UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
1 5 2C13
OFFICE OF
SOLID WASTE AND
EMERGENCY RESPONSE
OSWER Directive 9200.2-131
MEMORANDUM
SUBJECT: Superfund Special Accounts Management Strategy for 20 1 3 - 20 1 5
FROM: James E. Woolford, Director ->^. i,
Office of Superfund Remediation and Technology Innovation
Office of Solid Waste and Emergency Response
TO: Regional Counsels, Regions 1-10
Superfund National Program Managers, Regions 1-10
Assistant Regional Administrators, Regions 1-10
On behalf of HPA's Special Accounts Senior Management Committee, this updated Superfund Special
Accounts Management Strategy ("Strategy") sets forth EPA's plan for ensuring that special accounts are
successfully used nationwide to support cleanup at contaminated sites. The goal of the Strategy is to
continually improve the use, management and monitoring of special accounts. This Strategy serves as a
roadmap for EPA Regional and Headquarters personnel who are responsible for the oversight and
management of special accounts. This work includes: planning; monitoring; gathering, evaluating, and
reporting data related to special accounts; capacity building; training; and coordinating with all
interested parties. EPA has developed and updated a workplan to undertake the activities outlined in this
Strategy (see Attachment 1) and will evaluate and revise the Strategy after three years.
Through the development and implementation of this Strategy, EPA intends to achieve the following
objectives:
• Continue to implement a nationally consistent approach to managing and monitoring special
accounts;
• Maximize the use of special accounts to support site cleanups;
• Ensure the proper tools are available to maximize the use of special account funds; and,
• Improve coordination and transparency on the use of special accounts.
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
-------
The Superfund Special Accounts Senior Management Committee ("Committee") serves as the oversight
body for the Agency's management and use of special accounts.1 The Committee, comprised of senior
managers from the Office of Superfund Remediation and Technology Innovation (OSRTI), Office of
Site Remediation Enforcement (OSRE), Office of the Chief Financial Officer (OCFO), and lead Regions
for both Superfund and Management, oversees the implementation of this Strategy.
I. Background and Purpose
Special accounts are site-specific, interest bearing sub-accounts within the Superfund Trust Fund
established through settlements and used to fund site-specific work. The Agency's goal for the
establishment and use of special accounts is to provide cleanup dollars collected under an agreement
with Potentially Responsible Parties (PRPs) at sites where future response work remains, which
preserves annually appropriated resources for sites without viable PRPs. Use of special account
resources helps to achieve cleanup without relying solely on EPA's annual Superfund appropriations.
Special accounts have been established and used in the Superfund program for over two decades. Since
program inception, EPA has collected more than $3.8 billion in settlement funds, earned over $400
million in interest, and used more than $2.5 billion for the cleanup of hundreds of Superfund sites.2
While some special accounts have a large balance available, the vast majority (78%) of open special
accounts have less than $ 1 million available.3
As an Agency, we have been successful at collecting settlement funds to be placed in special accounts
and directing these funds towards future response costs; more than 58% of all funds made available
through special accounts over time have been obligated or disbursed for site response work. Through its
enforcement efforts, the Agency continues to receive site-specific settlement funds that are placed in
special accounts each year, so the extent of progress on actual obligation and disbursement of funds may
not be apparent upon review solely of the cumulative available balance. Annual reductions from using
current special account balances are offset by new deposits for future response work.
The Agency's success in collecting funds from PRPs for future response work and placing those funds
in special accounts has required EPA to place a greater focus on managing and using those funds.
Through implementation of this Strategy, the Agency will manage special accounts to:
1) Ensure available special account funds are needed for future site cleanup work and are being
used as expeditiously as possible;
2) Ensure special account funds rather than appropriated resources are used for response work
as appropriate;
3) Reclassify and transfer funds to the general portion of the Superfund Trust Fund when they
are no longer needed for future cleanup work at a particular site;
4) Close special accounts where funds are no longer required for work at the site and no future
deposits are expected, and,
5) Continue special accounts data collection to more effectively monitor the planned and actual
uses for these funds.
More information on the Superfund Special Accounts Senior Management Committee can be found at;
http://intranet.epa.gov/osrti/topics/speeial accounts.html
2 As of October 1, 2012, 1,175 special accounts have been established for 935 sites. The $2.5 billion used for cleanup
includes $2.2 billion disbursed and S270K obligated but not yet disbursed for cleanup work.
3 Based on Compass data from the Compass Data Warehouse on October 1,2012.
-------
II. Special Accounts Management Strategy
The establishment, planning, and use of special accounts require extensive coordination among the
Regions and Headquarters. EPA has implemented a number of management practices to help ensure that
the funds in special accounts are managed effectively to support cleanup at Superfund sites. To improve
upon these practices, EPA's management strategy focuses on four main areas: 1) Coordination and
Transparency; 2) Planning and Use of Special Accounts; 3) Monitoring Special Accounts; and 4)
Regional Support, Guidance and Training.
1. Coordination and Transparency
Intra-Agency Coordination
EPA has focused attention on improving coordination among the offices responsible for managing
special accounts: the three Headquarters offices (OSRTI, OSRE, and OCFO) and the Regions (Regional
program, counsel, and finance offices). These EPA offices have collaborated closely on improvements
to data systems, oversight and tracking, financial management procedures, and responding to inquiries
from external parties, such as the Office of the Inspector General (OIG) and the Government
Accountability Office (GAO). These offices have further reinforced management initiatives through
activities such as training events, regular meetings, and monthly conference calls.
OSRTI, OSRE, and OCFO Office Directors, along with the appropriate Division Directors for the Lead
Region for Superfund and the Lead Region for Management, participate on the Committee that centrally
oversees the implementation of this Strategy and the management of special accounts. The Committee
meets at least semi-annually to discuss the current status of the program and elevates issues, as
appropriate, to the appropriate senior level official(s) at the Assistant Administrator level or above for
resolution. OSRTI, as the Chair of the Committee, convenes and organizes the meetings.
OSRTI, OSRE, and the OCFO offices will continue to coordinate and have a presence at Superfund's
semi-annual Headquarters and Regional National Policy Manager (Division Director) meetings,
Regional Counsel Branch Chief meetings, and other national meetings. Coordination will also continue
through regular intra-agency meetings, such as at OSRE/OSRTI bi-weekly meetings. Designated staff in
OSRTI, OSRE, OCFO, and the lead Regions will continue to hold monthly conference calls to discuss
and coordinate special account activities and issues as they arise. OSRE, OSRTI, and OCFO will
continue to participate on national bi-monthly conference calls with Regional program, enforcement,
and financial staff to discuss special account activities and issues.
Responding to External Inquiries
EPA receives inquiries about special accounts from a host of entities, including the OIG, the Office of
Management and Budget (OMB), GAO, Congress, PRPs, and the media. EPA's goal in responding to
these inquiries is to be timely, informative, and accurately answer the questions posed.
OSRTI will coordinate responses to broad special account related inquiries from external parties, such as
the GAO and the OIG, as appropriate. OCFO will continue to be the lead office to coordinate responses
to inquiries from OMB, the Congressional Budget Office (CBO), Congressional appropriations
committees, or other external entities as appropriate.
-------
EPA will continue its practice of responding to requests in a timely and efficient manner and will
coordinate responses across offices. We recognize that external parties can provide insights into needed
changes that improve the program. Each request will be thoroughly reviewed and responded to as
warranted. If action is required, the relevant EPA office(s) will implement the action as appropriate.
Making Special Account Information Available to the Public
Publicly reporting information on special accounts allows external parties to understand the importance
and benefits of special accounts to the Superfund program, as well as how these funds are spent. EPA
will continue to report special accounts financial and planning information in the annual Performance
Plan and Congressional Justification that is submitted to Congress. This information is reported publicly
on EPA's Internet to provide more transparency without undermining enforcement efforts at Superfund
sites.
OSRTI and OSRE will update the Special Accounts internet page at least annually with cumulative
special account data, such as amounts collected, used, and available in all special accounts. Fact sheets
on EPA's special accounts program will be developed to assist the public in understanding what special
accounts are and how they may be used, and will be made available on the Internet. OSRE will continue
to maintain the special accounts Internet page, and staff in OSRTI, OSRE, and the OCFO offices will
routinely review and update the information available. The Committee will continue to explore options
for placing additional, pertinent information on EPA's Internet sites.
OSRTI has developed a communications strategy specifically for special accounts. The goal of the
communications strategy is to ensure consistent messaging across offices and regions when discussing
special accounts. The communications strategy also identifies opportunities for discussing special
accounts, in particular the success of special accounts and the benefits to EPA of having and using these
accounts, OSRTI will review and update the communications strategy at least once a year, and share
with the other EPA offices to ensure consistency across offices.
Availability of Information on the Intranet
The Intranet serves as an important resource for Agency staff working on special accounts. OSRE,
OSRTI, OCFO, and a number of Regional offices currently maintain Intranet pages specific to special
accounts. OSRE, OSRTI and OCFO have coordinated the Agency's special account content on the
Intranet, The OSRE Intranet special account pages include communication tools and tools for
practitioners, such as sample memos for Regions to use when notifying Headquarters of planned special
account actions. Also housed on the OSRE special accounts Intranet page is an annotated bibliography
of special account guidance and frequently asked questions specific for special accounts. These
interactive tools provide specific information on special accounts topics with links to relevant guidance,
models, and memos. OSRTFs special account Intranet page contains information on the Committee,
work planning and mid-year special account information, and responses to the OIG and GAO
concerning the Agency's management of special accounts.6 OCFO's special account Intranet page
contains information on the Agency's financial management policies and guidance for special accounts.7
4 Special Accounts Internet content is available at hup: wwu epa gin compliance cleanup supoi fund ^pi.(.-acLi.htmI.
OSRE's Special Accounts Intranet content is available at hup mti ana qi.t uo\ occn QMX- ^orkuroup -a
6 OSRTTS Special Accounts Intranet content is available at imp intranet iP.-. gin u-tti topics spec ial_,)n.ounts.html.
7 OCFO's Special Accounts Intranet content is available at hup, intranet upa urn txio iiipcftunJ spcM.il ^ccuim
-------
These resources will be updated as needed when new data and documents are released relating to special
accounts.
2. PlanningandUseof Special .Accounts
By developing and monitoring pians for using available special account funds, OSRTI, OSRE, and the
Regions will be able to analyze the use of special accounts and ensure special account funds are
considered as site response actions are planned. Through these efforts, the Agency will be able to better
plan and use special account resources on a site level, as well as identify trends at the Regional and
national levels.
Special Account Utilization
In general, special account resources should be used before appropriated resources for site response
activities. OSRTI, OSRE, and OCFO have worked to understand how the funds in special accounts are
being used to facilitate site response actions by establishing procedures for capturing special account
planning data and monitoring use. These offices will continue to work to ensure funds are used
efficiently and appropriately (discussed further in the Monitoring Special Accounts section below). As a
result, the Agency will strengthen and improve resource effectiveness with the ultimate goal of
maximizing human health and environmental benefits.
Enabling Effective Regional Planning
The Comprehensive Environmental Response, Compensation, and Liability Information System
(CERCLIS) Special Accounts Management screen enables Regions to see planning data and enter
additional planning data for the use of special accounts in conjunction with response activities for
individual sites.8 OSRTI and OSRE will ensure that special account planning capabilities are maintained
during the transition from CERCLIS to the Superfund Enterprise Management System (SEMS).
Available balances for special accounts are imported from information maintained in the Compass Data
Warehouse (CDW) nightly, which allows the Regions to monitor their account balances and more fully
plan the use of resources for ongoing and future site-specific response activities.
Regions are expected to plan appropriately for available funds in each special account, and regions will
update special account planning data on a continual basis, as warranted by site activity.9 The planning
data should be updated at least twice a year during the work planning and mid-year review process, but
also more frequently when a milestone is reached (e.g., an account is established, funds are received,
new planning information is available). During annual work planning and mid-year review meetings,
accounts will be reviewed to ensure CERCLIS (or SEMS) planning data is current and accurate.
OSRTI and OSRE will periodically review the utility of the special account planning fields in CERCLIS
(or SEMS) to determine if appropriate data have been captured to manage the accounts and assess and
report on the value of special accounts to the Superfund program. OSRTI and OSRE will also work with
the Regions to ensure the fields in CERCLIS (or SEMS) meet Regional needs for planning site actions
and using special account resources.
* CERCLIS will be replaced by the Superfund Enterprise Management System (SEMS), which is under development.
9 See the August 4, 2005, OSRE/OSRTI directive, "Management of Special Accounts" [OSWER Directive 9275.1-16]
-------
Quality Control / Quality Assurance
It is crucial to the successful management of special accounts that CERCLIS planning data are not only
current, but also entered completely and accurately. These data must be entered consistently across
Regions to reflect accurately the true nature of special accounts. Consistent with all plans for site-
specific response actions, the use of special account funds should be fully discussed with Regional
program management to ensure they are fully aware of the spending plans for each site. Through
review and analysis of these data, EPA can ensure that the funds are used to their fullest potential, as
well as report to internal and external stakeholders, as appropriate. Data monitoring is discussed below.
To further ensure the quality of the data, special account planning and utilization data will be discussed
at venues such as the Superfund Virtual Cost Recovery Conference. OSRTI maintains an Instruction
Guide that outlines how Regions should enter planning information in the data and comment fields, and
is updated as needed.11 Regional staff is also able to clarify procedures by participating in national bi-
monthly special account conference calls, bi-weekly Superfund Information Management
Coordinator/Budget Coordinator (IMC/BC) calls, or through consultation with a Headquarters special
accounts contact.
3. Monitoring Special Accounts
Monitoring special accounts will achieve the following goals:
1) Ensure appropriate use of the CERCLIS (or its replacement system) planning fields to
maintain data quality;
2) Ensure funds are planned to the fullest extent possible and in accordance with guidance;
3) Maximize the use of funds in special accounts; and,
4) Ensure both appropriated and special account resources are planned for and used
appropriately.
Both the Headquarters offices and the Regions have a responsibility to monitor special account use and
CERCLIS (or its replacement system) planning data. In order to fully meet these responsibilities,
OSRTI, OSRE, and OCFO have dedicated at least one person in each office who will be a primary point
of contact for the Regions and who will monitor special account use, planning data, and general special
account issues. In addition, each Region has designated at least one person as a Regional Lead Special
Account contact who coordinates across the Region on special account management issues.
Quarterly Reviews of Accounts with Negative Balances
On a quarterly basis, the Cincinnati Finance Center will monitor accounts with negative funds available
and coordinate with the Regions to correct the appropriate transactions within those accounts.
Review of Notification Memos
OSRTI, OSRE, and OCFO will work closely with the Regions on ^classifications, transfers to the
Superfund Trust Fund, and special account closeouts to ensure national policies are implemented
consistently. During work planning and mid-year sessions, as well as through the notification process for
10 See the September 28, 2010, "Guidance on the Planning and Use of Special Accounts" [OSWER Directive* 9275.1-20].
1' The Instruction Guide is available at: http://tntranet.epa,gov/osrti/topics/special_accounts.html
6
-------
these actions, Headquarters will discuss with the Regions their intentions to reclassify or transfer
resources to the general portion of the Superfund Trust Fund prior to such actions taking place.
Data Monitoring Plan
OSRTI and OSRE have developed a special account data monitoring plan that outlines the process for
reviewing CERCLIS (or its replacement system) special account planning data and determining areas of
OSRTI and OSRE focus for improving the management of special accounts. The plan helps to inform
work planning and mid-year reviews, reporting to management, and topics for additional training and/or
guidance. OSRTI and OSRE update the plan as necessary to reflect current priorities and activities.
Monitoring Reports
OSRTI, OSRE, and the Regions will develop new reports and/or modify existing reports to effectively
monitor CERCLIS (or its replacement system) planning data and the actual use of special accounts as
needed.
OCFO has created reports in Compass Business Objects Reporting and developed a query in CDW for
Regions to monitor their special account financial transactions. OCFO and OSRTI will work to develop
a report in CDW or CBOR to identify accounts with $0 disbursed or obligated in the past 5 years and a
report to identify sites with unliquidated obligations of appropriated funds where special account funds
may be available to ensure appropriate implementation of the "Effective Utilization of Superfund
Special Accounts" memorandum.12
Regional Superfund Division Directors will annually review open accounts with more than $1 million
available or accounts with $0 obligated or disbursed in the past 5 years to ensure effective utilization of
funds available in these accounts. OSRTI will provide a list of accounts that should be reviewed as part
of the annual work planning special account data review.13
OSRTI will continue to provide quarterly reports to the Superfund Division Directors and the
Committee on the status of planned reclassifications, transfers to the Superfund Trust Fund, and overall
utilization of special accounts.
Annual Regional Work Planning and Mid-Year Reviews
During the annual work planning and mid-year review processes, OSRTI and OSRE will pull CERCLIS
(or its replacement system) data using developed monitoring reports to serve as the basis for work
planning and mid-year discussions with the Regions. The work planning data pull will take place at the
beginning of the fiscal year to establish a baseline for planning data for the coming fiscal year and allow
EPA to report on special account multi-year plans. OSRTI and OSRE may conduct other CERCLIS (or
its replacement system) data pulls for use during mid-year reviews, and, on an ad hoc basis, may initiate
other queries of the data and conduct additional reviews.
During work planning as well as throughout the fiscal year, OSRTI, OSRE and the Regions will use
existing data to discuss how special account existing balances are being used to achieve site progress,
and whether opportunities exist to use additional funds for response actions at a site or reclassify or
12 The "Effective Utilization of Superfund Special Accounts" memorandum issued April 2, 2012 can be found at
http://www.epa.gov/superfund/pubs/pdfs/SF%20Special%20Accounts_Effective%20Utilization%20Memo.pdf.
13 See the "Effective Utilization of Superfund Special Accounts" memorandum issued April 2,2012.
7
-------
transfer resources to the general portion of the Superfund Trust Fund. OSRTI and OSRE staff will
review the planning data entered into CERCLIS (or its replacement system) in accordance with the
special account data monitoring plan. OSRTI and OSRE will also put special emphasis on ensuring
special account funds are planned and used in accordance with appropriate guidance.
4. Regional SujgporL Guidance and Training
Guidance and Training
The Agency has developed a number of support documents relevant to the establishment, use, and
management of special accounts and has issued guidance and documents clarifying roles and
responsibilities of staff. In addition, requirements documents, fact sheets, and program status reports
have been made available to assist in the understanding and management of special accounts. Review
and analysis of special account planning and use data will be used to identify areas where additional
training, guidance, and/or reference materials may be needed. Guidance and training materials will also
be developed at the direction of the Committee to ensure effective utilization and proper management of
special accounts.
OSRTI, OSRE, and OCFO will continue to conduct national and Region-specific special account
training. For example, special account training has been provided at the Special Accounts and Cost
Recovery Conference and has been discussed at Superfund Branch Chief meetings and Superfund
Division Director meetings. These dialogues may lead to the determination that further guidance or
input is required on an issue.
Special account planning and use data will also be used to identify areas where additional training,
guidance, and/or reference materials may be needed. OSRTI, OSRE, and the Regions will explore other
opportunities to engage on special account issues, such as during Regional visits.
III. Designation of Points of Contact
OSRTI and OSRE have designated at least one person in each office who will be a primary point of
contact for the Regions and will coordinate with designated OCFO staff as needed. Regions also have
designated points of contact in their program, enforcement, and finance offices.
IV. Strategy Implementation
Through implementation of the activities outlined in this Strategy, EPA will make additional
improvements in the management of special accounts. OSRTI, OSRE, and OCFO have updated a
workplan (Attachment 1) to undertake the activities outlined in this Strategy. The workplan is dynamic
to allow for activities to change as information and priorities regarding special accounts may change.
Implementation of this Strategy will be discussed at semi-annual meetings of the Committee, as well as
with Regions at national meetings. OSRTI, OSRE, and OCFO will evaluate and update this Strategy
after three years.
If you have any questions regarding this Strategy, please contact Tracey Stewart in OSRTI at 703-603-
8791 or stewart.traceyiq;gp_avgoy.
Attachment
-------
cc: Special Accounts Senior Management Committee
Superfund Special Account Contacts, Regions 1-10
Superfund Regional Branch Chiefs, Regions 1-10
Regional Comptrollers, Regions 1-10
Lawrence Stanton, OSWER/OEM
Reggie Cheatham, OSWER/FFRRO
Nigel Simon, OSWER/OPM
Suzanne Rudzinski, OSWER/ORCR
Tracey Stewart, OSWER/OSRTI
Manuel Ronquillo, OECA/OSRE
Laura Ripley, OCFO/OB
Nikki Wood, OCFO/OFM
Greg Luebbering, OCFO/OFS
Peter Hendrickson, OCFO/OFS
-------
Attachment 1
Special Accounts Management Strategy Implementation Work Plan
Strategy
Priority
Coordination &
Transparency
Activity
Determine OSRTI,
OSRE, and OCFO
Roles in Managing
Special Account
Intranet and
internet
Information
Report Special
Account Financial
and Planning Data
Publicly
Senior
Management
Committee Semi-
annual Meetings
Headquarters
Review of
Regional
Reclassification
and Closeout
Mem os
Respond to
External Inquiries
Office
OSRE
OSRTI
OCFO
OSRTI
OSRE
OCFO
Lead
Regions
OSRTI
OSRE
OCFO
Lead
Regions
OSRTI
OSRE
Regions
OSRTI
OSRE
OCFO
Regions
Due
Date
Ongoing
1st
Monday
in
February
each
year
Ongoing
As
memos
are
received
As
inquiries
occur
May 2012 Update
OSRE and OSRTI updated information on the EPA Special
Accounts web page in March 2012, Both offices agreed that
OSRE would continue to host the page. The page will need to
be reviewed and updated at least annually to update special
account summary data that is now available. OSRTI will place
Special Accounts as a topic under the Quick Finder section of
its Superfund home page at www.epa.gov/superfund.
SA financial and planning information was reported in EPA's
FY 201 3 Annual Performance Plan and Congressional
Justification on February 1 3, 201 2.
Committee met January 12, 2012 for their semi-annual
meeting.
Committee is scheduled to meet June 5, 2012 for their semi-
annual meeting.
OSRTI and OSRE have reviewed 24 accounts for
reclassification, transfer to the Trust Fund, and/or account
closure action in FY 2012. Regions have identified as a
concern the inability to currently recertify funds and as a result
may not proceed with ^classifications until recertifications are
able to be processed in the Compass environment.
GAO's final report, Status of EPA's Efforts to Improve Its
Management and Oversight of Special Accounts, was issued
January 18, 2012 to Senator Inhofe and made available to the
public on February 1 7, 2012. EPA did not provide a response
to the final report because it did not include any
recommendations for EPA to implement.
The Surveys and Investigations Staff of the House
Appropriations Committee initiated an inquiry into special
accounts on Februaiy 13, 2012. OSRTI, OSRE, OB, and
OCIR met with staff on March 27, 2012. On April 10, 2012,
OSRTI provided, through OCIR, special account and
Superfund site data requested by HAC SIS staff. OSRTI, in
coordination with the other offices, has responded to questions
from HAC SIS staff subsequent to providing the data
requested.
January 2013 Update
Placing Special Accounts as a topic under the Quick Finder
section is on hold pending completion of a restructuring of the
Superfund page.
SA financial and planning information will be reported in EPA's
FY 2014 Annual Performance Plan and Congressional
Justification to be released during February 2013.
Committee met on June 6, 2012 for their semi-annual meeting.
Committee is scheduled to meet January 30, 201 3 for their semi-
annual meeting.
OSRTI and OSRE reviewed 1 1 5 accounts with a reclassification,
transfer to the Trust Fund and/or closure action in FY 2012. Of
these, 65 were email notifications for actions less than $200k.
Staff is currently reviewing a sample of email notifications and will
notify regions where notifications were not in compliance with
guidance.
OSRTI continued to respond to questions from the HAC Surveys
and Investigations Staff pertaining to the inquiry into special
accounts. On June 14. 2012. OSRTI, OSRE. OB, OFS, and
OCIR participated on a conference call with HAC SIS staff on
special account ^classifications. Two Regions participated in
conference calls with representatives of HAC SIS staff and
OSRTI to provide detailed information on work planning for
special accounts at two Superfund sites.
The FY 2013 House Report (June 22, 201 2) accompanying
EPA's FY 2013 appropriations mark-up directs EPA to submit a
report to the Committee on Appropriations within 120 days of
enactment of the Act on the practical and legal implications of re-
prioritizing funds planned for future year activities (such as five
year reviews) to cleanup activities addressing human health and
environmental concerns in the near-term. The report should
evaluate alternative uses for these funds, including short-term
activities to reduce or eliminate human exposures and
-------
Strategy
Priority
Special
Account Use &
Planning Efforts
Activity
Update Special
Account
Management
Strategy
Report on Annual
Activities of the
SASMC
Maintain
CERCLIS Special
Account
Management
Screens
Update CERCLIS
Special Account
Planning Data
Office
OSRTI
OSRE
OCFO
Regions
OSRTI
OSRTI
OSRE
Regions
Due
Date
January
2013
Annually
Ongoing
At least
twice a
year
May 2012 Update
OSRTI, OSRE, and OCFO prepared a response to a letter
from Senator Inhofe received February 10, 2012 regarding the
unobligated balance in the Sitperfund Trust Fund, and
specifically EPA's plans to obligate special account money.
OSWER's AA provided a response to Senator Inhofe on March
19,2012. •
OSRTI responded to questions from House Energy and
Commerce staff about if remedial action construction projects
would be started at sites with special accounts and if there is a
publicly available list of sites with special accounts, including
site cleanup status and available balance information.
OSRTI, OSRE, and OCFO met with the Office of Management
and Budget (OMB) to discuss the recapture of special account
funds that are no longer needed for site-specific work and
account closures, including the trend over time for special
account reclassifications and closures and recent efforts
focused on these activities
An updated Management Strategy for 2013-2014 will be
issued early calendar year 2013. SASMC staff has developed
a draft Special Accounts Communications Strategy to be
discussed by the SASMC at the June 2012 meeting.
OSRTI issued on March 5, 2012 a report to EPA senior
managers on the activities of the SASMC in 2011, as required
by the charter establishing the SASMC.
The Instruction Guide for the CERCLIS Special Account
Management Screen was updated March 5, 2012 to update
the schedule for special accounts work planning and mid-year
reviews, areas of review by Headquarters offices, and
document that special account information is updated nightly in
CERCLIS rather than monthly.
OSRTI has organized a workgroup of regional special account
contacts to develop special account planning capabilities in the
Superfund Enterprise Management System (SEMS), which is
scheduled to replace CERCLIS for Superfund site and
financial planning purposes. A kick-off meeting was held April
25. 2012, and requirements for the special accounts portion of
SEMS are to be completed by September 2012.
Regions entered mid-year special account planning data
March 8 - March 29, 2012. Several issues with a recent
update to Compass were identified as regions updated plans
for using their available balances, which are now resolved
Mid-year calls with Regions 1-4, 8, and 10 took place between
May 1st and May 10th Regions 5-7 and 9 elected to provide
written responses to questions in lieu of a conference call with
Headquarters.
January 2013 Update
groundwater migration. SASMC staff is currently developing a
report in response to this requirement.
An updated Management Strategy is under review for issuance in
early calendar year 2013. The SASMC discussed the draft
Special Accounts Communications Strategy at the June 2012
meeting and requested development of fact sheets and
Frequently Asked Questions for the special accounts internet site.
OSRTI will report by March 31, 2013 to EPA senior managers on
the activities of the SASMC in calendar year 2012
The Instruction Guide for the CERCLIS Special Account
Management Screen was updated September 17, 2012 to update
the schedule for special accounts work planning areas of review
by Headquarters offices and to reflect the migration by the
Agency from IFMS to the Compass Financial System
The workgroup of regional special account contacts to develop
special account planning capabilities in the Superfund Enterprise
Management System (SEMS) met during April and May 2012 and
completed requirements for the special accounts portion of SEMS
on June 27, 2012.
Regions entered FY 2013 work planning data October 1 to
October 19, 2012 Work planning calls with Regions 1, 4, and 8
took place between December 5 and December 19 Regions 2,
3, 5, 6, 7, 9, and 10 elected to provide written responses to
questions in lieu of a conference call with Headquarters
11
-------
Strategy
Priority
Activity
Exploring Special
Account Uses
Office
OSRTI
OSRE
OCFO
Regions
Due
Date
As issues
arise
May 2012 Update
OGC provided a final opinion to OCFO on April 27, 2012 on
the use of special accounts for RCRA correction actions to
follow-up from the SASMC's January 2012 meeting and
discussion on this topic The SASMC will discuss
implementation of what is discussed in OGC's memo at their
June 2012 meeting.
OSRE is working with OGC, Region 2, and OSRTI on if funds
owed to EPA pursuant to a letter of credit under a Unilateral
Administrative Order (UAO) can be deposited into a special
account for use at the site.
OCFO and OSRE met with OGC in February 2012 to discuss
the placement of indirect costs collected pursuant to
settlement agreements in special accounts. As a result of
these discussions, language was added to RMDS Chapter 15
clarifying that indirect costs collected as part of settlement
agreements may be retained in special accounts.
January 2013 Update
The SASMC discussed the use of special accounts for RCRA
corrective actions at their June 2012 meeting. A memorandum
providing guidance on the use of special accounts for CERCLIS
and RCRA corrective actions at CERLIS and RCRA sites was
issued by the Committee on December 21, 2012.
OSRE continues to work with OGC, Region 2, and OSRTI to
determine if funds owed to EPA pursuant to a letter of credit
under a Unilateral Administrative Order (UAO) can be deposited
into a special account for use at the site.
Monitoring
Special
Accounts
Develop and
Review Standard
Special Accounts
Planning and Use
Reports
OSRTI
OSRE
OCFO
Regions
Ongoing
ReportLink reports were developed in March 2012 to pull only
those accounts identified by OSRTI and OSRE as a priority for
review during work planning and mid-year reviews in an effort
to streamline the review process. A report was also developed
for special account plans at sites that achieved construction
completion 15 years ago or more.
The status of planned reclassifications, transfers to the Trust
Fund, and account closures in FY 2012 were provided to the
SASMC and Superfund Division Directors on February 15,
2012 and May 17, 2012. as well as a national summary of
special accounts and a summary of planned uses for accounts
with more than S10M available.
The status of planned reclassifications, transfers to the Trust
Fund, and account closures in FY 2012 were provided to the
SASMC and Superfund Division Directors on September 26,
2012 and January 16, 2013, as well as a national summary of
special accounts and a summary of planned uses for accounts
with more than S1QM available.
OSRTI will request through the EPA Call Center development
of the following reports in the CBOR environment: 1) special
accounts with $0 obligated or disbursed in the past 5 years,
and 2) report of Superfund sites with unliquidated obligations
of appropriated funds that also have a special account
associated with the site. OSRTI has yet to request
development of these reports in light of other more pressing
issues that need to be resolved in association with Compass.
OSRTI has requested through the EPA call center development
of the following reports in the CBOR environment: 1} special
accounts with $0 obligated or disbursed in the past 5 years, and
2) report of Superfund sites with unliquidated obligations of
appropriated funds that also have a special account associated
with the site.
Develop and
Implement Special
Accounts Data
Monitoring Plan
OSRTI
OSRE
Ongoing
The Special Accounts Data Monitoring Plan was updated and
issued as an attachment to the memorandum, "Effective
Utilization of Special Accounts," on April 2, 2012.
OSRTI and OSRE reviewed FY 2013 work planning data
consistent with the checklist developed to document
Headquarters review of planning data
12
-------
Strategy
Priority
Activity
Office
Due
Date
May 2012 Update
January 2013 Update
Regional
Support,
Guidance &
Training
OSRTI and OSRE reviewed FY 2012 mid-year planning data
consistent with the checkiist developed to document
Headquarters review of special account planning data.
Conduct Special
Accounts Work
Planning and Mid-
Year Reviews
Regularly
Analyzing the
"Oldest Accounts"
Develop Controls
to Monitor
Negative Available
Balances
Reevaluate $88.4
Million Held for
Potential Future
Use
New Financial
System
Special Accounts
Training
OSRTI
OSRE
Regions
Twice a
year
FY 2012 mid-year data was updated by the regions March 8 •
March 29th Regional follow-up from OSRTI and OSRE
review of that data was completed by May 11, 2012.
FY 2013 work planning discussions were conducted December 5
to 19,2012.
OSRTI and OSRE provided an analysis of the FY 2012 mid-
year data to the SASMC for the June 2012 meeting.
OSRTi and OSRE will provide an analysis of the work planning
data to the SASMC for the January 2013 meeting
OSRTI
OSRE
twice;
year
OSRTI and OSRE analyzed the plans for using funds in the
196 open accounts that are 10 years old or more as part of FY
2012 mid-years.
OSRTI and OSRE analyzed the plans for using funds in the 197
open accounts that are 10 years old or more as part of FY 2013
work planning.
OCFO
9/30/201
0
Quarterly reviews of negative balances in special accounts
were not completed in the first half of FY 2012 due to the need
to resolve issues associated with the transition to Compass.
OFS started with a 2nd quarter review in May 2012 and will
continue conducting quarterly reviews of negative balances in
special accounts through the second half of FY 2012
OFS conducted reviews of negative balances in special accounts
and notified regions September 2012 of steps required to correct
the negative balances. OFS is continuing to conduct quarterly
reviews and will be sending the 1st quarter review in January
2013.
OSRTI
OSRE
At least
twice a
year
OSRTI and OSRE reviewed these accounts as part of FY
2012 mid-years and found their planned use of funds is
consistent with the 2010 SA Planning and Use Guidance.
OSRTI and OSRE reviewed these accounts as part of FY 2013
work planning and found their planned use of funds is consistent
with the 2010 SA Planning and Use Guidance
OCFO
OSRTI
Lead
Regions
10/1/12
OCFO is developing a Superfund reporting tool to consolidate
all Superfund financial information in one data universe, to be
completed by the end of FY 2012. Inclusion of special account
information is Phase 3 of this effort.
OCFO is continuing to develop a Superfund reporting tool (titled
the Superfund Consolidated Data Source - SFCDS) to
consolidate all Superfund financial information in one data
universe The SFCDS is undergoing beta testing and is not yet
ready to report on special account information.
OSRTI
OSRE
OCFO
Regions
Ongoing
The Superfund Virtual Conference, to be held May 22-24,
2012, includes the following topics specific to special accounts:
1) Special Account Reporting, and 2) Use of Special Account
Funds for ATSDR activities and RCRA corrective actions. OFS
and OSRE are presenters at the conference.
The 2013 Superfund Virtual Cost Recovery Conference is
scheduled to be held May 21-23, 2013 and is currently soliciting
potential topics.
The Superfund Information Management Coordinator/Budget
Coordinator (IMC/BC) meeting will be held Fall 2012 An
update on recent special account activities and initiatives may
be included on this agenda, particularly efforts to increase
utilization of available special account funds
13
-------
Strategy
Priority
Activity
identify and
Prioritize
Additional
Guidance or
Reference
Documents for
Completion or
Development
Office
OSRTI
OSRE
OCFO
Regions
Due
Date
Ongoing
May 2012 Update
Documents issued in FY 2012 include 1) Effective Utilization of
Special Accounts (4/2/12), 2) Annual Report to EPA Senior
Managers on Activities of the SASMC (3/5/12), and 3) Use of
Special Account Funds to Facilitate Work Settlements with
Potentially Responsible Parties and to Expedite the Cleanup of
Superfund Sites (1/26/12). The Financial Management of
Special Accounts (RMOS Chapter 15) is undergoing clearance
through EPA's directives process. A draft fact sheet on
managing deposits into special accounts has been developed
and was sent for regional review and comment on 5/14/12,
SASMC staff have developed a draft Special Accounts
Communication Strategy to be discussed by the SASMC at the
June 2012 meeting.
January 2013 Update
The SASMC discussed the draft Special Accounts
Communications Strategy at the June 2012 meeting. The
Committee requested staff develop fact sheets and Frequently
Asked Questions for the public and external audiences. A
memorandum providing guidance on the use of special accounts
for CERCLIS and RCRA corrective actions at CERLIS and RCRA
sites was issued by the Committee on December 21, 2012. The
Financial Management of Special Accounts (RMDS Chapter 15)
is undergoing clearance through EPA's directives process and is
anticipated to be released in the 2nd quarter of FY 2013.
14
------- |