vv EPA
             United States
             Environmental Protection
             Agency
           Office of
           Solid Waste and
           Emergency Response
DIRECTIVE NUMBER:  9295. 5-01
TITLE'
                    BETWEEN FEMA AND EPA FOR THE IMPLEMENTATION OF
                  CERCLA RELOCATION ACTIVITIES UN
              APPROVAL DATE: April 8, 1985

              EFFECTIVE DATE: April 8, 1985

              ORIGINATING OFFICE: <*«« of Solid Waste

              0 FINAL

              D DRAFT

               STATUS:



              REFERENCE (other documents):
 OS WER      OS WER     OS WER
/£   DIRECTIVE    DIRECTIVE   Di

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(03/19/87 United States Environmental Protection Agency
Washington, 0 C. 20460
EPA OSWER Directive Initiation Request
2. Originator Information
Name of Contact Person Mil Cod* Office
BROWN OERR/OPM
1 Olrecttve Number
9295.5-01

Telephone Number
475-8102
3. Title
MOU BETWEEN FEMA AND EPA FOR THE IMPLEMENTATION OF
CERCLA RELOCATION ACTIVITIES UN

4. oummdry of Directive (inciuce DTHI suisment 01 purpose)
Describes major responsibilities and outlines
areas of mutual support and cooperation relating
to relocation activities associated with response
actions persuant to CERCLA, Executive Order 12316,
and the NCP (40 CFR Part 300) . Effective until
'April 1989. (4/85, 17 pp)

5 Keywords ,i
SUPERFUND, CERCLA, RESPONSE ACTIONS, INTERAGENCY AGREEMENT
Km rV-h*a thlsi nirsM-rtH/tt Tiiium j\rlai Dr*usruia **' 	 *' — *-t«»l^^^n \tmrn I XI kin
b Does it Supplement Previous Directives^)? I I yes i xl No What<
7 Draft Lavsl
I I A-SlgnedbyA/lDAA | I B- Signed by Office Director I I C- For Review a


This H«quest Mists OaWen Dvscuves system Format


9 Name and Tttle of Approving Official
J.W. MCGRAW
What directive (number, title)
directive (number, title)
Comment 1 1 In Devetopment

Date
°r*^Y/fpA-^
OSWER    OSWER     OSWER
    DIRECTIVE    DIRECTIVE

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                        OSWER Directive 9295.5-01


                          MEMORANDUM OF UNDERSTANDING
                THE FEDERAL EMERGENCY MANAGE.1 E*T AGENCY AND ThE
        ENVIROfMENTAL PROTECTION \CE\CY FOR THE IMPLEMENTATION OF CEPCLA
  RELOCATION ACTIVITIES UNDER PL 96-510, THE OOIPREHEN3IVE ENVIRON 1ENTAL RESPONSE,
                    COMPENSATION, AND LLa3ILITY ACT OF 1980


1.  PURPOSE

     This memorandum of understanding (MCU)  between the United States Environmental

Protection Agency (EPA) and the Federal Emerqency Management Agency (FEMA)

describes -na^or responsibilities and outlines areas of mutual support and

cooperation relating to relocation activities associated with response actions

pursuant to the Comprehensive Environmental Response, Compensation, and Liability

Act of 1980 (CERCLA);  Executive Order (E.O.)  12316; and the National Oil and

Hazardous Substance Pollution Contingency Plan (NCP), 40 CFR Part 300.

     Separate interarjency agreements (IftGs)  between EPA and FEMA will be

developed to address both general and specific relocation activities.  Such

lAGs will be in conformance with the general policies, roles and responsi-

bilities of each aaency.


2.  AUTHORITY

     CERCLA provides a comprehensive framework for response to the release

or potential release of hazardous substances, pollutants, or contaminants

which may present an imminent and substantial danger to the public health or

welfare.

      Executive Order 12316 delegates to the Director of FEMA the functions

vested in the President oy CERCLA section 104(a) to the extent they require

Teinanent relocation of residents, businesses, and community facilities, or

temporary evacuation and housing of threatened individuals not otherwise provided

for.  Executive Order 12316 also delegated to FEMA the functions vested  in the

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                                      -2-



President by CFRCIA Section 1&H2*)  to the extpnt the Act rerruirss  a 1f»ter->nat



by the President that temporary or pemanent relocation  should be undertaken



as part of a remedial action.  By agreement between ^PA  and  FFMA, dated



Aucust 12, 1983, FEMA has redeleqated to EPA this authoritv  to make determinations



on temporary or permanent relocation as nart of a remedial action.   Similarly,



by agreement between EPA and FEMA dated July 13, 19P4, FEMA  re^elegated  to



E°A its authority to determine the need for temporary evacuation or housinn



as part of any removal action.



     The NCP, in 40 CFR 300.33(b), provides that the On-Scene-Coordinator



(OSC)/Remedial Project Manager (RPM) directs all Federal Fund-financed response



efforts and coordinates all other Federal efforts at the scene of a discharge



or release, subject to E. 0. 12316.  As stated above, E. O.  12316 delegates
                                                                 •


to the Director of FE"A the temporary and permanent relocation function,



thus FEMA directs relocation activities.  Section 300.33(b)(6) of the NCP



reguires the OSC/RPM to notifv FFMA of situations which  may  reguire evacuation



or temporary or permanent relocation.  The OSC/RPM must  also evaluate incoming



information and irmediately advise FEMA of potential major disaster situations



under the Hisaster Relief Act of 1974 (P.L. 93-283).



     Executive Order 12148 delegates to FEMA the President's authority to



provide assistance under the Disaster Relief Act.  TMA designates the Federal



Coordinating Officer to manage response to a maior disaster or emergency.  In



such an event, the OSC/RPM coordinates response activities with  the Federal



r->on1inatim Officer.  However, the OSC/RPM will still direct all Fund-financec'



response efforts, subject to E. 0. 12316.

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                                      -3-

3.  AGENCY RESPONSIBILITIES

3.1  EPA Responsibilities
     «T>A shall:

     0 Prepare all necessary environmental clearances  includim  appronriate
       docunentation to ccmply with the National  Environmental Policy  ~ct  for
       relocation actions.

     0 Consult and coordinate with FEMA, as soon  as  possible (preferably 3D
       days in advance), when relocation is identified  as  an option  at a ^te.
       See Attachments A and H for a sequence of  events for permanent  and  tm-
       porary relocations.

     0 Determine in »/ritinq  the need for temporary relocation as part  of a
       removal,  as ^ell as a temporary or permanent  relocation as part of  a
       remedial  response. In makina such determinations,  EPA will consult with
       the Centers for Disease Control (CDC)  and  appropriate State aqencies
       regarding potential health risks which may affect the need for  relocation.
       FPA will  indicafe the relocation boundaries and  whether there is- a  need
       for FEMA to provide site security (temporary  relocation only) and/or  pay
       for decontamination or acquisition of personal property.

     0 Provide for site-security for vacant hones at sites where FEMA  has  not
       been reouest-?«1 to provide site security.

     0 Dispose of all cortaninat?-i personal prooertv Acquired bv FEMA.
     0  Consult  with F'vMA on State commitments.   FPA will  not select  permanent
       relocation as the cost-effective remedy until rhe  State has provided  EPA
       with  written concurrence on the permanent relocation ootion and an
       acknowledcement of its responsibilities and commitments.  E°& will  make
       no public announcements concerninq permanent relocation determinations
       until FEMA and the affected State have reached aqreenent in writina
       concerninq respective roles and overall nroject manaaement.  FFMA will
       provide  FPA with written concurrence on the permanent relocation option
       or advise EPA of any constraints reqardinq implementation of  the reloca-
       tion.

     0  Provide  non site-specific f undine to FFJ'A for tasks appjyim  qenerally
       to CERCLA relocation activities (See section 7.1).

     0  Provide  site-specific fundinq to FFT'A when relocation is selected as  a
       removal  or remedial option and will become part or all of a cleanup
       action.   Mechanisms for prowling site-specific fundinq are covered in
       ^ecMon  7.2 of this aareement.  EPA will make no public announcement
       concerninq permanent relocation determinations until the EPA/ FEMA site-
       specific interaqency aqreement is sianed.

     8  Assure that both EPA Headquarters and Reqional Offices follow the sequence
       of events for EPA/FEMA coordination for both temporary and permanent
       relocations as provided in Attachments A and R.

     0  Take  lead responsibility for developinq and implementinq a community
       relations plan for response action, as specified in the "Superfund Com-
       munity Relations Policy" and "Community Relations  in Superfund, A Handbook".
       EPA will consult and involve FFJMA in developinq and disseminatinq infor-

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                                       -4-
       mation related to the relocation as  part of  the ccmunitv  relations  olar.
     0 Cooperate and coordinate with FEMA  in  all efforts  relitim  to
       action taken anainst notentiallv rssnonsiolp  parties  For  njunctws  relief
       and cost recovery, including c.ise initiation  and prosecution and  necc—
       tiation of settlements for any site for whicn there had been a  te-nnorarv
       and/or permanent relocation.  This  shall  include coordination  in  development
       and use of evidence and witnesses relafinq  to property aopraisals, title
       searches, property purchase neqotiations, closinq  documentation,  resident
       novinq procedures and expenses, and resident  relocation allowances and
       procedures.

     0 Provide FEMA with written notice of the verified amount of  State  credit,
       if FEMA notifies EP\ that a State is claiminq a credit under CERCLA  Section
       104(c)(3)(c), to be apolied toward  site-specif ic relocation activity.
       When PFMA notifies FP^ in vntirrj of the  amount of credit to be apolied
       toward the FEMA/State cost share agreement, EPA will  track  total  State
       credits applied to the site to ensure  application  of  credits is properly
       documented.  (For an explanation of claimed vs. verified  State  credits,
       see "State Participation in the Superfund Remedial Proqram" under Prepa-
       ration and Review of State Credit Submissions, II-4 and II-5.)

     0 Provide information uoon request to FEMA  on statutory credits  available
       at sites.

3.2  FFMA Responsibilities

     In the course of CEPCLA response actions, FEMA  .3  responsible for the  per-

     manent relocation of residents, businesses, and cTmjnity  facilities and/or
         ,   •> •       f
     tem[X)rary evacuation and housina of threatened  individuals.  FEMA shall:

     0 Provide technical assistance to the OSC/RPM to support a  determination
       of need for relocation, e.o., estimatina  the  costs for relocation.

     0 Establish policy, plans and other orenaredness activities reouired
       to support relocation activities.

     0 Imolenent temporary relocation, includina nenotiation of  leases an1  rent
       reimbursements and provision of essential utilitv  costs  at  the onoinal
       residence and other miscellaneous relocation  expenses.

     0 Imnlenent permanent relocation in accordance  with  P.L.  91-646, "Unifor"
       Relocation Assistance and Real Pronerty Acouisition  Policies ^ct of 1970".

     0 Provide site security at sites involved with  temporary relocation
       only, when requested by EPA.

     0 Pay individuals for decontamination of household items and/or acquisition
       of contaminate^ personal property,  when requested  by FPA.

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                                 -5-
8 Support EPA in develooinq ami carrying out cormunitv relations with
  rogard to relocation activity.

0 Coordinate with States to ensure anprooriate involvement in relocation
  actions, inclu'lina necotiation of contracts and cooperative agreements.
  Critical issues which must be resolv<=>d in writinq prior to FPVs selection
  of permanent relocation as the cost-effective remedy include:

  (a) identification of State, and if required, Federal condemnation
      authorities for public health reasons.  This would include corrutnents
      to condemn property as required durinq the proiect;

  (b) identification of the state agency which would take title  and written
      commitments to take title at the time of closing, to all real
      property acquired.

  (c) identification of the lead for acquisition - FEMA or State; and,

  (d) obtaininq cotmutnents for the State cost share.
  Once agreement has been reached on these issues, FEMA will provide EPA with
  written concurrence on the permanent relocation option.  If agreement has
  not been reached on any of these issues, FEMA will advise EPA of any
  constraints reqardina implementation of the relocation.

  Failure to reach ^areenent on any one of thes-3 issues may mean that a
  relocation cannot bp conducted and other alternatives to permanent
  relocation must be considered.

9 Cooperate and coordinate with EP^ in all efforts relating to any judicial
  action taken against ootentiallv responsiole parties for imunctive
  relief and cost recovery, including case initiation and prosecution and
  neootiation of settlements relative to any site for which there had been a
  temporary and/or permanent relocation.  THIS shall include coordination
  in development and use of evidence and witnesses relating to property
  appraisals/ title searches, property purchase negotiations, closinn
  documentation, resident moving procedures and expenses, and resident
  relocation allowances and procedures.  To the fullest extent of its
  ability* FEMA shall provide advance notice of property purchase negotia-
  tions and closing in its monthly reports to FPA.
0 Request written notification from FPA of the amount of verified credit,
  if a State notifies FF>IA of its intention to claim a credit under CFRCLA
  Section 104 (c)(3)(c), and apply it toward relocation activity.  FEMA
  will then confirm to FPA in writim the amount of credit to be applied
  to the FEMA/State agreement.  (For an explanation of claimed vs. verified
  State credits, see "State Participation in The Suoerfund Remedial nrogram"
  under Preparation and Peview of State Credit Submissions, IT-4 and II-5).»

0 Assure that both FFMA Headquarters and Regional Offices will follow
  the seguence of events for FPVFEVA coordination for both temporary and
  permanent relocation as provided in Attachments A and R.

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                                      -6-


4.  COORDINATION ON SITE-SPFCIFTC ISSUES

4.1 Tannorary Relocation

    Temporary relocation as nart of a renoval action or remedial action -ay be

consilered by P;P^ in cases such as the following:
     0 Due to health hazards inherent at the site.  Such hazards nay involve
       an emergency such as an unninent threat of fire or explosion, or they
       nay involve a threat to public health resulting from exposure to hazardous
       substances.

     0 While specific clean-up actions are underway, to protect the population
       at or near the site from hazards that may be created by the disturbance
       resulting from such cleanup actions (e.g., air-borne contaminants or
       danger of explosions or fire).

     See Attachment \ for a sample sequence of events for EPA/FEMA coordination

durinq a tennorary relocation.

•J.2  Permanent Relocation

     Pemanent relocation of residents, businesses, and community facilities

nay be provided where it is determined that, alone or in combination with other

ne=v3jres, such relocation is more cost-effective than and environmentally

r>ref<=»rahlt» to the transportation, storage, treatnent, obstruction, or secure

•"ispositnn offsite of hazardous substances, or may otherwise he necessary to

protect the public health or welfare.

     See \tt=*chment 3 for a sanple sequence of events for FPVFEMA coordination

•Jurng a permanent relocation.

5.  STATE IMPLEMENTATION OF RELOCATION ACTIVITIFS

     FEJfV will consult with the state concernina its wijlinnnpss and capability

fo •yjminisi-er te»nnorarv and permanent relocation activities.  :«)hen  FFMA and  the

ctate aqree that the state will administer all or part of the relocation activity

at a site, FEMA will provide fundirrj to the State for allowable costs, and

obtain cost share connitnents, as appropriate.  The OSC/RPM will continue to

consult with the FEMA Proiect Officer on all relocation matters unless the FEMA

Project Officer identifies a State contact for certain  issues.

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6. INFLATION DISSE.MI»!ATIrN



      Depending on  the  tyoe of  "-esponse  action,  = 11 oi.hlic  nror*-cv off^rial and  the  co-\ P^io-al



Public Affairs Officer or State_0fficial  ( ^hen_snecif lei  n  ^ ^tate-Coonprative



^grea^ent).   EPA  and  FEMA agree  to -^ak^  a  -joint  nu^lic announcenent wh=n relocation



activity  is determined to be necessarv.   ****\ aorees  to consjlt  in advance  with



the appropriate nublic information officer  on anv planned  public statements to



provide information about relocation.   TA  ^ill n=ike  any  statements on relocation



in consultation with FEMA.  The only exception  to this provision is in the



went of  a national disaster or emernency under the Disaster Belief Act of



1^74, when the Federal Coordinating Officer coordinates public  information



activities.



     r"i  and FET1A  also recoanize  the need for coordination in  all  Congressional



=)ctiv'ities.  This  includes noti^vinq and  coordinatina nth each other's Office



of Congressional Liaison  orior t-o Conoressional contacts  concerning sit3s



      relocation activity is involved and concprnirrj  legislative issues of



       interest.



            MEfHAN'T^S, REPORTING AMD nOCLW^TATION



7.1  Non-gife Specific Interaoencv Anreerents



     FP4  and FEMA  Headouarters Offices  will •'evelon  an Irte'-aqencv Vjreeraent



TV1) to  provide fundinq  to FEMA  for tasks  applyinq qen?rallv to TEPCLA



••lUxrrition activities, such as traini1^ of  "F^A personnel involved in rel<>-



c^«-i -ns and de«/elorr^nt of guidance on  relocation activities.   In limited



circumstances, this type  IAG mav  also  be used  to fund site-specific activities



occurring before a remedy or removal  is selected, such as assistance ;n plan-
                                                                                  «•


ninq  for  a relocation  or  preparing a  relocation option.  Such expenditures



shall be  tracked on a  site-specific basis.

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                                      -a-
7.2  site-Specif ic Int-en^ercy

     Temporary and permanent relocation actions -/ill ~>o fundeH throuah seoarate

site-specific interaqency aireenents netween ^Pi and FrM\.   T^se irteraa^nc /

a^re-r-epts shall reflect f^-Vs estimated amount of expenditures for relocation

activities.  Site-specific HGs may also include assistance to r=\ in olanninq

for a relocation or oreoarinq a relocation ootion before a remedy or removal  is

selected.  For lAGs coverina remedial relocation activities, there shall he

separate obligations under each IAG for planninq and innlenentation tasks to

clarify state cost-share requirements.

7.3  Financial ^anaae^ent and Peportino Requirements

     As manaqer of the "azardous Substance Rcsoonse Trust Fund, EPA is required

by statute or reoulation to follow certain accountinq and renortinq orocedures.

Sore of these oroced-ires are unicue to the Trust ^nd.  FET1A aarees to assist

    ccrplv with the followinn:
    0 FF"\ will nrcvi'-'e F^A with inforration, as sr>p~.cied !^/ EP^, to prepare
      annual operating ol^ns, includinq esti-nated obi -3tions bv object class.

    0 FPA will orcnotly infom FFJ^IA of anv annlicabl«> ceilinqs on oblioations
      for adninistrative ^exnenses and/or travel, ana F'-MA will comply with them.
    0
      \s the Acjencv receivina the transfer allocations, FEVA will submit the
      Peoort on Budnet Fxecution "tandard ^onr 133 (SF-133) to EPA wifnn
      fifteen calendar days after the close oe each calendar month.  The SF-133
      •nust reflect total obliqational authority available.

      FFTW will preoare a quarterly Standard Form 2?5  (-5F-225), "Report on
      nbliqations," which reflects obligations, to date, by object class.  This
      reoort, which is required by the Deoartment of the Treasury Fiscal Require-
      ments Manual Sub-section 4440. 30h,  indicates that the transfer allocation
      recipient is responsible ^or its nreoaration.
    0 FF'A will prenarc? an annual Treasury  Financial Statement  "?108
      vear-end closinq statement in accordance with Department  of Treasury
      requlations.

    0 OMB - Circular A-87  is aoolicable  to  any cooperative  aqreernent  issued  bv
      FSMA.

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                                       -9-

     0  The SF-133,  SF-225,  a^d  TFS-2103 r^norts  s^jlj  -v  se^t  "o:
                  Marty Foqarty (=r
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                                      -10-

This snail include coordination in dev3  the  statf> shall

    e to also naintain the aoove accounts and documentation.

     For cost recovery actions, within  thre«* weeks from  the  -late of a request, fron

EPA or the Department of Justice (HOJ),  FE"A will provide  to EPA or DOJ site-

specific costs and copies of  the hack-up documentation which supports those

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                                      -11-
costs.  This cost infornatior and docinentsticn nust also ^e available

audit or verification on reouest of the Inspector "General.

     As original docurents nay be reoueste-j for cost recovery }ctions, FEMi

will provide access to the original docunentation when rsaueste-l.  FFMA will

not if/ EPA in advance of placing anv proiect files in storage or archives.


8.  Amendments

     This agreement nay be amended at anv tr^e hv ^utual agreenent of F?* and

FP'SI.  Amendments will lie in writinc, and will he signed by anorooriate FEMA

and EPA officials.

Q.  Period of Agreement
    This agreement will continue  in effect for a period 4 years, subject to

           law.  This agreenent «ay •» t^rmnatexl UTOP notification by either

    or F^!A to tne other -^art/.   A ninirun of ninety   iys advance written

notice of termination is reguired.

10.  Effective Date
         ,                      ^          '      '
    This agreenent will becorie effective upon signature of both narties.
                                                      MX.
     Samuel W. Speck
     Associate Director
     State and Local Programs
       and Support
     VT. McGraw
Xtftino Assistant Administrator
Office of Solid waste
  and Emergency Resoonse
    Hate:
Date:

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                                                              Attachment
                     SEQUENCE OF EVENTS REQUIRING
                    COORDINATION FOR SITE-SPFCIFIC ACTIVITY

                              Temporary Relccaticn


I.  Preliminary Planning

    A.  EPA Regional Office:

        1.  At the earliest possible time,  notifies FEMA  Peaional office of sites
            which are populated and advises of  any notential  for relocation activity
            at the site.

        2.  Keeps FEMA Reqional Office informed of developino plans  for clean-un
            in order to allow FEMA to assess the impact on  any potential relocation
            activity.

    B.  FEMA Reqional Officet

            If appropriate, conducts a qeneral  assessment of  housim resources  in
            areas identified as havina potential for relocation activity.

II. Pre-Site-Snecific Determination

    A.  EPA Regional Office;

        1.  Provides to FEMA Reqional Office:

            a.  Specific listinq of each property where there is potential  that
                residents need to be relocated  or a leqal description of. the
                relocation boundaries.

            b.  Information regardinq potential contamination of personal property
                and requests for FEMA to acquire or provide payment  for decon-
                tamination.

            c.  An indication of need for FEMA  to provide site security.

            d.  An estimate:! timeframe for relocation.

        2.  Consults FEMA Reqional Office re: Activities  outlined  in the Community
            Relations °lan.  (e.q. conment neriods, public  meetings, fact sheets,
            small workshops, etc.)

        3.  When necessary, requests FEMA to orovide cost estimate necessary to
            make a determination of need, or any other technical  assistance.

        4.  Prepares all necessary environmental clearances including appropriate
            documentation to comply with the National Environmental  Policy  Act
            for relocation actions.

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                                      -2-

    B.  FEMA Regional Off ice;.

        1.  Develops cost-estimate For potential  relocation action.
        2.  Provides technical assistance to EP^,  as  reouired  (includino
            cost-estimate).
        3.  Participates in  implementation of Community Relations plan, e.q.,
            reviews fact sheets,  press releases and attends public meetinqs
            relating to relocation issues.
        4.  Coordinates with State regardinq State's  willingness to  administer
            relocation activity.


III. Determination of Need for Relocation

    A.  EP& Regional Office;

        1.  Prepares and provides to FEMA Regional Office in writing determination
            of need including CDC advisory or other statement of conditions  at the
            site, approximate duration of relocation, specific listing" of properties
            affected by the  relocation activity and when applicable, requests for
            FEMA to provide  sits security or assistance involving contaminated
            nersonal property.  (Any of the above may be referenced  if there were
            no changes since pre-determination information).

        2.  Prepares (utilizing budget information from FEMA, updated as  necessary
            from Section II, B.2) and provides to FF*A Regional Office four
            signed original  Interagency Agreements.

    B.  PEMA. Regional Office;

            Returns three fully executed Interagency aigre<*nents to EPA along with
            budget and outlay schedule.

    c.  FEMA Headquarters, Office of the Comptroller

            Provides budget and outlay schedule to EPA Comptroller who provides
            transfer allocation to FEMA.

    D.  FEMA Regional Office;

        1.  Notifies EPA orior to contacting the relocatees and encourages
            EPA support and involvement as appropriate.  Notifies affected
            relocatees (public announcements made -jointly with  EPA).
        2.  Provides assistance to eligible relocatees.

IV.  Ongoing


    A.  EPA Regional Office;

            Coordinates with FFMA concerning testina and clean-up plan and
            activities to assess the  impact on relocation  activities  as  well
            as any community relations activites  to be  conducted during  this
            time.

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                                      -3-
    B.  FEMA Regional Office;

        1.  Submits Interaqency Agreement reoorts to EPA "eaional Office on  a
            monthly basis.

        2.  Provides to EPA Regional Office intonation necessary to sunnort
            cost recovery efforts and community relations activities.

(Mote.  FEMA's Office of Comptroller also submits financial reports  to  FPVs
Office of Cc^ptroller).
V.  Close-Out

    A.  EPA Regional Office;

            At the earliest possible tine, notifies FEMA Reqional Office of
            date on which site may be reoccupied.

    3.  FEMA Reqional Office;

        1.   Terminates tenoorary relocation assistance.
        2.   'totifles EPA of Interaaency agreement  completion,  when final bills
            are paid.

    C.   rPA Regional office;

            If necessar
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                                                            Attachment Q


               SEQUENCE OF EVENTS PEOCTIRIMG FPVFEMA COORDINATION
                           FOR SITE-SPECIFIC ACTIVITY

Note,  then permanent relocation activity is involved,  all  FEMA responsibilities/
contacts are assumed hv FEMA Headquarters.

                              Permanent Relocation

I.  Preliminary Planning

    A.  FPA Regional Office;

        1.   At the earliest possible tune,  notifies FEMA Headquarters of sites
            which have potential for permanent relocation activity.

        2.   Keeps FEMA Headquarters informed of developing  plans  for clean-up
            in order to allow FEMA to assess the impact on  any permanent potential
            relocation activity.

    B.  FEMA Headquarters;

        1.   develops appropriate plans, contracts, etc.

        ">..   Provides technical assistance to EPA, as requested.


II.   pre-Site-qpecific Determination

    A.  EPA Regional Office;

        1.   Provides to FEMA Headquarters:

            .a.  Specific listinq of each property to be potentially acquired or
                a leqal description of relocation boundaries.

            V3.  *n assessment which details the conditions  at the site  which
                necessitate a permanent relocation program.

            c.  An indication regarding whether personal property is contaminated
                and requests for FEMA to acquire or provide payment for decon-
                tamination.

            d.  An indication of whether or not temporary relocation will also
                be determined necessary.

        2.   Reruesfs FEMA to provide cost estimate for potential permanent re-
            location, or other technical assistance.

        3.   Prepares all necessary environmental clearances including appropriate
            documentation to comely with the National Fnvironmental Policy Act   .
            for relocation actions.

        4.   Consults FEMA Headquarters re;  Implementation of Comrnunity Relations
         -   Plan activities (e.g. cement neriofl, public meetings,  fact sheets,
            small workshops.)

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                                      -2-

    B.  FEMA Headquarters;

        1.  Develops cost-estimate.

        2.  Provides technical  assistance  to  EPA Reqion, as required (includinq
            cost estimate).

        3.  Participates in  implementation of Community Relations plan e.q.
            reviews fact sheets/  press releases, attends nublic meetings
            related to relocations.

        4.  Coordinates with State reqardina  State's willinqness to adminsiter
            relocation.


III. Determination of Meed for  Relocation

    A.  EPA Regional Office;

        1.  Prepares and provides to FEMA  Headquarters  in  writing a determination
            of  need for permanent relocation  and temporary relocation, as
            appropriate, includinn CDC advisory or other assessment which
            details the conditions at the  site, legal description of site
            boundaries or snecific listinq of each property to be acquired, and
            a determination  reqardinq personal  property.   (Any of the  above may
            be  referenced,  if the pre-determination has not changed).

        2.  Prepares (utilizing budget information from FEMA,  updated  as
            necessary from Section IT, B.2) and provides to FEMA Headquarters,
            four siqne'l original  Tnteraqencv  Agreement.

    3.  FFMA Headquarters:
            Returns three fully executed Interaqency Agreements to EPA along with
            budget and outlay schedule.

    C.  FEMA Headquarters, Office of the Comptroller

            Provides budget and outlay schedule to EPA Comptroller who provides
            transfer allocation to FEMA.

    D.  FEMA Headquarters;

        1.  Notifies EPA prior to contacting the relocatees and encourage
            EPA supnort and involvement as appropriate.  Notifies affected
            relocatees (Public announcement is made lointly with EPA).

        2.  Provides assistance to eligible relocatees.

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                                       -3-

 IV.  Ongoing

     A.  EPA Regional Offic°;

            Coordinates with FEMA Headquarters concerninq testing and clean-uo
            plan and activities to assess the impact or relocation activities  as
            well as any community relations activities to he conducted during  this
            time.

     B.  FEMA Headquarters

        1.  Submits Interagencv Agreement reports to EPA Peqional Office on a
            monthly basis.

        2.  Provides to EPA Regional Office information necessary to support
            cost recovery efforts and cormunity relation activities.

(Note.  FEMA's Office of Comptroller also submits financial reports to EPA's
Office of Comptroller).


V.  Close-Out

    A.  FEMA Headquarters

            Notifies EPA Reqional Office of Interagencv Agreement completion,
            when final hills are paid.

    R.  EPA Regional Office

            If necessary to adiust dollar amount of Interaqencv Agreement
            forwards amendment to FEMA Headquarters.

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