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                                                    OSWERy'9833.0
                    GUIDANCE MEMORANDUM


                              ON


        USE  AND ISSUANCE OF ADMINISTRATIVE ORDERS


                            UNDER


                       SECTION  106 (a)


                          OF CERCLA
                                                   Received


                                                  JAN 2 8 2000
                                               Enforcement & Compliance Docket
                                                   & Information Centsr

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                        TABLE OF CONTENTS

I,        Introduction  ...........
II.       Requirements for Issuance and Scope
          of §106  (a) Administrative Orders  .	4

          A.   Necessity for "Determination"  ...  	  5


          B.   Necessity for Actual or Threatened
               Release of Hazardous Substance  .  	   6
          C.   Necessity that'Release or Threat
               of Release be From a Facility	7

          D.   Necessity for Existence of Imminent
               and Substantial Endangerment ...  	   7

          E.   Notice to Affected States	  9

III.      Persons "to Whom an Order May Be Issued	10

IV.       Criteria for Issuance of §106 Orders	  .   11

          A.   Responsible Parties' Financial Status	12

          B,   Number of Responsible Parties Subject  to
               the Order	  .   13

          C.   Specificity of the Necessary Response  Action  .  14

          D.   Agency's Readiness to Litigate the Merits
               of the Order	.16

          E.   Competing Consideration 	   16

V.        Orders Relating to Removals and Remedial Actions  .   17

          A.   Immediate Removals ......... 	  17

          B.   Planned Removals and Remedial Actions  ....   19

VI.       Procedures for Issuance of §106 Orders	19

          A.   Planned Removals and Remedial Actions  ....   20

          B.   Immediate Removals 	 .....  21

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                         C,   Conference Procedures
       -   D.   Modification, ???? or Stay of        .  •
               the Order	,	   24

VIII.     Procedure  if Order Not Obeyed	  .  24

IX.       Note on Purpose and Use of This Memorandum  ..... 25
Appendix A:  Notification Letter
Appendix B:  Sample §106 a Administrative Order

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                              WASHINGTON DC 20460
   SUBJECT:   Guidance Menoran^n-
   ens  Assistant  Administrator f-- c.
   waste and  Emerge^ Response     ~

                    ' c^. "r-
            -c-jrtr.ey y.  ric-

            Special Counsel for En forc^eV?-
  T0:       Regional Administrators, R^i
            R
                                -  r
         Counsels, Recrc ?~x
Air and Waste Manace-,orr D
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                                2                   OSWER =  9833.0


endangerment to the public health or welfare or  the environment


because of an actual or threatened release of a  hazardous
      •a-

substance from a facility."  A fine not exceeding $5,000  per day


may be imposed for willful violation, failure or refusal  to


comply with a §106(a) Order  (Order), and punitive damages of up


to three times the cost of clean-up of the site  may be imposed


under §!07(c)(3)  for failure, without sufficient cause, to


properly provide removal or remedial action pursuant to such an


Order.  In -view of the magnitude of these penalties, the  Agency


expects that the regulated community will comply with


administrative Orders.  At the same time, the Agency's obligation


is to ensure that Orders are properly issued.


     It is the current policy of EPA that, whenever possible,


parties who have caused or contributed to a release or a  threat


of a release of hazardous substances at a site should rectify the


problems at the site.  This action is necessary to ensure that


the Agency efficiently manages the limited funds available under


CERCIA and to ensure that. the. maximum number of sites are


addressed.


     Accordingly,  after the Agency discovers a site and in


advance of completing a Remedial.Investigation and Feasibility


Study (RI/FS),  (and has conducted an endangerment assessment, or


their equivalent),  responsible parties normally will be sent a


notice letter requesting them to clean up the site.   Following


completion of the feasibility study,  the Agency normally engages


in discussion with responsible parties in an attempt to obtain

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promptly the agreement of such parties to voluntarily undertake



the necessary response actions.  If the discussions are



successful, the terms of the agreement will be embodied in a



judicial consent decree or a §106 administrative consent Order.



     In circumstances where the Agency wishes to compel a



responsible party to undertake the response actions, including



instances where no settlement can be reached, the Agency will



consider issuing a unilateral §106 Order in accordance with this



guidance.



     The administrative enforcement authority is an important



component of the Agency's enforcement program authorized under



CERCLA.  This guidance is being issued to assist the regional



offices in developing and maintaining an effective CERCLA            (~



administrative enforcement program.  The effectiveness of the



program will be enhanced as site remedies are implemented by



Respondents in compliance with administrative orders, and as



enforcement of Orders with which Respondents are not in



compliance is successfully and expeditiously pursued by EPA.  The



Agency will aggressively defend judicial challenges to Orders and



enforce instances of non-compliance to validate the CERCLA



administrative enforcement program.  Regional offices should



issue Orders consistent with the criteria and procedures



contained in this guidance to ensure the legal sufficiency of the



program.



     The §106 administrative order authority provides strong



incentives for Respondents to undertake expeditiously response       \

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actions deemed necessary by EPA to ensure protection of public

health gr welfare or the environment.  Therefore, Regional

Offices are urged to consider the use of unilateral CERCLA

administrative orders in every case where compelling enforcement

authority is necessary.  Criteria are provided herein to  assist
         *
regional offices in determining whether Orders are appropriate in
                                           C.e/LCL.,T
any case.  It is essential that a balanced  ?-?-?-?  enforcement

program is implemented by EPA, combining administrative and

judicial enforcement authorities, to ensure protection of health

and the environment from the hazards of releases  or threats of

releases of hazardous substances.

II.-  Requirementsfor Issuance and Scope ofSection 106 CERCLA
     Orders                  ^  .

     A comparison of §106(a) and §7003 of the Resource

Conservation and Recovery Act (RCRA) reveals similarities in the

two sections, and therfore many of the criteria for issuance of a

§7003 Order also apply to §106 Orders.1   In many situations,

either Order would be appropriate.  Where the hazardous

substances are also "hazardous waste" under RCRA, the Order-

should cite the authority of both sections.


     Section 106(a) of CERCLA provides as follows:

     In addition to any other action taken by a State or  local
     government, when the President determines that there may be
     an imminent and. substantial endangerment to  the public
     health or welfare or the environment because of an actual or
                                •§
     1Guidance on the ftse of RCRA ^§7003 administrative orders may
be found in a memorandum entitled, "Issuance of Administrative
Orders Under Section 7003 of the Resource Conservation and ,
Recovery Act" dated September 11, 1981.

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                                  5                  OSWER = 9833.0

       threatened release of a hazardous substance from a facility,
       he may require the Attorney General of the United States to
       secure such relief as may be necessary to abate such danger
       or.threat... The President may also, after notice to the
       affected State, take such action under this section
       including, but not limited to, issuing such orders as may be
       necessary to protect public health and welfare and the
       environment.2

       In order for an Order to be issued, the following legal pre-

  requisites must be met:

       A.   Necessity for a Determination Based Upon Evidence

       A determination must be made that, because of a release or

  threat of a release, an imminent and substantial endangerment may

  exist.  This determination will depend upon documentary,

  testimonial, and physical evidence obtained through

  investigations and inspections.  Other information concerning the

  nature of the threat posed by a site may already be contained in

  Agency files, such as data generated pursuant to §103 of CERCLA

  or the permit and notification sections of RCRA.  The Order,

  therefore, must include a finding that an imminent and

  substantial endangerment may exist, in order to ensure that this

  statutory requirement is met.  (See sample order. Appendix b,

  Finding No. 7).
        The President has delegated his authority under this
  Section to the Administrator of EPA and the U.S. Coast Guard by
  Executive Order No. 12316 dated August 24, 1981.  EPA and the
  Coast Guard have entered into a Memorandum of Agreement dated
  October 9, 1981, that all site-related releases in the Coast
  Guard's jurisdictional areas (coastal zones, Great Lakes, ports
  and Harbors) shall be the responsibility of EPA.

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     B.   Necessit   for Actual or Threatened Release of Hazardous
          Substance      _LC^-t^lS. m^cvcr      .             ,
                                -o- NJ^C^^A    _
     Section  106  requires  ??^?-?--??? or threatened release
                         • t
of a hazardous  substance from a facility.   A "hazardous

substance" is defined  in Section 101(14)  of CERCLA, and is

generally any substance, waste or pollutant designated pursuant
           .•iC-'K*}    •iuOftv,           '              '     '
to Sections ??-?-?;'and ?-?-??- (A)  of the Clean Water Act, Section
k;            ,          f-.i.i-«^i \-\^.'<-,-i'  •  .
TSCA or Section -?-?-? - of CERCLA,  kCrude oil, •??-?-? :, natural gas, and

liquified natural gas  are  exempted from statutory coverage.)

     Whether a  release from a facility is "actual" or

"threatened" primarily depends upon temporal considerations.

Actual releases should be  observable in some form,  either

visually or through analysis  showing contaminants present in

samples of soil,  water or  air.   A "threat" of a release, on the

other hand, involves releases which have yet to occur or have yet

to find their way into the environment.  A bulging, tank

containing a  hazardous substance in which pressure has built up,

and  a surface impoundment  which is about to overflow because of

heavy rainfall, present obvious threats of a release,  A threat

is also presented by  corroding or leaking drums containing

incompatible  wastes mingled in a common area.  Accordingly, the
   •  3A "release  is  defined  in  CERCLA S101(22)  as "any spilling,   V
 leaking, "pumping, pouring,  emitting, emptying, discharging,  .       x
 ejecting,  escaping,  leaching, dumping, or disposing into the         v
 environment," with certain specific exemptions (e.g. release
 solely in  work place; engine exhaust; release of certain nuclear
 material;  and normal application of fertilizer).

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                                7                  OSWER =  9833.0    s

determination of whether a  "threat" of a release warrants

issuance of an Order is a judgement decision to be made on  a

case-by-case basis.

     The nature of both the hazardous substances present at the

site and the release or threat of release 'should be set forth as

findings in the order, together with the bases for such findings.

     C.   Necessity That Releaseor Threat ofRelease be From a
          Facility

     The release or threat of release must be from a "facility,"

which is defined in CERCLA $101(9) as:

     (A) any building, structure, installation, equipment,  pipe
     or pipeline (including any pipe into a sewer or publically
     owned treatment works), well, pit, pond, lagoon,
     impoundment, ditch, landfill, storage container, motor
     vehicle, roiling stock, or aircraft, or (B) any site or area
     where a hazardous substance has been deposited, stored,         ('
     disposed of or placed, or otherwise come to be located; but
     does not include any consumer product in consumer use  or any     •
     vessel {a ^atercraft or other contrivance used, or capable     'v
     of being used, as a means of transportation on water).

     This definition of "facility" includes on-shore or off-shore

sites,  including land transportation facilities, from which

releases or threats might originate.  The Order must specify the

physical location that is the source of the release.

     D.'   Necessity- for ExistenceofImminent and Substantial
          Enda nge rment

     Evidence presented to support the issuance of''§106 (a)  order    ''/

must show "that there may be an imminent and substantial

endangerment" to public health or welfare or the environment.

     The words "may be" indicate that Congress established  a

standard of proof that does not require a certainty.  The            -

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evidence need not demonstrate that an imminent and substantial

ehdangerment to public health or the environment definitely
      -r
exists.   Instead, an Order may be issued if there is sound reason

to believe that such an endangerment may exist.

     Evidence of actual harm is not required.  As the Court

stated in Ethyl Corp. v. EPA, construing, an endangerment

provision in the Clean Air Act:

          The meaning of "endanger" is not disputed.  Case law
          and dictionary definition agree that endanger means
          something less than actual harm.  When one is
          endangered, harm is threatened; no actual injury need
          over occur.  (541 F.2d 1 at 13, footnotes omitted,
          original emphasis,  D.C.  Cir.,  cert. den. 426 U.S. 941
          (1976).)

     It should also be noted while the risk of harm must be

imminent in order for the Agency to act under §106, the harm

itself need"not be.  (See the legislative history to the

"imminent and substantial endangerment" provision of §1431 of the

Safe Drinking Water Act, H. Rpt. 93-1185 at 35-36.)  For example,

EPA could act if there exists a likelihood that contaminants

might be introduced into a water supply which could cause damage

after a period of latency.  One must judge the risk or likelihood

of the harm by examining the factual circumstances, including,

but not limited to:  1) nature and amount of hazardous substance

involved. 2)  the potential for exposure of humans or the

environment to the substance, and 3) the known or suspected

effects of the substance on humans or that part of the

environment subject to exposure to the substance.

     Legal analyses of the concept of imminent and substantial

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4
                                   9                  OSWER = 9833.0    x



   endangerment can also be found in Reserve Mining Co, y, EPA . 514


                                                               '  r   ' /
   F.2d 492 (8th Cir.  1975); U.S. v. Vertac Chemical Co. et al. 429   *

           ''~'~IT,                                                '          S
           a '  -
   F.Supp/-2-23^ (E.D.  Ark. 1980); U.S, v.  Solvents Recovery Service.



   496  F.  Supp.  1127. (D. Conn.  1980); U.S.  v.' Midwest SoIvents"



   Recovery, 484 F.  Supp. 138 (N.D.  Ind.  1980):  U.S. v. Diamond



   Shamrock Corn..  17  E.R.  1329 (N.D. Ohio  1981); U.S. v.  Price.  688



   F. 2d 204  (3rd Cir.  1982) ; U.S.  v. Reilly, _Tar_ajid^Chemical Corp..



   546  F.  Supp 1100  (D.  Minn. 1982).



        The nature of  the endangerment and  the basis for the finding



   of an imminent and  substantial endangerment must be set forth in



   the  Order.   The link between the endangerment and the relief



   mandated by the Order should also be evident.



        E.   Notice  to AffectedStates



        Finally, before an Order may be issued,  the "affected state"



   must be given notice of the  Agency's intention to issue the



   Order,



        The Agency is  not held  to a statutory period of time for



   notice.  Normally,  written notification  to the state should



   precede federal action by at least one week.   Circumstances may



   arise,  however,  where rapid  response at  a site is necessary.  In



   such cases, issuance of an Order may follow an abbreviated notice



   period  or even a  telephone call made by  EPA to the Director of



   the  agency  responsible for environmental protection in the



   affected state.  Written confirmation must follow such telephone



   notice.



        As indicated above, the notification should be directed to

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the Director of the state agency  having jurisdiction over

hazardous waste matters.  A suggested form for a notification

letter is attached to this memorandum as Appendix A.  This  form

also provides the format for oral notice.

     An "affected state" is interpreted to be the state where the

facility is located from which the discharge is.being released or

threatens to be released, and in which the response activity

required by the -proposed order will be taken.  In some cases,

this may involve more than one state, such as where the facility

is located near the border of a state and the hazardous

substances have migrated from the facility located in one state

into another state(s).  In those cases,  all of the states in

which the hazardous substances are found and in which response

activity may be performed pursuant to the order should be

notified.

III. Persons To Whom an Order May BeIssued

     Section 106 does not specify any person or persons to whom

an Order may be issued, but permits the issuance of "such orders
                   * *»
as may be necessary.-;:"  Section 104 (a), however, refers to the

"owner or operator" or "other responsible party"  as the persons

to whom the Agency could look to determine whether clean-up of a

site will be done properly before expending CERCLA funds.

Section 107(a), designating those who shall be liable for

response costs, specifies present owners and operators of a

facility, persons who were owners and operators at the time of

disposal of a hazardous substance, and generators and certain

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transporters who, according to available evidence, contributed
hazardous substances to the facility.  It follows that those same
persons could be recipients of an Order issued under Section
106 (a), (see U.S. v. ^_Ou-tbo_ar.d_ _Marine Corp.. 556 P. Supp, 54, 57
(N.D. 111. 1982).  In addition, in appropriate cases, it may be
possible to issue orders to parties other than those listed in
Section 107(a), if actions by such parties are necessary to
protect the public or the environment.
IV.  Criteri.g for Issuance of JL106 Orders
     Other parts of this guidance document examine the legal
requirements for issuing an Order.  This section's purpose  is to
list specific factors which favor the use of Orders over other
possible enforcement responses.  These factors include:              ^
     »    Responsible parties' financial status
     *    Number of potentially responsible parties
     «    Certainty of the necessary response action
     »   . Agency's readiness to litigate the merits of the order
     The theme common to these .factors is that Orders should be
issued in those situations in which compliance with the terms of
the Order is feasible, i.e., where the Respondents are in a
position to perform the ordered response actions within specified
time periods.  This does not mean EPA must make a pre-issuanee
determination that Respondents will comply with an Order, but
rather'that compliance is practicable.  If the Agency does  not
anticipate compliance with an Order it is considering issuing,
the use of the Order may serve only to delay direct injunctive       '

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action under §106 or the initiation of Fund-financed response.



On the other hand, the Agency may wish to issue an Order in any



situation where the needed response action and the liability



therefore are clear and straight-forward, so that refusal to



comply with the terms of the Order would not, in all probability,



be with "sufficient cause" (CERCLA §107(c)(3)).  Such refusal



would render the Respondent liable for civil penalties or



punitive damages in the event of federal cleanup.



     A.   Responsible Parties' Financial Status



     Before an administrative order requiring remedial work is



issued, the Agency should assess, to the extend possible, whether



the responsible party has sufficient financial resources to



comply with the Order.  Financial information is.available from



several sources:



     •    Agency files contain financial information



          collected as part of the identification of parties



          responsible for the hazards posed by sites on the



         • National Priorities List.



     »    The Securities and Exchange Commission (SEC) requires



          publicly traded companies to submit detailed financial



          statements.  This information is publicly available.



          (Consult NEIC's manual entitled "Identifying



          Responsible Parties" for additional information on



          obtaining SEC files.)



     •    Responsible parties may submit financial information to



          the Agency during discussions or negotiations held

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          prior to. the  issuance of and Order.

     In addition,  NEIC  can provide further  information  on

Respondent's financial^   .  v

     B.   Number_ of Responsible Parties Subject to the  Order

     For two primary reasons, the success of Orders for remedial

action is enhanced where there are relatively few responsible

parties.

     1)'   Coordination  of Response JVgtjLop

     An Order issued to multiple Respondents who are jointly and

severally liable generally will not allocate, individual clean up

responsibilities.4   Instead,  the  Order will  require the same

response action to be conducted by each 'responsible party.

Multiple parties must organize and coordinate their response to

ensure compliance with the order's requirements.  Thus,

compliance with Orders may depend upon group agreement  of each

member's share of the response cost.  In a  large group  of

responsible parties, it may be difficult for the -group  to develop

a consensus on individual liability and perform response

activities as quickly as necessary to abate imminent hazard

conditions at a site.  Accordingly, issuing Orders to all

responsible parties may not be appropriate where there  are a

large number of parties who are unlikely to agree on a  concerted

response.  Instead, the Agency will pursue  judicial remedies or
      However,  the Agency may issue an Order to a Respondent
requiring a response to a discrete, separable aspect of the
hazard at a site, notwithstanding the existence of other
responsible parties or other less divisible problem areas.

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                                14                 OSWER = 9833.0


consider issuing Orders to a selected subset of responsible



parties.



     Even in situations where Orders are issued to a large number



or parties, Agency policy, which should be reflected in the terms



of the Order, -is that each Respondent is individually liable for


compliance with the Order's requirements.  Individual liability
                        •

also extends to penalties and punitive damages imposed by CERCLA



for failure to comply with the Order.



     2)   Supervision •


     After an Order is issued,  the Agency conducts compliance



monitoring at the site to ensure that responsible parties comply



with the terms of the Order.  Although no maximum number of



responsible parties can be specified as optimum, it is clear that


the Agency's oversight responsibility is most effectively


accomplished where there are a limited number of responsible



parties.


     C.   Specificity of the Necessary Response Action



     In order to minimize the potential for confusion between



Respondents and the Agency concerning the required response


action, Orders should be used in situations where the nature of


the required response action has been relatively precisely



identified.  Orders are normally better suited to mandating
                       "i                                            **
                       :.-. i '^~-;-                                       /

discrete tasks such as 3-Q?-?-" removals rather than less exact      V


actions such as planning.  Otherwise it may be difficult for the


Agency to supervise compliance activities, and for responsible


parties to reach agreement on a compliance plan.  In most cases,

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information sufficient to describe the required response actions



will be generated by the RI/FS.



     An Order should contain the following elements (see Appendix



B) :


     •    The steps the Respondent must take to comply with the



          Order;



     •    The effective date of the Order;



  :   •    A mandatory time-table for completion of remedial work;



          and, where appropriate,



     •    A statement to the effect that other actions or orders



          may follow.



     Specific remedial action Orders benefit both the Agency and



responsible parties.  Responsible parties are provided clearly       (



defined compliance standards which will facilitate agreement



among the responsible parties on a remedial plan.  If the



responsible parties then determine that the remedial work is best



^jcomplished by a third party contractor, the Order provides a



basis for their contract negotiations.



     Specific Orders benefit the Agency by reducing the



difficulty of supervision and judicial enforcement.  In



noncompliance situations, the Agency may seek to enforce an Order



in court.  A specific Order provides the court with Agency-



articulated standards by which to judge the responsible party's



non-compliance with its terms.  Therefore, EPA should make every



effort to clearly articulate the response activities required by


                                                                     f"
an Order.

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                                16                 OSWER = 9833.0



     D«   Agency's Readiness to Litigate the Merits of the Order



     After the Agency issues an Order, the respondent may seek



judicial review to stay the Order.  Respondents may challenge



their liability or the appropriateness of the remedy specified in



the Order.  On the other hand,  the Agency may,promptly seek to



enforce the Order in court.  In light of these possibilities, the



Agency must be ready to defend the Order in court at the time it



is issued.  This means that the site problem, the reasonableness



of the required response, evidence of liability, and the Agency's



response to issues raised by the recipient must be thoroughly



documented, and that the documentation be organized and easily



retrievable.  The documentation will constitute the



administrative record for any litigation.



     E.   Competing Considerations



     The absence of the factors listed above may argue in favor



of pursuing a judicial or Fund-financed,  rather than an



administrative, remedy.  For example, EPA should not normally



issue an order if the necessary response actions have not been



clearly identified.  In addition,  Agency enforcement personnel



should strongly consider the judicial course of action if:



     •    the responsible parties have violated provisions in



          several environmental statutes;



     •    the opportunity for public comment on the terms of a



          settlement agreement warrants the use of a judicial



          consent decree, (where there is a 30-day comment period

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          before the decree is finalized)5;  and

     *    there is a need for long terra court oversight of a

          settlement agreement, (such as in cases where an

          agreement calls for separately enforceable response

          milestones prior to completion of the cleanup).

V.   Orders Relating; to Removalsand Remedial Actions

     Guidance on conducting removal actions issued by the office

of Emergency and Remedial Response (OERR) divides the statutory

concept of removals into "immediate" and "planned" removals.

     A.   I mined ia te Remova Is

     Immediate removal actions are to be taken only if a response

is needed within a relatively short time frame to prevent or

mitigate significant harm to human health or the environment, and

such action will not otherwise be provided on a timely basis.

     Orders may be used to compel various immediate removal

measures, including:

     1.   Suspension of activities which aggravate an existing

          release or substantial threat of a release (e.g.,

          active use of a storage tank judged by the OSC to be in

          imminent danger of failure).

     2.   Suspension of activities which interfere with Federal

          removal actions  (e.g., plant traffic in area of

          cleanup).
      However, it should be noted that the Agency is exploring
mechanisms which provide for  public comment on both unilateral
and consent  administrative Orders.  Guidance on this matter will
be provided  at a later date.

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                                18                 OSWER =  9833.0
     3.   Movement or  non-movement of a transport vehicle
          (railway tank car, tank truck, tank vessel) which  is
          the source of a release or substantial threat of a
          release.
    • 4i.   Measures to  limit access, such as fencing.
     5.   Use of readily available equipment, owned by the
          responsible  party, to contain or remove a release
          during the initial stages of a response before the OSC
          is" able to obtain comparable equipment from other
          sources.
     6.   Dikings; construction of benns; or removal of the
          hazardous substance to an approved facility.
(This list illustrates various uses for an Order; it is not an
exclusive compendium.)
     Section 106(a) Orders, both in immediate and non-immediate
situations,  must contain a statement notifying the party of EPA's
authority and the liability that may be incurred by failure to
comply.  As specifically as possible the Order prescribes the
response activity and  sets the date for its completion.  To
ensure enforceability  of the Order, EPA should not undertake its
own CERCLA-funded response activity during the period of time
given to the party to  respond, unless (i) such CERCLA-funded
response activity becomes necessary due to the immediacy of the
release or threat of release or  (ii) the Respondent formally and
unequivocally states an unwillingness to comply with the Order.
In the event the party undertakes response activity, the OSC

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                                19           •      OSWER = 9833.0   x

should remain en-site to ensure that the work is being conducted

in accordance with the Order.

     B,   Planned Removalsand Remedial Actions

     Planned removal situations are those that allow several days

or weeks to execute the response.  Remedial actions, on the other

hand, are generally those intended to provide a permanent

resolution to the release and require a longer time and more

expensive efforts to implement.

     As in £he case of immediate removals,  an Order is available

to compel response measures routinely taken during planned

removal and remedial actions.  "Removal activity" includes

assessment programs to evaluate the nature of the problem, and

removal of material from the site.  "Remedial actions" are those    ^

consistent with a permanent remedy, and include such activity as

capping the area, trenching,  and provision of an alternate water

supply.6  EPA's  position  is that  any  activity that  the Government

night undertake at a site - from plannincr and studies to complete

cleanup-could be ordered pursuant to §106(a).  Of course, the

issuance of more than one Order may be necessary if the cleanup

is performed in stages, or if additional responsible parties

become known to EPA who should participate in the cleanup.

VI.  Procedures for Issuance of gi06(a) Orders^

     CERCLA designates the President as the primary official
                               _
     6See-^101(23)  of CERCLA for definition  of "remove"  or
"removal"/ and^iOi(24) of CERCLA for definition of "remedy" or
"remedial action".  Those definitions contain detailed examples
of the types of activities that fall within these categories.

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                                20                  OSWER = 9833.0



responsible for taking response and enforcement action under the



Act.  The authority to issue administrative orders under §106(a)



has been deiegated to the Administrator of EPA by Executive Order



No. 12316, and redelegated by the Administrator to the Regional



Administrators and the Assistant Administrator for Solid Waste



and Emergency Response (AA-OSWER).   The RAs and the AA-OSWER must



consult with the Associate Administrator for Legal and



Enforcement Counsel (AA-OLEC) prior to exercising this authority.



and the RAs-must obtain advance concurrence from the AA-OSWER.



(See Delegations Manual:  14-14.)  The AA-OLEC has redelegated the



consultation authority to the Associate Enforcement Counsel-Waste



and the Regional Counsels.  The AA-OSWER has redelegated his



advance concurrence authority to the Director, Office of Waste



Programs Enforcement (OWPE).  The Office of Waste Programs



Enforcement will develop and issue criteria in separate guidance



which will be used to evaluate circumstances under which this



advance concurrence requirement will be waived on a Region by



Region basis.  Regional offices are expected to develop strong



administrative enforcement programs, on an expeditious schedule,



which will permit them to initiate and issue legally and



technically adequate administrative orders with only prior notice



to Headquarters.



     A.   Planned Removals and Remedial Actions



     For planned removals and remedial actions, orders are



drafted by  the Regional program office with the cooperation of



the Regional Counsel's office.  The draft Order is forwarded to

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                                21                 OSWER =  9833.0    X
the office of Waste Programs Enforcement for review and
concurrence.  The Regional Administrators will usually issue the
Order and provide prior notice of the action to the state.
     B.   Iinined i a t eReao va 1 s
     For those Orders which require emergency or quick handling,
usually in response to situations warranting an immediate
removal, the following approval sequence will be used:
     The Regional Administrator first must determine whether to
issue an Order based on communication with the OSC and
consultation with Regional Counsel,  The Region then prepares an
order with any supporting information and electronically
transmits the material to the Office of "Waste Programs
Enforcement for review and concurrence.  Notification to the         (
State of our intent to issue the Order should be accomplished
orally, and followed up by formal written notice.
VII. Opportunity to Confer
     Agency policy is to offer parties to whom EPA has issued a
unilateral §106 Order an opportunity to confer with the Agency
concerning the appropriateness of its terms and its applicability
to the recipient.  The conference will help EPA ensure that it
has based its Order on complete and accurate information and help
EPA and Respondents reach a common understanding of how the Order
should be implemented or modified.  The procedures for exercising
this option are communicated to respondents through the text of
the Order itself.  (See sample Order, page 4 of Appendix B.)

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.  *-
                                22                  OSWER = 9833.0
     A.   Planned Removals and Remedial Actions
     Each Order will specify a date when the Order becomes
effective.  For actions other than immediate removals, the
effective date should ordinarily be twenty calendar days from the
day the Order is received by the Respondent.  Certain Orders,
such as those requiring that long term remedial actions be taken,
may warrant a more extensive examination of the facts.  In such
cases, the Order may specify an effective date more than twenty
days removed to permit the Respondent an opportunity to discuss
the Order with the Agency beyond that accorded by the procedures
set forth in Subpart C below.
     If the Respondent seeks to confer with the Agency about the
Order, the Respondent must provide written notification to the
EPA official listed in the Order within ten calendar days of'the
date of receipt.  The conference should be scheduled and held as
soon thereafter as practicable, but prior to twenty days from the
date the Order was received by the Respondent.
     B.   Emergency Situations
     The applicable time periods for the effective date and for
requesting a conference may be shortened, (e.g.,  to 72 and 48
hours respectively^ or the conference procedures may be
eliminated entirely, if the immediacy of the hazard posed by a
site and other surrounding circumstances so warrant.  In the
former situation, the Order should permit the Respondent to
request a conference orally, later followed by written
notification.

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                                23.                  OSWER = 9833.0   (-

     C.   Conference Procedures

     The conference will normally  be  held  at  the appropriate EPA

Regional office and will be presided  over  by  the Regional

Administrator's designee.  However, other  arrangements may be

agreed to for the sake of convenience to the  parties.   At the

conference, EPA should be prepared to provide the Respondent with

information sufficient to explain  the basis for  the Order and to

promote constructive discussions.  The Respondent will have the

opportunity to ask questions and present its  views through legal

counsel or technical advisors.  The schedule.and agenda for the

conference will be left to the discretion  of  the EPA official

leading the conference, as long as the Respondent receives a

reasonable opportunity to address  relevant issues.                  f~

     Following the conference, a written summary of the

proceeding must be prepared, signed by the Agency official who
                              -f(L. (_'« I 1V i\  <£\C- H- IN_V S.V -S* £>v-V « s- * • •••*•<;•:
presided over the conference:"" . ?3.?.2333-??-?-?-?-?-?-???? - ': —-             w
                            »*
     •    a statement of the date(s)  and attendees of any
                        <-Ad
          conference(s)?1L?T>T; and

    ' .•    A description of the major  inquiries made and views

          offered fay the Respondent contesting the terms of ^the

          Order.

In addition, the presiding official must prepare a statement

which  addresses the significant  arguments  raised by the

Respondent and which recommends  whether and how the Order should

be modified, together with the reasons therefor.

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'» *••
                                 24                  OSWER = 9833.0


     . D.   Modification, Revocation, or Stay of the order


      Based upon a review of the file upon which the Order


 initially was based, any probative information or argument


 proffered by the Respondent following receipt of the Order, and


 the recommendation of the presiding official, the issuing


 official may modify or revoke the Order.  Any modification to the


 Order must be communicated to the Respondent as part of a copy of


 a written statement containing the elements listed in Subpart C


 above,  The~original should be 'kept in the Agency files along


 with the evidence supporting the order, copies of written


 documents offered in rebuttal by the Respondent during the


 conference, and a copy of the request for a conference.


      The issuing official may also stay the effective date of the


 Order if the conference process could not be completed within the


 specified time period.  Before substantially modifying or


 revoking an Order, the issuing official must consult with the
                                                           O'-U •-'•'• '-

 appropriate Headquarters or Reginal counsel and obtain the £???;


 VIII.  .    Procedure If Order Is Not Obeyed


      In the event the party to whom the Order is issued does not


 comply with its terms, the Agency must quickly decide whether to


 attempt to enforce the Order by referring the case to the


 Department of Justice for filing of a suit to force compliance,


 or whether to undertake cleanup of the site by use of CERCLA


 funds, and then file suit against the party for reimbursement of


 the costs expended plus statutory penalties for failure to comply


 with the Order.

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                                25                 OSWER =  9833.0    ,

     The determination of which action to pursue depends on the

type of response action to be taken.  Obviously, if an immediate

removal action  is required by the hazard at the site, EPA will

clean up the site and attempt recovery of costs and penalties in

a subsequent recovery action.  The same course of action applies

to a planned removal where the removal action must be quickly

undertaken and  cannot await the filing of a suit.  However,           /

                                                    J-*    •          /
planned removal or remedial responses which required7 an extended   v

period of time  to perform, and in which initiation of action may

be delayed for  a brief period without jeopardizing human health

and the environment, may allow sufficient time for the filing of

a suit to enforce the Order, or at least that portion of the

Order which calls for the planned removal or remedial action to      f
      \
be taken.

     Other factors which way enter into this determination

include the strength of evidence and the financial ability  of the

party to perform the desired response activity.  The decision of

which option to pursue is initially to be made by the Regional

Administrator,  in the same manner and using the same procedures

as previously prescribed for any other enforcement action.  The

Regional Administrator's recommendation is then forwarded to

Headquarters for action.

IX.  Mote or._...P_mrpos_e_and Us_e_'_o_f_ This Memorandum

     The policy and procedures set forth herein, and internal

office procedures adopted pursuant hereto, are intended solely

for the guidance of attorneys and other employees-of the U.S.        (

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                                26                  OSWER = 9833.0

Environmental  Protection Agency,   They are not intended to nor do


they constitute  rule-making by the Agency, and may not be relied
       -,"
upon to create a right or benefit,  substantive or procedural/


enforceable at law  or  in equity,  by any person.  The Agency may


take any action  which  is at variance with the policies or


procedures contained in this memorandum,  or which is not in


compliance with  internal office procedures that may be adopted

pursuant to these materials.


     Attached  to this  memorandum  as Appendices A and B are


     «    A sample  letter to a state providing notification-of


          the  Agency's intent to  issue a §106 Order; and


     »    A sample  Order.


     If you have any questions or problems concerning any matter
                                            •r.u;f>—  £3*.3L-'-ijf ;••-;)
contained herein, please call the Director,  7333-*; _(J233-?-J, or     V/


Russell B. Selman (426-7503)  or Steve Leifer (**??•)  of the Office
                                            ( .^s-i-'-i^o  '
of Legal and Enforcement Policy.




Attachments

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                                                             OSWER =9833.0    /

                                     Appendix A

                              STATE  NOTIFICATION  LETTER  .                . .


         CERTIFIED MAIL
         RETURN RECEIPT REQUESTED


         Mr. R. Jones
         State Agency
         Division of Environmental  Control

         Dear Mr. Jones:

              Enclosed  for your  information  is a copy  of an  order (stamped
         "DRAFT" and ^CONFIDENTIAL") that the Agency intends to issue on
         or after__ tdate)  ,  to  the XYZ Company, pursuant  to Section
         106(a) of the  Comprehensive Environmental Response  Compensation,
         and Liability  Act of 1980, (42 use  9606).  The order requires
         certain activities to be taJcen at the company's site located at
            {IgcationL   •  Please  'refer to  the  enclosed copy -of the
         proposed order for the  specific actions required  of the coropany
         and the time within  which  such actions  must be taken.   If you
         have any comments or questions concerning the order,  please          f
         contact     fEPA off icialj_   at   (offJ^geJ _ .

                                  Sincerely  yours.
                                  Assistant  Administrator  for
                                  Solid Waste and Emergency  Response

                                             (or)

                                  Regional Administrator
                                                 designees)
         Enclosure

         cc:  Honorable J. Smith, Governor
#»

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                                28                 OSWER = 9833.0

                            Appendix B

                           SAMPLE ORDER
CERTIFIED MAIL
RETURN RECEIPT REQUESTED

          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


In the Matter of                        )
(Name of Person,                        )
 Firm or Corporation)                   )
                                        }    Docket No._	
Proceeding Under Section 106(a) of the  }
Comprehensive Environmental Response,,   }
Compensation and Liability Act of 1980  )
(42 USC Section 9606 fan   	  )


                              ORDER


     The following Order is  issued on this date to  (insert name
and address of person,firm or corporation, along with facility
name or place of business if the Respondent is not the owner or
operator)  ("Respondent(s)"), pursuant to §106(a) of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA) (42 USC 9606(a)), by authority delegated to
the undersigned by the Administrator of the United States
Environmental Protection Agency  (EPA).  Notice of the issuance of
this Order has heretofore been given to the State of 	.

     There is an imminent and substantial endangerment to the
public health and welfare and the environment due to a  (threat of
a release) (release) of  (a) hazardous substance(s) as defined in
§101(14) of CERCLA  (42 USC 9601(14)), from the following location
(the "Facility"):

               (insert legal description,  if known;
             otherwise,  use  street or route address)

This order directs you to undertake action to protect the public
and the environment  from this  endangerment.

                     FINDINGS AND CONCLUSIONS

1.    (Choose one or  more of  1A through  IE, as appropriate under
     the factual situation of  the case.  Do not  include
     headings.)

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                                                    OSWER = 9833.0    ,

1A. | ^Present Owner)-Respondent  is  nowf  and  has been since	.     ^
19	7 the  (owner)  (and^ *^perator^|J!—of the  Facility ,  as determined
from (source or information),]^

IB. I-fiFormer owner/operator) - Respondent  was,  from  	,
19	, until 	, 19	 the (owner) tand^Cpperator) of the
Facility, as determined from (source of information).  During
that time hazardous substances, including those  described herein,
were disposed of at the facility.  Respondent sold or otherwise
transferred and conveyed the Facility,_to  	 on 	,
19	_, according to (property records)JTj.

1C. L(Generator) - Respondent (disposed of)  (arranged,  by
contract or agreement, for the disposal or  transport for disposal")
of hazardous substances at the Facility as  determined from
(source)/)]. -                     •                                   v'
                                                                     x'
ID, [.((Transporter) - Respondent  chose to accept hazardous        "^
substances for transport ,to, and  disposal at,  the Facility as      /'
determined from (source)J'/*                                         ^
                         -I
                                                                   v"
IE. | ftOther Party)  (Insert reasons why  ordered actions are
necessary to facilitate the abatement  of the  hazard,  prevent the
aggravation of the hazard, or otherwise  protect the public health
and welfare and/or the environment.),)'' j           "                  •.//"

2.   (Describe the nature of the  facility.)

3.   On or about the 	 day of  	,  19	,  an inspection
of the Facility was conducted by  	(names)      (a)  duly
authorized representative(s) o^f (EPA,  State agency).   At the time  "•-"'
of that inspection, the inspectors observed the following
conditions existing at the Facility:

     A.   Approximately 1000 drums of  liquid,  semi-solid and
          solid material, which were leaking,  without covers and
          in various stages of corrosion,  rusting and other
          deterioration, located  directly on  the ground.
          Material leaking from said drums was observed running
          approximately 25 yards  across  the site into Crystal
          Creek, which adjoins the  Facility,  and which is a
          tributary of Pristine River, a navigable water.
          According to records at the  Facility, materials
          contained  in the drums  include:

                  (describe hazardous substances)

     B.   An area  in the Facility (the "Landfill area") of
          approximately four  (4)  acres in size, without
          vegetation, front which  leachate was observed flowing
          approximately forty  (40) yards into Crystal Creek.
          Vegetation had been killed in  the area of the leachate.

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                                ,--30 ,                 OSWER = 9833.0
                                v *- " ,x

           According to records at  the Facility, the following
           hazardous substances had been placed in the  Landfill
        __„..  area:

                           (List hazardous substances-
                          then continue with the following)

      At the time of the inspection, 	 samples  of  the drummed
 waste, samples of the leachate from the Landfill area, and 	
 samples of (soil, surface water, aroundwater, air,  etc.i  were
 obtained by the inspector(s) .

 4.    An analysis of the samples taken at.the time of the
 inspection disclosed the presence at the Facility of the
 following substances  in the concentrations set forth:

            ~   (list hazardous substances and concentrations
                confirmed by analysis - then continue with
                following sentence)

      These substances are "hazardous substances11 as defined in
 §101(14) of CERCLA, and are subject to the terms and provisions
 of  that Act.

 5.    The hazardous substances  described above are treated  or
 disposed of at the Facility in such manner that they (are  being;
{threaten to be )  released and  discharged from the Facility into
 the (soil, groundwater, surface water, air,  etc.)  and other parts
 of  the environment.

 6,    (Describe population or environment at risk and route of
 exposure).  Exposure to said hazardous substances may cause
 illness, disease, death or other harmful effects to plant  and
 animal life and humans.

 7.    The (release)  (and/or)  (threat of release)  of said hazardous
 substances may present an imminent and substantial endangerment
 to  public health and welfare and the environment.

 8.    In order to protect human health and welfare and the
 environment,  it is necessary that action be taken to contain and
 terminate the (release) (and/or)  (threat of release) of hazardous
 substances from the Facility into the environment.

                             „ORDER

      Based upon the foregoing  determinations and Findings  of
 Fact,  it is hereby ordered and Directed that:
                                 A***} bd.         s
      (Note -  the Respondent may^be ordered to undertake any
      response activity that ??-?-?-' required to protect public
      health,  333-23'?"'the environment,  including,  but not limited
               -~--.

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                                      .*v
                               l'~31 ,/                OSWER = 9833.0   f
      -W, _                      \^s           .                       C
      y^T those actions which the government  is  authorized to
      carry  out under  CERCLA.)
      (Insert  here  the  response actions which EPA directs
     Respondent to take  at the site.  Each activity,  (i.e,J
     redrumming of waste, construction of fencing,  levees,
     submission of plans for  installation of monitoring wells,
     etc.), and the date for  compliance with each activity,
     should be listed  separately. )

     (Insert  a statement to the effect that other orders or
     action may follow.)

              EFFECTIVE DATE - OPPORTUNITY TO CONFER
     This Order is effective on the twentieth calendar day
following receipt thereof by Respondent ,/ and all times for
performance'*~of response activities 333-2J?- be calculated from  that
date,   (Note:  For immediate removal situations, the effective
date will be considerably abbreviated.)

     You may, within ten calendar days after receipt of this
Order, request in writing a conference with (Official) to discuss
this Order and its applicability to you.   (Note:  For immediate
removal situations, the time for requesting a hearing will be
abbreviated.  In addition, the Respondent  should be informed that
he or she may make an oral request for a conference, to be
followed up by written notice within two or three days.)

     At any conference held pursuant to your request, you may
appear in person and by attorney or other  representatives for the
purpose of presenting any objections, defenses or contentions
which you may have regarding this Orde*-.   If you, desire such a
conference, please contact (name. title, address ancj telephone
number of EPA contact) within the 'time set forth above for
requesting a conference.

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                                J?2/                OSWER =>9833.0

                   PENALTIES FOR  NON-COMPLIANCE  /"    ^    y  p^xO. I-
        j                              OCCUvYi      /            .^Of fvvG
     Respondent is advised that willful violation or  failure  or
refusal"" it o comply with this Order, or any portion thereof,  =^?9- \^c^~j

for each day  in which such violation •?-?•?? or such failure to
comply  continues.   Failure-to comply with this Order,  or any
portion thereof,  without sufficient ??T? subject you  under ?-??-? 3s'c
of CERCLA  (42  u.s.c.  §9607(c)(3)), to\liability for punitive
damages in an  amount  up to three time^ the amount of  any costs
incurred by the government as  a result of your failure to take
proper  action.   .                      \ , ^ _ Cv, ^--
     WITNESS my  hand in the City of    ; _ , state of
                                                            _
as ^tj^tl^ of authorized EPA issuing official, on this _ day  of
   ....: _ , 19 _ .    "'.
                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                     By; _

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