United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9203.1-051
December 1992
Status of Key SACM Program
Management Issues — Interim
Guidance
Office of Emergency and Remedial Response
Office of Waste Programs Enforcement
Office of Enforcement
Intermittent Bulletin
Volume 1 Number 1
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 wuTfae
consistent with the National Oil 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.
Status of Key SACM Program Management Issues -
Interim Guidance
SACM raises a number of management-related issues
which require reconsideration of the current ways
Headquarters and Regions do business in budget
planning and execution, reporting accomplishments,
measuring performance, contracting, training, distribu-
tion of responsibility, and communications. This SACM
Program Management Update will describe activities
underway, planned, and recently completed to refocus
Superfund's program management systems to support
SACM implementation.
Regional Target (SCAP/STARS)
Flexibility
To allow greater Regional flexibility
in implementing Superfund site
cleanups, SACM will require
changes in the program's targets
and measures under the Superfund
Comprehensive Accomplishments
Plan (SC AP) and the EPA Strategic
Targeted Activities for Results Sys-
tem (STARS). FY93 program mea-
sures and targets were developed too early to incorporate
key aspects of SACM. To prevent the FY93 STARS/SCAP
measures from impeding the implementation of SACM,
the Office of Policy Planning and Evaluation (OPPE) ap-
proved an Office of Solid Waste and Emergency Response
(OSWER) request to allow the program maximum flexibil-
ity to grant target relief.
Granting FY93 target relief requires the Regions to pro-
vide, on a case-by-case basis, a good resource-based ratio-
nale which clearly shows work commensurate with the
targeted measure. For example, the Office of Waste Pro-
grams Enforcement (OWPE) has proposed to grantSC AP/
STARS target relief for Remedial Design/Remedial Action
(RD/RA) settlement where the Region implements a non-
time-critical removal with an estimated clean-up
value of greater than $2 million. The Office of
Emergency and Remedial Response
r (OERR) has proposed to grant target
6*~ reliefforremedialactionstartswhere
•^ the Region conducts a large (>S2
million) non-time-critical removal
instead.
\
Faster... C/eaner... Safer
Headquarters and the Regions
have started developing new FY94
SCAP/STARS measures. These
new measures will reflect the pro-
gram changes brought by SACM,
and will provide the Regions greater flexibility to clean up
"NPL-caliber" sites more efficiently. Headquarters will
transmit a proposal of draft FY94 measures to the Regions
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for review in January 1993. This package will be a basis for
discussion during the Program Management meeting in
February 1993. The intention is to complete a comprehen-
sive revision of STARS/SCAP targets and measures so that
SACM implementation is fully supported while reducing
the total number of Regional targets.
National SACM Evaluation Measures
Baseline national criteria need to be established to analyze
and evaluate the success of SACM in improving the time-
liness and cost-effectiveness of Superfund cleanup actions.
Existing Superfund time duration trend measures will be
reevaluated to ensure they effectively document the
program's baseline and capture incremental changes. De-
velopment of Superfund risk reduction measures is critical
to the program's ability to report achievements of early
action and long-term site cleanups. Existing Superfund
environmental indicators will be the starting point for
measuring risk reduction consistently for both early ac-
tions and long-term responses. These measures will allow
us to identify the extent to which SACM projects and
overall program changes linked to SACM implementation
are measuring up to the overall objectives of SACM. These
measures may also identify areas in which the SACM
approach can be refined as full implementation proceeds
in 1994.
In addition, there is a need to reach agreement on overall
measures of program performance that will communicate
meaningful program results to Superfund's customers.
Ongoing communication initiatives are being reexamined
to consider any refinements that are called for with the
SACM program changes.
Workload Model
The workload models were frozen in FY91 and FY92, and
are frozen for FY93. With SACM, there is a need to deter-
mine the future relationship between FTE workload/pric-
ing factors and future program goals. To date, Headquar-
ters' efforts have focused on generating a consensus on
revising/reopening the Superfund workload models.
The Regions provided input on whether the models should
be reopened. Six Regions favored reopening/revising the
models, two proposed that a new, less resource intensive
mechanism for distributing FTE be pursued, and two
opposed reopening/revising the models. The Regions also
made two key recommendations: the models should not be
reopened until FY95, and the family of Superfund models
(program, enforcement, and Federal facilities) should be
integrated.
In preparation for the February 1993 Program Manage-
ment meeting, Headquarters plans to draft an approach for
addressing the model changes based on the Regional and
Headquarters correspondence to date This proposal will
be the point of departure for a break-out/discussion ses-
sion during the meeting. The goal is to close the Program
Management meeting with a joint approach to revising the
Superfund workload models.
In addition, as was identified during the initial SACM
planning meetings, it is critical that Regions evaluate their
existing workforce skill mixes and identify cross-training
and workforce development activities that are needed to
effectively implement SACM.
Budget Flexibility
Beginning with the FY92 budget, Superfund monies have
been apportioned between "Cleanup," "Enforcement,"
and "Support," with control subtotals for each category,
and a narrow definition of cleanup. Regions need more
flexibility in resource utilization than the budget process
has provided to streamline and accelerate the cleanup of
Superfund sites under SACM. One of the most critical
areas involves the cleanup/support budget category. For
FY94 OERR recast the Superfund Response budget, taking
into accountSacm, in a way that considerably broadens the
definition of cleanup.
Though the broader definition of cleanup was developed
for the FY94 budget submission, it has been implemented
in the FY93 enacted budget. A new advice of allowance
(AOA) category has been added to the Cleanup category.
The new AOA is site characterization; it includes all site
assessment and remedial analysis (e.g., aerial photo, hy-
dro-geo work) funding, and creates more Regional fund-
ing flexibility in these categories. This change significantly
bolsters the Agency's ability to support the funding needs
of the integrated assessments called for under SACM.
Greater flexibility among the various response activities is
also needed. As an example, a Region that has planned a
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remedial action at a given site and identifies an opportu-
nity to more quickly reduce risks via an early action must
have access to the funds required to implement this action.
As such, the program has set aside $50 million of the
remedial action budget to encourage increased risk reduc-
tion at NPL sites through early action activities. The FY92
removal budget was successfully increased to support
SACM early action projects. As new opportunities for
flexibility present themselves we will continue to work
with the OSWER senior budget officer, comptroller, and
Office of Management and Budget (OMB) to further in-
crease budget flexibility.
Program Priorities
Implementation of SACM requires that overall Superfund
program priorities be reexamined. The Superfund Program
Management Manual and Agency Operating Guidance are the
key .documents that lay out these integrated program
priorities. The FY93 Program Management Manual was re-
vised to incorporate FY93 SACM implementation activi-
ties into overall program priorities.
SACM has modified the way we think of the Superfund
universe. Traditionally, sites were distinguished primarily
by whether or not they were listed on the National Priori-
ties Last (NPL). EPA typically conducts only emergency
and time-critical responses at non-NPL sites. EPAdoesnot
intend to alter significantly its traditional approach to
addressing non-NPL sites not expected to qualify for list-
ing.
In contrast, the program will seek to invest resources
earlier in NPL-caliber sites to conduct integrated assess-
ments and early actions. For sites currently on the NPL,
EPA intends to take ad vantage of opportunities to conduct
early actions and accelerate long-term responses. Thus, it
may be useful to think of the Superfund universe under
SACM as consistingof (1) non-NPL sites which EPA screens
and takes needed emergency /time-critical actions; (2) NPL
caliber sites where EPA conducts integrated assessments
and early actions; and, (3) NPL sites where EPA conducts
the full range of Superfund responses.
Analysis is underway to assess what actions will be needed
to achieve the Superfund program's long-term goal of 650
NPL construction completions by the year 2000. This analy-
sis should help to determine the abiUty of EPA and State
agencies to invest more resources into SACM integrated
assessments and early actions at NPL-caliber sites without
jeopardizing the NPL construction completion goal. Dis-
cussions during the February 1993 Program Management
meeting will clarify program priorities and provide more
specificity in appropriate resource investments and
disinvestments to support SACM's implementation.
Federal Facilities
The Office of Federal Facilities Enforcement (OFFE) sup-
ports the focus on accelerated cleanup. OFFE, in conjunc-
tion with the Regions, has developed a draft guidance
covering site assessment, impactof NPL listings, presump-
tive remedies, early actions vs. long-term actions, effect on
existing Federal facility agreements, and Regional Deci-
sion Teams. The draft guidance is due out for final com-
ment during the latter part of December and is expected to
be final by February 1993.
OFFE has been working with the Superfund Revitalization
Office (SRO) to communicate the Federal Facilities Accel-
erated Cleanup for Superfund (FFACS) policy and its
Superfund impacts to the other Federal and State agencies.
OFFE will also be assessing the impacts of FFACS on
SCAP/STARS targets and measures, workload model,
and other program management issues.
Contracts
The Long-Term Contracting Strategy for Superfund (LTCS)
was completed in September 1990. Implementation of the
Strategy is ongoing. The Strategy analyzed the long-term
contract needs of the Superfund Program and designed a
portfolio of Superfund contracts to meet those needs over
the next ten years.
Many of the underlying principles of SACM (e.g., increas-
ing early action responses) were anticipated in activities
under the LTCS (e.g., creating Emergency and Rapid Re-
sponse Services (ERRS) contracts; combining site assess-
ment and response technical assistance functions under a
single Superfund Technical Assessment and Response
Team (START) contract, etc.). Placement of new contracts
has begun and will continue over the next several years.
The LTCS itself and the scheduling of new procurements
easily lend themselves to the phase-in of SACM.
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Communicating Program Accomplishments
Considerable effort has been undertaken to communicate
the goals/objectives, plans, and expectations for imple-
menting SACM to other Federal and State agencies, other
EPA Offices, critical external groups including Congress,
environmental and trade groups, and others. We need to
seek and incorporate feedback from these groups into our
implementation efforts, and regularly communicate the
program's progress to this audience.
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.
Status of Key SACM Program Management Issues
- 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. Re-
gions are encouraged to contact the following indi-
viduals for information on program management
issues: Dave Evans (703) 603-8885 in OERR; Tai-ming
Chang (703) 603-8965 in OWPE (SCAP/STARS and
contracts); David Chamberlin (202) 260-1118 in OWPE
(workload model and budget); or Rene Wynn (202)
260-3025 in OFFE for further clarification, sugges-
tions or comments.
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 [OSWER Directive
No. 9203.1-03 (7/7/92)]. General SACM information
can be obtained by calling the Superfund Document
Center (202) 260-9760.
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