UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
APR 3 ,-ug-
I/-
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER Directive 9200.3-01G
MEMORANDUM
SUBJECT: Correction of FY'92 Superfund Progran^ Management Manual
Definitions
FROM: Henry L. Longest II, Director -jt^mM
Office of Emergency and RemediaJWReSponse (OS-200)
TO: Director, Waste Management Division
Regions I, IV, V, VII
Director, Emergency and Remedial Response Division
Region II
Director, Hazardous Waste Management Division
Regions III, VI, VIII, IX
Director, Hazardous Waste Division, Region X
PURPOSE
The purpose of this directive is to correct the "Definition
of Accomplishment" for Remedial Design (RD) and Remedial Action
(RA) Completions as defined in the FY'92 Superfund Program
Management Manual, (OSWER Directive 9200.3-01F). Additionally, a
site construction completion activity has been added in response
to the program's emphasis on construction completions.
BACKGROUND
The FX£93 Program Management Manual contains incorrect
"Definitiofljt Of Accomplishment" for RD and RA completion. As the
manual is e&mntly written, Fund-lead RDs must be sent to the
Headquarters Hazardous Site Control Division (HSCD) for
concurrence before the Regions can receive credit as an
accomplishment. To receive credit for either a first or
subsequent RA completion, the Regional Administrator is required
to sign an operable unit RA Report.
OSWER Directive 9320. 2-3C, dated February 19, 1992, outlined
new procedures for site completions. As a result of this
directive, a new field has been added to track "construction
completions. "
Printec y J« .• «
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OBJECTIVB
This directive corrects the FY'92 Program Management Manual
Definitions for an RD completion and a first or subsequent RA
completion, effective for FY'92. This directive also includes
the definition of a new field, "Site Construction Completion
through Final RA."
IMPLEMENTATION
The FY'92 Program Management Manual, page D-14 is corrected
to read as follows:
ACTIVITY: RD Completions — First and Subsequent (S/C-31
DEFINITION; An RD is complete when the final plans and
specifications and, in the case of a Fund-financed RD, a
Fund-financed RA solicitation package for the selected
remedy are completed.
DEFINITION OF ACCOMPLISHMENT;
Fund-financed (Includes F and S lead events) - An RD
completion is the date that EPA concurs with or approves and
accepts the final plans, specifications and RA solicitation
package.
PRP-financed (Includes MR, RP, and PS lead events) - No
changes.
The Office of Emergency and Remedial Response has deleted the
requirement that the Regions obtain HSCD concurrence prior to
reporting the accomplishment for Fund-financed event RDs. HSCD
remains available and willing to review RD plans and
specification packages, regardless of the lead.
The FY'92 Program Management Manual, pages D-18 and D-19,
is corrected to read as follows:
RA Completion - First and Subsequent fS/C-5)
: A first or subsequent RA is complete when
construction activities are complete, a final inspection has
been conducted, and an operable unit RA Report has been
submitted to, and accepted, by EPA.
DEFINITION OF ACCOMPLISHMENT; The date the designated
Regional Official (Superfund Branch Chief or above) signs a
letter accepting the RA Report for the operable unit. The
appropriate date must be recorded in CERCLIS with the event.
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This change has been made because previous editions of the
Superfund Program Management manual erroneously listed the
Regional Administrator as the signature authority for a report
that is not generated by EPA.
An explanation of procedures should help to clarify the
reason for the change. Typically, when a RA operable unit is
completed, pre-final and final inspections are held. These
inspections are the formal way to ensure that the requirements
under the RA contract have been fulfilled. Within 60 days of the
final inspection, the contracting party for the RA (ARCS, USAGE,
State, PRP, etc.) submits a signed RA Report to document the
completion of that specific remedial action. EPA formally
accepts the report as satisfactory by sending a letter back to
the contracting party. A Quick Reference Fact Sheet explaining
the components of an acceptable RA Report is forthcoming.
To the FY'92 Program Management Manual, page D-19, the
following activity is added:
ACTIVITY: Site Construction Completion through Final RA
DEFINITION; This measure is complete when construction
activities for the final operable unit are complete, a pre-
final inspection has been conducted, and a Preliminary Close
Out Report has been prepared. This report summarizes site
conditions, construction activities and, as appropriate, the
schedule for the EPA/State joint inspection (required before
the start of the operational and functional phase), approval
of the O&M workplan, and the establishment of institutional
controls.
DEFINITION OF ACCOMPLISHMENT; The date that the designated
Regional Official (Division Director or above) signs the
Preliminary Close Out Report documenting, based on a pre-
final inspection, that physical construction is complete and
only minor inspection/punch list items remain. The
appropriate date must be recorded in CERCLIS with the event.
A field fojp this activity is not presently available in CERCLIS.
Until the fi«ld is available, Regions should keep track of this
subevent aflgttrately and add the data to CERCLIS later. The field
should be available by September 30, 1992.
If you have any questions, please contact William Ross,
HSCD, at FTS 678-8335 or Robin Richardson, OPM, at FTS 260-9367.
cc: B. Diamond, (OS-510)
Information Management Coordinators, Regions I-X
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