team
Site Assessment Cooperative Agreement
Superfund Accelerated Cleanup Model
Superfund Amendments and Reauthorization Act of 1986
Superfund Comprehensive Accomplishments Plan
Site Evaluation Accomplished
State Emergency Response Commissions
Site Inspection
Site Management Plan
State Memorandum of Agreement
Special Notice Letter
Statute of Limitations
Statement of Work
Superfund Report Information System
Superfund State Contracts
Site/Spill Identification Number
Site Safety Plan
Strategic Targeted Activities for Results System
Technical Assistance Team
Toxic Substances Control Act
Total Quality Management
Unilateral Administrative Order
United States Army Corps of Engineers
United States Coast Guard
United States Fish and Wildlife Service
United States Geologial Survey
Work Assignment Manager
Zone Project Officer
m
-------
OSWER Directive 9200.3-01H-2
ORGANIZATIONAL CHARTS
Office of Waste Programs Enforcement
- CERCLA Enforcement Division
Office of Emergency and Remedial Response
- Office of Program Management
- Emergency Response Division
- Hazardous Site Evaluation Division
- Hazardous Site Control Division
Office of Federal Facilities Enforcement
U.S. EPA REGIONS MAP
-------
OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
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OSWER Directive 9200.3-01H-1
-------
OSWER Directive 9200.3-01H-2
INDEX
-------
OSWER Directive 9200.3-01H-2
INDEX
Accomplishment Reporting, II-5
Evaluation Responsibilities, n-7
Superfund Management Reports, n-7
Advice of Allowance (AOA)
AOA Flexibility and Change Request
Procedures, ni-6
AOA Process, IH-5
Financial Planning for Enforcement AOA,
m-6
Financial Planning for Response AOA,
m-5
Regional Allowances, ffl-4
Annual Regional Budget, SCAP's
Relationship to, III-4
Annual Target Setting, Procedures
for, II-2
Budget
Enforcement, ffl-1
Federal Facility, ffl-1
Response, III-l
CERCLIS
Audit Reports, H-9
Data Sponsors, n-12
Data Quality, H-9
Completions, 1-18
Data Quality, CERCLIS, II-9
Deletions, 1-18
Effectiveness, (Program Theme),
1-18
Completions/Deletions, 1-18
Five Year Reviews, 1-19
STARS Targets and Measures, 1-19
Supporting Program Goals, 1-20
Efficiency, (Program Theme), 1-6
Quick Response, 1-11
Superfund Accelerated Cleanup Model
(SACM), 1-6
Supporting Program Goals, 1-15
Enforcement Budget, III-l, 111-3
Development of the FY 93 National
Budget, III-l
Financial Planning for Enforcement AOA,
m-6
Relationship Between SCAP and the
Annual Regional Budget, in-4
Equity, (Program Theme), 1-24
Evaluations, Regional Performance,
II-5
Federal Facilities
Budget, HI-1
Program Goals, 1-17,1-23
Federal Facility Budget, III-l
Federal Facility Program Goals,
1-17, 1-23
Financial Management, Superfund
AOA Flexibility and Change Request
Procedures, III-6
Development of FY 93 National Budget,
ffl-1
Enforcement Budget, m-1
Federal Facilities Budget, III-l
Financial Planning for Enforcement AOA,
m-6
Financial Planning for Response AOA,
m-5
Regional Allowances, in-4
Relationship Between SCAP and Annual
Regional Budget, ni-4
Response Budget, III-l
Financial Planning for Response
AOA, III-5
Integrated Timeline for Site Management,
1-13
-------
OSWER Directive 9200.3-01H-2
INDEX
AOA Flexibility and Change Request
Procedures, III-6
Financial Reporting Requirements,
Advice of Allowance Procedures
AOA Flexibility and Change Request
Procedures, III-6
AOA Process, The, IE-5
Regional Allowances, ffi-4
Five-Year Reviews, 1-19
FTE Distribution Process,
Overview, III-8
Integrated Timeline, 1-13
Integrated Priority Setting Matrix,
1-2
Management Reports, Superfund,
II-7
National Budget, Development of,
III-l
Negotiations, Planning for, II-3
Performance Evaluation
Accomplishment Reporting and
Performance Evaluation, n-5
Superfund Management Reports, n-7
Pipeline
Completions, 1-18
Deletions, 1-18
Enforcement Program Goals, 1-16,1-20
Federal Facility Program Goals, 1-17,1-23
Five-Year Reviews, 1-18
Remedial Program Goals, 1-20
Site Assessment Program Goals, 1-16,1-20
Planning and Accomplishment
Reporting, II-5
Planning for Negotiations, II-3
Priorities
Framework for Setting, 1-2
Integrated Priority Setting Matrix, 1-2
Superfund Accelerated Cleanup Model
(SACM), 1-6
Program Evaluation, II-5
Accomplishment Reporting and
Performance Evaluation, n-5
Evaluation Responsibilities, n-7
Superfund Management Reports, n-7
Program Goals, 1-1
Effectiveness, 1-18
Efficiency, 1-6
Equity, 1-24
Framework for Setting Priorities, 1-2
Themes, FY 93,1-1
Program Goals, Supporting
Enforcement, 1-16,1-20
Federal Facilities, 1-17,1-23
Management Initiatives, 1-23
Remedial, 1-20
Removal, 1-15,1-20
Site Assessment, 1-16,1-20
Program Themes
Effectiveness, 1-18
Efficiency, 1-6
Equity, 1-24
Quick Response at NPL Sites, Ml
Authorities and Contracting Strategies, 1-13
Financial Considerations, 1-12
Procedures, 1-13
Regional Accomplishment
Reporting, II-5
Regional Financial Reporting
Requirements, III-4
B
-------
OSWER Directive 9200.3-01H-2
INDEX
AOA Flexibility and Change Request
Procedures, III-6
AOA Process, ffl-5
Financial Planning for Enforcement AOA,
III-6
Financial Planning for Response AOA,
ffl-5
Regional Allowance, m-4
Regional Performance Evaluations,
II-5
Removal Program Goals, 1-15, 1-20
Authorities and Contract Strategies, 1-13
Financial Considerations, 1-12
Procedures, 1-13
Quick Response, 1-11
Reports
Audit, H-9
Superfund Management Reports (Response
and Enforcement), H-7
Response Budget, III-l
Development of the FY 93 National
Budget, III-l
Financial Planning for AOA, ffl-5
Relationship Between SCAP and the
Annual Regional Budget, in-4
SCAP Accomplishment Reporting,
II-5
SCAP Change Request Procedures,
III-6
SCAP Planning for Negotiations,
II-3
SCAP Requirements
Overview of the SCAP Process, II-2
Performance Evaluation, n-5
Planning for Negotiations, II-3
Procedures for Annual Target Setting, n-2
Regional Accomplishment Reporting,
II-5
Relationship of SCAP to Other
Management Tools, n-1
SCAP/STARS Adjustments and
Amendments, n-9
SCAP Process, Overview of, II-2
SCAP's Relationship to Annual
Regional Budget, III-4
SCAP, Relationship to Other
Management Tools, II-1
SCAP/STARS Adjustments and
Amendments, II-8
Site Assessment Program Goals,
1-16, 1-20
STARS Targets and Measures, 1-19
SCAP/STARS Adjustments and
Amendments, H-9
Superfund Accelerated Cleanup
Model, (SACM), 1-6
Early Actions, I-10
Involvement of Enforcement, 1-11
Long-Term Actions, 1-11
Regional Decision Team (RDT), 1-7
Site Assessment, 1-7
Superfund Management Reports,
II-7
Targets and Measures, STARS,
1-19
Target Setting Procedures, II-2
-------
OSWER Directive 9200.3-01H-2
APPENDIX
SUPERFUND COMPREHENSIVE ACCOMPLISHMENTS PLAN (SCAPVSTRATEGIC
TARGETED ACTIVITIES FOR RESULTS SYSTEM (STARS) TARGETS/MEASURES
AND DEFINITIONS
-------
OSWER Directive 9200.3-01H-2
APPENDIX
SCAP/STARS TARGETS/MEASURES AND DEFINITIONS
TABLE OF CONTENTS
ROLE OF SUPERFUND COMPREHENSIVE ACCOMPLISHMENTS
PLAN(SCAP) A-l
SCAP/STARS TARGETS AND MEASURES A-l
FY 93 SCAP/STARS Targets and Measures A-2
SECTION 1: SITE ASSESSMENT DEFINITIONS A-5
INTRODUCTION A-5
PA Completions A-5
SI Completions (S/F-1) A-6
SECTION 2: PIPELINE DEFINITIONS A-9
INTRODUCTION A-9
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
ENFORCEMENT ACTIVITIES AND SETTLEMENTS A-14
NPL PRP Search Starts A-15
NPL PRP Search Completions A-15
Section 104(e) Letters Issued A-15
Section 104(e) Referrals and Orders Issued A-16
Issuance of General Notice Letters A-16
Issuance of Special Notice Letters A-16
RI/FS Negotiation Starts A-17
RI/FS Negotiation Completions A-17
Removal and RI/FS Administrative Orders A-17
De minimis Settlements Prior to ROD and Number
ofPRPs(S/E-3b) A-18
State Order for RI/FS A-18
Interagency Agreements (lAGs) A-18
REMEDIAL INVESTIGATION/FEASIBILITY STUDIES (RI/FS) A-22
Community Relations A-23
Management Assistance/Support Agency Assistance A-23
Technical Assistance A-24
Technical Assistance Grants A-24
Federal Facility Listing to RI/FS Start Duration A-24
RI/FS Start First and Subsequent A-25
Treatability Study A-27
RI/FS Projects Nominated for SITE Program A-27
RI/FS to Public A-27
Remedies Selected (ROD) First and Subsequent A-28
RI/FS Duration A-29
REMEDIAL DESIGN (RD)/REMEDIAL ACTION (RA)
ENFORCEMENT ACTIVITIES, SETTLEMENTS AND REFERRALS A-32
Administrative Record Compilation Completion A-32
-------
OSWER Directive 9200.3-01H-2
Issuance of Special Notice Letters A-33
RD/RA Negotiation Starts A-33
ROD to RD/RA Negotiation
Start Duration A-33
RD/RA Negotiation Completions A-34
ROD to RD/RA Negotiation Completion Duration A-35
RD/RA Negotiation Duration A-35
RD/RA Settlements and Injunctive Referrals (S/E-la and Ib) A-36
Unilateral Administrative Orders (UAO) Issued for RD/RA A-37
Mixed Funding Settlements A-37
De minimis Settlements and Number of PRPs (S/E-3a) A-38
Section 106,106/107, 107 Case Resolution A-38
State Consent Decree for RD/RA A-39
REMEDIAL DESIGN (RD) A-42
Design Assistance A-42
ROD Signature to RD Start Duration A-43
RD Starts First and Subsequent A-43
RD Completions First and Subsequent A-44
Federal Facility RD Start to RD Complete Duration A-45
REMEDIAL ACTION (RA) A-47
ROD Signature to RA Start Duration A-48
RA Start First and Subsequent A-49
RA Contract Award (S/C-1) A-49
RA On-Site Construction A-50
RA Construction Completion (SC-2) A-50
Final RA NPL Site Construction Completion A-51
Operational and Functional (O & F) A-51
RA Completion A-52
Final RA Completion A-52
Federal Facility RI/FS Start to RA Complete Duration A-53
Federal Facility RA Start to RA Complete Duration A-53
Long-Term Remedial Action (LTRA) A-54
Operation and Maintenance A-55
COST RECOVERY A-59
Issue Demand Letter A-59
Cost Recovery Actions/Decisions Less Than $200,000 A-59
Cost Recovery Actions/Decisions Greater Than $200,000 A-61
Section 106, 106/107,107 Case Resolution A-62
Dollars Achieved Toward Cost Recovery MBO Goal (S/E-7a) A-62
SECTION 3: RESPONSE DEFINITIONS A-65
INTRODUCTION A-65
Number of Sites Where Activity has Started, First NPL Removal
Action or RI/FS (S/C-4) A-66
Number of Remedial Program Remedies Selected (ROD) and Action
Memoranda Signed for Removal Actions at NPL Sites (S/C-5) A-66
NPL Site Construction Completions (S/C-3) A-67
-------
OSWER Directive 9200.3-01H-2
Five Year Reviews Completed A-69
NPL Deletion Initiation A-70
Federal Facility NPL Deletion A-70
Progress Through Environmental Indicators A-71
SECTION 4: REMOVAL DEFINITIONS A-73
INTRODUCTION A-73
REMOVAL ACTIVITIES A-73
Removal Investigations at NPL Sites A-76
Non-NPL PRP Search Starts A-76
Non-NPL PRP Search Completion A-76
Administrative Orders Issued for Removal and RI/FS A-77
Removal Starts NPL and Non-NPL A-77
Emergency Response Activity A-78
NPL and Non-NPL Removal Completions A-79
NPL Site Completions Through Removal A-80
Administrative Record Compilation A-81
Federal Facility Removal/ERAs (FFE-3(2)) A-81
-------
OSWER Directive 9200.3-01H-2
APPENDIX A - TARGETS/MEASURES AND DEFINITIONS
ROLE OF SUPERFUND COMPREHENSIVE ACCOMPLISHMENTS PLAN (SCAP)
SCAP and Strategic Targeted Activities for Results System (STARS) targets are the key
device by which program goals are translated into quantifiable program achievements. They
identify performance expectations for the Regions and should not be seen as only a method for
allocating resources. Specific targets are negotiated by Headquarters (HQ) and the Regions. The
Regions are expected to concentrate their resources on achieving these targets.
STARS is used by the Administrator to set and monitor the progress each program i:
making toward meeting its environmental goals. STARS targets and measures are reported
quarterly by HQ and the Regions to the Office of Pollution Prevention (OPP) through the OPP
STARS computer system. SCAP is used by the Assistant Administrator for the Office of Solid
Waste and Emergency Response (AA SWER), the Office of Enforcement (OE), and senior
Superfund managers to monitor the progress each Region is making toward achieving its Super-
fund goals. SCAP targets and measures are reported monthly by the Regions through the Com-
prehensive Environmental Response, Compensation and Liability Information System
(CERCLIS).
National and Regional STARS goals are established and tracked through SCAP. STARS
targets are a subset of those contained in SCAP.
SCAP/STARS TARGETS AND MEASURES
A SCAP or STARS target (either quarterly or annual) is a pre-determined numerical goal
that is established prior to the Fiscal Year (FY) to ensure that designated activities will take
place. STARS targets and measures track the priorities set forth in the Operating Guidance. All
STARS targets are SCAP targets. An example of a SCAP and STARS targeted activity is
Remedial Action (RA) Contract Award. Annual budgets are allocated based on STARS and
SCAP targets. In addition, Regions are evaluated on a quarterly basis according to their comple-
tion of activities with established targets.
A SCAP or STARS measure, on the other hand, is used to track an activity that is impor-
tant in monitoring overall program progress. The two types of measures are STARS reporting
and SCAP planning/reporting measures. Planning estimates result in numerical goals being
established prior to the FY, which are used in setting annual budgets. Regions report progress
against the planning estimates. STARS reporting measures have no associated quantitative
goals; only actual accomplishments are tracked (e.g., progress through environmental indicators).
National Priorities List (NPL) sites are the top priority for all response, and many en-
forcement and Federal Facility targets and measures. Regions will receive credit for accomplish-
ments at non-NPL sites only for non-NPL removal starts and non-NPL Potentially Responsible
Party (PRP) searches. The following targets and measures will credit accomplishments at both
NPL and non-NPL sites:
Progress Through Environmental Indicators;
Removal Completions;
A-l
-------
OSWER Directive 9200.3-01H-2
Emergency Response Activity;
Cost Recovery Actions/Decisions (< $200,000);
Cost Recovery Actions/Decisions (> $200,000);
107 Case Resolution;
Administrative Record Compilation;
Dollars Achieved Toward Cost Recovery Management by Objective (MBO)
Goal;
» Administrative Orders (AO) Issued for Removal;
Federal Facility Removals/Expedited Response Action (ERA); and
All site assessment, Oil Pollution Act (OPA), and Chemical Emergency Prepared-
ness and Prevention (CEPP) targets and measures.
All other targets and measures accomplishments are credited at NPL sites only.
FY 93 SCAP/STARS Targets and Measures
During the January 1992 Program Management Meeting, HQ and the Regions discussed
the SCAP/STARS targets and measures proposed in the FY 93 Agency Operating Guidance.
Regions expressed concerns that since the budget and workload models are frozen, HQ should
reevaluate and consider dropping some of the SCAP/STARS targets and measures. Based on
this discussion, the Regions voted on the highest priority STARS targets/measures for FY 93.
Seven targets/measures received the greatest number of votes. The information in this Manual
reflects HQ decisions relative to the Regional vote on the STARS targets and measures.
Following are the changes in the STARS targets and measures from FY 92 to FY 93:
Remedial Remedies Selected (Record of Decision (ROD)) and Action Memo-
randa Signed for NPL Removals is a new STARS target (S/C-5). Separate targets
are negotiated in SCAP for RODs and NPL removal starts;
NPL Site Construction Completions is a new STARS measure (S/C-3). The
target includes final RA NPL Site Construction Completions, RODs where all
necessary remediation has been completed and removal completions that cleaned
up NPL sites. Separate targets are negotiated in SCAP for final RA NPL Site
Construction Completions, RODs and removal completions;
RA Construction Completion is a new STARS measure (S/C-2).
De minimis Settlements and Number of PRPs is a new STARS measure (S/E-3).
The measure includes d£ minimis settlements (S/E-3a) and de. minimis settlements
achieved prior to ROD signature (S/E-3b);
Cost Recovery Actions/Decisions > $200,000 replaces Section 107 or 106/107
Settlements and Referrals as a STARS target (S/E-2a);
A-2
-------
OSWER Directive 9200.3-01H-2
Cost Recovery Actions/Decisions < $200,000 is a new STARS measure (S/E-25);
Federal Facility IAG Starts is a new STARS target;
Federal Facility RA Starts is a new STARS target (FFE-3(1));
Federal Facility Removal Actions/Expedited Response Actions (ERA) is a new
STARS measure (FFE-3(2));
RA completions is no longer a STARS target. First, subsequent and final RA
completions are still SCAP targets.
Site Inspection (SI) Completions is no longer a STARS target. It is still a SCAP
target;
Remedial Design (RD) Completions is no longer a STARS target. First and
subsequent RD completions are SCAP targets;
Remedial Investigation/Feasibility Study (RI/FS) Projects Nominated for the
Superfund Innovative Technology Evaluation (SITE) Program is no longer a
STARS reporting measure. It is still a SCAP reporting measure;
The trend analyses - ROD to RD Start Duration, ROD to RA Start Duration, and
ROD to RD/RA Negotiation Completion Duration - are no longer STARS report-
ing measures, however, they are SCAP reporting measures;
AOs Issued for Removals and RI/FS, Dollars Achieved Toward the Cost Recov-
ery MBO Goal, and 104(e) Referrals/Orders are SCAP reporting measures. All
were STARS reporting measures in FY 92; and
Resource Conservation and Recovery Act (RCRA) Preliminary Assessments (PA)
under the Environmental Priorities Initiative (EPI) is no longer tracked in STARS
or SCAP.
The definitions contained in this Appendix are those that were available at the time the
Manual went to the printer. Every effort has been made to ensure that the definitions contained
herein for SCAP and STARS targets and measures are consistent. If there are inconsistencies,
the STARS definition is the official definition. If STARS definitions are revised during the year,
an addendum to the Superfund Program Management Manual may be published.
The term "activity" as used in the definitions applies to a specific action. It does not
relate to the CERCLIS use of the term "activity" which is applied to enforcement actions.
The remainder of this Appendix is divided into the following four major sections:
Section 1: Site Assessment - Includes targets/measures and definitions for PAs
and Sis;
Section 2: Pipeline - Includes targets/measures and definition for response
events and enforcement activities that are integral to the remedial, enforcement
and Federal Facility programs. The definitions in this section are in remedial
pipeline order and include the following activities:
A-3
-------
OSWER Directive 9200.3-01 H-2
RJ/FS Enforcement Activities and Settlements;
RI/FS;
RD/RA Enforcement Activities, Settlements and Referrals;
RD;
RA; and
Cost Recovery.
Section 3: Response - Includes targets/measures and definitions for response
(removal and remedial) events that occur at sites on the NPL. It also includes
definitions for site completions and NPL deletions; and
Section 4: Removal - Includes targets/measures and definitions for events and
enforcement activities that are integral to the operation of the removal program.
Removal actions at Federal Facilities are also included in this section.
A-4
-------
OSWER Directive 9200.3-01H-2
SECTION 1: SITE ASSESSMENT DEFINITIONS
INTRODUCTION
The site assessment targets/measures track the initial events at Superfund sites. Two site
assessment events are projected and tracked through the Superfund Comprehensive Accomplish-
ments Plan (SCAPyStrategic Targeted Activities for Results System (STARS) process:
Preliminary Assessment (PA) Completions; and
Site Inspection (SI) Completions.
SI completions is a SCAP target. PA completions is a SCAP measure. Regions propose
targets for all site assessment activities in the CERHELP data system. Funds for site assessment
activities are included in the other response Advice of Allowance (AOA). Exhibit A-l displays
the SCAP/STARS targets and measures for the site assessment program.
EXHIBIT A4: SITE ASSISSMIMT S£&P/$TAKS T&RQUB AND Mi ASUK1S
PA
COMPLETIONS
SI COMPLETIONS
EPA - PA/SI
COMPLETIONS
STATE - PA/SI
COMPLETIONS
STARS/SCAP
TARGET
X*
STARS
REPORTING
SCAP PLAN
& REPORT
X
X
X
QUARTERLY
X
X
X
X
ANNUAL
X
X
X
X
*SCAP only
PA COMPLETIONS
Definition: A PA is the first stage of site assessment which determines whether a site
should be recommended for further Comprehensive Environmental Response, Compen-
sation and Liability Act (CERCLA) action. Federal, State, and local government files,
geological and hydrological data, and data concerning site practices are reviewed to
complete the PA report. A site reconnaissance is also conducted.
Definition of Accomplishment: A PA is complete when the report is reviewed and
approved by the Region and WasteLAN contains the PA completion date and the deci-
sion on further activities is shown in the Event Qualifier Field. Although a site can have
multiple PAs, only the first completed PA with an 'S' or 'F' lead counts toward the
target.
A-5
-------
OSWER Dkective 9200.3-01H-2
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: For budget and resource allocations,
separate projections must be made for Environmental Protection Agency (EPA) vs. State
PA completions. Accomplishments are reported site specifically in WasteLAN. This is a
SCAP reporting measure.
SI COMPLETIONS
Definition: The SI involves collection of field data from a hazardous substance site for
the purpose of characterizing the magnitude and severity of the hazard posed by the site
and/or to support enforcement. An SI should provide adequate data to determine the
site's Hazard Ranking System (HRS) score.
Definition of Accomplishment: This measure includes only screening Sis. A SI is
complete when: 1) a Focused Site Inspection Report has been received by the Region
from the Alternative Remedial Contracting Strategy (ARCS) contractor or the State;
2) the report has been reviewed and approved by the appropriate Regional official;
3) a decision has been made on whether to proceed with further site evaluation work;
and 4) the SI report date and decision on further action has been recorded in WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP target. Commitments are
made based on the sum of the EPA and State conducted Sis. However, for budget and
resource allocations, separate projections must be made for EPA vs. State SI completions.
Regions propose targets in the CERHELP non-site data system. Accomplishments are
reported site specifically in WasteLAN.
A-6
-------
OSWER Directive 9200.3-01 H-2
:, .C ^;;tx^^^f|tl|::||||p
PLANNING REQUIREMENTS
STARS?
SCAP?
TARGET OR MEASURE?
QUARTERLY TARGETS?
IF YES, WHEN?
PLANNED SITE SPECIFICALLY?
PLANNED/REPORTED ON
OPERABLE UNIT
OR WHOLE SITE BASIS?
REPORTED ON COMBINED PROGRAM
LEAD OR ON A PROGRAM SPECIFIC
BASIS?
REPORTED SITE SPECIFICALLY OR IN
NON-SITE PORTION OF WASTELAN?
AOA CATEGORY?
BASIS FOR AOA?
&&&$&$& 'i^U.'iW^'iJLJ'il
PA
NO
YES
MEASURE
NO
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
OTHER
RESPONSE
NON-SITE
PLANS
«f*|/*i|aif ';;'! .::?:''
SI
NO
YES
TARGET
YES
PRIOR
TOFY
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
OTHER
RESPONSE
NON-SITE
PLANS
A-7
-------
OSWER Directive 9200.3-01 H-2
(This page intentionally left blank)
A-8
-------
OSWER Directive 9200.3-01H-2
SECTION 2: PIPELINE DEFINITIONS
INTRODUCTION
The pipeline definitions include remedial, enforcement and project support activities at
both Federal Facility and non-Federal Facility Superfund sites. The remedial and support events
and enforcement activities have been placed in this section in the order they occur in the Super-
fund pipeline:
Remedial Investigation/Feasibility Study (RI/FS) Enforcement Activities and
Settlements;
RI/FS;
Remedial Design (RD)/Remedial Action (RA) Enforcement Activities, Settle-
ments, and Referrals;
RD;
RA; and
Cost Recovery.
Exhibit A-3 presents the SCAP/STARS targets for pipeline activities. Exhibit A-4
displays the SCAP/STARS reporting measures.
A-9
-------
OSWER Directive 9200.3-01H-2
I>0«IB^A^..PIFEI,I^BB^F/STARS-TAptB.'rS ' -
RI/FS Enforcement
Activities & Settlements
- Interagency Agree-
ments (IAG) Start
- LAG Complete at
National Priorities List
(NPL) or proposed
NPL Sites (FFE-2)
RI/FS
- First RI/FS Start
- Subsequent RI/FS Start
- First Remedy Selected
at NPL Sites-Record of
Decision (ROD)*
- Subsequent Remedy
Selected at NPL Sites -
ROD*
- Federal Facility
Remedy Selection at
NPL Sites (FFE-4)
First Federal Facility
RODs
Subsequent Federal
Facility RODs
RD/RA Enforcement,
Settlements & Referrals
- RD/RA Negotiation
Start
- RD/RA Negotiation
Completion
- RD/RA Settlements
and Injunctive Referrals
(S/E-la and Ib)
RD/RA Settlements
RD/RA Injunctive
Referrals
RD
- First RD Start
- Subsequent RD Start
- First RD Completions
- Subsequent RD
Completions
STARS
TARGET
X
X
X**
X
SCAP TARGET
X
X
X +
X +
X
X
X
X
X
X
X
X
x +
x +
x +
x +
QUARTERLY
TARGET
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ANNUAL
TARGET
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
* Includes F, FE, and SE-lead RODs
* * The STARS target combines first and subsequent, if appropriate, as a single target.
+ Includes projects with the following leads: Federal (F), State (S), PRP action under State order/decree (PS),
In-house RI/FS or RD (EP), Responsible party under Federal order /decree (RP), Mixed funding (MR) and Federal
Facility (FF).
A-10
-------
OSWER Directive 9200.3-01H-2
, . EXHIBIT && VOWUm SCAT/STARS TARQ1TS (COHHNUED)
RA
- First RA Start (Fund)
- Subsequent RA Start
(Fund)
- First RA Start
Potentially Responsible
Party (PRP)
- Subsequent RA Start
(PRP)
- RA Start-Federal
Facility (FFE-3U))
First RA Start
Subsequent RA Start
- RA Contract Award
(S/C-1)
First RA Contract
Award
Subsequent RA
Contract Award
- RA Completions
First RA Completion
Subsequent RA
Completion
Final RA Completion
Cost Recovery
- Actions/Decisions
(>$200,000) (S/E-2a)
STARS
TARGET
X**
X**
X
SCAP
TARGET
X
X
X
X
X
X
X
X
x +
x +
X
X
QUARTERLY
TARGET
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ANNUAL
TARGET
X
X
X
X
X
X
X
X
X
X
X
X
X
X
* * The STARS target combines first and subsequent, if appropriate, as a single target.
+ Includes projects with the following leads: Federal (F), State (S), PRP action under State order /decree (PS),
In-house RI/FS or RD (EP), Responsible party under Federal order /decree (RP), Mixed funding (MR) and Federal
Facility (FF).
A-11
-------
OSWER Directive 9200.3-01H-2
WmKA&.mPm3m$ey&£TAmmMmES ' '" : '.:<-
RI/FS Enforcement
Activities & Settlements
- NPL PRP Search Start
- NPL PRP Search
Completion
- 104(e) Letters Issued
- 104(e) Referrals &
Orders Issued
- Issuance of General
Notice Letters (GNL)
- Issuance of Special
Notice Letters (SNL)*
- RI/FS Negotiation Start
- RI/FS Negotiation
Completion
- De minimis Settlements
Prior to ROD (S/E-3b)
- Administrative Order
(AO) Issued for
Removals & RI/FS
- State Orders for RI/FS
Issued
RI/FS
- Federal Facility Listing
to RI/FS Start Duration
- Treatability Studies
- RI/FS Projects
Nominated for the
Superfund Innovative
Technology Evaluation
(SITE) Program
- RI/FS to Public
- RI/FS Duration
RD/RA Enforcement
Activities, Settlements &
Referrals
- Remedial
Administrative Record
Compilation
- Issuance of SNL*
- ROD to RD/RA
Negotiation Start
Duration
- ROD to RD/RA
Negotiation Completion
Duration
- RD/RA Negotiation
Duration
- Unilateral
Administrative Orders
(UAO) Issued for
RD/RA
STARS
REPORTING
X
SCAT
PLAN/REPORT
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x +
X
X
X
X
X
X
QUARTERLY
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ANNUAL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
+Indudes projects with the following leads: Federal (F), State (S), In-house ( EP), PRP action under State order/decree (PS),
Responsible party under Federal order/decree (RP), Mixed Funding (MR) and Federal Facility (FF).
'Activity is listed in two places in the exhibit.
A-12
-------
OSWER Directive 9200.3-01H-2
; EXHIBIT A«4t i ^IPlEBSriB:SAE/^ARS. MEpipE&:;*C$^ ''."..
RD/RA Enforcement
Activities, Settlements
Ef Referrals (continued)
~ Mixed Funding
Settlements Achieved
~ De minimis Settlements
(S/E-3a)
- Section 106, 106/107,
107 Case Resolution*
~ State Consent Decrees
(CD) for RD/RA Issued
RD
- ROD to RD Start
Duration
- Federal Facility RD
Start to RD Complete
Duration
RA
- ROD to RA Start
Duration
- Federal Facility RA
Contract Award
- RAOn-Site
Construction
~ RA Construction
Completion (S/C-2)
- NFL Site Construction
Completion (Final RA)
Federal Facility RA
- Final Completion
Federal Facility RA
- Start to RA Complete
Duration
Cost Recovery
~ Demand Letters Issued
~ Actions /Decisions
(<$200,000) (S/E-2b)
- Section 106, 106/107,
107 Case Resolution*
~ Dollars Achieved
Toward Cost Recovery
Management by
Objective (MBO) Goal
STARS
REPORTING
X
X
X
SCAP
PLAN/REPORT
X
X
X
X
X
X
X +
X
X
X
X
X
X
X
X
X
X
QUARTERLY
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ANNUAL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
^Includes projects with the following leads: Federal (F), State (S), PRP action under State order/decree (PS), Responsible party
under Federal order/decree (RP), Mixed Funding (MR) and Federal Facility (FF).
* Activity is listed in two places in the exhibit.
A-13
-------
OSWER Directive 9200.3-01H-2
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS) ENFORCEMENT ACTIVI-
TIES AND SETTLEMENTS
Following are the definitions for the RI/FS search, negotiation and settlement activities,
and Federal Facility Interagency Agreement (IAG) activities that are included in this section:
National Priorities List (NPL) Potentially Responsible Party (PRP) Search Starts;
NPL PRP Search Completions;
Section 104(e) Letters Issued;
Section 104(e) Referrals and Orders;
Issuance of General Notice Letters (GNL);
Issuance of Special Notice Letters (SNL);
RI/FS Negotiation Starts;
RI/FS Negotiation Completions;
Administrative Orders (AO) Issued for Removals and RI/FS;
De minimis Settlements Prior to the Record of Decision (ROD) and Number of
PRPs;
State Order for RI/FS Issued;
IAG Start; and
lAGs Complete at NPL or Proposed NPL Sites.
IAG start and lAGs complete at NPL or proposed NPL sites are SCAP/STARS targets.
De minimis settlements prior to ROD is a STARS reporting measure. NPL PRP search starts
and completions, Section 104(e) letters issued, Section 104(e) referrals and orders, issuance of
GNL, issuance of SNL, RI/FS negotiation starts and completions, AOs issued for removal and
RI/FS, and State orders issued for RI/FS are SCAP measures.
All of the RI/FS enforcement activities and settlements are planned site specifically.
Planning and accomplishment data for these activities are reported in WasteLAN. Funds to
support the non-Federal Facility enforcement activities are contained in the enforcement Advice
of Allowance (AOA). Funds to support Federal Facility lAGs are allocated in the Federal
Facility AOA.
For the definitions below, IAG start and completion definitions have been combined.
The definition for SNLs issued appears in this section and the RD/RA Enforcement Activities,
Settlements and Referrals Section. The definition for AOs issued for RI/FS and removals appear
in this section and Section 4: Removal Definitions.
A-14
-------
OSWER Directive 9200.3-01H-2
NPL PRP SEARCH STARTS
Definition: The purpose of the PRP search is to identify PRPs. At NPL sites the PRP
search should be initiated at the same time as the Site Inspection (SI) or Expanded Site
Inspection (ESI) or, at the latest, with the listing of the site. It should be completed in
time to send a GNL which should be approximately two months before the SNL date and
at least 90 days prior to the obligation of funds for a PJ/FS.
Definition of Accomplishment: If the search is being conducted by a contractor, the
start date is considered to be the date the work assignment is procured. If it is conducted
by EPA, the start date is the day the EPA staff begins the PRP search activities.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: NPL PRP searches are planned and funds
requested on a site-specific basis. PRP searches should be planned for all sites listed on
the NPL. This is a SCAP reporting measure.
NPL PRP SEARCH COMPLETIONS
Definition: A PRP search is the action taken by the Region to identify the responsible
parties at a site.
Definition of Accomplishment: The PRP search is complete when PRPs at a site have
been identified, all applicable activities described in the Agency's PRP Search Manual
have been completed, and the date and the outcome of the search has been determined
and entered into WasteLAN. If no PRPs are found, the date and the outcome of the
search are entered into WasteLAN.
This definition applies to both Phase I (single owner, operator site) and Phase II (multi-
generator site) PRP search accomplishments.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: NPL PRP search completions are planned
on a site-specific basis. This is a SCAP reporting measure.
SECTION 104(e) LETTERS ISSUED
Definition: This is a letter issued under Section 104(e) of the Superfund Amendments
and Reauthorization Act (SARA). It requests information from PRPs on matters such as:
the nature and extent of a release or threatened release at a site; nature and quantity of
materials; indemnification; financial ability of PRP to pay for response actions.
Definition of Accomplishment: Credit for this activity is given on the date the informa-
tion request letter is signed by the appropriate EPA official.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
recorded at the milestone level.
A-15
-------
OSWER Directive 9200.3-01H-2
SECTION 104(e) REFERRALS AND ORDERS ISSUED
Definition: Section 104(e)(5) referrals/orders are enforcement actions to compel parties
to respond to EPA requests for information.
Definition of Accomplishment: Report the number of Section 104(e)(5) orders issued or
referrals to Headquarters (HQ) or to the Department of Justice (DOJ) to compel PRPs to
comply with information requests. Credit for the referral is the date on the Regional
Administrator's transmittal memo to HQ or to the DOJ as recorded in WasteLAN. Credit
for the order is based on the date it is signed by the Regional Administrator as recorded in
WasteLAN. Due to workload considerations, Regions issuing referrals for non-compli-
ance with a Section 104(e)(5) order will receive credit for both the order and the follow-
up referral.
Changes in Definition FY 92 - FY 93.
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
ISSUANCE OF GENERAL NOTICE LETTERS
Definition: Letter sent by EPA under Section 122 of SARA informing recipients of their
potential liability for cleanup actions at the site. It is usually sent out during the PRP
search or during preparation for negotiations.
Definition of Accomplishment: Credit for this activity is given on the date the GNL is
signed by the appropriate EPA official.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
recorded at the milestone level.
ISSUANCE OF SPECIAL NOTICE LETTERS
Definition: A SNL is a letter from EPA to the PRPs informing them of their potential
liability and inviting them to offer to conduct the planned response action(s) at the site.
This letter, under Section 122 of SARA, triggers a negotiation moratorium allowing the
PRPs to consider EPA's invitation to negotiate. The moratorium period varies depending
on the response action (RI/FS, RD/RA) and can be extended if necessary.
Definition of Accomplishment: Credit for this activity is given on the date the SNL is
signed by the appropriate EPA official.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
recorded at the milestone level.
A-16
-------
OSWER Directive 9200.3-01 H-2
RI/FS NEGOTIATION STARTS
Definition: RI/FS negotiations are discussions between EPA and the PRPs on their
liability, willingness, and ability to conduct the RI/FS.
Definition of Accomplishment: RI/FS negotiations start when:
The first SNL is signed, or
A waiver of SNL is signed.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: If the Region does not plan to perform
RI/FS negotiations at a site, negotiation dates should not be placed in WasteLAN. The
start of RI/FS negotiations should be planned site specifically. This is a SCAP reporting
measure.
RI/FS NEGOTIATION COMPLETIONS
Definition: RI/FS negotiations end when the Region decides how to proceed with the
RI/FS activities.
Definition of Accomplishment: RI/FS negotiations end when:
A Unilateral Administrative Order (UAO)* or Administrative Order on Consent
(AOC) for RI/FS is signed by the Regional Administrator;
A signed Consent Decree (CD) for RI/FS is referred by the Region to HQ or DOJ;
or
The Region decides to proceed with a Fund-financed RI/FS, terminates negotia-
tions, and obligates funds for the RI/FS.
The negotiations conclusion date is the date the Regional Administrator signs the order,
the date on the transmittal letter referring the CD, or the date funds for RI/FS are obli-
gated.
* A UAO is not the preferred enforcement tool for RI/FS and should be used only under
unique circumstances.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: The activity is planned site specifically in
WasteLAN. This is a SCAP reporting measure.
REMOVAL AND RI/FS ADMINISTRATIVE ORDERS
Definition: Administrative Orders (AOC and UAO) are an enforcement tool to compel
the PRPs to assume responsibility for removal actions and RI/FS projects.
Definition of Accomplishment: Report Section 104/106/122 Administrative Orders
(AOC and UAO) issued by EPA for PRPs to conduct removal actions and/or RI/FSs.
A-17
-------
OSWER Directive 9200.3-01 H-2
Credit for the order is based on the date it is signed by the Regional Administrator as
recorded in WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Projections for AOs for RI/FS are made
site specifically. This is a SCAP reporting measure.
DE MINIMIS SETTLEMENTS PRIOR TO ROD AND NUMBER OF PRPS (S/E-3B)
Definition: Administrative or judicial settlement reached under Section 122(g) of SARA
prior to the first remedy being selected (ROD signature). This settlement involves the
established de minimis portions of the response costs at the site and is embodied as a CD
or in an AOC. If the total response costs at the site exceed $500,000 (excluding interest),
the AOC can only be issued with DOJ's prior written approval. If DOJ does not approve
or disapprove the AO within 30 days, the AOC is considered approved and can be issued.
(DOJ and the Administrator can agree to extend this 30-day period.)
Definition of Accomplishment: Credit for a final settlement is identified when an AOC
is signed by the Regional Administrator (as reported in WasteLAN), and for a CD, when
the Regional Administrator signs the transmittal memo to HQ or to the DOJ (as reported
in WasteLAN). The number of PRP signatories to each settlement must also be reported.
Post ROD de minimis settlements will not count in this measure.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: The remedy qualifier for de. minimis must
be entered into WasteLAN Enforcement Remedy Qualifier data elements (C2741 -
C2750 = "DL" or "DG"). This is a STARS reporting measure.
STATE ORDER FOR RI/FS
Definition: AO or CD signed by the State and the PRPs for the PRPs to conduct the
RI/FS.
Definition of Accomplishment: The date the last State official or party signs the order
or CD. All WasteLAN coding requirements for AOs and CDs apply. The enforcement
activity type (C1701) should be State decree ("SD") or State order ("SO") and the date
should be placed in C1717. In addition, the remedy field must denote that the AO/CD
was issued for an RI/FS.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure not a
targeted activity.
INTERAGENCY AGREEMENTS (lAGs)
Definition: Under CERCLA Section 120, Federal agencies are required to enter into an
IAG with EPA within six months of completing the RI/FS. However, as a matter of
policy, HQ encourages the Regions to enter into an IAG as soon after NPL listing as
A-18
-------
OSWER Directive 9200.3-01H-2
possible. lAGs are legally binding requirements which set forth detailed requirements for
performance of site response activities, as well as appropriate enforcement responses to
non-compliance with the IAG. IAG negotiations provide the Federal agency an opportu-
nity to meet with EPA, and often the State, to discuss key issues and come to a final
agreement.
Definition of Accomplishment:
IAG Start Date: Date notice letter is sent by EPA to the Federal Facility.
IAG Completion Date: Date the Federal agency and all parties sign the LAG, or the date
which the Letter of Intent is signed by all parties, or the date the draft IAG is signed by
all parties (generally prior to the start of a public comment period), or the date the LAG is
elevated to HQ for dispute resolution, or the date the IAG goes to Federal agency HQ, or
the date public comment is initiated.
NOTE: To enable accurate tracking of major milestones, a non-targeted data element,
IAG Effective Date will be added to CERCLIS. This will be the date on which the IAG
becomes effective.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: IAG start and IAG complete are STARS/
SCAP targets.
A-19
-------
OSWER Directive 9200.3-01 H-2
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A-20
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OSWER Directive 9200.3-01H-2
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A-21
-------
OSWER Directive 9200.3-01H-2
REMEDIAL INVESTIGATION/FEASIBILITY STUDIES (RI/FS)
Following are the SCAP and STARS events tracked for RI/FS:
Federal Facility Final Listing to RI/FS Start Duration;
First RI/FS Starts (Fund-financed, PRP and Federal Facility);
Subsequent RI/FS Starts (Fund-financed, PRP and Federal Facility);
Treatability Studies (Fund-financed and PRP);
RI/FS Projects Nominated for the Superfund Innovative Technology Evaluation
(SITE) Program (Fund-financed and PRP);
RI/FS to Public (Fund-financed and PRP);
First Remedy Selected (Record of Decision (ROD)) (Fund (F), Federal Enforce-
ment (FE), State Enforcement (SE), and Federal Facility (FF));
Subsequent Remedy Selected (ROD) (F, FE, SE, and FF); and
RI/FS Duration (Fund-financed, PRP and Federal Facility).
Federal Facility RODs is a STARS/SCAP target. First RI/FS start or first NPL removal
start is a target under STARS measure S/C-4 titled Number of Sites Where Activity Has Started.
The definition for Number of Sites Where Activity Has Started can be found in Section 3: Re-
sponse Definitions. The number of remedies selected and action memoranda signed for removal
actions at NPL sites are a target under STARS measure S/C-5. The definition for Remedies
Selected and Action Memoranda Signed can be found in Section 3: Response Definitions. First
and subsequent RI/FS starts, and F, FE, SE, and FF first and subsequent remedies selected
(RODs) are SCAP targets. RI/FS projects nominated for the SITE program, treatability studies,
Federal Facility final listing to RI/FS start duration, and Fund-financed, PRP and Federal Facility
RI/FS duration are SCAP reporting measures.
RI/FS commitments are made on a combined Fund-financed and PRP basis and there is a
limit on the number of RI/FS starts during the FY. Separate Fund-financed, PRP and Federal
Facility goals for RI/FS starts are set prior to the FY. All RI/FS activities are planned on a site,
OU and project specific basis. Planning and accomplishment information are entered into
WasteLAN. Funds for Fund-financed RI/FS projects are in the RI/FS AOA. Funds for oversight
of PRP and Federal Facility RI/FS projects are available in the enforcement and Federal Facility
AOAs, respectively.
For the definitions below, first and subsequent RI/FS starts have been combined, as have
first and subsequent remedy selections (RODs).
Definitions for RI/FS project support activities are presented at the beginning of this
section.
A-22
-------
OSWER Directive 9200.3-01H-2
COMMUNITY RELATIONS
Definition: Community Relations (CR) are the activities conducted in accordance with
SARA, the National Contingency Plan (NCP) and the Community Relations Handbook to
involve the community in response activities conducted at a site.
Definition of Accomplishment: The start of CR is the obligation of funds for the devel-
opment of the Community Relations Plan (CRP). For RP-lead sites where the PRP is
preparing the CRP in accordance with an AO or CD, the start of CR is defined as EPA
approval of the CRP. For EP-lead sites, CR begins when EPA initiates work on the CRP.
The completion of CR is the deletion of the site from the NPL or the conclusion of a
removal action.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: CR activities at PRP sites and Federal
Facilities are paid for by the Regional enforcement extramural budget and Federal Facil-
ity budget, respectively. Planned and actual start and completion dates are not required in
WasteLAN. Funds may be planned site or non-site specifically; however, they must be
obligated site specifically. Once funds are obligated, the non-site specific amount must
be reduced. Funds for CR activities are in the enforcement, other response or Federal
Facility AOAs.
MANAGEMENT ASSISTANCE/SUPPORT AGENCY ASSISTANCE
Definition: Management assistance/support agency assistance are the activities per-
formed by another entity in support of EPA. The support agency furnishes necessary
data to EPA, reviews response data and documents, and provides other assistance to EPA.
EPA may provide States, political subdivisions and Indian Tribes with funding to carry
out a variety of management responsibilities via a support agency Cooperative Agree-
ment (CA) to ensure their meaningful and substantial involvement in response activities.
Unless otherwise specified in the CA, all support agency costs, with the exception of RA
support agency costs, may be documented under a single Superfund account number
designated specifically for support agency activities. RA support agency activities must
be documented site specifically and require cost share provisions.
Definition of Accomplishment: The start of management assistance/support agency
assistance is the signature of the CA by the Regional Administrator or his designee. The
completion of management assistance is the completion of all remedial activities at the
site.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Management assistance/support agency
assistance activities for RP and PS-lead projects are paid for by the enforcement program,
are contained in the Regional enforcement extramural budget, and distributed to the
Region in the enforcement AOA. Funds to support MR and F-lead projects are in the
other response AOA. Planned and actual start and completion dates are not required in
WasteLAN. Funds may be planned site or non-site specifically; however, they must be
obligated site specifically. Once funds are obligated, the non-site specific amount must
be reduced.
A-23
-------
OSWER Directive 9200.3-01 H-2
TECHNICAL ASSISTANCE
Definition: Technical assistance is support provided by a third party to EPA in the
conduct of response activities.
Definition of Accomplishment: The start of technical assistance is the obligation of
funds for technical assistance. The completion is defined as the completion of the re-
sponse activities for which technical assistance was requested.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Planned and actual start and completion
dates are not required in WasteLAN. Funds may be planned site or non-site specifically;
however, they must be obligated site specifically. Once funds are obligated, the non-site
specific amount must be reduced. Funds for technical assistance are contained in the
other response AOA.
TECHNICAL ASSISTANCE GRANTS
Definition: Technical Assistance Grants (TAG) are provided under SARA to a commu-
nity for technical assistance in dealing with Superfund issues at NPL sites.
Definition of Accomplishment: The start of the TAG is the signature of the CA to the
community group. The completion of the TAG is the completion of the final RA or the
deletion of the site from the NPL.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Planned and actual start and completion
dates are not required in WasteLAN. Funds may be planned site or non-site specifically;
however, they must be obligated site specifically. Once funds are obligated, the non-site
specific amount must be reduced. Funds for TAGs at non-Federal Facility sites are
contained in the response budget and found in the other response AOA. Funds for TAGs
at Federal Facilities are in the Federal Facility AOA.
FEDERAL FACILITY LISTING TO RI/FS START DURATION
Definition: CERCLA/SARA Section 120(e) states "not later than six months after the
inclusion of any facility on the NPL the department, agency, or instrumentality shall...
commence a RI/FS for such facility."
Definition of Accomplishment: This measure will count final NPL sites, where the
duration between final NPL listing (publication of final listing in the Federal Register
and the first RI/FS start is less than six months (two quarters). The duration will be
calculated based on the RI/FS start definition contained in this manual.
Changes in Definition FY 92 - FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
A-24
-------
OSWER Directive 9200.3-01H-2
RI/FS START FIRST AND SUBSEQUENT
Definition: The RI/FS is an investigation designed to characterize the site, assess the
nature and extent of the contamination, evaluate potential risk to human health and the
environment, and develop and evaluate potential remediation alternatives.
In order for the RI/FS to be counted as a first start it must not have had previous RI/FS
activity at the site, a prior CERCLA settlement or prior Fund obligation for Remedial
Investigation (RI), Feasibility Study (FS), or combined RI/FS. In order for the Fund-
financed and PRP RI/FS to be counted in the STARS target S/C-4, Number of Sites
Where Activity has Started, First NPL Removal Actions and RI/FS, it must not have had
previous RI/FS or removal activity at the site.
Obligation of funds for forward planning, community relations and/or other support
activities do not constitute an RI/FS start. A subsequent RI/FS is any RI/FS that starts
after the first one.
Definition of Accomplishment:
Fund-financed (Including F- and S-lead events.) - A Fund RI/FS start is counted when
funds are obligated. Funds are obligated when:
The contract modification for the RI/FS has been signed by the Contracting
Officer (CO);
An IAG has been signed by the other Federal agency (U.S. Army Corps of Engi-
neers (USAGE) or Bureau of Reclamation (BUREC)); or
A CA has been signed by the Regional Administrator or his designee to conduct
an RI/FS; and
Obligations have been recorded or documented in WasteLAN.
If a subsequent RI/FS or focused FS is initiated without a new obligation of funds, the
start date is defined as EPA approval of the work plan for the subsequent RI/FS.
PRP-fmanced (Includes RP-, MR-, and PS- lead events) - A Responsible Party (RP or
MR)-lead RI/FS start counts when one of the following enforcement actions occurs:
An AOC is signed by the Regional Administrator. The RI/FS start date is the
AOC completion date (Regional Administrator signature date); or
A CD is referred by the Region to DOJ or HQ. The RI/FS start date is the last
signature date by the appropriate official or party (e.g., the Regional Administra-
tor, DOJ, or HQ);
A PS-lead RI/FS start counts when a State order or comparable enforcement document is
signed by the last appropriate official or party and the site is covered by one of the fol-
lowing:
State enforcement CA;
A-25
-------
OSWER Directive 9200.3-01H-2
Superfund Memorandum of Agreement (SMOA) containing a schedule for RI/FS
work at the site; or
Other State/EPA agreement.
If a subsequent RI/FS is initiated without a new or amended AOC, CD, State order, or
other comparable State enforcement document, the start date for the RI/FS is defined as
EPA's or the State's approval of the work plan for the subsequent RI/FS.
If an AOC, a State order, or other comparable State enforcement document is amended
for the subsequent RI/FS, the start date is the date the last official signs the amendment.
If an EPA CD is amended, the start date is the last signature date by the appropriate
official or party.
Federal Facility - In general, the RI/FS first start date should coincide with the IAG
effective date. However, for sites where RI/FS work starts prior to the IAG effective
date, the earliest date reportable is the IAG completion date. For sites where RI/FS work
is initiated under a Resource Conservation and Recovery Act (RCRA) order or permit,
the RI/FS first start date should equal the date when the RCRA order or permit becomes
effective. In rare cases, with HQ approval, when the RI/FS has been initiated prior to the
IAG completion date and there has been extensive Regional involvement with the facil-
ity, the RI/FS first start date can be the receipt of the RI/FS work plan.
Subsequent RI/FS starts count on the date of receipt of the work plan which addresses the
subsequent RI/FS. For cases where the subsequent RI/FS is described in the same work
plan as the first RI/FS start, the subsequent RI/FS start is the date of the RI/FS first start
(which is generally the IAG effective date or IAG completion date, whichever is earlier).
In rare cases, with HQ approval, when the RI/FS has been initiated prior to the IAG
completion date and there has been extensive Regional involvement with the facility, the
RI/FS subsequent start date can be the receipt of the RI/FS workplan.
EP-lead - An EP-lead RI/FS counts when the Region begins preparation of the
workplans following the initial scoping meeting.
Changes in Definition FY 92 - FY 93: Federal Facility definition is new in FY 93.
Special Planning/Reporting Requirements: First Fund or PRP RI/FS start or first Fund
or PRP NPL removal start is a target under STARS S/C-4, Number of Sites Where
Activity Has Started. The definition for Number of Sites Where Activity Has Started can
be found in Section 3: Response Definitions. Individual targets for first RI/FS starts and
NPL removals are established in SCAP. Separate Fund-financed, RP-lead and Federal
Facility RI/FS start targets will be established in SCAP prior to the FY. A limit will be
placed on the number of Fund-financed, RP and PS lead RI/FS that can be started during
the FY for budget purposes. Targets are established site specifically. For first RI/FS
starts, "to be determined (TBD)" sites are allowed.
Regions cannot receive credit for a site under STARS S/C-4, Number of Sites Where
Activity has Started, First NPL Removal Actions and RI/FS, if an RI/FS or NPL removal
began or was conducted at the site in a previous year. Regions also cannot receive credit
under STARS for both an RI/FS start and an NPL removal if they are started in the same
year. Credit is given for the first activity started and a site can receive credit only once.
Therefore, historical data must be reviewed prior to negotiating commitments and report-
A-26
-------
OSWER Directive 9200.3-01 H-2
ing accomplishments in STARS. Regions can receive credit for both individual events in
SCAP.
TREAT ABILITY STUDY
Definition: Treatability studies are laboratory or field tests used to evaluate and imple-
ment one or more remedial alternatives. This definition also covers post-ROD
treatability studies.
Definition of Accomplishment:
Fund-financed - The start of the treatability study is the obligation of funds specifically
for the study. If unexpended RI/FS or RD funds are used for the treatability study, the
start date is the date of EPA approval, as reflected in WasteLAN, of the treatability study
work plan. The completion is the approval of the report on the results of the treatability
study.
PRP-financed - The treatability study starts when EPA approves the treatability study
work plan submitted by the PRPs. The completion is the approval of the report on the
results of the treatability study.
Changes in Definition FY 92 - FY 93: Added that the definition also covers treatability
studies to support remedy implementation (i.e., RD/RA treatability studies). Included
Fund-financed and PRP definitions.
Special Planning/Reporting Requirements: Planned and actual start and completion
dates are required in WasteLAN. Funds are planned site specifically and are placed in
the other response AOA. This is a SCAP reporting measure.
RI/FS PROJECTS NOMINATED FOR SITE PROGRAM
Definition: The SITE program assesses new technologies for the treatment of hazardous
waste. Technologies enter the program through an annual solicitation. Once technolo-
gies are selected, it is necessary to find demonstration sites.
Definition of Accomplishment: An RI/FS project is nominated for the SITE program
when the Region sends a memorandum to HQ formally submitting the site for consider-
ation as a location for a demonstration project.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Accomplishments are reported site specifi-
cally. Fund-financed or RP-lead sites may be submitted for consideration. This is a
SCAP reporting measure.
RI/FS TO PUBLIC
Definition: The RI/FS is released to the public when the contamination at the site has
been characterized and alternatives for remediation have been evaluated.
A-27
-------
OSWER Directive 9200.3-01H-2
Definition of Accomplishment: An RI/FS to public is accomplished the date the pro-
posed plan is available to the public. This date must be recorded in WasteLAN (C3101)
with the RI/FS event under subevent code "CF."
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Accomplishments are based on the first
proposed plan released to the public for each RI/FS regardless of lead. This is a SCAP
reporting measure.
REMEDIES SELECTED (ROD) FIRST AND SUBSEQUENT
Definition: A remedy is selected at the completion of the RI/FS. Upon completion of
the public comment period on a Fund-financed or RP-lead RI/FS, a ROD which identifies
the Agency's selected remedy for a site or phase of site cleanup is signed by the Assistant
Administrator for the Office of Solid Waste and Emergency Response (AA SWER) or
the Regional Administrator/Deputy Regional Administrator.
Upon completion of a Federal Facility RI/FS, the Federal agency selects a remedy for the
site that is presented in a cleanup decision document (i.e., ROD, Corrective Action
Decision Document). This document is concurred upon or approved by either the AA for
the Office of Enforcement (OE) or the Regional Administrator/Deputy Regional Admin-
istrator.
Definition of Accomplishment:
F. FE. and SE-lead - The date the ROD is signed by the Regional Administrator/Deputy
Regional Administrator or the AA SWER is the remedy selection date.
Federal Facility - Date of EPA approval/concurrence on the clean-up decision document
pursuant to an LAG or other enforceable decision document, or the date of EPA's Letter of
Concurrence.
This date must be entered in WasteLAN as both the RI/FS and ROD completions.
Changes in Definition FY 92 - FY 93: Added Federal Facility ROD requirements.
Special Planning/Reporting Requirements: Commitments are made based on F, FE, or
SE lead RODs that result from F, S, EP, MR, RP, or PS lead RI/FS. Federal Facility
RODs are tracked separately. The RI/FS completion date and ROD completion date are
the same. Planned and actual dates must be entered with both events in WasteLAN. The
RA technology type should be entered into WasteLAN in the RA Technology Type data
field (C3401 = RT) and the specific technology type(s) in the Technical Information
Qualifier fields (C3402 - C3411).
Remedies selected (F, FE, or SE lead RODs) and Action Memorandum signed for re-
moval actions at NPL sites is a combined target under STARS S/C-5. F, FE, or SE lead
RODs at the final OU that state that no further remediation is necessary at the final OU
also meet the STARS measure S/C-3 of NPL Site Construction Completion. Definitions
for Remedies Selected and Action Memoranda Signed and NPL Site Construction
Completion can be found in Section 3: Response Definitions.
A-28
-------
OSWER Directive 9200.3-01H-2
RI/FS DURATION
Definition: The RI/FS is an investigation designed to characterize the site, assess the
nature and extent of contamination, evaluate potential risk to human health and the
environment, and develop and evaluate potential remediation alternatives.
The RI/FS starts with the obligation of Fund monies or the signature of an AO for RI/FS
or the date the Federal Facility IAG effective date. The RI/FS is complete with the
signature of the ROD or EPA concurrence/approval on the Federal Facility cleanup
decision document.
The objective of this measure is to focus on good project management of critical portions
of the remedial pipeline and establish a methodology which accurately assesses program
performance. The Integrated Timeline for Site Management (Chapter I) will be used for
establishing performance expectations. Duration trends provide indicators of areas that
require attention.
Only RI/FS projects that started post-SARA will be used for comparison and evaluation
purposes.
Definition of Accomplishment: This measure includes all RI/FS projects that have a
targeted completion date in FY 93. The RI/FS duration will be calculated based on the
SCAP/STARS RI/FS start and completion definitions specified in this Manual. Regional
performance in FY 93 will be compared to:
The Regional and national average of RI/FS projects completed in FY 91 and FY
92; and
The Regional and national average duration of RI/FS projects completed in
previous quarters of FY 93.
Changes in Definition FY 92 - FY 93: Added definition for calculation of Federal
Facility RI/FS duration.
Special Planning/Reporting Requirements: CERCLIS will automatically look at
actual RI/FS start dates, and planned and actual ROD completion dates. HQ will perform
the analysis of the average durations. Trend duration reports are currently being
developed. Fund, PRP, and Federal Facility RI/FS durations will be tracked. At sites
where one site-wide RI is conducted and OU specific FSs and RODs are conducted, links
data will be used. This is a SCAP reporting measure.
A-29
-------
OSWER Directive 9200.3-01H-2
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A-30
-------
OSWER Directive 9200.3-01 H-2
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OSWER Directive 9200.3-01H-2
REMEDIAL DESIGN (RD)IREMEDIAL ACTION (RA) ENFORCEMENT ACTIVITIES.
SETTLEMENTS AND REFERRALS
Following are the RD/RA negotiations, settlements and referral actions tracked in SCAP
and STARS:
Administrative Record (AR) Compilation Completion (Remedial);
Issuance of SNL;
RD/RA Negotiation Start;
RD/RA Negotiation Completion;
ROD to RD/RA Negotiation Start Duration;
ROD to RD/RA Negotiation Completion Duration;
RD/RA Negotiation Duration;
RD/RA Settlements and Injunctive Referrals;
UAO Issued for RD/RA;
Mixed Funding Settlements Achieved;
De minimis Settlements and Number of PRPs;
Section 106, 106/107, 107 Case Resolution; and
State CDs for RD/RA Issued.
RD/RA settlements and injunctive referrals is a STARS/SCAP target. De minimis
settlements is a STARS reporting measures RD/RA negotiation starts and RD/RA negotiation
completions are SCAP targets. The remaining activities are SCAP reporting measures.
The definition for issuance of SNL can be found in both the following and the RI/FS
Enforcement Activities and Settlements sections. The definition for Section 106, 106/107, 107
Case Resolution are in this section and the Cost Recovery section. The definition for AR compi-
lation completion appears in the following section and Section 4: Removal Definitions.
ADMINISTRATIVE RECORD COMPILATION COMPLETION
Definition: An AR is a compilation of all documents that EPA used to make a specific
decision on the appropriate response action to be taken at a Superfund site. SARA
specifies that ARs be compiled at sites where remedial or removal responses are planned
or are occurring, or where EPA is issuing a UAO or initiating litigation.
Definition of Accomplishment: The AR compilation begins when the AR is received at
the site repository and the start date is entered into WasteLAN. The AR compilation is
complete when the compilation is certified by the program office.
A-32
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OSWER Directive 9200.3-01H-2
Changes in Definition FY 92 - FY 93: Completion definition was modified to match
the December 1990 guidance.
Special Planning/Reporting Requirements: The completion of the compilation of the
AR must be reported site specifically in WasteLAN. A "E" must be recorded in the
Event Qualifier field (C2103) to indicate the AR is for a remedial activity. This is a
SCAP reporting measure.
ISSUANCE OF SPECIAL NOTICE LETTERS
Definition: A SNL is a letter from EPA to the PRPs informing them of their potential
liability and inviting them to offer to conduct the planned response action(s) at the site.
This letter, under Section 122 of SARA, triggers a negotiation moratorium allowing the
PRPs to consider EPA's invitation to negotiate. The moratorium period varies depending
on the response action (RI/FS, RD/RA) and can be extended if necessary.
Definition of Accomplishment: Credit for this activity is given on the date the SNL is
signed by the appropriate EPA official.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
recorded at the milestone level.
RD/RA NEGOTIATION STARTS
Definition: RD/RA negotiations are discussions between EPA and the PRPs on their
liability, willingness and ability to implement the remedy selected in the ROD for the site
orOU.
Definition of Accomplishment: RD/RA negotiations start when:
The first SNL is signed, or
A Section 122(a) waiver of SNL is signed.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: If the Region does not plan to conduct RD/
RA negotiations, dates should not be entered into WasteLAN. The start of RD/RA nego-
tiations is planned site specifcally. This is a SCAP target.
ROD TO RD/RA NEGOTIATION START DURATION
Definition: A remedy is selected when a ROD is signed by either the Regional Adminis-
trator or the AA SWER. RD/RA negotiations begin when the special notice letter is
issued.
The objective of this measure is to focus on good project management of critical portions
of the remedial pipeline, particularly the period between ROD and RA start. It also
results in the establishment of a methodology which accurately assesses program perfor-
mance. The Integrated Timeline for Site Management (Chapter I) will be used for estab-
A-33
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OSWER Directive 9200.3-01H-2
lishing performance expectations. Duration trends provide indicators of areas that require
attention.
Only RODs that resulted from RI/FS projects started post-SARA will be used for
comparison and evaluation.
Definition of Accomplishment: This measure includes all RD/RA negotiations that
have a scheduled start date in FY 93. Regional performance in FY 93 will be compared
to:
The Regional and national average duration for ROD to RD/RA negotiation start
duration in FY 91 and FY 92; and
The Regional and national average duration for ROD to RD/RA negotiation start
duration in previous quarters of FY 93.
The durations will be calculated using the actual ROD completion dates and planned and
actual RD/RA negotiation start dates. The SCAP/STARS definitions for Remedies
Selected (ROD) and RD/RA Negotiation Start contained in this Manual will be used in
the analysis.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will conduct the analysis. CERCLIS trend analysis reports are currently
under development. This is a SCAP reporting measure.
RD/RA NEGOTIATION COMPLETIONS
Definition: RD/RA negotiations end when the Region decides how to proceed with the
RD/RA.
Definition of Accomplishment: RD/RA negotiations end when:
A signed CD (Section 106 or 106/107 referral with settlement) for RD/RA and 10
point analysis are referred by the Region to either DOT or HQ;
A Section 106 or 106/107 injunctive referral to compel the PRPs to perform the
RD/RA is referred to DOJ or HQ. (HQ prefers that a UAO be issued prior to
initiating an injunctive referral);
A UAO for RD/RA or RA only to initiate site work is signed by the Regional
Administrator;
EPA and PRPs proceed to trial under an existing case;
Funds are obligated for a Fund-lead RD; or
If RD funds are not available and the Region decides a UAO is not appropriate;
and HQ concurs with this decision in writing, the negotiation completion date is
the date of the HQ memorandum concurring with the UAO decision.
A-34
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OSWER Directive 9200.3-01H-2
The negotiation conclusion date is: the date on the transmittal letter for the CD, the date
on the transmittal letter with the injunctive referral, the date the UAO is signed by the
Regional Administrator, the date the trial begins, the date funds are obligated, or the date
on HQ memorandum.
Changes in Definition FY 92 - FY 93: Injunctive referrals without a UAO are not
recommended. UAOs are for RD/RA or RA only.
Special Planning/Reporting Requirements: This SCAP target is planned site specifi-
cally in WasteLAN.
ROD TO RD/RA NEGOTIATION COMPLETION DURATION
Definition: A remedy is selected when a ROD is signed by either the Regional Adminis-
trator or AA SWER. RD/RA negotiations end when the Region decides how to proceed
with the RD/RA.
The objective of this measure is to focus on good project management of critical portions
of the remedial pipeline, particularly the period between ROD and RA start. It also
results in the establishment of a methodology which accurately assesses program perfor-
mance. The Integrated Timeline for Site Management (Chapter I) will be used for estab-
lishing performance expectations. Duration trends provide indicators of areas that require
attention.
Only RODs that resulted from RI/FS projects started post-SARA will be used for com-
parison and evaluation.
Definition of Accomplishment: The purpose of this measure is to evaluate Regional
performance in managing the RD/RA negotiation process. It includes all RD/RA nego-
tiations with a scheduled completion date in FY 93. The SCAP/STARS definitions for
Remedies Selected (ROD) and RD/RA Negotiation Completion contained in this Manual
will be used in the analysis. Regional performance in FY 93 will be compared to:
The Regional and national average duration for ROD to RD/RA negotiation
completion in FY 91 and FY 92; and
The Regional and national average duration for ROD to RD/RA negotiation
completion in previous quarters of FY 93.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. The durations will be calculated using the actual ROD completion dates and
planned and actual RD/RA negotiation completion dates. HQ will conduct the analysis.
CERCLIS trend analysis reports are currently under development. This is a SCAP
reporting measure.
RD/RA NEGOTIATION DURATION
Definition: RD/RA negotiations are discussions between EPA and the PRPs on their
liability, willingness and ability to implement the remedy selected in the ROD for the site
orOU.
A-35
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OSWER Directive 9200.3-01H-2
The RD/RA negotiations start when the SNL is signed or a Section 122(a) waiver of SNL
is signed. RD/RA negotiations are complete when a signed CD is referred to DOJ or HQ,
a Section 106 or 106/107 referral to enforce a UAO for RD/RA is referred to DOJ or HQ,
a UAO is issued, EPA and the PRPs proceed to trial under an existing case, or funds are
obligated for a Fund-lead RD.
Definition of Accomplishment: This measure includes all RD/RA negotiations that
have a targeted completion date in FY 93. Regional performance in FY 93 will be
compared to:
The Regional and national average duration of RD/RA negotiations completed in
FY91andFY92;and
The Regional and national average duration of RD/RA negotiations completed in
previous quarters of FY 93.
The durations will be calculated using the actual RD/RA negotiation start dates and
planned and actual RD/RA negotiation completion dates. The SCAP/STARS RD/RA
negotiation start and completion definitions specified in this Manual will be used in the
analysis.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will perform the analysis. Trend duration reports are currently under
development. This is a SCAP reporting measure.
RD/RA SETTLEMENTS AND INJUNCTIVE REFERRALS (S/E-1A AND IB)
Definition: RD/RA settlements are the enforcement actions when the PRPs agree to
conduct the RD and/or RA. That agreement is embodied in a CD. Injunctive referrals
are actions taken to enforce UAOs for RD/RA.
Definition of Accomplishment:
1) RD/RA Settlements (S/E-la) - This measure includes all CD referrals under Section
106, 107 and 122(d) for PRPs to conduct or pay for RD/RA. It includes mixed funding
and cash out settlements for RD/RA. Credit for the CD referral is the date on the Re-
gional Administrator's transmittal memo to HQ or to the DOJ as recorded in WasteLAN.
Regions also receive credit for this measure for UAOs issued under Section 106 for
RD/RA that are in compliance. Credit for UAOs is the date PRPs provide notice of intent
to comply with the order as recorded in WasteLAN. (Should a PRP initially comply with
a UAO, and later a CD is agreed to for the same work, credit will be for the UAO only.)
Also included in this measure are lAGs with Federal agencies at non-Federal Facility
sites.
2) RD/RA Injunctive Referrals (S/E-lb) - This measure includes injunctive referrals,
under Section 106 or 106/107, to enforce a UAO for RD/RA. Credit for the referral is the
date on the Regional Administrator's transmittal memo to HQ or to the DOJ as recorded
in WasteLAN. (Referrals for preliminary relief or penalties do not count toward this
measure.)
A-36
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OSWER Directive 9200.3-01H-2
Changes in Definition FY 92 - FY 93: The measure includes lAGs at non-Federal
Facility sites.
Special Planning/Reporting Requirements: RD/RA settlement and injunctive referrals
are a combined targets in STARS. TBD sites are allowed with an explanation. Credit
will be withdrawn if a case is returned by OE or DOJ for additional work. Credit will be
reinstated upon re-referral and will be based on the quarter of re-referral. In the event a
case is referred in one year and returned to the Region in subsequent years, no credit will
be provided for re-referral.
UNILATERAL ADMINISTRATIVE ORDERS (UAO) ISSUED FOR RD/RA
Definition: UAOs are an enforcement tool to compel the PRPs to conduct the RD and/or
RA.
Definition of Accomplishment: This measure includes UAOs issued under Section 106
to compel PRPs to conduct the RD/RA. Credit is based on the date the UAO is signed by
the Regional Administrator as recorded in WasteLAN. PRPs do not have to comply with
the UAO in order for the Region to receive credit under this measure.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: UAOs are reported separate from RD/RA
settlements and injunctive referrals. This is a SCAP reporting measure.
MIXED FUNDING SETTLEMENTS
Definition: Administrative or judicial settlements under Section 106 or 106/107 and
Section 122(b)(l) of SARA. Mixed funding generically refers to three types of settle-
ments: 1) preauthorization, 2) mixed work, and 3) cash outs. Preauthorization occurs
where PRPs reach a settlement with EPA whereby they agree to perform a share of the
response actions, and the Agency agrees to reimburse some part of their expenses. Mixed
work occurs where PRPs and EPA agree to jointly work on a project or where work may
be divided between the parties. Cash outs are funds received by EPA, a State, or another
PRP to pay for all or part of the future cost for a response action that is or may be imple-
mented at a site.
Definition of Accomplishment: This measure includes mixed funding settlements in the
form of a CD or AOC between EPA and the PRPs. Credit for the CD is the date on the
Regional Administrator's memo transmitting the referral to HQ or DOJ as recorded in
WasteLAN. Credit for the AOC is based on the date it is signed by the Regional Admin-
istrator as recorded in WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure only.
The remedy qualifier for cash out ("CO"), mixed work ("MW"), or preauthorization
("PA") must be entered into WasteLAN Enforcement Remedy Qualifier (C2741 -
C2750).
A-37
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OSWER Directive 9200.3-01H-2
DE MINIMIS SETTLEMENTS AND NUMBER OF PRPS (S/E-3A)
Definition: This is all administrative or judicial settlements that were reached solely
under Section 122(g) of SARA, with PRPs who qualified as d£ minimis PRPs under
Section 122(g). This settlement involves the established d£ minimis portions of the
response costs at the site and is embodied in a CD or an AOC. If the total response costs
at the site exceed $500,000 (excluding interest), the AOC can only be issued with DOJ
prior written approval. If DOJ does not approve or disapprove the AO within 30 days,
the AOC is considered approved and can be issued. (DOJ and the Administrator can
agree to extend this 30-day period.)
Definition of Accomplishment: Credit is given for a final settlement when an AOC is
signed by the Regional Administrator (as reported in WasteLAN) or when the Regional
Administrator signs the memo transmitting the CD to HQ or DOJ (as reported in
WasteLAN). The number of PRP signatories to each settlement must also be reported.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: The remedy qualifier for de minimis must
be entered into WasteLAN Enforcement Remedy Qualifier data elements (C2741 -
C2750 = "DL" or "DO"). This is a STARS reporting measure.
SECTION 106,106/107,107 CASE RESOLUTION
Definition: Case resolution is the conclusion of a Section 106, 106/107, or 107 judicial
action by a full settlement, a final judgment, a case dismissal, or a case withdrawal.
Definition of Accomplishment: Credit for case resolution is given when:
A CD is entered in the court fully addressing the complaint with all parties;
The case is withdrawn;
The case is dismissed; or
A trial concluded and a judgment entered fully addressing the complaint.
The case resolution date (activity actual completion date) is the same as the milestone
date and is defined as follows:
Date CD is entered;
« Date case is withdrawn;
Date case is dismissed; or
Date judgment is entered.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
A-38
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OSWER Directive 9200.3-01 H-2
STATE CONSENT DECREE FOR RD/RA
Definition: Judicial agreement between the State and the PRPs fully or partially settling
a claim under CERCLA. The settlement may be for response work, or both response and
cost recovery work.
Definition of Accomplishment: Date the State CD is signed by the last State official or
party. All WasteLAN coding requirements for CDs apply. The enforcement activity
type (C1701) should be State decree ("SD") and the date should be reported in C1717. In
addition, the remedy field must denote that the CD was issued for RD and/or RA.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure not a
targeted activity.
A-39
-------
OSWER Directive 9200.3-01H-2
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A-40
-------
OSWER Directive 9200.3-01 H-2
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A-41
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OSWER Directive 9200.3-01 H-2
REMEDIAL DESIGN (RD)
RD activities are planned site, OU and project specifically and reported in WasteLAN.
Initial schedules for RD are established when the RI/F'S for the site is initiated. These initial
schedules must be updated in WasteLAN as better planning data become available. The funds
for Fund-financed RDs and oversight of RP-lead RDs are pulled directly from WasteLAN and
allocated in the RD AOA. Funds for oversight of Federal Facility RDs are in the Federal Facility
AOA. The following SCAP and STARS activities are tracked:
First RD Start (Fund-financed, PRP and Federal Facility);
Subsequent RD Start (Fund-financed, PRP and Federal Facility);
ROD Signature to RD Start Duration (Fund-financed and PRP);
First RD Completions (Fund-financed, PRP and Federal Facility);
Subsequent RD Completions (Fund-financed, PRP and Federal Facility); and
Federal Facility RD Start to RD Complete Duration.
RD starts and RD completions are SCAP targets. Separate targets for first and subse-
quent and Fund, PRP and Federal Facility RD starts and first and subsequent, Fund/PRP, and
Federal Facility RD completions are established prior to the FY. Duration from ROD signature
to RD start and Federal Facility RD start to RD complete duration are SCAP measures.
In the definitions below, first and subsequent RD starts and first and subsequent RD
completions have been combined.
DESIGN ASSISTANCE
Definition: Design assistance activities are undertaken by the USAGE in preparation for
initiating RD activities. This includes:
Synopsize RD requirements in the Commerce Business Daily (CBD);
Develop architect/engineer (A/E) firm pre-selection list;
Contact A/E firms on the pre-selection list to ascertain interest in project;
Develop A/E selection list; and
Tentative selection of A/E firm.
Definition of Accomplishment: The initiation of design assistance is the obligation of
funds. The completion of design assistance is the start of RD.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Funds for design assistance should be
obligated prior to the signature of the ROD. Planned and actual start and completion
dates are not required in WasteLAN. Funds may be planned site or non-site specifically;
A-42
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OSWER Directive 9200.3-01H-2
however, they must be obligated site specifically. Once funds are obligated the non-site
specific amount must be reduced. Funds for design assistance are in the other response
AOA.
ROD SIGNATURE TO RD START DURATION
Definition: A remedy is selected when a ROD is signed by either the Regional Adminis-
trator or the AA SWER. An RD is started when funds are obligated for RD or when the
RD contract is awarded by the PRPs.
The objective of this measure is to focus on good project management of critical portions
of the remedial pipeline, particularly the period between ROD and RA start. It also
results in the establishment of a methodology which accurately assesses program perfor-
mance. The Integrated Timeline for Site Management (Chapter I) will be used for estab-
lishing performance expectations. Duration trends provide indicators of areas that require
attention.
Only RODs where the RI/FS started post-S ARA will be used for comparison and evalua-
tion.
Definition of Accomplishment: The purpose of this measure is to evaluate Regional
performance in managing the timeframe between ROD and the start of RD. The SCAP/
STARS definitions for Remedies Selected (ROD) and RD Start contained in this Manual
will be used in the analysis. This measure includes all RDs scheduled to begin in FY 93.
Regional performance will be compared to:
The Regional and national average duration between ROD and RD start in FY 91
and FY 92; and
The Regional and national average duration between ROD and RD start in previ-
ous quarters of FY 93.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. CERCLIS will automatically look at actual ROD completion dates and
planned and actual RD start dates. HQ will conduct the analysis. CERCLIS trend analy-
sis reports are currently under development. This is a SCAP reporting measure.
RD STARTS FIRST AND SUBSEQUENT
Definition: The RD establishes the general size, scope, and character of a project, and
details and addresses the technical requirements of the RA selected in the ROD. The RD
may include, but is not limited to, drawings, specification documentation, and statement
of bidability and constructability. The obligation of funds for design assistance or techni-
cal assistance do not constitute an RD start. Under certain circumstances, an RD may be
prepared by other parties (i.e., water lines where the city already prepared plans and
specifications); or the plans developed for one site may be used at a similar site.
Subsequent RD starts occur at NPL sites where previous RD activity has taken place.
A-43
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OSWER Dkective 9200.3-01H-2
Definition of Accomplishment:
Fund-financed (Includes F and S lead events.) - A Fund RD start is counted when funds
are obligated. An obligation is made when:
The CO signs the contract modification for the RD;
A CA is signed by the Regional Administrator or his designee; or
An IAG is signed by the other Federal agency.
In those instances where RD activities are conducted prior to ROD signature and there is
not a new obligation of funds for a subsequent RD, the start of RD is defined as the
approval of the work plan to conduct these activities. If there is a new obligation of
funds, the start of RD is defined as the date funds are obligated. When an RD has been
prepared by other parties or plans developed for a similar site will be used, the RD start
date is the same as the RA start date.
PRP-financed (Includes MR, RP, and PS lead events) - For MR and RP lead, the start is
credited on the date the Region approves the PRP design contractor and an enforcement
document, which clearly spells out EPA's expectations with respect to the RD, exists or
is planned. The appropriate dates for the RD start and the associated enforcement docu-
ment must be entered in WasteLAN.
For PS lead sites, credit will be given based on the issuance of a State order or other
comparable State enforcement document for RD (or RD/RA) or, if the RD is covered by
a pre-existing State order, the RD notice to proceed date.
If PRPs are doing the work "in-house" pursuant to an enforcement settlement document,
the start date is when EPA allows the PRPs to proceed.
Federal Facility - If post-ROD, the RD start date is the date of submission of RD work
plan or statement of work. If work begins prior to the ROD, the RD start date will coin-
cide with the ROD date.
Changes in Definition FY 92 - FY 93: Federal Facility RD start definition was added.
The PRP start date is when the Region approves the PRP contractor.
Special Planning/Reporting Requirements: Separate first and subsequent start SCAP
targets are established. Separate Fund, PRP and Federal Facility financed RD start goals
are established prior to the FY.
RD COMPLETIONS - FIRST AND SUBSEQUENT
Definition: An RD is complete when the plans and specifications and, in the case of a
Fund-financed RD, an RA bid package for the selected remedy are developed.
Definition of Accomplishment:
Fund-financed - For F or S lead RD projects, an RD completion is the date that EPA
concurs on or approves and accepts the plans, specifications and RA bid package. When
A-44
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OSWER Directive 9200.3-01H-2
the Fund performs the RD and the PRPs will do the RA under a CD, the RD completion
is the date that EPA concurs on or approves and accepts the plans and specifications.
PRP-fmanced - An RD is complete on the date that EPA concurs on or approves and
accepts the plans and specification. For PS-lead RDs, the RD is complete when the State
concurs on or approves and accepts the plans and specifications.
Federal Facility - The date of EPA approval of the final RD package.
Changes in Definition FY 92 - FY 93: Federal Facility RD completion definition was
added. RDs no longer have to be sent to the Hazardous Site Control Division (HSCD)
for concurrence. A sentence was added that defined the RD completion when the Fund
performed the RD and the PRPs will perform the RA.
Special Planning/Reporting Requirements: Separate SCAP targets are established for
first versus subsequent and Fund/PRP versus Federal Facility RD completions.
FEDERAL FACILITY RD START TO RD COMPLETE DURATION
Definition: The RD is an essential component of the remedial pipeline which links the
execution of a decision document with the initiation of remedial construction activities.
Initiation of the RA depends upon completion of an acceptable RD which reflects the
chosen remedy. Additionally, CERCLA/SARA Section 120(e) states that "substantial,
physical, onsite RA shall be commenced at each facility not later than 15 months after
completion of the investigation and study." Hence, it is necessary to manage the duration
of the RD to ensure that the statutory requirement described above is met and that overall
remedial timeframes are reduced to the maximum extent possible.
Definition of Accomplishment: This measure will look at Regional performance by
analyzing the average duration from RD start to RD completion for sites scheduled for
RD completion in FY 93. Duration will be calculated using the actual RD start dates and
the planned and actual RD completion dates in WasteLAN. RD start to RD completion
durations that are less than five quarters will be counted. For sites where the ROD leads
to RDs at different OUs, links data will be used. The RD start and RD completion defini-
tions contained in this Manual will be used in the analysis.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. CERCLIS will automatically look at actual RD start dates and planned and
actual RD completion dates. HQ will conduct the analysis. This is a SCAP reporting
measure.
A-45
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OSWER Directive 9200.3-01 H-2
' :- ,- : ;'; . .- j./'"v':' ?, ;;;.^ EXHIBIT A-8i MEDIAL DESIGN i . .
PLANNING REQUIREMENTS
STARS?
SCAP?
TARGET OR MEASURE?
QUARTERLY TARGETS?
IF YES, WHEN?
PLANNED SITE SPECIFICALLY?
IF YES, WHEN?
PLANNED/REPORTED ON
OPERABLE UNIT OR WHOLE
SITE BASIS?
REPORTED ON COMBINED
PROGRAM LEAD OR ON A
PROGRAM-SPECIFIC BASIS?
REPORTED SITE SPECIFICALLY
OR IN NON-SITE PORTION OF
WASTE LAN?
AOA CATEGORY IF FUND
FINANCED ACTION?
AOA FOR OVERSIGHT?
BASIS FOR AOA?
DESIGN
ASSIST.
NO
NO
NO
NOT REQ.
OPERABLE
UNIT
N/A
NOT
REQUIRED
OTHER
RESPONSE
N/A
SITE OR
NON-SITE
PLANS
DURATION
ROD TO RD
NO
YES
MEASURE
NO
NO
OPERABLE
UNIT
COMBINED
FUND & PRP
N/A
N/A
N/A
N/A
FIRST RD
START
NO
YES*
TARGET
YES
PRIOR TO
FY
YES
PRIOR TO
FY
OPERABLE
UNIT
COMB. #
FUND & PRP
SEPARATE
FEDERAL
FACILITY
SITE
SPECIFIC
REMEDIAL
DESIGN
REMEDIAL
DESIGN OR
FEDERAL
FACILITY
SITE SPEC.
PLANS OR
FEDERAL
FACILITY
WORKLOAD
MODEL
SUB. RD
START
NO
YES*
TARGET
YES
PRIOR TO
FY
YES
PRIOR TO
FY
OPERABLE
UNIT
COMB. #
FUND & PRP
SEPARATE
FEDERAL
FACILITY
SITE
SPECIFIC
REMEDIAL
DESIGN
REMEDIAL
DESIGN OR
FEDERAL
FACILITY
SITE SPEC.
PLANS OR
FEDERAL
FACILITY
WORKLOAD
MODEL
FIRST RD
COMP.
NO
YES*
TARGET
YES
PRIOR TO
FY
YES
PRIOR TO
FY
OPERABLE
UNIT
COMB.
FUND & PRP
SEPARATE
FEDERAL
FACILITY
SITE
SPECIFIC
N/A
N/A
N/A
SUB. RD
COMP.
NO
YES*
TARGET
YES
PRIOR TO
FY
YES
PRIOR TO
FY
OPERABLE
UNIT
COMB.
FUND & PRP
SEPARATE
FEDERAL
FACILITY
SITE
SPECIFIC
N/A
N/A
N/A
FFRD
DURATION
NO
YES
MEASURE
NO
NO
OPERABLE
UNIT
PROGRAM
SPECIFIC
SITE
SPECIFIC
N/A
N/A
N/A
# Goals are established on a program specific basis.
* Includes projects with the following leads: Federal (F), State (S), PRP action under State order/decree (PS), In-house RD (EP), PRP action under Federal order/decree
-------
OSWER Directive 9200.3-01H-2
REMEDIAL ACTION (RA)
Following are the SCAP and STARS activities tracked for RA:
ROD Signature to RA Start Duration (Fund-financed, PRP, and Federal Facility);
First RA Start (Fund-financed, PRP and Federal Facility);
First RA Contract Award (Fund-financed and PRP);
Subsequent RA Start (Fund-financed, PRP and Federal Facility);
Subsequent RA Contract Award (Fund-financed and PRP);
Award of RA Contract (Federal Facility);
RA On-Site Construction (Fund-financed and PRP);
RA Construction Completion (Fund-financed and PRP);
First RA Completion (Fund-financed, PRP and Federal Facility);
Subsequent RA Completion (Fund-financed, PRP and Federal Facility);
Final RA NPL Site Construction Completion (Fund-financed and PRP);
Final RA Completion (Fund-financed, PRP and Federal Facility);
Federal Facility RI/FS Start to RA Complete Duration; and
Federal Facility RA Start to RA Complete Duration.
RAs are planned site, OU and project specifically and reported in WasteLAN. Initial
schedules for RA are established when the RI/FS for the site is initiated. These initial schedules
must be updated in WasteLAN as better planning data become available. Funds for Fund-
financed RAs are allocated site specifically in the RA AOA. Funds for oversight of Federal
Facility RA activities are available in the Federal Facility AOA. Funds for oversight of RP-lead
RAs are placed in the RD AOA.
Federal Facility RA starts, Fund and PRP award of RA contract are SCAP/STARS
targets. Fund and PRP first and subsequent RA starts, first, subsequent and final fund and PRP
RA completions, and first and subsequent Federal Facility RA completions are SCAP targets.
RA construction completion is a STARS measure. Final RA NPL Construction Completion is
contained in the STARS measure S/C-3, NPL Site Construction Completions. The definition for
NPL Site Construction Completions can be found in Section 3: Response Definitions. The
duration from ROD signature to RA start, Federal Facility award of RA contract, RA on-site
construction, final Federal Facility RA completions, RA construction completion, Federal Facil-
ity RI/FS start to RA complete duration, and Federal Facility RA duration are SCAP measures.
In the definitions below, first and subsequent RA starts, first and subsequent award of RA
contract, and first and subsequent RA completions have been combined.
A-47
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OSWER Directive 9200.3-01H-2
ROD SIGNATURE TO RA START DURATION
Definition: A remedy is selected when a ROD is signed by either the Regional Adminis-
trator or the AA SWER. A Federal Facility remedy is selected when the EPA approves/
concurs on the Federal Facility decision document. An RA is started when funds are
obligated for RA, EPA approves the PRP RD package, or the CD for RA is referred to
HQ or DOJ. The Federal Facility RA starts when substantial, continuous, physical on-site
remedial actions begin pursuant to SARA Section 120.
The objective of this measure is to focus on good project management of critical portions
of the remedial pipeline, particularly the period between ROD and RA start. It also
results in the establishment of a methodology which accurately assesses program perfor-
mance. The Integrated Timeline for Site Management (Chapter I) will be used for estab-
lishing performance Fund-financed and PRP expectations. Duration trends will provide
indicators of areas that require attention.
CERCLA/SARA Section 120(e) states that substantial, physical, on-site remedial action
shall be commenced at each Federal Facility no later than 15 months after completion of
the investigation and study. This measure will provide a method for tracking compliance
with this key program requirement.
Only RODs that resulted from RI/FS projects started post-SARA will be used for com-
parison and evaluation.
Definition of Accomplishment: This measure will look at Regional performance by
comparing the average duration from ROD signature to RA start for all sites scheduled
for RA start in FY 93 to:
The Regional and national average duration from ROD signature to RA start in
FY91andFY92;and
The Regional and national average duration from ROD signature to RA start in
previous quarters of FY 93.
The durations will be calculated using the actual ROD completion dates and the planned
and actual RA start dates in WasteLAN. The ROD completion and RA start definitions
contained in this Manual will be used in the analysis.
Federal Facility ROD signature to RA start durations that are less than five quarters will
be counted.
Changes in Definition FY 92 - FY 93: Added Federal Facility duration analysis.
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will conduct the analysis. Fund, PRP and Federal Facility duration will
be tracked. For sites where the ROD leads to RAs at different OUs, links data will be
used. CERCLIS trend analysis reports are currently under development. This is a SCAP
reporting measure.
A-48
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OSWER Directive 9200.3-01H-2
RA START FIRST AND SUBSEQUENT
Definition : An RA start is the implementation of the remedy selected in the ROD at
final NPL sites that is intended to ensure protection of human health and the environ-
ment.
Definition of Accomplishment:
Fund-financed ( F or S lead events) - Credit for an RA start is given on the date a con-
tract modification for the RA is signed by the CO or the IAG or CA is awarded, and
funds are obligated. This date is entered into WasteLAN with the RA event.
PRP'-financed (RP, MR or PS lead events) - Credit for an RA start is given when one of
the following occurs and has been recorded in WasteLAN:
If work is performed by the PRPs under the same CD or UAO as the RD, the RA
start is the date EPA approves the PRP RD package (RD completion);
If the PRP is doing work under a State order or comparable enforcement docu-
ment, and the site is covered by a State enforcement cooperative agreement or
SMOA (PS-lead) with a schedule for RA work at the site, and EPA approved the
ROD, the RA start is the date the State approves the PRP RD package; or
Where the Fund performed the RD or the RD was done under a settlement/order
for RD and the PRPs are doing the RA under the terms of a CD, UAO or judg-
ment for RA only, the RA start is the date on which the PRPs provide notice of
intent to comply with the UAO (C2801 = "NC") or the date the CD is referred to
HQ or DOJ (as recorded in WasteLAN). Where the PRP is in significant non-
compliance with the UAO, credit will be withdrawn.
For both Fund and PRP financed actions -The Region must enter the Remedial Technol-
ogy of the RA into the RA Technology Type date field (C3401 = RT) and the remedial
technology types data fields (C3402 - C3411) for the RA event.
Federal Facility - Date of which substantial, continuous, physical, on-site, remedial
actions begin pursuant to SARA Section 120.
Changes in Definition FY 92 - FY 93: Federal Facility RA start is included. Added in
the requirement to record the RA technology type. For PS-lead sites, the RA starts when
the State approves the RD package.
Special Planning/Reporting Requirements: Fund and PRP RA starts is a SCAP target.
Federal Facility RA starts is a STARS target. The Region must enter the remedial tech-
nology of the RA into WasteLAN.
RA CONTRACT AWARD (S/C-1)
Definition: Award of RA contract is the initiation of on-site construction activities for
the remedy selected in the ROD.
A-49
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OSWER Directive 9200.3-01H-2
Definition of Accomplishment:
Fund-financed (F or S lead events) - Sites (as recorded in WasteLAN) where the EPA, a
State, the USAGE or BUREC has awarded a contract to initiate Fund-financed RA.
If the ARCS contractor is assigned RA responsibility, the award of RA contract is
defined as the date the RA subcontract is awarded. If the Emergency Response Cleanup
Services (ERGS) contractor will be performing the RA, award of RA contract is defined
as the obligation of funds to the ERGS contractor for the RA.
PRP-fmanced (RP, MR or PS lead events) - Sites (as recorded in WasteLAN) where the
PRP has begun substantial and continuous physical action, which is equivalent to an EPA
contract award, or where the PRP has taken equivalent action with its own work force.
Federal Facility - Date where the Federal agency has begun substantial and continuous
physical action at a site, which is equivalent to an EPA contract award, or the date where
the Federal agency has taken equivalent action with its own work force.
Changes in Definition FY 92 - FY 93: Added Fund-financed situations where ARCS or
ERCS are assigned the RA activities. Added a Federal Facility definition.
Special Planning/Reporting Requirements: First and subsequent, Fund and PRP RA
contract awards are a single STARS target. Individual targets are negotiated in SCAP.
Federal Facility award of RA contract is a SCAP measure. RA contract award triggers the
date for completion of Five Year Reviews. (See new measure for Five Year Reviews in
Section 3: Response Definitions.)
RA ON-SITE CONSTRUCTION
Definition: RA on-site construction begins when the EPA, ARCS, ERCS, USAGE,
BUREC or State contractor for a Fund-financed RA or the PRP or PRP's contractor for a
PRP RA, mobilizes to start implementation of the selected remedy.
Definition of Accomplishment: The date of mobilization must be placed in WasteLAN
against the RA subevent (3101) "RO" (on-site construction).
Changes in Definition FY 92 - FY 93: Added ARCS and ERCS.
Special Planning/Reporting Requirements: The planned completion date for RA on-
site construction must be placed in WasteLAN when the RA contract is awarded. This
date is used for planning cost recovery actions and establishing Statute of Limitation
(SOL) dates. This is a SCAP reporting measure.
RA CONSTRUCTION COMPLETION (S/C-2)
Definition: RA construction is complete when all construction activities for the OU have
been performed and a final inspection has been conducted. The time period to determine
if the remedy is Operational and Functional (O&F) still remains. This is equivalent to the
definition for Final RA NPL Site Construction Completion.
A-50
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OSWER Directive 9200.3-01 H-2
Definition of Accomplishment: The date the lead and support agencies conduct the final
inspection. This date must be entered into WasteLAN with the RA subevent, Final In-
spection and Certification (C3101=IN).
Changes in Definition FY 92-FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: RA construction completion is reported
site specifically in WasteLAN. This is a STARS reporting measure.
FINAL RA NPL SITE CONSTRUCTION COMPLETION
Definition: Final NPL RA site construction is complete when construction activities for
the final OU are complete, a pre-final inspection has been conducted, and a Preliminary
Close-Out Report prepared. This report documents the completion of physical construc-
tion, summarizes site conditions and construction activities and, as appropriate, provides
the schedule for the joint inspection (required before the start of the O&F phase), ap-
proval of the Operation and Maintenance (O&M) work plan, and the establishment of
institutional controls. The Preliminary Site Close-Out Report is only required for the final
OU.
Definition of Accomplishment: The date that the designated Regional official (Division
Director or above) signs the Preliminary Site Close-Out Report documenting, based on a
pre-final site inspection, that physical construction is complete and only minor inspec-
tion/punch list items remain. The appropriate date must be recorded in WasteLAN with
the RA subevent, Preliminary Close-Out Report Prepared (C3101=CC).
Changes in Definition FY 92-FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: Final RA site construction completion is
reported site specifically in WasteLAN. A new subevent for Preliminary Close-Out
Report Prepared (C3101=CC) has been added to WasteLAN. This will be valid for RA
and ROD events. This is a SCAP reporting measure. Final RA NPL Site Construction
Complete is also included in the STARS measure S/C-3 NPL Site Construction Comple-
tion. The definition for NPL Site Construction Completion can be found in Section 3:
Response Definitions.
OPERATIONAL AND FUNCTIONAL (O&F)
Definition: O&F means the activities required to determine that the remedy is function-
ing properly and is performing as designed. O&F activities are part of RA when a Fund-
financed RA was conducted. Physical construction may be complete before the start of
O&F. EPA funds O&F activities for a period up to one year after joint inspection by
EPA and the State, or until EPA and the State jointly determine that the remedy is func-
tioning properly and is performing as designed, whichever is earliest. EPA may extend
the one-year period, as appropriate.
Definition of Accomplishment: The completion of O&F is the date upon which the lead
and support agencies agree through a joint inspection that the remedy is operating in
accordance with the standards contained in the ROD and RD. This documentation is
reported in RA Report. Normally, O&F completion will occur within one year following
completion of construction.
A-51
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OSWER Directive 9200.3-01H-2
Changes in Definition FY 92 - FY 93: O&F only has a completion date.
Special Planning/Reporting Requirements:
RA COMPLETION
Definition: A first and subsequent RA is complete when construction activities are
complete, a final inspection has been conducted, the remedy is O&F (see definition for
O&F), and an RA Report has been prepared. This report summarizes site conditions and
construction activities for the OU.
Definition of Accomplishment: The date that the designated Regional official (Branch
Chief or above) signs a letter accepting the RA Report for the first or subsequent RA.
The contractor's construction manager (ARCS, USAGE, State, PRP, Federal Facility,
etc.) submits a signed RA report to document the completion of all construction activities
for that OU, and that the remedy is O&F. In lieu of a report from the contractor's con-
struction manager, the Region must prepare a report to document the completion. The
appropriate date must be recorded in WasteLAN with the RA event.
Changes in Definition FY 92 - FY 93: The RA Report is accepted by the Branch Chief
or above, not the Regional Administrator.
Special Planning/Reporting Requirements: Commitments are made on a combined
Fund and PRP basis. Federal Facility RA completion commitments are made separately.
First and subsequent Federal Facility RA completions is a SCAP target. First, subse-
quent and final Fund and PRP RA completions are SCAP targets. (See following defini-
tion for final RA completion.)
FINAL RA COMPLETION
Definition: A final RA is complete when:
Construction for all OUs is complete;
A pre-final inspection has been conducted;
A Preliminary Site Close-Out Report has been prepared. This report
documents the completion of physical construction, summarizes site
conditions and construction activities and, as appropriate, provides the
schedule for the joint final inspection (required before the start of the O &
F phase), approval of the O&M work plan, and establishment of institu-
tional control. The date of the Preliminary Close-Out Report must be
reported in WasteLAN with the RA Subevent, Preliminary Close-Out
Report Prepared (C3101 = CC);
A final inspection has been conducted;
The remedy is O&F;
A letter accepting the RA report has been signed by the designated Re-
gional official. The date of the letter is entered into WasteLAN as the RA
completion date (C2101=RA); and
A-52
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OSWER Directive 9200.3-01 H-2
An Interim Site Close-Out Report or Final Superfund Site Close-Out
Report has been prepared. An Interim Site Close-Out Report must be
prepared if the only activity remaining is Long Term Response Action
(LTRA).
Definition of Accomplishment: The final RA is complete on the date the Regional
Administrator signs the Interim Site Close-Out Report or Final Superfund Site Close-Out
Report documenting completion of the final RA. The appropriate date must be recorded
in WasteLAN with the Close-Out Report RA subevent (C3101=CL).
Changes in Definition FY 92-FY 93: More details were added to the definition for
clarification.
Special Planning/Reporting Requirements: The date of completion of the Preliminary
Close-Out Report must be entered into WasteLAN with the Preliminary Close-Out
Report Prepared subevent (C3101 = CC). The date of the letter accepting the RA Report
must be entered into WasteLAN with the RA event (C2101=RA). The date the Regional
Administrator signs the Interim or Final Superfund Site Close-Out Report must be en-
tered into WasteLAN with the Close-Out Report subevent (C3101=CL).
First, subsequent and final, Fund and PRP RA completions are SCAP targets. Final
Federal Facility RA completions is a SCAP measure.
FEDERAL FACILITY RI/FS START TO RA COMPLETE DURATION:
Definition: The objective of this measure is to focus on the duration of the essential
components of the remedial pipeline. As an indicator of the project duration, this mea-
sure reflects the success of EPA in reducing the length of time needed to complete reme-
dial activities at Federal Facilities. Duration trends will address the need for continuous
improvements relative to meeting the Office of Federal Facilities Enforcement (OFFE)
goals.
Definition of Accomplishment: This measure will look at Regional performance by
analyzing the average duration from RI/FS start to RA completion for sites scheduled for
RA completion in FY 93. Duration will be calculated using the actual RI/FS start dates
and the planned and actual RA completion dates in WasteLAN. The RI/FS start and RA
completion definitions contained in this Manual will be used in the analysis.
Changes in Definition FY 92 - FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will conduct the analysis. This is a SCAP reporting measure.
FEDERAL FACILITY RA START TO RA COMPLETE DURATION:
Definition: The objective of this measure is to project the success, as well as the com-
plexity, of the Federal Facilities Superfund program. The measure will also enable
management to focus on sites where additional emphasis on enhancing the pace of re-
sponse activities may be required. Duration trends will provide a basis for evaluating the
progress Federal agencies are making in performing RAs in as timely a manner as pos-
sible.
A-53
-------
OSWER Dkective 9200.3-01 H-2
Definition of Accomplishment: This measure will look at Regional performance by
analyzing the average duration from RA start to RA completion for sites scheduled for
RA completion in FY 93. Durations will be calculated using the actual RA start dates
and the planned and actual RA completion dates in WasteLAN. The RA start and RA
completion definitions contained in this Manual will be used in the analysis.
Changes in Definition FY 92 - FY 93: New definition in FY 93.
Special Planning/Reporting Requirements: Data on durations will be developed using
CERCLIS. HQ will conduct the analysis. This is a SCAP reporting measure.
LONG TERM RESPONSE ACTION (LTRA)
Definition: LTRA are response actions undertaken for the purpose of restoring ground
or surface water quality. (Guidance is currently under development that will expand the
LTRA definition to include soil vapor extraction and similar remedies.) These actions
require a continuous period of on-site activity before cleanup levels, specified in the ROD
or an Action Memorandum, are achieved.
For Fund-financed RAs involving treatment or other measures to restore contaminated
ground or surface water quality, the operation of such treatment or measures for a period
up to 10 years after the construction or installation and commencement of operation will
be considered part of RA.
Activities required to maintain the effectiveness of such treatment or measures following
the 10-year period, or after RA is complete, whichever is earlier, shall be considered
O&M. Ground or surface water measures initiated for the primary purpose of providing
drinking water, not for the purpose of restoring ground or surface water shall not be
considered treatment.
Definition of Accomplishment: LTRA begins when EPA and the State jointly deter-
mine that the RA is O&F. (See definition of O&F.) Typically, this is when the letter
accepting the RA Report is signed by the designated Regional official. The completion
date is the point at which the levels specified in the ROD or Action Memorandum have
been achieved and all necessary Superfund response required to protect human health or
the environment has been completed, or ten years after the remedy becomes O&F, which-
ever is earliest.
Changes in Definition FY 92 - FY 93: Deleted the phrase that the source control mea-
sures to prevent contamination of ground or surface water are not considered LTRA.
Deleted acceptance of Interim Site Close Out Report from the definition.
Special Planning/Reporting Requirements: LTRA is planned on a site-specific basis
in WasteLAN and is used for resource allocation purposes only. Funds for LTRA are
issued site specifically in the RA AOA.
A-54
-------
OSWER Directive 9200.3-01H-2
OPERATION AND MAINTENANCE (O&M)
Definition: O&M means the activities required to maintain the effectiveness or the
integrity of the remedy, and, in the case of measures to restore ground or surface waters,
continued operation of such measures beyond a period of ten years or when the remedia-
tion levels are achieved, whichever is earlier. Except for ground or surface water actions
covered under Section 300.435(f)(3) of the NCP, O&M measures are initiated after the
remedy has achieved the RA objectives and remediation goals in the ROD or CD, and is
determined to be O&F. The State or PRP is totally responsible for these activities for the
time period specified in the ROD or other appropriate documents.
Definition of Accomplishment: The start of O&M is defined as the date upon which the
designated Regional official signs a letter accepting the RA Report. This report docu-
ments that work has been performed within desired specifications and that the remedy is
O&F. The completion (where appropriate) of O&M is defined as the date specified in a
CA, Superfund State Contract (SSC), or CD.
Changes in Definition FY 92 - FY 93: O&M starts when the Region signs a letter
accepting the RA Report.
Special Planning/Reporting Requirements: O&M is planned site specifically in
WasteLAN and is used for resource allocation purposes only. Funds for oversight of
O&M are contained in the RA AOA.
A-55
-------
OSWER Directive 9200.3-01 H-2
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A-56
-------
OSWER Directive 9200.3-01H-2
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A-57
-------
OSWER Directive 9200.3-01H-2
I ' EXHIBJliA^: RiMBDlALACTlOfKCONTlNUEO) -
PLANNING REQUIREMENTS
STARS ?
SCAP?
TARGET OR MEASURE?
QUARTERLY TARGETS SET?
IF YES, WHEN?
PLANNED SITE SPECIFICALLY?
IF YES, WHEN?
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WASTELAN?
AOA CATEGORY IF FUND
FINANCED?
AOA CATEGORY FOR
OVERSIGHT?
BASIS FOR AOA?
FF RI/FS TO
RACOMP
NO
YES
MEASURE
NO
NO
OPERABLE
UNIT
PROGRAM
SPECIFIC
SITE
SPECIFIC
N/A
N/A
N/A
FFRA
DURATION
YES**
YES
MEASURE
NO
NO
OPERABLE
UNIT
PROGRAM
SPECIFIC
SITE
SPECIFIC
N/A
N/A
N/A
O&F
NO
NO
NO
NO
N/A
N/A
N/A
N/A
N/A
N/A
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NO
NO
NO
NO
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UNIT
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NO
NO
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N/A
RA
SITE
SPECIFIC
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* First and subsequent are a combined target under STARS and include Fund and PRP action.
** Final RA construction completions are also included in STARS measure S/C-3 NPL Site Construction Completions.
# Goals are established on a program-specific basis.
+ Includes projects with the following leads: Federal (F), State (S), PRP action under State order /decree (PS), Responsible
party under Federal order/decree (RP), Mixed funding (MR), and Federal Facility (FF).
A-58
-------
OSWER Dkective 9200.3-01H-2
COST RECOVERY
SCAP and STARS track the following cost recovery activities:
Issue Demand Letters;
Cost Recovery Actions/Decisions (<$200,000);
Cost Recovery Actions/Decisions (>$200,000);
Section 106, 106/107, 107 Case Resolution; and
Dollars Achieved Toward Cost Recovery Management by Objective (MBO) Goal.
Cost recovery actions/decisions (>$200,000) is a STARS target. Cost recovery action/
decisions (<$200,000) is a STARS measure. The remainder of the cost recovery activities are
SCAP reporting measures.
The definition for Section 106, 106/107, 107 Case Resolution are in this section and the
RD/RA Enforcement Activities, Settlements and Referrals section.
ISSUE DEMAND LETTER
Definition: A Section 122(e) letter issued pursuant to Section 107 from EPA to the PRP
requesting that the PRP reimburse the Fund for a specific amount associated with one or
more response activities. Demand letters are typically sent for each separate response
activity.
Definition of Accomplishment: Credit for this activity is given on the date the demand
letter is signed by the appropriate EPA official and recorded in WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure and is
recorded at the milestone level.
COST RECOVERY ACTIONS/DECISIONS LESS THAN $200,000
Definition: Cost recovery actions/decisions taken are defined as the decision to take cost
recovery action by use of administrative cost recovery settlement, Section 106/107 or 107
judicial referral for cost recovery, initiation of Alternative Dispute Resolution (ADR)
(mediation, arbitration, mini-trial), preparation of a decision document not to pursue cost
recovery, settlement for past costs under a CD (with no prior referral), bankruptcy filing,
cash out settlement for cost recovery or initiation of debt collection procedures.
This category only includes cost recovery actions for reimbursement of Trust Fund
amounts of less than $200,000.
Definition of Accomplishment:
Section 107 or 106/107 referrals - Credit is given on the date of the Regional
Administrator's transmittal letter to HQ or DOJ as recorded in WasteLAN.
A-59
-------
OSWER Directive 9200.3-01 H-2
Settlement under CD (with no prior referral) - Credit is given on the date of the Regional
Administrator's transmittal letter to HQ or DOJ as recorded in WasteLAN.
Cash out settlements - Credit is given on the date of the Regional Administrator's trans-
mittal letter to HQ or DOJ or when the Regional Administrator signs the AOC for the
cash out. This date must be recorded in WasteLAN.
Decision documents prepared not to pursue cost recovery claims - Credit is given when
the document is issued by the Regional office and recorded in WasteLAN.
Administrative Settlement - Credit is given on the date that the Regional office or DOJ
receives payment from the PRPs in direct response to a demand letter for voluntary cost
recovery or the date the Regional Administrator signs the AOC for cost recovery. The
date must be reported in WasteLAN.
Initiation of ADR - Credit is given on the date that the Region refers the case to the
Office of Enforcement (OE) for selection of a mediator or arbitrator as reported in
WasteLAN. An activity code or milestone will be added to WasteLAN to track ADRs.
Bankruptcy Filing - Credit is given based on the date that the bankruptcy strategy pack-
age is prepared or on the date that the first creditor committee meeting convenes as
reported in WASTELAN. New bankruptcy filing milestones have been added to
WasteLAN: C2801 = CP (Creditors Committee Meeting) and BS (Bankruptcy Strategy
Package).
Initiation of Debt Collection Procedures - Credit is given on the date the demand letter
indicating use of debt collection procedures is signed by the EPA official as reported in
WasteLAN. New debt collection milestones have been added to WasteLAN: C2801 =
CS (Collection Services); AF (Administrative Offset); and TF (Tax Refund Offset).
These milestones are valid only for activity AV (Administrative/Voluntary Cost Recov-
ery). A new statute code (C2771) will be added to WasteLAN for the Debt Collection
Act.
Changes in Definition FY 92 - FY 93: This definition encompasses the following FY
92 measures: Issue Cost Recovery Decision Document, Use of ADR for Cost Recovery,
Administrative Cost Recovery Settlements and Section 107 Referrals/Settlements
<$200,000. Bankruptcy case filings were added. The WasteLAN codes for reporting
accomplishments were added to the definitions.
Special Planning/Reporting Requirements: This is a STARS reporting measure. All
dates must be entered into WasteLAN. Credit for referrals is based on the referral pack-
age not on the number of sites. Credit will be withdrawn if a case is returned to the
Region by HQ or DOJ for additional work, but will be reinstated upon re-referral and will
be based on the quarter of re-referral. New WasteLAN activity codes were developed for
reporting, debt collection procedures and bankruptcies. A new activity code is still under
development for reporting settlements through ADR.
A-60
-------
OSWER Directive 9200.3-01 H-2
COST RECOVERY ACTIONS/DECISIONS GREATER THAN $200,000
Definition: Cost recovery actions/decisions taken are defined as the decision to take cost
recovery action by use of administrative cost recovery settlement, Section 106/107 or 107
judicial referral for cost recovery, initiation of ADR - (mediation, arbitration, mini-trial),
preparation of a decision document not to pursue cost recovery, settlement for past costs
under a CD (with no prior referral), bankruptcy filing, cash out settlement for cost recov-
ery or initiation of debt collection procedures.
This category includes cost recovery actions for reimbursement of Trust Fund amounts of
greater than $200,000.
Definition of Accomplishment:
Section 107 or 106/107 referrals - Credit is given on the date of the Regional
Administrator's transmittal letter to HQ or DOJ as recorded in WasteLAN.
Settlements under CD (with no prior referral) - Credit is given on the date of the Regional
Administrator's transmittal letter to HQ or DOJ as recorded in WasteLAN.
Cash out settlements - Credit is given on the date of the Regional Administrator's trans-
mittal letter to HQ or DOJ or when the Regional Administrator signs the AOC for the
cash out. This date must be recorded in WasteLAN.
Decision documents prepared not to pursue cost recovery claims - Credit is given when
the document is issued by the Regional office and recorded in WasteLAN.
Administrative Settlement - Credit is given on the date the Regional office or DOJ re-
ceives payment from the PRPs in direct response to a demand letter for voluntary cost
recovery or the date that the Regional Administrator signs the AOC for cost recovery.
The date must be reported in WasteLAN.
Initiation of ADR - Credit is given on the date that the Region refers the case to OE for
selection of a mediator or arbitrator as reported in WasteLAN. An activity code or
milestone will be added to WasteLAN to track ADRs.
Bankruptcy Filing - Credit is given on the date that the bankruptcy strategy package is
prepared or on the date that the first creditor committee meeting convenes and the infor-
mation is reported in WasteLAN. New bankruptcy filing milestones have been added to
WasteLAN: C2801 = CP (Creditors Committee Meeting) and BS (Bankruptcy Strategy
Package).
Initiation of Debt Collection Procedures - Credit is given on the date the demand letter
indicating use of debt collection procedures is signed by the EPA official and reported in
WasteLAN. New debt collection milestones have been added to WasteLAN: C2801 =
CS (Collection Services); AF (Administrative Offset); and TF (Tax Refund Offset).
These milestones are valid only for activity AV (Administrative/Voluntary Cost Recov-
ery). A new statute code (C2771) will be added to WasteLAN for the Debt Collection
Act.
A-61
-------
OSWER Directive 9200.3-01 H-2
Changes in Definition FY 92 - FY 93: This definition encompasses the following FY
92 measures: Issue Cost Recovery Decision Document, Use of ADR for Cost Recovery,
Administrative Cost Recovery Settlements and Section 107 Referrals/Settlements
>$200,000. Bankruptcy case filings were added. The new WasteLAN codes for report-
ing accomplishments were added to the definitions.
Special Planning/Reporting Requirements: This is a STARS target. All dates must be
entered into WasteLAN. Credit for referrals is based on the referral package not on the
number of sites. Credit will be withdrawn if a case is returned to the Region by HQ or
DOJ for additional work, but will be reinstated upon re-referral and will be based on the
quarter of re-referral. New WasteLAN activity codes were developed for debt collection
procedures and bankruptcies. A new activity code is still under development for report-
ing settlements through ADR.
SECTION 106,106/107,107 CASE RESOLUTION
Definition: Case resolution is the conclusion of a Section 106, 106/107, or 107 judicial
action by a full settlement, a final judgment, a case dismissal, or a case withdrawal.
Definition of Accomplishment: Credit for case resolution is given when:
A CD is entered in the court fully addressing the complaint with all parties;
The case is withdrawn;
The case is dismissed; or
A trial concluded and a judgment entered fully addressing the complaint.
The case resolution date (activity actual completion date) is the same as the milestone
date and is defined as follows:
Date CD is entered;
Date case is withdrawn;
Date case is dismissed; or
Date judgment is entered.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
DOLLARS ACHIEVED TOWARD COST RECOVERY MBO GOAL
Definition: Report the value of administrative cost recovery settlements (including
ADR), cash out settlements, cost recovery CDs (upon lodging), cost recovery judgements
(including bankruptcy judgements) and penalties and fines assessed.
A-62
-------
OSWER Directive 9200.3-01 H-2
Definition of Accomplishment: Credit is given when the value of the settlements/
judgments are entered into WasteLAN. Credit for administrative settlements will be
given when the AOC is signed by the Regional Administrator.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure only.
A-63
-------
OSWER Directive 9200.3-01 H-2
\
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CASE
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A-64
-------
OSWER Directive 9200.3-01H-2
SECTION 3: RESPONSE DEFINITIONS
INTRODUCTION
There are a subset of FY 93 STARS/SCAP targets/measures that reflect the status of
response activities and the accomplishment of cleanup goals at NPL sites. Following are the
response activities tracked in STARS/SCAP:
Sites Where Activity Has Started, First NPL Removal Actions or RI/FS;
Remedial Program Remedies Selected (ROD) and Action Memoranda Signed for
Removal Actions at NPL Sites;
NPL Site Construction Completions;
Five-Year Reviews Completed;
NPL Deletion Initiation (Fund, PRP and Federal Facility);
Federal Facility NPL Deletion Completion; and
Progress Through Environmental Indicators.
Sites where activity has started, first NPL removal action or RI/FS and Remedial program
remedies selected and action memoranda signed at NPL sites are STARS targets. Progress
through Environmental Indicators and NPL site Construction Completions are STARS measures.
Five-year reviews and NPL deletion starts and completions are SCAP measures. In the follow-
ing sections the definitions for Federal Facility NPL deletion start and completion have been
combined.
EXHIBIT A*ll: RESPONSE SCAP/STASSTAfiCETS AND MEASURES J
ACTIVITIES
NPL SITES ADDRESSED
THROUGH REMOVAL ACTION
OR RI/FS START (S/C-4)
DECISION DOCUMENT
DEVELOPMENT-REMEDIES
SELECTED AND ACTION
MEMORANDA SIGNED (S/C-5)
NPL SITE CONSTRUCTION
COMPLETIONS (S/C-3)
FIVE YEAR REVIEWS
NPL DELETION INITIATION
FEDERAL FACILITY NPL
DELETION COMPLETE
PROGRESS THROUGH
ENVIRONMENTAL INDICATORS
SCAP/STARS
TARGET
X*
X**
STARS
REPORTING
X*
X
SCAP
REPORTING
X
X+
X
QUARTERLY
X
X
X
X
X
X
ANNUAL
X
X
X
X
X
X
X
* Includes pro/eels with the following leads' federal (F), Slate (S), PRP Action Under StateOrder/Decree(PS),Iti-HouseRI/FS (EP), PRP
Action Under federal Order /Decree (RP), and Mixed Funding (MR)
" Remedies include Federal (F), Federal Enforcement (FE), and State Enforcement (SE).
+ Includes RA projects with the following leads. Federal (F), State (S), PRP Action Under State Order/Decree (PS), PRP Action Under
Federal Order/Decree (RP), Mixed Funding (MR), and Federal Facility (FF)
A-65
-------
OSWER Directive 9200.3-01 H-2
NUMBER OF SITES WHERE ACTIVITY HAS STARTED, FIRST NPL REMOVAL
ACTION OR RI/FS (S/C-4)
Definition: Number of NPL sites (final and proposed) where on-site activity has begun.
On-site activity is characterized by either a removal action under the direction of EPA or
through an AO, CD or judgment; or implementation of a first RI/FS (Fund or PRP) at the
site, but not both.
Definition of Accomplishment: See RI/FS start definitions in Section 2: Pipeline
Definitions and NPL removal start definition in Section 4: Removal Definitions.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: First NPL removal start or first RI/FS start
is a target under STARS. Separate targets are negotiated in SCAP for RI/FS starts and
removal starts. Regions cannot receive credit under STARS if an RI/FS or NPL removal
began or was conducted at the site in a previous year. Similarly, Regions cannot receive
credit for both an RI/FS start and a NPL removal at a site under STARS if they are started
in the same year. Credit is given for the first activity started and a site can only receive
credit once. Therefore, historical data must be reviewed prior to targeting and reporting
accomplishments in STARS.
NUMBER OF REMEDIAL PROGRAM REMEDIES SELECTED (ROD) AND ACTION
MEMORANDA SIGNED FOR REMOVAL ACTIONS AT NPL SITES (S/C-5)
Definition: A remedial program remedy is selected when a ROD has been signed and
the appropriate date has been recorded in WasteLAN.
An Action Memorandum to begin a removal is signed by the On-Scene Coordinator
(OSC), Regional Administrator or AA SWER. For PRP-financed removals, an Action
Memorandum is signed or the PRP begins the removal actions contained in an enforce-
ment document.
Definition of Accomplishment:
Remedies Selected - The date the Regional Administrator/Deputy Regional Administra-
tor or AA SWER signs the ROD represents the ROD completion date. This date must be
reported in WasteLAN. Remedies selected include RODs with a Federal (F), Federal
Enforcement (FE) or State Enforcement (SE) lead designation.
Action Memoranda for Removal (Fund-financed): To receive credit for an Action
Memoranda when a Fund-financed removal will be conducted:
An Action Memorandum is signed by the OSC, Regional Administrator or AA
SWER; and
The date of signature is recorded in WasteLAN with the removal subevent Ap-
proval of Action Memo (C3101=AM).
Action Memorandum for Removal (PRP-financed): An Action Memorandum for a
removal will be counted when:
An Action Memorandum is signed by the OSC, Regional Administrator, or AA
SWER;
A-66
-------
OSWER Directive 9200.3-01H-2
The date of the approval of the Action Memorandum is recorded in WasteLAN
with the removal subevent (C3101) "AM" (Approval of Action Memo); and
When the PRP begins to follow the removal instructions outlined in the AOC,
UAO or CD. The date of the AOC, UAO, or CD and the removal remedy code
(C2731=RV) must be recorded in WasteLAN.
Changes in Definition FY 92 - FY 93: This is a new STARS target in FY 93, however,
the ROD completion and removal start definitions are not new.
Special Planning/Reporting Requirements: Remedial program remedies selected
(RODs) and Action Memoranda for removal is a combined target under STARS. Sepa-
rate targets are negotiated in SCAP for RODs and removal starts. The Action Memoran-
dum signature date should be reported in WasteLAN with the removal subevent Approval
of Action Memorandum (C3101 = AM). For PRP-financed removals the date of the
Action Memo, the date of the AOC, UAO or CD and the remedy code (C2731 = RV)
i must be reported in WasteLAN.
NPL SITE CONSTRUCTION COMPLETIONS (S/C-3)
Definition: Starting in FY 93, construction at an NPL site is considered complete when
physical construction of the remedy is complete. Remedial/removal implementation is
complete as a result of a final RA or a ROD for the final OU stating that all necessary
remediation is complete. A removal completion that cleans up an NPL site and is docu-
mented by a ROD that states that all necessary remediation is complete and that the site
meets the requirements for site closeout also qualifies for an NPL site completion.
This is the definition to meet the Administrator's goal of 200 site completions by the end
of FY 93. In order to receive credit for a final RA completion there are other require-
ments that must be met. These requirements are discussed in the definition for final RA
completions. This definition can be found in Section 2: Pipeline Definitions.
Definition of Accomplishment:
RA site construction is complete when:
RA construction activities at all OUs are complete;
A pre-final inspection of the site has been conducted;
A Preliminary Close-Out Report has been prepared. This report documents the
completion of physical construction of the remedy, summarizes site conditions and
construction activities and, as appropriate, provides the schedule for the joint final
inspection (required before the start of O&F), approval of the O&M work plan and
the establishment of institutional controls; and
The designated Regional official (Division Director or above) signs the Prelimi-
nary Site Close-Out Report. The completion date must be reported in WasteLAN
with the RA subevent, Preliminary Close-Out Report Prepared (C3101 = CC).
Accomplishments are credited based on the completion date of the Preliminary
Close-Out Report Prepared (C3101 = CC).
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OSWER Directive 9200.3-01H-2
RODs that state that no remediation is required are signed by the Regional Administrator/
Deputy Regional Administrator or the AA SWER. The ROD must include a construction
completion certification. There should be no RD or RA activities at this OU.
For sites where EPA has conducted a RA and the ROD at the final OU states that all
necessary remediation has been completed, the Region is required to either prepare an
Interim or Final Superfund Site Close-Out Report oj document compliance with the
statutory requirements for site closeout in the ROD and include a construction completion
certification. The following data must be entered into WasteLAN:
The RI/FS completion date;
The ROD completion date;
The Remedial Action Technology Type (C3401 = RT and C3402 = NA); and
The completion date for the ROD subevent, Close-Out Report (C3101 = CL), if a
separate Interim or Final Superfund Site Close-Out Report is prepared.
Accomplishments are credited based on the ROD completion date, or the comple-
tion date in the Close-Out Report data field (C3101 = CL) if a separate Interim or
Final Superfund Site Close-Out Report is prepared.
Removal completion that cleaned up an NPL site (Fund financed) is credited when:
The contractor has demobilized and left the site as documented in a Pollution
Report (POLREP); and
A ROD that states that all necessary remediation is complete has been signed. The
ROD must document that the site meets the statutory requirements for site close-
out.
Removal completion that cleaned up an NPL site (PRP-financed) is credited when:
The Region certifies that the PRPs or their contractor have completed the removal
action and fully met the terms of the AO, CD or judgment; and
A ROD that states that all necessary remediation is complete has been signed. The
ROD must document that the site meets the statutory requirements for site close-
out.
The removal event qualifier that indicates that the site is cleaned up (C2103 = C) must be
entered into WasteLAN. The date of signature of the ROD that states that all necessary
remediation is complete must be entered in the removal completion and ROD completion
data fields. The RA Technology Type (C3401 = RT and C3402 = NA) must also be
entered into WasteLAN.
Accomplishments are credited based on the ROD completion date.
Changes in Definition FY 92 - FY 93: This is a new STARS measure in FY 93. The
definition encompasses the final RA NPL site construction completion definition from
Section 2: Pipeline Definitions. It also includes RODs where all necessary remediation
has been completed. This measure also credits removals that clean up NPL sites. The
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OSWER Directive 9200.3-01 H-2
definition for removal completions is found in Section 4: Removal Definitions. How-
ever, in order for a removal to qualify under this measure, a ROD that states that all
necessary remediation is complete must be prepared.
Special Planning/Reporting Requirements: The STARS measure NPL site construc-
tion completions includes final RA construction completion, RODs that state that all
necessary remediation is complete, and removal completions at NPL sites as documented
by a ROD stating that all necessary remediation is complete. Separate planning measures
are negotiated in SCAP for each of these events.
RA - The date the designated Regional official signs the Preliminary Close-Out Report
should be entered into WasteLAN with the Preliminary Close-Out Report Prepared
subevent(C3101=CC).
ROD - The date of signature of the ROD that states that all necessary remediation is
complete and documents that the site meets the statutory requirements for the site close-
out must be entered into WasteLAN in the RI/FS completion and ROD completion data
fields. If a separate Interim or Final Superfund Site Close-Out Report is prepared, the
date the Regional Administrator signs the Interim or Final Superfund Site Close-Out
Report is to be recorded in the Close-Out Report Completion subevent (C3101 = CL).
The RA Technology Type (C3401 = RT and C3402 = NA) must also be entered into
WasteLAN.
Removal - The removal event qualifier that states that the site is cleaned up (C2103 = C)
is to be recorded in WasteLAN. The signature date of the ROD that states that all neces-
sary remediation is complete upon completion of the removal must be entered into
WasteLAN in the removal completion and ROD completion data fields. The RA Tech-
nology Type (C3401 = RT and C3402 = NA) must also be entered.
FIVE-YEAR REVIEWS COMPLETED
Definition: Five-year reviews are intended to evaluate whether the response action
implemented at an NPL site remains protective of public health and the environment.
EPA will conduct five-year reviews of any site at which a remedy, upon attainment of the
ROD cleanup levels, will not allow unlimited use and unrestricted exposure.
Definition of Accomplishment:
Start (Fund-financed) - Obligation of funds for the five-year review.
Start (PRP-financed) - EPA approval of five-year review work plan.
Completion (Fund and PRP) - EPA acceptance of the five-year review report.
The five-year review must start within five years of the RA start (as defined in this
Manual). The five-year review must be complete within five years of award of RA
contract.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: Five-year reviews must be planned and
reported site specifically in WasteLAN. Funds are allocated in the RA AOA. The
WasteLAN event code for five-year reviews is C2101 = FA. This is a SCAP reporting
measure.
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OSWER Directive 9200.3-01 H-2
NPL DELETION INITIATION
Definition: The deletion process is initiated when performance monitoring of the com-
pleted remedy or remedies for the site has verified the integrity of the action and it has
been determined that all necessary remediation has been completed.
Definition of Accomplishment: The deletion process is credited when a notice of intent
to delete the site is published in the Federal Register. The deletion process is completed
when the notice of deletion is published in the Federal Register.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure.
FEDERAL FACILITY NPL DELETION
Definition: Site completion (another name for a deletion candidate) is the point at which
all response actions have been completed and no further RA is appropriate to protect
public health and the environment. Pursuant to Section 300.425(e)(l) of the NCP, sites
can be deleted or recategorized on the NPL, in consultation with the State, if one or more
of the following criteria are met:
Federal agency has implemented all appropriate response actions required by
EPA;
All appropriate Fund-financed responses under CERCLA have been implemented
and no further response by the Federal Facility is appropriate; or
Based on a remedial investigation, it is determined that the release poses no
significant threat to human health or the environment and, therefore, taking reme-
dial measures are not appropriate.
Deleting a site from the NPL does not eliminate the site's eligibility for future actions.
The deletion process can be divided into three phases: initiation phase, public notice and
comment phase, and the final (deletion) phase.
Definition of Accomplishment:
Deletion Start Date: The date the Regional Administrator approves the Final Superfund
Site Close-Out Report. Regions and HQ should work closely with the Deletion Coordi-
nator to prepare the documents necessary to delete a site from the NPL.
Deletion Completion Date: The date the responsive summary is approved by the Re-
gional Administrator. (The Regional Administrator will then publish the notice of dele-
tion in the Federal Register.)
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: Federal Facility deletion start and comple-
tion are SCAP reporting measures.
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OSWER Directive 9200.3-01H-2
PROGRESS THROUGH ENVIRONMENTAL INDICATORS
Definition: This measure results from the Environmental Indicators program. It docu-
ments the number of sites where the following types of results have been achieved:
Progress toward final cleanup goals; and
Reductions of acute threats.
Either of these results may be achieved through implementing removal and/or remedial
projects. Results are reported for each of the media affected at a site. These media
include contaminated land, surface water, and ground water.
Progress toward final cleanup goals is reported as three levels of progress at NPL sites:
Full achievement of site goals for a medium;
Partial achievement of goals for a medium; and
Cleanup underway.
Reduction of acute threats measures how often threats to human health have been elimi-
nated at both NPL and non-NPL sites by preventing exposure to contaminated materials.
Progress recorded by this indicator should reveal success in closing off exposure path-
ways. (See Volume I, Chapter n and Volume n, Appendix D for additional information
on the Environmental Indicators program.)
Definition of Accomplishment: Same as definition.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a STARS reporting measure.
Accomplishment data will be reported in WasteLAN. The results should be reflected in
the comment field of the STARS data base.
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OSWER Directive 9200.3-01H-2
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A-72
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OSWER Directive 9200.3-01H-2
SECTION 4: REMOVAL DEFINITIONS
INTRODUCTION
Requirements for the removal program differ from the remedial program due to the
nature of removal activities. The removal program responds to emergency, time critical and non-
time critical situations at NPL and non-NPL sites. Since so much of the removal work cannot be
anticipated in advance, the planning horizon of these activities is significantly shorter than for
remedial activities. Thus, quarterly commitments are not required. All SCAP/STARS targets,
however, are established on an annual basis. Targets are planned site specifically prior to the
quarter the removal is projected to begin. Site-specific removal funding needs are placed in
WasteLAN the quarter prior to the expected obligation date. The annual removal commitments
are placed in the Targets and Accomplishments portion of the CERHELP non-site data system.
Credit will be given for NPL or non-NPL activities depending on the NPL status recorded in
CERCL1S on the date accomplishment reports are pulled.
REMOVAL ACTIVITIES
The following removal activities are tracked in SCAP and STARS:
Removal Investigations at NPL Sites;
Non-NPL PRP Search Starts;
Non-NPL PRP Search Completion;
AO Issued for Removal and RI/FS;
NPL Removal Starts;
Non-NPL Removal Starts;
Emergency Response Activity;
Removal Completions;
NPL Site Completions Through Removal;
Administrative Record (AR) Compilation Completion;
Federal Facility Removals/Expedited Response Actions (ERA) Started; and
Federal Facility Removals/ERAs Completed.
Federal Facility removals/ERAs started and completed are STARS/SCAP measures.
First NPL removal start or first RI/FS start is a STARS target under S/C-4, Number of Sites
Where Activity has Started, First NPL Removal Actions and RI/FS. Separate RI/FS and removal
targets are established in SCAP. The definition for Number of Sites Where Activity has Started
can be found in Section 3: Response Definitions. Action Memoranda signed for removal actions
at NPL sites and remedial remedies selected are a STARS target under S/C-5. Separate ROD
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OSWER Directive 9200.3-01 H-2
and removal targets are established in SCAP. The definition for Remedial Remedies Selected
and Action Memoranda Signed can be found in Section 3: Response Definitions. NPL site
completions through removal actions are included in the STARS measure S/C-3, NPL Site
Construction Completions, separate planning measures are negotiated in SCAP. The definition
for NPL Site Construction Completions can be found in Section 3: Response Definitions.
Non-NPL and NPL removal starts are SCAP targets. SCAP commitments for removal
starts are made on a combined program basis. Separate goals for Fund-financed and RP-lead
removals are negotiated prior to the FY. Accomplishments are reported on a combined program
basis. Removal investigations, non-NPL PRP search starts and completions, AOs issued for
RI/FS or removal, removal completions, emergency response activity and AR compilation
completion are SCAP measures.
NPL and non-NPL removal start definitions have been combined. The Federal Facility
removal/ERA start and completion definitions have also been combined. The definition for AOs
issued for removal and RI/FS can be found in the following section and Section 2: Pipeline
Definitions.
Exhibit A-13 contains the SCAP/STARS targets and measures for the removal process.
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OSWER Directive 9200.3-01H-2
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memoranda for removal actions at NPL sites and remedies selected (RODs) are a combined target under STARS SjC-5.
*** SCAP target only. NPL site completions through removal are included in the STARS measure S/C-3, NPL Site Construction Completions.
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OSWER Directive 9200.3-01H-2
REMOVAL INVESTIGATIONS AT NPL SITES
Definition: A removal investigation at an NPL site is the process of collecting field data
at an NPL site for the purpose of characterizing the magnitude and severity of the prob-
lem to determine if a removal or quick response action is warranted.
Investigations may be conducted by the State, EPA and/or the Technical Assistance
Team (TAT), and must include an on-site component, such as a walk around survey or
sampling to be counted.
Definition of Accomplishment: The start of the removal investigation at NPL sites is
defined as the date of the site visit or the start of the review process if no site visit took
place. The completion is defined as the signature of an Action Memorandum, the date of
a memorandum to the file documenting the decision not to perform a removal action, or
signature of the Site Evaluation Report. The removal investigation completion date must
be entered into WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: This is a SCAP reporting measure. Ac-
complishments are reported site specifically in WasteLAN using event (C2101) type
"RS." Removal investigations at NPL sites are tracked on a calendar year basis.
NON-NPL PRP SEARCH STARTS
Definition: The purpose of the PRP search is to identify PRPs. It should be done prior
to the start of the removal action when possible or very soon after the initiation of the
emergency response.
Definition of Accomplishment: If the search is being conducted by a contractor, the
start date is considered to be the date the work assignment is procured. If it is conducted
by EPA, the start date is the day the EPA staff begins the PRP search activities.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Non-NPL PRP searches should be planned
site specifically to the maximum extent possible. All targeted non-NPL removal starts
should have an associated projection for a non-NPL PRP search. Funds for non-NPL
PRP searches are requested in CERHELP. Projections for non-NPL PRP searches should
be placed in the Targets and Accomplishments portion of CERHELP. This is a SCAP
reporting measure.
NON-NPL PRP SEARCH COMPLETION
Definition: A PRP search is the action taken by the Region to identify the responsible
parties at a site.
Definition of Accomplishment: The PRP search is complete when PRPs at a site have
been identified, all applicable activities described in the Agency's PRP Search Manual
have been completed, and the date and outcome of the search have been entered into
WasteLAN. If no PRPs are found, the date and the outcome of the search are entered
into WasteLAN.
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OSWER Directive 9200.3-01 H-2
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Non-NPL searches should be planned site
specifically to the maximum extent possible. All targeted non-NPL removal starts should
have an associated projection for a non-NPL PRP search. These projections should be
placed in the Targets and Accomplishments portion of CERHELP. This is a SCAP
reporting measure.
ADMINISTRATIVE ORDERS ISSUED FOR REMOVAL AND RI/FS
Definition: Administrative Orders (AOC and UAO) are an enforcement tool to compel
the PRPs to assume responsibility for removal actions.
Definition of Accomplishment: Report Section 104/106/122 administrative orders
(AOC and UAO) issued by EPA for PRPs to conduct removal actions and/or RI/FS s.
Credit for the order is based on the date the order is signed by the Regional Administrator
as recorded in WasteLAN.
Changes in Definition FY 92 - FY 93:
Special Planning/Reporting Requirements: Projections for AOs for removal actions
are made in the Targets and Accomplishments portion of the CERHELP non-site data
base. This is a SCAP reporting measure.
REMOVAL STARTS NPL AND NON-NPL
Definition: A removal is a response action taken to prevent or mitigate a threat to public
health, welfare or the environment posed by the release or potential release of a CERCLA
hazardous substance, or an imminent or substantial risk posed by a pollutant or contami-
nant.
In order for the NPL removal to be counted in the STARS target S/E-4, Number of Sites
Where Activity has Started, First NPL Removal Actions or RI/FS, it must not have had
previous Fund-financed or PRP removal or RI/FS activity at the site.
Definition of Accomplishment:
Fund-financed - A Fund-financed removal counts toward this target when on-site re-
moval work is begun as documented in the POLREP. Prior to on-site work beginning,
the following actions usually occur:
The Action Memorandum is approved by the OSC, Regional Administrator or AA
SWER; and
A Delivery Order has been issued by EPA under the ERCS contract or a contract
has been signed for a U.S. Coast Guard (USCG) on-site removal; and
An obligation for the removal has been recorded in WasteLAN and the Integrated
Financial Management System (IFMS) or the OSC activates $50,000; and
On-site removal work has begun.
The date the on-site work began is the start date for the removal action.
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OSWER Directive 9200.3-01 H-2
PRP-financed - A PRP removal counts when there is on-site removal activity financed by
the PRP in compliance with an AO (unilateral or consent), CD or judgment. The date the
PRPs begin actual on-site work (as entered in WasteLAN) is the start date. If PRPs start
the removal and become in substantial non-compliance and the Fund takes over the
removal, credit will be given for a PRP start but the Fund will be credited for the comple-
tion, because PRPs have not met the terms of the AO or CD. If the PRPs do not comply
with a UAO, credit for the removal is not given. Regions will receive credit under SCAP
for issuing the UAO. No credit will be provided where a PRP is conducting a response
without an enforcement document.
Changes in Definition FY 92 - FY 93: Added that the removal work must be docu-
mented in a POLREP.
Special Planning/Reporting Requirements: Plans are made site specifically prior to
the quarter the removal is expected to begin; TBD sites are allowed. Annual targets for
removals are established in the Targets and Accomplishments portion of the CERHELP
data base. A limit is placed on the number of Fund-financed removal starts. Commit-
ments for non-NPL removals are made based on a combined Fund and PRP financed and
first and subsequent basis. Removal starts is a SCAP target.
First NPL removal start or first RI/FS start is a target under STARS. Separate targets are
established in SCAP for RI/FS starts and removal starts. Regions cannot receive credit
for a site under STARS S/C-4, Number of Sites Where Activity has Started, First NPL
Removal Action or RI/FS, if an RI/FS or NPL removal began or was conducted at the site
in a previous year. Regions also cannot receive credit for both an RI/FS start and a
removal under STARS if they are started in the same year. Credit is given for the first
activity started and a site can receive credit only once. Therefore, historical data need to
be reviewed prior to negotiating commitments and recording accomplishments in
STARS. Regions can receive credit for both activities under SCAP.
Action Memoranda for removal actions at NPL sites and remedial remedies selected
(RODs) are a combined target under STARS S/C-5. Separate targets are established in
SCAP for removal starts and RODs.
Definitions for Number of Sites Where Activity Has Started and Remedies Selected and
Action Memoranda Signed can be found in Section 3: Response Definitions.
EMERGENCY RESPONSE ACTIVITY
Definition: An emergency response activity is an action performed by an EPA OSC
within 24 hours of receipt of an oil or hazardous substance incident notification. Such
actions include OSC field investigations, OSC on-scene monitoring, and the start of a
removal action; or OSC participation in emergency response field simulations.
Note that the time frame of 24 hours for response is used, as opposed to "hours or days,"
in order to capture first responder type activities and "days" is simply too open-ended.
These activities will only be counted when they are performed in the field and an EPA
OSC performs them. This pertains to simulations as well; table-top exercises do not
count. Training activities are purposely omitted. Contractor activities, for example, TAT
investigations, do not count as an accomplishment under this measure. The purpose of
this measure is to identify and track emergency response activities performed by EPA
OSCs to support OSC readiness initiatives.
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OSWER Directive 9200.3-01 H-2
Definition of Accomplishment: An Emergency Response Activity must be performed
by an EPA OSC and documented. Appropriate documentation includes the report date in
the Emergency Response Notification System (ERNS) Version 4.0 and the following:
Entry follow-up component of ERNS. To enter these data, check off "Emergency
Response Activity"; enter the "Emergency Response Activity Date"; enter the
"Responding OSC" name; and check off the appropriate activity (e.g., field simu-
lation, release investigation, etc.).
Entry in WasteLAN of an emergency removal action start and entry in the follow-
up component of ERNS to tie the removal action to the notification through
supporting comments, including "Responding OSC" name.
The note to the file or POLREP requirement provides backup documentation, as well as
more details for future applications (e.g., lessons learned, technology transfer, etc.).
Changes in Definition FY 92 - FY 93: Changes were made in how the information is
reported in ERNS.
Special Planning/Reporting Requirements: This is a SCAP reporting measure. Ac-
complishments should be reported site specifically in ERNS, entered into WasteLAN at
the Regional level on a quarterly basis, and uploaded to CERHELP.
NPL AND NON-NPL REMOVAL COMPLETIONS
Definition: A removal is complete when the conditions specified in the Action Memo-
randum have been met even if the OSC determines that additional response work may be
necessary.
Temporary demobilization and temporary storage on-site are not considered
completions, unless temporary storage is the only action identified in the Action Memo-
randum to mitigate threats to public health, welfare and the environment. Likewise,
temporary off-site storage of hazardous substances at a Treatment, Storage, and Dis-
posal (TSD) facility other than the facility of ultimate disposal is a continuation of the
removal action, not a completion. In addition, removal action would not be considered
complete if:
Hazardous substances stored on-site are being monitored by the ERCS contractor
or if any additional ERCS expenditures are anticipated, or
Hazardous substances are being stored at an off-site facility, other than the ulti-
mate TSD facility.
A removal action would be considered complete if:
The scope of work for the removal action does not specify final off-site disposal of
hazardous substances, the substances have been stabilized and are stored on-site,
and no additional CERCLA removal program funds are anticipated to be expended
at the site. In this case, hazardous substances may be expected to undergo long-
term storage on-site due to circumstances such as the unavailability of a final
treatment/disposal remedy. In this instance, no CERCLA removal program funds
will be expended for long-term site O&M. Any long-term (greater than 6 months)
site O&M will be performed by the PRP or another agency (e.g., State).
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OSWER Directive 9200.3-01H-2
Hazardous substances are being stored off-site at the location of final disposal, and
no additional ERCS expenditures are anticipated.
Definition of Accomplishment:
Fund-financed - Completions are counted when the actions specified in the Action
Memorandum are complete, the contractor has demobilized and left the site, as docu-
mented in a POLREP, and no additional ERCS expenditures are anticipated for the
action, as documented in a POLREP and recorded in WasteLAN.
PRP-fmanced - Completions will count when the Region has certified, by entering a date
in WasteLAN, that the PRPs or their contractors have completed a removal action and
fully met the terms of an AO, CD or judgment.
Changes in Definition FY 92 - FY 93: Added that the completion must be documented
in a POLREP.
Special Planning/Reporting Requirements: This is a SCAP reporting measure. Ac-
complishments are reported based on combined Fund and PRP-financed and first and
subsequent NPL and non-NPL removal completions. Projections on the number of NPL
removal completions are placed in the Targets and Accomplishments portion of the
CERHELP non-site data system. The removal event qualifier (C2103) is to be recorded
in WasteLAN.
NPL SITE COMPLETIONS THROUGH REMOVAL
Definition: An NPL site is completed through a removal action when conditions speci-
fied in the Action Memorandum or ROD have been met and all necessary remediation at
the site has been completed.
Definition of Accomplishment:
Fund-financed - A removal completion that cleaned up an NPL site is credited when:
The contractor has demobilized and left the site as documented in a POLREP; and
A ROD that states that all necessary remediation is complete has been signed. The
ROD must document that the site meets the statutory requirements for the site
closeout.
PRP-financed - A removal completion that cleaned up an NPL site is credited when:
The Region certifies that the PRPs or their contractor have completed the removal
action and fully met the terms of the AO, CD or judgment;
A ROD that states that all necessary remediation is complete has been signed. The
ROD must document that the site meets the statutory requirements for site close-
out.
The removal event qualifier that states the site is cleaned up (C2103 = C) must be entered
into WasteLAN. The date of the signature of the ROD that states that all remediation is
complete must be entered in the removal completion and ROD completion data fields.
The RA technology type (C3401 = RT and C3402 = NA) must also be entered into
WasteLAN.
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OSWER Directive 9200.3-01 H-2
Changes in Definition FY 92 - FY 93: Added requirements for completion of a ROD
that states that all necessary remediation is complete.
Special Planning/Reporting Requirements: This is a SCAP target. It is planned site
specifically and includes Fund-financed and PRP removals. NPL site completions
through removal are included in the STARS measure S/C-3, NPL Site Construction
Completion. The definition for NPL Site Construction Completion can be found in
Section 3: Response Definitions.
ADMINISTRATIVE RECORD COMPILATION
Definition: An AR is a compilation of all documents which EPA used to make a specific
decision on the appropriate response action to be taken at a Superfund site. SARA
specifies that ARs be compiled at sites where remedial or removal responses are planned
or are occurring, or where EPA is issuing a UAO or initiating litigation.
Definition of Accomplishment: The AR compilation is complete when the compilation
is certified by the program office. The AR compilation begins when the AR is received
at the site repository and the start date is entered into WasteLAN.
Changes in Definition FY 92 - FY 93: Completion definition was modified to match
December 1990 guidance.
Special Planning/Reporting Requirements: The completion of the AR must be re-
ported site specifically in WasteLAN. To indicate that the AR is for a removal activity, a
"V" must be recorded in the Event Qualifier field (C2103).
FEDERAL FACILITY REMOVALS/ERAs (FFE-3(2))
Definition: Removal actions and ERAs are defined in CERCLA as the cleanup or
removal of released hazardous substances from the environment, and the necessary
actions taken in the event of the threat of release of hazardous substances into the envi-
ronment. Removal actions and ERAs are conducted in response to emergency, time
critical, and non-time critical situations at NPL and non-NPL sites.
Definition of Accomplishment:
Removal Start Date: Date the Federal agency begins actual on-site removal work, or the
date of Action Memorandum signature, or other decision document signature/approval.
Removal Completion Date: Actual date the Federal agency has demobilized, completing
the scope of work set forth in the Action Memorandum or other decision document.
Changes in Definition FY 92 - FY 93: New definition for FY 93.
Special Planning/Reporting Requirements: This is a STARS/SCAP reporting measure
and must be planned and reported site specifically.
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OSWER Directive 9200.3-01H-2
\ B**ribitA-14: RBMQVAt DEflNITIONS
PLANNING REQUIREMENTS
STARS?
SCAP?
TARGET OR MEASURE?
QUARTERLY TARGETS SET?
IF YES, WHEN?
PLANNED SITE SPECIFICALLY?
IF YES, WHEN?
PLANNED/REPORTED ON
OPERABLE UNIT OR WHOLE
SITE BASIS?
REPORTED ON COMBINED
PROGRAM LEAD OR ON A
PROGRAM-SPECIFIC BASIS?
REPORTED SITE SPECIFICALLY
OR IN NON-SITE PORTION OF
WASTELAN?
AOA CATEGORY IF FUND
FINANCED?
AOA CATEGORY FOR
OVERSIGHT?
BASIS FOR AOA?
NPL REM.
INVEST.
NO
YES
MEASURE
NO
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
REMOVAL
N/A
SITE SPEC.
PLANS &
CONTING-
ENCY
NON-NPL PRP
SEARCH START
NO
YES
MEASURE
NO
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
ENFORCE-
MENT
N/A
NON -SITE
SPECIFIC
PLANS
NON-NPL
SEARCH COMP.
NO
YES
MEASURE
NO
NO
WHOLE
SITE
N/A
SITE
SPECIFIC
N/A
N/A
N/A
AOFOR
REMOVAL
NO
YES
MEASURE
NO
NO
WHOLE SITE
OR OPERABLE
UNIT
N/A
SITE
SPECIFIC
ENFORCE-
MENT
N/A
SITE
SPECIFIC
PLANS
EMERG.
RESP. ACT.
NO
YES
MEASURE
NO
NO
WHOLE
SITE
PROGRAM
SPECIFIC
SITE
SPECIFIC
INERNS
REMOVAL
N/A
SITE
SPECIFIC
PLANS &
CONTIN-
GENCY
* F/rsf RI/FS start or first NPL removal is a combined target under STARS, S/C-4. Action memoranda for removal actions and RODs are a combined
target under STARS, S/C-5.
** NPL removal site completions, RODs that state that all remediation is complete and final RA construction completions are combined under STARS
S/C-3, NPL Site Construction Completions.
*** "To Be Determined" sites are allowed.
# Separate program specific goals are established prior to FY. A limit is placed on the number of Fund-financed NPL removal starts.
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| EXHIBIT A-14: HlMGVAt DEFINITIONS
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