SEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9203.1-051
December 1992
SACM Regional Decision
Teams — Interim Guidance
Office of Emergency and Remedial Response
Office of Waste Programs Enforcement
Office of Enforcement
Intermittent Bulletin
Volume 1 Number 5
The purpose of the Superfund Accelerated Cleanup Model (SACM) is to make Superfund cleanups more timely and efficient.
This will be accomplished through more focus on the front end of the process and better integration of all Superfund program
components. The approach involves:
A continuous process for assessing site-specific conditions and the need for action;
Cross-program coordination of response planning;
Prompt risk reduction through early action (removal or remedial);
Appropriate cleanup of long-term environmental problems;
Early public notification and participation; and
Early initiation of enforcement activities.
SACM is a process change that should be considered for all Superfund activities. Implementation of this policy will be
consistent with the National CHI and Hazardous Substances Pollution Contingency Plan (NCP) and the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). Overall Superfund priorities remain the same: deal
with the worst problems first; aggressively pursue enforcement; and involve the public and relevant State agencies at all
appropriate stages of the work.
Regional Decision Team Goal
The goal of the Regional Decision Team
(RDT) is effective coordination, com-
munication, and integration of pro-
gram authority, expertise, re-
sources, and tools to solve prob-
lems that arise at Superfund sites.
Close coordination of the site as-
sessment and response processes
and initiation of any appropriate
enforcement responses through the
RDT mechanism will enable the
Superfund Program to achieve risk
reduction and site response goals quickly and efficiently.
Implementation
%
Faster... C/eaner...Safer
The RDT concept offers a new approach for determining
Superfund response actions. The RDT provides for broad
participation across all program elements while placing
emphasis on teamwork and Regional and staff empower-
ment for developing response strategies and solving site
problems. The RDT also has the responsibility for ensuring
that response actions are fully consistent with the require-
ments contained in CERCLA and the NCP. Regions have
flexibility in designing an RDT process that meets their
specific needs, recognizing that a specific formal structure
is not as critical as the overall goal of program integration.
Accordingly, Regions should design a process that,
at a minimum, ensures effective communi-
_ cation across the removal, site assessment,
CV remedial, enforcement, and commu-
€£» nity involvement program elements,
^X and provides for the full and active
v- participation of the Office of Re-
gional Counsel. Further, Re-
gions should ensure thatthe RDT
works in concert with the Region's
management structure, and with
those designated site managers
(e.g., Site Assessment Managers
(SAMs), On-Scene Coordinators
(OSCs), Remedial Project Managers (RPMs), and/or indi-
vidual site management teams) that are responsible for
handling the site on a day-to-day basis. In addition, the
Region should discuss and establish with the State a pro-
cess for Siate involvement during the SACM decision-
making process.
Each Region should develop guidelines for the operation
of the RDT so that it will function as smoothly and effec-
tively as possible, while facilitating the involvement of
representatives from various offices, both within and out-
side the Regional office. In addition, it will be impor-
tant for the Regional divisions to fully plan out what they
hope to achieve with their RDT, and initiate early dialogue
to establish roles and responsibilities throughout the re-
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sponse process. The following list of possible start-up
actions should be considered by each Region.
1. Assign roles and responsibilities of selected mem-
bers;
2. Establish coordination process with the States;
3. Establish decision criteria for determining response
decisions, including response authority;
4. Identify the universe of Superfund sites within the
Region and the plan of action for integrated assess-
ment of such sites;
5. Develop approach for designationof response priori-
ties;
6. Establish a process for quick initiation of potentially
responsible party (PRP) search activities and enforce-
ment efforts; and
7. Develop process for early coordination with Head-
quarters, and support agencies/organizations (e.g.,
Agency for Toxic Substances and Disease Registry
(ATSDR), Department of Justice POJ)) providing
technical/legal assistance to the RDT.
RDT Operations
The RDT is empowered by the Region to make those
decisions that are delegated to its level. This body serves as
a tool to ensure early and effective communication and
should provide input for the traditional line decision-
making authorities. The RDT should provide policy and
strategic direction to designated site managers (SAM, OSC
and RPM), to ensure the integration of program authorities
(Fund-lead vs. PRP-lead, removal vs. remedial), resources,
and tools to solve site-specific problems. (The RDT is not
responsible for true emergencies, which the removal pro-
gram will continue to handle.) The RDT should convene
either routinely or on an as-needed basis, to receive status
reports and strategy options from the site manager(s),
establish response priorities, and provide both advice and
direction on appropriate response actions (e.g., scope and
sequence of projects). RDT involvement in a site response
should follow the process or recommend actions as de-
scribed below:
1. Early Assessment Stage:
Following receipt of initial site information (e.g., Prelimi-
nary Assessment/Removal Assessment or Site Inspec-
tion), the RDT would convene to assess optional next steps
for all sites where a Site Evaluation Accomplished (SEA)
decision is not appropriate. Specific options available to
the RDT include:
* Recommend/Develop an Early Action Response
Plan
• Emergency/Time-Critical Removal Action — situa-
tions where prompt action is- required to mitigate a
risk to human health or the environment. RDT in-
volvement initiating these actions may be limited
based on the time available; however, the RDT should
participate in evaluating the response after the action
has been taken and identifying the next steps re-
quired to complete the response, if any. Time-critical
actions, which must be initiated quickly to protect
human health and the environment, should be re-
served for situations where an action must be initi-
ated quickly to protect human health and the envi-
ronment.
• Non-Time-Critical Removal Action — less urgent
action intended to stabilize the site and/or eliminate
contamination. The RDT should assess the opportu-
nity for response and initiate the preparation of the
Engineering Evaluation/Cost Analysis (EE /C A) and
Action Memo with prior public comment (and for
Fund-financed removals, the required justification
for exemptions to exceed statutory removal time and
dollar limits). Also, the RDT should determine
whether proposed actions are time-critical or non-
time-critical, or whether the site requires remedial
action (including expedite J National Priorities List
(NPL) evaluation if Fund-financed remedial action is
expected).
• Early/Interim Remedial Action — actions at \PL
sites intended to achieve site remediation and nsk
reduction. The RDT should initiate a Remedial Inves-
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tigation / Feasibility Study (RI/FS) leading to an early
or interim action Record of Decision (ROD).
• Direct The Acquisition of Additional Data
• The RDT may require that additional data be col-
lected prior to deciding on a course of action for a site.
If at any point in the process of collecting site infor-
mation, the site appears to be an NPL-caliber site, the
RDT should consider initiating RI activities, and,
where appropriate, early actions.
* NPL Listing
• Where sufficient data exist to list a site and where
remedial response actions are envisioned, the listing
process should be concurrent with early response
action or expanded Site Investigation/Remedial In-
vestigation (SI/RI) data collection. Fund-lead early
remedial actions can only be conducted after the site
is on the NPL.
• Enforcement Strategy
• Initiate early PRP search activities to aggressively
pursue enforcement first and define the role of PRPs
in response action and/or data collection. Negotia-
tions with PRPs should be conducted as appropriate
during the assessment process as well as for removal
or remedial response actions. The RDT will have
input on the selection of the appropriate enforcement
document (Administrative Order on Consent/Uni-
lateral Administrative Order (AOC/UAO), consent
decree, etc.) and maintainingcoordination with Head-
quarters and DOJ, where appropriate, regarding the
enforcement strategy.
2. Advanced Assessment Stage:
As additional site information is received (e.g., after or
during either the early action, or the focused or expanded
SI/RI part of the integrated site assessment), the RDT
should assess next steps for sites warranting additional
response action. Specific options would be similar to those
identified above. At this stage, response actions generally
would fall in the non-time-critical removal, early remedial
action category, or in the long-term action category. The
RDT should direct the initiation of the appropriate support
actions. Also, the RDT should assess the relative priorities
of the proposed response actions and allocate resources
accordingly, if delegated this authority. If not, recommen-
dations should be made if additional resources are neces-
sary.
3. Public Participation/Community Involvement
The success of SACM will depend to a large degree on
public acceptance of our actions at the site level. Maintain-
ing a strong focus on the local community (our primary
"customer") will contribute immensely to this success. The
administrative record file, a primary vehicle for public
participation, must be made available to the public for
inspection according to the schedule set out in the NCP
Subpart I. This is a necessary component for cost recovery.
The decisions that the RDT makes about the future of a site
will be important to the local community. The RDT, there-
fore, should take community concerns into account when
making decisions on a site response strategy. The commu-
nity should be promptly informed once those decisions are
made. Community relations planning should be included
in the site response strategy as an equal element with
technical and legal considerations, including due consid-
eration of CERCLA and NCP requirements.
Using non-time-critical removal actions, as compared to
time-critical removal actions, will allow prior public com-
ment, and are encouraged where time allows.
4. Follow-up:
The Regions should develop protocols defining the role of
the RDT in monitoring and evaluating ongoing response
and assessment activities.
Organization
As described above, the RDT is designed to ensure effec-
tivecommunicationand coordination across theSuperfund
program. The RDT provides policy advice and strategic
direction to site mangers and sets priorities to promote
efficient site response. RDT generally consists of manage-
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ment level personnel, as opposed to the make-up of site
management teams. The RDT generally will develop re-
sponse strategies for sites (e.g., the decision to take a
"removal" versus a "remedial" action). Individuals autho-
rized to sign Action Memos or RODs may be on the RDT.
The RDT will not have responsibility for the day-to-day
site project management, which will remain with OSCs/
RPMs and site-management teams.
Regions have flexibility in developing an organizational
structure for the RDT, and may decide to develop multiple
RDTs. In Regions where all program elements report to a
single manager, (e.g., Deputy Director forSuperfund), the
RDT might consist of the line managers reporting to that
manager, along with a representative from the Office of
Regional Counsel. In Regions where program responsibili-
ties are dispersed, a more formal arrangement would be
appropriate. In these instances, a typical model for start-up
might include the following senior level participants.
• Senior Manager
• Remedial Person
• Removal Person
• Site Assessment Person
• Cost Recovery Person
• RiskAssessor/BiologicaJTechnicalAssistanceGroup
(BTAG) Representative
• Attorney from Office of Regional Counsel
• Community Involvement Coordinator
The Regions should involve the States as often as possible
in an appropriate manner. Typically, States would be
consulted in concert v-ith RDT deliberations or in prepara-
tion for an RDT meeting. The RDT also should meet
periodically or on an as needed basis, with support agen-
cies and organizations (i.e., ATSDR, Corps of Engineers,
Office of Research and Development, BTAG, PRP search,
contract management staff, DOJ; etc.) to receive ad vice and
input on response options or enforcement actions as ap-
propriate.
Headquarters Consultation
Regions must consult with Headquarters prior to taking an
action which will require funding beyond what the Region
has in its allowance. Regions must also consult before
committing to a PRP-lead or Fund-lead non-time-critical
action costing over $5 million. Regions must always follow
the existing rules for justifying and obtaining exemptions
for removal actions estimated to cost over S2 million or
exceed one year duration. Regions are also strongly urged
to discuss with Headquarters any situations which present
particularly difficult issues or may be controversial with
State or other interested parties.
NOTICE: The policies set out in this fact sheet are not final
Agency action, but are intended solely as guidance. They
are not intended, nor can they be relied upon, to create any
rights enforceable by any party in litigation with the United
States. EPA officials should follow the guidance provided
in this fact sheet, or may act at variance with the guidance,
based on an analysis of site-specific circumstances. The
Agency also reserves the right to change this guidance at
any time without public notice.
SACM Regional Decision Teams - Interim
Guidance
This paper is one of five fact sheets published by EPA
under publication number 9203.1-051 (Volume 1,
Numbers 1-5) to describe the Superfund Accelerated
Cleanup Model (SACM) and should be reviewed in
conjunction with the other SACM fact sheets. Com-
ments on this document should be directed to Robin
Anderson of the Hazardous Site Control Division
(703) 603-8747.
There are two other important sources of informa-
tion: "SACM concept paper" (8/5/92) and Guidance
on Implementation of the Superfund Accelerated Cleanup
Model Under CERCLA and the NCP [OSVVER Direc-
tive No. 9203.1-03 (7/7/92)]. General SACM infor-
mation can be obtained by calling the Su
Document Center (202) 260-9760.
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