nrted States
Environmental Protection
Agency
Solid Waste and
Emergency Response
EPA
DIRECTIVE NUMBER: 9203.1-03A
• Exercising Flexibility Through the Superfund
Accelerated Cleanup Madel (SACM)
APPROVAL DATE: i0/26/92
EFFECTIVE DATE: 10/26/92
ORIGINATING OFFICE: OERR
03 FINAL
D DRAFT
LEVEL OF DRAFT
A — Signed by AA or DAA
B — Signed by Office Director
l~l C — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
DIRECTIVE DIRECTIVE
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..rweo Slates environmental Protection Agency
. OC 204«0
OSWER Directive Initiation Request
9203.1-03A
2. Originator Information
Name o( Contact Parson
Betti VanEpps
Mad Cad*
15201G
Office
OERR
, Tetegnone Code
! 260-9760
3. Title
Exercising Flexibility Through the Superfund Accelerated Cleanup Model
(SACM)
4. Summary at Directive (incude one* statement of ouraosei
The purpose of this memo is to reaffirm the Office of Solid Waste and
Emergency Response commitment to support Regional offices in soundly-based
decision making while implementing the Superfund Accelerated Cleanup Model
(SACM).
5. KeyvrordS
SACM, CERCIA, and NCP
64. Dots this Q-reeuv*Supersede Previous Qwectiveisi?
b Ones it S'jppi«nient Prevtous Directives)''
! v i No
' X i
IX !NO
Y« What directiv* (numocr. Wit}
Y« What directiv* (number. trt«l
art L«v«»
A - Signed By AA'OAA I j 8 - S<]n«d Oy Office Director
C - for H«vt«w & Com/runt
i - in Development
8.
Document
tob«
distributed
to
States
by
Headquarters?
Y«»
X
No
This R«qu*it M««ts OSWER Olr»ct1v«» System Format Standards.
9. Sionaturiribf Ueaa Office fiir«ctiv«s Coordinator
Oate
to. Name and fide of Approving
Date
SPA Form 13U-17 (R«v. 5-«7> Previous editions are oosoiete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OCT 26 1992
OF
SOLIO WASTE AND EMERGENCY RESPONSE
VERY IMPORTANT PLEASE DISTRIBUTE TO ALL STAFF
MEMORANDUM
SUBJECT: Exercising Flexi
Accelerated C]/e
OSWER DIRECTIVE NO. 9203.1-03A
erfund
\
FROM:
TO:
\
,-xDon R. Clay
* Assistant A
Addressees
The purpose of this memo is to reaffirm the Office of Solid
Waste and Emergency Response commitment to support Regional
offices in soundly-based decision making while implementing the
Superfund Accelerated Cleanup Model (SACM).
At the April SACM planning meeting, I offered Headquarters
support to the Regions in making decisions that will improve the
Superfund program through SACM. Our new Superfund model is being
implemented at a rapid pace, and I am pleased with the direction
it is taking. SACM is the way we will be doing business in the
future, and although it is exciting and promising, it also poses
certain challenges. Any time major changes are implemented,
decisions must be made and actions must be taken in order to
improve the efficiency of the program. Yet, we must also be
conscious of the legal boundaries of CERCLA and the NCP. In
order to ensure that SACM actions are fully supported, OSWER has
issued jointly with the Office of General Counsel Directive No.
9203.1-03, "Guidance on Implementation of the Superfund
Accelerated Cleanup Model (SACM) under CERCLA and the NCP".
Using this directive, I urge Regional personnel to take full
advantage of the flexibility that the NCP offers to streamline
the program to provide risk-based cleanups at the greatest number
of sites; this could include development of consolidated site
assessments, the early start-up of RI/FS's at likely NPL sites,
and the increased use of removal authorities to more
expeditiously address sources of contamination. The Office of
Regional Counsel Regional Decision Team (RDT) representative will
be essential in identifying the flexibility within the NCP, and
ensuring that such flexibility is exercised in a manner that does
not pose unacceptable litigation risks. I also urge you to use
your discretion and sound judgement in program innovations. The
ROT meetings will be an appropriate forum to discuss these types
Pnntea ?-
c>ed Paper
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-2-
of issues since the team is made up of experts with cross-program
skills.
Further, revision of guidances is underway, and draft "short
sheets" have been sent for Regional comment. We have also met
with the Office of Inspector General (OIG) to fully apprise them
of SACM developments. We have informed the OIG that SACM
expedites the Superfund process using the flexibility within our
authority per the OSWER/OGC directive, without creating the
inconsistencies with the NCP that have been identified in
previous audits.
We must continue the communication between Regions and
Headquarters on the SACM issues. The benefits from this type of
dialogue were clearly seen at the National SACM Meeting held in
August. Keep in mind that we are all on the same team, working
towards the same goals. I stand ready to support you in taking
advantage of the flexibility in the regulations in order to make
soundly-based decisions to implement SACM.
Addressees:
Regional Administrators, Regions I-X
Director, Haste Management Division
Regions I, IV, V, VII
Director, Emergency and Remedial Response Division,
Region II
Director, Hazardous Waste Management Division
Regions III, VI, VIII, IX
Director, Hazardous Waste Division, Region X
Director, Environmental Service Division
Regions I, VI, VII
Regional Counsel, Regions I-X
cc:
Rich Guimond, OSWER
Bowdin Train, OSWER
Bill White, OE
Lisa Friedman, OGC
Henry Longest, OERR
Bruce Diamond, OWPE
Tim Fields, SRO
Walt Kovalick, TIO
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bcc: Regional Removal Managers, Regions I-X
Regional Waste Management Branch Chiefs, Regions I-X
Larry Starfield, OGC
Larry Reed, OERR, HSED
Tom Scheckells, OERR, OPM
Debbie Deitrich, OERR, ERD
Jerry Clifford, OERR, HSCD
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