United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9200.5 - 4041
October 1989
SCAP
BULLETIN
This SCAP Bulletin was created to keep HQ and Regions Informed of the latest happenings In the Superfund
Program Management World.
Office of Emergency and Remedial Response
Office of Program Management OS - 24O
ttent Bulletin
1 Number 1
Calends! Ti
F
f
[
This column provides the latest schedule for
Program Management significant events. Any dates
that are different from those in the Program Manage-
ment Manual will be highlighted.
For the months of October and November -
OCTOBER
Accomplishments data pulled from CERCLIS/CER-
HELP and provided for: 20th
1) AA monthly report;
2) special program reports;
3) end-of-year assessment for FY89;
4) Superfund Progress Report;
5) final FY89 SPMS Accomplishments; and
6) Dingell Report.
Data pulled from CERCLIS/CERHELP for pro-active
memorandum 2Oth
NOVEMBER
FY90 final targets. Including open season changes,
set in CERHELP 7th
Accomplishments data pulled from CERCLIS/CER-
HELP and provided for: 7th
1) Superfund Progress Report;
2) special program reports;
3) AA monthly report; and
5) Dingell Report.
OMSE SPMS verified (fourth quarter FY89)
13th-17th
OMSE SPMS system closes (fourth quarter FY89)
20th
INSIDE:
Results of the FT9O Negotiations
Flexible Funding: Yes, There la Flexibility
Results of the RA Prioritizetlon Meeting
This column recognizes the achievements of
the regions/IMC/IMC Staff in the Program Man-
agement area. It also Includes new and moving
faces and duties as well as hallway news (gossip).
If you know someone who deserves recognition or
is moving on to bigger and better things tell us
about it at SCAP Bulletin, Congratulations, USEPA
(OS240), 401 M Street, S.W.. Washington, DC
20460. Attn.: Robin Richardson, FTS 475-9338.
MOVING FACES: Good Bye and Good Luck to
Joan Colson from Region 2. She has Just moved
to EPA Cincinnati. Tom McMenamin from HQ to
Region 9; Kirk Robinson from Region 9 to Region
10; Steve Smagin from HQ to Region 3; Ceilanne
Libber back in HQ after a detail in Region 5.
NEW FACES: Robin Richardson and Chad Little-
ton have joined the HQ Office of Program
Management. Resources Management Section
(Terry Ouverson's staff). Anne Nelson has joined
the HQ Compliance Branch, Regional Planning
and Evaluation Section (Jim Woolford's staff).
TEMPORARY CHANGES: Terry Ouverson (HQ) to
AA OSWER Staff for 2 months.
GOSSIP: Jim Woolford to be married.
OTHER DUTIES AS ASSIGNED: Susan Svirsky
and Terry Ouverson taught Financial Manage-
ment and SCAP at the OSC/RPM Basic Training
Academy, a resounding success.
blutiozf
ARCSCw
in
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
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SCAP BULLETIN
This column will contain areas of the Program
Management Manual that were not included
when the Manual was issued. Future columns will
provide infonnation on changes and additions to
the Superfund Program Management Manual.
-
Regions -
Do you have any advice, new or innovative
techniques or other infonnation you would like to
share with your fellow regions? Do you have any
problems or issues that could use some advice or
help from other regions? If so, the Regional Swap
column will get the word out. Send your thoughts
or issues to Regional Swap, SCAP Bulletin, USEPA
(OS24O), 401 M'Street, S.W., Washington, DC
20460.
_~I
Look here for any CERCLIS developments that
may affect SCAP planning, t~geting, budgeting
and evaluation.
. SUDerfund Infonnation Manaeement Confer-
~ for CERCLIS/WasteLAN Users. The
,,~o.~erericf.~. be l1eld tl,I",e} 4.t~t~~gh th~ l7th
~ '0[~~efU~~tnmjankeSn6rel1M1i:Hot~,;wash-
ington, DC.et$&>\N ~UObl!jS;:)H m fK~i~i')H
. Infonn~tj~n3W~gCttn~R~ (!o,oQnPmit9ET and
Waste~~1r!J.1S,~~WF:sI3"F:'9op!e[~nce
Meetings \Vth'bi'bel~ pn ~~e~qefJ:~~W~.', ":
If you have ariy~ q~estions: please call Shirley
Keehn (202) 475-9336. ,
Publication 9200.5 - 4041
~~
Dear Dr. SCAP:
What do I do finance-wise when a PRP takes over
a Fund-financed remedial response action?
. Happy but Confused
Dear Happy but Confused:
Since you did not indicate whether the takeover
occurred before or after Fund dollars were obligated
I will address both situations. . ,
If the PRPs took over a RI/FS after Fund-fi-
nanced dollars were obligated you should deter-
mine how much money you need for oversight
during the current fiscal year and deobligate the
rest. Funds for oversight ofPRP RI/FS activities in
future years will be provided by OWPE. If the PRP
has taken over the RD /RA after obligation of Fund
monies you should detennine how much you need
for oversight of the entire phase and deobligate the
rest. If the Funds were originally obligated in prior
fiscal years, the dollars deobligated will be retumed
to the Fund. If the funds were obligated during the
current fiscal year, they will be retumed to the
region and may be used in accordance with the
flexible funding initiatives.
If you had planned a Fund-financed response
action and the PRPs settle, you may use ,the funds
for other RI/FS activities (if a RI /FS was planned) or
RD activities (if a RD was planned). The RI/FS or RD
funds may also be used for other activities in
accordance with the flexible funding initiatives. RA
funds can only be used at another site in accor-
dance with the flexible funding and RA prioritiza-
tion initiatives." .
For additionalinfonnation onthe flexible fund-
ing initiative see the accompanying Special Fea-
ture: Flexible Funding - Yes there is Flexibility.
Dr. SCAP
Got problems, issues or suggestions on Program
Management? Ask Dr. SCAP. . .
Send your questions or suggestions to SCAP
Bulletin, Ask Dr. SCAP. USEPA (OS24O), 401 M
Street. S.W., Washington, DC 20460.
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE. OFFICE OF WASTE PROGRAMS ENFORCEMENT
2
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SCAP BULLETIN
Publication 9200.5 - 4041
~
Continuing Resolution - For an indefinite period
EPA will be operating under a Continuing Resolu-
tion. A memorandum dated September 29 from
Davtd P. Ryan outlines the actMties to be contin-
ued under the resolution. In short, funding for
emergencies or ongoing essential services and op-
erations should riot be curtailed.
ARCS Coding - ARCS Coding has been modified
slightly from the coding issued in the FY90 Pro~
gram Management Manual. The new codes have
been implemented in CERCUS and WasteLAN.
Ipstructions are being distributed to all regional
IMCs.
~~
Results of the FY90
Negotiations.
From August 4 through August 18, HQ and
the regions negotiated final FY90 SCAP ISPMS
targets. The negotiations were a success, due pri-
marily to HQ I regional preparedness. Many Agency
programmatic and funding 1n1tiattves and con-
cerns were addressed during the negotiations;
Topics discussed and negotiated included in-hou'se
Rl/FS starts, balanced approach for COE and
ARCS RD IRA oversight, planning for RD IRA nego-
tiations, full funding RIfFS projects, RIfFS mega-
site funding, and RA prioritization.
The 90-Day Study recommended that the
regions peIform in-house RI/FS as a means for
tratntng RPMs. 16 of the 129 RI/FS starts the
regions committed to were in-house (EP lead) RI/
FS starts, 10 first starts and 6 subsequent starts.
Additional resources ($400,000 and 150% of Fund
lead FTE) were allocated to the regions that com-
mitted to in-house RIfFS to fac1l1tate this effort.
A balanced approach to distribute RD IRA
. oversight responsibUities between the COE and
I
ARCS was discussed with all regions. Most regions
agreed to allocate 20 to 33% of their projects to the
COE. .
In keeptngwith the integrated OERR/OWPE
program approach, the negotiations were con-
ducted in an integrated fashion. Activities and
events were negotiated as they occurred in the
remedial pipeline. (Pre-Remedial, Removal and
. Federal Facility events were negotiated separately.)
This directed attention toward planning a more
realistic pipeline of events. The primary focus was
to ensure ample time for RD /RA negotiations be-
tween the ROD signature and the RD start. At least
. one quarter between the two events was
implemented to accommodate the RD/RA
negotiations. .
Prior to negotiations. instructions on cod-
ing Rl/FS funding needs were distributed to the
regions. These instructions responded to the RI/
FS full funding strategy. The request was to fund
all ongoing needs first and then identify heeds for
new project starts. The regions agreed that their
negotiated RI/FS funding levels satisfies all their
ongoing funding needs. '
RI/FS mega-site. funding needs were
negotiated separately from the RI/FS budget. The
funding levels were based on receipt and review of
site management plans and the site's cash-flow. To
date. there remain outstanding site management
plans. .
The FY90 targets and funding negotiations
concluded with a signed matrix/contract of that
. region's FY90 SCAP /SPMS targets. This provided
a formal source for HQ and the regions to reference
back in' the office when questions art~ . about
target commitments. A summary of the national
FY90 SPMS targets, including ~/FS starts is
shoWn below. The targets include FY89 carryover.
551 . RI/FS ROD RD RA NPL NPL
Campi. Starts Addrssd CampI.
Total 1620 149 22
1st 100 128 110
RP 38
fund 13
Sub. 29 53 50
RP 21
fund 18
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE' OFFICE OF WASTE PROGRAMS ENFORCEMENT
'3
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SCAP BULLETIN,
Publication 9200.5 - 4041
Flexible Funding - Yes,
There is FlexibiUty
The signtftcant level of reprogramming of
funds among Advice of Allowance (AOA) categories
during the last month of Fiscal Year 1989 indicated
that substantial flexibility exists within the AOA
design. Flexibility exists within the AOA design for
the purpose of moving funds both within and
among AOA categories. In addition. flexibility is
provided at the HQ level to move funds between
Regions. as well as reprogramming funds between
program offices. For example. in both FY89 and
FY90. $20 million have been moved from the re-
sponse program to OWPE to support enforcement
activities. This article details some of the key areas
of flexibility available to Regions and describes
some additional flexible funding initiatives cur-
rently underway.
, In order to meet the Congressional budget
reporting requirements. the following six allow-
ances will be issued in FY90 - RA (site specific). RD
(non-site specific). RI/FS (non-site specific),
Removal (non-site specific). Other Response (non-
site specific) and Enforcement (non-site specific).
With the. exception of the RA allowance. regions
may shift funds within allowances simply by chang-
ing the planned obligation data in CERCLIS. This
change does not require HQ involvement. How-
ever. to legally move funds between'AOAs. a SCAP
amendment and an AOA change request are re-
quired and must be reflected in CERCLIS prior to
HQ approval.
Funds available due to Potentially Respon-
sible Party (PRP) takeovers or due to costs which'
are lower than previously planned obligations may
be used within the RI/FS or RD allowances for
other RI/FS or RD projects. respectively. These
funds will also be generally approved by HQ for
movement between allowances consistent with the
following priorities: Classic emergencies. oversight
'of PRP settlements. RD projects. priority RA proj- '
ects. and removal actions at National Priorities List
(NPL) , sites. .
. Are there funds available within your regional
contingency account and/or AOA to start the
project?
. Can this project be substituted for an ap-
proved funded project that was scheduled to
begin during the current or in a future quar-
ter? .
. Can your future planned obligatIons be ad-
justed to allow this proj ect to start and still stay
within your annual regional budget?
. As a final resort. request HQ allocation of
funds availaple from other regions as a result
of the mid year. third or fourth quarter adjust-
mei'll of the regional budgets/ AOA.
The RA funding constraints and the im-
plementation of the RA prioritization criteria (see
accompanying special feature) has limited funding
flexibility that existed in previous years. Regions
should be sure that sites where settlement was not
achieved are evaluated at the next RA Prioritization'
meeting. Funds saved as a result of a PRP takeover
or lower bids will. most likely. be replaced in the
funding pool and distributed based on the national
RA priorities.' Regions. of course. will be able to
retain oversight monies.
Based on regional priorities. funds may also
be reprogrammed between response and enforce-
,ment, Th,ese shifts require a SCAP amendment and
AOA change request ahd require Congressional no-
tification if the shift exceeds $500.00<;>.
A flexible funding workgroup was formed a
year ago to look into flexible funding issues. This
same group will be brought together again for an-
other look into the flexible funding process and
structure. There will be a memo concerning FY90
revised flexible funding guidance coming out in
November.'
Regions should not shy away from taking
advantage of the flexible funding process. Flexibil-
ity within and between AOAs was instituted to
make more efficient use of the region's allocated
funds. Hopefully. this article has cleared up any
~ misconceptionS or misunderstandings that have
arisen in the regions. If there are stlll lingering
questions or if you have suggestions on how to
provide increased funding flexibility to the regions
To obtain funds to start an RIfFS or RD lease write to SCAP Bulletin. Dr. SCAP.
OFFICE OF EMERGENCY'AND REMEDIAL RESPONSE. OFFICE OF WASTE PROGRAMS ENFORCEMENT
It is possible to place unallocated RI/FS or .
RD funds in a regional contingency account until
specific actions or actMtles can be identified. Again.
if funds will be used for activities within another
AOA. Regions must submit a SCAP ,amendment
andAOA change request to HQ and update the site
specific financial information in CERCLIS prior to
obligating the saved RD funds.
4
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SCAP BULLETIN
PubUcation 9200.5 - 4041
Results of the RA
. Prioritization Meeting
As more sites move through investigation
and remedy selection and into design and construc-
tion, the funding needs have exceeded the budget.
In FY89, funding for remedial actions (RA) was
allocated on a first come/first selVe basis. The
shoI1fall in RA funds in FY90 .caused EPA HQ to
develop a new RA prioritization system. The system
ranks the sites according to the actual or potential
environmental and/or health risk they pose.
On July 25.,26, 1989, EPA held a RA Priori-
tization Conference in Washington, D.C. A
representative from each of the ten regions
attended, as well as HQ Superfund management.
Their primary goal was to evaluate RAs ready for
funding. in FY90 based on the ~ignif1cance of their
associated risks, and rank them according to this
evaluation for funding.
In preparation for this meeting, HQ required
a "RA Prioritization Site Fact Sheet" for all FY90 RAs.
This fact sheet specified five priority categories and
relevant criteria, for assessing degrees of human.
health and environmental risks. For instance,
Priority ~ sites were defined as being an "immediate
or imminent threat to human health", while Priority
5 posed a "potential threat to endangered species or
sensitive environs." Each region assigned priorities
to its respective sites depending on how closely a site
met the criteria. The completed Fact Sheets were
then returned to HQ prior to the conference.
. In addition, regions were asked to prepare a
three to four ~ute presentation on each site with
information supporting the assigned priority rank-
ing. Presentations were not required for Priority 1
sites and sites with fourth quarter RAs. The con-
firmed Priority 1 sites would all receive funding, and
Quarter 4 sites would be evaluated at a later date.
HQ, upon receiving the site fact sheets, re-
viewed the information on each to confirm the prior-
ity ranking assigned by the region. In the case of a
disagreement between HQ and the regional priori-
ties, the site would be presented at the Prioritization
Conference.
The first day of the conference was mainly
devoted to regional site presentations and evalu-
. ation.. As each regio~ presented its sites, the other
I
nine regional representatives, plus three HQ repre-
sentatives, scored each site in terms of six criteria:
A Volatility /Imminence/ Cost of Delay
B.. Nature of Contaminants
C. Concentrations/Volume (of
Contaminants)
D. Proximity to Population Center/Number
of People Affected .
E. Threat to an Environmentally Sensitive
Area/Endangered Species
F. Overall Programmatic Considerations
Each criterion was scored on a scale from 1
to 10,1 being the lowest possible rating, 10beingthe
highest. An individual's scores for the six criteria on
the score sheet were summed to give a total score for
each site. All indMdual scoring sheets were
collected at the meeting. and tabulated by computer
to arrive at a final total for each site. The three sets
of HQ scores were averaged together and only the
resulting composite score was entered into the site
score calculation.
Sites were ranked on the basis of their total
scores, with the highest scores receiving the highest
rankings.
The . second day of the conference was
devoted to a discussion of the site rankings and the
new prioritization. process itself. While it was
recognized that a few refinements to the system may
aid future meetings, participants were in consensus
as to the success of their efforts and the fairness of
the final outcome.
Analyses ofthedata gathered at the meeting
and the process of the prioritization are currently in
progress at HQ. The knowledge gained through this
undertaking will benefit the midyear meeting in
which EPA will monitor site progress, address the
FY90 Quarter 4 sites, and further review the new RA
Prioritization process.
The next meeting of the RA Priorttization
Group will be held in late October. The group will
continue to refine theRA prioritization approach
and examine other' facets of the pipeline for
potential prioritization.
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE. OFFICE OF WASTE PROGRAMS ENFORCEMENT
5
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