United State*
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
&EPA
DIRECTIVE NUMBER:
TITLE:
9272.0-02
Initial Guidance on Federal Facilities CERCLA
Sites
APPROVAL DATE: 12/03/84
EFFECTIVE DATE: i2/03/84
ORIGINATING OFFICE: QERR/HSCD
Q FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
1WER OSWER OSWER
DIRECTIVE DIRECTIVE Dl
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03/19/87 United States Environmental Protection Agency
Washington, O.C. 20460
EPA OSWER Directive Initiation Request
1. Directive Number
9272.0-02
2. Originator Information
Name of Contact Parson
BEAM
MaH Code
Office
OERR/HSCD
Telephone Number
475-8106
3. Title
INITIAL GUIDANCE ON FEDERAL FACILITIES CERCLA SITES
4. Summary of Directive (Include brief statement of purpose)
Status and direction of OSWER efforts to implement
hazardous site cleanup at Federal facilities.
Divides primary responsibility for national
management of Superfund Federal facility programs
between the Office of Waste Programs Enforcement
and the Office of Emergency and Remedial Response.
(12/84, 3 pp) ,
5. Keywords
SUPERFUND, CERCLA, REMEDIAL PROGRAM, FEDERAL FACILITIES
6a. Does this Directive Supercede Previous Dlrectlve(8)?| [ yes | X[ NO What directive (number, title)
b. Does it Supplement Previous Directive's)?
yes
No What directive (number, title)
7. Draft Level
A-SignedbyAA/DAA
B - Signed by Office Director
C - For Review & Comment
i Development
This Request Meets OSWER Directives System Format
8. Signature of Lead Office Directives Coordinator
Date
9. Name and Title of Approving Official
L. THOMAS
Date
12/03/84
OSWER OSWER OSWER
DIRECTIVE DIRECTIVE
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'/
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
DEC 3'984
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER Directive 9272.0-2
MEMORANDUM
SUBJECT:
PROM:
TO:
dance on Federal Facilities CERCLA Sites
ssistant Administrator
Regional Administrator
Regions I-X
A number of Regions have expresed interest in which
Headquarters (HQ) Office of Solid Waste and Emergency Response
(OSWER) organization should be their point of contact for site- -'
specific issues and have posed questions that are an outgrowth of
our recent action to list Federal facilities on National Priorities
List (NPL). This memorandum is to inform you of the status and
direction of OSWER efforts to implement our program for hazardous
site cleanup at Federal facilities. In order to better define
roles within OSWER at HQ, I have divided the primary responsibil-
ities for national management of the Superfund Federal facility
programs between the Office of Waste Programs Enforcement (OWPE)
and the Office of Emergency and Remedial Response (OERR) as
follows:
OWPE Responsibility:
OERR Responsibility:
Sites where releases of hazardous substances
have been caused solely by activities on f
Federal facilities. This Includes sites
eligible for inclusion or currently on the
proposed NPL list as Federal facility sites.
Sites where the release of hazardous
substances appears to relate to activities
by private parties outside the boundaries
of a Federal facility, which may also be a
source of contamination. If it can later
be determined that the Federal facility
is the sole cause of the release of
contamination, then the responsibility
will shift to OWPE.
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As a result of our effort to Increase the level of EPA
oversight, several other important Issues have been raised.
OERR and OWPE have agreed on short-term resolutions to the issues
as follows:
0 Regional Resources: We have distributed 7.5 FTEs and $750K
in PY'85 to the Regions in program element FAY9A for Federal
facilities oversight. Although the resources are conveyed
via an "OERR" "account, the resources are intended for whatever
unit the Regional Administrator designates for CERCLA over-
sight of Federal facilities in accordance with this initial
guidance.
0 "Credit" for Federal Facilities Efforts: We intend to
seek appropriate SPMS measures to account for the effort
required to oversee Federal facility cleanups. Current
measures either don't reflect this effort (Responsible
Party Searches) or are keyed to Regional SCAP allocations
(Negotiations & Settlements). We will adjust for this in
the 1st quarter FY'85 SCAP review.
0 Initial Actions for NPL Update #2 Federal Sites: HQ, OFA
and OSWER personnel have met with top management at almost
all Federal Agencies to inform them of our intent for over-"
sight activities. Regions should contact in writing owners/
operators/Federal facility managers of listed Federal
facilities to determine what cleanup plans and schedules
have been formulated for these sites and to advise them that
EPA will exercise oversight of the schedule and scope of
their overall cleanup plans in accordance with the CERCLA,
Executive Order 12088, and MOU authorities, including remedy
selection and implementation of the remedy. This effort should
be coordinated between the Region Waste Management Director and
the Federal facility coordinator. Further enforcement guidance
will be issued as described below.
0 Completion of Guidance for Regions and Program Manual for *
Agencies: On August 16, 1984, Al Aim sent you the draft EPA'
strategy for assuring Federal facility compliance with
CERCLA. A work group with OFA and Regional participation is
developing two documents to translate this policy direction
into operational guidance for your use and use by other
Federal agencies. The purpose of the first document is to
provide guidance to EPA Regional offices to assist Federal
agencies in complying with CERCLA and the second is a manual
to explain CERCLA responsibilities and provide guidance to
Federal agencies that need to develop programs for their
hazardous waste sites. These documents are Intended to be
broad working plans that serve as a framework for our CERCLA
Federal facility program. The appropriate program office
will develop detailed sections for these documents.
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OERR will continue as the overall lead to develop these two
documents. A first draft of each document will be distributed to
Regions and program offices by December,15, 1984. A work group
meeting to resolve draft document Issues .Is scheduled for
January 3, 1985- A final draft of the guidance will be distributed
to the Regions by February 1, 1985. A final draft of the program
manual will be distributed to Federal agencies the first week of
February, followed by a CERCLA orientation seminar in mid-March.
cc: OFA
OECM
OGC
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