vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9295.5-02
TITLE: IMPLEMENTATION OF EPA/FEMA* MOU ON CERCLA
RELOCATIONS
APPROVAL DATE: 06/14/85
EFFECTIVE DATE: 06/14/85
ORIGINATING OFFICE: <*«« of Solid Waste
0 FINAL
D DRAFT
STATUS:
] A- Pending OMB approval
j B- Pending AA-OSWER approval
] C- For review &/or comment
] D- .In development or circulating
headquarters
REFERENCE (other documents):
OSWER OSWER OSWER
fE DIRECTIVE DIRECTIVE
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03/19/87 United States Environmental Protection Agency
Washington, D.C. 20460
EPA OSWER Directive Initiation Request
2. Originator Information
Name of Contact Person Mil Code Office
BROWN OERR/OPM
1. Directive Number
9295.5-02
Telephone Number
475-8102
3. Title
IMPLEMENTATION OF EPA/FEMX MOU ON CERCLA RELOCATIONS
4. Summary of Directive (Include brief statement of purpose)
Forwards EPA/FEMA MOU on CERCLA Relocations (see
directive 9295.5-01) to Regional Administrators.
Provides guidance in establishing
Regional/Headquarter s/FEMA relocation contacts and
on following standards established in the MOU.
(6/85, 12 pp)
5. Keywords
SUPERFUND, CERCLA, RESPONSE ACTIONS, INTERAGENCY AGREEMENT
Sa. Does this Directive Supercede Previous Directives)?] | yes [ Xj No What directive (number, title)
b.T)oes It Supplement Previous Directives^)? I I yes 1 X| NO What directive (number, title)
' t *
i '"••'•
7. Draft Level
1 j A- Signed by AM) AA |~"~"| B - Signed by Office Director 1 1 C-FbrReviewa
TUfa DAMIIA** IA*Ata rtOfAJCCt nfrmfthtmm ^ttmtmm F ••••»•!
THIS Request Meets oswen wrectives system rormat
8. Signature of Lead Office Directives Coordinator
i
9. Nam* and THIS of Approving Official
J. MCGRAW
t Comment I In Development
,
Date
Date
06/14/85
OSWER
OSWER
OSWER
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C 20460
JMW I A JQOt; OFFICE OF
wii Wt/ SOLID WASTE AND EMERGENCY RESPONSE
, OSWER Directive 9295.5-02
,-•
MEMORANDUM
SUBJECT: implementation of EPA/FEMA MOU on CERCLA Relocations
FROM:
cting Assistant Administrator
'
TO: Regional Administrators
Attached Is a copy of the signed Memorandum of Understanding
(MOU) between the Federal Emergency Management Agency (FEMA) and
EPA covering major responsibilities and coordination on CERCLA
relocation activities. The signed MOU incorporates comments made
by Headquarters and Regional Offic.es of both agencies on the
draft MOU distributed in February. All comments received have
been addressed in the KOU or responded to individually.
Background
Executive Order (E.O.) 12316 delegates to the Director of
FEMA the functions vested in the President by CERCLA Section 104(a),
the authority to carry out temporary and permanent relocation
activities. FEMA redelegated to EPA on August 12, 1983 the authority
to make determinations on temporary or permanent relocation as part
of a remedial action. FEMA also redelegated to EPA on July 13, 1984
its authority to determine the need for temporary evacuation or
housing as part of a removal action.
Thus while EPA now makes the determination that relocation
actions are needed (usually after consultation with other agencies
such as the Centers for Disease Control), FEMA retains the authority
to actually conduct the relocation (or make arrangements for
States to conduct the relocation). This MOU is designed to provide
the policy framework for EPA/FEMA coordination on CERCLA relocation
actions. Site specific Interagency Agreements must be developed
for FEMA to carry out relocation actions.
EPA Regional Implementation Actions
Now that we have completed MOU negotiations with FEMA,
we are ready to move to implement the agreement. Several Immediate
action steps are required for EPA Regional offices:
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OSWER Directive 9295.5-02
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0 As part of our relationship with FEMA, EPA Regional
Offices should assure that the sequence of events stipu-
lated in attachments A and B of the MOU is followed and
closely coordinated to ensure the overall objectives are
accomplished effectively. Each Region should decide how
to proceed with the sequence of events and clearly establish
a point of contact (with a backup) within each agency to
facilitate better coordination and communication on
relocation issues. For example:
- Information on planned site action and any knowledge of
possible removal actions where a temporary relocation may
be necessary.
- Implementation of Communty Relation Activities Plan
(e.g. comment period, public meetings, fact sheets,
small work shops, etc.)
- Testing and clean-up plan and activities to assess the
impact on relocation activities.
Accordingly, we request that each Region establish a point
of contact and so notify the FEMA Regional Office program
that handles relocation Issues (The need for an established
point of contact within each Regional Office was farther
emphasized at a meeting recently held between SPA Head-
quarters and FEMA Headquarters and Regional personnel).
Furthermore, OSCs and RPMs should inform the EPA designated
point of contact as soon as either temporary or permanent
relocation is identified as a possibility at a site. I
also suggest that you review your planned remedial actions
with FEMA at least annually, perhaps more often. This will
enable them to have a full understanding of your workplan
and to determine the extent of Impact it may have on them.
0 Similarly, Regional Offices should contact FEMA
Headquarters when permanent relocation is determined
to be necessary. The point of contact at FEMA Head-
quarters for permanent relocation activities is:
Mr. Charles Robinson or Ms. Kathy Brody
PEMA PEMA
500 C Street, SW 500 C Street, SW
Room 701 Room 701
Washington, DC 20H72 Washington, DC 20472
FTS-646-4262 FTS-646-380H
0 All EPA Regional Offices should prepare a standby Inter-
agency Agreement (IAG) for emergency situations that may
require a temporary relocation. This IAG should be completed
as thoroughly as possible, leaving site-specific Information
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OSWER Directive 9295.5-02
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(site name, dollar amount, etc.) and approval signature to
be completed at the time a relocation determination is
made. This procedure would assist in avoidina delays
durino an emeroency where temporary relocation is determined
necessary. A revised sample IAG developed by Headauarters
is attached to assist Regions in preparing a standby IAG.
This was the mechanism Headauarters used for such emergency
situations prior to the delegation of this authority to the
Regions last fall.
As we proceed with the implementation of the MOU, the need
for additional guidance may be indicated. We may also find that
sections of the MOU reguire revision or updating. Please keep us
informed of such issue areas as they develop.
Thank you for your cooperation and assistance in the
development of the FPA/FFMA MOU. If you have any guestions
regarding implementation of this MOU, please contact James Makris
(475-8600) or David Speights (382-4*92) of the Hazardous Response
Support Division, OERR.
cc: Assistant Administrators
Associate Administrators
General Counsel -
Inspector General
Steve Lingle
Russ Wyer
Tim Fields
Bruce Engelbert
Regional Waste Management Division Directors
Superfund Community Relations Coordinators
Environmental Services Division Directors (Regions I, VI, VII
and VIII)
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OSWER Directive 9295.5-01
MEMORANDUM OF UNDERSTANDING
THE FEDERAL EMERGENCY MANAGEMENT AGENCY AND THE
ENVIRONMENTAL PROTECTION ACENCY FOR THE IMPLEMENTATION OF CEPCLA
RELOCATION ACTIVITIES UNDER PL 96-510, THE CO'IPREHENSIVE ENVIRONMENTAL RESPONSE,
COMPENSATION, AND LLASILITY ACT OF 1980
1. PURPOSE
This memorandum of understanding (MCU) between the United States Environnental
Protection Agency (EPA) and the Federal Emergency Management Agency (FEMA)
describes major 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 interagency agreements (LAGs) between EPA and FEMA will be
developed to address both general and specific relocation activities. Such
lAGs will be in conformance with the aeneral 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 unminent and substantial danger to the public health or
welfare.
Executive Order 12316 delegates to the Director of FEMA the functions
vested in the President by CERCLA section 104(a) to the extent they require
pernanent relocation of residents, businesses, and community facilities, or
terroorary 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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X
President by CFRCLA Section 101(24) to the extent the Act requires a detemination
by the President that temporary or permanent relocation should be undertaken
as part of a remedial action. By agreement between EPA and FFMA, dated
August 12, 1983, FEMA has redeleqated to EPA this authority to make determinations
on temporary or permanent relocation as part of a remedial action. Similarly,
by agreement between EPA and FEMA dated July 13, 1984, FEMA redelegated to
EPA 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. 0. 12316 delegates
to the Director of FE71A 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 situatioas which may require evacuation
or temporary or permanent relocation. The OSC/RPM must also evaluate incoming
information and immediately advise FEMA of potential major disaster situations
under the Disaster Relief Act of 1974 (P.L. 93-288).
Executive Order 12148 deleaates to FEMA the President's authority to
provide assistance under the Disaster Relief Act. FEMA designates the Federal
Coord mating Officer to manage response to a maior disaster or emergency. In
such an event, the OSC/RPM coordinates response activities with the Federal
Coordinating Officer. However, the OSC/RPM will still direct all Fund-financed
response efforts, subject to E. 0. 12316.
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3. AGENCY RESPONSIBILITIFS
3.1 EPA Responsibilities
EPA shall:
0 Prepare all necessary environmental clearances includinq aporooriate
docunentation to conply with the National Environmental Policv Act for
relocation actions.
0 Consult and coordinate with FEMA, as soon as possible (preferably 30
days in advance), when relocation is identified as an option at a site.
See Attachments A and B for a sequence of events for permanent and tm-
porary relocations.
0 Determine in writing the need for temporary relocation as part of a
removal, as well as a tenporary 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 agencies
regarding potential health risks which may affect the need for relocation.
EPA will indicate 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 requested to provide site security.
0 Dispose of all contaminated oersonal property acquired bv FEMA.
0 Consult with FFMA on State commitments. F,PA will not select permanent
relocation as the cost-effective remedy until the State has provided EP
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mation related to the relocation as part of the ccmmunitv relations plan.
0 Cooperate and coordinate with FEMA in all efforts relating to anv -judicial
action taken against ootentially responsible parties for in]unctive relief
and cost recovery, including case initiation and prosecution and neqo-
tiation of settlements for any site for which there had been a temnorarv
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, closing documentation, resident
moving 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 EPA that a State is claiming a credit under CERCIA Section
104(c)(3)(c), to be applied toward site-specific relocation activity.
When FEMA notifies EPA in writing of the amount of credit to be applied
toward the FEMA/State cost share agreement, EPA will track total State
credits anplied 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 Program" under Prepa-
ration and Review of State Credit Submissions, II-4 and II-5.)
8 Provide information upon request to FEMA on statutory credits available
at sites.
3.2 FFMA Responsibilities
In the course of CEPCLA response actions, FEMA is responsible for the per-
manent relocation of residents, businesses, and crnmunity facilities and/or
temporary evacuation and housing of threatened individuals. FEMA shall:
0 Provide technical assistance to the OSC/RPM to support a determination
of need for relocation, e.g., estimating the costs for relocation.
0 Establish policy, plans and other preparedness activities required
to support relocation activities.
0 Implement temporary relocation, including negotiation of leases an1 rent
reimbursements and provision of essential utilitv costs at the orininal
residence and other miscellaneous relocation expenses.
0 Implement permanent relocation in accordance with P.L. 91-646, "Uniform
Relocation Assistance and Real Property Acquisition Policies Act of 1970".
0 Provide site securitv at sites involved with temporary relocation
only, when requested by EPA.
0 Pay individuals for decontamination of household items and/or acguisition
of contain mated personal propertv, when requested by EPA.
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0 Support EPA in developing and carrying out cormunity relations with
regard to relocation activity.
0 Coordinate with States to ensure appronnate involvement in relocation
actions, including negotiation of contracts and cooperative agreements.
Critical issues which must be resolved in writing prior to EPVs 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 cormitnents
to condemn property as required during 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) obtaining cormutments 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 regardinq implementation of the relocation.
Failure to reach agreement on any one of these issues may mean that a
relocation cannot be conducted and other alternatives to permanent
relocation must be considered.
0 Cooperate and coordinate with EPJ\ in all efforts relating to any judicial
action taken against potentially responsible parties for imunctive
relief and cost recovery, including case initiation and prosecution and
negotiation 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, closing
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 EPA.
0 Request written notification from FPA of the amount of verified credit,
if a State noMfies FEMA of its intention to claim a credit under CERCIA
Section 104 (c)(3)(c), and apply it toward relocation activity. FEMA
will then confirn to F.PA in writing 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 Superfund Remedial nroqram"
under Preparation and Review of State Credit Submissions, IT-4 and II-5).
0 Assure that both FEMA headquarters and Regional Offices will follow
the sequence of events for EPVFEMA coordination for both temporary and
permanent relocation as provided in Attachments A and B.
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4. COORDINATION ON SITE-SPFCIFTC ISSUES
4.1 Temnorary Relegation
Temporary relocation as nart of a removal action or remedial action may be
considered by EP^ in cases such as the following:
0 Due to health hazards inherent at the site. Such hazards may involve
an emergency such as an inrunent 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 fron hazards that may he created by the disturbance
resulting fron such cleanup actions (e.g., air-borne contaminants or
danger of explosions or fire).
See Attachment A for a sample sequence of events for EPA/FEMA coordination
during a temnorary relocation.
4.2 Permanent Relocation
Permanent relocation of residents, businesses, and community facilities
nay be provided where it is determined that, alone or in combination with other
measures, such relocation is more cost-effective than and environmentally
pref^rabl*3 to the transnortation, storage, treatment, dpstruction, or secure
Disposition off site of hazardous substances, or may otherwise he necessary to
protect the public health or welfare.
See *\tt=»chment 3 for a sample sequence of events for EPVFEVA coordination
•Jjring a oermanent relocation.
5. ST^TE IMPLEMENTATION OF RELOCATION ACTIVITIFS
FEflA will consult with the state concerning its wiJlinqness and caoabilitv
ro ^minister temporary and permanent relocation activities. When FFMA and the
State agree that t-he State will administer all or part of the relocation activity
at a site, FEMA will provide funding to the State for allowable costs, and
obtain cost share conmtments, 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. INFORMATION DISSEMINATION
Depending on the type of response action, ?ll nuhlic information activities
will be coordinated with the appropriate leal £cprcv official and the FP^ P^gioral
Public Affairs Officer or State Official (*>hen specifleo in a state Cooperative
Agreement). EPA and FRMA agree^to mak<» a -joint public announcement whan relocation
activity is determined to be necessary. F^'A aorees to consult in advance with
the appropriate oublic information officer on anv planned public statements to
provide information about relocation. TA will make any statements on relocation
in consultation with FEMA. The only exception to this provision is in the
event of a national disaster or emerrjency under the Disaster Relief Act of
1^74, when the Federal Coordinating Officer coordinates public information
activities.
rpA and PEMA also recognize the need for coordination in all Congressional
activities. This includes notifying and coordinating -nth each other's Office
of Congressional Liaison prior to Conrjressional contact-s concerning sitss
*/hen? relocation activity is involved and concernina leoislative issues of
Tjtual interest.
7. FHMDIMC, MECHANISMS, REPORTING AMD nOOJMFINT^ION
7.1 ^on-s^^e Specific Interagency Agreements
TPA and FEMA Headguarters offices will •'evelon an Interaqency Vjreement
to provide funding to FEMA for tasks applying generally to CEPCLA
activities, such a
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7.2 ^ite-Specific Int-eragency Agreements
Temporary and permanent relocation actions will TO funded throuqh separate
site-specific interaqency agreements netween FP^ and FEM^. Those interanency
agreements shall reflect FEMVs estmated amount of expenditures for relocation
activities. Site-specific lAGs may also include assistance to F^A in planning ~"
for a relocation or preparing a relocation option before a remedy or removal is
selected. For lAGs covering remedial relocation activities, there shall be
separate obligations under each IAG for planning and implementation tasks to
clarify state cost-share reouirements.
7.3 Financial Management and Reporting Peguirements
As manager of the Hazardous Substance Response Trust Fund, EPA is required
by statute or regulation to follow certain accounting and reporting procedures.
Sone of these procedures are unigue to the Trust Fund. FEMA agrees to assist
and ccnply with the following:
0 FFM^ will provide EPA with information, as specified bv EP\, to prepare
annual operating clans, including estimated obi nations bv object class.
0 EPA will nromotly inform FEMA of anv applicable ceilings on obligations
for administrative expenses and/or travel, and FEMA will comply with them.
0 >\s the Agency receiving the transfer allocations, FEMA will submit the
Peoort on Budget Execution standard ^orm 133 (SF-133) to EPA within
fifteen calendar days after the close of each calendar month. The SF-133
must reflect total obligational authority available.
0 FEMA will prepare a ouarterly Standard Form 225 (SF-225), "Report on
Obligations," which reflects obligations, to date, by object class. This
reoort, which is reguired by the Department of the Treasury Fiscal Reguire-
ments Manual Sub-section 4440.30b, indicates that the transfer allocation
recipient is responsible for its preparation.
0 FE"A will prepare an annual Treasury Financial Statement 2108 (TFS-210B)
year-end closing statement in accordance with Department of Treasury
regulations.
0 OMB - Circular A-87 is applicable to any cooperative agreement issued by
FEMA.
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0 The SF-133, SF-225, and TFS-2108 renorts sh^ul
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Th is snail include coordination in de/elocrent an' use of ovinance and
witnesses relating to property aporaisals, title searches, nrcnerty ourchase
negotiations, closinq documentation, resident Coving procedures and exoenses,
and resident relocation allowances and procedures. To the fal] extent of its
ability under its cooperative agreements and contracts with states and
political subdivisions thereof, FEMA shall provide advance notice of oronertv
purchase negotiations and closinqs--in-its monthly reports to EPA.
EPA, actirn as manager of The Hazardous Substance Response Trust Fund,
requires current information on CFRCLA resoonse actions and related obli-
gations of CERCLA funds for these actions. In addition, CERCLA authorizes
the United States to recover from resoonsiMe oarties all governnent cost in-
curred during a response action. For soecific TAGs, this information will be
required in order to help assure successful recovery of CEPCLA funds. Therefore,
FEKA shaJl maintain site «?pecific accounts and decline nation of the following:
0 Employee hours and salary (TLmesheets)
0 Employee travel and per diem exoenses (travel authorization, paid
vouchers, and treasury schedules)
0 Receipts for materials, eouipment, and sunplies
0 Contra^ costs (paid vouchers, treasury schedules and a cony of contract)
0 State Cooperative Aareement and contract costs (invoices, letter of
credit, drawdown records, etc.)
0 Any other costs not included in the above categories associated with
relocation
The cooperative agreement- entered into by FEMA ana the state shall renuire the
State to also maintain the above accounts and documentation.
For cost recovery actions, within three weeks from the date of a reguest. from
EPA or the Department of Justice (POJ), FE"A will provide to EPA or DOJ site-
specific costs ant? copies of the hack-up documentation which supports those
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costs. This cost infornation and documentation must also he available for
audit or verification on reguest of the Inspector General.
As original documents may be reouestei for cost recovery actions, FEMa
will provide access to the original documentation when reouested. FFMA will
notify EPA in advance of placing any proiect files in storage or archives.
8. Amendments
This agreement ^ay be amended at any ti"ie hy ^utual agreement of FPA and
FEVA. Amendments will he in writing, and will he signed by appropriate FEMA
and EPA officials.
9. Period of Agreement
This agreement will continue in effect for a period 4 years, subject to
r>policable law. This agreement "ay he terminated unon notification by either
FPA or FF>1A to the other narty. A ninirunn of ninety jys advance written
notice of termination is reguired.
10. Effective Date
This agreement will beccnie effective upon signature of both parties.
^s
<;/////-,
Samuel W. Speck
Associate Director
State and Local Programs
and Support
Jatk W. McGraw
A/tina Assistant Administrator
Office of Solid waste
and Emergency Response
Hate:
-4/C/ S5-
Date:
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Attachment A
SEQUENCE OF EVEbTTS REOUIRING
COORDINATION FOR SITE-SPECIFIC ACTIVITY
Temporary Relocation
I. Preliminary Planning
A. EPA Regional Office:
1. At the earliest possible time, notifies FEMA Reoional Office of sites
which are populated and advises of any potential for relocation activity
at the site.
2. Keeps FEMA Regional Office informed of develomm plans for clean-un
in order to allow FEMA to assess the impact on any potential relocation
activity.
B. FEMA Regional Office;
If appropriate, conducts a qeneral assessment of housinq resources in
areas identified as havina potential for relocation activity.
•
II. Pre-Site-Snecific Determination
A. EPA Reaional Office:
1. Provides to FEMA Reqional Office:
a. Specific listinq of each pronerty 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 orovide oaynent for decon-
tamination.
c. An indication of need for FEMA to provide site security.
d. An estumated tuneframe for relocation.
2. Consults FEMA Reqional Office re: Activities outlined in the Community
Relations Plan. (e.q. conrnent nenods, public meetings, fact sheets,
small workshops, etc.)
3. When necessary, requests FEMA to provide cost estimate necessary to
make a determination of need, or any other technical assistance.
4. Prepares all necessary environmental clearances includinq appropriate .
documentation to comply with the National Environmental Policy Act
for relocation actions.
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B. FEMA Regional Office;
1. Develops cost-estunate for potential relocation action.
2. Provides technical assistance to EPA, as required (includinn
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 regarding State's willingness to administer
relocation activity.
III. Determination of Need for Relocation
A. EPA 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 listinorof properties
affected by the relocation activity and when applicable, reguests for
FEMA to provide site security or assistance involving contaminated
oersonal 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
frcm Section II, B.2) and provides to FFMA Regional Office four
signed original Interaqency Agreements.
B. ^EMA Regional Office:
Returns three fully executed Interaqency Agre<=*nents to EPA along with
budget and outlay schedule.
r. FEMA Headguarters, Office of the Comptroller
Provides budget and outlay schedule to EPA Comptroller who provides
transfer allocation to FEMA.
D. FEMA Regional Office:
1. Motifies EPA prior 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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B. FEMA Regional Office;
1. Submits Interagency Agreement reoorts to EPA Reqional Office on a
monthly basis.
2. Provides to EPA Regional Office information necessary to sunnort
cost recovery efforts -and community relations activities.
(Note. FEMA's Office of Comptroller also submits financial reports to FPA's
Office of Comptroller).
V. Close-Out
A. EPA Reqional Office;
/
At the earliest possible tune, notifies FEMA Reqional Office of
date on which site may be reoccupied.
B. FEMA Regional Office;
1. Terminates temporary relocation assistance.
2. Notifies EPA of Interaaency Agreement completion, when final bills
are paid. .
C. FPA Reqional Office;
If necessary to adjust dollar amount of TAG, forwards amendment to
FEMA Reqional Office.
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Attachment Q
OF EVENTS REQUIRING EPA/FEMA COORDINATION
FOR SITE-SPECIFIC ACTIVITY
Note. JJien permanent relocation activity is involved, all FEMA responsibilities/
contacts are assumed by FEMA Headquarters.
Permanent Relocation
I. Preliminary Planning
A. FPA Regional Office;
1. At the earliest possible time, notifies FEMA Headquarters of sites
which have potential for permanent relocation activity.
2. Keeps FEJ1A Headouarters informed of developinq 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.
2. 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.
b. An assessment which details the conditions at the site which
necessitate a permanent relocation program.
c. An indication regard inq 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. Requests FEMA to provide cost estimate for potential permanent re-
location, or other technical assistance.
3. Prepares all necessary environmental clearances includinq appropriate
documentation to comply with the National Environmental Policy Act
for relocation actions.
4. Consults FEMA Headquarters re; Implementation of Comimjnity Relations
Plan activities (e.q. comnent nenor), public meetings, fact sheets,
" small workshops.)
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B. FEMA Headquarters;
1. Develops cost-estimate.
2. Provides technical assistance to EPA Region, as required (including
cost estimate).
3. Participates in implementation of Community Relations plan e.q.
reviews fact sheets, press releases, attends public meetings
related to relocations.
4. Coordinates with State regarding State's willingness to adminsiter
relocation.
III. Determination of Need 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, including CDC advisory or other assessment which
details the conditions at the site, legal description of site
boundaries or soecific listing of each property to be acguire^, and
a determination regarding personal property. (Any of the above may
be referenced, if the pre-de term mat ion has not changed).
2. Prepares (utilizing budget information from FEMA, updated as
necessary from Section IT, B.2) and provides to FEMA Headquarters,
four signed original Tnteragencv Agreements.
3. FEMA 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 supoort and involvement as appropriate. Notifies affected
relocatees (Public announcement is made lointly with EPA).
2. Provides assistance to eligible relocatees.
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IV. Ongoing
A. EP^ Regional Offic0;
Coordinates with FEMA Eteadguarters conceminq testing and clean-up
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 Interagency Agreement reports to EPA Regional Office on a
monthly basis.
2. Provides to EPA Regional Office information necessary to support
cost recovery efforts and community 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 Interagency Agreement completion,
when final bills are paid.
R. EPA Regional Office
If necessary to adnust dollar amount of Interagency /agreement
forwards amendment to FEMA Headguarters.
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