&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9200.3-09
TITLE: Establishing a Construction Pipeline
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
E FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
December 19, 1989
December 19, 1989
Superfund
OSWER OSWER OSWER
/£ DIRECTIVE DIRECTIVE D
-------
v>EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9200.3-09
TITLE: Establishing a Construction Pipeline
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
E FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
December 19, 1989
December 19, 1989
Superfund
OS WER OS WER OS WER
/£ DIRECTIVE DIRECTIVE
-------
Washington. DC 204«0
QSWER Directive Initiation Request
1.DirectivtNumb«r
9200.3-09
Z Originator Information
Name of Conuct Person
SDT
Mail Coda
05-240
Office
QERR/OPM/MSDS t
Telephone Code
475-8864
3.TiUa
Establishing a Construction Pipeline
4. Summary of Directive-(include brief statement of purpose)
The purpose of this memorandum is to re-emphasize the importance of completing
activities to assure FY90 remedial actions (RA) are funded in a timely manner.-
The competition for scarce remedial construction funds on a national scale has
been the major factor towards development of the RA priority system that will
be implemented in FY 90.
5. Keywords
St. Does This Directive Supersede Previous Directive(s)?
b. Does It Supplement Previous Oirective(s)?
Yas What directive (number, tffle)
Yea What directive (number, tide) 9200 3—09
FY 90 Remedial Action Advice of Allowance and Maintenance of Queue
/Jjraft level
A-SJgnedbyAA/DAA
B - Signed by Office Director
C - For Review & Comment
D - ft Development
8. Document to be distributed to States by Headquarters?
Yas
No
This Request Meets OSWER Directives System Format Standards.
9. Signature of Lead Office Directives Coordinator
Betti VanEpps/ Superfund Documents Coordinator
1 0. Name and Title of Approving Official
Don R. Clay, Assistant Administrator
Office of Solid Waste and Emergency Response
Date
December
Data
December
19,
19,
1989
1989
EPA Form 1315-17 (Rev. 5-sT) Previous editions are obsolete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
DEC I 9 1989
SOLID WASTE ANDEMERGENCv RESPONSE
MEM3RANI™ OSWER 9200.3-09
SUBJECT: Establishing a Construction Pipeline
FHCM: Don R. Clay, Assistant Administrator
Office of Solid Waste and Emergency Response
TO: Regional Administrators
Regions I - X
As I know you are all aware, in Fiscal Year 1990 the Superfund Budget
received substantial reductions in the appropriations process, for the second
year in a row. Although final decisions have not been made as to where all of
those reductions will be taken, it is clear that these reductions will
significantly affect the amount of dollars available for construction funding.
At the same time, the number of projects moving toward the construction end of
the pipeline has grown significantly. When we began budget planning for this
operational year in July, we were able to identify a need for construction
exceeding $900 million. Seventy-five percent of those projects anticipated for
funding in FY 90 were already in design. This represents the greatest number
of projects in remedial design than ever before in Superfund's history. An
environmental priorities strategy was developed to drive our funding decisions
and ensure that we are addressing the worst sites and the worst problems at
these sites.
Moving projects forward to the point where they are ready for funding is
one of the highest priorities for the Superfund program this fiscal year. I
have attached to this memorandum a recent transmittal from Henry Longest to the
Waste Management Division Directors that lays out the commitments of each
Region. With this memo, I am requesting your personal involvement ensuring
that appropriate enforcement actions are taken and subsequent decisions to
continue enforcement or proceed with the fund are made in a timely manner.
This is a critical budget year in the history of the Superfund program.
In March of 1990, I will be before Congress testifying as to the program needs
in the last budget of this reauthorization. Spring budget preparation will
focus on the first budget of a new "reauthorization". Every project is
inportant this year, whether it moves forward for funding or not. The credible
need of this program for additional resources will likely rest on our ability
to complete projects and establish a legitimate queue, as well as our ability
to fund a substantial number of projects by mid-year.
I appreciate your personal attention to this effort. I will be talking
with you further about our national progress in this area throughout the year.
Attachment
-------
-2-
cc: Deputy Regional Administrators, Regions I-X
Waste Management Division Directors, Regions I-X
-------
USEJ
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
DEC 7 !989
M E MO RA N D U.M
SUBJECT:
FROM:
TO:
OSWER DIRECTIVE 9200.3-09
FY 90 Remedial Action Advice of Allowance and
Maintenance of Queue
Henry L. Longest II, Director I
Office of Emergency and Remedial
Directors, Waste Management Division,
Regions I, IV, V, VII, VIII
Director,'Emergency and Remedial Response Division,
Region II
Directors, Hazardous Waste Management Division ,
Regions III, VI
Director, Toxics and Waste Management Division,
Region IX
Director, Hazardous Waste Division,
Region X
PURPOSE:
The purpose of this memorandum is to re-emphasize the
importance of completing activities to assure FY90 remedial
actions (RA) are funded in a timely manner. The competition for
scarce remedial construction funds on a national scale has been
the major factor towards development of the RA priority system
that will be implemented in FY90. It is imperative that by mid-
year the RA obligation rate be significant.
BACKGROUND:
As we entered FY89, the Regions identified 76 projects worth
$620 million that would require funding. At the beginning of the
year, it appeared certain that the Superfund program would run out
of dollars to support ready work, and would be putting projects on
the shelf for the first time. As we all know, this did not occur.
We phase funded some large dollar projects (and shifted needs
into FY 1990), slipped some projects, and brought into the system
for funding a significant number of small projects. Of great
concern to the national program was the fact that thirty projects
identified at the beginning of the year to be ready in the fourth
Rtcycltd Papti
-------
quarter,'12 were funded during the course of the year, 9 slicped
into FY 1990, and 9 slipped into FY 1991.
As we begin FY 1990, a total of 66 projects (18 on-going and
43 new starts, first or subsequent), worth over $900 mill ion.'have
been identified for possible funding (see attachments I and II).
Even allowing for common expectations of unpreventable slippage,
it seer.s clear that with a remedial action budget of between $300
and $400 million dollars, a substantial queue of ready projects
would occur this year. Regions and headquarters working together
have put a substantial effort into establishing a list of prioritv
projects for funding based on public health and environmental
criteria.
The current funding strategy gives first priority to on-going
work, mixed funding, and five projects that the Regions have
identified as posing immediate threats. A large group of projects
are in the category called "priority 2" projects (projects that
have an actual threat or near term threat to human health and the
environment). At the last RA priorities workgroup meeting, it was
agreed to divide the priority 2 list into four quartiles (with
each quartile represe-hting sites that have more or less the same.
urgency for funding), and to fund those sites in the first two
quartiles that are ready first. Small dollar projects ($2.5
million or less) can be funded without prioritization, so long as
they do not cumulatively exceed a $10 million set aside for small
dollar projects.
As we approach the last eighteen months of Superfund
authorization (and budget hearings on the last budget year before
reauthorization), it is vitally important that we bring projects
to the point where they are ready to receive clean-up funding,
even if such projects cannot be funded. A massive amount of work
has gone into getting these projects to the point they are at now
in the final stages of remedial design. It is important
that we not get discouraged by funding shortfalls, and that we
take that work as far as we can.
IMPLEMENTATION:
As part of the funding strategy for FY 1990 , we have assured
the Regions that we will hold funding for priority projects that
stay on schedule through the first three quarters. Since some
priority projects could therefore block other projects that are of
a lower priority, but are ready for funding, it is vitally
important that we have accurate up-to-date information on the
readiness of projects. In addition, the RA priorities workgroup
has agreed that Regions should be held accountable for producing
the promised queued sites, and that they should be tracked against
their ability to have those projects ready, regardless of the
availability of funding. Accordingly, we have taken the following
steps:
-------
o Working with the RA priorities workgroup, we
have adopted a definition of "queue achieved" that
encompasses the notion that the remedial design is
complete, and that agreement in principle has been
reached regarding the State Superfund Contract.
o I have attached a management report chart to this
memorandum, which will be reflected in subsequent
monthly management reports, and which will highlight
Regional performance in getting sites ready for construction.
o I have asked the Hazardous Site Control Division to
specifically address RD work at approved and queued RA
projects during line item reviews with the Corps of
Engineers, and discussions with the Regions on ARCS
contract status reviews.
o Periodic conference calls will be conducted in order
to ascertain the current status of the plan. A headquarters
team, comprised 'of the Office of Program Management, the
Hazardous Site Control Division, and
CERCLA Enforcement Division representatives will
contact your Regional workgroup member in the very near
future. In addition to the status of remedial designs
and State Superfund Contracts, special attention will be
given to the status of State capacity assurance approvals,
and enforcement activity at the site.
Given the vital importance of accurate and timely
information, particularly this fiscal year, I am asking that you
pay particular importance to keeping CERCLIS information up-to-
date on a real time basis. Regions should generate CERCLIS
reports (SCAP-16) and review them to ensure that all queued
projects are accurately coded. These codes are as follows:
o Ongoing RA projects - code "0"
o Priority 1 RA projects - code "APR"
o Priority 2, 3 and 4 RA projects - code "Q"
o 4th Quarter RA projects - also code "Q"
-------
Note that for any "Q" coded sites, the region should enter "ALT"
for funding status once the queue has been achieved (e.g. the RD
is complete and agreement has been reached in principle with the
State on the SSC). In addition for any "Q" project that cannot
be funded due to CAP requirements, the phrase "CAP restricted "
should be entered into the comment field.
As a result of these conference calls, the regions will be
informed of any additional funding strategy for "priority 2"
projects through mid-year.
CONCLUSION:
I know you appreciate the importance and necessity of moving
projects through the remedial pipeline to the RA phrase. Please
call Clem Rastatter, FTS 382-2441, or Tom Sheckells, FTS 382-
2466, if you have any questions.
Attachments
cc: Regional RA Priorities Workgroup Members
Regional Branch Chiefs
Regional Information Management Coordinators
Bruce Diamond
Lloyd Guerci
Carol Rushin
Russ Wyer
Ken Ayers
Clem Rastatter
Tom Sheckells
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REGIONAL RA PROJECTS (FY90)
o
F
P
R
O
J
E
C
T
S
15
10
21
- ONGOING
M - PRIORITY 1
f||] - PRIORITY 2
{ill] - PRIORITY 3
prl - PRIORITY 4
| | - QUARTER 4
I II III IV V VI VII VIII IX X
REGION
n
H
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RA PRIORI NZATION FACTSIIHKT
Site Name Region
O&M, L1R. Mixed Funding
Projects
ONGOING PROJECTS
Charles George Land
)avis Liquid Waste
Hog Creek
Cilen Ridge Radium
Mont/W. Omg Radium
Moyers
Publicker Industries
Supp Battery
SCRDI Dixiana
Tower Chemical
1 chillier Mankato
New Brighton/Arden H
New Lyme
Verona
Old Inger
Sikes Disposal Pits
Denver Radium
Slriiigfellow
SUB-TOTAL (Ongoing)
1
1
2
2
2
3
3
4
4
4
5
5
5
5
6
6
8
9
Cost Running
(millions) Total
$35.0
$1.6
$1.0
$5.0
$18.0
$18.0
$2.0
$4.5
$11.0
$1.0
$11.0
$0.2
$0.5
$1.0
$0.6
$2.0
$65.0
$44.5
$2.4
$189.3
$35.0
$36.6
$37.6
$42.6
$60.6
$78.6
$80.6
$85.1
$96. 1
$97.1
$108.1
$108.3
$108.8
$109.8
$110.4
$112.4
$177.4
$221.9
$224.3
Dale
Q2
Ql
Q3
Ql
QJ
Q2
Ql
Q3
Ql
Ql
Q3
Ql
Ql
Q2
Ql
Q3
Ql
Ql
Priority
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Stale
MA
Rl
NJ
NJ
NJ
PA
PA
FL
SC
FL
MN
MN
OH
Ml
IA
TX
CO
CA
I]
ji:
i';j
I'uuc I
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RA PRIOKN IZATION FACTSIIliRT
Ql
Q2
Sile Name
PRIORITY 1 PROJECTS
Forest Glen Subdiv.
Radium Chemical
Koebling Steel
Whitmoyer Labs
Purity Oil Sales
SUB-TOTAL (Priority 1)
I'RIORITY 2 PROJECTS
Haird & McGuire
Palmetto Wood Presser
Cape Fear
American Qeosote
Smuggler Mountain
1 leleva
Lorenlz
Aberdeen Pesticides Dump
Keefe Environmental Serv
Times Beach OU2
Marathon Battery
Iron Mountain (RA4)
Odessa Chromium II
Amnicola Dump
1 luvertown PCP
Region
2
2
2
3
9
1
4
4
4
8
3
9
4
1 ,
7
2
9
6
4
3
Cost
(millions)
$3.0
$20.0
$6.0
$0.6
$1.0
$30.6
$60.8
$4.0
$150
$0.3
$5.2
$6.0
$3.0
$14.6
$3.7
$5.4
$81.0
$6.5
$7.0
$0.5
$0.8
Running
Total
$227.3
$247.3
$253.3
$253.9
$254.9
$315.7
$319.7
$334.7
$335.0
$340.2
$346.2
$349.2
$363.8
$367.5
$372.9
$453.9
$460.4
$467.4
$467.9
$468.7
Dale
Q"
Q3
Q2
Ql
Q3
Q3
Q2
Q3
Q2
Ql
Q2
Q2
Q3
Q3
Ql
Q3
Ql
Ql
Ql
Q2
Priority
1
1
1
1
1
2
2
2
2
2
2
2
2
i 2
2
2
2
2
2
2
Slate
NY
NY
NJ
PA
CA
MA
SC
NC
FL
CO
PA
CA
NC
Nil
MO
NY
CA
IX
TN
PA
\\
I'l
Pape 2
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RA PRIOR ITIZATION FACTSIIIiKT
Q3
— J
She Name
iciger (CAM Oil)
"ommencement Bay
dimmer Sanitary Ldfl
'inette's Salvage Yard
lavilaiid Complex
.ove Canal - 93rd St Sc
VI W Manufacturing
Sand Creek
Arrowhead Refinery
Combe Fill South
Hlosenski Landfill
Meialec/Aerosystems
Oak Grove San. LF
Purity Oil Sales
Zellwood OU#2
1 lebelka Auto Salvage
IlippsRd Landfill
Culcl well Trucking Co.
Waldick Aerospace
Pesses Chemical Co.
Urewster Wellfield
Arkansas City Dump
Berks Sand Pit
Millcreek, Erie, PA
SUB-TOTAL (Priority 2)
Region
4
10
5
1
2
2
3
8
5
2
3
2
5
9
4
3
4
2
2
6
2
7
3
3
Cost
(millions)
$3.0
$3.0
$11.0
$4.6
$1.3
$5.0
$2.2
$18.6
$1.7
$50.0
$9.0
$11.0
$8.0
$0.5
$7.5
$7.0
$3.0
$0.6
$3.5
$1.4
$0.8
$2.3
$7.0
$12.0
$387.8
Running
Tolal
$471.7
$474.7
$-185.7
$490.3
$491.6
$496.6
$498.8
$517.4
$519.
$569.
$578.
$589.
$597.
$597.6
$605.
$612.
$615.
$615.7
$619.2
$620.6
$621.4
$623.7
$630.7
$642.7
Dale
Q3
Ql
Q3
03
Q3
Q3
Ql
03
Q2
02
02
03
01
03
03
Q3
02
Ql
Q3
Q3
Ql
02
Q3
Q2
Priority
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Stale
SC
WA
MN
MI-
NY
NY
PA
CO
MN
NJ
PA
NJ
MN
CA
FL
PA
FL
NJ
NJ
IX
NY
KS
PA
PA
l\
.'I
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RA PKIOKITIZATION FACI SHI-Pi I
Cost Running
Site Name Region (millions) Total
PRIORITY 3 PROJECTS
Hurnl Fly Dog
SUB-TOTAL (Priority 3)
I'RIORITY 4 PROJECTS
Souih Valley SJ 6
Slunkey Landfill
SUB TOTAL (Priority 4)
QUARTER 4 PROJECTS
Caldwell Trucking Co.
D'linperio Property
Lang Property
Nascolile Corp.
Price Landfill
Hlosenski Landfill
Delaware Sand & Gravel
Pomey Road Landfill
62nd Street
American Creosote OU2
( 'olcman Evans
2
6
2
2
2
2
2
2
3
3
3
4
4
4
$4.8
$5.0
$26.0
$31.0
$7.0
$15.0
$7.6
$3.0
$9.1
$3.0
$18.0
$16.0
$5.0
$12.0
$20.0
$647.5
$652.5
$678.5
$685.5
$700.5
$708.1
$711.1
$720.2
$723.2
$741.2
$757.2
$762.2
$774.2
$794.2
Dale
Q2
Ql
CM
Ql
Ql
Ql
Q1
Q1
Ql
Ql
CM
Ql
Q4
Ql
Priority Stale
3 NJ
4 NJ
4 NM
NJ
NJ
NJ
NJ
NJ
PA
DE
PA
i-L
I;L
I:L
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RA PRIORI TIZATION FACI SIIRI-T
Site Name Region
Inlersiale Lead
Smith's Farm
Itau Claire
Forest Waste
lx>ng Prarie
U.S. Aviex
North Cavalcade Si.
Old Midland
Cherokee County
Hastings GW
Premier Hard Chrome
NW Transformer
SUB-TOTAL (Quarter 4)
TOTAL
4
4
5
5
5
5
6
6
7
7
10
10
Cost Running
(millions) Tola!
$5.0
$27.0
$1.5
$22.5
$2.0
$5.0
$5.8
$12.0
$20.0
$1.8
$6.0
$0.8
$225.1
$903.6
$799.2
$826.2
$827.7
$850.2
$852.2
$857.2
$863.0
$875.0
$895.0
$896.8
$902.8
$903.6
Dale Priority Stale
Q1
CM
Ol
O1
Q1
04
Q»
Q1
QJ
QJ
Ql
Q1
AL
KY
Wl
Ml
MN
Ml
IX
AR
KS
NE
WA
WA
i-j
.'I
I )
o
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