United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
&EPA
DIRECTIVE NUMBER:
TITLE:
DATE:
ORIGINATING OFFICE:
9610.6
The UST Program Appraisal Strategy
May 6, 1988
OSWER
OSWER OSWER OSWER
DIRECTIVE DIRECTIVE DIRECTIVE
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Table of Contents
I. INTRODUCTION 1
II. THE OUST APPROACH: ASSESSING AND IMPROVING PERFORMANCE 1
1. Taking Stock 1
2. Improving Performance 1
III. ROLES AND RESPONSIBILITIES 2
1. The State's Role 2
2. The Role Of EPA'S Regional Offices 2
3. The Role Of EPA Headquarters 4
IV. PROGRAM PRIORITIES FOR FY 89 4
THE UST PROGRAM APPRAISAL PROCESS 5
APPENDIX A: STATE PERFORMANCE MEASURES A-l
APPENDIX B: Regional Performance Measures B-l
APPENDIX C: Headquarters Performance Measures C-l
APPENDIX D: Reporting Requirements/SPMS D-l
OSWER Directive 9610.6
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I. INTRODUCTION
The purpose of this document is to explain the system of program appraisal, based on a franchise
management approach that will be used by EPA's Office of Underground Storage Tanks (OUST). This
document should clarify the franchise approach as it applies to program appraisal by:
Describing the nature of the program appraisal process, and how it, works to lift the level of
performance by all of us working to protect human health & the environment from potential or
existing releases from USTs;
Clarifying the roles and. responsibilities of headquarters, Regions, and States;
Defining clear performance goals and expectations by outlining national priority areas and listing
the specific performance measures that will be used to help evaluate States, Regions, and
Headquarters programs in FY 89. The performance measures are included in the appendices of
this strategy.
II. THE OUST APPROACH: ASSESSING AND IMPROVING PERFORMANCE
The goal of the program appraisal process is to ensure protection of human health and the environment
from UST releases by helping to build strong and effective State and local programs. This process
provides a systematic means for us (1) to take stock of our collective accomplishments and (2) to work
together to raise the level of performance by States, Regions, and Headquarters. Through regular
communication and feedback on issues, the process will focus on solving or anticipating issues such that
the performance of all (States, Regions, and Headquarters) is improved.
1. Taking Stock
The first job of program appraisal is to provide an accurate representation of what we have accomplished
and how far we have to go to achieve our long range goals. It is a learning process that is designed to
generate facts about current program results that will be useful to States and EPA.
These facts will provide a realistic program baseline from which we can build for success in the long run.
Establishing a realistic baseline is critical given the wide range of program development currently, found
in the UST community, and the tendency to begin with unrealistically high expectations for start-up
programs.
Tracking progress over time is also essential for identifying areas where policies and programs are more
and less successful. Less successful areas will call for corrections or new initiatives. In addition, periodic
taking stock is necessary so that we can report to Congress and the public on how effectively their
environmental and public health goals are being implemented.
2. Improving Performance
States and EPA will constantly work together to identify ways to improve performance - by
owners/operators, installers, clean-up contractors, State and local personnel, and by EPA Regional and
Headquarters offices. States and Regions will work to identify successful technical and management
practices at the State and local level and work with headquarters to make these practices available to other
areas of the country. Each State will also work with its Regional office to identify performance
improvement areas and assistance needs for its own program. Headquarters will support Regional efforts
OSWER Directive 9610.6 1
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and work with them to identify system-wide tools such as videos, technical guidance, or management
systems.
III. ROLES AND RESPONSIBILITIES
1. The State's Role
States have the lead role in field implementation of UST and LUST Programs and must balance State
environmental priorities with national ones. States exercise discretion in how to organize and staff for
program implementation, and choose how to best meet federal Subtitle I objectives tailored to State and
local conditions.
As primary implementing agencies, States play a major role in the program appraisal process.
Working with Regional offices, States determine goals and priorities for the State program which
are reflected in grants and cooperative agreements.
Through timely and accurate quarterly reporting and annual self-appraisals, States provide the
raw facts for us to take stock of accomplishments.
By making available information regarding successful efforts, States foster improvement
throughout the system.
States also work with Regions to identify areas to improve their program and needs for assistance
from EPA.
Two major tools will be available to the States for taking stock of their own programs. First, States will
have available from EPA data on national program progress which they can use as a point of reference for
their own programs. Second, Regions will ask States to conduct a self-appraisal that will result in States
completing a brief State accomplishments report designed to get the State's perspective on their
accomplishments and needs.
In what areas was the State most successful and what were the keys to success?
Did the State meet expectations as outlined in grant and cooperative agreement workplans and
performance measures?
What challenges did the State face in implementing the program, and how did they address them?
What areas are the State targeting for improvement in the coming year and how do they plan to
achieve results?
What assistance does the State need from EPA?
2. The Role Of EPA'S Regional Offices
EPA's Regional offices are the most important link in the program appraisal process. Key objectives for
the Regions are:
1. to establish a good working relationship with States and develop expert knowledge of State
performance and progress in key programmatic areas;
2. to work with States to identify their needs for improvement and assistance;
3. provide assistance to States; and
4. to work with headquarters to identify success stories and problems areas deserving of national
attention.
OSWER Directive 9610.6
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Program appraisal will normally be linked to the ongoing process of negotiating and evaluating
performance under grants and cooperative agreements, but will also occur through less formal
communications, visits, and efforts at joint problem solving.
During the negotiation of grants and cooperative agreements, Regions and States will agree on
performance goals and the means by which the Region will appraise the level of State performance
throughout the year. A major element of this appraisal will normally be formal mid-and/or end-of-year
reviews. These reviews should be documented in a brief written assessment of State accomplishments,
needs, and possible performance improvement areas. Based on discussions with States regarding
improvement areas, Regions will target services and resources to assist States in either problem diagnosis
or developing solutions. Regional responses could include providing contractor assistance, assigning a
Regional staff person on a temporary basis, arranging training, modifying a State workplan, or other
creative approaches.
Regional offices will use a variety of tools to assist, in their assessment of State programs. The State
performance measures in the appendix provide a useful checklist of program areas to examine. In
addition, SPMS data and other quantitative quarterly reports contribute to the baseline of information.
Regions will also review the timeliness and accuracy of reports, and oversee State progress in meeting
commitments in grant and cooperative agreement workplans.
Regional offices outside of UST (including Grants, Planning and Management, Emergency Response,
Regional Council and Financial Management) serve as experts in their functional areas in the State UST
program appraisal process. UST Regional Coordinators coordinate with these other offices in their
evaluations of UST State program performance. The financial management officer in the Region will be
responsible for reviewing State program financial and fiscal accounting procedures.
Regions will also contribute to the appraisal process by conducting a self-appraisal leading to a brief
Regional accomplishment report. This report is designed to provide a Regional perspective on program
progress and needs in the Region. The report should be based on the Regional performance measures
which will focus on:
In what areas was the Region most successful in responding to State needs and assisting States in
improving performance? What were the keys to this success?
What major challenges did the Region face in carrying out its responsibilities, and how did they
address them?
What areas is the Region targeting for improving its performance in the coming year, and how do
they plan to achieve results?
What assistance and support does the Region need from headquarters?
The Regions can also use this opportunity to evaluate Headquarters performance. The measures included
in appendix C list measures for Headquarters activities. The Regions should evaluate Headquarters
performance according to the definitions of performance provided. These evaluations are to be used
during Headquarter's annual review of the Region.
OSWER Directive 9610.6
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3. The Role Of EPA Headquarters
Headquarters is responsible for supporting Regions and States in implementing the UST program. It
issues and revises regulations, develops guidance, establishes national program priorities and policies
with significant involvement and input by States and Regions. It provides tools and resources to State and
Regional UST programs, and compiles and assesses national information. In the appraisal process,
headquarters will work with Regions and States to clearly define agreed upon expectations for Regional
performance, including criteria used to assess performance. These expectations and criteria are defined in
The Agency Operating Guidance, OUST Grant and Cooperative Agreement Guidance, the Transition
Strategy, and Appendix B of this document.
Headquarters will conduct annual reviews of each Region focusing on Appendix B Regional Performance
Measures, and will provide feedback to help improve Regional performance. It will offer tools, such as
contractor resources, training materials and data management systems to help States and local
governments implement UST programs. Headquarters will use reported information to compile statistics
Regions and States can use. They will also compile and disseminate information regarding successful
Regional practices, particularly ways that Regions have been most successful in improving State
performance.
Some issues may need to be explored in greater depth, particularly when issues arise which affect several
Regions. To meet this need, Headquarters, with Regional assistance, may initiate detailed studies that
focus on issues of concern. The need for these studies may arise from Regional requests for assistance or
policy direction, information from quarterly reporting data, or constantly recurring operational issues. An
example of a focused study is the cost recovery pilots project.
IV. PROGRAM PRIORITIES FOR FY 89
The Agency Operating Guidance for FY 89 states the priority activities for UST programs. Appendix A,
B, and C translate FY 89 priorities into specific performance measures for States, Regions, and
Headquarters. Appendix D lists the State reporting requirements and SPMS measures.
STATE PROGRAM APPROVAL: Develop State authorities and funding mechanisms, meet the
"no less stringent federal objectives" as stated in the State Program Approval Handbook, and
submit/approve complete applications for State program approval.
ADMINISTERING THE LUST TRUST FUND: Negotiate and oversee Trust Fund cooperative
agreements which increase emphasis on site work and oversight of responsible party clean-ups
and decrease the emphasis on program development.
PROMOTE COMPLIANCE WITH REGULATIONS: Offer training and technical assistance to
States in order to develop State capabilities to implement effective State regulatory and clean-up
programs. Provide education and information to the regulated community on their regulatory
responsibilities.
TRANSITION STRATEGY: Use existing State activities as a foundation for negotiating formal
agreements with States with grants and cooperative agreements to begin implementing the federal
regulations during the period after the final Federal regulations are promulgated and before State
programs are approved. Work with States to help them develop technical and enforcement
expertise as needed.
OSWER Directive 9610.6
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THE UST PROGRAM APPRAISAL PROCESS
TAKING STOCK IMPROVING PERFORMANCE
State Roles
Work with Regions to determine goals and priorities for grants and cooperative agreements.
Produce Quarterly Reports to define national program progress.
Produce Self-Appraisals to give feedback on State accomplishments and needs.
Regional Roles
Evaluate performance of States under grants and cooperative agreements.
Keep in contact with States to learn State programs.
Perform mid- and/or end-of-year reviews of State programs.
Produce a Brief Written Assessment which outlines State accomplishments needs and possible
improvement areas.
Target resources to State needs.
Produce Self-Appraisals to give feedback on program progress and to evaluate Headquarters.
Headquarter Roles
Produce Tools for Regions and States to help improve performance in the UST program.
Compile national statistics.
Promote successful practices.
Other Regional Office Roles
Serve as experts in their functional areas.
Financial Management Officer reviews State financial and fiscal accounting procedures.
OSWER Directive 9610.6
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APPENDIX A: STATE PERFORMANCE MEASURES
STATE PROGRAM APPROVAL
. STATE ACTIVITIES
1. Successfully meet all
the requirements for State
program approval.
2. Develop final
applications for State
program approval, and
submitting to EPA
Regional offices.
MEASURES
A. Has the State met the " no
less stringent federal objectives" for
State program approval as cited in
the State Program Approval
Handbook?
B. Does the State have adequate
enforcement and compliance
monitoring for State program
approval? (i.e., legal authorities,
comparable public participation
procedures and staffing)
C. Has the State submitted a final
application for State program
approval?
DEFINITION OF PERFORMANCE
EXPECTATIONS' .
A. The State is developing/implementing
authorities no less stringent than the Federal
requirements.
B. The State is developing/implementing the
capabilities, policies and procedures, necessary
for State program approval in the areas of
enforcement, compliance monitoring, and public
participation.
C. State is working with the Region to
develop/implement a final application.
COMPLIANCE ASSISTANCE, MONITORING AND ENFORCEMENT
; STATE ACTIVITIES - . ' MEASURES
1. Promote compliance with the
technical and financial responsibility
regulatory requirements.
Various means may be used to
achieve the objective of compliance;
for example:
- Traditional enforcement:
administrative orders, judicial orders,
temporary or permanent restraining
orders (with publicity of the actions).
- Alternative compliance techniques:
field citations, permit leverage,
enforcement outreach, alternative cost
recovery approaches, targeted
inspections.
A. Has the State developed
and distributed outreach
materials for the regulated
community?
B. Has the State been
responsive to inquiries from
the regulated community?
C. Does the State have
procedures in place for an
effective compliance
monitoring and enforcement
program?
DEFINITION OF PERFORMANCE
'. EXPECTATIONS . .
A. State has worked with the industry and
industry trade associations to develop or
has developed materials to distribute to
owners/operators on regulations and tank
management practices.
B. The State responds to the regulated
community in a timely fashion. State
identified areas where compliance is
inadequate and developed innovative
mechanisms to address these needs.
C. State is developing/implementing
procedures for implementation of a
compliance monitoring and enforcement
program.
OSWER Directive 9610.6
A-l
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CORRECTIVE ACTION
STATE ACTIVITIES
1. Encourage and oversee
responsible party
cleanups.
2. Undertake state
corrective action and
remedial responses in a
timely and appropriate
fashion.
. . MEASURES
A. Has State set up an effective tracking
system for overseeing Responsible party
clean-ups?
B. Did the State initiate the use of innovative
compliance techniques to encourage
responsible party clean-ups?
C. Has the State developed procedures for
protecting human health and water supplies
by providing for temporary relocation of
residents or temporary alternate water
supplies as needed?
D. Has the State developed/implemented
procedures for initiating long-term
remediation of the ground water?
DEFINITION OF PERFORMANCE'
' EXPECTATIONS
A. State has set up an effective tracking
system.
B. State is developing/implementing
innovative compliance techniques to
encourage responsible party clean-ups.
C. The State is
developing/implementing procedures for
temporary relocation of residents and
the provision of temporary water
supplies.
D. The State is
developing/implementing procedures for
initiating long-term remediation of the
ground water.
COOPERATIVE AGREEMENTS
STATE ACTIVITIES
1. Successfully carry out all of
the basic provisions set forth
in cooperative agreements.
. ' . MEASURES.
A. Is the State
implementing its workplan
and meeting its workplan
schedule?
DEFINITION OF PERFORMANCE .
' * ' EXPECTATIONS '
A. State has implemented a workplan that addresses
all elements required under Trust Fund Guidance and
is meeting all workplan schedules and commitments
on time.
OSWER Directive 9610.6
A-2
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COST RECOVERY
"; STATE ACTIVITIES
1. Recover from liable owners or
operators, the costs of undertaking
a corrective action or enforcement
action with respect to a release
from an underground storage tank.
. : MEASURES
A. Does the State have the legal authority to
carry out cost recovery actions?
B. Has the State developed cost recovery
policies and procedures including: a written
priority system for determining appropriate
cost recovery sites; an accounting system to
track site-related costs; a means of tracking and
documenting cost recovery efforts?
DEFINITION OF
PERFORMANCE .
. EXPECTATIONS
A. States with cooperative
agreements have necessary
legal authority.
B. States with cooperative
agreements have cost
recovery policy and
procedures in place.
6. PROGRAM APPRAISAL ROLES
STATE ACTIVITIES
1. State maintains adequate
records for the purposes of
review.
2. State maintains a working
automated data processing
system to store notification
information.
MEASURES
A. Does State have a
functional data processing
system which can produce
the information requested
by the Region and the
public in a timely fashion?
DEFINITION OF PERFORMANCE :
. EXPECTATIONS" '
A. State is developing/implementing a data
processing system that is able to store, and produce
information necessary for the development,
implementation, and running of limited aspects of
their UST program.
3. Produce aggregate tank
notification reports for EPA on
an annual basis.
B. Does the State report
aggregate data on its tank
universe that is accurate
and timely?
B. State reporting data is timely, accurate, detailed
and innovative. No corrections are required.
OSWER Directive 9610.6
A-3
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APPENDIX B: Regional Performance Measures
STATE PROGRAM APPROVAL
; REGIONAL
ACTIVITIES-
1. Provide guidance and
assistance to States in
setting up their UST
programs.
2. Assist States in
developing applications
for approval.
MEASURES
A. Has the region responded to requests from
States to review and identify possible problems in
State authorities capabilities and other
requirements for a state UST program to meet the
federal "no less stringent" requirements?
B. Has the Region responded to requests from
States for help in developing funds and other
mechanisms to help owners/operators meet the
federal financial assurance requirements?
DEFINITION OF
PERFORMANCE
' . EXPECTATIONS '. .
A. The Region has worked with
States to jointly determine areas of
improvement needed for State
program approval.
B. Region has responded to State
requests for assistance in developing
mechanisms to meet financial
assurance requirements.
COMPLIANCE ASSISTANCE, MONITORING AND ENFORCEMENT
'REGIONAL ACTIVITIES '.. MEASURES -
1. Assist States in establishing
policies and procedures for
promoting compliance among
the regulated community with
the technical, and financial
responsibility requirements.
2. Identify the outreach needs of
State UST programs.
DEFINITION OF PERFORMANCE
'.EXPECTATIONS'
A. Has the Region responded to
requests and provided
assistance in developing a State
compliance and enforcement
program?
B. Has the Region disseminated
successful compliance and
enforcement procedures
between States?
C. Has the Region identified
State informational needs,
communicated these needs to
Headquarters, and distributed
materials developed by
Headquarters to the States?
D. Does the Region have a
system to process notifications
and provide compliance
assistance as requested for UST
systems on Indian lands?
A. Region has responded to State requests to
jointly determine areas for
compliance/enforcement program
improvement.
B. The Region has developed an understanding
of alternative methods available to States in
developing comprehensive compliance
monitoring and enforcement programs and, is
transferring this information to States.
C. Regional staff regularly meet with State and
local officials to discuss outreach needs and
how to respond to these needs. The Regions
work to address these needs in a systematic
way.
D. The Region is developing/implementing a
system to process UST notification and to
provide compliance assistance requested for
UST systems on Indian lands.
OSWER Directive 9610.6
B-l
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CORRECTIVE ACTION
. REGIONAL
"; ACTIVITIES . '
1. Monitor State corrective
actions and assist States in
developing corrective
action programs.
' . MEASURES,
A. Is the Region disseminating
information on innovative technologies
and providing corrective action
guidance as requested by the States?
B. Is the Region knowledgeable of the
types of State follow-up actions on sites
under control?
' DEFINITION OF PERFORMANCE
/ ' 'EXPECTATIONS / ' '
A. The Region is actively working with the
States to identify State corrective action
needs.
B. The Region has developed/implemented
a plan to obtain summary information on
state clean-ups.
COOPERATIVE AGREEMENTS
; -REGIONAL-ACTIVITIES
1. Negotiate cooperative
agreements in order to facilitate
the early distribution of Trust
Fund resources, the rapid
development of State programs,
and the initiation of cleanup and
other corrective action and
enforcement activities.
2. Oversee State use of the Trust
Fund for corrective actions.
. MEASURES
A. Has the Region worked with the
States to expedite cooperative
agreement negotiations?
B. Has the Region worked with the
States to (1) help them identify and
solve problems in meeting the
requirements of the cooperative
agreements and (2) ensure Trust
Fund monies are used in accordance
with cooperative-agreement and
grant regulations?
DEFINITION OF PERFORMANCE
EXPECTATIONS
A. The Region has successfully
negotiated cooperative agreements and/or
amendments for all the States in the
Region.
B. the Region maintains a continuous
dialogue with the State to jointly identify
problems and solutions. The Region
educates the States on proper procedures
for procurement, allowable costs, and
other related activities covered by federal
UST regulations.
COST RECOVERY
REGIONAL
. 'ACTIVITIES
1. Assist States in
designing and
implementing cost
recovery programs.
MEASURES
DEFINITION OF PERFORMANCE,
"'EXPECTATIONS .
A. Has the Region communicated to other States A. Region has identified States within
within its Region and other Regional Offices,
exemplary cost recovery approaches? (e.g.,
appropriate selection of cost recovery sites,
tracking site related costs, documenting and
tracking cost recovery efforts)
the Region that need an example of
exemplary cost recovery approaches
and has communicated such examples
to the States.
TRANSITION STRATEGY
; , , REGIONAL ACTIVITIES' .
1. Negotiate formal agreements with States to
implement the federal regulations. Specific State
activities may include: supervise responsible party
cleanups; promote compliance with UST
performance standards, corrective action, financial
responsibility, and closure requirements.
. MEASURES
A. Has the Region
negotiated formal
agreements to implement the
Federal UST program
during the transition period?
DEFINITION OF.
PERFORMANCE*
. ] EXPECTATIONS
A. Region has negotiated
formal agreements with all
States with cooperative
agreements in place.
OSWER Directive 9610.6
B-2
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PROGRAM APPRAISAL ROLES
REGIONAL ACTIVITIES
1. Regions balance their oversight
role with their service role.
Activities in the process include
performing mid-year reviews,
developing targeted improvement
projects based on State needs-
assessments, and maintaining
close communication with the
States throughout the year.
2. Identify the training needs of
State UST programs.
3. Regions should assist states in
developing and improving a
working automated data
processing system for each state
within the Region.
MEASURES
A. Has the Region developed State-
specific targeted improvement
projects (TIPs) or targeted other
resource based on State-needs
assessments?
B. Has the Region effectively
serviced its States through reviews,
all-state meetings and routine
communications and meeting the
needs expressed in the State self-
evaluations?
C. Has the Region established a
working relationship with the
Regional Financial Mgmt Officer,
Grants, Regional Counsel and other
offices to assure that States have
procurement, cost accounting, and
Letter of Credit drawdown and
other procedures that comply with
federal requirements?
D. Has the Region identified State
training needs, communicated these
needs to Headquarters, and assisted
the States in locating or developing
appropriate training programs?
E. Is the Region responding to
requests from the state for
assistance in developing,
maintaining, and expanding an
automated system?
F. Does the Region assist with
periodic quality assurance checks to
detect errors in data?
DEFINITION OF PERFORMANCE
. "EXPECTATIONS .
A. Region has worked in conjunction
with State to determine State needs that
could be satisfied through a targeted
improvement project (TIP). Projects have
been completed successfully and Region
has submitted an evaluation of the
outcome of each project, the methods
used, and the lessons learned.
B. The Region has reviewed all States at
least once a year, held one all-State
meeting each year, maintained routine
communications, and addressed needs
expressed in the State self-evaluation.
C. the Region has developed and
implemented procedures for coordination
with other Regional offices (Financial
Mgmt Officer, Regional Council, Grants
and other Offices) that will ensure that
States have procurement, cost
accounting, Letter of Credit drawdown
and other procedures that comply with
federal requirements.
D. Regional staff regularly meet with
State and local officials to discuss
training needs and how to respond to
these needs. The Regions assist States in
locating and developing appropriate
training programs.
E. Region has responded and identified
data processing needs of states.
F. Region has assisted with quality
assurance checks and provided training to
the States as needed to produce accurate
data.
OSWER Directive 9610.6
B-3
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APPENDIX C: Headquarters Performance Measures
STATE PROGRAM APPROVAL
HEADQUARTERS -
ACTIVITIES
1. Provide guidance and
support to Regions in the
area of State Program
Approval and promote
consistency in the evaluation
of applications.
MEASURES
A. Has Headquarters issued
Guidance on how to meet
State Program Approval
Requirements?
B. Is Headquarters
responsive to questions and
requests for assistance or
issue resolution from
Regions in the area of State
Program Approval?
DEFINITION OF PERFORMANCE
-EXPECTATIONS
A. Headquarters issues guidance that is timely,
clearly written and responds to Regional needs in
working with States.
B. Headquarters is responsive to Regional questions
and responds with a short working answer or by
planning longer term guidance if necessary.
Headquarters disseminates information on State
program approval issues through an appendix to the
OUST weekly on a regular basis.
COMPLIANCE ASSISTANCE, MONITORING AND ENFORCEMENT
: MEASURES
, HEADQUARTERS
ACTIVITIES' '
1. Prepare and distribute
materials that help to
improve the prevention
program procedures of
owners and operators.
A. Has Headquarters identified the
informational needs of Regions and
States and developed materials that
can be distributed by States to
owners/operators?
B. Has Headquarters provided
guidance on enforcement and
compliance monitoring procedures
and disseminated information on
successful procedures in a timely
manner.
C. Is Headquarters responsive to
requests from the Regions and States
concerning enforcement issues?
DEFINITION OF PERFORMANCE -
EXPECTATIONS ' :
A. Headquarters identifies a need and
develops a product that can be readily adapted
for State use.
B. Headquarters sponsors forums to
disseminate information on successful
compliance and enforcement techniques used
by the States (e.g., through Regional
coordinators meeting, Regional Conference
calls, etc.).
C. Headquarters is responsive to Regional
questions and responds with short working
answers or by planning longer term guidance
if necessary.
CORRECTIVE ACTION
HEADQUARTERS
ACTIVITIES,
1. To provide guidance
and support to the
Regions in the area of
corrective action.
. . ' MEASURES
A. Has Headquarters worked with
other Headquarters Offices (Air,
Water, etc.) to support the Region in
developing a UST clean-up program.
B. Has Headquarters been responsive
to questions and clarification requests
for technical guidance from Regions
in the area of corrective action?
' DEFINITION OF PERFORMANCE' :
EXPECTATIONS ' . ;. '
A. Headquarters has coordinated areas of
overlap (air-stripper, and NPDES permits) with
other Headquarters program offices to expedite
clean-ups in the field.
B. Headquarters is responsive to Regional
questions and responds with short working
answers or by planning longer term guidance if
necessary.
OSWER Directive 9610.6
C-l
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TRANSITION STRATEGY
HEADQUARTERS ACTIVITIES' MEASURES
1. Provide assistance to the Regions on
specific issues that arise during the
transition period to facilitate a smooth
transition.
A. Has Headquarters provided
clear guidance on the type of
activities required by the
Region during the transition?
B. Has Headquarters been
responsive in addressing
Regional needs during the
transition?
DEFINITION OF PERFORMANCE .
EXPECTATIONS
A. Headquarters has provided clear
guidance on the activities required by the
Regions during the transition.
B. Headquarters is responsive to regional
questions and responds with short
working answers or by planning longer
term guidance of if necessary.
PROGRAM APPRAISAL ROLES
HEADQUARTERS
ACTIVITIES
1. Headquarters evaluates
Regional needs and responds
quickly and satisfactorily to
those needs.
2. Identify the training needs
of Regions.
3. Headquarters should work
with the States to assist
development of State
notification data systems and
enhancements.
MEASURES-,
A. Does headquarters respond
to Regional needs discovered
through the Regional Reviews,
written inquiries and routine
communications?
B. Is the Headquarters contact
for the Region (the desk
officer) being responsive to
Regional requests?
C. Is Headquarters developing
guidance in a timely fashion,
according to Regional requests
and written inquiries?
D. Has Headquarters met with
the Region to determine their
training needs and assisted the
Region in locating or
developing appropriate training
programs?
E. Has Headquarters provided
usable system guidance and
training and developed data
base enhancements as required
to assist States in meeting their
reporting requirements?
DEFINITION OF PERFORMANCE
EXPECTATIONS ' \
A. Headquarters works in conjunction with Region
to identify Regional needs. Unique and important
issues raised during the reviews and in Regional
correspondence are recorded in the issue docket.
Headquarters issues a letter to the region with a
short working answer and where appropriate,
specifies who will be working on specific issues
and the time-frame for response.
B. Desk officer responds promptly and effectively
to Regional requests.
C. Guidance anticipates Regional needs in working
with States, is transmitted well in advance of
application needs, and advances the spirit of
franchising.
D. Headquarters has identified priority training
needs of Regions and States and is working to
address these needs in a systematic fashion.
Headquarters has made its staff available, as
requested by the Regions, by sending in-house
experts or better information to Regions or other
States to provide technical assistance.
E. Headquarters responds promptly and helpfully
to State and Regional requests for data processing
assistance.
OSWER Directive 9610.6
C-2
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APPENDIX D: Reporting Requirements/SPMS
U.S. EPA OFFICE OF UNDERGROUND STORAGE TANKS
QUARTERLY REGIONAL REPORT FORM
Region: State: FY: Quarter:
ACTIVITIES REPORTING
Corr.
Cum. Actns. prev, Cum.
last+ this + Qtrs, = this
Qtr. Qtr. (-) Data Qtr.
1. Number of Site Investigations Completed
2. Number of Emergency Responses Taken
3. Number of Site Where Enforcement Actions Taken to Complete Clean-Up
4. Number of Sites Where Cost Recovery Initiated
5. CLEAN-UPS STARTED
a. RP Lead
b. State Lead with Trust Fund Money
c. State Lead with NO Trust Fund Money
6. SITES UNDER CONTROL
a. RP Lead
b. State Lead with Trust Fund Money
c. State Lead with NO Trust Fund Money
7. CLEAN-UPS COMPLETED
a. RP Lead
b. State Lead with Trust Fund Money
c. State Lead with NO Trust Fund Money
OSWER Directive 9610.6 D-l
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U.S. EPA OFFICE OF UNDERGROUND STORAGE TANKS
QUARTERLY REGIONAL REPORT FORM
State: FY: Quarter:
8. EXCEPTION REPORT [**DRAFT**]
Please list activity for this quarter and corrections to previous quarters:
Action Code Exception Code Site Name Amount
Exception Codes:
A - State plans to obligate over $100,00 at a site
B - State actually obligated over $100,00 at a site (cumulative site expenses exceeded $100,00 this quarter); also
enter amount
C - State plans to use innovative or experimental technology at the site
D - State plans to provide permanent alternative water supply
E - State plans to permanently relocate residents
F - State reached/received a cost recovery settlement; also enter amount
Action Codes:
N - Current Quarter Activity
D - Correction to previously reported data; delete this site
A - Correction to previously reported data; add this site
. .................................. / Corr,
Actns, prev, «
Cum. ,,. , 5-^ Cum.
, this + Qtrs. ...
. last + ~. , . . this
9. FORECASTING TRUST FUND USE
Number of Sites with Confirmed Releases Where
a. O/O has been Identified
b. O/O is Insolvent/Incapable of Conducting Timely Clean-Up (subset of number
included in 9a)
c. Search for Responsible Party Unsuccessful
OSWER Directive 9610.6 D-2
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U.S. EPA OFFICE OF UNDERGROUND STORAGE TANKS
REGIONAL SPMS REPORTING FORM
State: FY: Quarter:
STATE PROGRAM APPROVAL (UST-1)
Does State have adequate legislative authority in place for developing an approvable UST program that addresses
requirements for:
(a) Tank Design, Tank Maintenance and Corrective Action
(b) Financial Assurance
(c) Has State submitted a complete application for State Program Approval
(d) Does State have an Authorized Program
CLEAN-UP OF LEAKING TANKS (UST-2)
(a) Does State have LUST Trust Fund Co-operative Agreement that
includes FY 89 money (Y/N)
(b) Does State have adequate authorities in place for carrying out LUST Trust
Fund Activities in the areas of:
Corrective Action (Y/N)
Enforcement (Y/N)
Cost Recovery (Y/N)
(c) Number of Site Clean-Ups initiated in response to Leaking USTs
RPLead
State Lead with Trust Money Fund
State Lead with NO Trust Money Fund
(d) Number of Sites brought under control
RPLead
State Lead with Trust Money Fund
State Lead with NO Trust Money Fund
- Petroleum (Y/N)
- Chemical (Y/N)
- Petroleum (Y/N)
- Chemical (Y/N)
- Petroleum (Y/N)
- Chemical (Y/N)
- Petroleum (Y/N)
- Chemical (Y/N)
Corr.
Cum. Actns. prev. Cum.
last + this + Qtrs. = this
Qtr. Qtr. (-) Data Qtr.
OSWER Directive 9610.6
D-3
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IMPLEMENTATION OF FEDERAL UST PREVENTION PROGRAM (UST-3)
Does State have a formal agreement to implement the Federal UST Program during the
transition period (Y/N)
OSWER Directive 9610.6 D-4
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