united states environmental Protection Agency
Washington. DC 20460
OSWER Directive initiation Request
1. Directive Numb'er
9024.10
2. Originator Information
Name o( Contact Percon
Thad Juszczalc
Mail Code
OS-110
Office
OSWER
Telephone Code
382-4510
XTitle
MANAGEMENT ASSISTANCE FOR SUPERFUND COOPERATIVE AGREEMENTS
4. Summary ol Directive (include brief statement of purpose)
This Directive provides options for funding and outlaying management assistance for.
Superfund Cooperative Agreements.
5. Keywords
FUNDING. SUPERFUND COOPERATIVE AGREEMENTS
6«. Does .This Directive auperseae previous uirective(s).'
b. Does It Supplement Previous Qirective(s)?
X No
X No
Yes What directive (number, title)
Yes What directive (number, title)
7. Draft Level
A - Signed by AA/DAA
B - Signed by Office Director
C - For Review & Comment
D - in Development
8. Document to be distributed to States by Headquarters?
Yes
X
No
Thl* Request M««ta OSWER Directives System Format Standards.
9. Signature of Lead Office Directives Coordinator
Jshnsie' Webster, OSWER Directives Coordinator
'-Vcry.v-aL- OOj^Xj— -O--
10. Nam* and Title of Approving Official . -•
Bep&ty'Aitiltant Administrator
Date
March 29,
Date
March 28,
1990
1990
EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
OSWER OSWER o
VE DIRECTIVE DIRECTIVE DIRECTIVE
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NAR 2 B 1990
OSWER Directive 9024.10
MEMORANDUM
SUBJECT: Management Assistance for Superfund
Cooperative Agreements
i i
FROM: Mary A. Gade
Deputy Assistant Administrator
TO: Waste Management Division Directors, Regions I-X
The purpose of this memorandum is to provide you with
options for funding and outlaying management assistance for
Superfund Cooperative Agreements. These options have been
reviewed by a small work group of Headquarters and Regional
program and Comptroller staff. This options paper is not
designed to "tell" Regions how to fund management assistance;
instead, it is meant to provide you with more flexibility. v:e
are in the process of updating the Superfund Activity Codes so
that Option II can be used.
Our thanks go to Tom Hogan who drafted this paper and to
Tom Mateer who raised these issues to our attention.
If you have any questions, please contact Thad Juszczak at
382-4510.
Attachment
cc: Superfund Branch Chiefs, Regions I-X
Thad Juszczak
Jan Baker Wine
Bob Cluck
Kathyf^^fckiss, Region III
Karea^Hnrnoy, Region vn
Mike iMHkowski
Tom- Kateer, Region V
Maggie Mitchell
Deborah Orr, Region V
Bruce Pumphrey, Region V
Clem Rastatter
Jim Woolford
Tom Hogan, Region VII
- - • . tv-r - •
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OSWER Directive 9024.10
SUPPORT AGENCY (MANAGEMENT ASSISTANCE) COOPERATIVE AGREEMENTS
The purpose of this proposal is to provide an analysis of the
status of Support Agency (Management Assistance) Cooperative
Agreements (CAs) in light of current CERCLIS, IFMS and Cost
Recovery requirements. The options included in this analysis and
the advantages and disadvantages of each, will be provided to the
Regions as guidance for dealing with this issue. This proposal is
written from the perspective of the Regional staff member
responsible for planning and committing management assistance funds
in CERCLIS. Therefore, terms such as "Event" and "Activity" will
be used in their CERCLIS context rather than that of the
Headquarters Financial and Budget offices.
Support Agency roles described in the National Contingency
Plan are defined as site-specific activities performed by the State
to support EPA-lead site response. Management assistance for
Federal-lead sites is paid for by the Response Program while PRP-
lead is funded by the Enforcement Program.
Current Headquarters policy mandates that support agency CAs
for management assistance cannot be awarded and drawn-down as a
"lump sum" for each State because this does not provide adequate
documentation of site-specific expenditures for cost share and cost
recovery purposes. Although funds may be planned site-specifically
or in "lump sums" for each State, they must be obligated and drawn-
down on a site-specific basis.
In the past, Support Agency funds could be handled through a
Multi-Site CA (or one funding instrument) and obligated under one
account number (ACN) and document control number (DCN) per budget
source for each State. As cost recovery concerns increased,
Regions still were able to use the Multi-Site approach, but ACNs
and DCNs «*£•• assigned for each site using an event-specific
financialflHMfe£vity code. (Note: This term, "event-specific
activity ^^^B*, means that the 8th digit of the account number is
chosen tfljJ^Hbify the actual ongoing site event, such as Ri/FS,
RD, RA, ^BP1 which the management Assistance funds will be
utilized.) Under these procedures, funds could still be
transferred from ,one site to another or one financial activity code
to another by a transaction called a "transwitch" and a formal
amendment to the ,CA. In addition, site-specific and CERCLIS event-
specific cost Documentation could be maintained.
The flexibility facilitated by FMS was not incorporated into
which rdo-not facilitate transfers such as
,«™,..—. ,,-• At ;*fce f»eew>*fe; ih« roni»d«4y t*eRfSrt
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• OSWER Directive 9024.10
and re-obligating the funds; this is an administrative burden to
both the Srites and EPA. Currently under IFMS, if a Region de-
obligates prior year funds, the funds nay not be available for re-
certification and therefore, not availble for re-obligating to
another site or financial activity code. Even if the funds are
available for re-obligation, the process does not facilitate
flexibility in utilizing management assistance funds.
In response to this, the following three options are being
provided to the Regions for dealing with their Support Agency CAs.
Although each one complies with current IFMS/CERCLIS procedures,
there are advantages and disadvantages associated with each.
OPTION I: Obligate management assistance CAs site-specifically
using event-specific financial activity codes.
Under Option I, a Region would obligate specific dollar
amounts for each site and would indicate the event-specific
financial activity code (the 8th digit of the ACN: L-RI/FS, N=RD,
R-RA) and the budget source (the 2nd, 3rd and 4th digit of the ACN:
TFA or TGB) through the ACN. The Region would assign specific
pairs of ACN/DCNs for each site-specific commitment, showing the
exact dollar amount to be committed. This would be entered into
CERCLIS or WasteLAN on the Management Assistance ("MA") event, and
IFMS would then down-load the actual commitment, obligation and
future disbursements (i.e., draw-downs against the State's Letter
of Credit) to CERCLIS.
Advantages; Direct approach; provides excellent cost recovery
records.
This approach is direct and provides site-specific and event-
specific financial activity coded CERCLIS data for cost recovery
efforts. Although it iff somewhat time-consuming for the CERCLIS
staff and Financial Management office at the time of the CA award,
no additional manual follow-up in CERCLIS is required after that
(i.e., aUttjHffbursenents are recorded automatically through the
IFMS/CEM^^Ktm-load).
Vary little flexibility, for transferring funds.
There ie very little flexibility for transferring funds from
one site or financial .activity code to another. Once a site-
specific and event-specific financial activity coded dollar amount
is assigned its own ACN/DCN, entered into CERCLIS, and the IFMS
down-load takes place, the dollar amount is "dedicated" there.
The only way to move ..the dollars to another site or financial
activity code would .the £o-d«-sQbligate and then re-obligate. If the
mfet jficul ^iQE.ytar-ftiodty.ethe. RegJX3rt<;ould lose
£te;2ftBHobbigatted!
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OSWER Directive 9024.10
them to nnj|fr*r site or event-specific financial activity code.
Although tflmfit are procedures for requesting that prior year funds
be re-certified to the Region after de-obligation, there is no
guarantee that this will be approved by Headquarters.
In addition to the above, this option would most likely result
in small amounts of money left in the CA, dedicated to specific
phases of the site clean-up (i.e., RI/FS, RD, or RA). As
mentioned, these amounts could not easily be transferred from one
event-specific financial activity code to the next and would
eventually need to be de-obligated; most likely, the funds would
be lost to the Region.
OPTION II: Obligate management assistance site-specifically, but
with a general financial activity code in the ACN (for each budget
source), rather than an event-specific financial activity code.
This could be done for all CERCLIS events except Remedial Action
(RA), where the event-specific code must be utilized.
Note; To provide this option, the Superfund Activity Codes would
first need to be revised to allow use of the general financial
activity code "9" for Response-funded (TFA) management assistance
in the 8th digit of the ACN, rather than requiring that event-
specific financial activity codes be chosen. It should be
clarified that this could be used for all site events/activities
except RA, where the event-specific code would need to be utilized
for cost share documentation. The code for Enforcement-funded
(T6B) management assistance should be clarified to indicate that
"4" should be chosen.
Under Option II, a Region would obligate specific dollar
amounts for each site. The Region would use a general financial
activity code rather than event-specific and would indicate the
budget source (TFA or TGB) in the ACN. Again, funds for RA would
be the one exception and would require an event-specific financial
activity cog*. The Region would assign specific ACN/DCN pairs for
each siJMittbowing the exact amount of dollars to be
committe^^^Kgated. The commitment would be entered into CERCLIS
or Wasteft^^Bb th« Management Assistance ("MA") event, and IFMS
would thfl^Bfci-load the actual commitment, obligation and future
Advantagest Direct approach; funds are not "dedicated" to specific
events/activities and would be .available from one event/activity
at the site to the next (with the exception of RA).
*i'" •
This approach is direct and provides site-specific data for
cpst share : and cCost recovery purposes. it is somewhat time-
ior tnQPnftuming, for W»je^CiiIS^staffiidBd3Mrtai»cial ^Management office at
s awarded, but after that, requires no
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OSWER Directive 9024.10
manual foUspp-up because all disbursements will attach to CERCLIS
through thfr IFMS/CERCLIS down-loads. An advantage of this over
Option I, is that funds can be more fully utilized as the site
advances from one CERCLIS event/activity to the next (Negotiations,
RI/FS, RD) without de-obligating and re-obligating.
Disadvantages: There is no flexibility to transfer money from one
site to another without going through the formal de-obligation/re-
obligation process. Detailed event/activity-specific financial
data for cost recovery and management purposes would not be
documented in CERCLIS, except at the RA event level. When all
federally funded management assistance ends at the site, there may
be remaining funds that would need to be de-obligated from the CA.
OPTION III: Obligate management assistance funds into "lump sum
holding accounts" in CERHELP; when disbursements occur, de-obligate
from the CERHELP holding accounts, re-obligate site-specifically
and process the disbursements.
Under Option III, a Region would obligate funds into CERHELP
holding accounts by budget source (TFA and TGB) for each State.
A Region could opt to break-down the State's TFA "lump sum11
obligations by event-specific financial activity codes (RI/FS and
RD) or use the general activity code (established under Option II),
with the exception of RA which always requires an event-specific
activity code. Each of the CERHELP obligations would be assigned
an ACN and DCN, with "ZZ" as the last two digits of the ACN. These
commitments would be entered into CERHELP, and IFMS would then
down-load the actual commitment and obligation to CERHELP.
The Region would set-up a table in CERCLIS with all projected
sites that would draw-down from the CERHELP holding accounts. For
each of these sites, the ACN/DCN from the CERHELP holding accounts
from which it would draw-down would be listed; the only change
would be in the last two digits of the ACN, where the FMS Site I.D.
would replace the "ZZ". Specific dollar amounts would not be
entered tflfeythi* table.
At tJf^^Kh* of a disbursement, the Region would need to de-
amount of the disbursement from the appropriate
CERHELP ACN/DCN and re-obligate this exact dollar amount site-
specifically. At that point, the disbursement could be made site-
specifically and would link to the site-specific CERCLIS entry
during the IFMS/CERCLIS down-load. It should be clarified that
this would be an "administrative" de-obligation/re-obligation,
which would not require Headquarters approval and re-certification
of funds. This is possible because this transaction would not
change the terms of the original CA (i.e., the CA was established
for the purpose of haying funds available to be transferred to
sJLIfeg-specificentries5.,) .^;:/":' ': ;t7^^;.. '-vV - ' a«
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OSWER Directive 9024.10
il 1 illll IHMP Provides a great deal of flexibility in funds
utilizatiife
This option provides the greatest level of flexibility in
funds utilization of the three options. It also allows for site-
specific tracking or site-specific and event-specific financial
activity coded tracking in CERCLIS for cost recovery purposes.
Since only the exact amounts of disbursements are obligated site-
specifically, there are no funds.left obligated to sites, which
will eventually need to be de-obligated.
Disadvantages: Requires a closely monitored administrative and
financial system for handling disbursements.
Under Option III, the Region would need to establish a closely
monitored system for handling disbursements against the CERHELP
holding accounts. Each time a disbursement would be processed, the
Region would need to ensure that the correct amounts were de-
obligated from the appropriate CERHELP holding accounts and then
re-obligated to the correct site-specific account. At that point,
the disbursement could be made site-specifically. In addition, the
CERCLIS staff would need to ensure that the correct site-specific
information was already entered into the CERCLIS table, in order
to facilitate the IFMS/CERCLIS down-load.
As stated previously, the purpose of this analysis was to
provide options to the Regions for handling Support Agency
(Management Assistance) CAs. Hopefully, one of the three options
outlined above will prove to be an acceptable solution for each of
the Regions.
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