United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
OSWER9200.3-15-1G-Y
September 30,2014
Superfund
http ://www. epa. gov/superfund/action/process/spiml 5. htm
SEPA Superfund Program Implementation Manual
Fiscal Year 2015
Program Implementation Guidance for OSRTI, OSRE, FFRRO,
FFEO and OEM (Headquarters and Regional Offices)
Program Goals and Planning Requirements
Program Implementation Procedures
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AND
EMERGENCY RESPONSE
OSWER 9200.3-15- 1G-Y
September 30, 2014
MEMORANDUM
SUBJECT: FY 2015 Superfund Program Implementation Manual (SPIM)
FROM: Jennifer Hovis. Acting Director
Resources Management Division"
Office of Superfund Remediation and Technology Innovation (OSRT1)
TO: Superfund Branch Chiefs (Regions I - X)
Regional Counsel Branch Chiefs (Regions I - X)
PURPOSE
This memorandum announces the release of Office of Solid Waste and Emergency Response
(OSWER) Directive 9200.3-I5-1G-Y. the Fiscal Year (FY) 2015 edition of the Supe rfiiml Program
Implementation Manual (SPIM).
DOCUMENT
Headquarters and Regional staff worked collaboratively for more than a year to produce this updated
SPIM. which reflects the Superfund program's recent migration from the Comprehensive
Environmental Response. Compensation, and Liability Information System (CERCLIS) to the
Superfund Enterprise Management System (SEMS). SEMS was deployed into production in December
2013. followed by the decommissioning of CERCLIS in January 2014. This updated document
represents a tremendous amount of time and effort of many people across the program. Thank you to
all who participated in the update and review of this essential program document.
Due to the magnitude of the changes dictated by the migration to SEMS, revisions to all chapters are not
yet complete. For chapters that have not been updated, program staff are directed to the most recent prior
edition of the SPIM. the FY 2012 Addendum, Headquarters anticipates finalizing the remaining chapters
in a revised FY 2015 SPIM in approximately six months.
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
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The following chapters have been updated in this FY 2015 edition:
Chapter 1: Introduction
Chapter 2: Program Measures, Planning and Reporting Requirements
Chapter 3: Financial Management
Chapter 5: Remedial Site Assessment
Chapter 6: Removal Program
Chapter 8: Federal Facility Program
Chapter 10: Community Involvement
Chapter 11: Information Systems
Appendix B: Regional and Headquarters Contacts
Appendix D: American Recovery and Reinvestment Act
IMPACT ANALYSIS
The Summary of Changes included in the attachment describes the nature of updates made to this
edition of the SP1M. The most substantive changes were necessitated by the migration from CERCLIS
to SEMS. which resulted in changes to screen and data element names, reports, and some business
processes. Furthermore, SEMS includes a formal project management software. Oracle Primavera.
which functions very differently from CERCLIS. The updated chapters relied the new functionality
and new names for site activities in Primavera. Additional edits were made to this edition of the SPIM
in order to eliminate duplicative content and present a more streamlined guidance document.
Impacts to the system and reports as a result of these SPIM revisions are expected to be minimal, as the
document is intended to reflect the new tools and functionality provided by SEMS.
CONCLUSION
If you have specific program questions, please contact the appropriate Subject Matter Expert (SME)
identified within Appendix B of the SPIM. I may be contacted at 703-603-8888 or
hovis.jennifer@epa.gov for general SPIM questions. The FY 2015 SPIM, along with the FY 2012
Addendum and earlier editions, can be found on the Superfund webpage at
http://vvv\vv.epa.gov\/siipei1\ind/action/process/spiml5.1itml.
Attachment
CC: OSRTI Division Directors and Branch Chiefs
Superfund National Policy Managers (Regions I - X)
Regional Counsels (Regions 1- X)
Headquarters Data Sponsors (OSRTI. OSRE. OEM, FFRRO. FFEO)
Information Management Coordinators (Regions 1- X)
Budget Coordinators (Regions I - X)
Financial Management Coordinators (Regions I - X)
Records Managers (Regions I - X)
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OSWER Directive 9200.3-15-1G-Y
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September 30, 2014 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Superfund Program Implementation Manual FY 15
Table of Contents
Managers' Schedule of Significant Events
Acronyms
Organizational Charts
Summary of Changes
Chapter I: Introduction
LA Purpose 1-1
I.B Introduction 1-2
I.B.I Superfund Legislative Background 1-2
I.B.2 Description of Superfund Response and Enforcement Programs 1-3
a. Superfund Remedial (303DD2) 1-4
b. Superfund Emergency Response and Removal (303DC6) 1-4
c. Federal Facilities Response (303DC9) 1-4
d. Superfund Enforcement (501EC7) 1-4
e. Base Realignment and Closure (303D41 and 303D41B4) 1-5
f. Federal Facilities Enforcement (501EH2) 1-5
I.C Superfund Enterprise Management System (SEMS) 7-5
Chapter II: Performance Measures, Planning and Reporting
Requirements
II. A Introduction II-l
II.B Performance Goals and Measures II-l
II.B.l Removal Program Measure II-5
II.B.2 Remedial and Federal Facilities Program Measures II-5
a. Number of Superfund Remedial Site Assessments Completed
(Site Assessments) II-5
b. Number of Remedial Action Project Completions at Superfund NPL sites
(Remedial Action (RA) Projects) II-5
c. Annual Number of Superfund Sites with Remedy Construction
Completed (CCs) 11-6
d. Number of Superfund Sites with Human Exposures Under Control 11-6
e. Superfund sites with contaminated groundwater migration under control 11-6
f. Number of Superfund sites Ready for Anticipated Use Sitewide (SWRA U) 11-6
FY 15 SPIM TOC-1 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
g. Acres "Protective for People Under Current Conditions " (PfP) II-7
h. Acres "Ready for Anticipated Use" (RAU) 77-7
II.B.3 Enforcement Program Measures II-7
a. Pre-Remedial Enforcement Action 77-7
b. Past Costs Addressed > $500,000 77-7
c. Volume of Contaminated Media Addressed (VCMA) - Soil and Groundwater 77-7
d. Total Response Commitments 77-5
e. Total Cost Recovery Settlements 77-5
/ Value of PRP Over sight 77-5
II. C Annual Performance Plan and Budget Development Cycle. II-8
II.C.l Outyear II-8
II.C.2 Planning Year II-9
II.C.3 Current Year II-9
II.D Planning and Reporting Cycle 11-12
II.D.l Third Quarter 11-12
a. Current Year Performance Tracking 77-72
b. Planning for the Upcoming Year. 77-73
II.D.2 Fourth Quarter 11-13
a. Planning for the Upcoming Year 77-73
b. End of Year Performance Tracking 77-73
II.D.3 First Quarter (of the subsequent year) 11-14
a. Planning for the Current Year 77-74
b. Prior Year Performance Tracking 77-74
II.E Planning, Target, and Accomplishment Reports 11-14
II.E. 1 OSRTI Management Reports for Planning/Target Setting and Accomplishment
Reporting 11-14
II.E.2 OSRE Management Reports 11-15
II.E.3 FFRRO Management Reports 11-16
Chapter III: Financial Management
III.A Introduction III-l
III.B Financial Management Roles and Responsibilities III-l
III.B.I Regional Organization Financial Roles and Responsibilities III-l
a. Regional Administrator (unless delegated) 777-7
b. Regional Finance Office (RFO) 777-2
c. Regional Program Office (RPO) 777-2
d. Administrative Support Unit 777-2
III.B.2 Regional Staff Financial Roles and Responsibilities III-3
a. On-Scene Coordinator (OSC) 777-3
b. Remedial Project Manager (RPM) 777-3
c. Regional Project Officer (Deputy Project Officer (DPO) 777-4
III.B.3 Headquarters Support Office Financial Roles and Responsibilities III-4
a. Cincinnati Finance Center (CFC), Office of Financial Services, OCFO 777-4
b. Las Vegas Finance Center (LVFC), Office of Financial Services, OCFO 777-4
c. Office of Acquisition Management (OAM), OARM. 777-5
d. Office of Budget, OCFO 777-5
e. Office of Financial Management (OFM), OCFO 777-5
September 30, 2014 TOC - 2 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
/ Office of Grants and Debarment (OGD), OARM. III-5
g. Research Triangle Park (RTF) Finance Center, Office of Financial
Services, OCFO III-5
III.C Financial Vehicles 7/7-6
III.C.l Contracts III-6
III.C.2 Interagency Agreements (lAs) III-6
III.C.3 Cooperative Agreements (CA) III-6
III.C.4 Grants III-7
777.7) Financial Data Management Tools 777-7
III.D.I Superfund Enterprise Management System (SEMS) III-7
III.D.2 Budget Automation System (BAS) III-8
III.D.3 Compass III-8
III.D.4 Compass Business Objects Reporting Tool III-8
III.D.5 Compass Data Warehouse (CDW) III-8
777.7i Superfund Accounting Information and Treatment of SEMS Data 777-9
III.E.I Superfund Account Number III-9
III.E.2 Handling Financial Data in the SEMS Environment 111-13
777.F Allocating Superfund Resources Among the Regions 111-14
III.F.I Managing Site Allowance Resources in SEMS 111-14
III.F.2 Using Prior Year Funds 111-15
a. Carryover 111-15
b. Deobligations 111-15
III.F.3 Removal Program Resources (PRC 303DC6) 111-16
III.F.4 Homeland Security Resources (PRC 303D72) 111-17
III.F.5 Remedial Response Program Resources (PRC 303DD2) 111-17
a. Remedial Action Site Allowance 111-17
b. Pipeline Operations Site Allowance 111-18
III.F.6 Superfund Federal Facilities Response Program (PRC 303DC9) 111-18
III.F.7 Base Realignment and Closure (BRAC) (303D41 [non-site] and 303D41B4
[site-specific]) 111-19
III.F.8 Enforcement Program (PRC 501EC7) 111-19
III.F.9 Federal Facilities Enforcement Program Resources (PRC 501EH2) 111-19
III.G Cost Recovery 111-20
III.G.l Recoverable Costs 111-21
a. Direct Costs 111-21
b. Contractors' Annual Allocation Costs 111-21
c. Indirect Costs 111-21
777.77 Site Charging Policy (Site-Specific, ZZ, 00 SSIDs) 777-22
III.H.l WQ SSID and WQ Action Code 111-22
a. WQSSID 111-22
b. WQ Action Code 111-23
III.H.2 ZZSSID 111-23
III.H.3 OOSSID 111-23
777.7 Superfund State Contracts (SSC) 777-24
III.I.l Cost Share Provisions 111-24
III.1.2 Constraints on Obligating Funds for RA 111-25
III.I.3 Cost Share Payments 111-25
FY 15 SPIM
TOC-3
September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
III.1.4 Using Funds from State Cost Share Payments 111-26
777.7 Special Accounts 111-26
III.K Using the Fiduciary Reserve to Address Cost Overruns 7/7-27
Chapter IV: SEMS Data Management and SEMS Codes
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM(FY2012 - Addendum),
available at http://www. epa. gov/superfund/action/process/spiml2. html
Chapter V: Remedial Site Assessment
V.A Remedial Site Assessment V-l
V.A.I Introduction V-l
V.A.2 Remedial Site Assessment Priorities V-2
V.A.3 Remedial Site Assessment Backlogs V-3
V.A.4 Overview of Remedial Site Assessment Targets and Measures V-3
V.A.5 Data Quality and Data Entry Timeliness Requirement V-7
a. Data Quality V-7
b. Data Entry Timeliness Requirement. V-7
V.A.6 Action Qualifiers for Remedial Site Assessment Activities V-7
a. No Further Remedial Action Planned (NFRAP) V-8
b. Higher Priority /Lower Priority V-8
c. Refer to Removal V-8
d. Site addressed as part of another NPL or Non-NPL site V-8
e. Referred From RCRA V-9
f. Assessment Complete - Decision Needed V-9
V.A.7 Remedial Site Assessment Critical Indicators V-ll
V.A.8 Remedial Site Assessment Activities V-ll
a. Pre-CERCLA Screening V-ll
b. Referred From RCRA V-l 4
c. Remedial Site Initiation (Discovery) V-l 5
d. Preliminary Assessments (PA) at Non-Federal Sites V-l 6
e. Site Inspections (SI) at Non-Federal Sites V-18
f. Site Reassessments at Non-Federal Sites V-l 9
g. Expanded Site Inspections (ESI) at Non-Federal Sites V-20
h. Integrated ESI/Remedial Investigations (ESI/RI) at Non-Federal Sites V-21
i. Hazard Ranking System Packages (HRS) V-23
j. Other Cleanup Activity (OCA) V-24
k. Formal State Deferral V-27
I. NPL Listing Activities V-29
V.A.9 Cleanup Alternatives V-30
a. Referral to EPA Removal V-30
b. Deferral to RCRA V-31
c. Deferral to Nuclear Regulatory Commission (NRC) V-31
d. Other Cleanup Activity (OCA) V-31
e. Formal State Deferral V-33
f. Superfund Alternative Approach V-33
g. NPL Listing V-34
September 30, 2014 TOC - 4 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Chapter VI: Removal Program
VI.A Protect Human Health and the Environment VI-1
VI.A.l Overview of Removal Actions Target and Measures VI-1
VI.A.2 Removal Initiation VI-1
VI.A.3 Action Memorandum VI-2
VI.A.4 Removal Action VI-2
Chapter VII: Remedial Program
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM(FY2012 - Addendum),
available at http://www.epa.sov/superfund/action/process/spiml2.html
Chapter VIII: Federal Facility Program
VIII.A Federal Facilities Goals and Priorities VIII-1
VIII.A.l Overview VIII-1
VIII.A.2 Superfund Federal Facility Goals VIII-1
a. Strategic Federal Facility Goals VIII-1
b. Cross-Program Revitalization Measure Implementation VIII-3
VIII.A.3 EPA's Federal Facility Superfund Cleanup Principles VIII-3
VIII.A.4 Federal Facility Docket and Site Discovery/Site Assessment VIII-6
a. Overview VIII-6
b. Federal Facility Docket Process and the Federal Facilities Site
Discovery Process VIII-6
c. Federal Facility Site Assessment Process and Time Frames VIII- 7
d. Authority for Conducting Federal Facility Site
Assessments - E.O. 12580 VIII-8
e. Federal Facility Site Assessment Reports & EPA Review
and HRS Evaluation VIII-9
f. Tracking of Federal Facility Sites in SEMS VIII-10
VIII.A.5 BRAC Budget and Financial Guidance VIII-10
a. Resources and Tracking Mechanisms VIII-10
b. Accountability for Resources VIII-11
VIII.A.6 Cleanup Privatization at BRAC NPL Sites VIII-12
VIII.A.7 Military Munitions Response Program VIII-13
VIII.A.8 Stakeholder Involvement VIII-14
VIII.B Federal Facilities Targets and Measures VIII-14
VIII.B.I Overview of Federal Facilities Targets and Measures VIII-14
VIII.B.2 Federal Facilities Site Discovery/Site Assessment Definitions VIII-16
a. Remedial Site Initiation (Discovery) VIII-16
b. Federal Facility Preliminary Assessment Reviews VIII-17
c. Federal Facility Site Inspection Reviews VIII-19
d. Federal Facility Expanded Site Inspection (ESI) Reviews VIII-19
VIII.B.3 Federal Facilities Accomplishment Definitions VIII-20
a. Base Closure Decisions VIII-20
b. Non-BRAC Property Actions VIII-21
c. Federal Facility Agreement (FFA)/Interagency Agreement (IA) VIII-23
d. Federal Facility Dispute Resolution VIII-23
FY 15 SPIM TOC - 5 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
e. Remedial Investigation/Feasibility Study (RI/FS) or RCRA
Facility Investigation (RFI) Starts VIII-24
f. Decision Documents VIII-24
g. Final Remedy Selected VIII-25
h. Remedy Decision Changes VIII-26
i. Remedial Design (RD) or RCRA Corrective Measure Design (CMD) VIII-2 7
j. Remedial Action (RA) or RCRA Corrective Measure
Implementation (CMI) VIII-27
k. Removal or RCRA Interim/Stabilization Measure (ISM) VIII-29
1. Operation and Maintenance (O&M) VIII-30
m. Cleanup Goals Achieved VIII-30
n. Percent Construction Completion VIII-31
o. Federal Facility Five-Year Reviews VIII-31
VIII.B.4 Community Involvement Definitions VIII-34
a. Restoration Advisory Boards (RABs)/Site-Specific Advisory
Boards (SSABs) VIII-34
b. Technical Assistance Grants (TAGs) VIII-34
VIII.B.5 Cleanup Privatization at BRAC NPL Sites VIII-35
Chapter IX: Enforcement
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM (FY2012- Addendum),
available at http://www. epa. gov/superfund/action/process/spiml2. html
Chapter X: Community Involvement
X.A INTRODUCTION X-l
X.B COMMUNITY INVOLVEMENT ACTIVITIES X-l
X.B.I Overview of Community Involvement Activities X-l
a. Community Advisory Groups (CAGs) X-l
b. Technical Assistance Grants (TAGs) X-l
c. Technical Assistance Services for Communities (TASC) X-2
X.C National Program Requirements X-3
X.C.I Program Goals and Objectives X-3
X.C.2 Regulatory and Policy Requirements X-3
X.C.3 Roles and Responsibilities X-3
Chapter XI: Information Systems
XI.A Information Systems XI-1
XI.A.1 Overview of SEMS XI-1
a. Remedial Site Assessment (See chapter V) XI-1
b. Removal Program (See chapter VI) XI-2
c. Remedial Program (See chapter VII) XI-2
d. Federal Facility Program (See chapter VIII) XI-3
e. Enforcement Program (See chapter IX) XI-3
f. Community Involvement (See chapter X) XI-4
g. Project Management XI-4
September 30, 2014 TOC - 6 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
h. Program Management. XI-5
XI.A.2 SEMS System Components XI-5
XI.A.3 Reporting Superfund Information XI-6
XI.A.4 Data Owners/Sponsorship XI-6
Chapter XII: Records and Information Management
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM (FY2012 -Addendum),
available at http://www.epa.gov/superfund/action/process/spiml2.html
Appendix A: New Initiatives/New Requirements
This appendix has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM (FY2012- Addendum),
available at http://www. epa. gov/superfund/action/process/spiml2. html
Appendix B: Regional and Headquarters Contacts
B.A Headquarters (HQ) Subject Matter Experts/Data Sponsors B-l
B. B Office of Emergency Management (OEM) HQ Removal Coordinators B- 3
B.C HQ Superfund Cost Recovery Contacts B-3
B.D Cost Recovery Contacts B-3
B.E Regional Budget Coordinators B-4
Appendix C: Work Planning Memorandum
This appendix has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM(FY2012 - Addendum),
available at http://www. epa. gov/superfund/action/process/spiml2. html
Appendix D: American Recovery and Reinvestment Act (ARRA)
List of Exhibits
Exhibit II. 1. Superfund Performance Measures II-2
Exhibit II.2. Budget Planning Timeline 11-10
Exhibit III. 1. Superfund Account Number Structure III-9
Exhibit III.2. Sample Superfund Appropriation Codes 111-12
Exhibit III.3. Superfund Program Results Codes and Site Allowance Codes 111-13
Exhibit V.I. Superfund Remedial Site Assessment Process V-2
Exhibit V.2. Remedial Site Assessment Activities V-6
Exhibit V.3. Remedial Site Assessment Activity Qualifiers V-10
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OSWER Directive 9200.3-15-1G-Y
Exhibit VI. 1. Removal Program Activities VI-1
Exhibit VIII. 1 A. Federal Facilities NPL Sites VIII-15
Exhibit VIII. IB. Federal Facilities Fast-Track BRAC Sites VIII-15
Exhibit VIII.2. Remedial Pipeline Flow Charts VIII-29
Exhibit X.I. HQ and Regional Roles and Responsibilities X-3
September 30, 2014 TOC - 8 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Superfund Program Implementation Manual
FY15
Managers' Schedule of Significant Events
FY 15 SPIM September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
MANAGERS' SCHEDULE OF SIGNIFICANT EVENTS
The Superfund Enterprise Management System (SEMS) was deployed to production in fiscal year (FY) 2014,
and is now the official repository for Superfund data. Data are expected to be kept complete, current, and
consistent in order to be readily available for routine, unexpected, and immediate needs. For at least the first
quarter of FY 2015, Office of Superfund Remediation and Technology Innovation (OSRTI) expects that regional
and Headquarters (HQ) staff will still be learning the functionality of the SEMS tool and conducting quality
assurance of data migrated from the Comprehensive Environmental Response, Compensation, and Liability
Information System (CERCLIS) and updated in SEMS. Therefore, the schedule below is provided as a general
timeline which may be modified to account for the unique circumstances the program is in with respect to
migration to the new system.
FY 2015
OCTOBER 2014 (QUARTER 1 / FY 15)
F , Office of the Chief Financial Officer (OCFO) issues pipeline and remedial resources per the
draft agency operating plan, adjusted to reflect Continuing Resolution decisions
OSRTI will temporarily freeze special account available balance data in SEMS screens by
1 terminating the data feed from Compass; regions will begin updating plans to use available
special account resource balances.
,, Regions certify FY 2014 end of year accomplishments for the six remedial measures reported in
the Annual Commitment System (ACS)
National Program Managers (NPMs) and regions reach agreement in ACS on FY 2015
performance commitments
Mid/Late OSRTI drafts initial FY 2015 Remedial Action (RA) funding plan
Regions will complete updating plans to use available special account resource balances; OSRTI
24 will recommence importing Compass special accounts available balance data into SEMS
screens
NPMs and regions elevate any unresolved FY 2015 performance commitments to OCFO for
dispute resolution
NOVEMBER 2014
Mid Regions submit Superfund remedial unliquidated obligations review results to OSRTI
Late ACS is locked to prevent further adjustments to FY 2015 commitments
N ^ OSRTI and Office of Site Remediation and Enforcement (OSRE) hold special account specific
planning discussions with regions
FY 15 SPIM Managers' Schedule -1 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
DECEMBER 2014
TBD Office of Management and Budget (OMB) passback of FY 2016 budget request
TBD Agency appeal of the OMB FY 2016 budget passback
Mid/Late OSRTI sets targets for national remedial pool deobligations
JANUARY 2015 (QUARTER 2 / FY 15)
9 HQ pulls 1st Quarter FY 2015 accomplishments and financial data from SEMS
Mid Draft FY 2016 NPM Guidances due to OCFO
Mid/Late Regions submit draft deobligation plans to OSRTI
FEBRUARY 2015
Early President submits FY 2016 Annual Performance Plan and budget request to Congress
Mid NPMs issue draft National guidance for FY 2016
MARCH 2015
Early/Mid OSRTI/OSRE send preliminary mid-year work planning details to the regions
APRIL 2015 (QUARTER 3 / FY 15)
8 HQ pulls 2nd quarter FY 2015 accomplishment data from SEMS for mid-year ACS
accomplishments review as well as mid-year work planning review
Mid Mid-year data entry for special accounts
Late HQ pulls financial data from SEMS for special accounts
April/May OSRTI/OSRE anticipate conducting mid-year work planning meetings with regions to review
FY 2015 progress and begin planning for FY 2016
April/May OSRTI and OSRE hold special account specific planning discussions with regions
MAY 2015
Mid Annual Goal Team Meetings with Deputy Administrator on FY 2015 progress and FY 2015
priorities
Late NPMs meet with the Administrator to review FY 2015 program goals
Late NPMs/regions begin the bidding process for FY 2015 ACS performance measures
September 30, 2014 Managers' Schedule - 2 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
JUNE 2015
June OSRTI/OSRE send work planning memorandum to regions on proposed budgets, ACS
performances goals and program targets/measures for FY 2016
Mid/Late HQ presents FY 2016 Superfund goals and priorities and FY 2017 investments to the
June Administrator and Regional Administrators
Mid/Late OCFO provides HQ program offices and regions with policy for FY 2017 budget formulation
June
June/July Regions update schedules and financial information in SEMS for FYs 16, 17 and 18 in
preparation for work planning meetings
JULY 2015 (QUARTER 4 / FY 15)
Early Regions draft FY 2016 commitments which are due in ACS
9 HQ pulls 2nd quarter FY 2015 accomplishment data from SEMS
9 OSRTI pulls planning information from SEMS to support FY 2016 and 17 budget requests and
to prepare for FY 2017 work planning
Early/Mid NPMs submit proposed FY 2017 budgets to OCFO/Administrator
Mid HQ program offices and lead regions make presentation to Administrator/Deputy Administrator
on FY 2017
Late Administrator passback of FY 2017 budget request
AUGUST 2015
Mid Agency develops FY 2017 budget for submission to OMB
Late Final revisions to FY 2017 Annual Performance Goals (APG) and Annual Performance
Measures (APM) due to OCFO
August/Early OSRTI/OSRE hold FY 2016 and out year regional work planning meetings on program
Sept priorities, performance measures and budget
August/Sept NPMs begin drafting FY 2015 Annual Performance Report
FY 15 SPIM Managers' Schedule - 3 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
SEPTEMBER 2015
Early Last date for requests for recertification of deobligated funds for Superfund. Request must be
made in Recertification database, and reprogramming must be entered in COMPASS
Early Last day for any reprogrammings (no-year, reimbursable, Budget Object Class (BOC)
realignment) in COMPASS
Mid Agency submits FY 2017 budget to OMB
September 30, 2014 Managers' Schedule - 4 FY 15 SPIM
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Superfund Program Implementation Manual
FY15
Acronyms
FY 15 SPIM September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
AA Assistant Administrator
AA OECA Assistant Administrator for the Office of Enforcement and Compliance Assurance
AA OSWER Assistant Administrator for the Office of Solid Waste and Emergency Response
ACS Annual Commitment System
ADR Alternative Dispute Resolution
AH Allowance Holder
AH/RC Allowance Holder/Responsibility Center
AO Administrative Order
AOC Administrative Order on Consent
APA Abbreviated Preliminary Assessment
APG Annual Performance Goals
APM Annual Performance Measures
APR Annual Performance Report
AR Administrative Record
ARAR Applicable or Relevant and Appropriate Requirements
ARD Assessment and Remedial Division
ARRA American Recovery and Reinvestment Act
ATSDR Agency for Toxic Substances and Diseases Registry
BAS Budget Automation System
BC Budget Coordinator
BCP Base Realignment and Closure (BRAC) Cleanup Plan
BCT Base Cleanup Team
BFPL Bona Fide Prospective Lessee
BFPP Bona Fide Prospective Purchaser
BFY Budget Fiscal Year
BOC Budget Object Class
BPEB Budget, Planning and Evaluation Branch
BRAC Base Realignment and Closure
CA Consent Agreement; Cooperative Agreement
CAG Community Advisory Group
CARE Community Action for a Renewed Environment
CAS No. Chemical Abstract Services Number
CBD Commerce Business Daily
CBOR Compass Business Objects Reporting Tool
CC Construction Completed
CCDS Case Conclusion Data Sheet
CD Consent Decree
CDR Covenant Deferral Request
CDW Compass Data Warehouse
CEI Community Engagement Initiative
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980
CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System
CERFA Community Environmental Response Facilitation Act
FY 15 SPIM
Acronyms -1
September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
CFC Cincinnati Finance Center
CFMC Cincinnati Financial Management Center
CIC Community Involvement Coordinator
CIP Community Involvement Plan
CIPIB Community Involvement and Program Initiatives Branch
CLP Contract Laboratory Program
CMD Corrective Measure Design
CMI Corrective Measure Implementation
CMS Corrective Measure Study
CO Contracting Officer
COB Close of Business
COC Contaminants of Concern
COI Conflict of Interest
COR Contracting Officer Representative
CPARS Consolidated Payroll Reporting System
CPO Contiguous Property Owner
CPRM Cross Program Revitalization Measure
CPS Contract Payment System
CR Continuing Resolution
CWA Chemical Warfare Agents, Chemical Warfare Act
CWM Chemical Warfare Material
DA Deputy Administrator
DCN Document Control Number
DD Division Director
DERP Defense Environmental Response Program
DNPV Decision Not to Pursue Violations
DoD Department of Defense
DOE Department of Energy
DOJ Department of Justice
DPO Deputy Project Officer
DRA Deputy Regional Administrator
DS Data Sponsor
E.O. Executive Order
EAS EPA Acquisition System
EBS Environmental Baseline Survey
EE/CA Engineering Evaluation/Cost Analysis
EFY End of Fiscal Year
El Environmental Indicator
EJ Environmental Justice
EPA Environmental Protection Agency
EPA ID EPA Identification Number
EPCRA Emergency Planning and Community Right to Know Act of 1986
EPM Environmental Programs and Management
September 30, 2014
Acronyms - 2
FY 15 SPIM
-------
OSWER Directive 9200.3-15-1G-Y
EQR EPA Quarterly Report
ERNS Emergency Response Notification System
ERR Emergency Response and Removal
ERRS Emergency and Rapid Response Services
ERS Eligible Response Site
ESAT Environmental Services Assistance Team
ESCA Environmental Services Cooperative Agreement
ESD Explanation of Significant Differences
ESI Expanded Site Inspection
ESI/RI Expanded Site Inspection/Remedial Investigation
FAD Final Assessment Decision
FAS Field Analytical Sampling
FCOR Final Close-Out Report
FDMS Federal Docket Management System
FDW Financial Data Warehouse
FE Federal Enforcement
FE&C Federal Enforcement and Compliance
FF Federal Facility
FF FYR Federal Facility Five Year Review
FFA Federal Facilities Agreement
FFEO Federal Facilities Enforcement Office
FFERDC Federal Facilities Environmental Restoration Dialog Committee
FFLC Federal Facility Leadership Council
FFRRO Federal Facilities Restoration and Reuse Office
FFSEP Federal Facilities Site Evaluation Project
FMD Financial Management Division
FMFIA Federal Managers Financial Integrity Act
FMO Financial Management Office
FOIA Freedom of Information Act
FOSET Finding of Suitability to Early Transfer
FOSL Finding of Suitability to Lease
POST Finding of Suitability to Transfer
FPDS-NG Federal Procurement Data Systems' New Generation
FPS Fellowship Payment System
FR Federal Register
FS Feasibility Study
FTE Full-time Equivalent
FUDS Formerly Used Defense Site
FUSRAP Formerly Used Site Remediation Action Program
FWS U.S. Fish and Wildlife Service
FY Fiscal Year
FY/Q Fiscal Year/Quarter
FYR Five Year Review
FY 15 SPIM
Acronyms - 3
September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
GAAP Generally Accepted Accounting Principle
GAD Grants Administration Division
GAO General/Government Accountability Office
GFO Good Faith Offer
GICS Grants Information Control System
GIS Geographic Information System
GM Ground Water Management
GNL General Notice Letter
GPAS Grants Payment Allocation System
GPRA Government Performance and Results Act
GSA General Services Administration
GWMUC Groundwater Migration under Control
HE Human Exposure
HEID Insufficient Data to Determine Human Exposure Control Status
HENC Human Exposure Non Under Control
HEPR Human Exposure Under Control and Protective Remedies in Place
HEUC Human Exposure Under Control
HHPA Human Exposure Under Control and Long Term Human Health Protection Achieved.
HPPG High Priority Performance Goals
HQ Headquarters
HRS Hazard Ranking System
IA Interagency Agreement
IAA Interagency Assisted Acquisition
IAG Interagency Agreement
IASSC Interagency Agreement Shared Service Center
1C Institutional Control
ICI Integrated Cleanup Initiative
ICIS Integrated Compliance Information System
ICTS Institutional Control Tracking System
IDOTS Inter-Agency Doc Online Tracking System
IFMS Integrated Financial Management System
IG Inspector General
IGCE Independent Government Cost Estimate
IGMS Integrated Grants Management System
1MB Information Management Branch (OSRTI)
IMC Information Management Coordinator
IRMS Integrated Resource Management System
ISM Interim/Stabilization Measure
IT Information Technology
JG Judicial/Civil Judgments
JTI Job Training Initiative
KPI Key Performance Indicator
LGR Local Government Reimbursement
September 30, 2014
Acronyms - 4
FY 15 SPIM
-------
OSWER Directive 9200.3-15-1G-Y
LTRA Long Term Response Action
LVFC Las Vegas Finance Center
M&O Management and Operations
MAAC Maximum Amount Appropriate for Compensation
MC Munitions Constituents
MEC Munitions and Explosives of Concern
MIPR Military Interdepartmental Purchase Request
MM/DD/YY Month/Day/Year
MMRP Military Munitions Response Program
MOA Memorandum of Agreement
MOU Memorandum of Understanding
MRS Munitions Response Site
MS Mega Site
NCP National Contingency Plan; National Oil and Hazardous Substances Pollution Contingency Plan
NEPA National Environmental Policy Act
NFFA No Further Federal Action
NFRAP No Further Remedial Action Planned
NOA New Obligating Authority
NOAA National Oceanic and Atmospheric Administration
NOID Notice of Intent to Delete
NOIPD Notice of Intent to Partially Delete
NPL National Priorities List
NPM National Program Manager
NRC National Response Center; Nuclear Regulatory Commission
NRT National Response Team
NTC Non-Time Critical
NTCRA Non-Time Critical Remedial/Removal Action
O&F Operational and Functional
O&M Operation and Maintenance
OA Other Start and Completion Anomaly
0AM Office of Acquisition Management
OARM Office of Administration and Resources Management
OB Office of Budget
OB/OD Open Burn/Open Detonation
OC Office of Compliance; Office of the Comptroller
OCA Other Cleanup Activity
OCFO Office of the Chief Financial Officer
OCIR Office of Congressional and Intergovernmental Affairs
OECA Office of Enforcement and Compliance Assurance
OEI Office of Environmental Information
OEM Office of Emergency Management
OERR Office of Emergency and Remedial Response
OFM Office of Financial Management
FY 15 SPIM
Acronyms - 5
September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
OGC Office of General Counsel
OGD Office of Grants and Debarment
OIG Office of the Inspector General
OMB Office of Management and Budget
OP A Office of Public Affairs; Oil Pollution Act of 1990
OPS Operating Properly and Successfully
ORC Office of Regional Counsel
OS Other Start Anomaly
OSC On-Scene Coordinator
OSC On-Scene Coordinator
OSRE Office of Site Remediation and Enforcement (OECA)
OSRTI Office of Superfund Remediation and Technology Innovation
OSWER Office of Solid Waste and Emergency Response
OU Operable Unit
PA Preliminary Assessment
PAD Public Affairs Director
PAR Performance and Accountability Report
PAT Performance Assessment Tool
PCOR Preliminary Close-Out Report
PCS Pre-CERCLA Screening
PECB Program Evaluation & Coordination Branch (OSRE)
PFP Protective for People Under Current Conditions
PIN Procurement Initiation Notifications
PLA Prospective Lessee Agreement
POC Point of Contract
POLREP Pollution Report
PPA Prospective Purchaser Agreement
PPED Policy & Program Evaluation Division (OSRE)
PPL PeoplePlus
PR Procurement Request
PRC Program Results Code
PRN Pre-Referral/Remedial Negotiation
PRP Potentially Responsible Party
QA Quality Assurance
QRG Quick Reference Guide
RA Regional Administrator; Remedial Action
RAB Restoration Advisory Board
RAC Remedial Action Contract
RAU Ready for Anticipated Use
RC Regional Coordinator
RCMS Removal Cost Management System
RCRA Resource Conservation and Recovery Act
RD Remedial Design
September 30, 2014
Acronyms - 6
FY 15 SPIM
-------
OSWER Directive 9200.3-15-1G-Y
RD/RA Remedial Design/Remedial Action
RFA RCRA Facility Assessment
RFI Resource Conservation and Recovery Act Facility Investigation
RFO Regional Finance Office
RFP Request for Proposal
RI Remedial Investigation
RI/FS Remedial Investigation/Feasibility Study
RMDS Resource Management Directives System
ROC Remedial Oversight Contract
ROD Record of Decision
RP Responsible Party
RPIO Responsible Program Implementation Office
RPM Remedial Project Manager
RPO Regional Project Officer
RRT Regional Response Team
RSAC Remedial Site Assessment Completion
RTP Research Triangle Park
SA Approach Superfund Alternative Approach
SAM Site Assessment Manager
SARA Superfund Amendments and Reauthorization Act of 1986
SB/RTC Statement of Basis/Response to Comments
SCAP Superfund Comprehensive Accomplishments Plan
SCDS Superfund Comprehensive Data Source
SCORPIOS Superfund Cost Recovery Package and Image On-Line System
SDMS SEMS Document Management System
SDWA Safe Drinking Water Act
SEMS Superfund Enterprise Management System
SEP Supplemental Environmental Project
SFCDS Superfund Financial Comprehensive Data Source
SFO Servicing Finance Office
SI Site Inspection
SIP Site Inspection Prioritization
SME Subject Matter Expert
SMOA Superfund Memorandum of Agreement
SNC Substantial Non-Compliance
SNL Special Notice Letter
SOL Statute of Limitations
SOW Statement of Work
SPIM Superfund Program Implementation Manual
SPITS Small Payment Information Tracking System
SRO Senior Responsible Official
SSAB Site-Specific Advisory Board
SSC Superfund State Contract
FY 15 SPIM
Acronyms - 7
September 30, 2014
-------
OSWER Directive 9200.3-15-1G-Y
SSID Site/Spill Identification Code
START Superfund Technical Assistance and Response Team
SWRAU Sitewide Ready for Anticipated Use
TAG Technical Assistance Grant
TAPP Technical Assistance for Public Participation
TASC Technical Assistance Service for Communities
TC Time Critical
TCE Trichloroethylene
TDD Technical Direction Document
TOSC Technical Outreach Services For Communities
TSD Treatment, Storage, and Disposal Facility
UAO Unilateral Administrative Order
UMTRCA Uranium Mill Tailings Radiation Control Act
USAGE United States Army Corps of Engineers
USCG United States Coast Guard
UST Underground Storage Tank
UU/UE Unlimited Use and Unrestricted Exposure
VCMA Volume of Contaminated Media Addressed
VCP Voluntary Cleanup Program
WA Work Assignment
WEBOS Web Order System
WL Windfall Lien
WQ Bulk Funding
September 30, 2014
Acronyms - 8
FY 15 SPIM
-------
OSWER Directive 9200.3-15-1G-Y
Superfund Program Implementation Manual
FY15
Organizational Charts
FY 15 SPIM September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
This Page Intentionally Left Blank
September 30, 2014 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Office of Solid Waste and Emergency Response
Federal Facilities
Restoration & Reuse Office
Charlotte Bertrand, Act- Director
Doug Maddox, Act, Dep, Dir
Innovation Partnerships
Communication Office
Kent Benjamin, Act. Director
Center for Program
Analysis
Bngid Lowery, Director
IMMEDIATE OFFICE OF THE
ASSISTANT ADMINISTRATOR
Mathy Stanislaus, AA
Barry N. Breen, PDAA
Nitin Natarajan, DAA
Organizational
Managements
Integrity Staff
Lora Culver, Director
PMO
Office of Program
Management
Nigel Simon, Director
SIO
Information Management
& Data Quality Staff
Stephen Schmitt, Director
IMO
Policy Analysis &
Regulatory
Management Staff
Barbara Hostage, Director
Office of Superfund
Remediation &
Technology Innovation
Robin Richardson, Act. Director
Franklin Hill, Act Dep. Dir
Resources Management
Division
Vacant, Director.
Assessment & Remediation
Division
Dana Stalcup. Act. Director
Technology Innovation
& Field Services Division
Pamela Barr, Director
Environmental Response Team
Harry Compton. Chief
Marc Greenberg.DC (East) NJ
Dennisses Valdes. DC (West) NV
Office of Resource
Conservation & Recovery
Barnes Johnson, Director
Rosemarie Kelly, Act. Dep. Dir.
I Program Mgmt. Communications,
& Analysis Office
Mark Huff. Director
Materials Recovery &
Waste Management Div.
Betsy Devlin, Director
Resource Conservation &
Sustainability Div.
Cheryl Cdeman. Director
Program Implementation
& Information Division
Sonya Sasseville. Act. Director
Office of Underground
Storage Tanks
Carolyn Hoskinson. Dir
Mark Barolo, Deputy Dir.
Office of Brownfields
& Land Revitalization
David Lloyd, Director
Gail Cooper, Dep. Dir.
Management &
Communications
Division
Ray Worley, Director
Release Prevention
Division
Linda Gerber, Director
Cleanup and Revitalization
Division
Wil Anderson. Director
Budget
& Management Team
Tracy Stewart. Act. Team LDR
Grants Management Team.
Debra Morey, Team LDR
Policy, Research &
Outreach Team,
Patricia Overmeyer. Team LDR
Revised July 28, 2014
Acquisition & Resources
Management Staff
Meridith Sebring, Act Dir.
SBO
r
Office of Emergency
Management
Reggie Cheatham, Act. Dir.
Dana Tulis, Dep. Dir.
A
Regulations Implementation
Division
R.Craig Matthiessen, Dir.
Preparedness & Response
Operations Dlv.
Gilberto Irizairy, Dir.
Emergency Operations
Center & Continuity Branch
Eugene Lee Branch Chief
Resources Management
Division
Victoria van Roden. Dir.
CBRN/'CMA Division
Erica Canzler, Dir.
FY 15 SPIM
Organizational Charts -1
September 30, 2014
-------
OSWER Directive 9200.3-15-1G-Y
Office of Superfund Remediation and Technology Innovation
Robin H. Richardson, Acting Director
Franklin Hill. Acting Deoutv Director
Jennifer Wilbur
Special Assistant
Thea Williams
Special Assistant
Resources
Management Division
Jennifer Hovis, Acting Director
Vacant, Associate Director
Human Resources Branch
Connie Andrews, Chief
Contracts Management Branch
Barbara McDonough, Chief
Information Management Branch
Jennifer Hovis, Chief
Emily Johnson, Associate Chief
Budget, Planning and Evaluation Branch
Art Flaks, Chief
Alan Youkeles, Associate Chief
Technology Innovation
and Field Services Division
Pamela Barr, Director
Jeffrey Helmerman, Associate Director
Analytical Services Branch
Mel anieHoff, Chief
Technology Integration and
Information Branch
Dan Powell, Chief
Technology Assessment Branch
Gregory Gervais, Chief
Environmental Response Team
Harry Compton, Chief
Marc Greenberg, Deputy Chief (EAST)
Dennisses Valdes, Deputy Chief (WEST)
Assessment and
Remediation Division
Dana Stalcup, Actiiig Director
David E, Cooper. Acting Associate Director I
i i
ector
ate Director
Site Assessment and
Remedy Decisions Branch
Douglas Ainmon, Chief
Community Involvement and
Program Initiatives Branch
Suzanne Wells, Chief
Larry Zaragoza, Associate Chief
Construction and Post-Construction
Management Branch
Richard Jeng, Acting Chief
Science Policy Branch
Michael Scozzafava, Chief
Revised
September 2014
September 30, 2014
Organizational Charts - 2
FY 15 SPIM
-------
OSWER Directive 9200.3-15-1G-Y
U.S. Environmental
Protection Agency
Office of Compliance
(OC)
Director. Lisa C. Lund
DOD: Betsy Smidinger
AD: Mamie Miller
Enforcement Targeting
and Data Division
(ETDD)
Director: John
Dombrowski
DDD: Lucy Reed
Monitoring Assistance
and Media Programs
Division
(MAMPD)
Director: Edward Messina
DDD: Rick Duffy
DDD: Ann Pontius
National Enforcement
Training Institute Division
(NETI)
Director: Mike Walker
DD: Vacant
Planning. Measures and
Oversight Division
(PMOD)
Director:
Christopher Knopes
DDD: Daniel Palmer
Resource Management
Staff
Director: Michael
Richardson
Federal Facilities
Enforcement Office
(FFEO)
Director: David Kling
DOD (A): Richard Albores
Immediate Office
Assistant Administrator: Cynthia Giles
PDAA: Lawrence Starfield
DAA: Shari Wilson
AAA-EJ: Vacant
DAAA-EJ: Charles Lee
Office of Enforcement and
Compliance Assurance
(OECA)
Office of Environmental
Justice
(OBJ)
Director: Matthew Tejada
DOD (A): Sheila Lewis
AD Vacant
Office of Civil
Enforcement
(OCE)
Director Susan
Shinkman
DOD: Pam Mazakas
AD: John P. Fogarty
Office of Criminal
Enforcement, Forensics
and Training
(OCEFT)
Director: Henry Bamet
DOD (A): Julie lastra
AD Vacant
Air Enforcement Division
(AED)
Director: Phillip Brooks
AD (A): Jacqueline
Werner
AD: Apple Chapman
Special Litigation and
Projects Division
(SLPD)
Director (A): Andrew
Stewart
AD: Susan O'Keefe
Waste and Chemical
Enforcement Division
(WCED)
Director (A): Kenneth
Schefski
AD: Don Lett
AD: Vacant
Water Enforcement
Division (WED)
Director: Mark Rollins
DOD (A): Joe Theis
Office of Administration
and Policy
(OAP)
Director: Mark
Badalamente
DOD (A) Kenda Layne
Criminal Investigation
Division
(CID)
Director: Doug Parker
ODD: Ted Stanich
Field Operations Program
(FOP)
Director: Steven C. Drielak
DDD(A): Brian Maas
Legal Counsel Division
(LCD)
Director: Mike Fisher
DDD: Tom Seaton
National Enforcement
Investigations Center
(NBC)
Director: Carol Rushin
DDD: Tom Morris
Office of Site
Remediation Enforcement
(OSRE)
Director: Cyndy Mackey
DOD: Rafael DeLeon
Administration Management
Division
(AMD)
Director: Deborah Caution
Budget and Financial
Management Division
(BFMD)
Director: David Swack
Information Technology
Division (ITD)
Director (A): Kenda Layne
Policy and Legislative
Coordination Division
(PLCD):
Director: Caroline
Emmerson
Policy and Program
Evaluation Division
(PPED)
Director: Monica Gardner
DDD: Helena Healy
Regional Support Division
(RSD)
Director: Ken Patterson
DDD: Karin Leff
Program Operation Staff
(POS)
Director: Laura Milton
Office of Federal
Activities
(OFA)
Director: Susan Bromm
DOD: Kimberley Carney
AD: Cheryl Wasserman
International Compliance
Assurance Division
(ICAD)
Director: Robert Heiss
N EPA Compliance Division
(NCD)
Director: Cliff Rader
(A) = Acting
AAA-EJ = Associate Assistant Administrator for Environmental Justice
AD = Associate Director or Assistant Director
DAA = Deputy Assistant Administrator
DAAA-EJ = Deputy Associate Assistant Administrator for Environmental Justice
DDD = Deputy Division Director
DOD = Deputy Office Director
PDAA= Principal Deputy Assistant Administrator
Revised August 26. 2014
FY 15 SPIM
Organizational Charts -:
September 30, 2014
-------
OSWER Directive 9200.3-15-1G-Y
Office of Emergency Management (OEM)
Reggie Cheatham,ActlngOffic* Director
DanaS. lulls, Deputy Off ice Director
Regulation*
Im plem«nt*tion Division
(RID)
Director: C. Mallhiewen
Deputy Director; K. Jennings
Preparedness & Response
Operations Division (PROD)
Director:G. lozarry
Associate Director:
J. Woodyard
PR7 Leader; B.
Re voureei Management
Division (HMD)
Director: V, van Roden
DefHfty Omctorr I Beasley
EOC & Continuity S/anch
Branch Chief :E.Le*
CBRN Consequence
Management Advisory
Division (CMAO)
Director: E. Canzler
Associate Director: M.
Napilirwki
CBRN OPT Lead:
E. .tokabhaizy
Field Operations Branch
Branch Chief:
P. Ktxlarauikds
September 2014
September 30, 2014
Organizational Charts - 4
FY 15 SPIM
-------
OSWER Directive 9200.3-15-1G-Y
Superfund Program Implementation Manual
FY15
Summary of Changes
FY 15 SPIM September 30, 2014
-------
OSWER Directive 9200.3-15-1G-Y
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September 30, 2014 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Summary of Changes to FY 15 SPIM
Superfund Program Implementation Manual (SPIM) Leads
Jennifer Hovis - Chapters I, IV, VIII, X, XI, XII
Edward Germino - Chapters II, III
Randy Hippen - Chapter V
Brenda Haslett & Patti Ludwig - Chapters VI, IX
Chip Love - Chapter VII
The most notable changes to the SPIM include:
• Content that was duplicative or outdated was removed to present a more streamlined
guidance document
• Content was updated to reflect the migration from the Comprehensive Environmental
Response, Compensation, and Liability Information System (CERCLIS) to the Superfund
Enterprise Management System (SEMS)
Additional summary level changes can be seen in the sections below for each chapter. In addition
to these changes, there were other minor edits and corrections made throughout.
Chapter I: Introduction
• Updated content to reflect the migration to SEMS
• Removed duplicative and outdated content
• Other minor edits and corrections
Chapter II: Performance Measures, Planning and Reporting Requirements
• Updated content to reflect the migration to SEMS
• Removed duplicative and outdated content
• Other minor edits and corrections
Chapter III: Financial Management
• Updated content to reflect the migration to SEMS
• Removed duplicative and outdated content
• Other minor edits and corrections
Chapter IV: SEMS Data Management andSMES Codes
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM (FY2012 -Addendum),
available at http://www.epa.gov/superfund/action/process/spiml2.html
Chapter V — Remedial Site Assessment
• Updated content to reflect 2014-2018 Strategic Plan measure
• Updated content to reflect the migration to SEMS
FY 15 SPIM Summary of Changes -1 September 30, 2014
-------
OSWER Directive 9200.3-15-1G-Y
• Removed the following sections to be included in a new SPIM chapter for Site
Information at a later date
Site Status Indicators, including Final Assessment Decision
Special Initiatives
Sites Archived
Tribal Inventory Information
• Removed duplicative and outdated content
• Renamed Pre-CERCLIS Screening to Pre-Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) screening (PCS), per ongoing work by PCS
guidance revision workgroup
• Clarified guidance regarding PCS
• Updated Site Assessment process chart
• Included Federal Facility Site Reassessment Review as a new activity that gets
Government Performance and Results Act (GPRA) credit
• Added Remedial Site Assessment Completion (RSAC) sub-measures:
Reduce # non-federal sites > 5 years old w/o Preliminary Assessment (PA) by 10%
Address 10% of non-federal sites > 16 years old w/o National Priorities List (NPL)
listing decision
Universes for both sub-measures established at beginning of each year
• Added requirement for regions to review data issues on SEMS report SA-009: Site
Assessment Data Quality prior to end of each fiscal year, per the Office of Inspector
General (OIG) recommendation
• Added information regarding site assessment activity expected durations
• Clarified documentation requirements for Other Cleanup Activity (OCA)
• Added section for cleanup alternatives to describe various cleanup options that can be
selected at conclusion of remedial assessment process
Chapter VI — Removal Program
• Updated content to reflect the migration to SEMS
• Removed duplicative and outdated content
• Revised structure of accomplishment definition sections to more clearly identify data
requirements
• Removed the action qualifier data requirement for Removal Action Starts
• Other minor edits and corrections
Chapter VII — Remedial Program
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM (FY2012 -Addendum),
available at http://www.epa.gov/superfund/action/process/spiml2.html
Chapter VIII-FederalFacility Program
• Updated content to reflect the migration to SEMS
• Removed duplicative and outdated content
September 30, 2014 Summary of Changes - 2 FY 15 SPIM
-------
OSWER Directive 9200.3-15-1G-Y
• Revised structure of accomplishment definition sections to more clearly identify data
requirements
• Other minor edits and corrections
Chapter IX— Enforcement
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM (FY2012 -Addendum),
available at http://www.epa.gov/superfund/action/process/spiml2.html
Chapter X- Community Involvement
• Updated content to reflect the migration to SEMS
• Removed duplicative and outdated content
• Revised structure of accomplishment definition sections to more clearly identify data
requirements
• Other minor edits and corrections
Chapter XI — Information Systems
• Updated content to reflect the migration to SEMS
• Removed duplicative and outdated content
• Other minor edits and corrections
Chapter XII — Records and Information Management
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM (FY2012 -Addendum),
available at http://www.epa.gov/superfund/action/process/spiml2.html
Appendix A — New Initiatives/New Requirements
This appendix has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SP1M (FY2012 -Addendum),
available at http://www.epa.gov/superfund/action/process/spiml2.html
Appendix B - Regional and Headquarters Contacts
• Updated Subject Matter Experts and contacts as of September 2014
Appendix C - Work Planning Memorandum
This appendix has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the SPIM (FY2012 -Addendum),
available at http://www.epa.gov/superfund/action/process/spiml2.html
Appendix D -American Recovery and Reinvestment Act (ARRA)
• Removed outdated content
• Other minor edits and corrections
FY 15 SPIM Summary of Changes - 3 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
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September 30, 2014 Summary of Changes - 4 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Superfund Program Implementation Manual
FY15
Chapter I: Introduction
FY 15 SPIM September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
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September 30, 2014 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
CHAPTER I: Introduction
Table of Contents
LA Purpose 1-1
I.B Introduction 1-2
I.B.I Superfund Legislative Background 1-2
I.B.2 Description of Superfund Response and Enforcement Programs 1-3
a. Superfund Remedial (303DD2) 1-4
b. Superfund Emergency Response and Removal (303DC6) 1-4
c. Federal Facilities Response (303DC9) 1-4
d. Superfund Enforcement (501EC7) 1-4
e. Base Realignment and Closure (303D41 and 303D41B4) 1-5
f. Federal Facilities Enforcement (501EH2) 1-5
I.C Superfund Enterprise Management System (SEMS) 1-5
FY 15 SPIM I-i September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
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September 30, 2014 I-ii FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
CHAPTER I: INTRODUCTION
LA PURPOSE
The Enviornmental Protection Agency (EPA), working in collaboration with other
federal agencies, states, Indian tribes, local governments and affected community members,
manages programs designed to clean up priority hazardous waste sites and releases. These
programs include Superfund, Resource Conservation and Recovery Act (RCRA) Corrective
Action, and Underground Storage Tanks (UST). The focus of these programs is to maximize the
protection of human health and the environment.
The Superfund Program Implementation Manual (SPEVI) provides overarching program
management priorities, procedures, and practices for the Superfund remedial, removal,
enforcement, and Federal Facilities programs, providing the link between the Government
Performance and Results Act (GPRA), EPA's Strategic Plan, and Superfund program internal
processes. The SPEVI provides standardized and common definitions for Superfund program
accomplishments and processes for planning and tracking these accomplishments through
program targets and measures.
The SPEVI is part of EPA's internal control structure, and, as required by the Comptroller
General of the United States through generally accepted accounting principles (GAAP) and
auditing standards, this document defines program scope and schedule in relation to budget, and
is used for audits and inspections by the Government Accountability Office (GAO) and the
Office of the Inspector General (OIG). The SPEVI is updated annually but may also be revised
during the year as needed.
The SPEVI is divided into twelve separate chapters. Chapter I offers an introduction of
Superfund along with descriptions of each of the Superfund programs and the Superfund
Enterprise Management System (SEMS). Chapter II describes the Superfund program measures,
budget and program planning, and reporting requirements. Chapter III describes the financial
management mechanisms within the Superfund program and addresses resource management
topics, financial vehicles for obligating resources, systems and tools that manage financial data,
Superfund resource allocation procedures, Superfund State Contracts (SSCs), and special
accounts. Chapter IV describes SEMS data elements, including codes used for targeting and
reporting accomplishments as well as codes that describe specific budget sources and actions.
The next six chapters highlight program priorities and initiatives and provide detailed
information on annual targets for GPRA performance measures and targets for Key
Programmatic Measures for Superfund programmatic areas, and for the removal, remedial, and
federal facility programs. The chapters are given in the following order: Chapter V: Remedial
Site Assessment, Chapter VI: Removal Program, Chapter VII: Remedial Program, Chapter VIII:
Federal Facility Program, Chapter IX: Enforcement, and Chapter X: Community Involvement.
The last two chapters of the SPEVI are Chapter XI: Information Systems and Chapter XII:
Records and Information Management. Chapter XI describes the various modules of SEMS.
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Chapter XII describes the process of documenting records and information in the SEMS
Document Management System (SDMS)/SEMS.
In addition, there are four Appendices that provide supplemental information to the
SPIM. Appendix A provides details on new and future data initiatives and data reporting
requirements. Appendix B includes subject matter expert and data sponsor contact information
for both Headquarters (HQ) and regional offices. Appendix C contains the most recent remedial
program Work Planning Memo that identifies the scope and schedule of work planning activities
and priorities. Appendix D describes in detail the provisions, reporting requirements, budget
execution guidance and financial management as it relates to American Recovery and
Reinvestment Act (ARRA).
This edition of the SPIM has undergone extensive revision to reflect the recent migration
from multiple legacy information systems to the new, integrated SEMS. Due to the magnitude of
the changes, revisions to all chapters are not yet complete. For chapters that have not been
updated, program staff are directed to the most recent prior edition of the SPIM, the fiscal year
(FY) 2012 Addendum. The following chapters have been updated in this FY 2015 edition to
reflect SEMS:
Chapter 1: Introduction
Chapter 2: Program Measures, Planning and Reporting Requirements
Chapter 3: Financial Management
Chapter 5: Remedial Site Assessment
Chapter 6: Removal Program
Chapter 8: Federal Facility Program
Chapter 10: Community Involvement
Chapter 11: Information Systems
Appendix B: Regional and Headquarters Contacts
Appendix D: American Recovery and Reinvestment Act
LB INTRODUCTION
I.B.I Superfund Legislative Background
Congress passed the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), commonly called Superfund, in 1980. The Superfund program addresses
contamination from uncontrolled releases at Superfund hazardous waste sites that threaten human
health and the environment. The overarching goals of the program are to ensure the protection of
human health and the environment and to maximize the participation of potentially responsible
parties (PRP) in conducting cleanups at sites, also known as "enforcement first." EPA continues to
generally address the worst sites first, while balancing the need to complete response actions at all
contaminated sites.
Prior to CERCLA, there was no authority for direct federal response to hazards posed by
abandoned and uncontrolled hazardous waste sites. Existing environmental laws, such as RCRA,
provided regulatory requirements to address present activities and prevent future catastrophes,
but lacked authority to allow federal emergency and long-term responses to past hazardous waste
disposal problems.
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CERCLA is unique in that it provided the first federal response authority to address the
problem of uncontrolled hazardous waste sites. CERCLA, for the first time, required EPA to step
beyond its traditional regulatory role and provide response authority to clean up hazardous waste
sites.
In October 1986, Congress reauthorized CERCLA by enacting the Superfund
Amendments and Reauthorization Act (SARA). SARA included Title III, a freestanding statute
that created the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA is
designed to help communities prepare to respond in the event of a chemical emergency, and to
increase the public's knowledge of the presence and threat of hazardous chemicals. SARA also
included the Defense Environmental Response Program (DERP) which authorized the
Department of Defense to create a response program similar to EPA's Superfund remedial
program.
The major regulatory framework that guides Superfund response efforts is the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP). The NCP outlines a step-by-
step process for implementing Superfund responses and defines the roles and responsibilities of
EPA, other federal agencies, states, tribes, private parties, and the communities in response to
situations in which hazardous substances are released into the environment.
The Omnibus Reconciliation Act of 1990, which extended Superfund authority, expired
in 1994. Since 1994, many Congressional bills have been advanced to reauthorize the Superfund
program, but none have been enacted. Many aspects of the program that have been subject to
reauthorization proposals have been addressed through Superfund administrative reform.
Through the act of appropriations, SARA authority for the Superfund program has been extended
annually. During the 1990s, through various Defense Authorization Acts, Congress has modified
provisions of section 120, particularly those related to transfer of contaminated properties.
On January 11, 2002, President Bush signed into law the Small Business Liability Relief
and Brownfields Revitalization Act (Public Law 107-188; H.R. 2869). The law provides a new
definition of Brownfields as real property, the expansion, redevelopment, or reuse of which may
be complicated by the presence or potential presence of a hazardous substance, pollutant, or
contaminant. The law expands potential financial and technical assistance for Brownfields
cleanup and revitalization, including grants for assessment, cleanup, and job training. In addition,
the law provides limited liability relief to certain contiguous property owners and prospective
purchasers of contaminated properties, and clarifies the innocent landowner defense to encourage
Brownfields cleanup and redevelopment. The law also enhances the roles and funding for state
and tribal response programs.
I.B.2 Description of Superfund Response and Enforcement Programs
The Superfund budget reflects a continued commitment to implementing GPRA with
emphasis on completing construction at contaminated waste sites and maximizing PRP
involvement in site cleanup. Each Superfund program/project addresses a different set of goals
and priorities to achieve these aims. The following descriptions are adapted from the Agency
Program Project Description Book.
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a. Superfund Remedial (303DD2)
The Superfund remedial program implements numerous processes to determine the need
for and to conduct response actions. These processes include collecting data on sites to
determine the need for CERCLA response, adding sites to the National Priorities List
(NPL) conducting or overseeing investigations and studies to select remedies, designing
and constructing or overseeing construction of remedies and post-construction activities
at non-federal facility sites, including returning sites to productive use. Additionally, the
remedial program works closely with states and communities to ensure their meaningful
involvement in cleanup decisions and implementation activities. The remedial program
also conducts technical and administrative support activities to assist, monitor, and track
response actions to ensure remedies are and remain protective, to provide public
accountability, and to recover costs from PRPs, redevelopment functions, participation of
states, tribes, and communities in cleanups, and enhancement of response capabilities of
states and tribes.
b. Superfund Emergency Response and Removal (303DC6)
EPA's Emergency Response and Removal (ERR) program responds to chemical, oil,
biological, and radiological releases and large-scale national emergencies, including
homeland security incidents. More than 250 On-Scene Coordinators and other ERR staff
ensure that releases of hazardous substances and oil in the inland zone are appropriately
addressed when state and local first responder capabilities have been exceeded or where
additional support is needed. They also direct or monitor responses by responsible parties
or other agencies. The first priority is to prevent, reduce, or mitigate threats posed by
releases or potential releases of hazardous pollutants. The ERR program prioritizes and
provides services to sites that are known to pose greater actual or potential risk to public
health and the environment. In carrying out these responsibilities, the ERR program
coordinates with other EPA programs (including the Superfund remedial program), other
federal agencies, states, tribes, and local governments.
c. Federal Facilities Response (303DC9)
The Agency's Superfund federal facilities response program provides technical and
regulatory oversight at federal facilities, including Formerly Used Defense Sites (FUDS),
to ensure protection of human health and the environment, effective program
implementation, and meaningful public involvement, while facilitating restoration and
reuse of the properties. The federal facilities program provides oversight of removal,
remedial, and post-remedial work conducted by other federal agencies; this may include
technical assistance, document review, and stakeholder involvement assistance to other
federal agencies when their facilities are on the NPL.
d. Superfund Enforcement (501EC7)
The Superfund enforcement program works to ensure that PRPs either clean up
contaminated sites themselves or pay for a cleanup performed by others (i.e., EPA, a
state, or other PRPs). Superfund enforcement activities include finding the companies or
people responsible for contamination at a site; determining whether those PRPs have an
ability to pay for the cleanup; maximizing PRP performance of cleanups by negotiating
Remedial Design/Remedial Action (RD/RA) and removal settlement agreements or
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issuing unilateral orders to all appropriate parties; monitoring and ensuring PRP
compliance with performance or payment obligations under those enforcement
instruments to ensure timely and protective cleanups at Superfund sites; and addressing
cost recovery cases where Trust Fund dollars have been used to clean up sites.
e. Base Realignment and Closure (303D41 and 303D41B4)
Base Realignment and Closure (BRAC) is an EPA/Department of Defense (DOD)
supported reimbursable program carrying out accelerated cleanup at selected BRAC sites
with the ultimate goal of providing for rapid economic conversion and redevelopment for
the local communities affected by base closure. DOD provides reimbursement to EPA on
an annual basis to fund EPA work years (FTEs) for the Agency's participation at selected
DOD BRAC installations. EPA's role is to ensure protection of human health, effective
program implementation, and meaningful public involvement while facilitating
restoration and reuse of DOD's excess properties.
f. Federal Facilities Enforcement (501EH2)
The Federal Facilities Enforcement Office as well as the federal facilities regional
programs ensures that federal agencies who own sites currently listed on the NPL have an
Interagency Agreement (IA) in place to ensure clean up and compliance with federal
environmental statutes and regulations. lAs are also referred to as Federal Facilities
Agreements (FFAs). The following is a detailed list of activities supporting this program.
• Developing CERCLA guidance and policies for the federal facilities enforcement
program;
• Negotiating FFAs/IAs with federal agencies whose sites are listed on the NPL;
• Monitoring milestones provided in the FFAs/IAs to ensure full implementation;
• Using dispute resolution to ensure full implementation of FFA/IA; and
• Assessing stipulated penalties and using supplemental environmental projects
when appropriate.
/ C SUPERFUND ENTERPRISE MANAGEMENT SYSTEM (SEMS)
In FY 2014, the Office of Superfund Remediation and Technology Innovation (OSRTI)
completed the integration of several legacy systems into SEMS, including the Comprehensive
Environmental Response, Compensation and Liability Information System (CERCLIS), SDMS,
the Institutional Controls Tracking System (ICTS), the eFacts reporting tool, and ReportLink.
The following points outline the purpose of SEMS:
• Integrating the primary Superfund data collections, reporting and tracking systems into a
single system;
• Meeting both immediate and strategic, long-term Superfund needs;
• Serving as an official source of primary Superfund site activity data, records, and support
documentation for internal and external stakeholders;
• Improving operational effectiveness, reducing costs, streamlining business processes, and
enhancing information management capabilities; and
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• Adapting to meet ever-changing environmental, federal and agency needs yet tailored to
meet the unique requirements of the Superfund program.
SEMS is the Superfund program's accomplishment planning and tracking data
management system. It is the Superfund program's primary data source to answer questions from
the public, Superfund stakeholders, Congress, federal and state agencies, and EPA national
program managers on the status of Superfund program accomplishments. Regions plan current
and outyear site and non-site-specific accomplishments and resource use in SEMS as well as use
the system to report on actual accomplishments. EPA response and enforcement program
activities and milestones as well as state and PRP performance are tracked in SEMS. HQ uses
SEMS data as the basis for tracking, managing, and reporting on national program performance.
SEMS also continues to serve as the Superfund program's official repository of electronic
records.
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Superfund Program Implementation Manual
FY15
Chapter II: Performance Measures, Planning and Reporting
Requirements
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CHAPTER II: Performance Measures, Planning and Reporting
Requirements
Table of Contents
II. A Introduction II-l
II.B Performance Goals and Measures II-l
II.B.l Removal Program Measure II-5
II.B.2 Remedial and Federal Facilities Program Measures II-5
a. Number ofSuperfund Remedial Site Assessments Completed
(Site Assessments) II-5
b. Number of Remedial Action Project Completions at Superfund NPL sites
(Remedial Action (RA) Projects) II-5
c. Annual Number ofSuperfund Sites with Remedy Construction
Completed (CCs) 11-6
d. Number ofSuperfund Sites with Human Exposures Under Control 11-6
e. Superfund sites with contaminated groundwater migration under control 11-6
f Number ofSuperfund sites Ready for Anticipated Use Sitewide (SWRA U) 11-6
g. Acres "Protective for People Under Current Conditions " (PfP) 11-7
h. Acres "Ready for Anticipated Use" (RAU) 77-7
II.B.3 Enforcement Program Measures II-7
a. Pre-Remedial Enforcement Action 77-7
b. Past Costs Addressed > $500,000 77-7
c. Volume of Contaminated Media Addressed (VCMA) - Soil and Groundwater... 11-7
d. Total Response Commitments 77-5
e. Total Cost Recovery Settlements 11-8
f. Value of~PRP Oversight 77-5
II. C Annual Performance Plan and Budget Development Cycle II-8
II.C.l Outyear II-8
II.C.2 Planning Year II-9
II.C.3 Current Year II-9
II.D Planning and Reporting Cycle 11-12
II.D.l Third Quarter 11-12
a. Current Year Performance Tracking 77-72
b. Planning for the Upcoming Year 77-73
II.D.2 Fourth Quarter 11-13
a. Planning for the Upcoming Year 77-73
b. End of Year Performance Tracking 77-73
II.D.3 First Quarter (of the subsequent year) 11-14
a. Planning for the Current Year 77-74
b. Prior Year Performance Tracking 77-74
II.E Planning, Target, and Accomplishment Reports 11-14
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II.E. 1 OSRTI Management Reports for Planning/Target Setting and Accomplishment
Reporting 11-14
II.E.2 OSRE Management Reports 11-15
II.E.3 FFRRO Management Reports 11-16
List of Exhibits
Exhibit II. 1. Superfund Performance Measures II-2
Exhibit II.2. Budget Planning Timeline 11-10
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CHAPTER II: PERFORMANCE MEASURES, PLANNING AND
REPORTING REQUIREMENTS
ILA INTRODUCTION
The Office of Emergency Management (OEM), Office of Superfund Remediation and
Technology Innovation (OSRTI), the Federal Facilities Enforcement Office (FFEO), the Office
of Site Remediation Enforcement (OSRE), and the Federal Facilities Restoration and Reuse
Office (FFRRO) are responsible for overall program planning and for reporting on Superfund
program accomplishments. This chapter describes the Environmental Protection Agency's (EPA)
performance measurement approach generally, and, more specifically, the Superfund program's
processes for planning, budgeting, tracking, and reporting progress internally and externally.
ILB PERFORMANCE GOALS AND MEASURES
The Government Performance and Results Act (GPRA) of 1993 provides a general
framework for government accountability through the use of strategic planning. Under this
framework, EPA develops strategic plans, annual performance goals and other measures, and
national program offices develop planning and tracking mechanisms as well as conduct program
evaluations to ensure the Agency meets its goals effectively and efficiently.
EPA's Strategic Plan is the foundation of the Agency's planning and budgeting process.
The Strategic Plan is a five-year plan outlining the Agency's mission that establishes
quantifiable goals and objectives, including GPRA Performance Measures, and describes the
means and strategies that EPA programs employ to accomplish environmental results over a
multi-year period. The Agency must update the Strategic Plan every three years or more often
when there is significant policy, programmatic, or other type of change to the current plan.
EPA's Annual Performance Plan defines the Agency's annual budget goals and
objectives in greater detail by linking the annual budget to the Strategic Plan. The Annual
Performance Plan contains Annual Performance Plan Commitments (Annual Commitments) for
meeting the GPRA Performance Measures in the Strategic Plan as well as additional agency
performance measures. The Annual Commitments are calculated to ensure the successful
accomplishment of each five-year cumulative GPRA Performance Measure set by the Strategic
Plan. The President's annual budget request to Congress, known as the Justification of
Appropriation Estimates for the Committee on Appropriations (also known as the Congressional
Justification) also contains the Annual Commitments.
Each year in November, the Agency publishes the Performance and Accountability
Report (PAR), which summarizes the program performance for the fiscal year (FY) just ended.
The PAR consists of three reports, a summary Highlights Report, the Agency Financial Report,
and the Annual Performance Report. The Annual Performance Report provides the results EPA
achieved against its Annual Commitments and progress toward the long-term goals established
in the Agency's Strategic Plan.
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EPA's senior leadership also tracks Key Performance Indicators (KPIs) to advance
Strategic Goals and Cross-Cutting Fundamental Strategies described in EPA's Strategic Plan.
KPIs are a subset of the existing Annual Commitments that are tracked in Annual Commitment
System (ACS), which is a performance tracking module in the Agency's Budget Automated
System (BAS).
In addition, EPA maintains High Priority Performance Goals (HPPGs), which are
measurable commitments that represent high priorities for the Agency, have high relevance to
the public or reflect the achievement of key agency missions, and will produce significant,
measurable results over the next 12 to 24 months. The HPPGs for the Superfund program are
also a subset of the program's existing Annual Commitments.
Finally, Cross-Program Revitalization Measures are a collection of indicators and
performance measures that represent the Agency's effort to document progress toward land
revitalization across all of the Office of Solid Waste and Emergency Response's various cleanup
programs: Brownfields, Superfund, Resource Conservation and Recovery Act (RCRA)
Corrective Action, Underground Storage Tanks (UST), Federal Facilities Response, and
Emergency Response. With hundreds of communities having reclaimed formerly contaminated
properties for ecological, recreational, commercial, residential and other productive uses, EPA
has recognized the importance of measuring these revitalization accomplishments in order to
better capture and communicate their potential benefit and impact. These measures are reported
through the Superfund Program Redevelopment webpage:
(http://www.epa.gov/superfund/programs/recycle/effects/index.html).
Exhibit III identifies the venues where the Superfund measures are reported and also
identifies which Superfund programs are responsible for which measures. A description of each
measure is in the next section.
EXHIBIT ILL SUPERFUND PERFORMANCE MEASURES
Measure Name
Removal actions
completed
annually
Number of
Superfund
remedial site
assessments
completed
(Site
Assessments)**
Number of
Remedial Action
project
completions at
Superfund
National
Strategic
Plan GPRA
Performance
Measures
X
X
Annual
Performance
Plan
Commitments*
X
(ACS#137)
X
(ACS #122)
X
(ACS #131)
Key
Performance
Indicators
High Priority
Performance
Goals
Cross-
Program
Revitalization
Measures
Responsible
Superfund
Program
Removal
Remedial,
Federal
Facilities
Remedial,
Federal
Facilities
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Measure Name
Priorities List
(NPL) sites
(RA Projects)**
Annual number
of Superfund
sites with
remedy
construction
completed
(CCs)**
Number of
Superfund sites
with human
exposures under
control
(HEUC)**
Superfund sites
with
contaminated
groundwater
migration under
control
(GWMUC)**
Number of
Superfund sites
ready for
anticipated use
sitewide
(SWRAU)**
Acres
"Protective for
People Under
Current
Conditions"
(HP)
Acres "Ready
for Anticipated
Use" (RAU)
Pre-Remedial
Enforcement
Action at
Superfund Sites
Past Costs
Addressed >
$500,000 via
Settlements,
Referral, Write-
off, or Claims in
Bankruptcy
Volume of
Strategic
Plan GPRA
Performance
Measures
X
X
X
X
X
Annual
Performance
Plan
Commitments*
x
(ACS #141)
X
(ACS #151)
x
(ACS #152)
X
(ACS #S10)
OSRE-01
OSRE-02
HQ-VOL
Key
Performance
Indicators
X
(ACS #151)
X
(ACS#S10)
High Priority
Performance
Goals
X
(ACS #S10)
Cross-
Program
Revitalization
Measures
x
X
Responsible
Superfund
Program
Remedial,
Federal
Facilities
Remedial,
Federal
Facilities
Remedial,
Federal
Facilities
Remedial,
Federal
Facilities
Remedial,
Federal
Facilities,
Remedial,
Federal
Facilities,
Enforcement
Enforcement
Enforcement
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Measure Name
Contaminated
Media
Addressed
(VCMA)
Total Response
Commitments
Total Cost
Recovery
Settlements
Value of
Potentially
Responsible
Party (PRP)
Oversight
Strategic
Plan GPRA
Performance
Measures
Annual
Performance
Plan
Commitments*
Key
Performance
Indicators
High Priority
Performance
Goals
Cross-
Program
Revitalization
Measures
Responsible
Superfund
Program
Enforcement
Enforcement
Enforcement
*Code numbers are provided for each measure tracked in ACS or the Integrated Compliance Information
System (ICIS).
**Beginning in FY 2014, performance measure results include non-NPL sites with Superfund Alternative
Approach (SA Approach) Agreements
To support the GPRA framework, the Agency has several management and reporting
tools to track its plans and accomplishments. The Office of the Chief Financial Officer (OCFO)
uses the ACS to facilitate the development and tracking of the Annual Commitments by each
EPA program, including Superfund. OCFO annually issues National Program Manager (NPM)
guidance identifying the schedule for entering data into ACS. Coordinators in the Office of Solid
Waste and Emergency Response (OSWER) and the Office of Enforcement and Compliance
Assurance (OECA) work with their regional counterparts to ensure that the regional programs
are aware of the schedule for entering draft and final bids and final performance commitments
into ACS. Regions negotiate their own specific commitments with Headquarters (HQ) during
annual work planning sessions. The work planning process is discussed in section II.D.2 in more
detail.
The Integrated Compliance Information System (ICIS) is a web-based national database
for federal (and some state) enforcement and compliance data, and is managed by OECA's
Office of Compliance. ICIS is a comprehensive tool which integrates data from all media,
including Superfund, and allows users to access multi-media enforcement and compliance data.
The database is primarily used for programmatic management of EPA's federal enforcement and
compliance (FE&C) program. ICIS is used by OECA and the regions to manage information
associated with the Volume of Contaminated Media Addressed (VCMA) GPRA measure.
Annually, OECA issues the Reporting Plan memorandum and its attachments which contain a
schedule and detailed instructions for reporting FE&C activities and results for the FY. Deputy
Regional Administrators (DRAs) certify to the accuracy and completeness of the ICIS and the
Superfund Enterprise Management System (SEMS) data during a mid-year and end-of-year
certification process lead by the Office of Compliance.
SEMS is an internal management tool used by program staff and managers to plan and
track program activities and resource use. Various SEMS reports are used by senior Superfund
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managers in the Office of Solid Waste and Emergency Response (AA OSWER), the Office of
Enforcement and Compliance Assurance (AA OECA), and the regions to monitor the progress
each region is making towards achieving annual performance goals described in the Agency's
Strategic Plan as well as help the program project future program performance.
ILB.l Removal Program Measure
Removal Actions Completed
This measure tracks the number of removal completions performed by EPA or overseen
by EPA where the primary responsible party has been identified and is performing the
cleanup with or without an enforcement instrument (e.g., Administrative Order on
Compliance [AOCs], Unilateral Administrative Order [UAOs] or voluntary agreements).
The Agency or PRP is responding to the release of hazardous substances with the goal of
cleaning the contamination and protecting human health and the environment. Removal
actions fall into one of three categories: 1) emergency, 2) time-critical, and 3) non-time
critical. EPA is the lead for Superfund-lead removal actions when the responsible party
cannot be identified or is unable to perform the cleanup. Funding for these actions comes
from Superfund, established as part of Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA).
II.B.2 Remedial and Federal Facilities Program Measures
a. Number of Superfund Remedial Site Assessments Completed (Site Assessments)
Remedial site assessments are performed to determine and recommend the appropriate
responses to releases of hazardous substances to the environment, including whether or
not there is a need for remedial cleanup or further EPA involvement. Completing site
assessments determines which cleanup program is the best approach for addressing site
conditions (National Priorities List [NPL], removal, state voluntary cleanup program,
etc.). This also allows the program to show benefits earlier in the cleanup process. The
remedial site assessment measure also includes two related sub-measures: 1) reduce the
number of non-federal sites over five years old without a preliminary assessment
completed by 10 percent; and 2) address 10 percent of non-federal sites over 16 years old
without an NPL listing decision. Federal facilities site assessment is performed by federal
agencies (E.O. 12580) and only reviewed by EPA in accordance with the Hazardous
Ranking System (FIRS) criteria. More information about the site assessment measure can
be found in chapter V, titled "Remedial Site Assessment."
b. Number of Remedial Action Project Completions at Superfund NPL sites
(Remedial Action (RA) Projects)
This measure demonstrates progress in reducing risk to human health and the
environment, since multiple Remedial Action (RA) projects may be necessary prior to
achieving site-wide construction completion. Completion of the RA is documented in a
Remedial Action Report (see Close Out Procedures for NPL Sites, OSWER 9320.2-22,
May 2011). More information about the RA Projects measure can be found in chapter
VII, titled "Remedial Program."
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c. Annual Number of Superfund Sites with Remedy Construction Completed
(CCs)
Construction completion means physical construction of all cleanup actions is finished at
a site, including actions to address all immediate threats and to bring all long-term threats
under control. This measure tells the public that a site has generally entered a phase of
long-term, routine operation and maintenance. Construction completion is documented in
a Preliminary Close Out Report (see Close Out Procedures for NPL Sites, OSWER
9320.2-22, May 2011), and requires HQ's concurrence. More information about the CCs
measure can be found in chapter VII, titled "Remedial Program."
d. Number of Superfund Sites with Human Exposures Under Control
The Human Exposure Under Control (HEUC) environmental indicator documents long-
term human health protection on a site-wide basis by measuring the progress achieved in
controlling unacceptable human exposures to contamination at an NPL site. Information
about the HEUC indicator is available on EPA's website at:
http ://www. epa. gov/superfund/accomp/ei/ei. htm.
More information about the HEUC indicator can be found in chapter VII, titled
"Remedial Program."
e. Superfund sites with contaminated groundwater migration under control
The Groundwater Migration Under Control (GWMUC) environmental indicator
documents whether contamination is below protective, risk-based levels or, if not,
whether the migration of contaminated groundwater is stabilized and there is no
unacceptable discharge to surface water. Monitoring is conducted to confirm that affected
groundwater remains in the original area of contamination. Information about the
GWMUC indicator is available on EPA's website at:
http ://www. epa. gov/superfund/accomp/ei/ei. htm.
More information about the GWMUC indicator can be found in chapter VII, titled
"Remedial Program."
f. Number of Superfund sites Ready for Anticipated Use Sitewide (SWRAU)
The Sitewide Ready for Anticipated Use (SWRAU) measure tracks sites where all
physical construction of remedies is complete, human exposure is under control, and all
Institutional Controls are in place. SWRAU demonstrates the Agency's efforts to make
sites ready for reuse. This is an integral part of the Superfund process and reflects the
importance of considering future land use as part of the cleanup. It also demonstrates that
land at Superfund sites is available for the anticipated reuse as specified in the Record of
Decision (ROD) or other decision documents. Information about the SWRAU measure is
available on EPA's website at:
http://www.epa.gov/superfund/programs/recycle/effects/swrau.html.
More information about the SWRAU measure can be found in chapter VII, titled
"Remedial Program."
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g. Acres "Protective for People Under Current Conditions" (PfP)
Before a site is ready for anticipated use, it can be protective for people. This means that
human exposure is under control, but not all remedial actions have necessarily been
completed and/or all ICs are not in place. Measuring land revitalization accomplishments
communicates the benefits of land cleanup. This measure is the number of acres and sites
where no complete pathway for human exposures to unacceptable levels of
contamination exists based on current site conditions. Information about Cross Program
Revitalization Measure (CPRM) measures, including eligible sites, is available on EPA's
website at:
http ://www. epa.gov/superfund/programs/recycle/effects/cprm .html.
h. Acres "Ready for Anticipated Use" (RAU)
Measuring land revitalization accomplishments communicates the benefits of land
cleanup. This measure communicates to the public the number of acres which are ready
for anticipated use. Information about CPRM measures, including eligible sites, is
available on EPA's website at:
http://www.epa.gov/superfund/programs/recycle/effects/cprm.html.
II.B.3 Enforcement Program Measures
a. Pre-Remedial Enforcement Action
Pre-Remedial Enforcement Action at Superfund sites is intended to maximize Potentially
Responsible Party (PRP) participation by reaching a settlement or taking an enforcement
action by the time of the RA start at 99% of non-federal Superfund sites (with RA
starting during the FY), that have known viable, liable parties. Also, see chapter IX, titled
"Enforcement," for further discussion on the measure.
b. Past Costs Addressed > $500,000
Past Costs Addressed is the decision either to take cost recovery action by use of
administrative cost recovery settlement, to transmit a section 106/107 or 107 judicial
referral for cost recovery, including settlements for past costs under a Consent Decree
(CD) (with no prior litigation referral); to prepare a decision document or 10-point
settlement analysis document not to pursue cost recovery, or to file a claim in bankruptcy
at 100% of sites with statute of limitation (SOL) cases and unaddressed past Superfund
costs greater than or equal to $500,000. Also, see chapter IX, titled "Enforcement," for
further discussion on the measures.
c. Volume of Contaminated Media Addressed (VCMA) - Soil and Groundwater
By 2015, The OECA program will obtain commitments to clean up 1.5 billion cubic
yards of contaminated soil and groundwater media nationally as a result of concluded
enforcement actions. This measure is a national measure with an annual target of 200
million cubic yards per FY. Information for this target is entered into OECA's ICIS
database. Further information on calculating the VCMA may be found in the "Final
Methodology for Estimating Superfund and RCRA Corrective Action (CCDS)
Environmental Benefits 12-12-03." Also, see chapter IX, titled "Enforcement," for
further discussion on the measures.
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OSWER Directive 9200.3-15-1G-Y
d. Total Response Commitments
Total Response Commitments is the total universe of CERCLA enforcement instruments
(CDs, UAOs, AOCs, Consent Agreements [CAs], Bankruptcy Settlements and
Judicial/Civil Judgments [JGs]) where the parties agree to conduct cleanup work and/or
make cash payments toward future response costs at a site. The value of Total Response
Commitments is based on the estimated value of PRP response work and/or payments
(cashout) made by responsible parties toward response costs at a site. Also, see chapter
IX, titled "Enforcement," for further discussion on the measures.
e. Total Cost Recovery Settlements
Total Cost Recovery Settlements is the total universe of CERCLA enforcement cost
recovery settlements (CDs, AOCs, CDs, CAs, Bankruptcy Settlements, JGs, and
Administrative/Voluntary Cost Recovery actions i.e., demand letters) where the parties
agree to pay past costs to the Agency. Also, see chapter IX, titled "Enforcement," for
further discussion on the measures.
f. Value of PRP Oversight
The Value of PRP Oversight is the total amount billed to PRPs for PRP-lead actions
where a settlement document is in place with EPA that provides for payment of federal
oversight costs. Also, see chapter IX, titled "Enforcement," for further discussion on the
measures.
ILC ANNUAL PERFORMANCE PLAN AND BUDGET DEVELOPMENT
CYCLE
The Agency's budget and the Annual Performance Plan are developed hand-in-hand.
The budget development process is ongoing, and, in any given month, activities may be taking
place for several budget years at the same time. In any given year, the Agency is concurrently
formulating the President's request for the outyear budget, planning the upcoming year's budget,
and implementing (executing) the current year budget.
ILC.l Outyear
Outyear preparation of the Annual Performance Plan and budget formulation process
begins in the spring, eighteen months prior to the start of the FY for which the budget is being
prepared. Budget formulation is guided by the Agency's Strategic Plan, the Annual Performance
Plan, agency initiatives, and other emerging priorities. The Annual Performance Plan includes
objective, results-oriented, quantifiable, and measurable performance goals; resources necessary
to meet goals; performance indicators to assess outputs, services, and outcomes; and verification
and validation procedures. Development of the budget requires identification of major program
issues, analysis of program costs, and alignment of resources among competing priorities. The
plan, initiatives, priorities, and the budget are established through a series of executive level
meetings, which take place in the late spring and early summer.
EPA program offices generally submit budget formulation proposals to OCFO in the late
spring. SEMS outyear planning data are used to inform senior managers of Superfund program
resource trends and highlight opportunities to invest or disinvest in specific initiatives. As such,
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high quality site planning data are essential. Once the proposals pass through an internal review
process, EPA submits its proposal to the Office of Management and Budget (OMB) in the late
summer. After the late fall OMB "passback", during which time other revisions to EPA's
proposals may be made, the President submits a final budget (Annual Performance Plan and
Congressional Justification) to Congress by the first Monday in February for the new FY
beginning on October 1.
II.C.2 Planning Year
The second component of the budgeting process begins the summer before the upcoming
FY and involves revising the budget in anticipation of enactment of an appropriation and
determination of the allocation of funds for the regions for the new FY. During Phase I of
operating plan development, OCFO sets preliminary targets, based on the President's budget
request, for the national programs to use for developing initial resource allocations for regional
budgets by budget object class (BOC) and other categories so that the financial system will be
ready to make funds available once an appropriation (or continuing resolution) is passed. OCFO
pre-calculates the regional targets for some of these categories, such as budgets for non-site
travel, working capital fund, workforce support, and payroll. The Superfund national program
offices determine resource allocations for the regions for the other BOC categories, including
contracts and interagency agreements, grants and cooperative agreements, and site travel, but are
not required to distinguish the allocations among these BOCs. OSWER program offices allocate
most of these resources to the regions using Site Allowance codes that allow these program
offices to budget the use of regional resources at a more detailed level in the Agency's financial
system. OSRE does not use a Site Allowance code for budgeting enforcement resources to the
regions, but the OSRE regional allocation is still often referred to as a Site Allowance.
Some HQ program offices (the remedial program in particular) initially assign most of
the resources to a Regional Reserve, which does not identify the specific amounts that individual
regions will receive in the upcoming year. Rather, during annual work planning meetings that
start in late summer, HQ program offices review and analyze regional Superfund implementation
and funding plans (based on SEMS data) and develop preliminary budget estimates for the
regions for the upcoming year. The financial management components of this manual focus on
the use of resources issued to the regions through the Site Allowances. A description of the
financial management process is outlined in chapter III, titled "Financial Management."
II.C.3 Current Year
Phase II of operating plan development advances the planning year into the budget
execution year as the new FY begins and the appropriation is enacted by Congress. Enacted
operating plans for HQ and regional offices are finalized in the Agency's BAS by BOC, and
OCFO issues initial resources to the programs through the Agency's financial management
system.
Those HQ Superfund program offices that maintain Regional Reserve resources will send
(issue or reprogram) these resources to individual regions throughout the course of the year in
Site Allowances according to site-specific allocation methodologies, formulas, or funding plans
(program-specific details are provided in the section on Site Allowances). For example, once
funds become available, the HQ remedial program office will develop a preliminary ongoing
construction funding plan and issue first quarter RA and Pipeline Operations Site Allowance
FY 15 SPIM II-9 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
resources to the regions. The HQ remedial program office will issue additional funds later in the
year, taking into consideration changing regional plans.
In some years, an appropriation is not enacted by the start of the FY, and Congress passes
one or more continuing resolutions (CRs) to fund the government until a final appropriation is
enacted. Under a CR, only a portion of the annual appropriation is made available for the
Agency's use. OCFO issues special guidance to address funding issues under the CR, and any
increases, reductions or mandated redirections are reflected in the Agency's final operating plan.
Under short term CRs, the program offices work very closely with the regions to determine the
funding needs on a monthly (or weekly) basis to ensure that the limited available resources are
allocated where needed.
Superfund HQ program offices expect regions to work within the annual regional
Superfund budgets allocated to them. Agency-wide policy allows regions and HQ offices to shift
resources among programs (e.g., Superfund remedial and Superfund enforcement) on a limited
basis throughout the year as long as they are consistent with specific program office and OCFO
policies regarding those shifts. Within a specific program (e.g., Superfund remedial), regional
Superfund program offices may shift appropriated funds among Site Allowances (e.g., Pipeline
Operations and Remedial Action), but only with prior HQ program office approval. HQ program
offices also use a mid-year evaluation/review process to assess progress in meeting performance
targets and to realign resources in the current FY. Current year resource adjustments focus on
changes needed due to cost and project schedule modifications. Changes may result in resource
shifts both within program areas and among regions.
Exhibit II.2 provides a timeline for the formulation, planning, and execution processes.
Timing for some activities is dependent on the completion of other actions; e.g., occasions when
Congress does not pass an appropriation by the beginning of the FY.
EXHIBIT II.2. BUDGET PLANNING TIMELINE
Month
Outyear Budget
(FY2)
Planning Year Budget
(FY1)
Current Year Budget
(FYO)
(From September Outyear
Budget FY)
October
(From September Plan Budget
FY)
Congress provides resources to
the Agency in the form of an
annual appropriation or
continuing resolution.
OCFO loads resources into
Compass enabling spending, and
once the appropriation is
enacted, EPA submits the
Agency's Operating Plan to
Congress to finalize the enacted
budget. OSWER develops
preliminary ongoing
construction funding plan and
issues first quarter RA and
Pipeline Operations Site
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11-10
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Month
November
December
January
February
March
April
May
June
July
August
Outyear Budget
(FY2)
Revision to the Agency's
Strategic Plan begins
Annual national goal meetings
are held
OSWER pulls programs and
financial planning information
from SEMS to assist OSWER
managers develop proposals
National planning meetings are
held and NPMs submit
investment/disinvestment
proposals
OMB sets budget targets and
OCFO issues policy for budget
formulation
OCFO begins review process of
national program proposals,
develops a straw budget, and
conducts a budget forum
Agency leadership makes budget
decisions and EPA submits
Planning Year Budget
(FY1)
OMB passback of budget
request
HQ appeal of the OMB budget
passback
President submits budget request
to Congress
Congressional Appropriation
Hearing on President's Budget
Regions submit and OSWER
pulls program and financial
planning information from
SEMS (planning year budget
process begins here)
OSWER reviews and analyzes
regional budget estimates.
Phase I operating plan
development data are entered
into BAS.
OECA develops allocation of
enforcement site allowance for
Phase I operating plan.
OSWER/OECA/regions hold
work planning meetings to
Current Year Budget
(FYO)
Allowance resources to regions.
OECA and the Office of
Compliance (OC) approve
allocation of the initial technical
enforcement Site Allowance and
the full year Site Allowance for
the legal case budget
OCFO issues prior year
carryover
OSWER issues second quarter
RA Site Allowance resources to
regions
Third quarter response Site
Allowances and remaining call
memo for Enforcement Site
Allowance are issued
Mid-year assessment held to
evaluate regional progress and
utilization of regional
programmatic budgets
OSWER issues third quarter RA
Site Allowance allocation to
regions. OECA issues second
allocation of Enforcement Site
Allowance resources.
OSWER generally begins to
approve recertification requests
of deobligated resources (may
occur earlier)
Fourth quarter response Site
Allowances calculated
OSWER issues fourth quarter
RA Site Allowance resources
and final allocation of Pipeline
Site Allowance resources.
HQ pulls target/accomplishment
and financial data from SEMS
for analysis of program
accomplishments and
obligation/commitment rate.
OSWER/OECA continues to
pull target/accomplishment and
FY 15 SPIM
11-11
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OSWER Directive 9200.3-15-1G-Y
Month
Outyear Budget
(FY2)
Planning Year Budget
(FY1)
Current Year Budget
(FYO)
proposed budget to OMB on the
second Monday of the month.
establish budget/targets for
planning year.
financial data from SEMS for
analysis of program
accomplishments and regional
obligation commitment rate.
September
(Go to beginning of Planning
Year Budget)
OSWER develops preliminary
ongoing construction funding
plan
(Go to beginning of Current
Year Budget).
ILD PLANNING AND REPORTING CYCLE
The Superfund planning and reporting process is roughly a 16-month cycle beginning in
June. The cycle ends with final accomplishment reporting after the completion of the fiscal
implementation year. Because the duration of this cycle exceeds a year, multiple cycles overlap,
which means the regions and HQ conduct reporting activity for the current year and planning
activity for subsequent years at the same time.
ILD.l Third Quarter
a. Current Year Performance Tracking
On the sixth working day of April, OSRTI pulls second quarter planning and
accomplishment data for the current FY from SEMS. Generally, OSRE pulls second
quarter enforcement accomplishments data from SEMS and other systems on the
eleventh working day of April.
Shortly after the sixth working day of April, OSRTI transfers mid-year Annual
Performance Measures data into ACS and then regions raise performance issues using the
"Comments" field on the results screen in ACS.
In the April/May timeframe, HQ and the regions hold mid-year reviews to discuss
regional progress in achieving current year negotiated targets and regional budget
utilization (obligation rates). These discussions provide HQ and the regions with an
opportunity to assess performance, consider the impact of regional program performance
on the Superfund pipeline, and identify trends in program performance and adjust
program management strategies accordingly. These meetings also facilitate
communications regarding site-specific technical and funding issues as well more general
policy and strategic planning questions. During the mid-year review processes, the
regions are also expected to update plans to use available funds in each special account in
a manner consistent with guidance. Special accounts are discussed further in section III. J
of chapter III, titled "Financial Management."
During this timeframe, OSRE also requests the regions to submit site and activity-
specific requests for additional extramural enforcement resources, and then allocates
remaining enforcement resources based on these submissions.
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b. Planning for the Upcoming Year
In late June or early July, HQ issues a Superfund Remedial and Enforcement Work
Planning memorandum that outlines the process for the upcoming work planning
sessions. The work planning memorandum includes the schedule, scope, and areas of
emphasis for developing the upcoming year's priorities, targets, and budgets. A copy of
the Superfund Remedial and Enforcement Work Planning memorandum is included in
appendix C of the Superfund Implementation Manual (SPIM).
The removal and federal facilities programs conduct separate work planning sessions
with the regions that address similar topic areas as the remedial program, but with a
program-specific focus. Schedules for these discussions are determined on an annual
basis.
Work planning sessions between HQ program offices and the regions allow HQ to
communicate program priorities, discuss new initiatives, and obtain preliminary estimates
for program performance and funding needs for the upcoming FY. HQ may also use this
opportunity to review past and projected regional accomplishments, historical obligation
trends, and planned durations/dollars to ensure that the region is planning the appropriate
amount of work given the dollars it is requesting.
II.D.2 Fourth Quarter
a. Planning for the Upcoming Year
HQ staff will schedule work planning meetings with each region which generally take
place during August and September. Pursuant to the guidance in the Superfund Remedial
and Enforcement Work Planning memorandum, regions will enter the applicable
planning data into SEMS by dates negotiated between HQ and the region (usually three
to five days before the region's scheduled meeting), and HQ program offices will review
program target and accomplishment data before the meetings. Data to be reviewed
include projections of activities that will be undertaken (site- and non-site-specifically),
annual performance goal and other internal program measure targets that will be
achieved, and planned resources (appropriated and reimbursable) for the expected work.
b. End of Year Performance Tracking
HQ pulls preliminary end-of-year accomplishments on the fifth working day of
September as a starting point for preparing for the end-of-year assessment that occurs in
November. This information gives HQ an indication of progress expected through the
end of the year and allows the regions and HQ to identify and review final issues that
may affect program success. In the final weeks of the FY, HQ staff from each Superfund
program office will closely monitor regions' progress toward meeting Annual
Performance Plan commitments and ensure that the accomplishment data are entered into
SEMS, ACS, and ICIS in a timely manner.
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OSWER Directive 9200.3-15-1G-Y
II.D.3 First Quarter (of the subsequent year)
a. Planning for the Current Year
During the first quarter of the FY, HQ meets with the regional division directors to
discuss the national program's annual performance goals. OSRTI develops a preliminary
ongoing construction funding plan and allocates RA and Pipeline Operations Site
Allowance resources to the regions. FFRRO finalizes regional commitments and has
discussions on budget allocation during end-of-year regional work planning meetings.
b. Prior Year Performance Tracking
HQ pulls final SEMS accomplishment reports for annual performance measure
accomplishments as well as all other regional accomplishments on the eleventh working
day (holidays are not counted as a working day) of October. OSRTI and OEM annual
performance measure data are transferred to ACS by HQ after a short review period
following the eleventh working day of October. Regions explain differences that occur
between the commitment and actual performance using the "Comments" field on the
results screen in ACS. HQ will publicly report these accomplishments in late October to
mid-November. This schedule allows regions opportunity to review end-of-year financial
data, ensure that all accomplishments are accurately reflected in SEMS, and determine
when the commitments were met.
Although OSRE coordinates end-of-year accomplishment reporting with OSWER and
OECA, OECA's accomplishments reporting schedule differs from Superfund's. Each
year, OECA issues the current FY's reporting plan. The "Reporting Plan" describes the
enforcement and compliance reporting requirements for regional and OECA offices,
including key dates for second quarter and end-of-year data entry and reporting as well as
data certification deadlines. Typically, the annual "Reporting Plan" is distributed to the
regions in April.
II.E PLANNING, TARGET, AND ACCOMPLISHMENT REPORTS
The following lists provide the primary SEMS reports used by HQ and the regions to
track regional performance. The first set of reports is used to establish regional targets/measures
and to evaluate and report regional accomplishments. OSRE and FFRRO-specific management
reports are also identified. OEM does not use SEMS to run any management reports.
Additionally, Superfund also maintains a set of senior management reports that illustrate
site progress through the Superfund pipeline and the involvement of PRPs in cleanup activities.
These reports include regional, state, or national views and the reports on site assessment, federal
facilities, construction completions, performance on annual commitments and other internal
program measures and provide a comprehensive picture of program activity.
ILE.l OSRTI Management Reports for Planning/Target Setting and Accomplishment
Reporting
• SCAP-002: The Site Summary Report is used by EPA to display enforcement sensitive
SEMS data for NPL and non-NPL sites.
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OSWER Directive 9200.3-15-1G-Y
• SCAP-004: The Financial Report will display aggregate dollars by program area and
provide both site-specific and non-site specific backup from SEMS. There will be various
options available to run the report by specific program areas.
• SCAP-013: The Site Assessment Report is used for reporting site assessment plans and
accomplishments. This report tracks a wide range of site assessment activities and
complements the remedial site assessment completion data included on the SCAP-15
GPRA report.
• SCAP-014: The Superfund Accomplishments Report is used to track targeting, planning,
and accomplishment actions in support of the remedial, enforcement, removal, and
federal facility programs.
• SCAP-015: The GPRA Report is used to track GPRA performance goals and measures in
support of the Response program.
• SCAP-016: The Reconciliation (SCAP-014 Audit) Report is used to extract all potential
candidates for a SCAP-014 category and provide the user with the ability to determine
the way in which the action will be selected or eliminated based on the values or lack of
values in the Select Logic columns.
• SA-006: Site Assessment Accomplishments report is used to report the results of
assessments completed during the fiscal year and the number of sites needing remedial
assessment.
• SA-034: Remedial Site Assessment Completion Sub-Measures report tracks progress
towards completing remedial Preliminary Assessments at sites over five years old and
making NPL listing decisions at sites over 16 years old.
• SA-031: The Final Assessment Decisions report is used to report the number of final
assessment decisions (FADs) made during the fiscal year. FADs are a component of
EPA's cross-program CERCLA site assessment measure.
II.E.2 OSRE Management Reports
• ENFR-003: The Settlement Master Report is the Official OSRE accomplishment report.
This report displays and summarizes all settlements completed during the user selected
time frame. It displays the Value of Past Costs, Value of Cashout Dollars, or the
Estimated Value of PRP Response for the settlement, remedies, and other qualifier
information.
• ENFR-004: The PRPs, Party Listing Report displays the PRPs and their information for a
Site or all Sites associated with PRPs and their corresponding enforcement instrument or
notice letter activity.
• ENFR-007: The DeMinimis Settlement Report provides a master list of settlements for
Cost Recovery and Response. For each settlement, the report identifies the associated
number of Parties, Compliance Status, Start and Completion dates, Lodging or Intent to
Comply Milestone data, Statutes, Remedies, Settlement Type and Qualifier and Cost
Recovery, Penalty Cashout or Value of Work Financial data. This report is used for
comprehensive planning purposes.
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OSWER Directive 9200.3-15-1G-Y
• ENFR-011: The Ongoing Remedial Design/Remedial Action (RD/RA) Negotiations
Timeline Report is used to track the duration of ongoing RD/RA negotiations. The report
shows categories of duration (e.g., between 60 and 120 days).
• ENFR-016: The Cost Recovery Decision Documents Report provides justification why
past costs are unrecoverable and written off.
• ENFR-017: The Cost Recovery Targeting Report is a tool used to identify potential
targets for cost recovery with upcoming statute of limitations.
• ENFR-022: The ROD Amendment and RD/RA Negotiations Report is used to track
RD/RA negotiation progress. The report is categorized into RD/RA negotiations started
from signed ROD and No RD/RA negotiations started from signed ROD.
• ENFR-025: The Administrative/Unilateral Orders Issued Report lists AOCs and UAOs
that have been issued. The report is an audit report for the ENFR-03 Report.
• ENFR-066: The RA Starts with Viable PRPs Report is the Official GPRA measure report
to track enforcement instruments for RA actions started within the user specified year
with viable PRPs.
• ENFR-067: The Financial Assurance Report is used to identify response settlements
where financial assurance is required as well as a tool to monitor and track when a
financial mechanism is coming up for renewal based on the financial mechanism
expiration date.
II.E.3 FFRRO Management Reports
• The Federal Facility Accomplishments Report is a subset of the SCAP-014 report. It
includes several extra categories concentrating specifically on accomplishments at federal
facility sites (NPL, non-NPL, and Base Realignment and Closure Act (BRAC)
• FF-005: The Federal Facility Audit Report lists all of the federal facility data issues
detected in SEMS for the selected FY.
• FYR-003: This contains all the data formerly in the Federal Facility Five Year Review
Status Report. It lists the status of all the planned and completed Federal Facility Five
Year Reviews.
• CPRM Audit-002: This contains all the data formerly in the Federal Facility Findings of
Suitability to Transfer (FOST)/Findings of Suitability to Lease (FOSL)/ Environmental
Baseline Survey (EBS) Reports and in the Federal Facilities Site Summary Report. It lists
the EBS completion date and all of the FOST, FOSL and Findings of Suitability to Early
Transfer (FOSET) that EPA has concurred on in the selected FY. Also included are
summaries of all the actions, EBSs, FOSTs, FOSLs, FOSETs and Supplemental,
Environmental Projects (SEPs) for the entire history of all the federal facilities in the
selected region(s).
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Superfund Program Implementation Manual
FY15
Chapter III: Financial Management
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CHAPTER III: Financial Management
Table of Contents
III.A Introduction III-l
III.B Financial Management Roles and Responsibilities III-l
III.B.I Regional Organization Financial Roles and Responsibilities III-l
a. Regional Administrator (unless delegated) 7/7-7
b. Regional Finance Office (RFO) 777-2
c. Regional Program Office (RPO) 777-2
d. Administrative Support Unit 777-2
III.B.2 Regional Staff Financial Roles and Responsibilities III-3
a. On-Scene Coordinator (OSC) 777-3
b. Remedial Project Manager (RPM) 777-3
c. Regional Project Officer (Deputy Project Officer (DPO) 777-4
III.B.3 Headquarters Support Office Financial Roles and Responsibilities III-4
a. Cincinnati Finance Center (CFC), Office of Financial Services, OCFO 777-4
b. Las Vegas Finance Center (LVFC), Office of Financial Services, OCFO 777-4
c. Office of Acquisition Management (OAM), OARM. 777-5
d. Office of Budget, OCFO 777-5
e. Office of Financial Management (OFM), OCFO 777-5
/ Office of Grants and Debarment (OGD), OARM. 777-5
g. Research Triangle Park (RTF) Finance Center, Office of Financial
Services, OCFO 777-5
III.C Financial Vehicles 7/7-6
III.C.l Contracts III-6
III.C.2 Interagency Agreements (lAs) III-6
III.C.3 Cooperative Agreements (CA) III-6
III.C.4 Grants III-7
777.7) Financial Data Management Tools 777-7
III.D.I Superfund Enterprise Management System (SEMS) III-7
III.D.2 Budget Automation System (BAS) III-8
III.D.3 Compass III-8
III.D.4 Compass Business Objects Reporting Tool III-8
III.D.5 Compass Data Warehouse (CDW) III-8
777.7i Superfund Accounting Information and Treatment of SEMS Data 777-9
III.E.I Superfund Account Number III-9
III.E.2 Handling Financial Data in the SEMS Environment 111-13
777.F Allocating Superfund Resources Among the Regions 111-14
III.F.I Managing Site Allowance Resources in SEMS 111-14
III.F.2 Using Prior Year Funds 111-15
a. Carryover III-l 5
b. Deobligations III-l 5
III.F.3 Removal Program Resources (PRC 303DC6) 111-16
III.F.4 Homeland Security Resources (PRC 303D72) 111-17
III.F.5 Remedial Response Program Resources (PRC 303DD2) 111-17
FY 15 SPIM
Ill-i
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OSWER Directive 9200.3-15-1G-Y
a. Remedial Action Site Allowance 7/7-7 7
b. Pipeline Operations Site Allowance 111-18
III.F.6 Superfund Federal Facilities Response Program (PRC 303DC9) 111-18
III.F.7 Base Realignment and Closure (BRAC) (303D41 [non-site] and 303D41B4
[site-specific]) 111-19
III.F.8 Enforcement Program (PRC 501EC7) 111-19
III.F.9 Federal Facilities Enforcement Program Resources (PRC 501EH2) 111-19
III.G Cost Recovery 7/7-20
III.G.l Recoverable Costs 111-21
a. Direct Costs 777-27
b. Contractors'Annual Allocation Costs 777-27
c. Indirect Costs 777-27
777.77 Site Charging Policy (Site-Specific, ZZ, 00 SSIDs) 777-22
III.H.l WQ SSID and WQ Action Code 111-22
a. WQSSID 777-22
b. WQ Action Code 777-23
III.H.2 ZZSSID 111-23
III.H.3 OOSSID 111-23
777.7 Superfund State Contracts (SSC) 777-24
III.I.l Cost Share Provisions 111-24
III.1.2 Constraints on Obligating Funds for RA 111-25
III.I.3 Cost Share Payments 111-25
III.1.4 Using Funds from State Cost Share Payments 111-26
777.7 Special Accounts 777-26
III.K Using the Fiduciary Reserve to Address Cost Overruns 777-27
List of Exhibits
Exhibit III. 1. Superfund Account Number Structure III-9
Exhibit III.2. Sample Superfund Appropriation Codes 111-12
Exhibit III.3. Superfund Program Results Codes and Site Allowance Codes Ill-13
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CHAPTER III: FINANCIAL MANAGEMENT
777,4 INTRODUCTION
This chapter introduces certain financial management components important to the
Superfund program. The following section outlines responsibilities of various offices and
positions within the Agency in managing and administering Superfund resources. The third
section describes the financial vehicles used to obligate Superfund resources, and the fourth
section identifies numerous financial data management systems and tools for tracking Superfund
costs. The fifth section describes the processes by which the various Superfund programs make
resource allocation decisions among the regions, and the sixth section briefly describes the cost
recovery process and recoverable costs. The final sections of this chapter address issues of
special interest to financial management, including site-specific charging policy (including bulk
funding), special accounts, Superfund State Contract (SSC) management, and using the
Fiduciary Reserve. Various Superfund-specific financial management policies issued by the
Office of the Chief Financial Officer (OCFO) may be found in the Resource Management
Directives System (RMDS) 2550D at http://intranet.epa.gov/ocfo/policies/direct/2550d.htm.
III.B FINANCIAL MANAGEMENT ROLES AND RESPONSIBILITIES
Due to the complexities of the Superfund program, numerous organizational units within
the regional Environmental Protection Agency (EPA) offices have responsibility for Superfund
financial management. As described in this document, the Regional Management Division is the
organization in which financial management, budgetary, accounting, planning and assistance
agreements, and administration functions are carried out. The Regional Servicing Finance Office
(SFO), the Grants Officer, and the Contracting Officers (CO) for the Response Action Contract
(RAC), Superfund Technical Assessment and Response Team (START), Regional Oversight
Contract (ROC) and Emergency and Rapid Response Services (ERRS) contracts are considered a
part of this division. This section first lists the primary regional offices with Superfund-related
financial management responsibilities and the duties for which each office has responsibility or
authority. The next section lists the financial management roles and responsibilities of several
staff positions.
III.B.I Regional Organization Financial Roles and Responsibilities
a. Regional Administrator (unless delegated)
• Approves cleanup actions under removal authority
• Approves consistency exemptions at National Priorities List (NPL) sites where
the removal costs are more than $2 million
• Awards Interagency Agreements (lAs), Cooperative Agreements (CAs), and
Technical Assistance Grants (TAGs)
• Enters into SSCs
• Initiates response planning activities
• Ensures reimbursable Base Realignment and Closure (BRAC) costs are accurate
and appropriate (1996 BRAC Guidance, section 3.2.1)
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b. Regional Finance Office (RFO)
• Processes Procurement Requests (PRs), Requisitions (REQs), lAs, and CAs
• Establishes Site/Spill Identifier code (SSID) at request of Regional Program
Office (RPO)
• Assigns Account Number, Document Control Number (DCN), and Cooperative
Agreements (CA) identification numbers to funding documents
• Enters quarterly Site Allowance into Compass, controls regional allowance
• Sets up regional account numbers, including SSIDs, in Compass
• Enters commitments into Compass
• Reviews invoices, monthly financial reports, and payment requests
• Commits funds under regional contracts and modifications
• Assists RPO in the pre-application phases of the CA development
• Maintains Superfund document files on regional costs and handles the
compilation and review of cost documentation for cost recovery
• Provides RPO with financial data as requested
• Enters reprogramming information for recertification of deobligated funds into
Compass
Note that some of these functions may be performed by the RPO or Office of Financial
Services Finance Centers in some regions.
c. Regional Program Office (RPO)
• Prepares Commitment Notices (CNs), REQs, and PRs
• Assigns the Account Number to funding documents
• Provides technical support to the CO
• Reviews vouchers and/or financial reports
• Manages CAs and lAs
• Requests SSIDs from the RFO
• Develops SSCs
• Approves Request for Proposals (RFPs) or Request for Bids and contracts
developed by the states
• Monitors the transfer of financial data on contracts, lAs, and CAs from Compass
into the Superfund Enterprise Management System (SEMS);
• Maintains Superfund document files on regional work performed for cost
recovery
• Monitors unliquidated obligations and deobligations
• Requests recertification of deobligated funds
Note that some of these functions may be performed by the RFO in some regions.
d. Administrative Support Unit
• Established in some RPOs depending on regional structure
• Staffed with EPA staff (the non-government functions may be performed by a
contractor)
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• Provides administrative support to the On-Scene Coordinator (OSC)/Remedial
Project Manager (RPM)
• Provides liaison between OSC/RPM and other groups involved in administrative
matters
• Provides support to regional program management
• Assists in developing regional removal site budgets and Action Memoranda
• Sets up and maintains active site files
• Completes PRs, REQs, and CNs
• Reviews Compass reports
Note that some of these functions may be performed by the RFO or RPO in some
regions.
111.B.2 Regional Staff Financial Roles and Responsibilities
a. On-Scene Coordinator (OSC)
• Is an employee of EPA or U.S. Coast Guard (USCG)
• Is an Ordering Officer (must have "Delegation of Procurement Authority," also
called "Warrant Authority," signed by a Senior Procurement Manager)
• Conducts response activities at hazardous substance spills and releases, or threats
of release
• Initiates and manages cleanup actions under removal authority
• Aware of, in control of, and responsible for site charges
• Ensures costs are reasonable and necessary
• Prepares site budgets and contract action requests
• Completes Action Memoranda
• Prepares delivery orders/task orders and PRs
• Initiates PRs, REQs, Work Assignments (WAs), CAs, lAs, and contracts
• Approves site-specific IA invoices
• Establishes and maintains official site file
• Reviews and approves cleanup contractors' charges on a daily basis
• Tracks site costs against the established site ceiling
• Approves contractor invoices
• Acquires services using warrant for up to $250,000
b. Remedial Project Manager (RPM)
• Is an EPA employee
• Initiates and manages remedial actions and, if applicable, removal actions at
remedial sites
• Manages enforcement costs and activities
• Aware of, in control of, and responsible for site charges
• Ensures costs are reasonable and necessary
• Reviews contractor invoices and monthly technical and financial reports
• Establishes and maintains official site files in coordination with the Records
Center
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• Initiates PRs, WAs, CAs, lAs, and site-specific contracts
• Approves site-specific IA invoices
c. Regional Project Officer (Deputy Project Officer (DPO)
• Is an EPA employee
• Manages remedial, enforcement, removal, and general site support contracts
• Evaluates and designates contractor award fees
• Monitors contractors' activities
• Reviews monthly contractor reports and site- specific attachments
• Initiates PRs, WAs, CAs, lAs, and site-specific contracts
• Prepares Procurement Initiation Notifications (PIN) including contract Scope of
Work and Independent Government Cost Estimate (IGCE) for procurement of
Superfund Mission contracts such as START, RACs, and ERRS
• Approves site-specific IA invoices
• Identifies regional and site-specific contract requirements
• Reviews invoices
• Provides general contract management support
III.B.3 Headquarters Support Office Financial Roles and Responsibilities
Selected program offices in Headquarters (HQ), particularly within the OCFO and the
Office of Administration and Resources Management (OARM), also have Superfund Financial
Management responsibilities. Within the Office of Solid Waste and Emergency Response
(OSWER) and the Office of Enforcement and Compliance Assurance (OECA), each national
program office can address financial management issues associated with its program. Refer to
appendix B to identify the appropriate contacts within each office. Other Superfund financial
management functions provided by EPA's enabling support offices are briefly described below.
a. Cincinnati Finance Center (CFC), Office of Financial Services, OCFO
• Provides accounting support for all Superfund lAs
• Processes disbursement requests from other agencies
• Issues and processes disbursements for reimbursable activities (e.g., special
accounts) and for payment of state cost share
• Enters IA obligations and disbursements into Compass
• Enters all reclassification transactions into Compass
• Records remedial state cost share credits into Compass
• Monitors negative available balances in special accounts quarterly
b. Las Vegas Finance Center (LVFC), Office of Financial Services, OCFO
• Provides support of Grant Payments and financial closeout of Assistance
Agreements for all of the 11 Grant Award Offices
• Processes payments under EPA's Local Government Reimbursement (LGR)
program for hazardous substance, pollutant, or contaminant threat response
• Provides consolidation and certification of EPA's daily grant, vendor, and travel
payments through the Treasury's Secure Payment System
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c. Office of Acquisition Management (OAM), OARM
• Conducts Superfund contracting program
• Negotiates, awards, monitors, modifies, and terminates contracts (some contracts
are also awarded by COs in the regions)
• Provides technical guidance on contract administration
• Provides cost and price analysis
d. Office of Budget, OCFO
• Allocates, approves and reprograms Superfund allowances among HQ and
regions
• Monitors obligations and resource balances
• Processes change requests
• Reviews and approves regional requests for reimbursable authority
• Approves requests to recertify prior year Superfund appropriated resources
• Issues the deobligation recertification guidance memo
e. Office of Financial Management (OFM), OCFO
• Collects HQ Superfund cost documentation for cost recovery
• Oversees annual allocation site-specific reporting process
• Develops financial policies and procedures
• Provides general accounting support
• Records transfer allocations
• Manages investments in the Superfund Trust Fund
• Establishes and maintains accounting models in Compass
f. Office of Grants and Debarment (OGD), OARM
• Issues policies, regulations, and guidance for processing, awarding, and managing
financial assistance agreements and lAs
• Issues identification numbers for all lAs
• Processes and awards HQ lAs
g. Research Triangle Park (RTF) Finance Center, Office of Financial Services,
OCFO
• Provides accounting support for all Superfund contracts
• Enters contract award and obligation data into Compass
• Processes contractor invoices
• Enters payments into Compass via the Contract Payment System
• Conducts redistribution of costs to various sites as requested by approving official
once invoices are paid
• Completes corrections on contracts and simplified acquisitions
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IILC FINANCIAL VEHICLES
EPA uses a variety of acquisition vehicles to carry out the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA)-funded response actions. These include
contracts, lAs and Grants and Cooperative Agreements (CAs).
IILC. 1 Contracts
Superfund contracts are awarded through standard procurement procedures as outlines in
the EPA Contracts Management Manual. There are three basic types of contracting within
Superfund: site-specific, non-site specific, and support contracts. Site specific contracts are
generally awarded to support work at a particular site or project. Funds for site-specific contracts
are obligated and tracked on a site-specific basis. The non-site specific contract vehicles
primarily support program areas, such as remedial or removal program areas and include RAC,
START, ROC, ERRS, Contract Laboratory Program (CLP), and Environmental Services
Assistance Team (ESAT). Generally, the non-site support contracts are not awarded on a site-
specific basis though they allow for site-specific task or delivery orders, funding for which can
be obligated on a site-specific basis. Task or delivery orders may also be bulk funded with the
"WQ" SSID (or "WQ" action code) and then paid out site-specifically. Bulk funding (WQ) is
discussed in detail in section III.H. Mission Support Contracts are contracts that provide support
to HQ and regional program offices and are not generally used for site-specific work.
For more discussion on contracts, see OCFO's RMDS 2550C, chapter 3
(http://intranet.epa.gov/ocfo/policies/direct/), and the EPA Contracts Management Manual.
III.C.2Interagency Agreements (lAs)
An Interagency Agreement (IA, previously called IAG) is a written agreement between
federal agencies under which goods and services are provided. The Superfund program uses
Disbursement lAs to request federal agencies' assistance with site cleanups and associated
activities, and to provide ongoing support or services. HQ manages specific lAs with other
agencies, including USCG, Department of Justice (DOJ), U.S. Fish and Wildlife Service (FWS),
National Oceanic and Atmospheric Administration (NOAA), and United States Army Corps of
Engineers (USAGE). Each IA specifies the services required and identifies the method of
payment. The regional program offices initiate and manage site-specific lAs. For additional
information see OCFO's RMDS 2550D, chapter 6 at:
http://intranet.epa.gov/ocfo/policies/direct/2550d-06.pdf or see OARM's website on lAs:
http://intranet.epa.gov/ogd/interagency_agreements.htm
III.C.3 Cooperative Agreements (CA)
A Superfund CA is a legal instrument between the federal government and a state,
political subdivision, or Indian tribe (including intertribal consortia) that forms a working
relationship where both parties provide funding and services for the design and implementation
of Superfund responses. The Superfund CA ordinarily transfers money, goods or services to the
recipient to lead or support agency Superfund activities. There are several types of Superfund
CAs which serve different purposes, including site assessments, site-specific response actions to
support agency functions (typically in a multi-site agreement), and general support for state
Superfund programs. These CAs have unique provisions that are described in 40 CFR Part 35
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Subpart O, including satisfying CERCLA provisions regarding state involvement and payment of
state cost share.
Several offices are involved in the commitment process for a CA. The RPO prepares the
commitment notice and obtains the necessary program approvals; the regional finance office
certifies availability of funds, assigns DCN, and enters commitments in Compass; and the Grants
Administration Division assigns the CA identification number. The Regional Administrator (or
designee) must first sign the CA before funds may be obligated. The regional finance office
processes the obligation in accordance with OAM, Grants Administration Division (GAD), and
Financial Management Division (FMD) requirements and then enters the obligation into
Compass.
III.C.4 Grants
The Superfund program has limited grant making authority and thus very few grants are
awarded in the Superfund program. There is also a unique grant program, called Technical
Assessment Grants authorized by the Superfund Amendments and Reauthorization Act of 1986
(SARA) was established to provide technical assistance to eligible communities. A TAG
provides money for activities that help communities participate in decision making at eligible
Superfund sites. An initial grant up to $50,000 is available to qualified community groups so
they can contract with independent technical advisors to interpret the technical information about
the site and explain it to the community. TAGS are available at NPL and proposed to NPL
Superfund sites where response actions have begun.
III.D FINANCIAL DATA MANAGEMENT TOOLS
The unique aspect of Superfund financial tracking stems primarily from the need to
associate EPA's incurred costs with specific Superfund sites and operable units (OUs) and
projects to support the cost recovery process. Court actions and cost recovery negotiations with
Potentially Responsible Parties (PRPs) require careful documentation of federal costs incurred at
each site/spill. The following data management systems and tools are used to plan and track the
use of programmatic resources:
III.D. 1 Superfund Enterprise Management System (SEMS)
SEMS is a Superfund specific database that houses site- and non-site specific data
including the financial planning data that are used by program managers to monitor resource
needs and uses. SEMS contains various screens and reports, generated from the Oracle Business
Intelligence Reporting tool, that support program planning and performance (see chapter II, titled
"Performance Measures, Planning and Reporting Requirements"). Regions enter planned
obligations in the Primavera project management tool, which can be further refined in the
detailed obligation planning screens in SEMS. HQ uses the Superfund Comprehensive
Accomplishments Plan (SCAP) 4 report to track regional financial planning and actual financial
transactions are imported from the Agency's financial system. SEMS financial information is
used for management purposes only and is not an official representation of Superfund incurred
costs. Resource planning data are also usually considered enforcement sensitive since they may
inadvertently give leverage to PRPs who are negotiating settlements with EPA, and are not made
available to the public (See chapter IV for more information on confidentiality of SEMS data).
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III.D.2 Budget Automation System (BAS)
BAS is the central EPA system used to integrate strategic planning, annual planning,
budgeting, and financial management for all programs across the Agency. The system contains
resource (dollars and full time equivalent [FTE]), planning, and performance data. The system
supports budget formulation, annual planning, and operating plan development. EPA also uses
BAS to record and track regional commitments of performance targets within the Agency and
project-based planning/resource allocations within Offices. BAS is used only for reprogramming
funds between program projects. Recertified funds are reprogrammed in Compass.
III.D.3 Compass
Compass is the umbrella name for EPA's financial management and reporting system.
This system replaced an earlier financial management system, Integrated Financial Management
System (IFMS), at the beginning of fiscal year (FY) 2012. The Compass financial system
supports the general ledger, budget execution, funds control, accounts payable, disbursements,
accounts receivable and collections, travel, project cost accounting, fixed assets and standard
reporting functions. Compass is integrated with several agency financial systems, including the
Bank Card Payment System, the Fellowship Payment System (FPS), the Integrated Grants
Management System (IGMS), Concur (which replaced GovTrip in FY 2014), Property
Inventory, eBusiness, the Grants Payment Allocation System (GPAS), BAS, the Inter-Agency
Doc Online Tracking System (IDOTS), the Web Order System (WEBOS), the Small Payment
Information Tracking System (SPITS), the EPA Acquisition System (EAS), the Integrated
Resource Management System (IRMS), the Contract Payment System (CPS), and PeoplePlus.
Financial data are loaded into the Compass Data Warehouse (CDW).
III.D.4Compass Business Objects Reporting Tool
The Compass Business Objects Reporting tool (CBOR) provides a corporate, web-based
approach to agency financial reporting and information needs. CBOR also integrates financial,
administrative and program performance information, which is useful for monitoring agency
operating activity, conducting trend analysis, and developing program strategy. CBOR consists
of three main components:
1. Standard Reports: Provide users with detail and summary information on automated
disbursement, budget execution, fixed assets, General Ledger accounting, and
purchasing.
2. Ad Hoc Reports: Provides users with custom reporting capabilities to meet the needs of
their respective organization.
3. Information Centers: Provide users with a platform for posting, viewing and sharing
reports of interest with multiple users across their Responsible Program Implementation
Office (RPIO) Organization
III.D.5 Compass Data Warehouse (CDW)
The CDW is an official agency reporting tool that contains a collection of financial and
administrative data in an Oracle database pulled from Compass and other agency systems. The
CDW intranet site is available to EPA users at http://ocfosysteml.epa.gov/neis/adw.welcome.
CDW data are refreshed constantly as transactions are processed in the Compass financial
system.
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Historical financial data in Compass and portions of the CDW are limited. While all open (i.e.,
unliquidated) at the end of FY 2011 were migrated to Compass, completed transaction data only
from budget fiscal year (BFY) 2001 and later are contained in Compass and portions of the
CDW. At the CDW intranet site, there is a link to Financial Data Warehouse (FDW) queries that
may be used to access historic data, which are frozen as of FY 2011. These queries allow access
to all data migrated to Compass as of the end of FY 2011 as well as historic data that were not
migrated. Neither CDW nor FDW contain certain pre-IFMS financial data. OCFO is currently
developing a Superfund Financial Comprehensive Data Source (SFCDS) that will eventually
provide an authoritative source for all current and historical Superfund financial data.
IILE SUPERFUND ACCOUNTING INFORMATION AND TREATMENT
OFSEMSDATA
The Agency's financial account number structure is integral to the Agency's management
of financial resources and is used for processing and tracking financial transactions with
Compass, the Agency's financial management system. When planning resource uses in SEMS,
regions will generate Superfund account numbers that may be used as the basis for preparing
procurement requests through the Agency's procurement systems. The SEMS interface with
financial information in Compass, necessary for tracking resource use (commitments,
obligations, payments) in SEMS also depends on the account number structure.
III.E.l Superfund Account Number
The account number structure is comprised of six fields of data elements that identify the
specific nature of the expense. These fields are: the budget fiscal year; fund (or appropriation);
organization; program results code; project and cost organization. Exhibit III.l provides an
example of an account number and a brief definition of each of its fields. The sections after the
table provide more detail on each field.
EXHIBIT III.1. SUPERFUND ACCOUNT NUMBER STRUCTURE
Budget Fiscal Year
Fund
Budget
Organization
Program Results Code
Project
Cost/Org
20 12
T R 2 A
7 A OOP
3 0 3 DP 2
0 723 R A 01
C|0|0|2|
Data Element Field Name
Definition
Sample Entry
Budget Fiscal Year
(eight characters)
The first four positions in this field identify the beginning budget
fiscal year (e.g., '2012'). The last four positions in this field identify
the ending budget fiscal year (for expiring funds), but these positions
are not generally used by the Superfund program and should be left
blank.
2012
Fund (Appropriation)
(six characters)
The type of appropriation is entered into this field with up to four
characters indicating appropriation accounts and sub-accounts (e.g.,
'HSCR' or 'TR2A'). The Superfund appropriation fund code is 'T'.
Multi-character 'T*' fund codes represent Superfund sub-accounts.
Each year OCFO publishes an Advice of Allowance memorandum
that identifies which appropriation codes are available for use in the
current fiscal year. The most frequently used codes within SEMS for
obligation of Superfund resources are identified in exhibit III.2.
TR2A
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Budget Organization
(seven characters)
The Budget Organization field includes the Allowance Holder/
Responsibility Center (AHRC) codes (e.g., 07H). The AHRC code
can be between three and seven characters in length.
In the regions, the first two positions represent the region and type of
allowance holder (AH) in use. The 'A' AH is represented with the
regional number in the first position and an 'A' in the second position
and the '0' AH is represented by an '0' in the first position and the
regional number in the second position (e.g., Region 7 may be
represented as 07 or 7A; Region 10 is represented as 10 or OA). The
'A' AH holds extramural appropriated resources that Response
Program (OSWER) HQ offices have distributed to specific Superfund
Site Allowances for Superfund actions. The '0' AH generally holds
other regional resources such as personal compensation and benefits,
site and non-site travel resources, and certain administrative expenses.
The Enforcement Program (OECA) does not use the 'A' AH and
distributes extramural as well as intramural resources to the '0' AH.
At HQ, AH represents the National Program Manager (NPM) office
responsible for managing and allocating the resources (e.g., '72' for
the Office of Superfund Remediation and Technology Innovation
[OSRTI], 'D3' forthe Office of Emergency Management [OEM]).
The third position of the Budget Organization is an alphanumeric
character that designates the responsibility center within the region or
HQ office (see the region's budget office for a list of these codes). The
fourth position has multiple region or HQ specific uses.
The fifth position generally represents the Superfund Site Allowance
code (shown in exhibit III.3) within the Response Program Results
Code (PRC) (e.g., Pipeline Operations or Remedial Action). The
Response Program Superfund Site Allowance codes are used with the
'A' AHs.
Positions five through seven may also represent a local option or
congressional add-on (e.g., CUD - counter-terrorism response) to
further identify resources beyond the appropriation code and PRCs
(e.g., RSF for Recovery Act Superfund Maintenance and Operations),
or other special purposes. These uses may necessitate overriding the
use of the fifth position as a Superfund Site Allowance.
Certain regions use a combination of characters within the Budget
Organization Field to identify site-specific budgets for the use of
special account resources. This practice varies across regions and has
not been codified.
7AOOP
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Program Results Code
(PRC)
(nine characters)
The first six positions identify the PRC. The Agency financial
strategic architecture is designed to reflect the Agency Strategic Plan
and annual commitments made under the Government Performance
and Results Act (GPRA). The PRC identifies the goal, objective,
NPM, and program/project. The remaining positions should be left
blank.
Resources for Superfund Response programs are found under Goal 3,
Objective 03 (the first three positions of the PRC) and resources for
the Superfund enforcement and Federal facilities enforcement
programs are found under Goal 5, Objective 01.
The most common NPMs (fourth position of the PRC) associated with
Superfund are OSWER (D), OECA (E), and OCFO (J).
Program/projects (fifth and sixth positions of the PRC) within the
Superfund program further distinguish the nature of the work within
each program office (i.e., homeland security is '72', emergency
response and removal is 'C6', enforcement is 'C7', federal facilities is
'C9', remedial is 'D2', and federal facilities enforcement is 'H2').
Positions seven through ten of the PRC are reserved for special use.
Exhibit III. 3 shows PRCs that support key Superfund response
program areas for which national program offices allocate resources to
regional program offices primarily through site allowances.
Descriptions of each of the programs are given in chapter 1, section
l.B.2. The exhibit also identifies the Site Allowance codes (used in
Compass and BAS) that the Response programs use to allocate
resources to the regions. The Site Allowance codes are found in the
fifth position of the Budget Organization field.
303DD.
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Project
(eight characters) - consists
of SSID, Action Code, and
Operable Unit1
The first four positions define the SSID, which the Agency uses to
account for and to accumulate Superfund costs by site. The SSID is
comprised of the regional number in the second position (e.g., '07' for
Region 7) with an alphanumeric placeholder in the first position. For
Region 10, '10' or 'AO' is generally entered in this position. The third
and fourth positions are alphanumeric characters that, with the rest of
the SSID uniquely identify a site or some other form of financial
transaction.
Positions five and six represent the action code, which is a two
character alpha code, a listing of which can be found in chapter IV,
exhibit IV. 3.
The Operable Unit number is entered in positions seven and eight
(e.g., '01' for Operable Unit 01). A unique format in the OU positions
may be used for non-site cooperative agreements awarded to states.
Generally, an SSID should be established when there is a reasonable
expectation that a future response action will be taken, but no later
than either site proposal to the NPL, execution of an action memo, or
an official decision to undertake a response. Other SSIDs (ZZ, WQ, or
00 in the third or fourth positions) denote site-specific work where a
site-specific SSID has not yet been established, or funding where the
precise amount to be charged to a site or action is not known at the
time of obligation, or non-site funding. These codes are described in
more detail in section III.F.
The Project field can also be used to track conference spending and
information technology (IT) -related transactions. A unique format is
used for IT related transactions that overwrites Superfund specific
uses of this field.
0723RA01
Cost Organization
(seven characters)
For the Superfund program, the first position of this field is system
generated by 'C' which is used by Compass to identify Superfund
transactions tracked in SEMS. The numerical characters in the second,
third, and fourth positions represent the action sequence number (e.g.,
'002' for the second occurrence of an action at a site). The remaining
positions should be left blank.
COO.
EXHIBIT III.2. Sample SUPERFUND APPROPRIATION CODES
Fund Code
T
TC
TD
TR
TR1
TR2
Title
Superfund (this appropriation code is also used for funds obligated in FY prior
to current FY and deobligated in current FY)
Superfund Carryover
Superfund Deobligations
Superfund Reimbursable - Funds-in Interagency Agreements
Superfund Reimbursable -SSC (state match funds)
Non-Federal Special Accounts - unearned revenue (i.e., future costs)
Refer to the NCP definition: http://edocket.access.gpo.gov/cfr 2003/iulqtr/pdf/40cfr300.5.pdf
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Fund Code
TR2A
TR2B
Title
Federal Special Accounts - unearned revenue (i.e., future costs)
Special Accounts - earned revenue (i.e., past costs and interest)
EXHIBIT III.3. SUPERFUND PROGRAM RESULTS CODES AND SITE ALLOWANCE CODES
Program
Remedial Program
Remedial Action
Pipeline Operations
Removal Program
Removal Actions
Removal Support
Homeland Security
Federal Facility Response
BRAC (non-site)
BRAC (site-specific)
Enforcement - Technical and Legal
Federal Facility Enforcement
Program Results Code
303DD2
303DC6
303D72
303DC9
303D41
303D41B4
501EC7
501EH2
Site Allowance Code (BAS Local Code)
R
P
E
S
c
F
none
none
none
none
III.E.2 Handling Financial Data in the SEMS Environment
Compass data are downloaded nightly into SEMS through an automated link. This
automatic transfer of financial information from Compass to SEMS includes commitments,
obligations, and payment data. Planned financial data must be entered into SEMS by the region;
the Account Number is generated by SEMS at the time the planned obligation is first entered.
This Account Number must be entered on all funding documents at the time the planned
obligation is executed, i.e., committed or obligated. If the Account Number is not correct, the
Compass to SEMS transfer will not work properly.
The Information Management Coordinator (IMC) or regional Superfund Budget
Coordinator can request, on a regular basis, a report from the RFO that contains all Superfund
financial transactions in Compass. The information in this report can be compared with the
funding documents and the information in SEMS. The CDW is another source for this
information. If there is a discrepancy between the financial data in SEMS and Compass, the
funding document should be used to verify the information in both systems.
Errors in account number or other information on the original funding document can only
be corrected by the same process used to initially create the financial record (i.e. by a contract
modification or by amendment to the IA or CA).
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IILF ALLOCATING SUPERFUND RESOURCES AMONG THE
REGIONS
Each Superfund national program office has specific procedures for allocating resources
among the regions. This section focuses on resources that the national program offices allocate to
the regions through Site Allowances (formerly known as Advices of Allowance) and use SEMS
to track regional plans and usage.
Each Site Allowance represents a national program office's annual allocation of
extramural resources for the regions to conduct specific program functions. Extramural resources
are identified using budget object class (BOC) codes as follows:
• BOC 36 Administrative expenses
• BOC 37 Contracts and Interagency Agreements
• BOC 41 Grants and Cooperative Agreements.
The national program offices also have various methodologies to allocate additional
resources to the regions for other functions, namely site- and non site-specific travel and
Working Capital Fund (BOCs 28, 21, and 38, respectively), but these resources are not generally
currently planned in SEMS and their distribution is not addressed in this manual. Regions may
use their discretion to plan the use of BOC 38 resources, which occasionally will be allocated
from regional site allowances to fund, for example, information technology (IT) functions, in
SEMS.
III.F.l Managing Site Allowance Resources in SEMS
Regions are required to plan obligations in SEMS by Site Allowance and/or
program/project (PRC code). Planned obligations in SEMS are site (i.e., project and OU-
specific) or non-site specific. Some planned obligations are associated with specific site
activities, while other planned obligations are estimates of total funding required for an activity
within a region (i.e., bulk funding). Regions should make sure all their programmatic funding
needs are reflected in SEMS and that they correspond with the appropriate program Site
Allowance.
Once funds are issued to the regions, the regions are responsible for managing the funds
within each Site Allowance and for operating within budget ceilings, floors, and other
restrictions. Compass tracks all financial transactions in the Agency, and commitments,
obligations, and expenditures associated with the Site Allowances are imported into SEMS on a
nightly basis to facilitate regional management of these funds. Additionally, regions must follow
agency reprogramming guidelines issued annually by OCFO to shift resources among
program/project codes or Budget Object Classes (BOCs).
To the extent practicable, the regional budget for each Site Allowance must balance at all
times with the sum of actual obligations, open commitments to date, and remaining planned
Similar to the carryover policy, funds issued and deobligated in the current fiscal year or
issued one year prior and deobligated in the current fiscal obligations in SEMS that have been
approved by regional management (or OSRTI in the case of remedial action funding). Regions
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should not delete planned obligations from SEMS that have been obligated (as was the practice
with CERCLIS). Planned obligations will remain in SEMS and be available for viewing even
after the obligation of those funds takes place. Regions should delete planned obligations from
SEMS only if they no longer have need for the funds.
III.F.2 Using Prior Year Funds
Superfund appropriated resources are no-year appropriation funds. This means that EPA
does not have congressional time constraints for obligating and expending these funds. However,
OCFO issues an annual "Advice of Allowance" policy to manage the execution of these and
other agency resources.
a. Carryover
Under OCFO's policy, the Agency effectively treats Superfund appropriated resources as
two year appropriation funds. Thus, if an organization does not obligate current BFY
resources in the current year, the funds will "carry over" and be available for use in the
subsequent year. At the end of the second year, uncommitted/unobligated balances are
swept by the Agency and used to meet the Administrator's priorities. For example, if a
region is issued BFY 2014 remedial program funds in FY 2014, it has two years (through
FY 2015) to obligate these funds, after which time the funds will be reassigned to the
Administrator. Although this policy provides flexibility to the Superfund program,
OSWER strongly discourages the regions from carrying over any funds associated with
the response program Site Allowances. Because of coding complexities, it is very
difficult to track the availability and use of these funds in Compass and SEMS, and due
to continual Superfund program budget constraints and the need for HQ to carefully
allocate funds across regions, it is inappropriate for a region to not obligate funds in the
year in which they have been provided. Special account and Superfund state cost share
(reimbursable) resources do not carry over from year to year and reimbursable authority
must be acquired each year to establish annual available budgets for these resources.
b. Deobligations
For various reasons, a region will find that a portion of the funds obligated to a particular
activity have not been expended (these are unliquidated obligations) and are no longer
necessary to implement the activity. Under OCFO policy, EPA may deobligate funds
appropriated in a prior year and reuse them in a subsequent year. The deobligation and
reuse of prior year funds is a good fiscal management practice and helps offset shortfalls
in the current year Superfund budget.
Similar to the carryover policy, funds issued and deobligated in the current fiscal year or
issued one year prior and deobligated in the current fiscal year are automatically returned
to the originating office. For example, if a region obligated BFY 2013 Site Allowance
funds in 2013 and then deobligated in those funds in either 2013 or 2014, they would be
immediately returned to the region's Site Allowance as available balance ready for use.
However, if a program deobligates funds that were issued two or more years prior (e.g.,
BFY 2012 or earlier if the current year is BFY 2014), the funds must first be recertified
by OCFO pursuant to procedures described in the Deobligation Recertification Guidance
("Deob Policy"), issued jointly by OCFO, OSRTI, the Office of Site Remediation
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Enforcement (OSRE), and OEM. Funds obligated and deobligated in the same fiscal year
return directly to the originating office and do not require recertification. Beginning in
FY 2014, funds obligated in fiscal year prior to current fiscal year return directly to
region upon deobligation and do not require recertification.
The Deobligation Policy also includes national program-specific policies regarding the
use of recertified funds. Depending on the program, a region may be required to recertify
a portion of the prior year funds resources that it deobligates to the national program
office (to a "National Pool"), who may redistribute these funds to other regional offices
based on national priorities.
Special account and Superfund state cost share (reimbursable) resources may be
deobligated, but they are not recertified for use. Reimbursable authority must be acquired
each year to establish annual available budgets for these resources.
Because of changes in the Agency financial management system, the Agency continues
to modify the policies and procedures for deobligating and recertifying funds. Interested
staff should carefully read the most recent Deob Policy and participate in budget and
finance community networks to keep up to date on the most current procedures.
III.F.3 Removal Program Resources (PRC 303DC6)
OEM manages the removal response program budget. Removal resources are allocated in
two Site Allowances: the Removal Site Allowance (fifth position of the Budget Organization
code is site allowance code E) which supports emergency response and site-specific removal
actions; and the Removal Support Allowance (fifth position of the Budget Organization code is
site allowance code S) which provides resources for activities such as removal assessments, site
management, equipment procurement, and OSC training and exercises. Resource distribution
under the Removal Site Allowance is based upon a historical allocation methodology as well as
the annual obligation of resources. Distribution under the Removal Support Allowance is based
upon allocation decisions made by HQ and regional management at the time the Site Allowance
was established in FY 2004.
Following enactment of the annual appropriations and establishment of the Agency's
operating plan, HQ issues funding to the regions in two increments. The first increment is
distributed during the first quarter of the fiscal year and the second at the beginning of the third
quarter. HQ also retains a small reserve for emergencies or removal actions that may exceed a
region's annual resource allocation. Regions may request these funds at any point during the year
by submitting a request along with a justification to the Office of Emergency Management
Director. If the reserve remains unobligated by August of each year, HQ will ask the regions to
submit a list of critical sites that require additional resources. Sites selected for funding will be
determined by the type of threat a site poses; i.e., potential for a significant fire, explosion or the
threat of a catastrophic release.
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III.F.4 Homeland Security Resources (PRC 303D72)
The Homeland Security program develops and maintains the EPA's Homeland Security
capabilities and assets in both headquarters and regions. The program Ensure readiness of EPA
preparedness and response personnel through planning, training, and exercises and coordinates
Homeland Security activities with the Department of Homeland Security and other federal
agencies to ensure consistency with the National Response Framework. Homeland Security
resources are allocated under the Site Allowance code "C." Resources are distributed through the
operating plan and are allocated equally across the regions to implement core Homeland Security
preparedness programs and activities.
III.F.5 Remedial Response Program Resources (PRC 303DD2)
OSRTI manages the remedial response program budget, which includes two Site
Allowances, Remedial Action and Pipeline Operations. Each year, OSRTI determines the
amount of resources to allocate to these Site Allowances based on the process for developing the
Agency's annual budget.
a. Remedial Action Site Allowance
The Remedial Action (RA) Site Allowance (fifth position of the Budget Organization site
allowance code is R) is used to allocate appropriated resources for new and ongoing
remedial actions and non-time-critical removals at NPL sites (collectively termed
"construction"), long-term response actions and five-year reviews (five year reviews may
also be planned using Pipeline Operations Site Allowance resources). Regions are
required to enter all planned obligations site-specifically into SEMS for all actions funded
through the Remedial Action Site Allowance.
Through the annual work planning process, OSRTI works with the regions to develop
funding plans for the upcoming year for ongoing construction projects, including long-
term response actions and five-year reviews. During the work planning process, OSRTI
relies on planned obligation data from SEMS, ongoing discussions with the regions, and
projections of the availability of funds to develop a preliminary ongoing construction
funding plan. Only funds that a region intends to obligate in the identified year for
anticipated work should be planned for that year. Regions should ensure that special
account resources are planned and utilized to the maximum extent prior to entering
planned needs for appropriated funds. Once an appropriation is enacted and funds are
allocated to the national program offices through the operating plan, HQ will issue funds
to the regions based on the preliminary ongoing construction funding plan. If the fiscal
year begins without an enacted appropriation, HQ will allocate available resources to
each region on a case-specific basis until an appropriation is enacted and the Operating
Plan is approved. HQ and regions will continuously work together to update the plan
based on site-specific cost estimate adjustments that occur throughout the year. Regions
must also regularly update planned obligations in SEMS to accurately reflect the current
year's expected use of RA Site Allowance resources and to identify additional funding
needs.
Regions are required to obtain OSRTI approval for any proposed changes to the ongoing
construction funding plan greater than $100,000, (e.g., shift resources among sites or
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activities within the RA Site Allowance) and record all changes to planned obligations in
SEMS. Because of the changing needs of the regions during the course of the year,
OSRTI will continually monitor regional obligation rates and usage of the RA Site
Allowance resources. Based on mid-year regional reviews as well as contact throughout
the year, OSRTI will update the ongoing construction funding plan to reflect changes in
regions' resource needs as well as additional resources that may come available (e.g.,
through deobligations). Unless otherwise directed by OSRTI, and except for deviations of
$100,000 or less, regions are required to return allocated resources that will not be used
according to the ongoing construction funding plan to HQ by way of the reprogramming
process. OSRTI will include these resources in a national resource pool from which it
will fund remaining program priorities. Regions may not shift resources into or out of the
RA Site Allowance without prior OSRTI approval.
b. Pipeline Operations Site Allowance
Annually, HQ will determine the amount of resources to include in the Pipeline
Operations Site Allowance based on available appropriation funds. HQ distributes
Pipeline Operations Site Allowance (fifth position of the Budget Organization code is site
allowance code P) resources among the regions based on the Pipeline Allocation Model.
The model allocates a portion of the Site Allowance based on historical allocations and
the remaining portion using a work-based scoring system. At the initiation of the annual
work planning process, OSRTI will provide general guidance regarding its projections of
the funding that will be available to the regions through the Pipeline Operations Site
Allowance. Using this information, each region will plan out the use of these resources
and enter its planned obligations and accomplishments into SEMS. Pursuant to work
planning discussions with HQ and refined resource allocation projections based on the
Pipeline Allocation Model, regions will finalize their program operating plans in SEMS.
OSRTI then finalizes the Pipeline Operation Site Allowance allocation using the Pipeline
Allocation Model.
At the beginning of the fiscal year, HQ will generally issue 60% of the Pipeline
Operations Site Allowance among the regions. HQ will issue the remaining Site
Allowance funds during the third quarter. If a region's commitment/obligation rate is less
than 50% at the end of the second quarter, HQ may delay the remaining allocation to the
region and renegotiate the region's program allocation for the remainder of the year,
which could result in a reduction in the region's budget. If the fiscal year begins without
an enacted appropriation, HQ will work with each region to determine its funding needs
until an appropriation is enacted and the Operating Plan is approved. Funds from the
Pipeline Operations Site Allowance may not be moved to any other Site Allowance
without prior OSRTI approval.
III.F.6 Superfund Federal Facilities Response Program (PRC 303DC9)
Regional Superfund federal facilities response budgets (fifth position of the Budget
Organization code is site allowance code F) are determined during the annual work planning
sessions. If the Agency has an enacted budget, each region will receive 50% of its portion of the
approved budget during the first quarter and will receive the remainder during the third quarter.
If a region has a low obligation/utilization rate, discussions will be held prior to third quarter
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distribution as to what the need is for the remainder of the funds. To request additional funds, a
region should contact federal facilities Restoration and Reuse Office (FFRRO) and provide a
description of the amount needed and a justification for the funds. Funds may not be moved out
of the Federal Facilities Site Allowance without the FFRRO office director's prior approval.
III.F.7 Base Realignment and Closure (BRAC) (303D41 [non-site] and 303D41B4 [site-
specific])
To assist the Department of Defense (DOD) with cleaning up and transferring selected
BRAC I-IV properties, DOD provides resources to EPA to cover the cost for those employees
working in the BRAC program. Upon receiving transfer authority, the U.S. Army transfers
BRAC resources to EPA via a Military Interdepartmental Purchase Request (MTPR). Once the
HQ Grants Administration Division has processed a fully executed IA and Cincinnati Finance
Center posts the information, FFRRO distributes resources via a reprogramming to the various
Allowance Holders. Although resources are not loaded into Compass on an installation-specific
basis, DOD provides the funding to the Agency site-specifically. To increase or decrease the
funding level for any BRAC installation, regions must receive prior approval from HQ.
III.F.8 Enforcement Program (PRC 501EC7)
The Superfund enforcement program uses program/project C7. Under program/project
C7, enforcement resources are distributed under the program code 501EC7 which are Superfund
enforcement technical and legal resources that are managed by OSRE in OECA, and program
code 501JC7 which are Superfund enforcement financial management resources that are
managed by OCFO. The resources for these programs have not been assigned a Site Allowance
code and are identified in financial management databases by program/project. The initial
operating budget for technical enforcement is allocated based on each region's share of the usage
rate (as measured by expenditures for the current year to date and the preceding two years) for
enforcement activities. HQ allocates 60% of the President's budget request (if there has been
congressional appropriation committee mark-up, it will be the lesser of the two) in the early
phases of the Operating Plan. This initial allocation will be made available in the Interim
Operating Plan for spending as soon as Congress and the President agree upon an appropriation.
An additional allocation will be made in the third quarter of the fiscal year. OSRE will
issue a call to the regions late in the second quarter for requests for additional funding. Emphasis
will be placed on funding program priorities which will be outlined in the call. The call will
consider all sources of unallocated funding, including the remaining new obligating authority not
allocated in the Interim Operating Plan, carryover of funds from the previous year, projected
reprogramming, and a projection of regional resources to be deobligated and recertified. This
second allocation of funds will be distributed in the third quarter.
Funds must not move into or out of the Superfund enforcement program code 501EC7
without agency and, if necessary, Congressional approval. Funds may be redirected within the
Enforcement Site Allowance to other BOCs and to other regions or HQ offices.
III.F.9 Federal Facilities Enforcement Program Resources (PRC 501EH2)
The federal facilities enforcement program budget consists of two components: an
Environmental Programs and Management (EPM) appropriation and a Superfund appropriation,
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which are both managed by the Federal Facilities Enforcement Office (FFEO). At the beginning
of the fiscal year, FFEO informs the regional Federal Facility Program Managers of the amount
each region is allocated. The regions are requested to provide FFEO with prioritized requests for
resources, not to exceed the allocated amount. The resources consist of New Obligating
Authority (NOA), and carryover of prior year funds. The funds are disbursed by project, and
monitored by HQ. The resources for this program have not been assigned a Site Allowance code
and are identified in financial management databases by program/project. Funds may not move
into or out of the enforcement function without Congressional approval. Funds may be redirected
within the Federal Facility Enforcement Site Allowance and to other regions or HQ offices.
IILG COST RECOVERY
CERCLA allows the federal government, states, and some private parties to recover
response costs. If EPA does cleanup work using Superfund money, it will try to recover those
costs from PRPs. EPA is permitted to recover all costs of response that are found to not be
inconsistent with the National Contingency Plan (NCP).
EPA's cost recovery process involves documenting the costs, evaluating the factors for
pursing recovery of those costs, notifying parties of the costs and demanding repayment, and
negotiating a payment agreement.
When EPA uses Superfund money for work at a site (or relating to a site), the Agency
must document all of its cleanup costs so they can be recovered later on (See section IE.G.I on
Recoverable Costs). For example, costs related to any work performed by contractors must
indicate that the work was authorized and completed. Further, cost documentation must prove
that the costs were actually incurred and paid for by the government. Costs incurred by EPA are
recorded in Compass via the use of the Account Number and are paired and presented alongside
images of supporting cost and technical documentation in the Superfund Cost Recovery Package
and Image On-Line System (SCORPIOS) to yield a complete cost recovery package.
EPA's decision to pursue cost recovery is based on the evaluation of several factors, such
as strength of liability evidence, financial strength of PRPs, and the amount of incurred costs.
As a matter of policy, EPA typically sends a written demand letter to PRPs prior to filing
a cost recovery lawsuit. The demand letter requests that the PRPs reimburse the Superfund Trust
Fund for a specified amount and triggers the accrual of prejudgment interest on the costs sought
by EPA. Following the issuance of a demand letter, EPA and PRPs will attempt to negotiate a
settlement for the reimbursement of EPA's response costs. EPA will often pursue not only costs
incurred ("past costs"), but also costs it anticipates incurring at or in connection with the site
("future costs"). If a Potentially Responsible Party (PRP) agrees to reimburse EPA for its costs,
the resulting settlement will be documented in a judicial consent decree or in an administrative
settlement. If a PRP refuses to reimburse EPA for its costs or if a settlement agreement cannot be
reached, EPA may refer the case to the DOJ, who would then file a cost recovery action in court
to recover past and/or future costs. EPA may deposit costs recovered through settlements or
judgments into special accounts within the Superfund Trust Fund (See section III.J) to pay for
cleanup activities at the site for which it received the money if future work remains to be
performed at or in connection with the site.
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III.G.l Recoverable Costs
EPA may recover all of its costs that are "not inconsistent" with the NCP. Examples of
costs that the courts have found are recoverable include:
• Planning, implementing, or overseeing cleanup actions
• Investigation and monitoring
• Actions to limit access to the site
• Indirect costs needed to support the cleanup work
• EPA's contractor costs
• Annual allocation costs
a. Direct Costs
Direct costs are those expenses directly traced to a particular activity at a particular site.
These costs can include the following expenses incurred by EPA and the cleanup
contractor:
• Time spent on a cleanup-related activity
• Travel to and from the site
• Contractor costs at the site
• Equipment used at the site, etc.
b. Contractors' Annual Allocation Costs
Contractors' annual allocation costs include money spent by government contractors
doing site-related work not traceable to a particular site. For example, training received
by contractors in handling hazardous materials is an allocable cost. This training is
essential to Superfund cleanup site work, but the training received may be used at several
sites.
On an annual basis, contractors are required to follow a documented methodology for
allocating certain non-site specific costs to sites and submit an annual allocation report to
EPA for review and approval. Annual allocation costs are computed site-specifically in
SCORPIOS to enable their cost recovery. More information is at:
http://intranet.epa.gov/ocfo/superfund A/annual allocation.htm.
c. Indirect Costs
Indirect costs are EPA's expenses for managing the Agency. These costs are not directly
traceable to any particular site-specific activity and include the following activities:
• Superfund program support
• Agency support activities that benefit Superfund program
• Non-site portion of personnel compensation and benefits
• Office rent, utility, communication, supply costs, etc.
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EPA uses a complex methodology, computed in SCORPIOS, for allocating these costs
site-specifically to enable their cost recovery. OCFO annually issues computed regional
indirect rates at:
http://intranet.epa.gov/ocfo/superfund A/indirect cost rate.htm.
More information about indirect rates and methodology can also be found via:
http://www.epa.gov/superfund/policy/guidance.htm.
IILH SITE CHARGING POLICY (SITE-SPECIFIC, ZZ, OOSSIDS)
The funding documents processed through EPA's administrative and financial systems
must contain enough information to assign Superfund costs properly. Consequently, EPA uses
the SSID so that the Agency can properly assign hazardous waste cleanup costs and identify
costs by site for cost recovery and reporting purposes. The SSID is a four-character alpha-
numeric code occupying the first four positions of the Project field in EPA's Account Code
Structure. It is used in Compass to track Superfund costs for each specific site. The process for
establishing an SSID is described in exhibit III. 1.
All costs directly associated with cleanup/response actions at or for a particular
Superfund site must be charged to a site-specific SSID for that site. Costs to be charged include
salaries and benefits, travel, rental and purchase of equipment and supplies, and those costs
incurred by parties external to EPA, such as EPA's contractors, other federal agencies, local
governments, and states.
However, under some circumstances, it is impossible or impractical to charge certain
Superfund costs to a specific site. EPA uses special SSID codes for these situations (WQ, ZZ,
00). These standard codes (see following sections) appear in the third and fourth position of the
SSID and must be used by all regions and HQ offices charging costs to the Superfund.
Refer to Direct Charging of Superfund Costs Site-Specific Cost Accounting Methods in
OCFO's RMDS Resources Management Directive System 2550D-04-P1 (and Technical
Interpretation 2550D-04-P1-T1) via: http://intranet.epa.gov/ocfo/policies/direct/2550d.htm for
more detail.
III.H.1WQ SSID and WQ Action Code
"WQ" represents a generic code used to obligate funds when the precise amount to be
charged to a site or action is not known at the time of obligation. The WQ code may be applied
to the SSID, to the action code, or to both, in the Project field in EPA's Account Code Structure.
a. WQSSID
The WQ SSID is a generic SSID code (e.g., 02WQ) that EPA uses to obligate funds to
lAs, cooperative agreements, grants, and contracts when the precise amount to be
charged to specific sites or actions is unknown at the time of obligation. Use of the WQ
SSID is called "bulk funding."
Once WQ SSID obligations are expended, these costs should be redistributed from the
WQ SSID to a site-specific, ZZ, or 00 SSID within 30 days of payment for all funding
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vehicles (i.e., lAs, grants, small purchases, and contracts). Payroll and travel may not be
obligated to the WQSSID.
Special account funds (appropriation codes TR2, TR2A, and TR2B) and state cost share
funds (appropriation code TR1) must be obligated to site-specific SSIDs, not a WQ
SSID.
b. WQ Action Code
The WQ action code is a generic action code (described in chapter IV, titled SEMS Data
Management and SEMS Codes) that occupies the fifth and sixth positions of the Project
field in EPA's Account Code Structure. The WQ action code serves a similar function as
the WQ SSID, but applies to the type of actions that are being conducted in association
with the site or non-site SSID. Use of the WQ action code is also called "bulk funding."
It is possible to use both the WQ SSID and WQ action code simultaneously in the Project
field of an obligating document (e.g., 02WQWQOO). Just like the WQ SSID, once WQ
action code obligations are expended, these costs should be redistributed from the WQ
action code to a site- or non site-specific action code within 30 days of payment for all
funding vehicles Payroll and travel may not be obligated to the WQ action code.
As of FY 2014, special account funds must be obligated to site-specific SSIDs, but may
be obligated to a WQ action code. State cost share funds must be obligated to site-
specific SSIDs, and site-specific action codes.
III.H.2ZZ SSID
The "ZZ" SSID (e.g., 02ZZ) records initial assessment costs at a Superfund site where no
SSID exists. Within the removal program, costs charged to the ZZ SSID primarily include
removal assessment and technical assistance-related costs. For the remedial program, costs
charged to the ZZ SSID generally include, but are not limited to, preliminary assessment/site
inspections. If EPA determines that a cleanup response is necessary, a site-specific SSID is set
up to charge all future costs incurred. Generally, site-specific costs associated with the Remedial
Investigation and beyond should be assigned to a site-specific SSID, not the ZZ SSID.
Once a site-specific SSID is established, the approving official, usually the project
officer, will request adjustment of previous disbursements from the ZZ SSID to the site-specific
SSID. Generally, readjustments should be conducted during the first billing cycle after the site-
specific SSID is established. Redistributions of ZZ cooperative agreement disbursements are not
required due to the complexity associated with tracking site-specific costs outside agency
systems. Additionally, ZZ intramural redistributions are not required due to the relatively low
amount of time charged. However, once a site-specific SSID is established, subsequent
disbursements for the site should not be charged to the ZZ SSID.
III.H.300 SSID
The "00" SSID (e.g., 0200) is used to record general Superfund costs or when it is not
economically feasible to charge costs on a site basis. For example, if an employee's time is
divided among several sites in a manner that is not economically feasible to charge to a specific
site (e.g., less than 15 minutes per site), or cannot be tracked by site, the 00 SSID should be used.
Multi-site project management should also be charged to the 00 SSID when it is not
FY 15 SPIM 111-23 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
economically feasible to divide costs among site-specific SSIDs. Efforts spent preparing a
response to a site-specific Freedom of Information Act request for information about a particular
site are charged to the 00 SSID.
//// SUPERFUND STATE CONTRACTS(SSC)
An SSC is a legally binding agreement between EPA and a state or tribe that provides the
mechanism for obtaining statutorily required state cost share and other assurances, outlines the
statement of work for the response action, includes a cost share payment schedule, and
documents responsibilities for implementation of response activities at a site. The SSC does not
obligate funds but is used to describe the state's or tribe's role when EPA or a political
subdivision has the lead for a Fund-financed Remedial Action (Fund RA). The SSC is signed by
EPA, the state or tribe, and, if necessary, the political subdivision. The SSC must be signed prior
to the obligation of funds for a Fund RA.
Alternatively, where a state or tribe has the lead for a Fund RA, a remedial action CA,
which transfers resources to the state, is used to document the statutory assurances and other
requirements addressed by the SSC. When a political subdivision enters into a CA with EPA to
lead a Fund RA, the assurances must still be documented in an SSC.
Greater detail is provided below and in Subpart O of 40 CFR Part 35, and in State Cost
Share Provisions for Super/and State Contracts and Remedial Cooperative Agreements in
OCFO's RMDS Resources Management Directive System 2550D-09-P1 (and Technical
Interpretation 2550D-09-P1-T1) via: http://intranet.epa.gov/ocfo/policies/direct/2550d-09-pl.pdf
(effective 10/1/2012).
III.I.l Cost Share Provisions
A signed SSC or remedial CA for remedial action has five statutorily required assurances,
including a remedial state cost share assurance that must be made by a state before EPA can
obligate or expend appropriated funds for remedial action (or long-term response action) at a
particular site. The following provisions address the basic components of the cost share
assurance requirements.
a. Ten percent. Where a facility, whether privately or publicly owned, was not operated by
the state or political subdivision thereof, either directly or through a contractual
relationship or otherwise, at the time of any disposal of hazardous substances at the
facility, the state must provide 10% of the cost of the remedial action, if CERCLA-
funded (CERCLA 104(c)(3)(C)(i)); or
b. Fifty percent or more (herein after referred to as 50%). Where a facility was operated by
a state or political subdivision either directly or through a contractual relationship or
otherwise, at the time of any disposal of hazardous substances at the facility, the state
must provide at least 50% of the cost of removal, remedial planning, and remedial action
if the remedial action is CERCLA-funded (CERCLA 104(c)(3)(C)(ii)); and
c. Operation and Maintenance. The state must provide an assurance that it will assume
responsibility for all future operation and maintenance (O&M) of CERCLA-funded
remedial actions for the expected life of each such action.
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OSWER Directive 9200.3-15-1G-Y
Based on the terms of the SSC or remedial CA, the RPO, with assistance from the RFO,
will use project and action-specific direct, extramural expenditures of Superfund appropriated
resources (as well as any state cost share [TR1 fund code] resources expended) to calculate the
amount of remedial state cost share liability incurred. Typically, a state's 10% cost share will be
calculated using specific action codes that correspond with the remedial action and long-term
response action; costs associated with 5-year review are not included in this calculation. Other or
additional action codes (for removal, planning and design) may be included in the cost share
calculation if depending on the nature of the SSC or the 50% cost share requirement applies. The
RPO may consult with Regional Counsel and HQ program staff to confirm the scope of activities
to be captured in the cost share calculation and to ensure consistent application across the
regions.
III.I.2 Constraints on Obligating Funds for RA
EPA may not obligate funds for Fund RA without having a signed SSC in place. When
EPA conducts an EPA-performed, Fund-financed RA, it will generally obligate funds to a
contractor or to another federal agency through an IA. EPA may obligate Remedial Design (RD)
funds to initiate the RA procurement process, up to the point of soliciting for construction bids
without a signed SSC. In cases of extreme urgency, a solicitation (for bids on RA work) may be
issued before an SSC is signed. The solicitation must notify prospective bidders that the
availability of funds for the contract is contingent on EPA and the state concluding an SSC. To
ensure that Fund monies are effectively used, procurement activities should be initiated with RD
funds only when the region is confident the SSC will be signed before bids are opened. If the
SSC is not signed before the bid opening, one of the following decisions must be made: 1) the
solicitation may be canceled; or 2) the bid opening date may be postponed (giving bidders an
opportunity to withdraw, modify, or submit new bids) (See Office of Emergency and Remedial
Response (OERR) Directive 9735.7-02).
Among other requirements, the SSC must contain an estimated value of the remedy that
EPA will implement using Fund resources (and the state's share), the amount of cost share that
the state is assuring to provide, and a cost share payment schedule. EPA may not spend RA
resources in excess of the estimated value of the remedy determined in the SSC. If there are
increases to the cost of the RA, the SSC must be amended to reflect the change and document the
state's increased share of the cost (See OERR Directive 9375.7-01). The region must provide the
Cincinnati Finance Center (CFC) copies of any SSC, amendment, or closeout document within
five business days.
III.I.3 Cost Share Payments
A state may pay for its share of response costs using cash, services, credit, or any
combination thereof. Greater detail of these cost share payment provisions and their
requirements are described in Subpart O, sections 35.6285 and 35.6815.
1. Cash. A state may pay for its share of response cost by direct cash payments to EPA.
Payment terms are specified in the SSC between the state and EPA.
2. Services. This form of payment may be provided only through a cooperative agreement.
Where EPA (or a political subdivision) is conducting the remedial action and an SSC is
required, this form of payment must also be documented in the SSC. In-Kind Services are
described in 40 CFR 31.24.
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OSWER Directive 9200.3-15-1G-Y
3. Credit. A state may satisfy its cost share requirement using credits, which are limited to
state site-specific expenses that EPA determines to be reasonable, documented, direct,
out-of-pocket expenditures of non-federal funds for remedial action, as defined in
CERCLA section 101(24), that are consistent with a permanent remedy at the site.
a. Credits are established on a site-specific basis and only a state may claim credit.
b. For sites already listed on the NPL, the state may be eligible for credit only if the
state initiated the remedial action after obtaining EPA's written approval
(authorization to conduct work).
c. Expenditures of non-federal funds for removal actions, as defined in CERCLA
section 101(23), are not eligible for credit.
d. The state must first apply all credit to the site for which it was earned. With the
approval of the EPA regional administrator, the state may use excess credit earned
at one site for its cost share at another site. EPA will not reimburse excess credit.
III.I.4 Using Funds from State Cost Share Payments
SSC collections become part of the Superfund appropriation and are designated as
reimbursable resources using the TR1 fund code. These funds must be used at the site for which
they were collected, and EPA cannot obligate these funds until reimbursable authority has been
issued. The Office of Budget annually issues a reimbursable authority guidance memo giving
direction on requesting reimbursable authority. To receive reimbursable authority, the regional
program office generally initiates a request and the RFO submits a reprogramming document in
Compass to request unobligated TR1 resources associated with the site.
To maximize the use of appropriated resources elsewhere in the program, the region
should annually assess the availability of TR1 funds at a particular site to determine whether
these resources may be used in lieu of T funds. Generally, obligations of TR1 funds, relative to T
obligations for remedial action, should roughly match the proportions specified in the cost share
contract (e.g., TR1 obligations would equal 10% of the value of total remedial action
appropriation obligations). Since resource use is a dynamic process, such estimates will
necessarily be rough, and the precise calculation of cost share amounts will occur during SSC
reconciliation.
IILJ SPECIAL ACCOUNTS
Special accounts are site-specific, interest bearing sub-accounts within the Superfund
Trust Fund. CERCLA authorizes EPA to retain and use funds received in settlement with PRPs
to carry out corresponding settlement agreements. Special accounts ensure that funds provided to
EPA by PRPs are used to remediate contamination that those parties are responsible for. This in
turn preserves annually appropriated resources for sites without financially viable PRPs. Use of
special account resources helps to achieve cleanup without relying solely on EPA's annual
Superfund appropriations.
EPA has been successful at collecting settlement funds to be placed in site-specific
special accounts and using these funds for future response costs at those sites. The growth of
special accounts requires greater focus on managing the funds. In particular, EPA's focus on
special account management includes: ensuring available special account funds are used for
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response work rather than annually appropriated resources; reclassifying and transferring funds
to the general portion of the Superfund Trust Fund when appropriate; and closing out special
accounts where funds are no longer required for work at the site.
The SEMS Special Accounts Management screen enables regions to see and enter
planning data for the use of special accounts alongside response activities and appropriated
resource planning for individual sites. Regions are expected to plan the use of available funds in
each special account consistent with guidance. Special account planning data should be updated
at least twice a year during the work planning and mid-year review processes, but also more
frequently when a milestone is reached (e.g., an account is established, funds are received, new
planning information is available). OSRTI and OSRE review special account planning data to
ensure SEMS planning is appropriate and special account funds are being used expeditiously to
further cleanup work at sites.
Several guidance documents are available to assist the planning and use of special
account funds for response actions at: http://intranet.epa.gov/oeca/osre/workgroup/sa/sa-
policy.html
III.K USING THE FIDUCIARY RESERVE TO ADDRESS COST
OVERRUNS
EPA has a strong commitment to ensure that unliquidated obligations are periodically
reviewed, and if appropriate, are deobligated and committed toward activities in need of funding.
The Agency discourages the practice of retaining funds after a project period expires. Offices
should deobligate any unliquidated obligations with expired project periods, with the exception
of funds to address immediate pending invoices (OSRTI recommends within 90 days).
The Agency's fiduciary and expired fund reserve accounts, which are monitored by the
Office of Budget, are sufficient to cover circumstances where funds were deobligated but
subsequently needed. For Superfund, the Agency has an enhanced reserve in order to encourage
timely deobligation and to help maintain the pace of cleanups. Use of the fiduciary reserve will
not cause an Anti-deficiency Act violation. However, the Director, Office of Budget (OB), at
his/her discretion, may ask the program office responsible to reimburse the fiduciary reserve for
any overrun with current dollars if OB believes there is a need to replenish the fiduciary reserve.
Accessing the fiduciary reserve does not require Office of Budget approval, only
notification if the amount is over $50,000. The obligating official, payment official, or
Contacting Officer should fund the obligation with a modification including the appropriate
accounting information, based on the year of the overrun. Program offices should not submit new
commitments to cover these obligations.
Because of the possibility that the program office will need to replenish the reserve, if the
prior year obligation is within the remedial program and is over $50,000, the region should
consult with OSRTI, Chief of the Budget Planning and Evaluation Branch (BPEB), before
proceeding to fund the obligation. The obligating official or payment official should then notify
the OB Control Team Leader, copying the BPEB Chief. The message should include the total
amount of the charge (above and beyond any unliquidated obligation) broken down by the
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OSWER Directive 9200.3-15-1G-Y
Budget Fiscal Year, appropriation and amount. The OB Control Team Leader will acknowledge
the notification via a responding e-mail.
For prior year obligations of Superfund resources other than the remedial program, please
contact the appropriate program office.
September 30, 2014 111-28 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Superfund Program Implementation Manual
FY15
Chapter IV: SEMS Data Management and SEMS Codes
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the
SPIM (FY2012 - Addendum), available at
http://www.epa.gov/superfund/action/process/spiml2.html
FY 15 SPIM September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
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September 30, 2014 FY 15 SPIM
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Superfund Program Implementation Manual
FY15
Chapter V: Remedial Site Assessment
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CHAPTER V: Remedial Site Assessment
Table of Contents
V.A Remedial Site Assessment V-l
V.A.I Introduction V-l
V.A.2 Remedial Site Assessment Priorities V-2
V.A.3 Remedial Site Assessment Backlogs V-3
V.A.4 Overview of Remedial Site Assessment Targets and Measures V-3
V.A.5 Data Quality and Data Entry Timeliness Requirement V-7
a. Data Quality V-7
b. Data Entry Timeliness Requirement. V-7
V.A.6 Action Qualifiers for Remedial Site Assessment Activities V-7
a. No Further Remedial Action Planned (NFRAP) V-8
b. Higher Priority /Lower Priority V-8
c. Refer to Removal V-8
d. Site addressed as part of another NPL or Non-NPL site V-8
e. Referred From RCRA V-9
f. Assessment Complete - Decision Needed V-9
V.A.7 Remedial Site Assessment Critical Indicators V-ll
V.A.8 Remedial Site Assessment Activities V-ll
a. Pre-CERCLA Screening V-ll
b. Referred From RCRA V-l 4
c. Remedial Site Initiation (Discovery) V-l 5
d. Preliminary Assessments (PA) at Non-Federal Sites V-l 6
e. Site Inspections (SI) at Non-Federal Sites V-l 8
f. Site Reassessments at Non-Federal Sites V-l 9
g. Expanded Site Inspections (ESI) at Non-Federal Sites V-20
h. Integrated ESI/Remedial Investigations (ESI/RI) at Non-Federal Sites V-21
i. Hazard Ranking System Packages (HRS) V-23
j. Other Cleanup Activity (OCA) V-24
k. Formal State Deferral V-27
I. NPL Listing Activities V-29
V.A.9 Cleanup Alternatives V-30
a. Referral to EPA Removal V-30
b. Deferral to RCRA V-31
c. Deferral to Nuclear Regulatory Commission (NRC) V-31
d. Other Cleanup Activity (OCA) V-31
e. Formal State Deferral V-33
f. Superfund Alternative Approach V-33
g. NPL Listing V-34
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List of Exhibits
Exhibit V.I. Superfund Remedial Site Assessment Process V-2
Exhibit V.2. Remedial Site Assessment Activities V-6
Exhibit V.3. Remedial Site Assessment Activity Qualifiers V-10
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CHAPTER V: REMEDIAL SITE ASSESSMENT
V.A REMEDIAL SITE ASSESSMENT
V.A.I Introduction
The Superfund remedial site assessment (aka remedial site evaluation) process evaluates
sites to determine and implement the appropriate responses to releases of hazardous substances
to the environment. During the site assessment process, the Environmental Protection Agency
(EPA), states, tribes or other federal agencies collect data to identify, evaluate, and rank
hazardous waste sites based on Hazard Ranking System (HRS) criteria. The HRS is a
numerically based screening system that uses information from initial, limited investigations to
assess the relative potential of sites to pose a threat to human health or the environment. It is the
principal mechanism EPA uses to place uncontrolled waste sites on the National Priorities List
(NPL). Sites with HRS scores of 28.5 or greater are eligible for placement on the NPL. Only
sites on the NPL are eligible for Superfund-financed remedial actions.
Superfund site assessment staff may be notified of a potential site through various
mechanisms, including receipt of a citizen's petition, referrals from EPA's removal and Resource
Conservation and Recovery Act (RCRA) programs, and referrals or notifications from states,
tribes and other federal agencies. Following notification, a non-federal site undergoes a minimal
screening process to determine whether the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) remedial site assessment process is appropriate.
This process is referred to as pre-CERCLA screening. Once a potentially hazardous site is
identified as appropriate for the remedial site assessment process, it is assigned a remedial site
initiation (discovery) date and is added to the Superfund Enterprise Management System
(SEMS) remedial assessment active site inventory. Using criteria established under the HRS,
EPA and/or its state and tribal partners, or another federal agency, conducts a remedial
Preliminary Assessment and if warranted, a remedial Site Inspection or other more in-depth
remedial assessment to determine whether the site warrants short- or long-term cleanup attention.
Federal sites are submitted through the Federal Facilities Hazardous Waste Compliance Docket
and do not go through the pre-CERCLA screening process. Federal facilities site assessment is
generally performed by federal agencies (E.O. 12580) and reviewed by EPA in accordance with
the HRS criteria. EPA's responsibilities during the remedial assessment process at federal
facilities are further discussed in chapter VIII, titled Federal Facility Program, of the Superfund
Program Implementation Manuel (SPEVI).
During the remedial site assessment process, the HRS model may be applied to derive a
preliminary site HRS score. Sites with preliminary HRS scores below 28.5 generally require no
further Superfund remedial interest and are assigned a NFRAP decision. The NFRAP decision
can also be made at sites with preliminary HRS scores of 28.5 or higher if EPA believes the site
would receive a No Action Record of Decision (ROD) if it was placed on the NPL.
Sites that do warrant further removal- or remedial-type study are referred to appropriate
cleanup programs for further work. These cleanup programs include: EPA removal; RCRA;
Nuclear Regulatory Commission (NRC); state, tribal, municipal or other federal cleanup
programs; the Superfund Alternative Approach (SA Approach); and the National Priorities List.
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EXHIBIT V.I. SUPERFUND REMEDIAL SITE ASSESSMENT PROCESS
Site Assessment Process Under CERCLA
Pre-CERCLA
Screening
Discovery/Add
to Active Site
Inventory
Refer to Removal Program as necessary
Sites that do not pass Pre-CERCLA Screening are
tracked in SEMS as "Not a Valid Site or Incident"
NFRAP
Deferred to RCRA
Deferred to Nuclear
Regulatory Commission
State Cleanup
Programs
Superfund Alternative
Approach
Preliminary
Assessment
(PA)
Removal Action
Site Inspection (SI)*
MRS Package
*Process may also include
Expanded Site Inspection (ESI)
and/or Site Reassessment (SR)
Placement on the NPL
(NPL Listing Process)
V.A.2 Remedial Site Assessment Priorities
EPA regional offices should incorporate the following priorities into regional remedial
site assessment business practices as practicable in each region and as available resources permit.
Assessing the worst sites first continues as a national priority. The regions should identify the
sites posing the highest risk or potential risk and develop a strategy to assess those sites in a
timely manner, while balancing their other site assessment needs.
While assessing the worst sites first, the regions must strive to meet annual remedial
assessment commitments and goals established to ensure sites are assessed in a timely manner
and to prevent the backlog of sites needing remedial assessment from rising unacceptably.
Regional site assessment programs are encouraged to pursue more cost- and time-efficient
methods of assessing sites without compromising the quantity and quality of site assessment
decisions. This includes, among other approaches, combining and/or integrating assessments to
reduce cost and time to assess sites. Regions should continue the use of pre-CERCLA screening
to assure only appropriate non-federal sites are placed in the SEMS remedial assessment active
site inventory. The regions should also ensure the appropriate remedial assessments of sites of
tribal concern that are in or near Indian Country.
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To better accomplish the national priorities, the regions should continue negotiating work
share agreements with individual states (and tribes if applicable) in a manner that achieves
program objectives in the most efficient manner possible.
Site assessment is the first step in determining whether a site meets the criteria for
placement on the NPL. NPL Listing is one of several approaches for addressing sites where
assessment indicates remedial study/cleanup is needed to address human health and/or ecological
risks. NPL listing should be used when it is believed to be the best approach for addressing a site.
In 1992, EPA's Office of Emergency and Remedial Response (OERR), now the Office of
Superfund Remediation and Technology Innovation (OSRTI)) issued a directive entitled
Guidance on Setting Priorities for NPL Candidate sites (Office of Solid Waste and Emergency
Response (OSWER) Directive 9203.1-06). The 1992 directive provided regions with general
factors that should be considered in the risk-based decision making process for choosing sites to
propose for listing pursuant to section 105(a)(8)(B) of CERCLA.
The SA Approach is generally the Agency's preferred enforcement approach for
CERCLA non-NPL sites that are NPL-caliber, where feasible and appropriate. Additional
information on the SA Approach is included in section V.A.9 Cleanup Alternatives.
V.A.3 Remedial Site Assessment Backlogs
A key function of Headquarters (HQ) is to report national progress in the remedial site
assessment program. Workload estimates are critical indicators of future program needs. HQ
captures these workload estimates by identifying the number of sites at various stages in the site
assessment pipeline. These stages are commonly referred to as "backlogs". For example, sites
needing completion of a CERCLA remedial Preliminary Assessments (PA) are collectively
termed the "PA Backlog". HQ will measure regional progress on non-federal sites still needing
assessment with special emphasis on older sites needing preliminary assessments completed or
needing a listing decision. A listing decision is defined as an assessed site with a NFRAP
decision, or with a decision to study/cleanup a site via the NPL or a non-NPL cleanup approach.
Regions should consider these assessment workloads when planning assessment work; however,
the primary goal within the assessment program continues to be assessing worst sites first.
V.A.4 Overview of Remedial Site Assessment Targets and Measures
The following pages contain, in pipeline order, the definitions of Superfund remedial site
assessment targets and measures. Exhibit V.2 displays the full list of remedial site assessment
activities defined in this chapter and the associated reporting hierarchy.
EPA's 2014-2018 Strategic Plan, Goal 3, Objective 3.3 Restore Land contains the
Government Performance and Results Act (GPRA) measure for Superfund remedial assessment
work: "By 2018, complete 95,500 assessments at potential hazardous waste sites to determine if
they warrant CERCLA remedial response or other cleanup activities." Commonly referred to as
Remedial Site Assessment Completions (RSACs), this measure reflects the total number of
Pipeline-funded remedial site assessments at non-federal sites and reviews of remedial
assessments provided by other federal agencies at federal facility sites. Regional targets for
RSACs are established each year in the Agency's Annual Commitment System (ACS). RSAC
accomplishment credit is given upon successfully recording the completion of the following site
assessment reports in SEMS:
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• Pre-CERCLA Screening (PCS)
• PA
• Federal Facility PA Review
• Site Inspection (SI)
• Federal Facility SI Review
• Expanded Site Inspection (ESI)
• Federal Facility ESI Review
• Site Reassessment
• Federal Facility Site Reassessment Review
• Expanded Site Inspection/Remedial Investigation (ESI/RI)
• HRS Package
Except for pre-CERCLA screening activities, sites must have a completed remedial site
initiation (discovery) activity recorded in SEMS to get GPRA accomplishment credit for a
Superfund remedial site assessment. Only remedial assessments with an actual completion date
falling in the current fiscal year (FY) will get captured in current year accomplishment reporting.
All completed Superfund pre-CERCLA screenings and all other remedial site assessments at
sites with a completed discovery activity will get captured in cumulative accomplishment
(inception-to-date) reporting.
Two sub-measures apply to remedial assessment work to help the Agency meet statutory
and program timeliness goals and to ensure the age and number of sites needing completion of
remedial assessment work does not rise unacceptably. Each fiscal year, regions must reduce the
number of non-federal sites over 5 years old without a preliminary assessment completed by 10
percent and address 10 percent of non-federal sites over 16 years old without an NPL listing
decision. The universe of sites and associated sub-measure targets will be established at the
beginning of each year to account for previous accomplishments and the addition of new sites.
Regional progress towards meeting these sub-measure goals will be monitored each fiscal year.
The overall program priority of assessing worst sites first shall be a valid factor to consider when
evaluating regional progress.
For the annual 5-year PA sub-measure, accomplishment credit will be given at sites that
get eliminated from the universe of sites established at the beginning of each fiscal year.
For the 16-year NPL Listing Decision sub-measure, accomplishment credit will be given
at: 1) sites that get an NPL listing decision made or otherwise no longer require a listing
decision; and 2) sites still in the universe at the end of the fiscal year that have had a remedial
site assessment action started during the fiscal year. Remedial site assessment activities include
all the GPRA-based remedial site assessment activities described in the SPEVI except for pre-
CERCLA screenings.
The annual and cumulative number of Superfund remedial site assessments completed
will be captured on the Superfund Comprehensive Accomplishments Plan (SCAP)-15 report and
will be included in EPA's Annual Report. Site detail supporting annual completion counts will
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be included on the SCAP-13 and SCAP-15 reports. The annual PA and NPL Listing sub-
measures will be tracked on the SEMS report no. SA-034, Remedial Site Assessment
Completion Sub-Measures.
The following non-GPRA measures are tracked to capture the disposition of sites based
on remedial site assessment work performed in the current fiscal year:
1. # Remedial Site Assessments Completed: NFRAP (site does not qualify for the NPL
based on existing information) - this measure will capture the portion of GPRA
Superfund remedial site assessments that are:
a. Assigned a NFRAP decision
b. Determined not eligible for entry into the active SEMS inventory based on a pre-
CERCLA screening report
c. Addressed as part of a non-NPL parent site that has since been assigned a NFRAP
decision or placed in the SEMS Archive site inventory
2. # Remedial Site Assessments Completed: Remedial Study/Cleanup Needed - this
measure will capture the portion of GPRA Superfund remedial site assessments that are
assigned one of the following decisions or status designations:
a. Deferred to NRC
b. Deferred to RCRA
c. Referred to removal, needs further remedial assessment
d. Referred to removal, no further remedial assessment
e. Addressed as part of a parent site that is on the NPL
f. Remedial activities under EPA enforcement, including sites addressed using a SA
Approach agreement
g. Other Cleanup Activity
3. # Remedial Site Assessments Completed: Further Site Assessment Needed - this measure
will capture the portion of GPRA Superfund remedial site assessments that are assigned
one of the following decisions:
a. Higher priority for further assessment
b. Lower priority for further assessment
c. Recommended for FIRS scoring
d. Being considered for proposal to the NPL
e. Addressed as part of a non-NPL parent site that is still being assessed
f. Needs a remedial preliminary assessment based on completion of a pre-CERCLA
screening report
SEMS report SA-006, Site Assessment Accomplishments report is used to report the
results of assessments completed during the fiscal year and the number of sites needing remedial
assessment.
Final Assessment Decisions (FADs) are tracked as the Superfund component to the
OSWER Cross Program CERCLA Site Assessment Measure. FADs are tracked as a reporting
measure only - no goals or targets are set at the beginning of the fiscal year.
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OSWER Directive 9200.3-15-1G-Y
SEMS report SA-031, Final Assessment Decisions, is used to report the number of FADs
made during the fiscal year. Additional information on FADs is provided in the SPIM Site
Information chapter.
Exhibit V.2 presents a comprehensive list and reporting status of remedial site assessment
activities:
EXHIBIT V.2. REMEDIAL SITE ASSESSMENT ACTIVITIES
ACTIVITY
No. of Completed Superfund Remedial Site Assessments
No. of Completed Remedial Site Assessments: NFRAP
No. of Completed Remedial Site Assessments: Remedial Study/Cleanup Needed
No. of Completed Remedial Site Assessments: Further Site Assessment Needed
No. of Final Assessment Decisions
NPL Listing (Proposed, Final, Removed From Proposed, Withdrawn)
Reduce # of non-federal sites over 5 years old without a PA completion by 10%
Address 10% of non-federal sites over 16 years old needing an NPL listing decision
Pre-CERCLA Screening
Remedial Site Initiation (Discovery)
PA at Non-Federal Site
Federal Facility PA Review
SI at Non-Federal Site
Federal Facility SI Review
Site Reassessment
Federal Facility Site Reassessment Review
ESI at Non-Federal Site
Federal Facility ESI Review
Integrated ESI/RI
HRS Package (non-federal and federal facility)
Other Cleanup Activity
State Deferral
Referred from RCRA
External Program
Reporting
Annual Commitment
System (ACS),
Strategic Plan
Internal
Program
Reporting
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Key to Reporting Hierarchy
ACS = Regional targets are established in Annual Commitment System.
Strategic Plan = National target is publicly reported in the Agency's FY14-FY18 Strategic Plan.
Measure = SCAP reporting measure, but target not required.
September 30, 2014
V-6
FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
V.A.5 Data Quality and Data Entry Timeliness Requirement
a. Data Quality
The regions should assure that their site assessment information is complete, current,
consistent and accurate. To assist the regions in this determination, data quality reports
for Superfund site assessment information in SEMS are available through the SEMS
reporting tool. SEMS report no. SA-009, Site Assessment Data Quality displays
information on sites with potential remedial site assessment data errors. Regions are
required to review the data issues on this report prior to the end of each fiscal year and
make data corrections in SEMS as necessary to ensure end of year reporting is accurate.
b. Data Entry Timeliness Requirement
It is good management practice to enter data regarding events as soon as practicable after
the event occurs. Generally, to insure data are reflected in quarterly reports, data must be
entered in SEMS prior to the quarterly pull date which occurs on the fifth business day
following the end of each quarter or the 10th business day following the end of the fourth
fiscal quarter
V.A.6 Action Qualifiers for Remedial Site Assessment Activities
Site screening and assessment decisions are made upon completion of most types of
remedial assessment activities. These decisions are tracked in SEMS as "qualifiers" for
applicable activities. To achieve GPRA RSAC credit, the following activities must have a
qualifier recorded for them in the SEMS Site Management module (qualifiers are added on the
Site Decision tab of the Edit Site Evaluation Schedule screen):
• PA
• Federal Facility PA Review
• SI
• Federal Facility SI Review
• ESI
• Federal Facility ESI Review
• Site Reassessment
• Federal Facility Site Reassessment Review
• ESI/RI
• HRS Package
The following non-GPRA activities must also have a decision/qualifier recorded for them
when complete to enable the Agency to correctly determine the status of the site from the
perspective of the Superfund remedial site assessment program:
• Other Cleanup Activity
• State Deferral
FY 15 SPIM V-7 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
SEMS report no. SA-009 Site Assessment Data Quality includes a "Completed Actions
with No Decision" line item. Regions should pay particular attention to this data issue since it
may impact GPRA RSAC credit and classification of site status in annual reporting.
Most decisions are self-explanatory. Exhibit V.3. Remedial Site Assessment Activity
Qualifiers displays available decisions/qualifiers for each type of remedial site assessment
activity. The following provides additional details for select decisions/qualifiers:
a. No Further Remedial Action Planned (NFRAP)
No further Superfund remedial assessment work will be taken at a site with a No Further
Remedial Action Planned (NFRAP) determination unless new information warranting
such action is received by EPA. NFRAP decisions should not be confused with archiving.
NFRAP decisions are made from a site assessment perspective only; they simply denote
that further Superfund NPL assessment work is not required based on currently available
information. In contrast, the archival of SEMS sites is made only when no further
Superfund interest exists at a site. This means that sites are not archived if there are
planned or ongoing removal or enforcement activities or if other Superfund interest still
exists, even if a NFRAP decision was made based on remedial site assessment activities.
b. Higher Priority / Lower Priority
Decisions of higher priority and lower priority for further assessment are used to indicate
more complex evaluation activities are required to determine whether or not the site
should be pursued for placement on the NPL. There is no standard national definition for
higher priority or lower priority. In general, sites with a higher priority remedial
assessment decision are expected to need further remedial assessment attention sooner
than sites with a lower priority decision.
c. Refer to Removal
Upon completion of a remedial assessment activity, the region may determine that a time-
critical, non-time critical (NTC), or other activity from the EPA removal program is
warranted. There are two different decisions used to track the referral of a site to the
removal program. The decisions depend upon whether or not the region believes
additional remedial assessment will still be needed following completion of work by the
removal program. The two decisions are self-explanatory and include:
1. Referred to Removal, Needs Further Remedial Assessment; and
2. Referred to Removal, No Further Remedial Assessment.
Regions should monitor those sites referred to removal that need further remedial
assessment to ensure additional remedial assessment is not overlooked once removal
work is complete.
d. Site addressed as part of another NPL or Non-NPL site
Upon completion of a remedial site assessment activity, the region may decide that a non-
NPL site is best addressed as part of another pre-existing site. The pre-existing site may
be on the NPL or not on the NPL. This most frequently occurs at federal facilities and
September 30, 2014 V-8 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
sites with an area-wide groundwater contamination or sediment problem resulting from
multiple sources. To address these situations, regions should select one site to serve as the
parent site and the other site will become a child site. Parent sites may have multiple
child sites. Once the parent/child relationship is established in SEMS, no further response
work should be recorded at the child site. Instead, any further response work should be
tracked under the parent site. The following data entry steps are required in SEMS when
parent/child relationships are established:
• Upon completion of the remedial site assessment activity that led to the decision
to combine the two sites, the region should enter a qualifier of "Addressed as part
an existing NPL site" or "Addressed as part of another non-NPL site" depending
on whether the parent site is on the NPL;
• The seven digit Site ID number of the parent site must be entered into the Parent
Site ID field for the child site;
• The seven digit Site ID number of the child site must be entered into the Child
Site ID field for the parent site;
• The NPL Status for the child site must be changed to 'Site is part of NPL Site' if
the parent site is an NPL site;
• The Non-NPL Status for the child site must be changed to 'Addressed as part of
another non-NPL site' if the parent site is not an NPL site.
The Final Assessment Decision value for a child site should match that of its parent site.
e. Referred From RCRA
Facilities whose owners have demonstrated an inability to finance corrective action are
referred to Superfund from RCRA. An action qualifier of Financial should be added for
all Referred from RCRA actions where the site is referred to Superfund due to a failed
financial assurance.
f. Assessment Complete - Decision Needed
This qualifier can be used at NPL caliber sites when all anticipated remedial site
assessment work is completed and a decision still needs to be made regarding which
remedial cleanup program approach to pursue (e.g., NPL, removal, state voluntary
cleanup program).
FY 15 SPIM V-9 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
EXHIBIT V.3. REMEDIAL SITE ASSESSMENT ACTIVITY QUALIFIERS
Available Action Decisions
SITE ASSESSMENT
Ml^ MUIM NMWItvJ & UUUtG
Pre-CERCLIS Screening HX
Discovery OS
Preliminary Assessment PA
Federal Facility1 PA Review RX
Site Inspection SI
Federal Facility SI Review TY
Site Reassessment 00
Federal Facility Site Reassessment Review ZC
Expanded Site Inspecticns ES
Federal Facility ESI Review TZ
ESI/RI S3
State Deferral AQ
HRS ^ackage HR
Other Cleanup Activity VA
Referred from RCRA XR
Archive Site VS
Site Unarchived VU
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
I/
•
•
•
•
•
•
NOT APPLICABLE
NOT APPLICABLE
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
/ ^
•
/ v
•
•
•
•
•
•
•
•
•
•
•
This action is populated when the archive flag is selected. No leads/decisions for these actions are available.
This acticn is populated when the archive flag is ceselected. No leads/decisions for these actions are available.
September 30, 2014
V-10
FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
V.A.7 Remedial Site Assessment Critical Indicators
Critical Indicators are used in SEMS as a way to further describe the activity at the site.
Critical indicators are entered on the Work Package Info tab of the Edit Schedule screen in the
SEMS Site Management module. The critical indicators available for remedial site assessment
activities include:
• Abbreviated Preliminary Assessment - Available for the PA and Federal Facility (FF)
Preliminary Assessment Review activity.
• Integrated Removal and Remedial Assessment (Int Rmvl/Rmdl Assess) - Available
for the following activities:
Preliminary Assessment;
Site Inspection;
Expanded Site Inspection;
Site Reassessment;
- HRS Package;
- Integrated ESI/RI; and
Removal Assessment.
V.A.8 Remedial Site Assessment Activities
a. Pre-CERCLA Screening
Activity Definition:
Pre-CERCLA screening (PCS) is an initial review of existing information on a potential
Superfund site to determine if a release or potential release of a hazardous substance has
occurred and is eligible for further remedial evaluation under CERCLA authority, and
whether the site should be entered into the SEMS remedial assessment active site
inventory for further assessment. Pre-CERCLA screening intends to prevent entry of
uncontaminated sites or sites ineligible under CERCLA into this inventory, and help site
assessors determine whether the site needs further attention under Superfund or another
cleanup program.
PCS activities include reviewing existing information and collecting minimal additional
information to determine whether a site warrants entry into the Superfund active
inventory for further remedial assessment. Minimal additional information can include
collecting limited sampling data (less than $10,000 sampling costs per screened site)
subject to EPA regional policy, procedures or practices. PCS activities do not include
checking SEMS to see if the site is already included in the Superfund active or archive
inventories.
PCS activities should not be performed at sites that clearly do not fall within the scope of
CERCLA section 105. Subsequent PCS activities may be performed when new
information is received at sites previously screened and determined not to warrant entry
into the active inventory.
FY 15 SPIM V-l 1 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
PCS activities apply only to non-federal facility sites. PCS activities do not apply at
federal facility sites because they get added to the Federal Facilities Hazardous Waste
Compliance Docket and require completion of a preliminary assessment per CERCLA.
A pre-CERCLA screening can be initiated for a number of reasons, including, but not
limited to:
• The receipt of a phone call or referral from a state, tribal or other federal agency
staff on a potential new site;
• In response to a CERCLA 105(d) petition to conduct a remedial preliminary
assessment;
• As part of an area-wide discovery effort to determine the source of known
contamination;
• As part of an activity identified in a state or tribe cooperative agreement.
The following minimum level of information is required prior to initiating PCS work at a
potential site:
• State;
• County;
• City (or section township and range);
• Street address; and
• Professional judgment by regional site assessment program staff that a PCS is
warranted.
• Note: A zip code is preferred, but not required.
Once regional staff determine a PCS is warranted, the potential site should be added to
the SEMS database to track the PCS activity. For PCS work conducted by a state or tribe
pursuant to a cooperative agreement with EPA, the site(s) can be added to the SEMS
database after EPA receives the PCS report.
For planning purposes, regions should complete a PCS report within one year after
determining a PCS is warranted. The SEMS project management software will
automatically create a planned PCS completion date one year from the date the site is
added to SEMS. The site assessment reports area in SEMS includes SEMS report no. SA-
036: Sites Needing Completion of Pre-Comprehensive Environmental Response,
Compensation and Liability Information System (CERCLIS) Screening. This report
displays sites added to SEMS that need a PCS completed.
Regional remedial site assessment programs are responsible for reviewing PCS reports
and making a decision on whether to add the site to the SEMS remedial assessment active
site inventory for further assessment. A Remedial Site Initiation (Discovery) activity
must be added to SEMS with an actual finish/completion date for those sites determined
to need further remedial site assessment (e.g. remedial preliminary assessment). Regions
should communicate PCS report decisions to appropriate state staff and to tribes with a
September 30, 2014 V-12 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
known interest in the site in a timely manner. The PCS report is a Superfund core
document and must comply with the relevant requirements described in the Records and
Information Management chapter of the SPIM.
For more information on pre-CERCLA screening, please refer to the Pre-CERCLIS
Screening Assessments fact sheet (OSWER 9375.2-11FS) available at
http://www.epa.gov/superfund/sites/npl/hrsres/fact/sascreen.pdf. NOTE: EPA plans to
distribute revised pre-CERCLA screening guidance in FY 2015.
Accomplishment Definition:
Pre-CERCLA Screening Start - A pre-CERCLA screening activity is started when: 1) the
region begins collecting data and performing other tasks related to completion of the PCS
report; or 2) a PCS report is submitted by a state or tribe pursuant to a cooperative
agreement with EPA; and SEMS contains the actual pre-CERCLA screening activity start
date and an activity lead of: EPA; EPA-In House; State; or Tribe. The pre-CERCLA
screening activity start date can be the same as the activity completion date.
Pre-CERCLA Screening Completion - A pre-CERCLA screening is completed when:
• A PCS document has been approved and signed by EPA, including a decision
made on whether to add the site to the SEMS remedial assessment active site
inventory. The pre-CERCLA screening actual completion date is the date the PCS
report is signed by EPA; and
• SEMS contains the actual pre-CERCLA screening activity and actual completion
date, a valid performance lead, and appropriate values in the NPL and Non-NPL
Status fields.
In addition to the pre-CERCLA screening activity, entry of the following information is
required:
Sites that require remedial assessment work, or both remedial assessment and removal
work
• A Remedial Site Initiation (Discovery) actual completion date;
• An NPL Status of Not on the NPL on the Site Information screen in the SEMS
Site Management module;
• A Non-NPL Status of PA Start Needed or Integrated Removal Assessment PA
Start Needed on the Site Information screen.
Sites that require only removal work
• A Removal Site Initiation actual completion date;
• An NPL Status of Not on the NPL on the Site Information screen;
• A Non-NPL Status of Removal Only on the Site Information screen.
Sites that require no further evaluation beyond the pre-CERCLA screening
• An NPL Status of Not a Valid Site or Incident on the Site Information screen;
• A Non-NPL Status of Not a Valid Site or Incident, Not a Valid Site - RCRA
Lead, Not a Valid Site - NRC Lead, Not a Valid Site - State Lead, or Not a Valid
Site - Tribal Lead.
FY 15 SPIM V-13 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
Special Planning/Reporting Requirements:
All pre-CERCLA screening activities should be tracked in SEMS, including activities at
sites not found to be CERCLA-eligible. Sites that are screened out of the SEMS remedial
assessment active site inventory will be tracked through the "Not a Valid Site or
Incident" values in the NPL and Non-NPL status field. If the decision is made that the
site requires NPL assessment and potential cleanup under CERCLA authority, it should
be added to the SEMS inventory by entering a Remedial Site Assessment Initiation Date
and a valid NPL and Non-NPL Status. A Remedial Site Assessment Initiation activity or
date should not be entered into SEMS if the site only needs a removal assessment/action
and no NPL assessment work is necessary. For these sites with removal-only interest, the
Removal Site Initiation Date on the Add Site Information screen needs to be entered for
these sites to be considered part of the SEMS active site inventory.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new activities and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate. Data
entry timeliness practices are important to obtain all accomplishments. See section V.A.5
above for details.
b. Referred From RCRA
Activity Definition:
A site is Referred from RCRA when both RCRA and Superfund programs agree that the
site may require additional investigation or cleanup under the Superfund program. Sites
are considered for referral to Superfund from RCRA under a number of scenarios,
including:
• sites with facilities that ceased treating, storing, or disposing of hazardous waste
prior to November 19, 1980 (the effective date of Phase I of the Subtitle C
regulations) and to which the RCRA corrective action or other authorities of
Subtitle C cannot be applied.
• sites at which only materials exempted from the statutory or regulatory definition
of solid waste or hazardous waste are managed
• contamination areas resulting from the activities of RCRA hazardous waste
handlers to which RCRA subtitle C corrective action authorities do not apply,
such as hazardous waste generators or transporters, which are not required to have
Interim Status or a final RCRA permit; and
• sites having a low priority or questionable enforcement under RCRA, such as
non-filers or converters.
• facilities whose owners have demonstrated an inability to finance corrective
action are referred to Superfund from RCRA.
Appropriate documentation must exist and be signed by both programs that in fact RCRA
has turned the site over to Superfund, and Superfund has accepted the site. All sites
referred to Superfund from RCRA must have a Referred from RCRA activity and actual
completion date documented in SEMS.
September 30, 2014 V-14 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Accomplishment Definition:
A site referred from RCRA is considered complete the date the region received the
paperwork that documents the decision that the site warrants Superfund NPL assessment
and/or potential cleanup attention. Valid performing leads for Referred from RCRA
activities include: Fund-Financed (F) and EPA-In House (EP). A qualifier of "Financial"
should be added for all Referred from RCRA activities where the site is referred to
Superfund due to a failed financial assurance.
Special Planning/Reporting Requirements:
If the referred site does not already exist in SEMS, the site should be added to SEMS
using the same EPA Identification number used by the site in RCRAInfo. Data entry
timeliness practices are important to obtain all accomplishments. See section V.A.5
above for details.
c. Remedial Site Initiation (Discovery)
Activity Definition:
Remedial Site Initiation (Discovery) is the process by which a potential hazardous waste
site is entered into the SEMS remedial assessment active site inventory for NPL
assessment activities. All sites moving through the NPL assessment process must have a
Remedial Site Assessment Initiation milestone and actual completion date documented in
SEMS. Entry of the Remedial Site Assessment Initiation date initiates the NPL
assessment process and places the site on the Preliminary Assessment backlog.
Accomplishment Definition:
Remedial Site Initiation (Discovery) of non-federal facilities is the date the region
completes a pre-CERCLA screening report indicating the site warrants Superfund NPL
assessment and potential cleanup attention. The Remedial Site Initiation (Discovery) date
for federal facilities is the date the site is formally added to the Federal Facilities
Hazardous Waste Compliance Docket indicating Superfund involvement is required.
Special Planning/Reporting Requirements:
Planned start/complete dates will automatically be generated in Primavera when a new
site is added to SEMS. The same calendar date should be entered for both the Remedial
Site Initiation (Discovery) actual start and actual complete date. The actual start/complete
date must not be earlier than the pre-CERCLA screening complete date. Multiple
Remedial Site Initiation (Discovery) activities are not allowed.
Note: The Removal Site Initiation activity is used by the removal program to track
initiation of sites that have Superfund removal interest. Sites with only removal interest
should not have a Remedial Site Initiation (Discovery) activity tracked in SEMS. Sites
with only remedial assessment interest should not have a Removal Site Initiation activity
tracked in SEMS. Sites with both removal and remedial assessment interest should have
both a Removal Site Initiation activity and a Remedial Site Initiation (Discovery)
activity. The Remedial Site Initiation (Discovery) actual start/complete date for a site
referred from removal to remedial assessment or from RCRA to remedial assessment
should be the date the referral decision is made.
FY 15 SPIM V-15 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new activities and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate.
Data entry timeliness practices are important to obtain all accomplishments. See section
V.A.5 above for details.
d. Preliminary Assessments (PA) at Non-Federal Sites
Activity Definition:
A PA is often the first phase of the NPL assessment process following remedial site
initiation (discovery). The PA is used to determine what steps, if any, need to occur next
at the site. Federal, state, and local government files, geological and hydrological data,
and data concerning site practices are reviewed to complete the PA report. An on- or off-
site reconnaissance also may be conducted, although it is not required. Samples are not
generally collected during a PA; however, limited sampling may be performed as
necessary to determine whether further assessment (e.g., site inspection) is needed.
Regions also have been encouraged to further reduce repetitive site characterization tasks
and costs by combining site assessment and removal evaluation activities where
warranted by site conditions. An integrated removal assessment and remedial preliminary
assessment combines requirements of a both types of assessments into a single report.
There are instances when an Abbreviated Preliminary Assessment (APA) can be
performed in lieu of a standard PA. An APA is preferred when: 1) available information
indicates the site would not pass the pre-CERCLA screening step if it was not already in
the SEMS site inventory; and 2) available information indicates a SI or ESI is warranted.
The October, 1999 Abbreviated Preliminary Assessment fact sheet (OSWER 9375.2-
09FS) provides information on conducting APAs and includes a checklist to help site
assessors determine whether an APA report is appropriate for a given site. The checklist
or an equivalent document can serve as documentation that the APA was completed. The
APA checklist or equivalent report must address the requirements set forth in the
National Contingency Plan (NCP) for conducting remedial preliminary assessments.
Combining PA and SI or ESI activities into a single event may be performed at sites
where it is known that more intensive sample collection as warranted and where time and
cost efficiencies can clearly be gained. When combining remedial assessments, the PA
documentation must still be developed to meet NCP requirements. An APA report is
sufficient for this purpose. When combining PA and SI or ESI assessments, the same
actual start and complete dates for the PA and SI or ESI activity should be entered into
SEMS. The PA should be assigned a high priority qualifier in SEMS. The decision
reached at the end of the combined PA and SI/ESI assessment should be entered as the
qualifier for the SI or ESI activity. When applicable, a critical indicator of Abbreviated
PA should be assigned to the PA activity in SEMS.
Accomplishment Definition:
PA Starts - A PA is started when the region begins collecting data and performing other
tasks related to development of the PA report; or when the region signs a letter, form,
September 30, 2014 V-16 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
memo, or issues a Technical Direction Document (TDD) to the EPA contractor or
state/tribal government (where applicable), requesting performance of a PA at a specific
site or group of sites; or when EPA receives written confirmation from a state/tribal
government that the state/tribal government will conduct the PA; and SEMS contains the
actual PA start date and a performing lead of: Fund-Financed; EPA-In House; State; or
Tribal. PA start dates are required and are used by HQ as a program measure.
PA Completions - A Preliminary Assessment is completed when:
• A PA Report has been developed by EPA; or received by the region from the
federal contractor or state/tribal government; and the appropriate regional official
signs a letter, form, or memo approving the PA report. The PA actual completion
date is the date the PA report is approved; and
• SEMS contains the actual PA completion date and a decision on whether further
activities are necessary in the Qualifier field; and
• The decision is documented by completing the Site Decision Form 9100-3 in
SEMS or an equivalent document.
A valid decision must be recorded in SEMS upon completion of the PA. Please refer to
exhibit V.3 for a list of valid qualifiers for this action and a description of each qualifier.
Special Planning/Reporting Requirements:
For planning purposes, regions should complete a PA at a non-federal site listed in SEMS
within one year of the remedial site initiation (discovery) completion date. The SEMS
project management software will automatically create a planned PA completion date one
year from the planned or actual remedial site initiation (discovery) completion date.
Integrated removal assessment and remedial preliminary assessment reports are tracked
in SEMS by entering a PA activity and selecting INTEGRATED RV/RMDL as a critical
indicator on the PA Work Package Info tab of the Edit Schedule screen in the SEMS Site
Management module. APA reports are tracked in SEMS by entering a PA activity and
selecting APA as a critical indicator on the PA Work Package Info tab of the Edit
Schedule screen in the SEMS Site Management module.
PA starts and completions are reported site-specifically in SEMS. Preliminary
Assessment completions at non-federal facility sites is a program measure. Regions are
responsible for maintaining the accuracy of the non-NPL status for every non-NPL site in
the SEMS inventory. As new actions and new dates are entered into SEMS, the system
will ask the user to confirm or change this value as appropriate. Data entry timeliness
practices are important to obtain all accomplishments. See section V.A.5 above for
details.
Please refer to chapter VIII, titled Federal Facility Program, of the SPEVI for a description
of this activity as performed at federal facilities.
FY 15 SPIM V-17 September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
e. Site Inspections (SI) at Non-Federal Sites
Activity Definition:
The SI involves the collection of field data from a suspected hazardous waste site to
confirm or deny the presence of contamination and to further characterize contaminants,
migration pathways, and background contaminant levels. The SI serves as a further
screening activity to determine what steps, if any, need to occur next at the site. Regions
should employ Field Analytical Sampling (FAS) techniques wherever practical during
conduct of SI activities.
Regions also have been encouraged to further reduce repetitive site characterization tasks
and costs by combining site assessment and removal evaluation activities where
warranted by site conditions. An integrated removal assessment and remedial site
inspection combines requirements of a both types of assessments into a single report.
See the PA section above for a discussion on combining PA and SI activities into a single
event.
Accomplishment Definition:
,57 Starts - A SI start date at a non-federal facility site is defined as the date when EPA or
the state/tribal government signs a letter, memo or form approving the site-specific SI
work plan, or a TDD is issued to the contractor at a site (refer to OSWER Publication
#9345.1-03FS for further guidance on defining SI starts) and SEMS contains the actual SI
start date and a performing lead of: EPA; EPA-In House; State; or Tribal. SI start dates
are required.
,57 Completions - A SI is completed when:
• A SI Report has been generated by EPA, or received by the region from the
federal contractor or state/tribal government, and the appropriate regional official
signs a letter, form, or memo approving the SI report. The SI actual completion
date is the date the SI report is approved; and
• SEMS contains the actual SI completion date, a valid performing lead, and a
decision on whether further activities are necessary in the Qualifier field; and
• The decision is documented by completing the Site Decision Form 9100-3 in
SEMS or an equivalent document.
A valid decision must be recorded in SEMS upon completion of the SI. Please refer to
exhibit V.3 for a list of valid qualifiers for this action and a description of each qualifier.
Special Planning/Reporting Requirements:
For planning purposes, regions Sis at non-federal sites are expected to average two years
from start to completion. The SEMS project management software will automatically
create a planned SI completion date two years from the planned or actual PA completion
date.
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Actual start and complete dates are required for Sis. SI starts and completions are
reported site-specifically in SEMS. Site Inspection completions at a non-federal sites is a
program measure.
Integrated removal assessment and remedial site inspection reports are tracked in SEMS
by entering a SI action and selecting INTEGRATED RV/RMDL as a critical indicator on
the SI Work Package Info tab of the Edit Schedule screen in the SEMS Site Management
module.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new actions and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate. Data
entry timeliness practices are important to obtain all accomplishments. See section V.A.5
above for details.
Please refer to chapter VIII, titled Federal Facility Program, of the SPEVI for a description
of this activity as performed at federal facilities.
f. Site Reassessments at Non-Federal Sites
Activity Definition:
A Site Reassessment represents the gathering and evaluation of new information on a site
previously assessed under the federal Superfund Program to determine whether further
Superfund attention is needed. A Site Reassessment serves as a supplement to previous
assessment work and not as a replacement for traditional assessment activities (e.g.,
Preliminary Assessment, Site Inspection). The scope of work for a Site Reassessment
activity is flexible, but will usually represent a component of a traditional site assessment
activity. The intent of the Site Reassessment action is to document the expenditure of
Superfund resources on older sites where EPA has received new information or learned
that site conditions have changed. This activity is also used to record further assessment
decisions made after reviewing this new site information. A brief summary of work
performed as part of the Site Reassessment action and the related site decision as a result
of this work must be documented by completing the Site Decision Form 9100-3 in
SEMS, or an equivalent document. Correction of site disposition decisions (i.e., action
qualifiers) based solely on file reviews should be documented using the historical lockout
feature in SEMS and not as a new Site Reassessment activity.
Accomplishment Definition:
Site Reassessment Starts - A Site Reassessment start is defined as the date when EPA or
state/tribal government signs a letter, memo or form approving the site-specific Site
Reassessment work plan or a TDD is issued to the contractor at a site and SEMS contains
the actual Site Reassessment start date and a performing lead of: EPA, EPA-In House;
State; or Tribal.
Site Reassessments Completions - A Site Reassessment is complete when:
• A Site Reassessment report has been developed by EPA, or received by the region
from the federal contractor, or the state/tribal government, and the appropriate
regional official signs a letter, form, or memo approving the Site Reassessment
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report. The Site Reassessment actual completion date is the date the Site
Reassessment report is approved, and
• SEMS contains the actual Site Reassessment completion date, a valid performing
lead, and a valid decision on whether further activities are necessary in the
Qualifier field; and
• The decision is documented by completing the Site Decision Form 9100-3 in
SEMS or an equivalent document.
A valid decision must be recorded in SEMS upon completion of the Site Reassessment.
Please refer to exhibit V.3 for a list of valid qualifiers for this action and a description of
each qualifier.
Special Planning/Reporting Requirements:
For planning purposes, Site Reassessments at non-federal sites are expected to average
one year from start to completion. Actual start and complete dates are required for Site
Reassessment activities. Site Reassessments are reported site-specifically in SEMS. Site
Reassessment completions are program measures for non-federal facilities.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new actions and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate. Data
entry timeliness practices are important to obtain all accomplishments. See section V.A.5
above for details.
Please refer to chapter VIII, titled Federal Facility Program, of the SPEVI for a description
of this activity as performed at federal facilities.
g. Expanded Site Inspections (ESI) at Non-Federal Sites
Activity Definition:
The ESI collects additional data beyond that collected in the SI to evaluate the site for
HRS scoring. ESIs are reserved for more complex sites that cannot be adequately
characterized using standard SI methodologies. Installation of groundwater monitoring
wells is typical of activities performed under the ESI. Regions should employ Field
Analytical Sampling (FAS) techniques wherever practical during ESI activities.
Regions also have been encouraged to further reduce repetitive site characterization tasks
and costs by combining site assessment and removal evaluation activities where
warranted by site conditions. An integrated removal assessment and ESI combines
requirements of a both types of assessments into a single report.
See the PA section above for a discussion on combining PA and ESI activities into a
single event.
Accomplishment Definition:
ESI Starts - An ESI start is defined as the date when EPA or state/tribal government signs
a letter, memo or form approving the site specific ESI work plan or a Technical Direction
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Document is issued to the contractor at a site and SEMS contains the actual ESI start date
and a performing activity lead of: EPA; EPA-In House; State; or Tribal.
ESI Completions - An ESI is complete when:
• An ESI Report has been developed by EPA; or received by the region from the
federal contractor; or the state/tribal government; and the appropriate regional
official signs a letter, form, or memo approving the ESI report. The ESI actual
completion date is the date the ESI report is approved; and
• SEMS contains the actual ESI completion date, a valid performing lead, and a
valid decision on whether further activities are necessary in the Qualifier field;
and
• The decision is documented by completing the Site Decision Form 9100-3 in
SEMS or an equivalent document.
A valid decision must be recorded in SEMS upon completion of the ESI. Please refer to
exhibit V.3 for a list of valid qualifiers for this action and a description of each qualifier.
Special Planning/Reporting Requirements:
For planning purposes, ESIs at non-federal sites are expected to average one year from
start to completion. Actual start and completion dates are required for ESIs. ESI starts
(Actual Start) and completions are reported site-specifically in SEMS. ESI starts and
completions are program measures for non-federal facilities.
Integrated removal assessment and expanded site inspection reports are tracked in SEMS
by entering an ESI action and selecting INTEGRATED RV/RMDL as a critical indicator
on the ESI Work Package Info tab of the Edit Schedule screen in the SEMS Site
Management module.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new actions and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate. Data
entry timeliness practices are important to obtain all accomplishments. See section V.A.5
above for details.
Please refer to chapter VIII, titled Federal Facility Program, of the SPEVI for a description
of this activity as performed at federal facilities.
h. Integrated ESI/Remedial Investigations (ESI/RI) at Non-Federal Sites
Activity Definition:
The integrated ESI/RI is an assessment consisting of an ESI and a RI. The ESI/RI is used
to expedite remedial response by gathering site characterization data common to both ESI
and RI activities in one step, thereby expediting the later collection of data when
comprehensive RI activities are performed. The goal of ESI/RIs is to save time and costs
characterizing sites when compared to the traditional, sequential ESI-NPL Listing-RI
process. ESI/RIs facilitate but do not replace RIs, and are recommended at sites where
conditions indicate that the HRS score will be above 28.5 and a remedial response will be
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needed. The RI portion of an ESI/RI is intended to be a site-wide activity. ESI/RIs
activities should be entered into SEMS at operable unit 00.
ESI/RIs may not always be feasible given known site conditions and activities completed
to date. In some cases, it may be more prudent to conduct a separate ESI and RI. The
definitions for Remedial Investigation/Feasibility Study (RI/FS) Completion and RI
Completion (see definitions in chapter VII) are different from the definition for ESI/RI
Completion. The definition of an ESI/RI Completion is the same as that of an ESI
Completion. If an ESI/RI activity is recorded in SEMS, a stand-alone ESI activity should
not be recorded at that site.
Regions also have been encouraged to further reduce repetitive site characterization tasks
and costs by combining site assessment and removal evaluation activities where
warranted by site conditions. An integrated removal assessment and integrated ESI/RI
combines requirements of a both types of assessments into a single report.
Accomplishment Definition:
ESI/RI Starts - ESI/RI start date is defined as the date when EPA approves the site-
specific ESI/RI work plan and SEMS contains the actual ESI/RI start date and a
performance lead of: EPA; EPA-In House; State; or Tribal.
ESI/RI Completions - An ESI/RI is complete when:
• An ESI/RI Report has been reviewed and accepted by the region and the
appropriate regional official signs a letter, form, or memo approving the ESI/RI
report. The ESI/RI actual completion date is the date the ESI/RI report is
approved; and
• The following has been recorded in SEMS: the actual ESI/RI completion date; a
valid performance lead; and a decision on whether further activities are necessary
in the Qualifier field; and
• The decision is documented by completing the Site Decision Form 9100-3 in
SEMS or an equivalent document.
A valid decision must be recorded in SEMS upon completion of the ESI/RI. Please refer
to exhibit V.3 for a list of valid qualifiers for this action and a description of each
qualifier.
Special Planning/Reporting Requirements:
For planning purposes, ESI/RIs are expected to average one year from start to
completion. Actual start and completion dates are required for ESI/RIs. ESI activities
should not be recorded separately in SEMS if they are conducted as part of an ESI/RI.
ESI/RI completions at non-federal facility sites are program measures.
An integrated removal assessment and ESI/RI report is tracked in SEMS by entering an
ESI/RI action and selecting INTEGRATED RV/RMDL as a critical indicator on the
ESI/RI Work Package Info tab of the Edit Schedule screen in the SEMS Site
Management module.
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Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new actions and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate. Data
entry timeliness practices are important to obtain all accomplishments. See section V.A.5
above for details.
i. Hazard Ranking System Packages (HRS)
Activity Definition:
The HRS Package documents a numeric score of the relative severity of a hazardous
substance release or potential release based on: 1) the relative potential of substances to
cause hazardous situations; 2) the likelihood and rate at which the substances may affect
human and environmental receptors; and 3) the severity and magnitude of potential
effects. The HRS Package also includes references and documentation in support of the
score. The score is computed using the revised HRS. Regions are responsible for
preparing HRS packages for both federal and non-federal facility sites. Regions submit a
draft version of the HRS package to HQ for quality assurance review. Regions and HQ
work together to address issues and agree on a final version of the HRS package. Based
on results of the completed HRS package and other factors, regions determine what next
steps, if any, are appropriate for a site (e.g., NPL listing, NFRAP, etc.)
Regions also have been encouraged to further reduce repetitive site characterization tasks
and costs by combining site assessment and removal evaluation activities where
warranted by site conditions. An integrated removal assessment and HRS Package
combines requirements of both types of assessments into a single report.
Accomplishment Definition:
HRS Package Starts - An HRS Package start is defined as the date when EPA signs a
memo, form, or letter requesting development of a HRS Package for a specific site and
SEMS contains the actual HRS Package start date and a valid performance lead of: EPA-
In House; State; or Tribal. HRS Package start and complete dates are required for both
federal and non-federal facility sites, and are used to identify the status of sites in the site
assessment pipeline and to measure activity durations.
Due to the pre-decisional nature of HRS packages, regions may postpone entry of HRS
start dates until after the HRS package has gone through HQ quality assurance review or
after the site has been proposed to the NPL.
HRS Package Completions - An HRS Package is complete when:
• An HRS Package has completed HQ quality assurance review and HQ and the
region agree to a final version, or an HRS package has completed regional quality
control review and the HRS package will not be submitted to HQ for quality
assurance review; and
• The following has been recorded in SEMS: the approval date for the final version
of the HQ quality assurance (QA) reviewed (if submitted to HQ) or regional
quality control (QC) reviewed (if not submitted to HQ) HRS Package date or the
NPL Proposal publication date as the actual HRS Package completion date, a
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performance lead, and a decision on whether further activities are necessary in the
Qualifier field; and
• The decision is documented by completing the Site Decision Form 9100-3 in
SEMS or an equivalent document.
• Note: Submission of HRS Packages to HQ for technical assistance does not
represent an HRS Package completion.
A valid decision must be recorded in SEMS upon completion of the HRS Package. Please
refer to exhibit V.3 for a list of valid qualifiers for this action and a description of each
qualifier.
Special Planning/Reporting Requirements:
For planning purposes, HRS packages are expected to average one year from start to
completion.
A full HRS package is required for sites being addressed through the SA Approach;
however, the HRS package does not have to go through the EPA Headquarters quality
assurance process.
Actual start and completion dates are required for HRS Packages. HRS Package
completions at both federal and non-federal facilities are program measures.
Integrated removal assessment and HRS Package reports are tracked in SEMS by
entering an HRS Package action and selecting INTEGRATED RV/RMDL as a critical
indicator on the HRS Package Work Package Info tab of the Edit Schedule screen in the
SEMS Site Management module.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new actions and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate. Data
entry timeliness practices are important to obtain all accomplishments. See section V.A.5
above for details.
j. Other Cleanup Activity (OCA)
Activity Definition:
This activity is used to document the referral of a non-NPL site to a state, tribal, or
federal environmental cleanup program for remedial-type work without EPA
enforcement or oversight. Remedial-type work can include comprehensive site
investigations in support of making cleanup determinations, interim cleanup actions,
removals or final cleanup decisions, including decisions that cleanup is not required. For
this definition, "without EPA enforcement or oversight" means that there is no
continuous and substantive involvement on the part of EPA while remedial-type work is
ongoing, such as routinely reviewing work products and other documents and providing
comments to the non-EPA party. However, EPA may gather information about activities
at an OCA site through meetings or calls with the non-EPA party, by accessing related
web sites, or through other means.
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OCA status should only be used for sites that have completed the Superfund site
assessment process and are considered to be NPL-caliber (i.e., existing information
indicates that the site may achieve an HRS score > 28.5 and the site warrants remedial-
type work as described above).
Regions should periodically discuss progress of OCA sites with the other party leading or
managing the remedial-type work to ensure adequate progress is being made. OCA sites
not making adequate progress should be evaluated to determine whether another cleanup
approach is warranted.
Accomplishment Definition:
OCA Starts - An Other Cleanup Activity start date is defined as the date EPA refers the
site to the state, tribal, or federal environmental cleanup program for further consideration
or acknowledges that the site is being cleaned up by a non-EPA party as supported by
existing documentation. Preferred minimum documentation required to proceed with an
OCA start is written confirmation from the other party that it agrees to take the lead and
provide cleanup status updates to EPA on an annual basis or other acceptable timeframe.
This minimum documentation requirement may be relaxed in cases where it is clear
based on other information that cleanup work is progressing adequately. An example of
other information would be a web page managed by the other party that provides periodic
site cleanup progress updates to the public.
OCA Completions - An Other Cleanup Activity completion date is defined as either: 1)
the date EPA obtains or receives documentation from the non-EPA party that the site has
been addressed in accordance with all applicable standards (i.e., determination that
cleanup was successfully completed or that cleanup was not necessary); 2) the date EPA
determines remedial-type work will not be completed by the non-EPA party (e.g., site
referred back to EPA or otherwise returned to EPA for evaluation of other cleanup
approaches); or 3) the date EPA determines, based on documentation from the non-EPA
party, that sufficient progress related to needed remedial-type work is being made such
that the site should be archived from the SEMS active site inventory since the site is not
considered a likely NPL candidate. The date the documentation is received or
determination is made is entered into SEMS as the actual completion date of the OCA.
The minimum documentation required to record a determination that cleanup was
successfully completed is a close-out report or equivalent document submitted by the
non-EPA party indicating no further remedial cleanup is needed. An actual completion
date for the OCA activity and a NFRAP qualifier should be entered into SEMS, and the
site can be archived if no further Superfund interest exists. In cases where EPA, states,
tribes, municipal governments or other federal agencies decide to perform a site
reassessment or other remedial site assessment to confirm no further Superfund interest is
warranted, an actual completion date should be added to the OCA activity in SEMS with
a lower or higher priority qualifier and the appropriate site reassessment or other remedial
assessment activity should be added to the site schedule in SEMS.
Minimum documentation required to record a determination that remedial-type work will
not be completed by the non-EPA party is a signed document from the non-EPA party
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stating work will not be completed. In cases where a signed document is not available
from the other party, EPA shall, at a minimum, submit a signed document to the non-
EPA party stating EPA is resuming an active role in pursuing additional remedial
assessment and/or an alternative cleanup approach. An actual completion date for the
OCA activity can be entered into SEMS with a lower or higher priority or other further
assessment-type qualifier.
Minimum documentation required to record a determination that sufficient progress has
been made such that the site is no longer considered a likely NPL candidate is a progress
report or equivalent document submitted by the non-EPA party providing sufficient
information for the region to make a NFRAP determination. An actual completion date
for the OCA activity and a NFRAP qualifier should be entered into SEMS, and the site
can be archived if no further Superfund interest exists.
In SEMS, the OCA decision is documented by completing the Site Decision Form 9100-3
in SEMS, or an equivalent document.
Valid decisions to be recorded in SEMS upon completion of the OCA include:
For sites that require further remedial site assessment:
• (H) - High - Higher priority for further assessment; or
• (L) - Low - Lower priority for further assessment; or
• (F) - Referred to the removal program with further remedial assessment needed.
For sites that do not require further remedial site assessment:
• (N) - No further remedial action planned; or
• (D) - Deferred to RCRA (Subtitle C); or
• (DN) - Deferred to NRC; or
• (A) - Site is being addressed as part of an NPL site. A site having an event
qualifier of Collapsed should have an NPL Status indicator (Site NPL Status) of A
and a valid value in the Site Parent ID field; or
• (B) - Addressed as part of another non-NPL site; or
• (W) - Referred to the removal program with no further remedial assessment
needed.
Special Planning/Reporting Requirements:
Recording Final Assessment Decisions at Other Cleanup Activity Sites: Regions should
assign a Final Assessment Decision to those OCA sites where no further site assessment
work is anticipated beyond reviewing cleanup progress/closeout reports and related
information. If new information is received or conditions change such that further site
assessment is warranted (e.g., site reassessment), regions should delete the Final
Assessment Decision.
A No Further Federal Action (NFFA) should not be assigned to sites with on ongoing
OCA activity.
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OCA activity start and completion dates are used to generate the following OCA status
values displayed on EPA's public web site for Superfund:
• Referred to state for Remedial Study/Cleanup - (value calculated when OCA start
date exists and no actual completion date exists); and
• State Remedial Study/Cleanup Completed - (value calculated when OCA start and
completion dates both exist).
For existing OCA actions that do not meet the current SPEVI definition, an Action
Anomaly Code shall be recorded at the OCA action as follows:
• Other Start Anomaly (OS) - use if only an actual start date has been recorded; or
• Other Start and Completion Anomaly (OA) - use if both a start and completion
date have been recorded.
The following six steps can be entered under the Other Cleanup Activity to generically
capture the different cleanup phases a site may be undergoing:
1. Comprehensive Site Investigation;
2. Remedy Selection;
3. Design;
4. Construction;
5. Post-Construction Maintenance; and
6. Short Term Cleanup.
Step start and complete dates and lead codes are available for documenting the start and
completion of the different cleanup phases being conducted at non-NPL sites by non-
EPA parties.
The following qualifiers are available for these activities:
• (H) - High - Higher priority;
• (L) - Low - Lower priority; and
• (Blank) - No qualifier specified.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. Data entry timeliness practices are important to
obtain all accomplishments. See section V.A.5 above for details.
k. Formal State Deferral
Activity Definition:
State Deferral is an administrative mechanism enabling states and tribes, under their own
laws, to respond at sites in the SEMS inventory that EPA would otherwise not soon
address. Under the State Deferral program, EPA anticipates that responses may be quick
and efficient, yet still be protective of the environment and of communities' rights to
participate in the decision-making process. Refer to the guidance on Deferral of NPL
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Listing Determinations While States Oversee Response Actions (OSWER Directive
9375.6-11, May 1995) for additional information on this program.
Accomplishment Definition:
State Deferral Starts - The state deferral process start is defined as the date when the
regional Superfund program director and the state program director sign a document
deferring the site to the state under the terms established in the deferral guidance. A State
Deferral action must be recorded in SEMS with a lead of State Deferral. State deferrals
are applicable only to non-federal facility sites that are not on the NPL.
State Deferral Completions. The state deferral completion date is defined as either: 1) the
signature date of a formal regional document confirming that the deferral has been
completed successfully, or terminating the deferral agreement; or 2) 90 days after the date
EPA receives state certification that the deferral has been completed. The outcome
(Qualifier) of the state deferral must be entered with the completion date.
Valid decisions (Qualifiers) must be recorded in SEMS upon completion of the state
deferral. Please refer to exhibit V.3 for a list of valid qualifiers for this activity and a
description of each qualifier.
Special Planning/Reporting Requirements:
Six steps can be entered for the State Deferral activity to genetically capture the different
cleanup phases a site may be undergoing. These steps include:
1. Comprehensive Site Investigation;
2. Remedy Selection;
3. Design;
4. Construction;
5. Post-Construction Maintenance; and
6. Short Term Cleanup
Start and completion dates and lead codes are available for documenting the start and
completion of the different cleanup phases being conducted at non-NPL sites by non-
EPA parties.
Actual start and completion dates are required. Sites successfully completing the deferral
process are eligible for archiving (removal) from the SEMS inventory. State deferral
starts and completions are program measures.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new actions and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate. Data
entry timeliness practices are important to obtain all accomplishments. See section V.A.5
above for details.
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1. NPL Listing Activities
Activity Definition:
The NPL is a list of national priorities among the known or threatened releases of
hazardous substances, pollutants, or contaminants throughout the United States and trust
territories.
There are three mechanisms for placing sites on the NPL for possible remedial action:
• A site may be included on the NPL if it scores sufficiently high on the HRS. The
HRS serves as a screening device to evaluate the relative threat that uncontrolled
hazardous substances pose to human health or the environment. As a matter of
Agency policy, those sites that score 28.5 or greater on the HRS are eligible for
the NPL.
• Each state may designate a single site as its top priority to be listed on the NPL,
regardless of the HRS score.
• Certain sites may be listed regardless of their HRS score, if all of the following
conditions are met:
The Agency for Toxic Substances and Disease Registry (ATSDR) of the U.S.
Public Health Service has issued a health advisory that recommends
dissociation of individuals from the release; and
EPA determines that the release poses a significant threat to public health; and
EPA anticipates that it will be more cost-effective to use its remedial authority
than to use its removal authority to respond to the release.
Accomplishment Definition:
Proposed NPL Listing - The process of proposing a site for placement on the NPL is
complete when a Proposed Rule proposing the site to the NPL is published in the Federal
Register (FR).
Removal of Proposed NPL Listing - The process of removing a site from proposal to the
NPL begins and simultaneously ends when a notice announcing the removal of the site
from NPL proposal is published in the Federal Register (typically published in a
regularly scheduled NPL proposed rule)
Final NPL Listing - The listing process for a site is complete when a Final Rule adding
the site to the NPL is published in the Federal Register.
Withdrawn from the Final NPL - The process of withdrawing a site is complete when a
Final Rule withdrawing the site is published in the Federal Register.
Special Planning/Reporting Requirements:
HQ will update the following SEMS data when Proposed and/or Final NPL rules are
published in the Federal Register:
• SEMS Site Name;
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• Federal Register Site Name (for historical record keeping purposes should the
SEMS site name change);
• NPL listing activities (Proposed NPL Listing in FR, Removed from Proposed
NPL Listing in FR, Final NPL Listing in FR, and Withdrawal of Final NPL
Listing in FR;
• NPL listing activity actual completion date and performance lead of EPA In-
House;
• The NPL Status of Proposed for NPL (P), Removed from proposed NPL (R),
Currently on Final NPL (F), and Withdrawn from NPL (W);
• Federal Docket Management System (FDMS) number, if not already assigned;
• The FAD Date will be added to the site and any associated child sites using the
date of NPL proposal (this automatically checks the FAD box);
• The Eligible Response Site (ERS) Exclusion will be unchecked at the site and any
associated child sites (when proposed);
• The Non-NPL Status and date fields will be deleted (when proposed);
• The Federal Register date, volume, and page;
• The federal facility status; and
• Location data updates include latitude/longitude, street address, city, county and
zip code.
V.A.9 Cleanup Alternatives
The Superfund remedial process begins once sites are brought to the attention of the
Superfund remedial site assessment program. As the EPA uses all available tools to ensure the
protection of human health and the environment, various avenues for site cleanup are evaluated
during remedial site assessment to determine which is the most appropriate to meet site cleanup
needs.
In addition to determining whether placing a site on the National Priorities List is the
most efficient option to achieve site cleanup, the EPA evaluates a number of other options for
addressing site issues. Below are descriptions of each of these site cleanup options.
a. Referral to EPA Removal
Removal actions are quick responses to immediate threats from hazardous substances in
order to eliminate dangers to the public. Typical situations requiring removal actions
include chemical fires or explosions, threats to people from exposure to hazardous
substances, or contamination of drinking water supplies. Types of removal actions
include removing and disposing of hazardous substances, constructing a fence or taking
security precautions to limit human access to a site, providing a temporary alternative
water supply to local residents when drinking water is contaminated, and temporarily
relocating area residents if necessary.
Upon completion of a remedial assessment activity, the region may determine that a time-
critical, non-time critical (NTC), or other activity from the EPA removal program is
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warranted. In SEMS, there are two different activity qualifiers and corresponding Non-
NPL Status values used to track the referral of a site to the removal program. The values
to be used depend upon whether or not the region believes additional remedial
assessment will still be needed following completion of work by the removal program.
The two activity qualifiers and their corresponding non-NPL Status values are self-
explanatory and include:
1. Referred to Removal, Needs Further Remedial Assessment (action qualifier)
Referred to Removal-Further Assessment Needed (non-NPL status)
2. Referred to Removal, No Further Remedial Assessment (action qualifier)
Referred to Removal - NFRAP (non-NPL status)
Regions should monitor those sites referred to removal that need further remedial
assessment to ensure additional remedial assessment is not overlooked once removal
work is complete.
b. Deferral to RCRA
Upon completion of remedial assessment activity, the region may determine that the site
is excluded from Superfund consideration under policy, regulatory, or legislative
restrictions and defer it to the RCRA program. It is the EPA's policy to defer placing
sites on the NPL that can be comparably addressed under the Resource Conservation and
Recovery Act (RCRA) Subtitle C corrective action authorities; however, there are certain
exceptions to this policy (e.g., uncooperative or bankrupt responsible party). Additional
information regarding EPA's RCRA deferral policy is available at
http://www.epa.gov/superfund/sites/npl/p880624.htm. RCRA sites not subject to Subtitle
C can continue to be considered for NPL listing.
c. Deferral to Nuclear Regulatory Commission (NRC)
Upon completion of remedial assessment activity, the region may determine that the site
is excluded from Superfund consideration under policy, regulatory, or legislative
restrictions and defer it to the NRC cleanup program. It is EPA's policy not to list
releases of source, by-product, or special nuclear material from any facility with a current
license issued by the NRC because the NRC has full authority to require cleanup of
releases from such facilities. If a facility is licensed by the NRC, but the NRC does not
have authority to require cleanup, the site will not be deferred from NPL listing.
d. Other Cleanup Activity (OCA)
Sites that are not on EPA's National Priorities List that have completed the Superfund
remedial assessment process and are considered to be NPL-caliber (i.e., existing
information indicates that the site may achieve an HRS score > 28.5 and determined to
need remedial-type cleanup attention may be addressed under a State, Tribal, Municipal,
or other federal agency environmental cleanup program. EPA refers to these sites as OCA
sites. Remedial-type work can include comprehensive site investigations in support of
making cleanup determinations, interim cleanup actions, removals or final cleanup
decisions, including decisions that cleanup is not required. At these sites, there is no
continuous and substantive involvement on the part of EPA's site assessment program
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while remedial-type work is ongoing, such as routinely reviewing work products and
other documents and providing comments.
EPA performs a monitoring role at OCA sites by annually checking in with State, Tribal,
Municipal and other federal agency partners on the status of cleanup work at these sites.
Should conditions change such that federal Superfund involvement becomes necessary,
EPA will work with these partners to determine an alternative approach for addressing a
site.
EPA's SEMS inventory contains limited information on these sites. EPA posts OCA sites
on its public web site at:
http://www.epa.gov/superfund/programs/npl hrs/othercleanup.htm. The information on
this site includes a summary cleanup status designation for each site. EPA staff will
generally need to forward public inquiries for specific cleanup information at non-federal
OCA sites to state, tribal, municipal or other federal agency partner staff. For federal
facilities, EPA staff can refer requestors to EPA's Federal Facilities Site Evaluation
Project (FFSEP) web site at http://epa.gov/swerffrr/ffsep/ or to the appropriate federal
agency for more information.
The following definitions are provided to assist EPA staff in making consistent OCA
status designations across regions:
Other Cleanup Activity: State-Lead Cleanup
A state agency with environmental responsibilities has requested or agreed to
pursue a non-NPL cleanup under a state government managed cleanup program
such as a state Superfund or other enforcement program, a State Voluntary
Cleanup program, or other program with sufficient oversight ability to ensure
progress is effectively monitored and communicated annually to the EPA.
Other Cleanup Activity: Tribal-Lead Cleanup
A tribal government program with environmental responsibilities has requested or
agreed to pursue a non-NPL cleanup under a tribal government managed cleanup
program with sufficient oversight ability to ensure progress is effectively
monitored and communicated annually to the EPA.
Other Cleanup Activity: Municipal/Other Government-Lead Cleanup
A municipal or other local government program with environmental
responsibilities has requested or agreed to pursue a non-NPL cleanup under a
municipal or other local government managed cleanup program with sufficient
oversight ability to ensure progress is effectively monitored and communicated
annually to the EPA.
Other Cleanup Activity: Federal Facility-Lead Cleanup
A non-EPA federal agency with environmental responsibilities has requested or
agreed to pursue a non-NPL cleanup under their own federally mandated cleanup
program with sufficient oversight ability to ensure progress is effectively
monitored and communicated annually to the EPA.
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The four types of OCA designations are tracked in the Non-NPL Status column in SEMS.
Sites with these designations must also have an OCA activity added to their project
schedule in SEMS. The schedule activity enables EPA to track the start and finish of
OCA work as well as progress made while OCA work is underway.
The OCA cleanup option does not apply to sites being addressed under RCRA Subtitle C
corrective action. Subtitle C sites should use the RCRA deferral cleanup option.
e. Formal State Deferral
State Deferral is an administrative mechanism enabling states and tribes, under their own
laws, to respond at sites in the SEMS inventory that EPA would otherwise not soon
address. Under the State Deferral program, EPA anticipates that responses may be quick
and efficient, yet still be protective of the environment and of communities' rights to
participate in the decision-making process. Refer to the guidance on Deferral of NPL
Listing Determinations While States Oversee Response Actions (OSWER Directive
9375.6-11, May 1995) for additional information on this program.
f. Superfund Alternative Approach
When a liable Potential Responsible Party (PRP) demonstrates it is viable and
cooperative, EPA regional offices, at their discretion, may enter into a SA Approach
agreement with the PRP to facilitate the cleanup of a site. The SA approach uses the same
investigation and cleanup process and standards that are used for sites listed on the NPL.
The SA approach is generally the Agency's preferred enforcement approach for
CERCLA non-NPL sites that are NPL-caliber, where feasible and appropriate.
Threshold eligibility criteria for using the SA Approach are:
• Site contaminants are significant enough that the site would be eligible for listing
on the NPL (i.e., the site would have a HRS score > 28.5);
• a long-term response (i.e., a remedial action) is anticipated at the site; and
• there is a willing, capable PRP who will negotiate and sign an agreement with
EPA to perform the investigation or cleanup.
EPA determines if the SA approach is appropriate at a particular site. (A PRP may
request that a site be evaluated for the SA approach.) If a site meets criteria 1 and 2
above, EPA and the PRP may choose to negotiate an SA approach agreement. The SA
approach agreement is equivalent to an agreement negotiated at an NPL site.
Potentially responsible parties, or a subset of PRPs, may choose not to negotiate an SA
approach agreement. In that case, the site would proceed to cleanup on a different path.
The following transparency and accountability requirements apply to sites using the SA
approach:
• Prior to starting negotiations for a SA approach agreement, the regions should
bring the site to the NPL-listing panel for discussion regarding site characteristics
(including adequate documentation supporting a HRS score of > 28.5) and
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planned use of the SA approach. This is the same panel that reviews sites that the
regions propose to list on the NPL. Adequate HRS documentation consists of a
full HRS package prepared by the region. The HRS package does not have to go
through the EPA Headquarters quality assurance process.
• The regions should notify the public of its intent to use CERCLA authority at the
site.
• The regions should use SEMS to track the same progress milestones for sites with
SA approach agreements as those that are tracked for PRP-lead sites listed on the
NPL.
• Final SA approach agreements will be reviewed at EPA Headquarters and
catalogued on EPA's SA Approach website so that all interested parties can know
what sites have a SA approach agreement.
• The regions will develop and maintain on the internet the same site-specific fact
sheets that are developed for sites listed on the NPL.
• EPA will report annually on progress at sites using the SA approach.
• EPA will maintain and update the SA approach web pages as a source of public
information on the approach. SA approach web pages include a list of sites with
SA approach agreements, links to their site-specific fact sheets, and links to
related information.
SEMS includes a Special Interest code of 'Site with SA Agreement per Office of
Enforcement and Compliance Assurance (OECA) Policy' to track and report
accomplishments at sites using the SA approach. Regions are responsible for ensuring the
code comports with the list of sites posted on the SA approach website. For historical
reporting purposes, this code should remain in place once properly added to SEMS. The
code should not be deleted regardless of the outcome of the SA approach unless it was
originally added due to a data entry error.
EPA's OECA is responsible for reviewing final SA approach agreements and
maintaining the SA approach website. The SA approach website includes SA approach
guidance and the latest list of sites with SA approach agreements. The website is located
at http://www2.epa.gov/enforcement/superfund-alternative-approach.
g. NPL Listing
The NPL is a list of national priorities among the known or threatened releases of
hazardous substance, pollutants, or contaminants throughout the United States. The list,
which is appendix B of the NCP (40 CFR part 300), was required under Superfund law.
The NPL is required to be revised annually and it is intended primarily to guide EPA in
determining which sites warrant further investigation to assess the nature and extent of
public health and environmental risks associated with a release of hazardous substances,
pollutants or contaminants. Sites with HRS scores of 28.5 or greater are eligible for
placement on the NPL. Only sites on the NPL are eligible for Superfund-financed
remedial actions.
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Once a site is determined to be NPL-caliber and a decision has been made that the federal
Superfund program should manage the site cleanup, regions should apply a strong initial
presumption in favor of listing on the NPL. In 1992, EPA's OERR, now the OSRTI)
issued a directive entitled Guidance on Setting Priorities for NPL Candidate sites (Office
of Solid Waste and Emergency Response (OSWER) Directive 9203.1-06). The 1992
directive provided regions with general factors that should be considered in the risk-based
decision making process for choosing sites to propose for listing pursuant to section
105(a)(8)(B) of CERCLA.
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Superfund Program Implementation Manual
FY15
Chapter VI: Removal Program
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Chapter VI: Removal Program
Table of Contents
VI.A Protect Human Health and the Environment VI-1
VI.A.l Overview of Removal Actions Target and Measures VI-1
VI.A.2 Removal Initiation VI-1
VI.A.3 Action Memorandum VI-2
VI.A.4 Removal Action VI-2
List of Exhibits
Exhibit VI.1. Removal Program Activities VI-1
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CHAPTER VI: REMOVAL PROGRAM
VI. A PROTECT HUMAN HEALTH AND THE ENVIRONMENT
Protection of human health and the environment remains the highest priority for the
Superfund program. The Environmental Protection Agency (EPA) will continue to address the
worst sites first while balancing the need to complete response actions at sites. The Agency will
ensure that available resources are disbursed in a fiscally sound manner. Maximizing Potentially
Responsible Party (PRP) involvement remains a high priority.
VI.A.1 Overview of Removal Actions Target and Measures
The following pages contain, in pipeline order, the definitions of removal program targets
and measures. Exhibit VI. 1 displays the reporting hierarchy of removal activities defined in this
chapter. Data entry timeliness practices are important to obtain all accomplishments (see chapter
IV for details).
EXHIBIT VI. 1. REMOVAL PROGRAM ACTIVITIES
Activity
Action Memo s
Removal Starts
Removal Completions
External Program
Reporting
Annual
Commitment
System (ACS),
Strategic Plan
Internal Program
Reporting
Headquarters (HQ)
HQ
Target
Note: For each activity, the definitions and reporting requirements in this chapter specify applicability with
respect to National Priorities List (NPL) status, activity lead, and actual start and completion dates.
Key to Reporting Hierarchy
ACS = Regional targets are established in Annual Commitment System.
Strategic Plan = National target is publicly reported in Agency fiscal year (FY) 11-FY15 Strategic Plan.
Target = Superfund Comprehensive Accomplishments Plan (SCAP) target and reporting measure.
Measure = SCAP reporting measure, but target not required.
HQ = Tracked by HQ for program management purposes, but not a SCAP target or measure.
Regional = Tracked by regions only, primarily for financial management purposes.
VI.A.2 Removal Initiation
Removal Initiation is the process by which a potential hazardous waste site is entered into
the Superfund Enterprise Management System (SEMS) inventory for removal response
activities. All sites considered removal only sites should have an initiate removal site date
documented in SEMS. Entry of the removal initiation site date begins the removal process and
distinguishes it from the National Priority List (NPL) assessment process. The initiate removal
site date should be entered when a site is entered in SEMS. If the site needs to go through the
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NPL assessment process, then a Site Discovery date is required (see chapter V, titled Remedial
Site Assessment for further information on sites needing assessment work).
VI.A.3 Action Memorandum
An Action Memorandum is developed to document decisions for removal activities at
NPL, non-NPL, and Superfund Alternative sites. Decisions are documented in an approval
memorandum and authority is granted when the action memorandum is signed by the appropriate
regional official. Subsequent Action Memos may be signed during the course of a removal action
to document Ceiling Increases, Scope of Work changes, 12 Month Exemptions, and $2M
Exemptions. Regions will not receive credit for subsequent Action Memos.
Work Package
Activity/Milestone
Sign Action Memo
Performance
Lead
EPA, Tribe,
State, PRP
Milestone/Activity date requirements
Start/Finish: Action Memo signed bv the appropriate
regional official
Special Reporting Requirements:
Specific information must be added to the appropriate Action Memo information screens
within the SEMS Site Management Module. This includes removal activity details, media,
response technology, Action Memo type, and ceiling costs. All tabs for data entry are found on
SEMS screen upon selection of the applicable Action Memo. A SEMS Document Management
System (SDMS) Doc ID must be associated to the Action Memo in SEMS before the SCAP data
can be entered.
VI.A.4 Removal Action
The goal of EPA's Emergency Response and Removal (ERR) program is to provide
quick response to immediate threats to public health and the environment from releases of
hazardous substances, pollutants or contaminants whenever and wherever they occur. Removal
actions are responses performed at NPL and non-NPL sites that eliminate or reduce threats to
public health or the environment from the release, or potential release, of hazardous substances
or pollutants or contaminants that may pose an imminent and substantial danger to public health
or welfare. These risk reduction activities can be conducted as emergency, time-critical, or non-
time critical removal actions. The appropriate use of Special Account funds for removal actions
is provided in the Guidance on the Planning and Use of Special Account Funds (OSWER
9275.1-20. September 2010) (http://www2.epa.gov/sites/production/files/2013-
10/documents/plan-use-specacct.pdf).
Classic Emergencies: Removals where the release requires that on-site activities be
initiated within hours of the lead agency's determination that a removal action is
appropriate. These removal actions should not take longer than a year to complete. If the
work is ongoing beyond a year the removal type must be changed to Time-Critical or
Non-Time-Critical.
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Time-Critical: Removals where, based on the site evaluation, the lead agency determines
that a removal action is appropriate and that there is a period of less than six months
available before on-site activities must be initiated.
Non-Time Critical: Removals where, based on the site evaluation, the lead agency
determines that a removal action is appropriate and that there is a planning period of
more than six months available before on-site activities must begin. The lead agency will
undertake an Engineering Evaluation/Cost Analysis (EE/CA) for non-time critical
removals. These removal actions are typically led by the Remedial program.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity date requirements
Government Removal
EPA, Tribe,
State
Start: Initial Pollution Report (POLREP) documenting
date of mobilization to the site for the start of removal
work specified in the Action Memo
Finish: Final POLREP documenting the date of
demobilization from the site when all work specified in
the Action Memo has been completed
PRP Removal
EPA Oversight
Start: Initial POLREP documenting date of mobilization
to the site for the start of removal work specified in the
Action Memo or enforceable document
Finish: Final POLREP documenting the date of
demobilization and the date of Notice of Completion
document to the PRPs
EPA Oversight
(Special
Account [SA]
Financed)
Start: Initial POLREP documenting date of mobilization
to the site for the start of removal work specified in the
Action Memo or enforceable document
Finish: Final POLREP documenting the demobilization
date and the date of Notice of Completion document to
the PRPs
State
Oversight,
Tribe
Oversight
Start: Initial POLREP documenting date of mobilization
to the site for the start of removal work specified in the
Action Memo or enforceable document
Finish: Final POLREP documenting demobilization
date and the date that the state certified that the PRPs
have fully met the terms of the enforcement instrument
and have completed all work specified in the Action
Memo
PRP Removal without an
Enforcement Instrument
EPA Oversight
Start: Initial POLREP documenting EPA's role in
conducting oversight of the PRP-lead action and date that
the PRPs mobilized to the site to start the removal work
Finish: Final POLREP documenting the date that EPA
along with the Incident Command have determined that
the emergency has been stabilized.
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Special Reporting Requirements (Starts):
1. A Preliminary PRP Search is required in order to start the first non-emergency
Government lead action at a site. The completion date must be entered as the Preliminary
PRP Search Finish Milestone date.
2. To receive credit for PRP removal action starts with an enforcement settlement, the date
of the following applicable enforcement instrument must be entered in Primavera as well
as all required data elements for the enforcement instrument identified in chapter IX:
• The date the Administrative Order on Consent (AOC) was signed by the PRPs and
the designated regional official; or
• The date the PRPs provide notice of intent to comply with a Unilateral Administrative
Order (UAO) for a PRP-lead removal signed by the designated regional official; or
• The date the Regional Administrator signs the memorandum transmitting the Consent
Decree (CD) to the Department of Justice (DOJ) or HQ; or
• The date a judgment was signed by the federal judge; or
• The date the state enforcement instrument was signed by the appropriate state official.
3. For both Government and PRP removals, the Response Type (Critical Indicator) field
must be entered into the SEMS Site Management Module.
Program policy remains enforcement first. HQ encourages the regions, in order to have the
ability to bill for oversight costs, to use enforceable instruments for PRP-Lead time critical and
non-time critical removals.
Special Planning/Reporting Requirements (Finish):
The removal program requires the actual start and finish dates to be entered for removal
completions. The data elements listed below must also be entered into the SEMS Site
Management Module for Government and PRP removal completions. If these fields are left
blank the removal will not be captured on reports and will not count towards the Government
Performance and Results Act (GPRA) annual performance goal.
• Removal Work Package Name and Sequence Number
• Performance Lead
• Response Type (Critical Indicator)
• Media Name
• Media Type
• Volume
• Contaminants of Concern
In addition, regions should ensure the NPL and/or Non-NPL Status fields and Site
Type/Subtype fields are maintained in the Site Information screens within the Site Management
Module of SEMS.
Common Exceptions: An entry of "0" (zero) for volume is valid when no volume
information for contaminated material is reported by EPA or the PRP or if EPA activities include
only air monitoring or ground water sampling.
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Temporary demobilization and temporary storage on-site are not considered completions,
unless temporary storage is the only action specified in the Action Memorandum to mitigate
threats to public health, welfare, and the environment. Likewise, temporary off-site storage of
hazardous substances at a Treatment, Storage, and Disposal (TSD) facility other than the facility
of ultimate disposal is a continuation of the action, not a completion, unless temporary off-site
storage at a TSD is the only action specified in the Action Memorandum. In addition, a removal
would not be considered complete if: a) The Action Memorandum requires the EPA contractor to
monitor the hazardous substances stored on-site or additional contractor expenditures are
anticipated; or b) Hazardous substances are being stored at an off-site facility other than the
ultimate TSD facility required in the Action Memorandum.
Regions will receive credit in the management of the Superfund program for completion
of a removal action even though the removal action itself may not be complete for cost recovery
statute of limitations purposes. Agency policy for statute of limitations purposes provides that a
removal is not complete until EPA has made a final decision on whether any additional cleanup
activity is required (and, if it is required, until EPA has both made a final decision on such
additional activity and has completed the design for that activity). The date found in the removal
action, actual finish column of a SEMS report is a programmatic measure only, and cannot be
relied upon to create any rights, substantive or procedural, enforceable by any party in litigation
with the United States. EPA reserves the right to change such data at any time without public
notice.
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Superfund Program Implementation Manual
FY15
Chapter VII: Remedial Program
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the
SPIM (FY2012 - Addendum), available at
http://www.epa.gov/superfund/action/process/spiml2.html
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Superfund Program Implementation Manual
FY15
Chapter VIII: Federal Facility Program
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CHAPTER VIII: Federal Facility Program
Table of Contents
VIII. A Federal Facilities Goals and Priorities VIII-1
VIII.A.l Overview VIII-1
VIII.A.2 Superfund Federal Facility Goals VIII-1
a. Strategic Federal Facility Goals VIII-1
b. Cross-Program Revitalization Measure Implementation VIII-3
VIII.A.3 EPA's Federal Facility Superfund Cleanup Principles VIII-3
VIII.A.4 Federal Facility Docket and Site Discovery/Site Assessment VIII-6
a. Overview VIII-6
b. Federal Facility Docket Process and the Federal Facilities Site
Discovery Process VIII-6
c. Federal Facility Site Assessment Process and Time Frames VIII- 7
d. Authority for Conducting Federal Facility Site
Assessments - E.O. 12580 VIII-8
e. Federal Facility Site Assessment Reports & EPA Review
and HRS Evaluation VIII-9
f. Tracking of Federal Facility Sites in SEMS VIII-10
VIII.A.5 BRAC Budget and Financial Guidance VIII-10
a. Resources and Tracking Mechanisms VIII-10
b. Accountability for Resources VIII-11
VIII.A.6 Cleanup Privatization at BRAC NPL Sites VIII-12
VIII.A.7 Military Munitions Response Program VIII-13
VIII.A.8 Stakeholder Involvement VIII-14
VIII. B Federal Facilities Targets and Measures VIII-14
VIII.B.I Overview of Federal Facilities Targets and Measures VIII-14
VIII.B.2 Federal Facilities Site Discovery/Site Assessment Definitions VIII-16
a. Remedial Site Initiation (Discovery) VIII-16
b. Federal Facility Preliminary Assessment Reviews VIII-17
c. Federal Facility Site Inspection Reviews VIII-19
d. Federal Facility Expanded Site Inspection (ESI) Reviews VIII-19
VIII.B.3 Federal Facilities Accomplishment Definitions VIII-20
a. Base Closure Decisions VIII-20
b. Non-BRAC Property Actions VIII-21
c. Federal Facility Agreement (FFA)/Interagency Agreement (IA) VIII-23
d. Federal Facility Dispute Resolution VIII-23
e. Remedial Investigation/Feasibility Study (RI/FS) or RCRA
Facility Investigation (RFI) Starts VIII-24
f. Decision Documents VIII-24
g. Final Remedy Selected VIII-25
h. Remedy Decision Changes VIII-26
i. Remedial Design (RD) or RCRA Corrective Measure Design (CMD) VIII-2 7
j. Remedial Action (RA) or RCRA Corrective Measure
Implementation (CMI) VIII-27
k. Removal or RCRA Interim/Stabilization Measure (ISM) VIII-29
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/. Operation and Maintenance (O&M) VIII-30
m. Cleanup Goals Achieved VIII-30
n. Percent Construction Completion VIII-31
o. Federal Facility Five-Year Reviews VIII-31
VIII.B.4 Community Involvement Definitions VIII-34
a. Restoration Advisory Boards (RABs)/Site-Specific Advisory
Boards (SSABs) VIII-34
b. Technical Assistance Grants (TAGs) VIII-34
VIII.B.5 Cleanup Privatization at BRAC NPL Sites VIII-35
List of Exhibits
Exhibit VIII. 1 A. Federal Facilities NPL Sites VIII-15
Exhibit VIII. IB. Federal Facilities Fast-Track BRAC Sites VIII-15
Exhibit VIII.2. Remedial Pipeline Flow Charts VIII-29
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CHAPTER VIII: FEDERAL FACILITY PROGRAM
VIILA FEDERAL FACILITIES GOALS AND PRIORITIES
VIII. A.I Overview
To manage the Superfund federal facilities program, the Federal Facilities Enforcement
Office (FFEO) and the Federal Facilities Restoration and Reuse Office (FFRRO) use the Federal
Facilities Leadership Council (FFLC) to help identify and resolve issues unique to the
management of the Environmental Protection Agency's (EPA) Superfund federal facility
response program. The FFLC is comprised of Superfund and/or the Resource Conservation and
Recovery Act (RCRA) program and enforcement/counsel representatives from all regions, as
well as representatives from the Federal Facilities Headquarters (HQ) offices and other HQ
offices that handle federal facility issues.
The guidance documents and policy memos referenced in this chapter may be found by
searching by title or document number on the Cleanups at Federal Facilities webpage
(http ://www2. epa. gov/fedfac).
VIII.A.2 Superfund Federal Facility Goals
a. Strategic Federal Facility Goals
Superfund federal facility activities have high visibility because of the significant threats
posed by military sites, the impact of military base closings, the resources needed to
implement Department of Defense (DoD)/Department of Energy (DOE) cleanup efforts
at facilities listed on the National Priorities List (NPL) and other non-NPL facilities, and
heightened state, tribal, local governments and other stakeholder interests. Federal facility
program goals are based on a number of related factors, including overall Superfund
program goals, anticipated resource constraints, and statutory requirements. Program
activities and resources should be planned to achieve the following goals of the federal
facility program:
• Percent Construction Complete - This new percent construction complete measure
is based on the average of three specific factors at each federal facility NPL site:
1) Operable Unit (OU) percent complete; 2) Total actions percent complete; and
3) Duration of actions percent complete.
• Expediting Property Transfer and Reuse - Revitalization is one of the Office of
Solid Waste and Emergency Response's (OSWER) highest priorities. The number
of acres EPA has found suitable for transfer or lease are currently being tracked
by EPA in the Superfund Enterprise Management System (SEMS). One way of
facilitating property reuse occurs when DoD installations are slated for closure or
realignment, or have been identified as excess property through other means. At
these Base Realignment and Closure (BRAC) installations, environmental
restoration activities continue with the same cleanup objective as those of active
installations - protect human health and the environment. At the time of closure or
realignment, specific BRAC property, and its possible future use, is identified.
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The closed or realigned property will eventually be transferred to another Service
Component, federal agency or a non-federal entity, such as a state or local
government or private entity. Along with achieving cleanup objectives, BRAC
installations focus on efficient property transfer and providing beneficial and
protective reuse of the property by the local community.
Environmental Indicators - The environmental indicator currently reported under
the Government Performance and Results Act (GPRA) framework for the
Superfund program is Human Exposure Under Control, This measure provides
current site information regarding risk reduction at all NPL sites.
Sitewide Ready for Anticipated Use - This GPRA performance measure
documents the number of final and deleted construction complete NPL sites
where, for the entire site or facility:
All cleanup goals in the Record(s) of Decision (ROD) or other remedy
decision document(s) have been achieved for media that may affect current
and reasonably anticipated future land uses of the site, so that there are no
unacceptable risks; and
All institutional or other controls required in the Record(s) of Decision or
other remedy decision document(s) have been put in place.
The introduction of this measure reflects the Agency's commitment to land
revitalization. The Agency's policies have increasingly addressed the issue of
making Superfund NPL sites protective for current and future uses. In particular,
one of EPA's key responsibilities under Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) is to ensure that contaminated
property owned by the federal government is environmentally suitable for transfer
or lease.
Involving Citizens, Local Governments, and Tribes in Environmental Decision
Making - The publication of the Final Report of the Federal Facilities
Environmental Restoration Dialogue Committee (FFERDC) in April 1996 was a
watershed event for public involvement in federal facility cleanups. As a result of
the Report, federal agencies have established Restoration Advisory Boards
(RABs) at DoD installations and Site Specific Advisory Boards (SSABs) at DOE
facilities. Other federal agencies have also formed advisory boards. Regional staff
and management are expected to be especially sensitive to the requests at NPL
facilities and at the BRAC facilities. Because of resource constraints, EPA
regional participation and support for non NPL facilities is minimal. Regions need
to work closely with state agencies and their federal counterparts to ensure that
the President's Executive Order on Environmental Justice is successfully carried
out (E.G. 12898).
Enforcing the Laws - The public needs to know that it will be protected from
environmental hazards through vigorous enforcement by the EPA and the states
for violations of environmental laws and situations that put people and natural
resources at risk. EPA intends to use its enforcement authorities not only to
compel compliance, but also to promote long term policy objectives such as
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greater citizen involvement, pollution prevention, technology development, and
natural resource management.
Regions should continue to strive to place these priorities and project milestones in
enforceable Federal Facility Agreements (FFAs)/Interagency Agreements (lAs) at NPL
sites. FFAs and lAs should reflect the best judgments by all parties of cleanup priorities
and milestones at the time of agreement.
b. Cross-Program Revitalization Measure Implementation
Federal facilities and remedial programs continue to implement the OSWER-wide Cross-
Program Revitalization Measures effort by tracking the number of actually or potentially
contaminated, or previously contaminated, sites and surface acres that are "Protective for
People Under Current Conditions" (PFP) and "Ready for Anticipated Use" (RAU).
Sites and surface acres tracked by these measures include investigated land, wetlands,
surface water, and/or sediments for which these programs have a documented oversight
role for any necessary assessment, remedial action, and/or property transfer. The federal
facilities and Superfund programs are using the current Human Exposure Under Control
Environmental Indicator as basis for determining whether sites and acres are PFP; the
PFP measure captures the number of acres at a site for which there are no complete
pathways for human exposure to unacceptable levels of contamination based on current
site conditions.
The Program is also tracking two optional indicators, Status of Use and Type of Use.
These indicators describe how the acres are being used when the determination is made
for the PFP and RAU performance measures. Acres and sites that meet Cross-Program
Revitalization Measures (CPRM) PFP and/or RAU criteria as well as Status and Type of
Use information are documented via a checklist in SEMS. Acres are measured on an OU
or property transfer parcel basis.
VIII.A.3 EPA's Federal Facility Superfund Cleanup Principles
Consideration of Human Health and Environmental Risk and Other Factors in Federal
Facility Environmental Cleanup Decision Making: Protection of Human Health and the
Environment and meeting state applicable or relevant and appropriate requirements (ARARs) are
threshold criteria at all Superfund sites, including federal facilities. Addressing the greatest risk
sites will generally be a driving factor, but not the only factor in determining environmental
cleanup priorities and milestones. In setting priorities and milestones, regions should consider:
• Human Health and Environmental Risk: Risk assessments and other analytical tools
used to evaluate risks to human health (including non-cancer as well as cancer health
effects) and the environment all have scientific limitations and require assumptions in
their development. As decision-aiding tools, risk assessments should only be used in a
manner that recognizes those limitations and assumptions. In addition to criteria
established by statute, regulation or guidance, as noted below there are other factors
that affect whether and to what extent cleanups are to occur.
• Emerging pollutants, contaminants and hazardous substances of concern: As
analytical detection methods improve and health risk data are better defined, EPA and
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the federal community are detecting chemicals, like perchlorate, perfluorinated
compounds, and Trichloroethylene (TCE), at lower levels of concern and at a greater
number of sites. Thus, we may need to expand the scope of investigations and
cleanup actions, and take other actions to adequately address these chemicals.
• Other Factors: In addition to human health and environmental risk, other factors that
warrant consideration in setting environmental cleanup priorities and milestones
include, but are not limited to:
cultural, social, and economic factors, including environmental justice
considerations
short-term and long-term ecological effects and environmental impacts in general,
including damage to natural resources and lost use
- making land available for other uses
- acceptability of the action to regulators, tribes, and public stakeholders
statutory requirements and legal agreements
life cycle costs
permanence and reliability of remedy
pragmatic considerations, such as the ability to execute cleanup projects in a
given year, and the feasibility of carrying out the activity in relation to other
activities at the facility
overall cost and effectiveness of a proposed activity
• Green Remediation: The practice of considering all environmental effects of remedy
implementation and incorporating options to minimize the environmental footprints
of cleanup actions. EPA strives for remedies that use natural resources and energy
efficiently, reduce negative impacts on the environment, minimize or eliminate
pollution at its source and reduce waste to the greatest extent possible. Therefore
green remediation reduces the demand placed on the environment during cleanup
actions. EPA's Office of Solid Waste and Emergency Response issued the Principles
for Greener Cleanups (Principles) in August 2009. The Principles document defines
the five core elements that may be considered when evaluating and implementing a
green cleanup: Total Energy Use and Renewable Energy Use, Air Pollutants and
Greenhouse Gas Emissions, Water Use and Impacts to Water Resources, Materials
Management and Waste Reduction and Land Management and Ecosystems
Protection. Green Remediation practices fit within existing cleanup programs and
comply with existing statutes and regulations. Green Remediation can be applied
throughout all phases of cleanup, including site investigation, design, construction,
operation, and monitoring. For more information visit:
http://www.epa.gov/superfund/greenremediation/
• Collaboration: The federal facilities response program will continue to work in a
collaborative fashion with other federal agencies, other regulators, tribal
governments, local governments and communities. In many situations, EPA's
statutory responsibilities will place the Agency in a leadership role that requires
convening the relevant parties and facilitating interaction. In other situations, EPA
will simply act as one of the many interested parties in a collaborative problem-
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solving effort convened by another federal agency, tribe, state, local government or a
private entity. However, it is important to recall that collaboration cannot replace the
core functions of a regulatory agency nor compromise EPA decision-making and
enforcement responsibilities.
Typically, EPA looks to all affected stakeholders for ideas and innovative solutions and,
where appropriate, incorporates stakeholder recommendations into policy and practice.
• Innovation: Federal facilities should continue to serve as a test bed for new cleanup
technologies and new cleanup processes. We should continue efforts, working with
others, to promote more effective and efficient cleanups that support redevelopment
and reuse of contaminated properties, especially those that support the mission of the
responsible agency. Efforts to improve and streamline the cleanup process should
continue to focus on reducing paperwork and developing more collaborative
relationships among all parties.
• Consistency of Treatment between Federal Facilities and Private Sites: Federal
facilities, especially NPL sites, are generally large complex sites. CERCLA requires
that federal facilities be treated the same as other entities.
• Environmental Justice: As federal facilities affect many diverse communities and
communities of low income, the federal Government has an obligation to make
special efforts to reduce the adverse effects of environmental contamination related to
federal facility activities on affected communities that have historically lacked
economic and political power, adequate health services, and other resources. This
needs to continue to be a focus for the Program.
• Stakeholder Involvement: Despite a very impressive record of success, involvement
by the public continues to be an area where improvements can be made. Federal
facility cleanup decisions and priorities should reflect a broad spectrum of
stakeholder input from affected communities including indigenous peoples, low-
income communities, and minority groups. Stakeholder involvement has, in many
instances, resulted in significant cleanup cost reductions. It should therefore not only
be considered as a cost of doing business but as a potential means of efficiently
determining and achieving acceptable cleanup goals.
• The Role of Negotiated Cleanup Agreements: Enforceable cleanup agreements play a
critical role both in overseeing priorities at a site and providing a means to define and
balance the respected interdependent roles and responsibilities in federal facilities
cleanup decision making. EPA must continue to hold federal agencies accountable for
meeting the terms of these agreements to ensure timely and protective cleanup.
• The Critical Role of Future Land Use or Activity Determinations: Reasonably
anticipated future land uses should be considered when making cleanup and reuse
decisions for federal facilities. The communities that are affected by federal facility
cleanups, along with their state and local governing bodies and affected tribes, should
be given a significant role in determining reasonably anticipated future use of federal
property that is expected to be transferred, and in how future use determinations will
be used in making cleanup decisions.
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• The Importance of Characterizing Sites Correctly: The identification and
characterization of contamination and the evaluation of health impacts on human
populations and ecological effects are essential parts of the cleanup process. If a
quality characterization is done, money and time can be saved during the response
phase. Characterization must also include proper quality assurance/quality control
processes to ensure that data are used to make decisions of known and reliable
quality.
VIII.A.4 Federal Facility Docket and Site Discovery/Site Assessment
a. Overview
The U.S. EPA Federal Agency Hazardous Waste Compliance Docket (Docket) Process
and Federal Facility Site Discovery/Site Assessment Process are different from the non-
Federal Facility Site Assessment Process; and are governed by a specific set of statutes
and guidance in the CERCLA, 1980, as amended by the Superfund Amendments and
Reauthorization Action (SARA), 1986, and in the National Contingency Plan (NCP). The
federal facilities process is different in at least four ways:
1. Federal Facility Docket Process and Federal Facilities Discovery Process: The
process for federal facilities involves listing federal facility sites on the Docket
(CERCLA/SARA section 120(c)) prior to any listing of the Site Discovery in
SEMS.
2. Federal Facilities Site Assessment and Time Frames: The time frame for
completion of federal facilities site assessment activities following Site Discovery
is that of "a reasonable time schedule" (CERCLA/SARA section 120(d)) as
Amended in 1997; and for completion of Hazard Ranking System (HRS)
evaluations the time frame is within four years from Site Discovery.
3. Authority for Conducting Federal Facility Site Assessments - Executive Order
12580: The authority for conducting federal facility site assessments has been
delegated to the federal agencies under Executive Order 12580 (E.O. 12580), and
CERCLA 120(h).
4. Federal Facility Site Assessment Reports & EPA Review and HRS Evaluation:
EPA is required to review federal facility site assessment reports and evaluate
such facilities in accordance with the HRS criteria (authority retained by EPA).
b. Federal Facility Docket Process and the Federal Facilities Site Discovery Process
EPA is required to establish a Federal Agency Hazardous Waste Compliance Docket
("Docket") under section 120(c) of the CERCLA of 1980, as amended by SARA of 1986.
section 120(c) requires EPA to establish a Docket that contains information reported to
EPA by federal facilities that manage hazardous waste or from which a reportable
quantity of hazardous substances, pollutants, or contaminants have been or may be
released. The Docket was established by EPA in 1988.
The Docket is used to identify federal facilities that should be evaluated to determine if
they pose a threat to public health or welfare and the environment; and to provide a
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mechanism to make this information available to the public. As new facilities are
reported to EPA by federal agencies, EPA publishes a list of these facilities in the
Federal Register.
The Docket contains information submitted by federal agencies under the following
authorities:
• Section 103 of CERCLA requires owners or operators of vessels or facilities to
notify the National Response Center of a release of a reportable quantity of a
hazardous substance (notification of a release or potential release);
• Section 3005 of RCRA provides EPA authority to establish a permitting system
for hazardous waste treatment, storage, and disposal (TSD) facilities, which in
turn requires them to submit certain information as part of the permit application
(interim status/permitting authority). The hazardous waste permitting program is
generally implemented by authorized states;
• Section 3010 of RCRA requires hazardous waste generators, transporters, and
TSD facility owners/operators to notify EPA of their hazardous waste activities
(notification of hazardous waste activity);
• Section 3016 of RCRA requires federal facilities to submit an inventory of
hazardous waste sites they own or operate, or have owned and operated in the past
(biennial inventory of hazardous waste activities);
• "Other" has been added as a reporting mechanism to indicate those federal
facilities that otherwise have been identified to have releases or threat of releases
of hazardous substances. EPA's NCP, (40 CFR 300.405) further addresses the
discovery or notification and outlines what constitutes discovery of a hazardous
substance release, and states that a release may be discovered in several ways.
This information is collected and stored in the Federal Facilities E-Docket tool. Facilities
are identified via web query pulls from the RCRA Info and Emergency Response
Notification System (ERNS) systems, and compiled for Regional Docket Coordinator
review and proposal to the Docket. Following publication of the site's addition to the
Docket in the Federal Register., the site is then entered in SEMS as a Site Discovery. The
Site Discovery Date is that of the publication in the Federal Register. For additional
information see the EPA Docket Reference Manual, Federal Agency Hazardous Waste
Compliance Docket, Interim Final, March 9, 2007; website:
http ://www. epa. gov/fedfac/documents/docket. htm
c. Federal Facility Site Assessment Process and Time Frames
CERCLA/SARA, as amended, section 120(d) (1) requires that EPA take steps to assure
that a Preliminary Assessment (PA) be completed and that evaluation and listing of sites
be completed within a reasonable time frame (CERCLA/SARA, as amended, section
120(d) (3)) for each federal facility included on the published list of federal facilities
reported pursuant to section 120(c) of CERCLA/SARA (the "Federal Facilities docket").
The PA is designed to provide information for EPA to consider when evaluating the site
for potential listing on the NPL. E.O. 12580 delegated the authority to conduct Federal
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Facility PAs and, when warranted, Federal Facility Site Inspections (Sis) to the federal
agencies.
EPA believes the most reasonable schedule for assessing federal facility sites listed on
the Docket would be one consistent with the schedule for assessing non-federal facility
sites which are tracked in SEMS. Potential budgeting issues of a federal facility may also
be a factor in conducting a PA. Under Superfund policy (OSWER directive 9200.3-14-
1E), EPA attempts to complete a non-federal facility PA within one year of that site's
discovery (inclusion in SEMS). However, the need of federal agencies to wait for the
next budget cycle to obtain funding may make the one year time frame problematic in
some cases. Further, past experience using the 18 month time frame has shown it to be a
reasonable period of time for completion of the Federal Facility PA. As a result, it is
appropriate to expect federal facilities to strive to submit completed Federal Facility PA
Reports within 18 months from inclusion on the Docket. Of course, in cases where a PA
petition is submitted pursuant to CERCLA section 105(d), a PA may need to be
completed within 12 months.
It is worth noting that under section 116(b) of SARA, a facility should be evaluated
within four years of SEMS listing. EPA believes this is a reasonable time frame for
making listing decisions at federal facility sites as well. On receipt and following
evaluation of a Federal Facility PA and, if warranted, a Federal Facility SI, EPA would
make a determination either of No Further Remedial Action Planned (NFRAP) under
EPA's Superfund program (CERCLA/SARA); or of potential NPL candidate. However,
if further EPA involvement is warranted for an HRS evaluation and proposal of the site to
the NPL, then all these steps, from Discovery to NPL proposal, have to be completed
within a four year time frame. Historically, it was sometimes difficult for EPA and the
federal agencies to complete these tasks within the 30 months originally provided under
section 120(d), and EPA believes 48 months is a more appropriate and reasonable time
frame for both the federal facility and EPA.
EPA and the individual agencies should work together to ensure these time frames are
met.
d. Authority for Conducting Federal Facility Site Assessments - E.O. 12580
Sections 104(b) and (e) of CERCLA grant to the President broad investigative authority
to conduct a PA and/or a SI. The President has delegated this authority through
E.O. 12580 to the heads of the respective federal executive departments and agencies with
jurisdiction, custody, or control over their facilities. The NCP provides for the lead
federal agency to perform a PA and, as appropriate, an SI, on all sites on the Docket and
in SEMS (see CERCLA/SARA 120(d) and 40 CFR Part 300.420(b)(l) and (c) (1)).
Section 300.5 of the NCP defines "lead agency" generally as that federal executive
agency with jurisdiction, custody, and control over the facility on which a release occurs
or is from (except in the case of an emergency). Accordingly, each federal agency
typically is the lead agency to conduct a PA or an SI on facilities within its respective
jurisdiction, custody, or control. Lead agency, or the responsible federal agency, can
differ from the federal agency ownership party. The Federal Agency Owner field of the
Docket is the federal department or agency that owns the facility at the time of Docket
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listing, deletion, and/or correction whereas the Responsible Federal Agency is the lead
agency responsible for the oversight.
EPA must take steps to ensure that a PA is completed for facilities on the federal facilities
docket where the respective federal agencies are delegated the authority to conduct a PA
or SI, and thus the respective federal agencies are the "lead agency" for conducting such
investigations.
Federal facilities that conduct a PA may satisfy some of the PA reporting requirements
through work already conducted pursuant to the RCRA corrective action program or state
cleanup programs. For example, a facility at which a RCRA Facility Assessment (RFA)
has been conducted may base its PA on the RFA report. When work conducted under
such non-CERCLA authorities is the basis for satisfying PA requirements, the facility
should demonstrate that all information required for the CERCLA PA is provided. In
some instances, it may be appropriate to provide supplemental information to ensure that
all hazardous substances, pollutants, or contaminants at the facility are addressed.
Similarly, at a federal facility sites when under CERCLA 120(h) ownership Federal Real
Property is being transferred, where there have been observed releases, the federal
facilities may satisfy some of the PA reporting requirements through work already
conducted for General Services Administration (GSA) Environmental Phase II Reports or
other environmental investigations done by DoE/DoD. Again, as in the foregoing RCRA
Facility Assessment discussion, the federal facilities should demonstrate that all
information required for the CERCLA PA is provided, and as appropriate, provide
similar supplemental information as mentioned above.
For additional information see the Federal Facilities Remedial Preliminary Assessment
and the Federal Facilities Remedial Site Investigation Summary Guides, 2005
(http ://www2. epa. gov/fedfac).
e. Federal Facility Site Assessment Reports & EPA Review and HRS Evaluation
For federal facilities, the site assessment process under CERCLA/SARA begins when the
federal facility site has been listed on the Docket. When a federal facility submits a
Federal Facility PA report (also see CERCLA 104(h)), and if warranted a Federal Facility
SI report, EPA evaluates the site in accordance with the HRS final rule1 to determine
whether the site poses a threat to human health and the environment.
If EPA determines that the site does not pose a threat to human health and the
environment based on the data provided in the PA or SI reports, then EPA will designate
a decision of NFRAP under Superfund. A decision not to take further response/remedial
action under the Superfund program is based on a finding that the facility/situation does
not meet the minimum CERCLA eligibility requirements or that there is insufficient risk
to human health or welfare, or the environment to be included or proposed, at this time on
the NPL by the EPA. This decision does not preclude any further action at the facility by
other EPA programs, by the states or other federal agencies. If there is a clear non-
1 Hazard Ranking System; Final Rule, 40 CFR Part 300, appendix A, Federal Register, Vol. 55, No. 241, December
14, 1990.
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compliance with other environmental programs, EPA will make a deferral to the
appropriate alternate authorities. Should EPA receive new information and/or issue new
rule making that warrants further EPA involvement, EPA will reactivate the site.
If the results of a Federal Facility SI indicate that the federal facility site warrants further
investigation based on the HRS evaluation, EPA will prepare an HRS scoring package to
evaluate propose the site on the NPL. To make such an NPL decision, EPA may collect
further data to complete the HRS package.
f. Tracking of Federal Facility Sites in SEMS
Federal facility sites can be tracked through the federal facility docket screen in SEMS,
EPA's official CERCLA/SARA sites database tracking system. It allows authorized EPA
SEMS users to enter new Federal Facility Docket sites. SEMS users can access that and
other screens to select and track federal facility sites in the SEMS universe, and to
manage site assessment activities (i.e., Federal Facility Preliminary Assessment Review
and Federal Facility Site Inspection Review actions) at these sites.
SEMS tracks site assessment activities that are being or have been conducted for all
federal facilities listed on the Docket pursuant to CERCLA section 120 et al.
For more in depth understanding of the site assessment process for federal facilities,
search for the following documents at http://www2.epa.gov/fedfac:
• EPA Federal Facilities Preliminary Assessment Summary Guide, July 21, 2005;
• EPA Federal Facilities Remedial Site Inspection Summary Guide, July 21, 2005;
• Appendix A to the above: Federal Facilities Remedial Preliminary Assessment
and Remedial Site Inspection Summary Guide (Information Supplement)., July 21,
2005, for Law/Regulations: Summary of Appropriate Legislation/Regulation;
Definition of Site; and Site Assessment Process for federal facilities;
• EPA Guidance for Performing Preliminary Assessments Under CERCLA (1991);
• EPA Guidance for Performing Site Inspections Under CERCLA (1992).
VIII.A.5 BRAC Budget and Financial Guidance
a. Resources and Tracking Mechanisms
BRAC occurred in five different rounds: 1988 (BRAC I), 1991 (BRAC II), 1993 (BRAC
III), 1995 (BRAC IV), and 2005 (BRAC V). The primary mission of the BRAC program
is to ensure that the hazardous waste sites owned or operated by the Military Components
are addressed, cleaned up and in some cases made available for transfer and/or lease as
quickly as possible.
BRAC I-IV
Under the first four rounds of BRAC (BRAC I - IV), the Military Components identified
107 installations for an accelerated cleanup effort (formerly known as fast track sites).
Thirty-four of these installations were listed on the NPL. In 1994, EPA and DoD signed
the first BRAC Memorandum of Understanding (MOU) establishing responsibilities and
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funding for EPA's assistance in accelerating cleanup at 107 realigning and closing
installations. DoD continues to provide resources for EPA's assistance in assessing
BRAC properties and determining their suitability for transfer and/or lease, accelerating
cleanup actions wherever possible, and ensuring that remedies selected reflect the views
of the affected communities surrounding the sites and the proposed future reuse. In
expediting the BRAC cleanup and supporting property transfer, reuse and economic
development, the federal facilities program works with its federal partners, tribal, state
and local governments, and private parties. The majority of EPA's BRAC resources are
directed to the regions for technical, regulatory and property transfer oversight at BRAC
installations. BRAC funding is also used for EPA personnel to participate on BRAC Base
Cleanup Teams (BCT) as either the EPA designated team member or as technical experts.
EPA reports to DoD on the issues and progress at individual sites through semi-annual
reports, as required under the Memorandum of Understanding.
BRAC-V
EPA continues to fulfill its statutory obligations at the 72 NPL installations which were
affected by the fifth round of BRAC, and at certain non-NPL bases where EPA has a
regulatory role. In addition, EPA regions may be requested to perform activities by states,
tribes, local governments, the military components or others at certain facilities where
EPA has no formal regulatory role. Given EPA's resource constraints, each region has to
examine those requests individually and determine whether it can positively respond.
EPA's annual budget request does not include additional support for BRAC-related
services to DoD at BRAC V facilities. If EPA services are required at levels above its
base for non-NPL BRAC V related installations, EPA would seek reimbursement from
DoD. See the interim BRAC guidance for more information:
http://www2.epa.gov/fedfac/base-closure-federal-facilities.
b. Accountability for Resources
Regions are allocated full time employee (FTE) and administrative dollars (payroll and
site travel) based on installation-specific negotiations between EPA and DoD. BRAC
resources received from DoD are to be used and allocated according to the BRAC MOU
between EPA and DoD (http://www2.epa.gov/fedfac), and the official funding letter
which provides the annual budget and installation-specific FTE levels. BRAC
reimbursable FTE and funding must be used only for EPA related Base Closure activities,
and changes affecting the FTE level for any installation require prior approval by
FFRRO. Military Base Closure activities are activities related to cleanup of specific
installations identified by OSWER (in consultation with DoD). These activities include:
accelerating the identification of clean parcels under the Community Environmental
Response Facilitation Act (CERFA); developing BRAC Cleanup Plans (BCP); promoting
community involvement in cleanup decision making; preparing and reviewing site
documents (e.g., BCP, Environmental Baseline Survey, Remedial Investigation
(RI)/Feasibility Study (FS), RODs, RD, and RAs) and RCRA documents (e.g., RCRA
Facility Investigation (RFI) Starts, Corrective Measure Design (CMD) Starts, and
Interim/Stabilization Measure (ISM) Starts and Completions); studying and sampling
field data; National Environmental Protection Act (NEPA) review and analysis; assisting
DoD or states with BRAC site issues; and activities supporting EPA personnel
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participation in the BRAC program. These activities are outlined in the EPA/DoD BRAC
MOU, and subsequent memorandums and guidance related to EPA BRAC resources.
As the signatory and executing agent for the reimbursable agreement with DoD, the
Assistant Administrator for OSWER will rely on Regional Administrators and, as the
primary focus of the EPA BRAC resources, the regional RCRA/Superfund National
Program Managers to ensure reimbursable costs are accurate and appropriate. Each
region has identified an individual in the appropriate division that is responsible for
coordinating the regional BRAC program and resources, and acts as a day to day liaison
with OSWER and DoD. FFRRO, within OSWER, provides the Assistant Administrator
(AA) OSWER with periodic programmatic and financial updates on the program.
Reprogramming of funds request submitted to the Office of Budget require notification of
FFRRO for their approval. Around late August, the Superfund and Waste Division
Directors are asked to provide a response to FFRRO validating the individuals charging
to BRAC are actually doing BRAC work, and the hours reflected on the Compass Data
Warehouse report are correct. HQ and regional personnel utilizing BRAC resources
should receive authorization from their appropriate regional senior managers and use the
funds as outlined in the BRAC MOU. The EPA Remedial Project Manager (RPM) and
the support team are empowered to make decisions locally to the maximum extent
possible. EPA has delegated certain authorities to the Regional Administrators (e.g.,
CERFA and Covenant Deferral Request (CDR) concurrence), who have in turn delegated
the authorities to others within their organizations. Regional personnel should be familiar
with their internal delegation of authorities. Should the need arise, the RPM and support
team will have the ability to raise issues immediately to senior EPA officials for
resolution.
FFRRO and the Cincinnati Finance Office use Compass, Business Objects and Compass
Data Warehouse for monitoring BRAC resources. The Cincinnati Finance Office
provides quarterly BRAC billing statements (by installation and funds received,
expended and remaining balance) to DoD. HQ receives semi-annual program activity
reports from the regional offices on the progress of work at existing BRAC I-IV
installations. These reports are generated by the EPA regional BRAC Cleanup Team
personnel and provide HQ and DoD with pertinent program information related to
cleanup and reuse. During early fourth quarter, FFRRO works with Cincinnati Finance in
determining a projected carryover balance for the program. The estimate which is
provided to DoD is used to offset the BRAC budget transfer to EPA for the upcoming
fiscal year. Since we no longer have the liberty of using carryover to cover additional
charges, the regions must be mindful of their BRAC spending.
VIII.A.6 Cleanup Privatization at BRAC NPL Sites
EPA recognizes that the privatization of the cleanup at BRAC sites can present an
opportunity to integrate redevelopment planning with cleanup. Such privatized cleanups provides
another option to federal and state agencies and local communities to help maximize the impact
of cleanup and redevelopment resources to help move properties back into productive reuse more
quickly.
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Privatization refers to a site where: 1) a non-federal party will take title to BRAC
property; 2) the property will be transferred using CERCLA 120(h)(3)(C) early transfer,
covenant deferral authority; and 3) the transferee, rather than the military, will conduct the
cleanup using funding provided by the DoD. The DoD funding to the transferee is provided
through an Environmental Services Cooperative Agreement (ESCA). Other documents that are
typically required for such transfers include an amendment to the existing Federal Facility
Agreement. The amendment provides: that in the event the transferee defaults on the cleanup of
the property or fails to meet the cleanup standards, the military is obligated to return and
complete the cleanup; negotiation of an Administrative Order on Consent (AOC) with the non-
federal entity who is to be responsible for the cleanup; and the issuance of a Finding of
Suitability for Early Transfer (FOSET). Importantly, the AOC provides for continuing EPA and
state oversight and the reimbursement of such oversight costs. (See the April 27, 2006, Interim
Guidance for EPA's Base Realignment and Closure (BRAC) Program, at pages 18-21.) Early
transfer covenant deferral requests seek deferral of the CERCLA 120(h)(3)(A)(ii)(I) deed
covenant that all remedial action has been taken.
VIII.A.7 Military Munitions Response Program
Millions of acres of former munitions use or manufacturing areas have been transferred
from DoD control to non-federal entities or other federal agencies to be used for other purposes
(a large percentage of these properties now are identified as Formerly Used Defense Sites
[FUDS]). DoD has an online inventory of munitions response sites (MRS) and associated
acreage that are potentially contaminated. Furthermore, active military installations and
installations affected by the BRAC program may have locations other than operational ranges
contaminated with Munitions and Explosives of Concern (MEC) and Munitions Constituents
(MC). While some MRS are fairly small (e.g., small arms ranges, burial pits and trenches),
others may be dozens or even hundreds of square miles in area (e.g., former bombing ranges). In
addition to MEC, these MRS may have soil, ground water, and surface water contamination from
MC or other sources (including explosives and heavy metals, depleted uranium, and at a small
number of sites, chemical warfare agents (CWA) or chemical warfare materiel (CWM). The MC
may derive from a number of sources. Such sources include: live-fire training or testing, low
order detonations of munitions used in training or testing, open burning and open detonation
(OB/OD) treatment/destruction activities, or munitions burial. Explosives safety (e.g., the
potential for the detonation of MEC) is usually the principal concern during munitions response
actions involving MEC.
The National Defense Authorization Act for fiscal year (FY) 2002 (P.L. 107-107)
directed DoD to develop and maintain an inventory of defense sites that are known or suspected
to contain unexploded ordnance, discarded munitions or munitions constituents. The Handbook
on the Management of Munitions Response Actions (http://www2.epa.gov/fedfac/military-
munitionsunexploded-ordnance) is designed to facilitate a common understanding of the state of
the art of MEC detection and munitions response, and to present EPA guidance on the
management of munitions response actions. The EPA Munitions Response Guidelines (July
2010) were developed to provide guidance to project managers overseeing munitions response
actions at locations other than operational ranges where MEC/MC are suspected to be or have
been encountered. Types of response actions include, but are not limited to, assessments,
investigations and cleanups under the authorities of CERCLA, RCRA, and, where appropriate,
response actions under other federal environmental authorities, such as the Safe Drinking Water
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Act (SDWA). The Guidelines may be useful in situations involving enforcement, permitting, and
emergency or time critical actions where MEC/MC are involved. There are several ongoing
collaborative efforts with DoD, states and others to address MRS issues. These include multi-
agency munitions response policy workgroups, training programs, quality assurance/quality
control requirements, and technology evaluations.
EPA issued a memo to the regions on April 5, 2010 to clarify issues with the DoD
Military Munitions Response Program (MMRP) (http ://www2. epa. gov/fedfac/military-
munitionsunexploded-ordnance). In some situations, an MRS that is within the boundaries of an
NPL site may not be currently included in the list of areas of concern, facility inventory, or other
description of sites to be addressed under a FFA or other document providing for regulatory
oversight (e.g., RCRA 7003 order). The MRS should be added to the FFA (or other oversight
document) as soon as practicable together with an enforceable schedule of milestones, including
primary and secondary documents. To resolve any disagreements that arise over adding the
MRS, EPA regions should use the tools provided by the applicable FFA, including the Dispute
Resolution process. Neither Congress' enactment of Defense Environmental Restoration Program
(DERP) providing funds to address munitions, nor DoD's administrative creation of its MMRP
to spend that money, exempts DoD from or alters CERCLA section 120 requirements. That
includes the requirement for an FFA for any cleanup at a federal facility on the NPL.
VIII.A.8 Stakeholder Involvement
By Executive Order, federal facilities have lead responsibilities for cleanup activities
under CERCLA. This means that they are responsible for implementing the full suite of
community involvement activities that Superfund performs for private sites. Federal facilities are
required to staff this function with personnel who are knowledgeable about all aspects of public
participation and who are authorized to encourage and support the public in becoming involved
in the cleanup decision-making process through early and meaningful community involvement
activities. In its regulatory role, Superfund provides oversight of this activity, principally through
its Community Involvement Coordinators (CIC). In the absence of an assigned CIC, the
Superfund Remedial Project Manager is responsible to ensure early and meaningful public
participation through all cleanup stages. In particular, Superfund staff will ensure that public
participation documents, like the Proposed Plan, are of the highest quality in terms of clarity,
completeness, ease of use and plain language. For DoD sites, Superfund staff will participate in
RABs, offer Technical Assistance Grants, remind the DoD facility to offer their Technical
Assistance for Public Participation (TAPP) program to RAB members, assure that the facility
updates its mailing list and provides frequent community update fact sheets, and approximately
every two years, review the Community Involvement Plan (CIP) to determine the need for an
update. For Department of Energy sites, the above applies, except that the stakeholder groups are
called Site-specific Advisory Boards (SSAB).
VIII.B FEDERAL FACILITIES TARGETS AND MEASURES
VIII.B.l Overview of Federal Facilities Targets and Measures
The following pages contain, in pipeline order, the definitions of federal facilities targets
and measures. Exhibit VIII. 1 displays the internal and external reporting hierarchy for the full list
of federal facilities activities defined in this chapter.
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Regions are responsible for entering data into SEMS for federal facility sites, especially
BRAC Sites where regions are involved. This data includes, where appropriate, FUDS, PA, SI,
removals, decision documents, acres transferred, etc.
EXHIBIT VIII.1A. FEDERAL FACILITIES NPL SITES
ACTIVITY
FFA/IA
Remedial Site Assessment Completions
RI/FS or RFI Starts
Decision Documents (RODs, ROD Amendments, Explanation of Significant
Differences (BSD), Action Memos)
Final Remedy Selected
Remedial Design (RD) or RCRA CMD Starts
RD or CMD Completions
Remedial Action (RA) or Corrective Measure Implementation (CMI) Starts
RA or CMI Completions
Removal or RCRA ISM Starts
Removal or ISM Completions
Operation and Maintenance (O&M) Starts
Percent Construction Completion
Federal Facility Five-Year Reviews (FYR)
External
Program
Reporting
Annual
Commitment
System (ACS),
Strategic Plan
ACS
(RA only)
Internal
Program
Reporting
Measure
Target
Target
Target
Measure
Measure
Target
Target
Measure
Measure
Measure
Target
Target
Key to Reporting Hierarchy
ACS = Regional targets are established in Annual Commitment System.
Strategic Plan = National target is publicly reported in Agency's Strategic Plan.
Target = Superfund Comprehensive Accomplishment Plan (SCAP) target and reporting measure.
Measure = SCAP reporting measure, but target not required.
EXHIBIT VIII.1B. FEDERAL FACILITIES FAST-TRACK BRAC SITES
ACTIVITY
FFA/IA
Federal Facility Dispute Resolution
Use of Supplemental Environmental Projects (SEPs)
RI/FS or RCRA Facility Investigation (RFI) Starts
External
Program
Reporting
Internal
Program
Reporting
Measure
Measure
Measure
Measure
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OSWER Directive 9200.3-15-1G-Y
ACTIVITY
Decision Documents (RODs, ROD Amendments, ESDs, Action Memo s)
Final Remedy Selected
Remedial Design (RD) or RCRA CMD Starts
RD or CMD Completion
Remedial Action (RA) or CMI Starts
RA or CMI Completion
Removal or RCRA Interim/Stabilization Measure (ISM) Starts
Removal or ISM Completions
BRAC Construction Completions
Operation and Maintenance (O&M) Starts
Federal Facility Five-Year Reviews
RABs
Technical Assistance Grants (TAGs)
Operating Properly and Successfully (OPS)
External
Program
Reporting
Internal
Program
Reporting
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Measure
Key to Reporting Hierarchy
ACS = Regional targets are established in Annual Commitment System.
Strategic Plan = National target is publicly reported in Agency FY11-FY15 Strategic Plan.
Target = SCAP target and reporting measure.
Measure = SCAP reporting measure, but target not required.
VIII.B.2 Federal Facilities Site Discovery/Site Assessment Definitions
a. Remedial Site Initiation (Discovery)
Remedial Site Initiation (Discovery) is the process by which a potential hazardous waste
site is entered into the SEMS inventory for NPL assessment activities. All sites moving
through the NPL assessment process must have a Remedial Site Assessment Initiation
milestone and actual completion date documented in SEMS. Entry of the Remedial Site
Assessment Initiation date initiates the NPL assessment process and places the site on the
Federal Facility (FF) Preliminary Assessment Review backlog.
The process typically starts when the facility has been listed on the Federal Agency
Hazardous Waste Compliance Docket. NOTE: There may be instances when a facility
included in the docket may not be listed in the SEMS database.
Work Package
Activity/Milestone
Remedial Site Initiation
(Discovery)
Performance
Lead
EPA, EPA In-
House, Tribe,
State, FF
Activity/Milestone Date Requirements
Start/Finish: After the region determines the federal
facility is a valid CERCLA site, the site discovery date
for federal facilities is the date the site is formally added
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Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
to the Federal Agency Hazardous Waste Compliance
Docket.
Special Planning/Reporting Requirements:
Planned start/complete dates will automatically be generated in Primavera when a new
site is added to SEMS. The same calendar date should be entered for both the Remedial
Site Initiation (Discovery) actual start and actual complete date. The actual start/complete
date must not be earlier than the Pre-CERCLA Screening complete date. Multiple
Remedial Site Initiation (Discovery) activities are not allowed.
Note: The Removal Site Initiation (Discovery) activity is used by the removal program to
track initiation of sites that have Superfund removal interest. Sites with only removal
interest should not have a Remedial Site Initiation (Discovery) activity tracked in SEMS.
Sites with only remedial assessment interest should not have a Removal Site Initiation
(Discovery) activity tracked in SEMS. Sites with both removal and remedial assessment
interest should have both a Removal Site Initiation (Discovery) activity and a Remedial
Site Initiation (Discovery) activity. The Remedial Site Initiation (Discovery) actual
start/complete date for a site referred from removal to remedial assessment or from
RCRA to remedial assessment should be the date the referral decision is made.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new activities and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate.
Site discovery is an internal program measure.
b. Federal Facility Preliminary Assessment Reviews
Federal Facility PA Review is a quality assurance review of a PA or PA-equivalent report
submitted by another federal agency. EPA's role at federal facilities is to review PA
reports developed and submitted by the federal agencies responsible for a given federal
facility. EPA may also approve the review done by a state in lieu of its review. Upon
reviewing the PA or PA-equivalent report for accuracy, completeness, and working with
the other federal agency to address any deficiencies, EPA then determines what next
steps are appropriate with respect to additional response action. Guidance can be found in
the Federal Facilities Remedial Preliminary Assessment Summary Guide (July 21, 2005)
(http ://www2. epa. gov/fedfac).
There are instances when an Abbreviated Preliminary Assessment (APA) can be
performed in lieu of a standard PA. The October, 1999 Abbreviated Preliminary
Assessment fact sheet (OSWER 9375.2-09FS) provides information on conducting APAs
and includes a checklist to help site assessors determine whether an APA report is
appropriate for a given site. The checklist or an equivalent document can serve as
documentation that the APA was completed. The APA checklist or equivalent report
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must address the requirements set forth in the NCP for conducting remedial preliminary
assessments.
Once a federal facility site has been entered into the SEMS site inventory for remedial
assessment, an APA may be performed if the site/release:
• is regulated under a statutory exclusion (e.g., petroleum);
• is subject to certain limitations based on definitions in CERCLA (e.g., naturally
occurring substance in its unaltered form);
• can be addressed as part of another site already in SEMS;
• will be deferred to another program (e.g., RCRA, Nuclear Regulatory
Commission (NRC), EPA removal) based on existing policy considerations
(follow-up confirmation of the deferral is required);
• requires no further remedial assessment; or
• will require a Superfund site inspection.
Backlogs: The Federal Facility PA Review backlog consists of federal facility sites with a
Non-NPL Status of FF-PA review needed or FF-PA review ongoing.
Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
Start: EPA starts an in-house review of the Federal
FF Preliminary Assessment
Review
EPA, EPA In-
House
Facility PA or PA-equivalent report, or sends a letter,
form, or memo to the EPA contractor requesting review
of the federal facility PA or PA-equivalent report.
Finish: Letter, form, or memo approving the PA report
is signed by the appropriate regional official. The Site
Decision Form 9100-3 or equivalent decision document
must be printed, signed by the appropriate regional
official, and placed in the file.
Special Planning/Reporting Requirements:
Regions should attempt to complete PA reviews at federal facility sites listed in the
SEMS inventory within a reasonable schedule upon receipt of a sufficient PA. PA review
starts and completions are reported site-specifically in SEMS. Federal Facility
Preliminary Assessment Review starts and completions are internal program measures.
An action qualifier representing a valid decision must be recorded in SEMS (see chapter
V for a list of valid qualifiers).
If the Federal Facility PA report does not provide sufficient information to complete the
PA, the report should be referred back to the federal facility. The actual finish date and
qualifier for the Federal Facility Preliminary Assessment Review should not be entered
until all the report deficiencies have been addressed.
An Abbreviated Preliminary Assessment report at a federal facility is tracked in SEMS
by entering a Federal Facility PA Review activity and selecting APA as a critical
indicator on the Federal Facility PA Review activity in the Work Package Info screen.
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Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new actions and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate.
c. Federal Facility Site Inspection Reviews
Federal Facility Site Inspection Review is a quality assurance review of an SI or Si-
equivalent report submitted by another federal agency. EPA's role at federal facilities is
to review SI reports developed and submitted by the federal agencies responsible for a
given federal facility response. Upon reviewing the SI or Si-equivalent report for
accuracy, completeness, and working with the other federal agency to address any
deficiencies, EPA then determines what next steps are appropriate. Guidance can be
found at Federal Facilities Remedial Site Inspection Summary Guide (July 21, 2005)
(http ://www2. epa. gov/fedfac).
Backlogs: The Federal Facility SI Review backlog consists of sites with a Non-NPL
Status of FF-SI review needed or FF-SI review ongoing.
Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
Start: EPA starts an in-house review of the Federal
Federal Facility SI Review
EPA, EPA In-
House
Facility SI or Si-equivalent.
Finish: Letter, form, or memo approving the SI report is
signed by the appropriate regional official. The Site
Decision Form 9100-3 or equivalent decision document
must be printed, signed by the appropriate regional
official, and placed in the file.
Special Planning/Reporting Requirements:
Regions should attempt to complete SI reviews at federal facility sites listed in the SEMS
inventory within a reasonable schedule upon receipt of a sufficient SI. SI review starts
and completions are reported site-specifically in SEMS. Federal Facility Site Inspection
Review starts and completions are internal program measures. An action qualifier
representing a valid decision must be recorded in SEMS (see chapter V for a list of valid
qualifiers).
If the Federal Facility SI report does not provide sufficient information to complete the
SI, the report should be referred back to the federal facility. The actual finish date and
qualifier for the Federal Facility Site Inspection Review should not be entered until all the
report deficiencies have been addressed.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new actions and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate.
d. Federal Facility Expanded Site Inspection (ESI) Reviews
Federal Facility Expanded Site Inspection (ESI) Review is a quality assurance review of
an ESI or ESI-equivalent report submitted by another federal agency. EPA's role at
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federal facilities is to review ESI reports developed and submitted by the federal agencies
responsible for a given federal facility. Upon reviewing the ESI or ESI-equivalent report
for completeness, and working with the other federal agency to address any deficiencies,
EPA then determines what next steps are appropriate with respect to NPL listing.
Backlogs: The Federal Facility ESI Review backlog consists of sites with a Non-NPL
Status of FF-ESI review needed or FF-ESI review ongoing.
Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
Start: EPA starts an in-house review of the Federal
Federal Facility ESI Review
EPA, EPA In-
House
Facility ESI or ESI-equivalent.
Finish: Letter, form, or memo approving the ESI report
is signed by the appropriate regional official. The Site
Decision Form 9100-3 or equivalent decision document
must be printed, signed by the appropriate regional
official, and placed in the file.
Special Planning/Reporting Requirements:
Regions should attempt to complete ESI reviews at federal facility sites listed in the
SEMS inventory within a reasonable schedule upon receipt of a sufficient ESI. ESI
review starts and completions are reported site-specifically in SEMS. Federal Facility
Expanded Site Inspection Review starts and completions are internal program measures.
An action qualifier representing a valid decision must be recorded in SEMS (see chapter
V for a list of valid qualifiers).
If the Federal Facility ESI report does not provide sufficient information to complete the
ESI, the report should be referred back to the federal facility. The actual completion date
and qualifier for the federal facility Expanded Site Inspection Review should not be
entered until all the report deficiencies have been addressed.
Regions are responsible for maintaining the accuracy of the non-NPL status for every
non-NPL site in the SEMS inventory. As new actions and new dates are entered into
SEMS, the system will ask the user to confirm or change this value as appropriate.
VIII.B.3 Federal Facilities Accomplishment Definitions
a. Base Closure Decisions
A base closure action occurs when EPA is involved in either a CERCLA section
120(h)(4) uncontaminated parcel CERFA determination, a Finding of Suitability to
Transfer (FOST), a Finding of Suitability to Lease (FOSL), or a determination is made by
EPA that an approved remedy is OPS at BRAC locations pursuant to CERCLA section
120(h)(3). Under CERCLA section 120(h)(4), the military service must designate, and
EPA/state is required to concur, on property that is uncontaminated. A FOST documents
the conclusion that real property made available through the BRAC process is
environmentally suitable for transfer by deed under the CERFA amendment to CERCLA.
A FOSL documents that property at a BRAC location is environmentally suitable for
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lease, i.e., that the reuse does not impede the environmental response at the location and
that the use of the property is limited to a manner which will protect human health and
the environment. Under CERCLA section 120(h)(3), before property can be transferred
by deed, the military service must demonstrate to EPA that the approved remedy is
operating properly and successfully.
The phrase "operating properly and successfully" involves two separate concepts:
operating "properly" is used if the remedy is operating as designed; operating
"successfully" is used if the operation of the remedy will achieve the cleanup levels or
performance goals for the particular contaminant delineated in the decision document.
Where more than one remedial action is required for a parcel, all such actions must
operate properly and successfully. Therefore, EPA interprets the term "operating properly
and successfully" to mean that the remedial action was engineered and implemented and
is functioning in such a manner that it is expected to achieve cleanup goals and
adequately protect human health and the environment.
Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
Start: EPA receives a document that identifies a facility
FFFinding of Suitability to
Transfer (POST)
FF Finding of Suitability to
Early Transfer (FOSET)
FF Finding of Suitability to
Lease (FOSL)
EPA In-House
or a parcel as a candidate to be transferred by deed or
lease (e.g., Environmental Baseline Study (BBS)
submitted); or EPA receives a clean parcel
determination for concurrence as required by CERFA;
or EPA receives a written request submitted by the other
federal agency for concurrence on suitability to transfer
or lease; or EPA receives a written request for EPA
concurrence that a 120(h)(3) remedy is operating
properly and successfully.
Finish: Letter, form, or memo stating that EPA has
completed its review and provided comments or
concurrence on the POST or FOSL signed by the
appropriate regional official; or letter, form, or memo
stating that EPA has completed its review of the
demonstration that a remedy is operating properly and
successfully for purposes of CERCLA section 120(h)(3)
signed by the appropriate regional official; or letter
concurring on a clean parcel identified under CERFA
signed by the appropriate regional official.
Special Planning/Reporting Requirements:
In addition to entering the finish date, regions must also enter the acreage covered by the
Base Closure Decision Document. Acreage information can be entered through the POST
or FOSL screens in SEMS.
b. Non-BRAC Property Actions
A non-BRAC property transfer action occurs when EPA has reviewed and concurred on:
• The transfer of non-BRAC property from the federal government under CERCLA
120(h)(3)(A): A federal agency may request that EPA review and
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comment/concur on transfers under this section, however, EPA does not
statutorily have to provide concurrence or comment for the transfer to occur, other
than in instances where an OPS determination is required to be made prior to the
transfer of deed.
An early transfer under CERCLA 120(h)(3)(C): For facilities listed on the NPL,
EPA is required to approve the deferral of the covenant found in CERCLA
120(h)(3)(A)(ii)(I) that all remedial action necessary to protect human health and
the environment has been taken before the date of transfer. The EPA Early
Transfer Guidance should be used to approve such requests.
Provided an OPS determination pursuant to CERCLA 120(h)(3): Under
CERCLA section 120(h)(3), before property can be transferred by deed, the
federal department or agency must demonstrate to EPA that the approved remedy
is operating properly and successfully.
Provided a concurrence to DOE for the lease of property on the NPL under the
Hall Amendment: Leasing of real property at DOE weapons production facilities
that are either being closed or reconfigured is subject to the requirements of the
Hall Amendment under the following conditions: 1) the Hall Amendment is the
authority invoked for a lease, and 2) the real property to be leased is on the NPL.
In these cases, DOE must request the concurrence of the EPA Regional
Administrator for the proposed lease. DOE may lease if EPA concurs within 60
days or EPA fails to respond to DOE's concurrence request after 60 days. The
Joint DOE/EPA Interim Policy Statement on Leasing Under the Hall Amendment
(1998) governs these leases.
Made a CERCLA 120(h)(4) uncontaminated parcel determination: Under the
CERFA amendment to CERCLA section 120(h)(4), the federal department or
agency must designate, and EPA is required to concur, on property that is a part
of a facility listed on the NPL that is uncontaminated. For property not closed or
realigned pursuant to a base closure law, the identification and concurrence is
required to be made at least six months before the termination of operations on the
facility.
Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
Start: EPA receives a written request submitted by the
FFFinding of Suitability to
Transfer (POST)
FF Finding of Suitability to
Early Transfer (FOSET)
FF Finding of Suitability to
Lease (FOSL)
EPA In-House
other federal agency for EPA concurrence on suitability
to transfer, including early transfers, or lease; or EPA
receives a clean parcel determination for concurrence as
required by CERFA; or EPA receives a written request
for EPA concurrence that a 120(h)(3) remedy is
operating properly and successfully.
Finish: Letter, form, or memo stating that EPA has
completed its review and provided comments or
concurrence on the transfer or leasing document(s) is
signed by the appropriate regional official; or Letter,
form, or memo stating that EPA has completed its
review of the demonstration that a remedy is operating
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Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
properly and successfully for purposes of CERCLA
section 120(h)(3) is signed by the appropriate regional
official; or Letter concurring on a clean parcel identified
under CERFA is signed by the appropriate regional
official.
Special Planning/Reporting Requirements:
In addition to entering the finish date, regions must also enter the acreage covered by the
property action. Acreage information can be entered through the POST or FOSL screens
in SEMS.
c. Federal Facility Agreement (FFA)TInteragency Agreement (IA)
FFAs/IAs are legal agreements between federal agencies responsible for cleanup, EPA,
and the states. A state elects whether to participate in FFA/IA negotiations. FFA/IAs set
forth detailed requirements for performance of site response activities as well as penalties
for non-compliance with the FFA/IA. The FFA/IA requirement is set forth in section
120(e) of CERCLA. Such agreements are required at NPL facilities no later than six
months after the first ROD is signed at the facility.
Work Package
Activity/Milestone
FFA/IA Negotiation
Performance
Lead
EPA In House
Activity/Milestone Date Requirements
Start: Notice letter is sent by EPA to the federal facility.
Finish: FFA/IA is signed by the federal asencv, EPA,
and/or state.
Special Planning/Reporting Requirements:
This is an internal program measure. Regions do not receive credit for FFA/IA
completion when the FFA/IA is elevated to HQ for dispute resolution.
d. Federal Facility Dispute Resolution
When the federal agency, state, and/or EPA make an effort to formally resolve a FFA/IA
dispute after the FFA/IA is signed.
Work Package
Activity/Milestone
Performance
Lead
/Activity/Milestone Date Requirements
Start: Letter from any party of the FFA/IA to the other
Alternative Dispute Resolution
EPA In-House
parties notifying them as to the issue in dispute.
Finish: Document resolving the issue is signed by the
appropriate regional official (e.g., letter of agreement,
agreement document).
Special Planning/Reporting Requirements:
This is an internal program measure.
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e. Remedial Investigation/Feasibility Study (RI/FS) or RCRA Facility Investigation
(RFI) Starts
The RI/FS is a CERCLA investigation designed to characterize the site, assess the nature
and extent of contamination, evaluate potential risks to human health and the
environment, and develop and evaluate potential remedial alternatives. A RFI is a RCRA
investigation designed to evaluate thoroughly the nature and extent of the release of
hazardous wastes and hazardous constituents and to gather necessary data to support the
Corrective Measure Study (CMS) and/or ISM.
Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
FFRI/FS
FFRI
RCRA Facility Investigation
FF
If there has been no Previous RI/FS or RFI work or
RI/FS or RFI work started prior to the FFA/IA effective
date and there has been substantial EPA or state
involvement (EPA or the state has reviewed and
commented, approved/concurred, or accepted the work
plan)
Start: RI/FS or RFI draft work plan received by EPA or
State
If RI/FS or RFI work starts prior to the FFA/IA effective
date and there has been limited EPA or state
involvement:
Start: FFA/IA signed by EPA or the state and the other
agency
Finish: Decision document signed by appropriate
regional official
Special Planning/Reporting Requirements:
This is an internal program target and measure.
f. Decision Documents
Upon completion of a Federal Facility RI/FS, CMS, or Engineering Evaluation/Cost
Analysis (EE/CA), the federal agency selects a remedy that is presented in a cleanup
decision document (e.g., ROD, RCRA Statement of Basis/Response to Comments,
Action Memo, Removal Action Decision Document, ROD Amendment or Explanation of
Significant Differences [ESD]). EPA may either approve or concur on the remedy
selection or, in the case of a dispute, EPA may select the remedy. For EPA, this authority
has been delegated to the Regional Administrator or her/his delegate.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
FF Record of Decision,
RCRA Statement of
Basis/Response to Comments,
Removal Action Decision -
Approve EECA/Action
Finish: Decision document signed by the Regional
FF
Administrator or delegate, or the date of EPA
concurrence/approval on the clean-up decision
document pursuant to FFA/IA or other enforceable
decision document, or the date of EPA's letter of
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OSWER Directive 9200.3-15-1G-Y
Work Package
Activity/Milestone
Memorandum,
FF GOVT Remedy Decision
Change
Performance
Lead
Milestone/Activity Date Requirements
concurrence.
Special Planning/Reporting Requirements:
This is an internal program target and measure. One ROD document equals one ROD
target completion, even if the ROD covers multiple OUs. HQ's ROD data entry
contractors will enter in the associated remedy selection information.
The regions should not enter a Remedial Design (RD) or a Remedial Action (RA)
following a "No Action ROD". For RODs which choose limited actions (e.g.,
institutional controls), the regions should not enter a Remedial Design for these RODs.
However, the regions should enter a Remedial Action on the project schedule with the
Critical Indicator of "Limited Action".
g. Final Remedy Selected
This measure will track the Final Remedy Selected at NPL Sites. A Final Remedy
Selected occurs when a final decision has taken place at a site (i.e. the final remedy has
been selected at the last OU of a site). This can include the signature of the Final ROD,
ROD Amendment or Removal Action at a site. In general, an BSD will not constitute a
Final Remedy Selected since ESDs document a non-fundamental change to a remedy.
Also, a partial deletion from the NPL does not constitute a Final Remedy Selected since it
does not constitute a final decision for the entire site.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
FF Record of Decision,
RCRA Statement of
Basis/Response to Comments,
Removal Action Decision -
Approve EECA/Action
Memorandum,
FF GOVT Remedy Decision
Change (ROD Amendment
Only)
FF
Finish: Decision document signed by the Regional
Administrator or delegate when no planned ROD, ROD
Amendment, Removal Action Memorandum, RI/FS, or
EE/CA exist at the site.
Preliminary Close-Out Report
EPA In-House
Finish: Site is Construction Complete with Preliminary
Close-Out report signed by EPA, and no future ROD,
ROD Amendment, Action Memorandum, RI/FS or
EE/CA is planned and no previous ROD, ROD
Amendment, or Action Memorandum exists that
constitutes the final decision.
Final Close-Out Report
EPA In-House
Finish: Site is Construction Complete with Final Close-
Out report signed by EPA, and no future ROD, ROD
Amendment, Action Memorandum, RI/FS or EE/CA is
FY 15 SPIM
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September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
planned.
Finish: Notice of Deletion is published in the Federal
Final Deletion from NPL
EPA In-House
Register and no future ROD, ROD Amendment, Action
Memorandum, RI/FS or EE/CA is planned and there is
no Preliminary Close-Out Report (PCOR) and no
previous ROD, ROD Amendment or Action
Memorandum that constitutes the final decision.
Special Planning/Reporting Requirements:
This is an internal program target and measure. To receive Final Remedy Decision credit
when a site is Construction Complete, the site must have the Construction Completion
indicator in SEMS (entered by HQ) and no future ROD, ROD Amendment, Action
Memorandum, RI/FS or EE/CA is planned at the site. The Final Remedy qualifier must
be selected for the activity that represents the final remedy.
h. Remedy Decision Changes
A ROD Amendment documents fundamental changes to the remedy selected in the ROD.
Fundamental changes involve an appreciable change or changes in the scope,
performance, and/or cost or may be a number of significant changes that together have
the effect of a fundamental change. HQ's ROD data entry contractors will enter in the
associated remedy selection information.
An ESD documents significant changes to a ROD. Significant changes generally involve
a change to a component of a remedy that does not fundamentally alter the overall
cleanup approach. HQ's ROD data entry contractors will enter in the associated remedy
selection information.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
ROD Amendment
FF
Finish: ROD Amendment signed by the Regional
Administrator or delegate, or the date of EPA
concurrence/approval on the cleanup decision document
pursuant to FFA/IA or other enforceable decision
document, or the date of EPA's letter of concurrence
Explanation of Significant
Differences
FF
Finish: ESD signed by the Regional Administrator or
delegate, or the date of EPA concurrence/approval on
the cleanup decision document pursuant to FFA/IA or
other enforceable decision document, or the date of
EPA's letter of concurrence
Special Planning/Reporting Requirements:
ROD Amendments and ESDs count towards the program target for Decision Documents.
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OSWER Directive 9200.3-15-1G-Y
i. Remedial Design (RD) or RCRA Corrective Measure Design (CMD)
The RD is a CERCLA design that establishes the general size, scope, and character of a
project, and details and addresses the technical requirements of the RA selected in the
ROD. The RD may include, but is not limited to, drawings, specification documentation,
and statement of bidability and constructability. The CMD is a RCRA design that
establishes the general size, scope, and character of a project, and details and addresses
the technical requirements of the CMD selected in the RCRA Corrective Measure
decision document. The CMD may include, but is not limited to, drawings, specification
documentation, and statement of bidability and constructability. A RD or CMD is
complete when the plans and specifications for the selected remedy are developed and
approved.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
Start: Post ROD - RD or CMD work plan or other
FF Remedial Design/RCRA
Corrective Action Design
FF
appropriate documents or statement of work submitted
Pre-ROD - ROD signed by the Regional Administrator
or delegate or RD or CMD work plan or other major
deliverable submitted
Finish: Letter approving the entire final RD or CMD
package is signed or Commerce Business Daily (CBD)
or other appropriate publication requesting bids on the
final RD or CMD package is published.
Special Planning/Reporting Requirements:
This is an internal program measure.
j. Remedial Action (RA) or RCRA Corrective Measure Implementation (CMI)
A RA or CMI is the implementation of the remedy selected in the ROD or appropriate
RCRA corrective measure decision document at NPL sites to ensure protection of human
health and the environment. A RA or CMI is complete when construction activities are
complete, a final inspection has been conducted, and an RA Report or appropriate CMI
reporting vehicle has been prepared and approved by EPA in writing. This report
summarizes site conditions and construction activities. Note: This date may be later than
12 0(h)(3) BRAC requirements for base closure.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
Start: Memo or letter to EPA documenting the date on
FFRA/RCRA
Corrective Action
Construction
FF
which substantial, continuous, physical, on site,
remedial actions began
Finish: RA Report approved in writing by Branch Chief
or delegate or CMI Reporting vehicle documenting the
completion of construction activities signed by the
Branch Chief or delegate
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OSWER Directive 9200.3-15-1G-Y
Special Planning/Reporting Requirements:
RA or CMI Starts is an internal program target and measure. RA or CMI completions is a
program target. RA or CMI completions are reported site specifically in SEMS. In lieu of
a report from the contractor's construction manager, the region must prepare a report to
document the completion. The approval can be provided with an appropriate signature on
the RA Report cover sheet or by letter to the originator of the RA Report.
Beginning in FY 2011, the Superfund program began reporting "Remedial Action Project
Completions" as a key program measure with an annual target. The measure includes
Fund, Potentially Responsible Party (PRP) (including special account-funded) and
Federal Facility RA completions at final and deleted NPL sites. The new measure is
intended to augment the existing site-wide Construction Completion measure and reflect
the large amount of work being done at Superfund sites. Reporting on the new measure
will provide valuable information to communities by demonstrating incremental progress
in reducing risk to human health and the environment at sites.
Examples of Remedial Action completions and criteria for EPA approval of an RA
Report may be found in chapter 2 of the Close Out Procedures for National Priorities
List Sites (OSWER 9320.2-22, May 2011).
September 30, 2014 VIII-28 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
EXHIBIT VIII.2. REMEDIAL PIPELINE FLOW CHARTS
Treatment and Off-site Disposal Remedies Pipeline
Final
RA Report
RA
For example; blare mediation. SVE
OPS
(no 0 + M r#qurk«d)
Containment Remedies Pipeline
Final
RA Report
RA
O +M
{no ne«d for OPS)
Ground Water and Surface Water Restoration Pipeline
and Monitored National Attenuation
Intc
RAR
RA
O'PS
Tim Final RA Report
eport (Cleanup Goals
Achieved)
OPS= Operating Properly & Successfully and applies only to BRAC sites.
k. Removal or RCRA Interim/Stabilization Measure (ISM)
Removal actions are defined as the cleanup or removal of released hazardous substances
from the environment, and the necessary actions taken in the event of the threat of release
of hazardous substances into the environment. ISMs are defined as RCRA removal
actions that are intended to abate threats to human health and the environment from
releases and/or to prevent or minimize the further spread of contamination while long
term remedies are pursued. Regions need to report removal actions conducted in response
to emergency, time critical (TC), and non-time critical (NTC) situations at BRAC, non
NPL or NPL sites. Under the DERP, DoD is required to notify EPA of its removal
actions. Long term O&M should not be conducted under the removal.
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OSWER Directive 9200.3-15-1G-Y
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
Start: Federal agency begins actual on site removal
FFRemoval
RCRA Interim/Stabilization
Measure
FF
work, or Action Memorandum signed by the appropriate
regional official, or the lead federal agency provides
notice to EPA, or other decision document
signed/approved by the appropriate regional official
Finish: Federal agency notifies EPA of demobilized,
completing the scope of work delineated in the Action
Memorandum or other decision document
Special Planning/Reporting Requirements:
This is an internal program measure.
1. Operation and Maintenance (O&M)
O&M are the activities required to maintain the effectiveness or integrity of the remedy
including institutional controls. Except in the case of groundwater or surface restoration
remedies, including monitored natural attenuation, O&M measures are initiated after
cleanup goals are achieved, and the remedy is operating as intended. In the case of
groundwater or surface water restoration remedies, including monitored natural
attenuation, O&M measures are initiated when the remedy is operating as intended.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
Start: Remedial Action Report is approved in writing
FF Operations and
Maintenance
FF
by designated EPA regional official (Branch Chief or
above, as determined by the EPA region)
Finish: Where appropriate, the completion of O&M is
defined as the date specified in the FFA/IA.
Special Planning/Reporting Requirements:
O&M Start is an internal program measure.
m. Cleanup Goals Achieved
This measure is used to indicate when cleanup objectives are achieved for groundwater
and surface water restoration, including monitored natural attenuation. It tracks
achievement of cleanup objectives for these remedies because they have not yet achieved
cleanup objectives at the time of Remedial Action completion.
Work Package
Activity/Milestone
Cleanup Goals Achieved
Performance
Lead
FF
Milestone/Activity Date Requirements
Finish: Valid monitoring data demonstrating restoration
goals have been achieved are documented in the O&M
Report
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OSWER Directive 9200.3-15-1G-Y
Special Planning/Reporting Requirements:
This activity may be tracked by HQ for program management purposes, but it is not a
program target or measure.
n. Percent Construction Completion
The percent construction complete measure is based on the average of three specific
factors at each federal facility NPL site: 1) OU percent complete; 2) Total actions percent
complete; and 3) Duration of actions percent complete (see definitions below). To reflect
progress at each site, HQ will calculate the percentage complete for each of the three
factors and determine the average of the factors combined. This combined average will
reflect the percent construction complete at each site. HQ will then calculate the national
average of all site-specific percentages. EPA's yearly target will be the net increase in the
national % construction complete (CC) for NPL FF sites. The table below outlines the
method of calculating each of the three specific factors that make up the percent
construction complete measure.
OU percent complete
Total actions percent
complete
Duration of actions
percent complete
Numerator: Count of operable units designated as OU
CC (including OUs with no actions).
Denominator: Count of all operable units (including OUs
with no actions).
Numerator: Count of completed RI/FS, Decision
Documents, Action Memos, ROD Amendments, Remedial
Designs, Remedial Actions, and Removals with FF lead.
Denominator: Count of all RI/FS, Decision Documents,
Action Memos, ROD Amendments, Remedial Designs,
Remedial Actions, and Removals with FF lead.
Numerator: Duration of completed actions plus duration
from start date to current date for ongoing actions for
RI/FS, Remedial Designs, Remedial Actions, and
Removals with FF lead.
Denominator: Duration of all actions (planned, actual,
ongoing) for RI/FS, Remedial Designs, Remedial Actions,
and Removals with FF lead.
Special Planning/Reporting Requirements:
EPA will verify and release certified data after the end of each fiscal year.
o. Federal Facility Five-Year Reviews
A Five Year Review is a review of remedial action(s) selected under CERCLA section
121(c). The purpose of the Five Year Review is to determine whether the remedy at a site
is/remains protective of human health and the environment and to evaluate the
implementation and performance of the selected remedy. Where remedial actions are
either still under construction or completed, a Five Year Review determines whether
immediate threats have been addressed and whether EPA continues to expect the remedy
to be protective when all remedial actions are complete. EPA conducts statutory reviews
FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
of any site at which a post-SARA remedy, upon attainment of cleanup levels specified in
the ROD, will not allow for unlimited use and unrestricted exposure (UU/UE). EPA
conducts policy reviews at sites where remedial actions will attain cleanup levels that,
upon completion will allow for UU/UE but will take longer than five years to complete,
at sites with pre-SARA remedies at which cleanup levels do not allow for UU/UE, and at
NPL removal only sites where cleanup levels do not allow unlimited use and unrestricted
exposure. Discretionary reviews may be conducted at the discretion of the Lead agency.
Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
FF Five Year Review
FF
Start: Five-year review work plan submitted by the
other federal agency is approved by EPA or federal
facility starts the review or submits the draft document
for review, as outlined in the ROD or IA
Finish: Five-year review report, stating whether the
remedy is or is not protective of human health and the
environment or on the date the region has issued its own
protectiveness determination, is signed by the designated
regional official or regional protectiveness
determination, if the region non-concurs with the
protectiveness statement in the report
FF Five Year Review
Addendum
FF
Start: Five-year review Addendum work plan submitted
by the other federal agency is approved by EPA
Finish: Five-year review addendum, stating a new
protectiveness determination of all remedies that have
deferred protectiveness determinations is signed by the
designated regional official
Statutory: The 1st FF FYR planned finish date should be scheduled for five years after
the Federal Facility RA activity planned start date. All subsequent FF FYRs are
scheduled for five years after the planned completion date of the previous FYR.
Policy: The 1st FF FYR planned finish date should be scheduled for five years after the
date the site achieved Construction Completion. All subsequent FF FYRs are schedulef
for five years after the planned completion date of the previous FYR.
The Five-Year Review Addendum planned finish date should be consistent with the date
entered into the Five-Year Review protectiveness determination tab in the "Planned Date
of Addendum" text box for sites that have a "Protectiveness Deferred" OU-specific or
sitewide determination.
Special Planning/Reporting Requirements:
Five-year Review completion is an internal program target and measure. Five-year
review completions must be planned and reported site-specifically in SEMS. There are
multiple triggers for five-year reviews. Please reference program guidance available at
http://www.epa.gov/superfund/cleanup/postconstruction/5yr.htm to select the appropriate
method for calculating the Five-Year Review date.
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FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Situations do occur where multiple NPL sites are covered under a single five-year review
report. In these situations the date of the report will be used to signify the completion of
the five-year review for each of the NPL sites.
The following information is captured in the SEMS Five Year Review data entry forms:
• The type of Five Year Review (e.g., statutory, policy or discretionary)
• The ability to modify the Five Year Review type on a planned review only if
changing from a discretionary review to a policy or statutory review or changing
from a policy review to a statutory review;
• The ability to associate issues/recommendations with a specific OU;
• The ability to enter/track more than one Five Year Review with multiple OUs for
each site;
• A Missing Accomplishment Data tab informs the user of all missing information;
and
• The ability to update milestone dates and track the current status of
implementation for Five Year Review Issues and Recommendations.
In order to receive credit for a Federal Facility Five Year Review completion the region
must enter the following data into SEMS:
• applicable OUs
• associated issue for each OU (if there is no issue, enter the relevant OU(s) with
the "No Issue" category)
• recommendations or follow-up actions (a party responsible, oversight agency, and
milestone date must be identified for each recommendation or follow-up action)
• protectiveness determination for each remedy/OU (if a determination is deferred,
enter a date for when a protectiveness determination will be made)
• protectiveness statement as it appears in the Five Year Review
If the Construction Completion flag has been checked for the site, the user must enter the
following information:
• site protectiveness determination
• site-wide protectiveness statement as it appears in the Five Year Review
In order to receive credit for the FYR Addendum completion, the user must enter the
following information:
• The new protectiveness determination for those OUs that were deferred;
• Protectiveness statement as it appears in the parent Five Year Review; and
• If new issues/recommendations are referenced in the Five Year Review
Addendum, enter them into the Five Year Review screens through the FYR parent
action for the addendum.
All Sites must have the following information:
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OSWER Directive 9200.3-15-1G-Y
• If future Five Year Reviews are not necessary at the site, indicate that this is the
final Five Year Review at the site by selecting the "no" radio button under the
heading asking whether future FYRs are necessary. The user should also enter a
description of the reason why future reviews are not needed. If future FYRs are
necessary, select the "yes" radio button.
VIII.B.4 Community Involvement Definitions
The following section contains Community Involvement requirements for federal
facilities. Community Involvement requirements for non-federal facility sites are included in
chapter X.
a. Restoration Advisory Boards (RABs)/Site-Specific Advisory Boards (SSABs)
Site-Specific Advisory Boards (SSABs) are a forum for concerned stakeholders to
provide advice and recommendations on DOE's Environmental Management strategic
decisions. RABs provide a forum through which members of nearby communities can
provide input to DoD's environmental restoration program. RABs and SSABs
complement other community involvement activities, such as public meetings, mailings,
and local information repositories.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
Restoration Advisory Board
(RAB)/Site-Specific Advisory
Board(SSAB FF CI)
Start: Initial RAB/SSAB information meeting
FF
establishing the Board
Finish: RAB is adjourned by DoD or SSAB is
terminated by the Secretary of Energy
Special Planning/Reporting Requirements:
This is an internal program measure.
b. Technical Assistance Grants (TAGs)
SARA established the TAG program to provide technical assistance to eligible
communities. This technical assistance allows communities to improve the decision
making process at their sites.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
Start: Award document signed by the regional award
Technical Assistance Grant
EPA In-House
official
Finish: Award document, one year extension document,
time period extension document, or other documents,
such as a memo to the file prepared by the TAG
coordinator documenting the ending date of the budget
and project period.
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OSWER Directive 9200.3-15-1G-Y
Special Planning/Reporting Requirements:
TAG is an internal program measure. Planned start and finish dates are required in
SEMS. The planned or actual finish date in SEMS (whichever is applicable) must be
changed to reflect the date of the most recent source document, e.g., award document,
one-year extension document, memo to the file, etc. These definitions may be applied to
all historical activities, including data prior to FY 89, which is the first fiscal year TAG
appeared in the Superfund Program Implementation Manual (SPEVI). In addition, the
TAG completion definitions from previous years may also be used for TAGs completed
within those years.
Funds may be planned site-or non-site specifically; however, they must be obligated site
specifically. Funds for TAGs at federal facility sites are contained in the federal facility
budget and found in the Federal Facility Site Allowance.
VIII.B.5 Cleanup Privatization at BRAC NPL Sites
At Department of Defense (DoD) BRAC sites, EPA recognizes that the privatization of
the cleanup, where a developer or other organization rather than the military conducts the
cleanup using funds provided by DoD, can present an opportunity to integrate redevelopment
planning with cleanup. Such privatized cleanups provides another option to federal and state
agencies and local communities to help maximize the impact of cleanup and redevelopment
resources to help move properties back into productive reuse more quickly.
Privatization is an early transfer of property. In order to conduct an early transfer of
property, DoD must request a deferral of the covenant required by CERCLA section
120(h)(3)(A)(ii)(I) ensuring that all remedial action necessary has been completed prior to
transfer by the federal government. For NPL installation, EPA and the Governor of the state
must approve such requests.
Regions should follow EPA Guidance on the Transfer of Federal Property by Deed
Before All Necessary Remedial Action Has Been Taken Pursuant to CERCLA section (120(h)(3)
(Early Transfer Guidance) (June 1998) (http://www2.epa.gov/fedfac) when reviewing covenant
deferral requests from other federal agencies. Where institutional controls are or will be required
as part of the early transfer, regions should also consult the Institutional Controls and Transfer of
Real Property under CERCLA section 120(h)(3)(A), (B) or (C) Guidance
(http://www2.epa.gov/fedfac). DoD often transmits the information used by EPA to review and
approve an early transfer through a FOSET. EPA's guidance discusses the requirements found in
CERCLA 120(h)(3)(C) and how they are related to EPA approval of the FOSET and deferral of
the covenant.
Work Package
Activity/Milestone
Removal Action Decision -
Approve EECA/Action
Memorandum
FF Removal
Performance
Lead
FF
FF
Activity/Milestone Date Requirements
Finish: Action Memo signed bv designated regional
official
Start: Pollution Report documenting that Private Party
and their contractor mobilized at the site to perform the
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OSWER Directive 9200.3-15-1G-Y
Work Package
Activity/Milestone
FF Engineering
Evaluation/Cost Analysis
FFRI
FFRI/FS
Public Comment Period
Record of Decision
FFRD
FFRA
Performance
Lead
FF
FF
EPA In-House
FF
FF
FF
Activity/Milestone Date Requirements
removal action. (Critical Indicator = TC or NTC).
Finish: Final Pollution Report documenting that Private
Party and their contractor have completed actions
specified in the action memo and have demobilized from
the site.
Start: EE/CA Approval Memo approved bv EPA.
Finish: EE/CA Action Memo approved bv EPA.
Start: RI or RI/FS draft work plan received from Private
Party.
Finish: Record of Decision signed bv designated
regional official
Start: Letter transmitting RI/FS reports and the
proposed plan to the site repository for public review,
signed by the appropriate regional official or first page
of the approved proposed plan is included in the site file.
Finish: Record of Decision signed bv designated
regional official
Start: RD draft work plan received from Private Party.
Finish: RD Report approved bv EPA.
Start: RA draft work plan received from Private Party.
Finish: RA Report approved bv EPA.
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OSWER Directive 9200.3-15-1G-Y
Superfund Program Implementation Manual
FY15
Chapter IX: Enforcement
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the
SPIM (FY2012 - Addendum), available at
http://www.epa.gov/superfund/action/process/spiml2.html
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Superfund Program Implementation Manual
FY15
Chapter X: Community Involvement
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Chapter X: Community Involvement
Table of Contents
X.A INTRODUCTION X-l
X.B COMMUNITY INVOLVEMENT ACTIVITIES X-l
X.B.I Overview of Community Involvement Activities X-l
a. Community Advisory Groups (CAGs) X-l
b. Technical Assistance Grants (TAGs) X-l
c. Technical Assistance Services for Communities (TASC) X-2
X.C National Program Requirements X-3
X.C.I Program Goals and Objectives X-3
X.C.2 Regulatory and Policy Requirements X-3
X.C.3 Roles and Responsibilities X-3
List of Exhibits
Exhibit X.I. HQ and Regional Roles and Responsibilities X-3
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CHAPTER X: COMMUNITY INVOLVEMENT
X.A INTRODUCTION
Community involvement is the process of engaging in dialogue and collaboration with
community members throughout the Superfund process. Community Involvement activities
include Community Advisory Groups (CAGs), Technical Assistance Grants (TAGs), Technical
Assistance Services for Communities (TASC), Just In Time community services, and the
Superfund Job Training Initiative (Super JTI). These activities are the core components of the
Superfund Community Involvement and Program Initiatives Branch's (CIPIB) work to support
EPA's Strategic Plan. While Restoration Advisory Boards (RABs)/Site-Specific Advisory
Boards (SSABs) involve community involvement activities, the work of these Boards is
addressed in the federal facilities section of the Superfund Implementation Manual (SPEVI).
The community involvement data tracked and reported by the program are currently in
review and may be modified in Superfund Enterprise Management System (SEMS) in the future.
The SPEVI will be updated to reflect any system changes and to support the reporting of
community involvement information.
X.B COMMUNITY INVOLVEMENT ACTIVITIES
X.B.I Overview of Community Involvement Activities
This section contains the definitions of the following community involvement activities:
CAGs, TAGs, TASC and the Super JTI.
a. Community Advisory Groups (CAGs)
A CAG is an organized group of local stakeholders representing the diversity of
community interests for a particular Superfund site. CAGs serve as a point for
exchanging information among the local community, EPA, the state regulatory agency,
and other agencies involved in Superfund cleanups. CAGs also provide a forum for
community members to present and discuss their needs and concerns related to the
Superfund decision-making process. CAGs may receive help from EPA, state, tribal and
local governments, and universities in areas such as meeting facilitation, technical
assistance, and administrative support.
Work Package
Activity/Milestone
Community Advisory Group
Performance
Lead
EPA In-House
Activity/Milestone Date Requirements
Start: First meaningful (not interest finding)
Community Advisory Group Meeting is held
Finish: CAG is completed/closed out bv EPA and CAG
b. Technical Assistance Grants (TAGs)
The Superfund Amendments and Reauthorization Act of 1986 (SARA) established the
TAG program to provide technical assistance in interpreting site-related technical
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information to eligible communities. This technical assistance enables communities to
better participate in and inform the decision making process at their sites.
Work Package
Activity/Milestone
Performance
Lead
Activity/Milestone Date Requirements
Start: TAG award document is signed by the regional
award official
Finish: Award document, one year extension document,
Technical Assistance Grant
EPA In-House
time period extension document, or other documents,
such as a memo to the file prepared by the TAG
coordinator documenting the ending date of the budget
and project period.
Special Planning/Reporting Requirements:
Planned start and finish dates are entered in SEMS. Funds may be planned site-or non-
site specifically; however, they must be obligated site specifically. Funds for TAGs at
federal facility sites are contained in the federal facility budget and found in the Federal
Facility Site Allowance.
The planned or actual finish date in SEMS (whichever is applicable) must be changed to
reflect the date of the most recent source document, e.g., award document, one-year
extension document, memo to the file, etc. These definitions may be applied to all
historical Comprehensive Environmental Response, Compensation, and Liability
Information System (CERCLIS) and SEMS data, including data prior to fiscal year (FY)
89, which is the first fiscal year TAG appeared in the SPEVI. In addition, the TAG
completion definitions from previous years may also be used for TAGs completed within
those years.
There can only be one active TAG at a site.
c. Technical Assistance Services for Communities (TASC)
TASC was developed to provide communities that live near hazardous waste sites with
independent technical assistance to help them understand the technical issues related to
hazardous substance contamination and cleanup so that they can substantively participate
in the decision-making process. Just in Time and Super JTI are two related services
provided to communities.
Just in Time community services are offered through the EPA's Conflict Prevention and
Resolution Center contract. The Office of Superfund Remediation and Technology
Innovation (OSRTI) provides regions with access to neutral third party consultation,
collaboration and dispute resolution support services to help prevent, constructively
discuss, and address or resolve difficult issues or conflicts with community members and
other Superfund site stakeholders.
Super JTI provides community members with training and follow on job opportunities,
and fosters partnerships that remain long after a Superfund site is cleaned up.
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Technical Outreach Services for Communities (TOSC) activity data exist in SEMS for
historical purposes only. The TOSC program has been replaced by the TASC program.
Work Package
Activity/Milestone
Performance
Lead
Milestone/Activity Date Requirements
Start: Regional Task Order Monitor/Contracting
Technical Assistance Services
for Communities (TASC)
EPA In-House
Officer's Representative approves technical approach to
site specific project.
Finish: Documentation, such as an evaluation of the
TASC project, marks the completion of the project
period for the TASC services.
X. C NA TIONAL PROGRAM REQUIREMENTS
X.C.I Program Goals and Objectives
The goal of Superfund community involvement is to advocate and strengthen early and
meaningful community participation during Superfund cleanups. Superfund community
involvement staffs at Headquarters and in the regions strive to:
• Encourage and enable community members to get involved.
• Listen carefully to what the community is saying.
• Take the time needed to deal with community concerns.
• Change planned actions where community comments or concerns have merit.
• Keep the community well informed of ongoing and planned activities.
• Explain to the community what EPA has done and why.
X.C.2 Regulatory and Policy Requirements
Section 300 of the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) and subsequent policy directives and guidance documents establish the requirements for
community involvement through every phase of Superfund's cleanup process. These
requirements are specifically outlined in appendix A of the Superfund Community Involvement
Handbook (EPA-540-K-05-003, April 2005).
X.C.3 Roles and Responsibilities
To meet these national program requirements, specific roles and responsibilities have
been identified for the Headquarters (HQ) and regional staff that work in the community
involvement program area. The following table summarizes each of these positions along with
their responsibilities.
EXHIBIT X.l. HQ AND REGIONAL ROLES AND RESPONSIBILITIES
Title
Data Sponsors (HQ)
Responsibilities
Facilitate SEMS staying closely aligned with the Superfund program,
including developing and updating guidance that requires submission of
these data for national reporting needs, maintaining and updating data
element definitions, and developing and implementing the process of
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Title
Managers of Data Sponsors
(HQ)
Data Sponsors (HQ) and
Community Involvement
Managers (regions)
Community Involvement
Coordinators (CICs), Remedial
Project Managers (RPMs) and
On-Scene Coordinators (OSCs)
Information Management
Coordinator (IMC)
Budget Coordinator
Records Manager/Records
Center Staff (regions)
Responsibilities
gathering, reviewing and entering the data into SEMS.
Direct and oversee the creation of useful program policy and guidance to
help the regions achieve program goals. Act as the central point of contact
for the regions and provide regional coordination support.
Participate in program reviews, as well as preparing periodic reports on
regional accomplishments and progress on problems. Respond to quick
turn-around, site specific requests for information from senior management
for Congressional requests, regional visits or other needs. Serve as a forum
for sharing information and lessons learned on community involvement
activities.
Ensure all data necessary to meet the requirements(s) are in SEMS to
support regional reporting needs and commitments to HQ.
Coordinate with the CICs/RPMs/OSCs to ensure data necessary to support
reporting requirements are in SEMS according to timeliness requirements.
Ensure all data necessary to support the regional budget are in SEMS prior
to specified calendar events.
Coordinate with CICs/RPMs/OSCs/DVIC to ensure program records are
properly managed in SEMS and made available in the Administrative
Record and Information Repository, as appropriate.
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Superfund Program Implementation Manual
FY15
Chapter XI: Information Systems
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Chapter XI: Information Systems
Table of Contents
XI. A Information Systems. XI-1
XI.A.1 Overview of SEMS XI-1
a. Remedial Site Assessment (See chapter V) XI-1
b. Removal Program (See chapter VI) XI-2
c. Remedial Program (See chapter VII) XI-2
d. Federal Facility Program (See chapter VIII) XI-3
e. Enforcement Program (See chapter IX) XI-3
f. Community Involvement (See chapter X) XI-4
g. Project Management XI-4
h. Program Management. XI-5
XI.A.2 SEMS System Components XI-5
XI.A.3 Reporting Superfund Information XI-6
XI.A.4 Data Owners/Sponsorship XI-6
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CHAPTER XI: INFORMATION SYSTEMS
XI. A INFORMATION SYSTEMS
The Office of Superfund Remediation and Technology Innovation's (OSRTI)
information systems portfolio has been established to ensure that all Superfund information
technology (IT) investments align with the Environmental Protection Agency (EPA) mission and
support business needs. They are designed to minimize program risks and maximize return on
investment throughout each IT investment's lifecycle. Together the portfolio systems provide a
structured, integrated toolset to assist management and staff to support the business and mission
needs of the Agency.
In fiscal year (FY) 2014, OSRTI completed the integration of several legacy systems into
the Superfund Enterprise Management System (SEMS). This includes the Comprehensive
Environmental Response, Compensation and Liability Information System (CERCLIS),
Superfund Document Management System (SDMS), the Institutional Controls Tracking System
(ICTS), the eFacts reporting tool, and ReportLink. The following points outline the purpose of
SEMS:
• Integrating the primary Superfund data collections, reporting and tracking systems into a
single system;
• Meeting both immediate and strategic, long-term Superfund needs;
• Serving as an official source of primary Superfund site activity data, records, and support
documentation for internal and external stakeholders;
• Improving operational effectiveness, reducing costs, streamlining business processes, and
enhancing information management capabilities; and
• Adapting to meet ever-changing environmental, federal and agency needs yet tailored to
meet the unique requirements of the Superfund program.
XI.A. 1 Overview of SEMS
As a result of the successful integration of multiple legacy systems into SEMS in FY
2014, SEMS is now the official repository of nationally defined and required data for planning,
tracking, and describing all activities at site assessment, remedial and removal sites. SEMS also
continues to serve as the Superfund program's official repository of electronic records (See
chapter XII, Superfund Records). The integrated system is the Superfund program's source of
site information, activity data and supporting documentation across all areas of the pipeline (e.g.,
site assessment, remedial program).
The following sections provide a summary of the information specific to each program
area that is contained in SEMS. Additional guidelines can be found in each associated chapter of
the Superfund Program Implementation Manual (SPEVI).
a. Remedial Site Assessment (See chapter V)
To support the remedial site assessment and National Priorities List (NPL) listing
processes, SEMS provides the following capabilities:
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• Enter, store, and retrieve basic site discovery information, including site
identification (name and location), narrative description, and site setting;
• Identify the Site Assessment Manager (SAM) and other site contacts;
• Distinguish between removal program site initiation and remedial site assessment
program discoveries;
• Enter, store, and retrieve site assessment decision information, including
qualifiers and text rationale, as well as referrals to states or other program areas;
• Manage schedule of site assessment activities through the Primavera site
scheduling tool;
• Store program records that support remedial site assessment and NPL listing
decisions;
• Generate standard reports and perform ad hoc queries; and
• Track information associated with NPL listing actions, including Federal Register
citations, Federal Docket Management System (FDMS) numbers, Hazardous
Ranking System (HRS) scores and changes to NPL status.
b. Removal Program (See chapter VI)
To support the removal process, SEMS provides the following capabilities:
• Manage schedule of removal activities through the Primavera site scheduling tool;
• Identify the On-Scene Coordinator (OSC) and other site contacts;
• Track the type of removal response (e.g., emergency, time critical or non-time
critical), media addressed, contaminants of concern, and response technology.
• Assist in the management of removal budgets for various contract vehicles and
other EPA costs;
• Store program records that support removal program decisions; and
• Generate standard reports and perform ad hoc queries.
c. Remedial Program (See chapter VII)
To support the remedy selection process, SEMS provides the following capabilities:
• Manage schedule of remedial activities through the Primavera site scheduling
tool;
• Identify the Remedial Project Manager (RPM) and other site contacts;
• View and update remedy decision information, including media addressed,
contaminants of concern, and response technology;
• View and update Five Year Review information, including issues,
recommendations and protectiveness statements;
• Track key performance measures for the remedial program, including
Construction Completion, Environmental Indicators and Sitewide Ready for
Anticipated Use;
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• Assist in the management of remedial budgets for various contract vehicles and
other EPA costs;
• Store program records that support remedial program decisions; and
• Generate standard reports and perform ad hoc queries.
d. Federal Facility Program (See chapter VIII)
To support federal facilities, SEMS provides the following capabilities:
• Manage schedule of federal facility activities through the Primavera site
scheduling tool;
• Record, display, and update information pertaining to Base Realignment and
Closure (BRAC) sites, including BRAC types, Fast Track sites, Environmental
Baseline Survey (EBS) information, Finding of Suitability to Lease (FOSL)
information, and Finding of Suitability to Transfer (FOST) information;
• Record and display Federal Facility Docket information;
• Assist in the management of federal facility budgets for various contract vehicles
and other EPA costs;
• Store program records that support federal facility program decisions; and
• Generate standard reports and perform ad hoc queries.
e. Enforcement Program (See chapter IX)
To support the enforcement process, SEMS provides the following capabilities:
• Manage schedule of enforcement activities through the Primavera site scheduling
tool;
• Identify site attorneys and other contacts;
• Capture and retrieve information about Potentially Responsible Parties (PRPs)
and other parties and associate parties with all sites and enforcement actions with
which they have been involved;
• Document a party's involvement type with a site;
• Generate party-related summary statistics;
• Group parties for enforcement actions or correspondence mailings;
• Track party compliance with letters and settlement terms;
• Track liens against a party's property;
• Document the issuance of Comfort/Status letters, the parties they were sent to,
and the intended future use of the property;
• Track the assessment of Prospective Purchaser Agreements (PP As);
• Track negotiations, including type of response actions sought, cost recovery
amount sought, orphan share compensation offered and outcome;
• Track Alternative Dispute Resolution (ADR) usage, identifying sites where ADR
was used, the outcome of the ADR, and the mediator used;
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• Track settlements, type and estimated value of response actions to be performed
by the parties, cost recovery funds achieved, response actions that are being
reimbursed, cash out funds achieved, amount of orphan share that was actually
compensated, amount of funds to be disbursed from a special account or
deposited into a special account as part of the settlement, and whether the
settlement was with de minimis or non-exempt de micromis parties;
• Log case files, including EPA Docket and Department of Justice (DOJ) case
numbers and names and district court location docket number;
• Track referrals, including the type of referral, statutes, response actions sought,
cost recovery amount sought, and outcome;
• Track potential Statute of Limitation (SOL) dates;
• View costs written off and the rationale behind a decision not to pursue cost
recovery;
• Track the timely issuance of oversight bills or accounting of oversight costs
incurred;
• Record the planned bills, actual bills, refunds/payments, and collections;
• Store program records that support federal facility program decisions; and
• Generate standard reports and perform ad hoc queries.
f. Community Involvement (See chapter X)
To support the community involvement process, SEMS provides the following
capabilities:
• Manage schedule of community involvement activities through the Primavera site
scheduling tool;
• Identify the Community Involvement Coordinator (CIC) and other site contacts;
• Store program records that support community involvement decisions; and
• Generate standard reports and perform ad hoc queries.
g. Project Management
To support the project management process, SEMS provides the following capability:
• Manage schedules for all site activities through the Primavera site scheduling
tool;
• Identify RPMs and other site contacts;
• View and edit activity-specific information including operable unit, sequence
number, performance lead, qualifiers, critical indicators, and planned and actual
start/finish dates;
• View the targeted fiscal year/quarter (FY/Q) for actions defined as regional and
national targets;
• Define predecessor and/or successor relationships between activities;
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• Reorder actions on the schedule and create what-if scenarios by cascading
planned dates (automatically updating subsequent dates based on a schedule
change);
• Add and view activity-specific comments;
• View financial data by site, action, or financial transaction and track Superfund
State Contracts (SSC) cost share payment and reimbursable account information;
• Allow reviewers (e.g., Section Chiefs) to approve or disapprove schedule changes
and financial transactions before they become official; and
• Generate standard reports and perform ad hoc queries.
h. Program Management
To support the program management process, SEMS provides the following capabilities:
• View allowance and budget information for a comparison of regional spending
plans to the negotiated budget for each allowance;
• Record and access all site and non-site financial details associated with an
allowance;
• Track allowance change requests by viewing existing change request data used to
issue/reprogram an allowance and generate a new change request online;
• View aggregate site planning data to support program planning and reporting
measures and access data on a national (at Headquarters [HQ] only), regional,
branch, or section level, or by program office;
• Access project schedule details for sites included in the aggregated information on
planning and reporting measures and identify target candidates;
• Track progress in meeting targets and planning estimates, view details on target
and alternate sites that support these targets/estimates for each planning and
reporting measure, and substitute target and alternate sites when necessary;
• Associate sites with a specific national and/or regional priority initiatives;
• Enter Environmental Indicator (El) and Land Reuse data at the site/action level,
and view summary information for Indicators identified in chapter VII, titled
Remedial Program, at the national (at HQ only) and regional levels;
• Transfer financial data from Compass on a daily basis; and
• Generate HQ program management reports.
XI.A.2 SEMS System Components
SEMS is comprised of various modules that allow for data entry and/or retrieval. The
goals of this architecture are to allow regions, as the primary data owners, to enter data and
ensure that the national database contains all regional data, and to allow all users to run reports
and retrieve data as necessary.
System users enter site information into SEMS thru a variety of interfaces. Site
schedules, planned site obligations and other limited data is entered via the Primavera site
scheduling tool. Basic site information (e.g., location, site activity type) and some activity-
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specific information is entered into forms in the Site Management Module. Finally, supporting
documentation is entered and indexed thru the Document Management Module. Users may run
reports, customize dashboards and perform ad hoc queries thru the Reporting Tool. SEMS also
includes support components, such as the System Administration Module and the Portal.
Regular exports of datasets from SEMS have been recreated in a manner that is consistent
with the datasets provided from CERCLIS. These data extracts include:
• Active: This dataset contains active sites and related program management information
tracked through the Superfund Comprehensive Accomplishments Plan (SCAP) process.
• Freedom of Information Act (FOIA): This dataset contains active sites and related
information that is releasable to the public.
• Archive: This dataset contains archived sites and related information.
Additional datasets can be created to meet additional program needs and special
initiatives as they are defined.
In addition, each day, financial data from Compass are transferred into SEMS.
XI.A.3 Reporting Superfund Information
The SEMS Reporting Tool is accessible to users at HQ and in the regions, and contains
nationally defined reports and dashboards. The reports are categorized by program areas,
including Site Assessment, Five Year Reviews, Federal Facilities, Removal, Enforcement,
Project Management, and Program Management, among others. HQ program managers and staff
have access to the database and the ability to use the application to display data and print reports.
In many cases the application can be used by program managers in lieu of contacting regional
staff for inquiries on data or site information.
XI.A.4 Data Owners/Sponsorship
HQ program staff take an active role in improving the quality of data stored in SEMS by
serving as data sponsors. Data sponsorship promotes consistency and communication across the
Superfund program. HQ data sponsors communicate and gain consensus from data owners on
data collection and reporting processes. Data sponsors ensure that the data they need to monitor
performance and compliance with program requirements are captured and stored properly in
SEMS. To meet this goal, HQ data sponsors identify their data needs, develop data field
definitions, and distribute guidance requiring submittal of these data. Data owners are typically
the RPMs or EVICs that input the data into the system. Data owners follow the guidance they
receive from data sponsors, as they acquire and submit data.
HQ data sponsors assist data owners in maintaining and improving the quality of
Superfund program data. These data are available for data evaluation and reporting. Data
sponsorship helps promote consistency in both national and regional reporting. In addition, data
sponsorship provides a tool to improve data quality through program evaluation and adjustments
in guidance to correct weaknesses detected. Data sponsors may conduct audits to determine if
there are systematic data problems (e.g., incorrect use of codes, data gaps, etc.).
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Superfund Program Implementation Manual
FY15
Chapter XII: Records and Information Management
This chapter has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the
SPIM (FY2012 - Addendum), available at
http://www.epa.gov/superfund/action/process/spiml2.html
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Superfund Program Implementation Manual
FY15
Appendix A: New Initiatives/New Requirements
This appendix has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the
SPIM (FY2012 - Addendum), available at
http://www.epa.gov/superfund/action/process/spiml2.html
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Superfund Program Implementation Manual
FY15
Appendix B: Regional and Headquarters Contacts
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Appendix B: Regional and Headquarters Contacts
Table of Contents
B.A Headquarters (HQ) Subject Matter Experts/Data Sponsors B-l
B.B Office of Emergency Management (OEM) HQ Removal Coordinators B-3
B.C HQSuperfund CostRecovery Contacts B-3
B.D Cost Recovery Contacts B-3
B.E Regional Budget Coordinators B-4
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APPENDIX B: REGIONAL AND HEADQUARTERS CONTACTS
B.A HEADQUARTERS (HQ) SUBJECT MATTER EXPERTS/DATA SPONSORS
Subject Area
Annual Commitment System
ARRA
Community Involvement
Construction Completions
Cost Recovery Process
Cost Recovery Statute of
Limitations
Data Quality
Enforcement
Environmental Indicators
Environmental Justice
Federal Facilities
Enforcement Budget
Federal Facilities Measures
Federal Facilities Response
Federal Facilities Response
Budget Execution
Federal Facilities Response
Budget Planning
Five Year Reviews
FOIA (OSRTI)
Groundwater
Institutional Controls
Mining Sites
OCFO
OEM - Removal
Implementation
OEM - Removal Planning &
Reporting
Name of Contact
Lou Belsito
William Dalebout
Barbara McDonough
Freya Margand
Laura Knudsen
Anne Dailey
Ruth Broome
Mary Bell
Sheldon Selwyn
Mary Bell
Richard Norris
Yolanda Sanchez
Lance Elson
Brendan Roache
Ellen Treimel
Marie Bell
Tencil Coffee
Steve Ridenour
Bill Bushee
David Bartenfelder
Steve Ridenour
Shahid Mahmud
Diane Kelty
Bill Finan
Peter Oh
Peter Oh
E-mail
belsito . louis(@,epa. sov
dalebout. wiHiam(3),epa. sov
mcdonoush.barbara(S>,epa. sov
marsand.freva(@,epa. sov
knudsen. lauratSlepa. sov
dailev.anne(2>,epa. sov
broome.ruthSiepa.sov
bell. marv(@,epa. sov
selwvn. sheldontSiepa. sov
bell.marv(8),epa.sov
norris.rich(S>epa.sov
sanchez.volandatSlepa. sov
elson. lance(3),epa. sov
roache.brendantSiepa.sov
treimel. ellen(S),epa. sov
bell.marie(S>,epa.sov
coffee. hortensia(3),epa. sov
ridenour. steve(3),epa. sov
bushee . williani(@,epa. sov
bartenfelder.david(@,epa. sov
ridenour. steve(3),epa. sov
mahmud. shaihid(@,epa. sov
keltv.dianetSlepa. sov
fman.bill(@,epa. sov
oh.peter(@,epa. sov
oh.peter(3>epa.sov
Phone Number
703-603-8708
703-603-9058
703-603-9042
703-603-8889
703-603-8861
703-347-0373
202-564-6077
202-564-2256
703-603-8776
202-564-2256
703-603-9053
703-603-9246
202-564-2577
703-603-8704
703-603-0720
703-603-0050
703-603-0053
703-603-8922
703-603-8963
703-603-9047
703-603-8922
703-603-8789
202-564-7688
202-564-7981
202-564-2375
202-564-2375
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OEM - Removal
OSRE
OSRE/Action Codes -
Enforcement, Annual Budget
Process
OSRE Budget
OSRE Work Planning
OSRTI Budget Execution
OSRTI Budget, Planning &
Evaluation
OSTRI Annual Budget
Process (SEMS Action
Codes)
OSRTI Work Planning
OSWER Budget
Pipeline Allocation Model
Post-Construction
Radiation Contaminated Sites
Remedial Design/Remedial
Action
Remedial Financial Data
Remedy Selection
SCAP Report Coordinator
Site Assessment/NPL Listing
Special Accounts
SPIM Lead
Superfund Alternative
Approach
Superfund Financial
Management
Superfund Financial
Management
Superfund Financial
Management
Superfund Redevelopment
Rob Fox
Eric French
Mary Bell
Alice Ludington
Laura Milton
Alice Ludington
Amy Vandenburg
ArtFlaks
Alan Youkeles
Lou Belsito
William Dalebout
Larry Wilbon
Alan Youkeles
Tracy Hopkins
Stuart Walker
Kate Garufi
Alan Youkeles
Melanie Keller
Emily Johnson
Randy Hippen
Tracey Stewart
Jennifer Hovis
Nancy Browne
Kevin Brittingham
Tanya Jenifer
Tina van Pelt
Melissa Friedland
fox.rob(@,epa.sov
french.eric(S>,epa. sov
bell.marvfSlepa.sov
lundinston.alice(@,epa.sov
milto n. laura(@,epa. sov
lundinstoaalice (Slepa. sov
vandenburs.amv(@,epa.sov
flaks.art(3),epa. sov
voukeles.alan(S>epa. sov
belsito . louis(@,epa. sov
dalebout. williani(@,epa. sov
wilbon.larrv(@,epa.sov
voukeles.alan(3),epa.sov
hopkins .tracv(8),epa. sov
walker. stuarttSlepa. sov
sarufi.katherine(@,epa. sov
voukeles.alan(S>epa.sov
keller.melanie(2>,epa.sov
iohnson.emilv(@,epa.sov
hippen. randv(@,epa. sov
stewart.tracevfSlepa. sov
hovis . i ennif er(@,epa. sov
browne.nancv(@,epa.sov
brittinsham.kevin(3>epa. sov
i enifer. tanva(3),epa. sov
vanpelt.tina(@,epa. sov
friedland.melissa(S),epa.sov
202-564-1538
202-564-0051
202-564-2256
202-564-6066
202-564-6017
202-564-6066
703-603-9028
703-603-9088
703-603-8784
703-603-8708
703-603-9058
202-566-1903
703-603-8784
703-603-8788
703-603-8748
703-603-8827
703-603-8784
703-603-8706
703-603-8764
703-603-8829
703-603-8791
703-603-8888
202-564-4219
202-564-4941
202-564-7572
202-564-4984
703-603-8864
September 30, 2014
B-2
FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
B.B OFFICE OF EMERGENCY MANAGEMENT (OEM) HQ REMOVAL COORDINATORS
Subject Area
Regional Coordination Team
Leader
Region 1 Coordinator
Region 2 Coordinator
Region 3 Coordinator
Region 4 Coordinator
Region 5 Coordinator
Region 6 Coordinator
Region 7 Coordinator
Region 8 Coordinator
Region 9 Coordinator
Region 10 Coordinator
Name of Contact
Brian Schlieger
John Irizarry
Tim Grier
Eugene Lee
Patrick Easter
Sherry Fielding
Lisa Boynton
Lisa Boynton
Eugene Lee
Sherry Fielding
John Irizarry
e-mail
schrieser.brian(8),epa.sov
irizarrv.iohn(@,epa.sov
srier.tim(S>epa. sov
lee.eusene(@,epa.sov
easter.patrick(@,epa. sov
fieldins.sherrv(S>,epa.sov
bovnton.lisa(@,epa. sov
bovnton.lisa(3),epa. sov
lee.eusene(@,epa.sov
fieldins.sherrv(S>,epa.sov
irizarrv.iohn(®,epa.sov
Phone Number
202-564-3128
202-564-2520
202-564-2361
202-564-7988
202-564-2534
202-564-6174
202-564-2487
202-564-2487
202-564-7988
202-564-6174
202-564-2520
B.C HQ SUPERFUND COST RECOVERY CONTACTS
Area of Specialization
Annual Allocation
Cost Documentation and
Reporting
National Cost Documentation
Advisor; Special Projects
Program Costing Staff Acting
Director & Associate
Director; Superfund Policy
Regional Coordination &
SCORPIOS
Superfund Indirect Costs
Superfund Interest Rate; Trust
Fund Oversight
Name of Contact
Jill Beresford
Vickie Spencer
Tina Van Pelt
Kevin Brittingham
Kevin Brittingham
Dale Miller
Meshell Jones-Peeler
Tina Van Pelt
Alan Eng
Nikki Robinson
E-mail
beresford. i ill(@,epa. sov
spencer. vickie(@,epa.sov
vanpelt.tina(3),epa.sov
brittinsham.kevin(3>epa. sov
brittinsham.kevin(®,epa. sov
miller. dale(@,epa. sov
i ones-peeler. meshell(2>,epa. sov
vanpelt.tina(3),epa. sov
ens.alan(3),epa. sov
robinson. nikki(3),epa. sov
Phone Number
202-564-4805
202-564-9851
202-564-4984
202-564-4941
202-564-4941
202-564-2586
202-564-3160
202-564-4984
202-564-3203
202-564-1784
B.D COST RECOVERY CONTACTS
Location/Region
Region 1
Region 2
Name of Contact
Joan Buonopane
Carlos Kercado
Alexida Perez
Don Pace
E-mail
buonopane .i oan(@,epa. sov
kercado . carlos(@,epa. sov
perez.alexida(2>,epa. sov
pace .donald(2>,epa. sov
Phone Number
617-918-1227
212-637-3480
212-637-4144
212-637-4135
FY 15 SPIM
B-3
September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
Cincinnati Finance Center
Las Vegas Finance Center
Research Triangle Park
Finance Center
Daria Arnold
Steven Pandza
Diane McCall
Sarah Franco
Charles Hayes
Vickie Tellis
Richard Hackley
Linda Haile
Michael Bednarz
Carolyn Ragon
Rey Gomez
John Phillips
Karren Johnson
Joe Poetter
David Wood
Carrie Williams
Scott Ryan
Gloria Owens
Betty Hamilton
arnold.daria(@,epa.sov
pandza. steven(@,epa. sov
mccall.diane(8),epa.sov
franco sarah@epa gov
haves.charles(@,epa.sov
tellis.vickie(@,epa. sov
hacklev.richard(@,epa.sov
haile . linda(3),epa. sov
bednarz. michael(@,epa. sov
ragon.carolvn@,epa. gov
somez.revnaldo(2>,epa. sov
phillips.iohn(3),epa.sov
i ohnson.karren(3>epa. sov
poetter.i oe(2>,epa. sov
wood.david(@,epa.sov
williams.carrie(@,epa.gov
rvan. scott(@,epa. sov
owens. sloria(3),epa. sov
hamilton.bettv(@,epa. sov
215-814-5171
215-814-5178
215-814-5172
404-562- 8215
404-562-8393
404-562-8218
312-886-9144
312-353-4175
312-353-8480
214-665-8389
214-665-6520
913-551-7014
303-312-6159
303-312-6186
415-972-3709
206-553-1194
206-553-0285
919-541-0052
919-541-4280
B.E REGIONAL BUDGET COORDINA TORS
Location/Region
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
Name of Contact
Joan Buonopane
Courtney McEnery
Maryanne Ruiz
Charlotte Whitley
Saray Cubacub
Carlene Chambers
Teri Hankins
Mandi Rodriguez
Jackie Easley
(Enforcement)
Anabel Yo-Eco
Lynne Kershner
E-mail
buonopane .i oan@,epa. sov
mcenerv.courtnev(®,epa.sov
ruiz. marvanne(@,epa. sov
whitlev.charlotte(S),epa.sov
cubacub . sarav(2>,epa. sov
chambers.carlene(®,epa.sov
hankins.teri(S),epa.sov
rodrisuez. mandi(@,epa. sov
easlev.iackie(@,epa.sov
vo -eco . anabel(3),epa. sov
kershner. lvnne(@,epa. sov
Phone Number
617-918-1227
212-637-4295
215-814-5779
404-562-8863
312-353-1518
214-665-3181
913-551-7118
303-312-6697
303-312-6758
415-972-3225
206-553-6518
September 30, 2014
B-4
FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Superfund Program Implementation Manual
FY15
Appendix C: Work Planning Memorandum
This appendix has not yet been updated to reflect the migration to SEMS.
Please continue to reference the previous edition of the
SPIM (FY2012 - Addendum), available at
http://www.epa.gov/superfund/action/process/spiml2.html
FY 15 SPIM September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
This Page Intentionally Left Blank
September 30, 2014 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
Superfund Program Implementation Manual
FY15
Appendix D: American Recovery and Reinvestment Act (ARRA)
FY 15 SPIM September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
This Page Intentionally Left Blank
September 30, 2014 FY 15 SPIM
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OSWER Directive 9200.3-15-1G-Y
AMERICAN RECOVERY AND REINVESTMENT ACT (ARRA)
The American Recovery and Reinvestment Act of 2009 ("Recovery Act" or "Act")
(ARRA) provided a supplemental appropriation of $600 million for Superfund remedial
activities authorized by the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA)1. Most of the ARRA appropriations have been expended, but for the
remaining funds on projects, the following guidance applies:
1) Expenditure of Funds
Recovery Act resources for Superfund remedial activities were obligated by September
30, 2010. Recovery Act resources placed on contracts are available for expenditure until
September 30, 2017. The Recovery Act management and oversight resources were
obligated by September 30, 2011, and are available for expenditure until September 30,
2018. Recovery Act resources placed on Superfund grants (i.e. Cooperative Agreements)
were obligated by September 30, 2010. Office of Management and Budget (OMB) Memo
M-l 1-34 link:
http://www.whitehouse.gov/sites/default/files/omb/memoranda/2011/mll-34.pdf
2) Projects that are Unable to Use Allocated Recovery Act Funds
On September 30, 2010, budget authority to incur new obligations against the Recovery
Act appropriation of "Recovery Act: Superfund Remedial Actions" (Fund Code: TS)
resources expired. Once this budget authority ended, no new obligations could be
incurred against the appropriation. All unliquidated obligations as of September 30, 2017
will be automatically returned to the U.S. Treasury.
3) Cost Recovery
For cost recovery purposes, the Recovery Act is a supplemental appropriation and thus
should be treated the same as the annual Superfund remedial program appropriation. Any
cost recovery funds must be returned to the Trust Fund for future appropriations as
required by 26 U.S.C. 9507 or, if future work is anticipated at the site, placed into a
special account, under the authority of CERCLA 122(b)(3). Unlike annual Superfund
remedial program "no-year" appropriations, by law Recovery Act funds had to be
obligated by September 30, 2010, and therefore, expenditures of contract stimulus funds
were included in any reclassification of special account resources unless they could have
been recertified and obligated before September 30, 2010 and liquidated by September
1 This document provides guidance to regional staff and states regarding how the Agency intends to interpret and
implement the American Recovery and Reinvestment Act of 2009. This document does not impose legally binding
requirements, nor does it confer legal rights, impose legal obligations, or implement any statutory or regulatory
provisions. This document does not change or substitute for any statutory or regulatory provisions. Any decisions
regarding a particular situation will be made based on the statute and the regulations, and Environmental Protection
Agency (EPA) decision-makers retain the discretion to adopt approaches on a case-by-case basis that differ from the
guidance where appropriate.
FY 15 SPIM D-l September 30, 2014
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OSWER Directive 9200.3-15-1G-Y
30, 2017 (September 30, 2013 for grant resources). There are no stimulus-specific coding
requirements for recoveries of EPA costs incurred using Recovery Act funds or for the
establishment of special accounts using such recoveries.
September 30, 2014 D-2 FY 15 SPIM
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