: UN'TED STATES ENVIRONMENTAL PROTECTION AGENCV
WASHINGTON, D.C. 20460
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Addressees
Waste Management Division Directors
Regions I, IV, V, VII
Emergency and Remedial Response Division Director
Region II
Hazardous Waste Management Division Directors
Regions III, VI, VIII, IX
Hazardous Waste Division Directors
Region X
Environmental Services Division Directors
Regions I, VI, VII
Superfund Branch Chiefs
Regions I-X
Superfund Branch Chiefs
Office of Regional Counsel
Regions I-X
cc: Rich Guimond, OSWER
Walt Kovalick, OSWER
Bill White, OE
Lisa K. Friedman, OGC
Tim Fields, SRO
Superfund Section Chiefs
All OERR, OWPE and SRO Staff
All Regional Superfund staff
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United States
Environment?' Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9203.1-10FS
EPA 540-F-93-024
PB 93-963286
July 1993
&EPA
Superfund Accelerated Cleanup
Model (SACM)
Questions & Answers
Office of Emergency and Remedial Response (OS-200)
Office of Waste Programs Enforcement
This bulletin provides answers to issues the Regions have raised on the Superfund Accelerated Qeanup Model
(SACM). The answers are based on discussions with Henry L, Longest n (Director, Office of Emergency and
Remedial Response), and the SACM Steering Committee which includes: Tom Sheckells (Director, Office of
Program Management); Debbie Dietrich (Director, Emergency Response Division); Larry Reed (Director,
Hazardous Site Evaluation Division); Dave Bennett (Acting Director, Hazardous Site Control Division); and
Sally Seymour (Director, OWPE/CERCLA Enforcement Division).
REGION: What is the priority of
SACM relative to construction
completions?
Henry Longest In a recent directive
(OSWER Directive No. 9202.1-14),
OSWER and the Office of
Enforcement (OE) outlined the
eight National Superfund
Program Priorities for FY 1993.
The top three include: (1)
construction completions; (2)
enforcement first; and (3) accelerating cleanup through
implementation of SACM and presumptive remedies. We
view theso as complementary priorities that are aimed at
achieving measurable program results (completions),
leveraging all available resources for cleanup (enforcement
first), and improving and streamlining our process
(acceleration). Our priority still is to deal with the worst sites
first. SACM provides tools to help us accelerate sites already
in the pipeline, and assess and respond to the worst sites
awaiting entry into the pipline. It is a base assumption that
emergencies will always be given first attention. We are
developing more detailed guidance on how to manage the
blending of program priorities.
REGION: How will Regions get credit for work
performed under SACM?
Tom Sheckells: For FY93, the Office of Policy, Planning and
Evaluation (OPPE) approved the joint Office of Emergency
and Remedial Response (OERR)and Off ice of Waste Programs
Enforcement (OWPE) request for increased flexibility in target
adjustments for Regions pursuing
SACM initiatives. Regions were given
the opportunity to request relief
from specific SCAP/STARS FY93
targets by April 30. Targets will
be adjusted accordingly for
Regions to get credit while
implementing SACM.
Faster... CJesner...Safer
REGION: Will the number
of non-NPLsites the removal
program has cleaned up be used to count towards
construction completions?
Henry Longest: No. It has been estimated that over 700 non-
NPL sites have been cleaned up by the removal program. The
size, duration, and complexity of the non-NPL removals can
not be equated with long-term responses at NPL sites.
However, the number of non-NPL sites cleaned up by the
removal program will be a separate accomplishment from the
NPL construction completion number. Together these
numbers will convey a more comprehensive measure of ajl of
Superfund's accomplishments to the public.
REGION:
measured?
How are the impacts of SACM being
Tom Sheckells: Initially, we will measure the impacts of
SACM by comparing the results of the pilot project sites with
a historical baseline. Currently, we are in the process of
developing a comprehensive revision of our FY94 SC AP and
STARS measures to focus our program evaluation efforts on
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measurement of program results in terms compatible with
SACM'sgoalsof(l)accelera ting response, (2) improving cost-
effectiveness, and (3) achieving rapid risk reduction in a
manner consistent with "enforcement first".
REGION: How will SACM activities be funded?
Tom She eke Us: Currently, SACM funding activitiesare dealt
with on a case-by-case basis inconsultation with Headquarters.
We are working on a FY94 funding strategy that will integrate
funding for SACM initiatives with funding for traditional
pipeline activities. This strategy will be documented in the
FY94 Program Management Manual that will be available to
the Regions in draft form this summer, prior to FY94 resource
negotiations.
REGION: Under SACM, should Regions reevaluate
existing pre-NPL and NPL sites for potential early
actions in addition to focusing on integrated site
assessments and early actions for new sites?
Tom Sheckells: After determining the resources required to
meet the construction completion goal, Regions should focus
remaining resources on the worst sites first to reduce risk
most quickly and efficiently at NPL, NPL
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REGION: Whattype ofdecision documents are required
for removal actions at NPL sites where those removal
actions are the sole or final responses at the site?
Debbie Dietrich: The action memorandum is the decision
document for all removal actions. When a removal action is
the sole or final response at a NPL site, a ROD is required in
addition to the action memo. EPA's policy on site deletion is
that a ROD is needed to document that no further action is
necessary for an entire NPL site. The basis for this policy is
that the ROD and the supporting RI provides the information
necessary for the finding that the site warrants deletion from
the MPL. This information is included in the administrative
record to support the site deletion. This policy is under
review in light of SACM. (See Interim Final Guidance on
Preparing Superfund Decision Documents, October 1989,
OSWER Directive 9335.3092, page 9-2).
REGION: Do non-time-critical removals need an action
memorandum?
Debbie Dietrich: Every response action using removal
authority must be authorized with an action memorandum.
This includes emergency, rime-critical and non-time-critical
removals. The action memo is the decision document and
justifies the use of removal authority as required by the NCP.
REGION: To what extent are remedial balancing criteria
used in non-time-critical removal response decisions?
Debbie Dietrich: Generally, non-time-critical removal
(NTCR) actions are focused on problemsof relatively limited
complexity and scope. Consequently, the NTCR decision
process is a streamlined version of the RIPS/ROD process.
The nine cri teria used in remedial decision-making will not be
applied individually; for NTCRs, these criteria have been
collapsed intothreecategories: effectiveness, implementabiiity
and cost. These categories will be the basis of the alternatives
analysis, which will lead to the selection of the NTCR response.
REGION: What does the $50 million set-aside
cover?
Debbie Dietrich: These funds are for removal or remedial
response work that will contribute to early action at NPL
sites. Unless part of the response action, the funding should
not be used exclusively for site analysis, response planning, or
negotiations. Unplanned funding for these activities may
come from approved reallocarions of RI/FS and design
budgets or the regular removal allowance. The set-aside
fundsareallocatedon a first-come, first-served basis. Regions
should submit proposals directly to the Emergency Response
Division.
REGION: What is EPA's policy on State deferral under
SACM?
Larry Reed: Superfund currently does not defer cleanups to
the States. Deferral to the States and PRFs was proposed in
1988 in the draft NCP. There was considerable opposition
from Congress and environmental groups, and the
Administrator agreed not to carry the issue any further. EPA
should work with the States to appropriately prioritize the
"worst sites" with regard to threats to human health and the
environment. This prioritization is for establishing the order
in which sites are addressed, not to remove sites from further
consideration. Tr^Adrairustrator'sSuperfund Administrative
Improvements study is reevaluating the usefulness and
feasibility of State deferral.
REGION: How does the Long-Term Contracting
Strategy (ITS) support SACM?
Tom Sheckells: The Long-Term Contracting Strategy
(LTCS) supports SACM in several ways. The LTCS was
designed to gain contract flexibility beyond the services
provided to only one particular program area. The new
contracts are structured to support functions, rather
than specific program areas.
For example, Field Assessment capabilities will
be available in the Superfund Technical Assessment and
Response Team (START) contracts and will provide
flexibility to cross program areas to serve multiple
Regional personnel. START is a merge of what used to be
the TAT (removal) and FIT (remedial) contracts. Many
of the underlying principles of SACM, such as expanding
short-term responses, were anticipated in activities
under the LTCS. One example of this is the Emergency
and Rapid Response Service (ERRS) contracts. The
Regions felt that Regional management of the contracts
would lead to improvement in oversight and contractor
responsiveness. This also provides maximum support
to the Regional Decision Teams (RDTs).
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REGION: Since many of the SACM/LTCS contracts
willbe under thepurview of theRegions,will appropriate
resources be provided to the Regions to properly manage
the contracts?
Tom Sheckells: There will not be additional resources for
Superfund; however; the workload model for Superfund is
currently being revised, with active Regional participation, to
more accurately reflect the resource distribution needs of the
program. Contracts management is and will continue to be an
important part of doing business responsibly under
Superfund; contracts management will have to be given
appropriate weight in the overall resource distribution. The
Administrator has made it dear that EPA managers are to
adopt a philosophy of " management over mission*' in an
effort to "effectively leverage the Agency'sresourcestoprotect
the environment." Hence, contract management issues will
need to be addressed and the necessary resources devoted to
them.
REGION: Will there be adequate capacity in the
contracts to handle SACM activities? Will there be
extramural funds available to add to the contracts?
Tom Sheckells: The Regions have formed work groups
to put together plans for the implementation of LTCS and
how they will address various issues. One of the issues
currently being addressed as Statements of Work and
procurement packages are put together is contract
capacity in support of SACM activities. If there are
specific concerns about a contract or area of SACM, you
should contact your Regional LTCS lead. Contracts will
be designed to best support the streamlined process of
One Program. While no additional resources are expected.
there may be shifts in resources from different contract areas.
to meet the demands of the program.
REGION: Are there any limitations on
using the Emergency and Rapid Response Services
(ERRS) contracts for early actions?
Debbie Dietrich: There are no hard and fast limitations on
the use of the ERRS contracts. Though the first priority must
be given to emergency and time-critical actions, ERRS contracts
may also be used for non-time critical removals and early
actions using remedial authority.
Use of the ERRS contracts will be limited, obviously,
by their capacity. The amount of early remedial responses
to be performed by the ERRS contracts must be determined by
the Regions and built into all new contracts. The current ERRS
contracts do not allow for a significant amount of work over
the removal needs.
Currently, the OSCs provide on-site supervision of ERR3
contractors. Use of the ERRS contracts will be determined by
OSC staffing levels and resources. Some Regions may train
Remedial Project Managers to oversee and manage ERRS
work for early remedial and non-time critical removal response
actions. (See OSWER Directive #9242.2-07FS).
REGION: How does the Delivery of Ana lytical Services
(DAS) Strategy support SACM?
Larry Reed: The DAS Strategy decision gives the Regions and
RDTs maximum flexibility in determining the best analytical
contract structure to meet its needs.
NOTICE: The policies set out in this fact sheet are not final Agency action, but are intended solely as
guidance. They are not intended, nor can they be relied upon, to create any rights enforceable by any parry
in litigation with the United States. EPA officials should follow the guidance provided in this fact sheet,
or may act at variance with the guidance, based on an analysis of site-specific circumstances. The Agency
also reserves the right to change this guidance at any time without public notice.
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r
SACM ISSUE EXCHANGE
FAX TO: Katie Daly (Office of Emergency and Remedial Response)
Phone #: (703)603-9026
FAX*: (703)603-9133
Issue/Recommendation
Contact Information
Your Name and Office: Your FAX #:
Your Phone #: Date:
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