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          Eflviranmtnial Protection
                Ofticvof
                SoHdWi
and
&EPA
DIRECTIVE NUMBER: 9200.1-11


TITLE: Accessing the $50 Million Set-Aside In the
     Remedial Action Budget for Quick Response at
     National Priorities List Sites
APPROVAL DATE:
            2/20/92

EFFECTIVE DATE: 2/2Q/92
               QERR
            ORIGINATING OFFICE:

               FINAL

            D  DRAFT

               LEVEL OF DRAFT

                n  A — Signed by AA or DAA

                D  B — Sigrad by Office Director

                O  C — Review ft Comment

            REFERENCE (other documents):
  OSWER    OSWER    OSWER
     DIRECTIVE     DIRECTIVE

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Q CPA Washington, DC 20480
otrH QSWER Directive Initiation Reauest
2. OrtglfMrter Intonation
Hum of Contact PvMft Mad Cod* jQffice
Tim Grier los-210 1 niRR
1 Qwectwe Number
9200.1-11

T«fepnon« Cod*
?fin-Rnn
3, Title
Accessing the $50 Million Set-Aside in the Remedial Action Budget for Quick
Response at National Priorities List Sites
4. Summary of Directive (include Dnef statement of purpose)
This memorandum establishes the procedures required to access the $50 million that
has been set aside from the FY92 Remedial Action budget for quick response at
National Priorities sites.
S. Keyword*
Site assessment and remediation
6* Does This Directive Supersede Previous Oifective(s)? "S^/1
yS\ No Yes What directive

(numfter. title)
o Does n Supplement previous uirectrvais)'* rv/j
|/\i No Yt* Wh-t directive (number, trtfe)

7 Ofift level
A - Signed by AA/OAA j IB- Signed by Office Director C - For Review & Con

iment 0 - in Oevelopmint
.

8. Document to be distributed to States by Headquarters? _

Yes i/\ NO
Thi» R«pu«it M«*u OSWER Otreetives System Format Standards,
9 Signature of Laad Office Directives Coordinator
1 0 Name and Title of Approving uncial
Date
Date
   EPA Form 1315-17 (H«v. S-*7) Previous eOitlons are oosoiete.
 OSWER      OSWER         OSWER        O
VE   DIRECTIVE     DIRECTIVE    DIRECTIVE

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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON, D.C. 20460
                          FEB 2 0 1992
                                             OFPICE OF
                                    SOLID WASTE AND EMERGENCY RESPONSE
                                         O8WER Directiva 9200.1-11
MEMORANDUM
8OBJECTS
FROM:
TO:
Accessing the $50 Million Set-Aside  in  the  Remedial
Action Budget for Quick Response  at  National  Priorities
List Sites
Henry L. Longest II, Director
Office of Emergency and Remedi
                                                onse
Director, Waste Management Division,
  Regions I, IV, V, and VII
Director, Emergency and Remedial Response  Division,
  Region II
Director, Hazardous Waste Management  Division
  Regions III, VI, VIII and  IX
Director, Hazardous waste Division
  Region X
Director, Environmental Services Division
  Regions I, VI, and vii
Purpose

     This memorandum  establishes  the procedures required to
access the $50 million  that  has been set aside from the FY 92
Remedial Action  (RA)  budget  for quick response at National
Priorities List  (NPL) sites.

Background

     In the months  since  the 30-Day Task Force Report,  the
program ha3 looked  at a number of strategies for accelerating
cleanups.  These have included strategies for identifying quick
response opportunities  in the NPL universe,  expanding the con-
tract vehicles available  to  carry out quick  response actions, and
initiating remedial action under  a "thin" Record of Decision
(ROD).  Another option, which this directive implements,  is to
offer an incentive  for  initiating quick responses by setting
aside $50 million in  the  RA  budget specifically for that type of
work.
                                                             c. —'•• rjed Paper

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Implementation

     The $50 million set-aside may be used to initiate rapid
remedial responses or, when it is determined that removal author-
ities are more appropriate, the funds may be transferred to the
removal account for removal actions.  The funds may be trans-
ferred to the removal budget only if the percentage of the
Region's budget devoted to NPL sites and the number of NPL
removals conducted by the Region remains near or above historical
levels.  In other words the $50 million is not intended to
replace the removal funding which is currently projected for NPL
site work.  Each current removal advice of allowance gives the
Region flexibility to address any immediate threats that may be
discovered at NPL sites.

     The $50 million will only be set aside until the end of the
third quarter of the fiscal year.  Quick response projects need
to be identified by that time in order to qualify for funding.
After that time, unplanned and unobligated funds remaining in the
quick response set-aside pool will revert to the RA budget and
may be used to fund or supplement priority RAs or quick response
projects identified after the third quarter.

     During site planning and RI/FS phases, the Remedial Project
Manager (RPM) should identify opportunities for quick response
actions.  Also, Removal Managers in the Regions have the respon-
sibility to assess 50% of their non-Federal Facility proposed and
final NPL sites each year to ensure that no immediate threats
have arisen.  The On-Scene Coordinators (OSCs)  who perform these
assessments should use them to identify opportunities for quick
response.

     Criteria to evaluate the potential for a quick response
action include:

          The cleanup actions should be well defined, of low to
          moderate technical complexity, use a proven technology,
          have existing field information readily available,  and
          have a low to moderate cost to complete.  Examples are
          surface cleanup, soil excavation, volatile substance
          reduction, interim ground water plume controls,  tank or
          structure demolition, and impoundment closure.

          Prior to initiating a quick response,  enforcement
          issues need to be addressed.

          A project should not be broken up and expedited just to
          "turn dirt."  The decision of a quick response should
          be based on an attempt to reduce risks and compress the
          critical path for pipeline remedial activities.   The
          actions must be consistent and appropriate to the over-
          all remediation of the site.

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          Quick response projects generally should not cost more
          than $2 nillion, however exceptions may be allowed for
          projects up to $5 million.

     A Region may request funding from the $50 million by writing
the Director of the Emergency Response Division (ERD).  The ERD
Director is responsible for coordinating with the Hazardous site
Control Division (HSCD), the Office of Program Management (0PM),
and the Office of Waste Programs Enforcement (OWPE).  The re-
quests to the ERD Director should address the relevant criteria
listed above justifying the need for the quick response.  The
request should be supported by relevant documents.  If the quick
response will be a rapid remedial response, Regions are encour-
aged to conduct a focused feasibility study that will lead to a
"thin" ROD. The ROD must be signed and the State Superfund
Contract in place prior to initiating the action.   The funds must
be obligated this fiscal year.

     A separate determination needs to be made over which author-
ity and contract vehicle will be employed to do the quick re-
sponse.  Several new Emergency Response Cleanup Services (ERCS)
contracts have the capability and capacity to perform time-
critical removal and rapid remedial responses.   Under the remedi-
al program, the Alternate Remedial Contract Strategy (ARCS)
contractor performing RI/FS activities may conduct quick response
actions.  The ARCS contractor would normally subcontract for this
type of work.  EPA has also put in place a Prequalified Offerors
Procurement Strategy (PQOPS) which is a list of contractors who
are technically prequalified to perform mobile incineration and
chemical fixation/stabilization.  The U.S. Army Corps of Engi-
neers has rapid response contracts for demolition actions,  clo-
sures, point source contamination controls, and site stabiliza-
tion available for use by EPA.  Finally, separate site-specific
contracts should also be considered.

conclusion

     These procedures are intended to facilitate access to the
$50 million set aside from the FY 92 RA budget for quick response
at National Priorities List (NPL) sites.

     For further information regarding this memorandum contact
Tim Grier of ERD at FTS 260-8110.

cc;  SF Branch Chiefs, Regions I-X
     Removal Managers, Regions I-X
     OERR Office Directors
     Tim Fields, OSWER
     Sally Mansbach, OWPE

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