UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OCT "2005
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
Directive No. 9275.1-12-D
MEMORANDUM
SUBJECT: Superfund Cc
FROM: Michael B. Cook
Office of Superfii
echnology Innovation
TO:
Superfund National Policy Managers, Regions 1-10
Background
Over the past several years, demands on the Superfund budget have increased to the point
where not all projects ready for construction in a given year can be funded In response, the
managers of the Superfund remedial program have focused their efforts on several cost
management measures with a goal of placing more funding toward construction projects, This
memorandum presents these measures along with associated activities and status.
The purpose of this memo is to provi jort on the status of the Superfund cost
management measures. There are 17 recommended Superfund cost management measures,
representing 45 separate activities. These cost management measures are intended to provide
greater program review to ensure that the Superfund program is positioned to address new ways
of conducting site management as effectively and efficiently as possible and also build upon
previous Superfund efforts to improve program operations. We expect all of these cost
management initiatives to aid in managing costs for the Superftmd Program. Many of these 1?
recommended measures are already being implemented in the program. The current status of the
stivMes is that 22 are completed, 14 are due to be completed in 2005 or 2006, and 9 are
ongoing beyond 2006, The name and product list of'these recommended measures is contained in
the attachment to this memorandum. My office will update the progress of these recommended
measures on a semi-animal basis beginning in October, 2005. These recommended measures are
focused on program management and do not change Superfund response policies.
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In the early 1990s, the Superfund program initiated a series of Administrative Reforms to


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improve the overall workability of the program. The Superfund Administrative Reforms
consisted of various initiatives and pilots designed to make the Superfund program work faster,
fairer, and more efficiently, [see http:/7wwm''.epa.gO¥/sttperftirid/prograiBs/rcforms/t¥Pcs/
deanmfctn.il Many of the activities under the Superfund Administrative Reforms have, over
time, been incorporated into the daily operations of the program. These 17 recommended cost
management measures continue to build on those reforms, but specifically focus on activities
directly related to cost and program management. These recommended measures should help
provide continuous overall improvement to the Superfund program.
Today, the Superfund program is currently facing a large backlog of sites ready for remedy
construction, however, the current level of appropriated fading does not permit the Superfund
program to start long-term construction at every project that is ready to begin construction. In
addition, sites posing significant threats continue to be listed on the National Priorities List (NPL)
and the program continues to conduct Remedial Investigations/Feasibility Studies (RI/FS) at sites
currently on the NPL. Therefore, available program resources need to be allocated across all
functions, not just construction.
Recently, Congress directed Resources for the Future (RFF) to study the projected future
costs of Superfund for fiscal years 20< 39. The report titled, "Superfund's Future: What
Will It Cost?", was released in July, 2001. The study looked at all major elements of the
Superfund program, including the removal program (which focuses on emergency and short-term
cleanups); the remedial program (which focuses on long-term cleanup); site assessment activities
(prior to inclusion on the NPL); program staff, management, and support costs; program
administration; and Superfund-related work of other programs and ageucif	tort, which
contained several recommendations intended to improve the program, was supported by
Office of the Administrator.
In 2001, the Deputy Administrator directed the development of an action plan to address
the recommendations in the RFF Report. The plan resulted in the formation,, in July 2002, of a
Superfund Subcommittee under the auspices of the Agency's National Advisory Council for
Environmental Policy and Technology (NACEPT). Results from the NACEPT process were
released in April 2004, also in the form of recommendations.
In 2003, to support the work of NACEPT, the Acting Deputy Administrator requested that
an EPA workgroup be established to conduct an internal review of the Superfund prograi
objective of this review was to identify opportunities for program efficiencies enabling the
Agency to complete more cleanups with current resources. The 120-day study was issued in
April 2004. Many of the 17 recommended cost management measures are directly related to the
recommendations in that study (e.g., the attachment to this memorandum lists each measure and
identifies the 120-day study recommendations that apply to that particular measure).
Finally, this cost management effort was begun in August, 2003. Superfund Regional
managers provided recommendations for improved cost management measures. These were
discussed by Regional managers in the first quarter of FY04. The current 17 recommended

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measures'are the result of those discussions, These measures fall within the following general
areas:
People responsible for contamination should pay for or conduct the cleanup work;
Getting the most out of Superfund money;
Ensuring the best cleanup for the money;
Getting the most out of cleanup decisions/remedies; and
Utilizing technology for outstanding site management.
mmended measures include several projects that arc carry-overs or
enhancements to the Administrative Reforms. For example, the National Remedy Review Board
(item 4.2) continues to provide cost savings and promotes greater consistency in decision making.
This new initiative expands the scope of the original initiative lowering the threshold for Board ¦
review and encourages Regions to seek Board review for their preferred remedies at other sites.
Similarly, the Remedy Updates Administrative Reform (iter s being re-emphasized to
ensure that Regions take a hard look at remedies, particularly in design, to make sure that they are
the best decisions given the current site conditions. Headquarters will now expand the tracking of
the remedy update reform to include non-technical and non-scientific remedy changes (e.g.,
changes in Applicable and Relevant and Appropriate Requirements (AKAKs) or land use). The
Remedy Updates work also ties into a new project looking at costs daring remedial design, titled
"Third Party Review of Fund Lead Rem© sign." (item 3.3)
mmended measures also recognize and encourage additional efforts in areas
that have been explored by all Regions. A draft list of measures was sent to all Regions for
review and comment in May, 2004. Regional replies included the following ideas: pursuit of cost
shares for non-time critical removals, ground water remedy performance optimization, and
improved sampling and analysis data management. Each of these ideas has been included to
varying degrees. The 17 recommended measures highlight these important ideas and encourage
their continued use to the extent possible.
Conclusion/Implementation
The purpose of the 17 recommended cost management measures is to ensure greater cost
and program management efficiencies and to make the best use of the Superfund dollars to
achieve the maximum impact. Some of the measures are expected to achieve cost savings, while
others are designed to ensure that dollars are better directed to the work that needs to be done.
OSRTI staff will provide updates of the recommended cost management measures every 6 months
beginning in October, 2005. New measures can be added at any time and they will be included in
the first semi-annual report after their proposal.
For Additional Information
Copies of this document arc available on our web site (http://www.epa.gov/XXXXXXX)
[Note - web site to be added at the time the memo is finalize neral questions about this topic
should be referred to the Call Center at 1-800-424-9346. The subject matter expert for this

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document is Matthew Charsky of OSRTI whose phone number is (703-603-877?) and Ms email
address is charsky,mattliew@epa.gov.
Attachment
cc: OSRTI Managers
>ie Dietrich, OEM
Jim Woolford, FFRRO
Matt Hale, OSW
Linda Garcz>nski, OBCR
Susan Bromm, OSRR
Dave Kling, FFEO
Scott Sherman, OGC
Earl Salo, OGC
Charles Openchowski, OGC
Ed Chu» Land Revitalization Staff, OSWER
Eric Steinhaus, Superfund Lead Region Coordinator, US EPA Region 8
NARPM Co-Chairs
Joanna Gibson, OSRTI Documents Coordinator

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