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OSWER #9840.1
ATTACHMENT -I
REVISED FY 86 SCAP SCHEDULE
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OSWER # 9840.1
REVISF.P FY 86 SCAP SCHEDULE
Instructions for preparing June 14, 1985
final FY 86 SCAP furnished
to Regi ons
HO finalizes SPMS measures and June 30, 1985
definitions with Regions
1st draft of revised FY 86 July 15, 1985
SCAP submitted to HO by Regions
Passback to regions on revised August 1, 198b
FY 86 SCAP
OSWER submits draft SPMS targets, August 15, 1985
based on-FY 86 SCAP
AA/OSWER and PA's approve FY 86 Early September, 1985
SCAP, and submit final SP^S targets
to OMSE
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OSWER # 9840.1
ATTACHMENT II
REVISED FY 86 SCAP TARGETS
FOR ENFORCEMENT ACTIVITIES
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OSWER # 9840.1
ATTACHMENT III
DISCUSSION OF TARGET CHANGES
FOR ENFORCEMENT ACTIVITIES
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OSWER # 9840.1
Attachment
ENFORCEMENT TARGETS
Targets for enforcement activities were changed as follows:
Site Classification/RP Searches; NPL Sites
The goal for FY 1986 is to complete RP searches for all
sites proposed in NPL Updates 3,4,5 and 6 (which is currently
projected for February, 1986). The national target remains at
220, which is believed to be a conservative estimate of the number
of sites to be proposed. Regional targets were increased
proportionally to total 2200 Targets will be revised during FY
1986 to reflect actual numbers of proposed sites.
RP Searches; non°NPL Removals
The goal for FY 1986 is to complete RP searches for all non-
NPL removal sites so that notice letters, administrative enforcement
actions and cost recovery can be properly pursued. Targets were
adjusted to reflect revised targets for non-NPL removal initiations.
Enforcement and PRP RI/FS; NPL Sites
Some redistribution of targets was done consistent with
proposals submitted by Regions and with numbers of candidate
sites identified by Regions. PRP RI/FS should generally be
projects originally identified in the SCAP as fund or enforcement
managed RI/FS where PRPs agree to undertake them. Regions should
then backfill with new enforcement or fund RI/FS to maintain
their targeted level for RI/FS initiations.
Negotiations-Removal
Original targets were inadvertently set to be identical to
removal initiations. Revised targets are set at 50% of the
revised removal initiation targets.
Neqotiations-RI/FS
Targets were adjusted to reflect negotiations initiated
prior to all enforcement and PRP RI/FS and prior to 75% of the
targeted fund-lead RI/FS (assuming 25% of the fund-lead RI/FS
have no identified PRPs).
Neqotiations-RD/RA
Regions proposed targets based on all projected completions
which exceeded the national budget target. Regional proposed
targets were reduced to take into'consideration the number of
sites that are projected to be fund financed from the beginning
and those sites where only minimal chances of success would be
possible.
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OSWER # 9840.1
-2-
Negotiations - Cost Recovery
Targets were increased to reflect current policy that
negotiations will be conducted at all completed response actions
(completed non-NPL removals or RA completions) where viable PRPs
have been identified. The targets are set assuming viable PRPs
will be identified at 75% of candidate sites.
Administrative Orders - Removal
Targets were adjusted to 50% of the revised targets for
removal initiations.
Administrative Orders - Remedial
Targets were adjusted minimally to accomodate Regions proposed
targets, consistent with the national budget target. Some Regions
have proposed surprisingly few orders as compared to the number of
RD initiations targeted. Orders are estimated to be appropriate
prior to obligation at approximately 50% of the targeted RD sites.
Administrative Orders - Sections 3008 and 3013
Targets for these activities have been deleted as a result
of Regional comment. Use of these orders will be reported in
FY 86, and should be used by Regions where appropriate.
Enforcement Actions To Achieve RD/RA Response;
Enforcement Lead Sites
Most Regions proposed lower targets than originally assigned,
generally pointing out that administrative actions would be used
at many sites. However, judicial actions should be targeted for
all enforcement-lead or PRP RI/FS which will be completed by the
3rd quarter of FY 86 where appropriate. The budget assumes that
a significant percentage (70%) of the enforcement actions will be
$106 case referrals.
The revised targets reflect 90% of the number of such RI/FS
scheduled for completion (according to information submitted by
Regions through FY 85 quarterly reporting). RI/FS completions for
sites already referred for S106 judicial actions or where
administrative settlements include RD/RA have been substracted
from targets. Targets are set at,,.that level to ensure that
further slippage of RI/FS does not occur at more*than 10% of
sites and to ensure that judicial enforcement activities are
planned and brought when necessary.
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OSWER ft 9840.1
-3-
In order not to penalize Regions who bring successful
unilateral administrative enforcement actions or achieve
administrative settlements, those activities will also count
against this target. Unilateral orders which do not result in
compliance will not count against the target* and should be
followed by judicial referrals (they will eount against remedial
Aod. target).
Judicial Enforcement Actions (other)
Targets were adjusted to reflect Region's proposed targets.
Cost Recovery Checklists
Targets for these activities have been deletedo However,
Regions should plan to submit checklists at the appropriate time
in order to meet negotiation and referral schedules.
Cost Recovery Referrals
Targets were adjusted to reflect Region's proposed targets,
consistent with the budget target. Targets for removal and
remedial referrals are now combined. Targeted referrals which
are settled administratively (through a covenant not to sue) and
which are for expenditures of more than S200K will count against
the target.
Dioxin Response Actions
Targets were adjusted to reflect Region's proposals.
Resolution of Ongoing Judicial Actions
In order to ensure timely prosecution (or settlement) of
judicial actions, targets have been set for resolution of $106
• -and §107 actions. Targets are set at 33% of ongoing active cases.
Cases which are fully settled, dismissed or which begin a full,
final trial will count against these targets. This will require
close coordination with DOJ and the Office of Regional Counsel in
order to achieve this target.
NOTE: Activities at NPL federal facilities may count against
targets where comparable. For example, federal facility RI/PS
may count as PRP RI/FS if being done under a compliance agreement,
Similarly a compliance agreement for RD/RA may count against the
administrative order target. t
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OSWER #9840.1
ATTACHMENT IV
COMMENTS FOR INTEGRATING REMEDIAL AND ENFORCEMENT
ACTIVITIES IDENTIFIED IN THE SCAP
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OSWER # 9840.1
ENFORCEMENT PLAN - REGION I
lo Enforcement RI/FS; Enforcement-lead RI/FS should be clearly
identified as FE (or SE) on the remedial portion of the SCAP and
listed in the enforcement portion.
2e PEP RI/FS; The remedial SCAP should include a list of
"additional RI/FS projects* which will be funded as fund or
enforcement RI/FS on the SCAP are taken over by PRPs.
3o Negotiations; RI/FS; All RI/FS starts indicated on the remedial
SCAP should be listed prior to obligation unless there are no
known PRPs.
40 Negotiations; RD/RA; Cross check to be certain that all
completed RI/FS (whether fund, enforcement or PRP lead) are
scheduled unless there are no known PRPs,
5. Negotiations; Cost Recovery? All completed non-NPL removals
or remedial actions should be identified where FY 86 completions
can be projected now.
60 Remedial Administrative Orders; RI/FS A.O.s do not count
against this target (they are counted as PRP RI/FS). A.O.'s shoulf2-
be considered for each fund-financed RD candidate identified in
the SCAP.
7. Judicial Action; RD/RA; All enforcement or PRP RI/FS scheduled
for completion by the end of the third quarter, FY 86 should be
scheduled for referral in the event that administrative action is
unsuccessful.
8. Cost Recovery Referrals; Cross check with projected completions
of remedial actions and non-NPL removals which are now ongoing.
9o Case Resolution; Identify likely candidates for settlement
or trial.
10. FY 87 Projections;
(a) Remedial Administrative Orders; identify likely candidates
based on projected completions of enforcement/ PRP and fund
lead RI/FS.
(b) Remedial Cost Recoverys identify candidates by cross checkin
with projected R.A. completions in late FY 86 or early FY 87
(c) Judicial Action; RD/RA;'identify candidates based on
projected completions of enforcement and PRP RI/FS. For
purposes of projections, assume that administrative
will be unsuccessful.
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OSWER # 9840.1
ENFORCEMENT PLAN - REGION II
1. Enforcement RI/FS As per the December 24, 1984 SCAP guidance,
only approximately 20% of the enforcement RI/FS should be designated
state-enforcement lead. Obligation quarters should be indicated.
2. PRP RI/FS Regions should not attempt to project which sites
will be RI/FS settlements at this time, but should indicate "To
Be Determined". Sites originally designated on the remedial SCAP
as fund or enforcement lead will fill this catagory as they
settle. Additional fund and enforcement lead RI/FS should be
identified to backfill new starts when settlements occur.
3. Judicial Actions; RD/RA All enforcement or PRP RI/FS scheduled
for completion by the end of the third quarter, FY 86 should be
scheduled for referral in the event that administrative action is
unsuccessful.
4. Cost Recovery Referrals Cross check with projected completions
of remedial actions and non-NPL removals which are now ongoing.
5. Case Resolution; Identify likely candidates for settlement
or trial.
6. FY 87 Projections
(a) Remedial Administrative Orders: identify likely candidates
based on projected completions of enforcement, PRP and
fund lead RI/FS<
(b) Remedial Cost Recovery: identify candidates by cross
checking with projected R.A. completions in late FY 86
or FY 87.
(c) Judicial Action: RD/RA: identify candidates based on
projected completions of enforcement and PRP RI/FS.
For purposes of projections, assume that administrative
action be unsuccessful.
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OSWER # 9840.1
ENFORCEMENT PLAN - REGION III
1. PRP RI/FS: The Region should not attempt to project which
sites will be RI/FS settlements at this time, but should indicate
"To Be Determined". Sites originally designated on the remedial
SCAP as fund or enforcement lead will fill this catagory as they
settle. Additional fund and enforcement lead RI/FS should be
identified to backfill new starts when settlements occur.
2. Negotiations; Removal Regions should only identify sites to
the extent that it is known now that a removal will be initiated„
3. Negotiations; RI/FS All RI/FS scheduled for funding which
have identified PRPs should be scheduled for negotiation.
4. Negotiations; Cost Recovery Cross check against projected
completions of remedial actions.
5. Remedial Administrative Orders: A.O.s should be considered
for completed fund-lead RI/FS prior to RD obligations.
6. Judicial Actions RD/RA All completed PRP or enforcement
RI/FS should be scheduled.for referral.
7. Case Resolution; Identify likely candidates for settlement
or trial.
8. FY 87 Projections
(a) Remedial Administrative Orders: identify likely candidates
based on projected completions of enforcement, PRP and
fund lead RI/FS.
(b) Remedial Cost Recovery: identify candidates by cross
checking with projected R.A. completions in late FY 86 or
early FY 87.
(c) Judicial Action: RD/RA: identify candidates based on
projected completions of enforcement and PRP RI/FS.
For purposes of projections, assume that administrative
action will be unsuccessful.
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OSWER ft 9840.1
ENFORCEMENT PLAN - REGION IV
1. PRP RI/FS; The Region should not attempt to project which
sites will be RI/FS settlements at this time, but should indicate
"To Be Determined". Sites originally designated on the remedial
SCAP as fund or enforcement lead will fill this catagory as they
settle. Additional fund and enforcement lead RI/FS should be
identified to backfill new starts when settlements occur.
2. Negotiations; RI/FS All RI/FS scheduled for funding which
have identified PRPs should be scheduled for negotiation.
3. Negotiations; RD/RA Cross check to be certain that all
completed RI/FS (whether fund, enforcement or PRP lead) are
scheduled unless there are no known PRPs.
4. Negotiations; Cost Recovery Cros check against projected
completions of remedial actions.
5. Remedial Administrative Orders A.O.s should be considered for
completed fund-lead RI/FS prior to RD obligations.
6. Judicial Actions RD/RA All completed PRP or enforcement
RI/FS should be scheduled for referral.
7. Cost Recovery Referrals Cross check with projected completions
of remedial actions and non-NPL removals which are now ongoing.
8. Case Resolution: Identify likely candidates for settlement
or trial.
9. FY 87 Projections
(a) Remedial Administrative Orders: identify likely candidates
based on projected completions of enforcement, PRP and
fund lead RI/FS.
(b) Remedial Cost Recovery: identify candidates by cross
checking with projected R.A. completions in late FY 86 or
early FY 87.
(c) Judicial Action: RD/RA: identify candidates based on
projected completions of enforcement and PRP RI/FS.
For purposes of projections, assume that administrative
action will be unsuccessful.
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OSWER # 9840.1
ENFORCEMENT PLAN - REGION V
1. Negotiations; Cost Recovery Cross check against projected
completions at remedial and non-NPL removal sites«
2o Remedial Administrative Orders; AoO.s should be considered
for completed fund-lead RI/FS prior to RD obligations.
3o Judicial Actions RD/RA All completed PRP or enforcement
RX/PS should be scheduled for referral.
4. Cost Recovery Referrals Cross check with projected completions
of remedial actions and non-NPL removals which are now ongoing.
5. Case Resolution; Identify likely candidates for settlement
or trial.
6. FY 87 Projections
(a) Remedial Administrative Orders; identify likely candidates
based on projected completions of enforcement, PRP and
fund lead RI/FS.
(b) Remedial Cost Recovery: identify candidates by cross
checking with projected R.A. completions in late FY 86 or
early FY 87.
(c) Judicial Action; RD/RA; identify candidates based on
projected completions of enforcement and PRP RI/FS.
For purposes of projections, assume that administrative
action will be unsuccessful.
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OSWER # 840.1
ENFORCEMENT PLAN - REGION VI
1. Negotiations; RI/FS; All RI/FS starts indicated on the remedial
SCAP should be listed prior to obligation unless there are no
known PRPs.
2. Remedial Administrative Orders; A.O.s should be considered
for completed fund-lead RI/FS prior to RD obligations.
3. Judicial Action; RD/RA; All enforcement or PRP RI/FS scheduled
for completion by the end of the third quarter, FY 86 should be
scheduled for referral in the event that administrative action is
unsuccessfulo
4. Case Resolution; Identify likely candidates for settlement
or trial.
5. FY 87 Projections
(a) Remedial Administrative Orders: identify likely candidates
based on projected completions of enforcement, PRP and
fund lead RI/FS.
(b) Remedial Cost Recovery: identify candidates by cross
checking with projected R.A. completions in late FY 86 or
early FY 87.
(c) Judicial Action: RD/RA: identify candidates based on
projected completions of enforcement and PRP RI/FS.
For purposes of projections, assume that administrative
action will be unsuccessful.
6. RD/RA Obligations; RD/RA obligations are generally not
available for enforcement lead sites such as Vertac and Hardage
and they have been deleted from the SCAP. Funds can be made
available, depending on other program requirements, only if there
are legitimate reasons for changing site classification.
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OSWER ft 9840.1
ENFORCEMENT PLAN - REGION VII
1. Enforcement RI/FS; The "Type Codes" indicated by the submittal
are inconsistent with site classification codes and are confusing.
Enforcement RI/FS candidates should be federal enforcement or
state enforcement lead sites»
2> PRP RI/FS; Regions should not attempt to project which sites
will be RI/FS settlements at this time, but should indicate "To
Be Determined". Sites originally designated on the remedial SCAP
as fund or enforcement lead will fill this catagory as they
settleo Additional fund and enforcement lead RI/FS should be
identified to backfill ne starts when settlements occur.
3. Negotiations; RD/RAr Cross check to be certain that all
completed RI/FS (whether fund, enforcement or PRP lead) are
scheduled unless there are no known PRPs.
4. Negotiations; Cost Recovery; All completed non-NPL removals
or remedial actions should be identified where FY 86 completions
can be projected now.
5. Remedial Administrative Orders; A.O.s should be considered
for completed fund-lead RI/FS prior to RO obligations.
6. Judicial Action? RD/RA; All enforcement or PRP RI/FS scheduled
for complet: n by the end of the third quarter, FY 86 should be
scheduled for referral in the event that administrative action is
unsuccessful.
7. Case Resolution; Identify likely candidates for settlement
or trial.
8. FY 87 Projections
(a) Remedial Administrative Orders: identify likely candidates
based on projected completions of enforcement, PRP and
fund lead RI/FS.
(b) Remedial Cost Recovery: identify candidates by cross
checking with projected R.A. completions in late FY 86 or
early FY 87.
(c) Judicial Action: RD/RA: identify candidates based on
projected completions of enforcement and PRP RI/FS.
For purposes of projections, assume that administrative
action will be unsuccessful.
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OSWER # 9840.1
ENFORCEMENT PLAN - REGION VIII
1. PRP RI/FS Regions should not attempt to project which sites
will be RI/FS settlements at this time, but should indicate "To
Be Determined". Sites originally designated on the remedial SCAP
as fund or enforcement lead will fill this catagory as they
settle. Additional fund and enforcement lead RI/FS should be
identified to backfill ne starts when settlements occur.
2. Negotiations; RI/FS: All RI/FS starts indicated on the remedial
SCAP should be listed prior to obligation unless there are no
known PRPs.
3. Negotiations; RD/RA; Cross check to be certain that all
completed RI/FS (whether fund, enforcement or PRP lead) are
scheduled unless there are no known PRPs.
4. Negotiations; Cost Recovery: All completed non-NPL removals
or remedial actions should be identified where FY 86 completions
can be projected now.
.5. Judicial Action; RD/RA; All enforcement or PRP RI/FS scheduled
for completion by the end of the third quarter, FY 86 should be
scheduled for referral in the event that administrative action is
unsuccessful.
6. Case Resolution; Identify likely candidates for settlement
or trial.
7. FY 87 Projections
(a) Remedial Administrative Orders: identify likely candidates
based on projected completions of enforcement, PRP and
fund lead RI/FS.
(b) Remedial Cost Recovery: identify candidates by cross
checking with projected R.A. completions in late FY 86 or
early FY 87.
(c) Judicial Action: RD/RA: identify candidates based on
projected completions of enforcement and PRP RI/FS.
For purposes of projections, assume that administrative
action will be unsuccessful.
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OSWER * 9840.1
ENFORCEMENT PLAN - REGION IX
1. PRP RI/FS; Regions should not attempt to project which sites
will be RI/FS settlements at this time, but should indicate "To
Be Determined". Sites originally designated on the remedial SCAP
as fund or enforcement lead will fill this catagory as they
settle. Additional fund and enforcement lead RI/FS should be
identified to backfill ne starts when settlements occur.
2. Negotiationst RI/FSt All RI/FS starts indicated on th.e remedial
SCAP should be listed prior to obligation unless there are no
known PRPs.
3. Negotiations; Cost Recovery; All completed non-NPL.removals
or remedial actions should be identified where FY 86 completions
can be projected now.
4. Remedial Administrative Orders; A.O.s should be considered
for completed fund-lead RI/FS prior to RD obligations.
5. Judicial Action; RD/RA;- All enforcement or PRP RI/FS scheduled
for completion by the end of the third quarter, FY 86 should be
scheduled for referral in the event that administrative action is
unsuccessful.
6. Cost Recovery Referrals; Cross check with projected completions
of remedial actions and non-NPL removals which are now ongoing.
7. Case Resolution; Identify likely candidates for settlement
or trial.
8. FY 87 Projections
(a) Remedial Administrative Orders; identify likely candidates
based on projected completions of enforcement, PRP and
fund lead RI/FS.
(b) Remedial Cost Recovery: identify candidates by cross
checking with projected R.A. completions in late FY 86 or
early FY 87.
(c) Judicial Action; RD/RA; identify candidates based on
projected completions of enforcement and PRP RI/FS.
For purposes of projections, assume that administrative
action will be. unsuccessful.
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OSWER ft 9840.1
ENFORCEMENT PLAN - REGION X
1. Enforcement RI/FS Candidate sites, including additional
projects to replace PRP takeover should be identified.
2. Negotiations; RI/FS: All RI/FS starts indicated on the remedial
SCAP should be listed prior to obligation unless there are no
known PRPs.
3. Negotiations; RD/RA; Cross check to be certain that all
completed RI/FS (whether fund, enforcement or PRP lead) are
scheduled unless there are no known PRPs.
4. Negotiations; Cost Recovery; All completed non-NPL removals
or remedial actions should be identified where FY 86 completions
can be projected now.
5. Remedial Administrative Orderst A.O.s should be considered
for completed fund-lead RI/FS prior to RD obligations.
6. Judicial Action: RD/RA; All enforcement or PRP RI/FS scheduled
for completion by the end of the third quarter, FY 86 should be
scheduled for referral in the event that administrative action is -
unsuccessful. .
7. Case Resolution; Identify likely candidates for settlement
or trial.
8. FY 87 Projections
(a) Remedial Administrative Orders: identify likely candidates
based on projected completions of enforcement, PRP and
fund lead RI/FS.
(b) Remedial Cost Recovery: identify candidates by cross
checking with projected R.A. completions in late FY 86 or
early FY 87.
(c) Judicial Action: RD/RA: identify candidates based on
projected completions of enforcement and PRP RI/FS.
For purposes of projections, assume that administrative
action will be unsuccessful.
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OSWER # 9840.1
FY Kfi SCAP NEW ENFORCEMENT
RI/F$
REGION
I
II
III
IV
V
VI
VII
VIII
IX
X
TOTALS
PRELIMINARY
FY 86
TARGETS
4
13
6
6
14
3
1
1
3
1
52
REGIONAL
SUBMISSIONS
0
12
6
6
14
n
a
a
5
0
51
REVJSFP
FYRfi SPMS
TARGETS
•RI/FS-R
H
13
fi
fi
1M
3
1
1
• • V •
1
52
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