«eo sta>.
-------
IMPLEMENTATION
Issue Elevation and Resolution
Typically, for non-Federal Facility FYRs reviewed by OSRTI, the Remedial Project Manager (RPM)
submits the draft FYR report to the Construction and Post Construction Management Branch (CPCMB)
for review. The CPCMB reviewer has up to 10 business days to review the draft report and provide
written comments to the RPM.
In some instances, the CPCMB reviewer may find that the protcctiveness determination in the draft FYR
report is not sulficiently supported by the text of the report or appears to be inconsistent with national
policy. In these cases, the CPCMB reviewer will contact the RPM via email and may suggest a
protectiveness finding of "not protective" or "deferred." In the email, the RPM will be requested to
provide a written response to the CPCMB reviewer within ten (10) business days as to whether they
agree or disagree with the reviewer's suggested protectiveness recommendation. If the RPM agrees with
the CPCMB reviewer's protectiveness recommendation, the RPM's written response will be saved as an
electronic file in CPCMB's five-year review share directory.
If the RPM disagrees with the CPCMB reviewer's protectiveness recommendation, the RPM's written
response should include sufficient information (e.g., additional site data/information) to more fully
support the region's protectiveness determination. The RPM is encouraged to discuss with the CPCMB
reviewer the type of information that would be sufficient to support the region's protectiveness
determination prior to sending their response. The CPCMB reviewer will respond to the RPM's written
response via email within five (5) business days. If the CPCMB reviewer agrees with the RPM's written
response, the response will be saved as an electronic file in CPCMB's five-year review share directory.
If the CPCMB reviewer disagrees that the RPM's written response fully supports the region's
protectiveness determination, the CPCMB reviewer wi 11 initiate a follow-on conversation with the RPM
and his/her immediate supervisor in an attempt to resolve the disagreement. If the disagreement
concerning the protectiveness determination is resolved at the staff level, the CPCMB reviewer will
document the resolution of the issue in writing and save a copy with the HQ comments as an electronic
file in CPCMB's five-year review share directory.
However, there may be occasions where disagreements on the protectiveness determination in the draft
FYR cannot be resolved at the staff level. In these instances, the issue will be elevated, within two (2)
business days, to the branch chief for CPCMB and the branch chief in the region in an attempt to resolve
the disagreement.
In the unlikely event that there is no resolution at the branch chief level, the issue will be elevated,
within five (5) business days, to the Division Director of QSRTI's Assessment and Remediation
Division and the Deputy Division Director in the region for final resolution. At each level, the CPCMB
reviewer will document the resolution of the issue in writing and save a copy with the HQ comments as
an electronic file in CPCMB's five-year review share directory.
-------
Conclusion
Early issue identification, and when necessary, elevation and resolution are key to this process. In
discussing FYR comments, CPCMB and regional staff should clarify which protectiveness issue(s) may
need to be elevated. Resolution should include, where applicable, agreement on appropriate wording to
adequately support the agreed to protectiveness determination.
In addition, OSRTI recognizes that the regions produce and CPCMB typically review over 200 draft
FYRs per year and quick resolution to any disagreement regarding protectiveness is important to making
this process work. Therefore, one year after implementation, CPCMB will evaluate how this process is
working and make changes as appropriate.
If you have any questions about this approach, please contact David Cooper at (703) 603-8763 or at
Barnes Johnson, OSWER/OSRTI
Reggie Cheatham, OSWER/FFRRO
Phyllis Anderson, OSWER/OSRTI
Bruce Means, OSWER/OSRTI
David E. Cooper, OSWER/OSRTI
John Michaud, OGC
Construction and Post Construction Management Branch, OSWER/OSRTI
Regional Five-Year Review Coordinators, Regions 1-10
NARPM Co-Chairs
3
-------