United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9360.3-111
July 1991
vvEPA
Superfund Removal
Procedures Manual Bulletin
Office of Emergency and Remedial Response
Emergency Response Division, OS-210
Intermittent Bulletin
Volume I, Number 2
This bulletin is the second in a series of intermittent bulletins on the Superfund Removal Procedures manual (SRP).
The SRP is one of the removal program's most important and widely used manuals on new and continuing activities
at removal action sites. The manual is currently being revised into a series of ten stand-alone documents on specific
topics. Further information on the background and purpose of the SRP, summaries and highlights of each of these
volumes, and a timeframe for final completion of the individual volumes are included below. Because the SRP is
so widely used throughout EPA Headquarters and the Regions, this bulletin will be published as needed to update
EPA personnel on the expected publication of each volume of the manual. This bulletin will include an explanation
of key issues or questions of general interest that may arise during the development of the revised SRP. In addition
to this bulletin, fact sheets will be available for each volume upon publication.
Background
The SRP is one of the most widely used
manuals by On-Scene Coordinators (OSCs) and other
response personnel in the Superfund program. It
provides guidance on day-to-day activities at removal
sites. Other EPA personnel such as Regional
Counsel, remedial program staff, and enforcement
personnel also depend on the SRP for information
and reference. In addition, other federal agencies,
states, contractors, and potentially responsible parties
(PRPs) all use the SRP for reference. The manual
has become one of the Office of Emergency and
Remedial Response's most requested documents.
Purpose
As a result of the widespread use of the
manual, and the recent promulgation of the National
Oil and Hazardous Substances Pollution Contingency
Plan (NCP) (55 FR 8666, March 8, 1990), the SRP is
being updated to reflect program changes; to be more
user friendly; to convey more information with charts,
graphics, and tables; and to avoid costly interim
updates.
Structure of the Manual
The SRP will consist of ten volumes of
guidance documents. Each volume of the SRP
presents a particular aspect of the removal process
and includes a volume-specific table of contents, list
of exhibits, reference list, and key word index. The
series includes the following volumes:
(1) Action Memorandum Guidance;
(2) Removal Response Reporting;
(3) Response Management: Removal Start-up
to Close-out;
(4) Removal Enforcement Guidance for On-
Scene Coordinators;
(5) Public Participation Guidance for On-Scene
Coordinators: Community Relations and
the Administrative Record;
(6) The Removal Response Decision: Site
Discovery to Response Decision;
(7) Special Circumstances;
(8) Guidance on the Consideration of ARARs
During Removal Actions;
(9) State Participation in Federal-Lead
Removals; and
(10) Overview volume that includes
comprehensive quick references.
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This bulletin will provide the purpose,
summary, and timeframe for publication of each
individual volume of the SRP. In addition, if there is
any update to the progress of a particular volume, this
bulletin will provide that update.
(1) ACTION MEMORANDUM
GUIDANCE
PURPOSE
Because the Action Memorandum is a
primary decision document for the removal program,
improving the quality of Action Memoranda is a high
priority within the Superfund program. The purpose
of this guidance is to assist an OSC in preparing a
concise, high quality Action Memorandum.
As the primary decision document
for a removal action, the Action
Memorandum must document the
need for the action based on the
NCP.
SUMMARY
The Action Memorandum Guidance volume
begins with an overview section which includes the
purpose of the Action Memorandum, the relationship
of the Action Memorandum to the administrative
record, and the roles and responsibilities of the
Action Memorandum in the Superfund removal
program. The guidance also includes a model initial
Action Memorandum, model Action Memoranda for
special circumstances, and information on Action
Memorandum supplements. This volume concludes
with information on the review and approval
procedures for Action Memoranda. A fact sheet on
this volume is available from the Superfund Removal
Procedures Series Coordinator at FTS 382-4671.
TIMEFRAME
The Action Memorandum Guidance volume
of the SRP has been published as OSWER Directive
9360.3-01. Bound copies of the document have been
distributed to the Regional offices. EPA personnel
can obtain a copy by calling (202) 475-9760. Copies
are available to the public through the National
Technical Information Service (NTIS) at (703) 487-
4650 (order # PB90-274473).
(2) REMOVAL RESPONSE
REPORTING
PURPOSE
This volume presents the removal program
policy requirements where applicable, and regulatory
requirements under section 300.165 of the NCP for
preparing and distributing Pollution Reports
(POLREPs) and OSC Reports. In addition, this
volume clarifies and emphasizes reporting criteria,
promotes quality reports, and informs preparers of
POLREPs and OSC Reports about the potential
users and uses of these reports.
SUMMARY
This volume is divided into two sections:
section I is the guidance for developing and
distributing POLREPs; and section n is the guidance
for developing and distributing OSC Reports. Section
I contains the purpose, distribution, users and uses,
information, and format requirements for POLREPs.
The section concludes with models for different types
of POLREPs and review procedures for POLREPs.
Section n contains information on the
purpose, users and uses, timeliness of preparation,
and format and information requirements for OSC
Reports. In addition, section II contains a useful
table on the users, uses, and information
requirements for the users of OSC Reports. This
section concludes with a model OSC Report and
information on report attachments, distribution, and
review procedures.
UPDATE
In order to more completely meet the needs
of OSCs, the progress of this
volume has been delayed slightly.
Specifically, a short survey was
distributed to over 150 Regional
emergency response personnel.
The results of the survey are being
compiled and this volume may be
revised as a result of our findings.
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FlMEFRAME
The Removal Response Reporting volume is
expected to begin the Headquarters review and
ipproval process soon. This volume will be published
ji late summer, 1991 as OSWER Directive 9360.3-03.
RESPONSE REPORTING TEMPLATES
To simplify writing Action Memoranda,
POLREPs, and OSC Reports, we are developing
macros and templates in WordPerfect 5.0. These
macros and templates are based on the Action
Memorandum Guidance and the
Removal Response Reporting
volumes of the SRP. To use the
templates and macros, OSCs only
need a basic familiarity with
Wordperfect 5.0.
The macros and templates were introduced
in March, 1991 at the National OSC Association
conference in Seattle and are now in use at several
sites. When the format for POLREPs is finalized, the
POLREP option will be added to the package. In
addition, ERD is offering demonstration sessions and
customized macros for any Region. To get a copy of
the macros or to make an appointment to see a
demonstration, please contact Gil Laskowski at
202/FTS 382-6943.
(3) RESPONSE MANAGEMENT:
REMOVAL START-UP TO
CLOSE-OUT
PURPOSE
This volume describes procedures for
initiating on-site activities, developing various cleanup
agreements, managing costs, documenting site
activities, performing contract oversight, and
managing health and safety. The volume describes in
detail the procedures for entering into site-specific
interagency agreements and procedures for the
management of all activities during the life of a site.
UPDATE
A questionnaire was circulated to OSCs at
the National OSC Conference in March, 1991. The
compilation of the answers is currently being reviewed
so that the guidance will reflect Regional needs
identified by the OSCs.
TlMEFRAME
The volume is expected to be published in
early 1992 as OSWER Directive 93603-04.
(4) REMOVAL ENFORCEMENT
GUIDANCE FOR ON-SCENE
COORDINATORS
PURPOSE
Because OSCs conduct or contribute to all
steps in the Superfund
enforcement process, this volume
summarizes the relevant guidance
and statutory authorities for
conducting enforcement activities
during removal actions.
SUMMARY
This volume begins with an introduction to
and overview of the Superfund enforcement process
and authorities. This first section also includes
definitions of enforcement terms that may be
unfamiliar to users of the volume. The second
section describes the various roles in the enforcement
process and the resources available to the OSC. The
roles of the OSC, Regional enforcement staff,
program management staff, Regional counsel, and
public participation staff are described in this section.
The section also includes information on the
procedures to request a criminal investigation. The
third section describes the enforcement procedures
specific to the removal program. This includes:
information on PRP searches and notification; state
notification; negotiations, settlements and orders;
oversight of enforcement-lead removals;
documentation; and public participation. The final
section of this volume includes a description of cost-
recovery procedures.
TlMEFRAME
This volume has been submitted for
concurrence and is expected to be published in late
summer, 1991 as OSWER Directive 93603-06.
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(5) PUBLIC PARTICIPATION
GUIDANCE FOR ON-SCENE
COORDINATORS:
COMMUNITY RELATIONS AND
THE ADMINISTRATIVE
RECORD
PURPOSE
This volume is intended to assist OSCs in
meeting the community relations and administrative
record requirements mandated by CERCLA and the
NCP. Because removal actions generally proceed
quickly, there is little time to plan
or conduct public participation
activities. For this reason, public
participation procedures for
removals have been designed to
ensure an appropriate level of public involvement
without causing unnecessary delay. These procedures
therefore vary depending on site-specific
circumstances.
SUMMARY
This volume begins with an overview of
public participation activities during the removal
process and continues with an approach to public
participation for OSCs. The second section describes
the required and non-required community relations
activities likely to take place during a removal action.
The third section details the requirements and
activities associated with the administrative record
during a removal action. The final section details the
roles and responsibilities of various staff in
implementing the community relations activities
during a removal action. This includes the
identification of primary and secondary resources.
This volume includes examples and charts to
aid the user in understanding the public participation
requirements. In addition, a detailed Community
Relations Plan outline is included as an appendix.
UPDATE
Final Regional and Headquarters comments
are being incorporated into the volume. It will be
submitted for concurrence in mid-summer, 1991.
TlMEFRAME
This volume is expected to be published in
late summer, 1991 as OSWER Directive 9360.3-05.
(6) THE REMOVAL RESPONSE
DECISION: SITE DISCOVERY
TO RESPONSE DECISION
PURPOSE
This volume is intended to provide
information on the relevant guidance and statutory
authorities for determining when to initiate a removal
action. The volume includes information from site
discovery to the final response decision.
SUMMARY
This volume presents information on the
response decision framework. This includes criteria
for removal actions and the scope of the response
(i.e., urgency, type of action, and limitations).
Another part of the response is the roles and
responsibilities of response teams, contractors, other
federal agencies, and state and local governments.
The final section of this volume contains the
procedures for determining whether or not a removal
action is necessary. This begins with the discovery or
notification of a release. Things to consider include:
the removal site evaluation; CERCLA 104(b)
investigations; responsible party search and
notification; coordination with other agencies;
compliance with ARARS; engineering evaluation/cost
analysis; and final determination that there is a threat
to human health or the environment. This volume
also includes a decision-making checklist.
TlMEFRAME
This volume is scheduled to be distributed
for Regional comment in late 1991.
(7) SPECIAL CIRCUMSTANCES
PURPOSE
This volume will address removal site issues,
problems, and circumstances not covered in detail by
the other SRP volumes. Many of these topics, such as
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radioactive substances, drinking water contamination,
and removals on Indian lands, have been discussed in
previous Agency policy or guidance documents.
TlMEFRAME
This volume is currently being drafted by
ERD and will be distributed for Regional review in
late 1991.
(8) GUIDANCE ON THE
CONSIDERATION OF ARARS
DURING REMOVAL ACTIONS
PURPOSE
This volume provides an overview of the
procedures for considering applicable or relevant and
appropriate requirements (ARARs) that should be
followed in the removal process. The volume details
the steps involved in considering ARARs during
removals, such as identifying federal ARARs, and
identifying and evaluating state ARARs. In addition,
' this volume assists the OSC in determining the extent
to which compliance with a requirement is practicable
and in documenting ARARs analysis.
Although CERCLA does not require
compliance with ARARs during a removal action, as
a matter of program policy and pursuant to section
300.415(i) of the NCP, CERCLA removal actions are
expected to identify and comply with ARARs to the
extent practicable, considering the exigencies of the
situation.
SUMMARY
The guidance begins with a purpose and
introduction section. It continues with an overview of
the identification of ARARs in the removal action
process, including timely identification of ARARs
during removal actions. The next
two chapters include details on the
identification of potential federal
and state ARARs. The last two
chapters describe procedures for
determining when compliance with
ARARs is impracticable and
procedures for documenting ARAR evaluations.
TlMEFRAME
This volume is scheduled to receive final
concurrence in July, 1991 and will be published as
OSWER Directive 9360.3-02.
(9) STATE PARTICIPATION IN
FEDERAL-LEAD REMOVALS
PURPOSE
It is EPA's intent to foster an effective and
cooperative relationship with states in implementing
the goals of the Superfund program. For this reason,
this volume of the SRP is intended to provide
information to OSCs and other Superfund personnel
on state participation in federal-lead Superfund
removals.
SUMMARY
This volume begins with an overview of the
removal program, the authorization for state
involvement, and an introduction to removal program
coordination with the state. The next section details
state support during federal-lead
removals. This includes a
description of required and
suggested state activities for
involvement in removal actions.
The next section provides
information on the resources
available for increasing state emergency response
capabilities. These resources include the Core Grant
Program and the Peer Match Program. The volume
concludes with information on the training that is
available to increase the states' capabilities in the
removal program and on documenting the states' role
in removal actions.
UPDATE
We are currently reviewing all funding
options for states to conduct removal actions; or to
create new or improve existing removal programs.
When the results of this review are complete, a
recommendation may be made to further encourage
state involvement in the removal program.
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TlMEFRAME
This volume has been revised to reflect
Regional comments and is expected to be published
in 1992 as OSWER Directive 93603-07.
(10) OVERVIEW
PURPOSE
This volume will contain a comprehensive
table of contents, list of exhibits, key word index, list
of acronyms, and glossary for use as a quick
reference.
TlMEFRAME
This volume will be
published in the SRP series.
the final volume
FURTHER INFORMATION
If you have any questions about
the SRP or if you would like fact
sheets on volumes that have been
published, please contact-^Seett
-Maid, Office of Emergency and
Remedial Response, Emergency
Division, at 202/FTS 382-4671r
Res
)you have any questions about the macros
and templates; would like a copy of them; or would
like to make an appointment to see a demonstration,
please contact Gil Laskowski at 202/FTS 382-6943.
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