United States Office of EPA 540-R-01-004
Environmental Protection Solid Waste and OSWER 9200.3-14-1G-Q
Agency Emergency Response PB2003 100720-J
April 7, 2003
Superfund http://www.epa.gov/superfund/action/process/spim04.htm
Superfund Program Implementation Manual
Fiscal Year 2004/2005
Program Implementation Guidance for OSRTI, OSRE, FFRRO,
and FFEO (Headquarters and Regional Offices)
Program Goals and Planning Requirements
Program Implementation Procedures
iiiiiiniiiniiiiiiininiiiiiniiin
134303
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
April 4, 2003
MEMORANDUM
SUBJECT: FY 2004/2005 Superfund Program Implementation Manual (SPIM)
FROM: Paul Nadeau, Director
Planning, Analysis and Resources Management, OERR
Monica Gardner, Chief
Program Evaluation & Coordination Branch, OSRE
TO:
Address List (attached)
PURPOSE
The purpose of this document is to transmits the attached OSWER Directive OSWER 9200.3-14-1G-
Q "Superfund Program Implementation Manual (SPIM), Fiscal Year 2004/2005".
BACKGROUND
The SPIM was last published in April 2001 for FY 2002 and 2003 with five subsequent changes. For
FY 2004 and 2005, the SPIM was circulated for review on December 16, 2002; and comments were to be
received by January 24, 2003.
DOCUMENT
For FY 2004 and 2005, the SPIM is in a loose leaf, three ring binder format. It, also, is available as
a WORDPERFECT and PDF file and will be available on the web @
http://www.epa.aov/superfund/action/process/spim04.htm in approximately 5 - 10 workdays. For this SPIM,
Appendix F, Oil Pollution Prevention and Response Program, has been removed since the Oil program is
under a separate appropriation. In addition, the majority of the SPIM text for the Brownfields program has
been removed since that program is under it own appropriation for FY 04. Appendix G, "Government
Performance and Results Act (GPRA)", will be sent out under separate cover upon finalization of the
Agency's strategic plan for FY 03 - 08.
Please distribute this document to your Superfund and Federal Facilities managers and responsible
staff. If you have any specific program questions, please contact the Subject Matter Expert identified at the
end of each chapter or appendix of the SPIM. For general questions about the SPIM, please contact Robert
White (703-603-8873).
TMPACT ON CERCLTS/WASTELAN
Please see attached Impact Analysis.
ACTTON
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Attachments
-------
DISTRIBUTION LIST
Addressees
TO: Superfund Branch Chiefs (Regions I - X)
Regional Counsel Branch Chiefs (Regions I - X)
CC: Superfund National Policy Managers (Regions I - X)
Office of Regional Counsel (Regions I - X)
Information Management Coordinators (Regions I - X)
Budget Coordinators (Regions I - X)
Financial Management Coordinators (Regions I - X)
Michael B. Cook
Susan Bromm
Tom Kelly
Elliott Gilberg
Elaine Davies
Betsy Southerland
OERR Directors and Senior Process Managers
Regional Oil Removal Managers
Linda Garczynski (5101)
Juanita Standifer (5101)
Paul Connor
Sandra Connors
Neilima Senjalia
David Hindin (2222A)
James Woolford ( 5106G)
Dana Stalcup
Susan Janowiak (5103)
Lance Elson (2261A)
Randy Hippen
Marie Bell ( 5106G)
Willie Griffin
Sharon Blandford
Kenneth Lovelace
Ken Skahn
Terry Jeng
Richard Jeng (5103)
Tracy Hopkins
Mark Savedoff
Dela Ng
Scott Blair
Dan Dickson
Filomena Chau
Cate Tierney
Anne Berube
Kevin Brittingham (273 3R)
Vince Velez
Final FY 04/05 SPIM
-------
Charles Young
Nancy Riveland
Patricia Gowland
Hans Waetjen
Ben Hamm (5101)
Joshua Barber
Kathryn Frasso
Final FY 04/05 SPIM
-------
^tosr,,^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 2 0460
September 24, 2003
U32J
\ pro^N°
MEMORANDUM
SUBJECT: Change 1, FY 2004/2005 Superfund Program Implementation Manual (SPIM) &
Change 6, FY 2002/2003 Superfund/Oil Program Implementation Manual (SPIM)
FROM: Paul Nadeau, Director //Signed//
Planning, Analysis and Resources Management, OSRTI
Monica Gardner, Chief //Signed//
Program Evaluation & Coordination Branch, OSRE
Renee Wynn, Associate Director //Signed//
Federal Facilities Restoration and Reuse Office, OSWER
Charlotte Englert, Team Leader //Signed//
Resource Management and Administration, OEPPR
(Signatures on file at OSWER/OSRTI/PARM/5203G)
TO: Address List (attached)
This document transmits Change 1 to OSWER Directive 9200.3-14- 1G-Q, "Superfund Program
Implementation Manual (SPIM), Fiscal Year 2004/2005"; and Change 6 to OSWER Directive 9200.3-14-
1G-P, "Superfund/Oil Program Implementation Manual (SPIM), Fiscal Year 2002/2003".
DOCUMENT
The FY 04/05 SPIM was published in April 2003. The proposed Change 1 was circulated for
review on August 8, 2003; and comments were to be received by September 2, 2003. Please refer to the
attached FY 04/05 SPIM Change 1 Log for a summary of the final changes.
Since publishing the FY 04/05 SPIM, a number of organization changes in the Office of Solid
Waste and Remedial Response (OSWER) have occurred: 1) the Oil and Removal programs have moved
to the Office of Emergency Prevention, Preparedness & Response (OEPPR); and 2) OERRhas become
the Office of Superfund Remediation and Technology Innovation (OSRTI). Terminology for these
changes are not reflected in Change 1 but will be reflected in a later SPIM change.
The change to delete text for Fund-financed Coast Guard removals in the Removal Start and
Completion definitions in Appendix B also applies to the FY 02/03 SPIM as Change 6. This change was
circulated for review with the proposed Change 1 to the FY 04/05 SPIM. Please refer to the FY 02/03
SPIM Change 6 Log for a summary of the final changes.
IMPACT ON CERCLIS/WASTELAN
Please see attached Impact Analysis.
ACTION
-------
The SPIM is in a loose leaf, three ring binder format. Please remove the old materials from your
FY 02/03 and FY 04/05 SPIMs and insert the enclosed new materials. Changed or added text is redlined
to assist you in identifying the changes. Addressees, also, will be sent revised WordPerfect (WP) files. If
you have specific program questions, please contact the Subject Matter Expert identified on the change
log or the last page of each section of the SPIM. Please contact Robert White (703-603-8873) for general
SPIM questions. The FY04/05 SPIM can be found @ http://www.epa.qov/superfund/action/process/spim04.htm
and the FY02/03 SPIM @ http://www.epa.qov/superfund/action/process/spim.htm . These documents will contain
the updates for the FY 02/03 Change 6 and FY 04/05 Change 1 in approximately 5-10 workdays.
Attachments
-------
($ss)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINON D.C. 2 0460
March 3, 2004
MEMORANDUM
SUBJECT: Change 2, FY 2004/2005 Superfund Program Implementation Manual (SPIM)
FROM: Jeff Lape, Director //SIGNED//
Resources Management Division, OSRTI
Monica Gardner, Chief //SIGNED//
Program Evaluation & Coordination Branch, OSRE
Renee Wynn, Associate Director //SIGNED//
Federal Facilities Restoration and Reuse Office, OSWER
Charlotte Englert, Team Leader //SIGNED//
Resource Management and Administration OEPPR
//SIGNATURES ON FILE//
TO: Address List (attached)
This document transmits Change 2 to OSWER Directive 9200.3-14-1G-Q, "Superfund Program
Implementation Manual (SPIM), Fiscal Year 2004/2005".
DOCUMENT
The FY 04/05 SPIM was published in April 2003. Change 1 was approved on September 24, 2003. Change
2 was circulated for review on December 4, 2003 and comments were received by January 16, 2004. Please refer to
the attached FY 04/05 SPIM Change 2 Log for a summary of the final changes.
This finalizes the text changes to the SPIM resulting from the re-organization of the Office of Emergency
and Remedial Response (OERR) and the Technology Innovation Office (TIO) into the Office of Superfund
Remediation & Technology Innovation (OSRTI).
IMPACT ON CERCLIS/WASTELAN
Please see attached Impact Analysis.
ACTION
The SPIM is in a loose leaf, three ring binder format. Please remove the old materials from your FY 02/03
and FY 04/05 SPIMs and insert the enclosed new materials. Changed or added text is redlined to assist you in
identifying the changes. Addressees, also, will be sent revised WordPerfect (WP) files. If you have specific
program questions, please contact the Subject Matter Expert identified on the change log or the last page of each
section of the SPIM. Please contact Robert White (703-603-8873) for general SPIM questions. The FY04/05 SPIM
can be found 'a. http://www.epa.gov/superfund/action/process/spim04.htm and will contain the updates for the
Change 2, FY04/05 SPIM in approximately 5-10 workdays.
Attachments
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D.C. 2 0460
June 14, 2004
MEMORANDUM
SUBJECT: Change 3, FY 2004/2005 Superfund Program Implementation Manual (SPIM)
FROM: Paige Peck, Director (Acting)
Resources Management Division , OSRTI
Signature on file OSRTI
John Michaud, Associate Director (Acting)
Federal Facilities Restoration and Reuse Office, OSWER
// Signature on file OSRTI
Monica Gardner, Chief
Program Evaluation & Coordination Branch, OSRE
// Signature on file OSRTI
Charlotte Englert, Team Leader
Resource Management and Administration, OEPPR
// Signature on file OSRTI
TO: Address List (attached)
This document transmits Change 3 to OSWER Directive 9200.3-14- 1G-Q, "Superfund Program
Implementation Manual (SPIM), Fiscal Year 2004/2005".
DOCUMENT
The FY 04/05 SPIM was published in April 2003. Change 1 was approved on September 24,
2003. Change 2 was circulated for review on December 4, 2003 and issued on March 3, 2004. Change
3 was circulated for review on May 10, 2004, and comments were received by June 4, 2004. Please refer
to the attached FY 04/05 SPIM Change 3 Log for a summary of the final changes. The log identifies
changes to the SPIM driven by OSWER's response to OIG audit report number 2002-P-00016.
IMPACT ON CERCLIS/WASTELAN
Please see attached Impact Analysis.
ACTION
The SPIM is in a loose leaf, three ring binder format. Please remove the old materials from your
FY04/05 SPIMs and insert the enclosed new materials. Changed or added text is redlined to assist you in
identifying the changes. Addressees, also, will be sent revised WordPerfect (WP) files. If you have
specific program questions, please contact the Subject Matter Expert identified on the change log or the
last page of each section of the SPIM. Please contact Robert White (703-603-8873) for general SPIM
questions. The FY04/05 SPIM can be found @ http://www.epa.qov/superfund/action/process/spim04.htm
and will contain the updates for Change 3 in approximately 5-10 workdays.
53ZZ
^ PRO^
Attachments
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 2 0460
September 24, 2004
MEMORANDUM
SUBJECT: Change 4, FY 2004/2005 Superfund Program Implementation Manual (SPIM)
Resources Management Division , OSRTI
Signature on file OSRTI
John Michaud, Associate Director (Acting)
Federal Facilities Restoration and Reuse Office, OSWER
// Signature on file OSRTI
Monica Gardner, Chief
Program Evaluation & Coordination Branch, OSRE
// Signature on file OSRTI
Charlotte Englert, Acting Director
Business Operation Center, OEM
// Signature on file OSRTI
This document transmits Change 4 to OSWER Directive 9200.3-14-1G-Q, "Superfund Program
Implementation Manual (SPIM), Fiscal Year 2004/2005".
DOCUMENT
The FY 04/05 SPIM was published in April 2003. Change 1 was approved on September 24,
2003. Change 2 was circulated for review on December 4, 2003 and approved on March 3, 2004.
Change 3 was circulated for review on May 10, 2004, and approved on June 4, 2004. Change 4 was
proposed and circulated for review on August 11, 2004; comments received on September 8, 2004.
Please refer to the attached FY 04/05 SPIM Change 4 Log for a summary of the final changes. The log
identifies changes to the SPIM driven by OSWER's response to OIG audit report number 2002-P-00016.
IMPACT ON CERCLIS/WASTELAN
Please see attached Impact Analysis.
The SPIM is in a loose leaf, three ring binder format. Please remove the old materials from your
FY04/05 SPIMs and insert the enclosed new materials. Changed or added text is redlined to assist you in
identifying the changes. Addressees, also, will be sent revised WordPerfect (WP) files. If you have
specific program questions, please contact the Subject Matter Expert identified on the change log or the
last page of each section of the SPIM. Please contact Robert White (703-603-8873) for general SPIM
questions. The FY04/05 SPIM can be found @ http://www.epa.qov/superfund/action/process/spim04.htm
and will contain the updates for Change 4 in approximately 5-10 workdays.
FROM: Paige Peck, Director (Acting)
TO:
Address List (attached)
ACTION
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 2 0460
January 11, 2005
MEMORANDUM
Final Change 5, FY 2004/2005 Superfund Program Implementation Manual (SPIM)
Paige E. Peck, Director (Acting) ///SIGNED///
Resources Management Division , OSRTI
Renee Wynn, Deputy Director ///SIGNED///
Federal Facilities Restoration and Reuse Office, OSWER
Monica Gardner, Chief ///SIGNED///
Program Evaluation & Coordination Branch, OSRE
Kim Jennings, Acting Director ///SIGNED///
Business Operation Center, OEM
///SIGNATURES ON FILE @ OSRTI/BPEB///
Address List (attached)
This document transmits the attached Change 5 to OSWER Directive 9200.3-14-1G-Q,
"Superfund Program Implementation Manual (SPIM), Fiscal Year 2004/2005".
DOCUMENT
The FY 04/05 SPIM was published in April 2003. Change 1 was issued on September 24, 2003;
Change 2, on March 3, 2004; Change 3, on June 14, 2004; and Change 4, on September 24, 2004.
Proposed Change 5 was circulated for review on November 19, 2004; and comments were due on
December 10, 2004. The attached Change Log provides a list of changes. This change introduces Data
Quality Objectives as a supplement to this Manual. This supplement is meant to complement the SPIM
with additional data quality information for CERCLIS users and does not supercede the SPIM. SPIM
language will prevail if there are inconsistencies.
IMPACT ON CERCLIS/WASTELAN
Please see attached Impact Analysis.
ACTION
The SPIM is in a loose leaf, three ring binder format. Please remove the old materials from your
FY04/05 SPIMs and insert the enclosed new materials. Changed or added text is redlined to assist you in
identifying the changes. Addressees, also, will be sent revised WordPerfect (WP) files. If you have
specific program questions, please contact the Subject Matter Expert identified on the change log or the
last page of each section of the SPIM. Please contact Robert White (703-603-8873) for general SPIM
questions. The FY04/05 SPIM can be found @ http://www.epa.qov/superfund/action/process/spim04.htm
and will contain the updates for Change 5 in approximately 5-10 workdays.
USSJ
SUBJECT:
FROM:
TO:
Attachments
-------
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MEMORANDUM
SUBJECT: Final FY 2006/2007 Superfund Program Implementation Manual (SPIM); & Change 6, FY
2004/2005 SPIM
FROM: Joan Harrigan-Farrelly, Director (Acting) ///SIGNED///
Resources Management Division , OSRTI
Renee Wynn, Deputy Director ///SIGNED///
Federal Facilities Restoration and Reuse Office, OSWER
Monica Gardner, Chief ///SIGNED///
Program Evaluation & Coordination Branch, OSRE
Kim Jennings, Acting Director ///SIGNED///
Business Operation Center, OEM
///SIGNATURES ON FILE @ OSRTI/BPEB///
TO: Address List (attached)
This document transmits the attached OSWER Directive 9200.3-14-1G-R, "Superfund Program
Implementation Manual (SPIM)," Fiscal Year (FY) 2006/2007; and Change 6 to OSWER Directive 9200.3-14-
1G-Q, "SPIM, FY 2004/2005".
DOCUMENT
The FY06/07 SPIM was circulated for review on December 13, 2004; and comments were to be
received by January 21, 2005. The FY04/05 SPIM was last published in April 2003, with five subsequent
changes, listed in the FY04/05 SPIM change log. The attached sixth change updates Chapter III, Budget
Planning Process & Financial Management, for a recent reorganization at the Office of the Chief Financial
Office (OCFO), and adds text for the new People Phis payroll system.
IMPACT ON CERCLIS/WASTELAN
Please see attached Impact Analysis.
ACTION
The SPIM is in a loose leaf, three ring binder format. Please remove the old materials from your
FY04/05 SPIM and insert the enclosed new materials. Changed or added text is redlined to assist you in
identifying the changes. Addressees, also, will be sent new Adobe (pdf) files. If you have specific program
questions, please contact the Subject Matter Expert identified on the change log or the last page of each section
of the SPIM. Please contact Robert White (703-603-8873) for general SPIM questions. The FY04/05 SPIM
can be found @ http://www.epa.qov/superfund/action/process/spim04.htm and the FY06/07 SPIM @
http://www.epa.qov/superfund/action/process/spim06/. The new materials will be installed in approximately 5-10
workdays.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 2 0460
April 1, 2 005
Attachments
-------
iSz)
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MEMORANDUM
SUBJECT: Change 1, FY 2006/2007 Superfund Program Implementation Manual (SPIM); & Change 7,
FY 2004/2005 SPIM
FROM: Joan Harrigan-Farrelly, Director ///SIGNED///
Resources Management Division , OSRTI
Renee Wynn, Deputy Director ///SIGNED///
Federal Facilities Restoration and Reuse Office, OSWER
Monica Gardner, Chief ///SIGNED///
Program Evaluation & Coordination Branch, OSRE
Dana Stalcup, Director ///SIGNED///
Business Operation Center, OEM
///SIGNATURES ON FILE @ OSRTI/BPEB///
TO: Address List (attached)
This document transmits the attached Change 1 to OSWER Directive 9200.3-14- 1G-R, "Superfund
Program Implementation Manual (SPIM)," Fiscal Year (FY) 2006/2007; and Change 7 to OSWER Directive
9200.3-14-1G-Q, "SPIM, FY 2004/2005".
DOCUMENT
The FY06/07 SPIM was published in April 2005. The FY04/05 SPIM was published in April 2003,
with six subsequent changes listed in the FY04/05 SPIM change log. Proposed Changes 1 and 7 were
circulated for review on June 28, 2005 and comments were returned on July 27, 2005. The attached changes
update the Data Quality Objectives timeliness requirements and updates text as noted in the change logs.
IMPACT ON CERCLIS/WASTELAN
Please see attached Impact Analysis.
ACTION
The SPIM is in a loose leaf, three ring binder format. Please remove the old materials from your
FY04/05 & FY06/07 SPIMs and insert the enclosed new materials. Changed or added text is redlined to assist
you in identifying the changes. Addressees, also, will be sent new Adobe (pdf) files. If you have specific
program questions, please contact the Subject Matter Expert identified on the change log or the last page of
each section of the SPIM. Please contact Robert White (703-603-8873) for general SPIM questions. The
FY04/05 SPIM can be found @ http://www.epa.qov/superfund/action/process/spim04.htm and the FY06/07 SPIM @
http://www.epa.qov/superfund/action/process/spim06/. The new materials will be installed on the internet in
approximately 5-10 workdays.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 2 0460
September 12, 2 0 05
Attachments
-------
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$ A \ DISTRIBUTION LIST
, v\i/7 ° Addressees
PRO^
TO: Superfund Branch Chiefs (Regions I - X)
Regional Counsel Branch Chiefs (Regions I - X)
CC: Superfund National Policy Managers (Regions I - X) Vincent Velez
Regional Counsels (Regions I - X) Charles Young
Information Management Coordinators (Regions I - X)
Budget Coordinators (Regions I - X)
Financial Management Coordinators (Regions I - X)
Michael B. Cook
Elaine Davies
Betsy Southerland
Susan Bromm
Elliott Gilberg
OSRTI Directors and Senior Process Managers
Charlotte Englert
Paul Connor
Sandra Connors
Neilima Senjalia
David Hindin (2222A)
James Woolford ( 5106G)
Dana Stalcup
Susan Janowiak (5103)
Terry Eby
Mark Mjonness
Lance Elson (2261A)
Randy Hippen
Marie Bell (5106G)
Willie Griffin
Sharon Blandford
Kenneth Lovelace
Ken Skahn
Terry Jeng
Richard Jeng
Tracy Hopkins
Mark Savedoff
Karin Koslow
Dela Ng
Dan Dickson
Cate Tierney
Deniz Ergener
Greg Madden
Kevin Brittingham (2733R)
Nancy Riveland
Patricia Gowland
Hans Waetjen
Joshua Barber
Steven Blankenship
Kathryn Frasso
Deborah Dietrich
Kerron Weston
Melinda Dickens
Final Change 6, FY02/03 SPIM, & Final Change 1, FY 04/05 SPIM
-------
DISTRIBUTION LIST
Addressees
TO: Superfund Branch Chiefs (Regions I - X)
Regional Counsel Branch Chiefs (Regions I - X)
CC: Superfund National Policy Managers (Regions I - X)
Regional Counsels (Regions I - X)
Information Management Coordinators (Regions I - X)
Budget Coordinators (Regions I - X)
Financial Management Coordinators (Regions I - X)
Michael B. Cook
Betsy Southerland
Susan Bromm
Elliott Gilberg
OSRTI Division Directors and Branch Chiefs
Charlotte Englert
Paul Connor
Kathleen Johnson
Neilima Senjalia
David Hindin (2222A)
James Woolford ( 5106G)
Dana Stalcup
Susan Janowiak (5103)
Terry Eby
Mark Mjonness
Lance Elson (2261A)
Randy Hippen
Marie Bell (5106G)
Willie Griffin
Sharon Blandford
Kenneth Lovelace
Ken Skahn
Terry Jeng
Richard Jeng
Tracy Hopkins
Mark Savedoff
Karin Koslow
Dela Ng
Dan Dickson
Pat Kennedy
Kevin Brittingham (2733R)
Nancy Riveland
Patricia Gowland
Hans Waetjen
Joshua Barber
Steven Blankenship
Kathryn Frasso
Deborah Dietrich
Kerron Weston
Melinda Dickens
TomDeHoff
Charles Young
Final Change 2, FY 04/05 SPIM
-------
| A \ DISTRIBUTION LIST
I v\i/7 * Addressees
sr&
*1 PROl*-
TO: Superfund Branch Chiefs (Regions I - X)
Regional Counsel Branch Chiefs (Regions I - X)
CC: Superfund National Policy Managers (Regions I - X) StevenWilson
Regional Counsels (Regions I - X) Eric Steinhaus
Information Management Coordinators (Regions I - X)
Budget Coordinators (Regions I - X)
Financial Management Coordinators (Regions I - X)
Michael B. Cook
Betsy Southerland
Susan Bromm
Elliott Gilberg
OSRTI Division Directors and Branch Chiefs
Charlotte Englert
Paul Connor
Kathleen Johnson
Neilima Senjalia
David Hindin (2222A)
James Woolford ( 5106G)
Dana Stalcup
Susan Janowiak (5103)
Terry Eby
Mark Mjonness
Lance Elson (2261A)
Randy Hippen
Marie Bell (5106G)
Willie Griffin
Sharon Blandford
Kenneth Lovelace
Ken Skahn
Terry Jeng
Richard Jeng
Tracy Hopkins
Mark Savedoff
Karin Koslow
Dan Dickson
Pat Kennedy
Kevin Brittingham (2733R)
Nancy Riveland
Randy Hippen
Patricia Gowland
Joshua Barber
Steven Blankenship
Kathryn Frasso
Deborah Dietrich
Kerron Weston
Melinda Dickens
TomDeHoff
Charles Young
Monica Gardner
Bernard Schorle
Final Change 3, FY 04/05 SPIM
-------
^tosx
$ A \ DISTRIBUTION LIST
, v\i/7 ° Addressees
PRO^
TO: Superfund Branch Chiefs (Regions I - X)
Regional Counsel Branch Chiefs (Regions I - X)
CC: Superfund National Policy Managers (Regions I - X) Steven Wilson
Regional Counsels (Regions I - X) Eric Steinhaus
Information Management Coordinators (Regions I - X) Lantha Gilmore
Budget Coordinators (Regions I - X) Barbara Edmonson
Financial Management Coordinators (Regions I - X) Bernard Schorle
Michael B. Cook
Betsy Southerland
Susan Bromm
Elliott Gilberg
OSRTI Division Directors and Branch Chiefs
Charlotte Englert
Paul Connor
Neilima Senjalia
David Hindin (2222A)
James Woolford ( 5106G)
Dana Stalcup
Susan Janowiak (5103)
Terry Eby
Mark Mjonness
Lance Elson (2261A)
Randy Hippen
Marie Bell (5106G)
Willie Griffin
Sharon Blandford
Kenneth Lovelace
Ken Skahn
Terry Jeng
Richard Jeng
Tracy Hopkins
Mark Savedoff
Karin Koslow
Dan Dickson
Pat Kennedy
Kevin Brittingham (2733R)
Nancy Riveland
Randy Hippen
Patricia Gowland
Joshua Barber
Steven Blankenship
Kathryn Frasso
Deborah Dietrich
Kerron Weston
Melinda Dickens
TomDeHoff
Charles Young
Monica Gardner
Final Change 4, FY 04/05 SPIM
-------
| A \ DISTRIBUTION LIST
I v\i/7 * Addressees
sr&
*1 PROl*-
TO: Superfund Branch Chiefs (Regions I - X)
Regional Counsel Branch Chiefs (Regions I - X)
CC: Superfund National Policy Managers (Regions I - X) Eric Steinhaus
Regional Counsels (Regions I - X) Lantha Gilmore
Information Management Coordinators (Regions I - X) Barbara Edmondson
Budget Coordinators (Regions I - X) Bernard Schorle
Financial Management Coordinators (Regions I - X) Catherine Allen
Michael B. Cook Kim Jennings
Kathy .Tones Phyllls Anderson
Elizabeth Southerland
Susan Bromm
Elliott Gilberg
OSRTI Division Directors and Branch Chiefs
Laura Milton
Charlotte Englert
Paul Connor
Neilima Senjalia
David Hindin (2222A)
James Woolford ( 5106G)
Dana Stalcup
Susan Janowiak (5103)
Terry Eby
Mark Mjonness
Lance Elson (2261A)
Randy Hippen
Marie Bell (5106G)
Eric Steinhaus
Willie Griffin
Sharon Blandford
Kenneth Lovelace
Ken Skahn
Terry Jeng
Richard Jeng
Tracy Hopkins
Mark Savedoff
Karin Koslow
Dan Dickson
Pat Kennedy
Kevin Brittingham (2733R)
Randy Hippen
Patricia Gowland
Joshua Barber
Steven Blankenship
Deborah Dietrich
Kerron Weston
Melinda Dickens
TomDeHoff
Sue Priftis
Charles Young
Monica Gardner
Final FY 04/05 SPIM
-------
^tosx
$ A \ DISTRIBUTION LIST
, v\i/7 ° Addressees
PRO^
TO: Superfund Branch Chiefs (Regions I - X)
Regional Counsel Branch Chiefs (Regions I - X)
CC: Superfund National Policy Managers (Regions I - X) Eric Steinhaus
Regional Counsels (Regions I - X) Lantha Gilmore
Information Management Coordinators (Regions I - X) Barbara Edmondson
Budget Coordinators (Regions I - X) Bernard Schorle
Financial Management Coordinators (Regions I - X) Catherine Allen
Michael B. Cook Kim Jennings
Kathy .Tones Phyllls Anderson
Elizabeth Southerland
Susan Bromm
Elliott Gilberg
OSRTI Division Directors and Branch Chiefs
Laura Milton
Charlotte Englert
Paul Connor
Neilima Senjalia
David Hindin (2222A)
James Woolford ( 5106G)
Dana Stalcup
Susan Janowiak (5103)
Terry Eby
Mark Mjonness
Lance Elson (2261A)
Randy Hippen
Marie Bell (5106G)
Eric Steinhaus
Willie Griffin
Sharon Blandford
Kenneth Lovelace
Ken Skahn
Terry Jeng
Richard Jeng
Tracy Hopkins
Mark Savedoff
Karin Koslow
Dan Dickson
Pat Kennedy
Kevin Brittingham (2733R)
Randy Hippen
Patricia Gowland
Joshua Barber
Steven Blankenship
Deborah Dietrich
Kerron Weston
Melinda Dickens
TomDeHoff
Sue Priftis
Charles Young
Monica Gardner
Final FY06/07 SPIM and Change 6, FY 04/05 SPIM
-------
^tosx
$ A \ DISTRIBUTION LIST
, v\i/7 ° Addressees
PRO^
TO: Superfund Branch Chiefs (Regions I - X)
Regional Counsel Branch Chiefs (Regions I - X)
CC: Superfund National Policy Managers (Regions I - X) Eric Steinhaus
Regional Counsels (Regions I - X) Lantha Gilmore
Information Management Coordinators (Regions I - X) Barbara Edmondson
Budget Coordinators (Regions I - X) Bernard Schorle
Financial Management Coordinators (Regions I - X) Catherine Allen
Michael B. Cook Kim Jennings
Kathy .Tones Phyllls Anderson
Elizabeth Southerland L°ri ^ee
Susan Bromm Finan
Elliott Gilberg Armando Santiago
OSRTI Division Directors and Branch Chiefs Mary Bell
Laura Milton
Charlotte Englert
Paul Connor
Neilima Senjalia
David Hindin (2222A)
James Woolford ( 5106G)
Dana Stalcup
Susan Janowiak (5103)
Terry Eby
Mark Mjonness
Lance Elson (2261A)
Randy Hippen
Marie Bell (5106G)
Eric Steinhaus
Willie Griffin
Sharon Blandford
Kenneth Lovelace
Ken Skahn
Terry Jeng
Richard Jeng
Tracy Hopkins
Mark Savedoff
Karin Koslow
Pat Kennedy
Kevin Brittingham (2733R)
Randy Hippen
Patricia Gowland
Joshua Barber
Steven Blankenship
Deborah Dietrich
Kerron Weston
Melinda Dickens
TomDeHoff
Sue Priftis
Charles Young
Monica Gardner
FINAL Change 1, Final FY06/07 SPIM and Change 7, FY 04/05 SPIM
-------
Impact Analysis
Change 1, FY 04/05 SPIM
22 SEP 03
The following are potential impacts resulting from the Change 1, FY 04/05 SPIM that may affect
WasteLAN. The impacts identified are based on a limited review of the data. Additional impacts
may be identified once the requirements analysis is complete.
Manager's Schedule
No impacts anticipated.
Chapter II
No impacts anticipated.
Chapter III
As a result of changes made to the Who Pays For What Chart, there may be an impact on the
SCAP-04 report and the financial management screens to allow regions to plan TAGs, FF
Oversight, Community Involvement and Five-year Review non-site specifically.
Appendix A
No impacts anticipated. Changes have already been made to add ERS Exclusion and NFFA
decisions.
Appendix B
A new action 'Ready for reuse determination' will need to be added to WasteLAN. In addition, the
SCAP Information screens along with the Site Status and Description/Operable Units screen will
need to be updated to include new data fields for tracking acreage and sites with land ready for
reuse data.
SCAP-14 and SCAP-15 may need to be updated to reflect change in responsibility of removal
measures. SCAP-15 will need to be updated to include the new GPRA measures for reuse and final
remedy selected.
Appendix C
Add two new qualifiers of 'Windfall Lien' and 'Reasonable Steps' to be made available for the
Comfort Status Letters action.
Two new actions "107(r) Windfall Lien" and "Windfall Lien Assessment" with a SubAction of "All
Necessary Information Received by EPA" and Action Qualifiers will need to be added to
WasteLAN. A new Enforcement Instrument Categories Selected of "Windfall Lien Resolution
Agreement" will need to be added under the action of "Consent Agreement."
Enforcement reports will be updated to reflect new measures of 'Windfall Lien Filed' and Windfall
Lien Resolution - Assessed and Finalized' and addition of the type of Comfort Status Letters action.
The ENFR-03 will need to be updated to give credit on the date of the PRP's written notice of intent
to comply for all Unilateral Administrative Orders for response work.
Appendix D
-------
No Impact anticipated.
Appendix E
No impact anticipated.
Appendix H
No impact anticipated.
Appendix M
Action lead codes of 'CG' and 'SG' will be deleted as available action leads for removal actions. In
addition, the SCAP-14 and SCAP-15 reports will be modified to reflect the lead code changes and
to reflect the changes in responsibilities (i.e., non-time critical removals to be tracked by OSRTI).
-------
Impact Analysis
Change 2, FY 04/05 SPIM
24 FEBRUARY 04
The following are potential impacts resulting from the Change 2, FY 04/05 SPIM that may affect
WasteLAN. The impacts identified are based on a limited review of the data. Additional impacts may be
identified once the requirements analysis is complete.
Manager's Schedule
No impacts anticipated.
Chapter 1
No impacts anticipated.
Chapter 2
As a result of changes made to the Target and Definition Change Requests, sites cannot be substituted for
five-year review targets, and the Five-Year Reviews must be completed by the actual completion date for
each site. The Additional Site Selection screen may need to be modified to exclude Five Year Reviews.
Chapter 3
The action lead table may need to be updated to take out the MR lead as an available lead for the Five-
Year Reviews. The SCAP-04 report may need to be updated based on changes to the 'Who Pays for
What' table. WasteLAN has been updated to accommodate the new program results codes.
Appendix A
No impacts anticipated.
Appendix B
As a result of changes made to the Decision Documents Developed section, the required data screens for
the Cost Summary screen will need to be modified to reflect changes. SCAP-14 logic may need to be
modified to accommodate this change.
Change the subaction name of RA On-Site Construction Sub Action to RA On-Site Construction Start. The
Five Year Review planned completion date has been changed to five years after the RA On-Site
Construction Start Sub Action planned completion date instead of after the start date.
The action lead table may need to be updated to take out the MR lead as an available lead for Five-Year
Reviews.
Appendix C
No impacts anticipated.
Appendix D
Change the subaction name of RA On-Site Construction Sub Action to RA On-Site Construction Start.
Appendix E
No impacts anticipated.
Appendix G
-------
SCAP-15 has been modified to accommodate new GPRA strategic goals.
Appendix H
No impacts anticipated.
Appendix J
No impacts anticipated.
-------
Impact Analysis
Change 3, FY 04/05 SPIM
12 JULY 04
The following are potential impacts resulting from the Change 3, FY 04/05 SPIM that may affect
WasteLAN. The impacts identified are based on a limited review of the data. Additional impacts may be
identified once the requirements analysis is complete.
Manager's Schedule
No impacts anticipated.
Chapter 2
A database revision is needed to update the workplanning targets for FY 05.
Appendix A
SCAP-15 has been modified to accommodate new GPRA strategic goals.
Appendix B
Database and application changes are needed to update lead codes for O&F, FCOR and PCOR. The data
rules for entering information for Land Ready for Reuse have changed and will require application
changes.
Appendix E
No impacts anticipated.
-------
Impact Analysis
Change 4, FY 04/05 SPIM
20 SEPTEMBER 04
The following are potential impacts resulting from the Change 4, FY 04/05 SPIM that may affect
WasteLAN. The impacts identified are based on a limited review of the data. Additional impacts may be
identified once the requirements analysis is complete.
Managers' Schedule
No impact
Chapter 2
No impact
Chapter 3
The new 'Action Codes for Financial Transactions' table in Chapter 3 will have a substantive impact on
SCAP reports and Budget AOA screens, and could possibly impact reference tables and application
behavior. A thorough review of the 'Action Codes for Financial Transactions' table is needed to fully
understand all of the impacts to WasteLAN.
Appendix A
No impact
Appendix B
No impact
Appendix C
No impact
-------
Impact Analysis
Change 5, FY 04/05 SPIM
10 January 05
The following are potential impacts resulting from the Change 5, FY 04/05 SPIM that may affect
WasteLAN. The impacts identified are based on a limited review of the data. Additional impacts may be
identified once the requirements analysis is complete.
Chapter 3
New Program Results Codes were added for BRAC. The Program Results Code for Federal Facilities
Enforcement was changed.
Appendix A
No impact
Appendix B
Added new Five Year Review Report Due subaction.
Significant changes have been made to Environmental Indicators including new measures. The outdated
Environmental Indicators module was replaced with the current Environmental Indicator data entry screens.
The Add/Edit EI and Exposures/Releases Controlled worksheets can now be accessed in one location by
selecting Program Management.
Appendix D
No impact
-------
Impact Analysis
Change 6, FY 04/05 SPIM
1 April 05
The following are potential impacts resulting from the Change 6, FY 04/05 SPIM that may affect
WasteLAN. The impacts identified are based on a limited review of the data. Additional impacts may be
identified once the requirements analysis is complete.
Chapter 3
No impact
-------
Impact Analysis
Change 7, FY 04/05 SPIM
12 September 05
The following are potential impacts resulting from the Change 7, FY 04/05 SPIM that may affect
WasteLAN. The impacts identified are based on a limited review of the data. Additional impacts may be
identified once the requirements analysis is complete.
Chapter 2
No impact
Chapter 3
New appropriation codes were added for Superfund Homeland Security and Superfund Carryover -
Deobs. These codes should be made available in WasteLAN.
Appendix A
New measure "Referred from RCRA" should be added to WasteLAN to correspond with the new
measure added to the SPIM.
Appendix B
No impact
Appendix C
No impact
Appendix E
No impact
-------
OSWER Directive 9200.3-14-1G-Q
Superfund Program Implementation Manual FY 04/05
Managers' Schedule of Significant Events
Change 1, FY 04/05 SPIM
September 22, 2003
-------
OSWER Directive 9200.3-14-1G-Q
This Page Left
Intentionally Blank
April 7, 2003
FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
MANAGERS' SCHEDULE OF SIGNIFICANT EVENTS
CERCLIS/WasteLAN is 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.
FY 04
OCTOBER 2003 OUARTER 1 (FY 04)
21
The AAs and OC approve the first and second quarter AOA
7
HQ pulls national environment indicators (EI) data from WasteLAN
7
HQ pulls 4th quarter FY 03 accomplishment data from WasteLAN and provides for:
1) Special program reports and
2) Initial FY 03 end-of-year Program Assessment
7
HQ pulls 4th quarter FY 03 accomplishment data from WasteLAN for review of end of year
accomplishments and inclusion in Annual Performance Report.
7
HQ pulls WasteLAN data to assist in preparation for FY 04 work planning.
Mid
HQ/Regions begin work planning sessions on the final FY04 GPRA Annual Performance Goals and
Program Targets/Measures and budget.
NOVEMBER 2003
TBD
SF National Policy Managers Meeting
TBD
AA/RA Priorities Meeting for FY 05
4-6
Superfund Focus Forum (SFF) - San Antonio, TX
15
Regions submit draft deobligation plans to OERR and OSRE
Late
OMB passback of FY 05 budget request
DECEMBER 2003
Late
Nov/
Early
Dec
HQ appeal of the OMB FY 05 budget passback
dependent on approval of final appropriations.
Change 1, FY 04/05 SPIM i
September 22, 2003
-------
OSWER Directive 9200.3-14-1G-Q
JANUARY 2004 OUARTER 2 (FY 04)
8
SCAP Pull for First Quarter FY 04 accomplishments - 5th working day of the month
Mid
Headquarters sends memorandum to regions on final budgets, GPRA annual performance goals, and
program targets/measures.
Mid
Regions revise WasteLAN to reflect final negotiated budget and GPRA performance goals and
targets/measures.
FEBRUARY 2004
Early
HQ submits FY 05 Annual Performance Plan (budget request) to the President
20
HQ distributes FY 03 EI analysis to HQ/Regional managers
MARCH 2004
5
HQ pulls data from WasteLAN for 3rd quarter AOA for FY 04
22
HQ submits 3rd quarter AOA request to the AA/SWER and places it in WasteLAN
29
Regions input AOA into IFMS
TBD
Headquarters publishes Annual Performance Report for FY 03
APRIL 2004 OUARTER 3 (FY 04)
5
The AAs and OC approve the 3rd quarter AOA
7
HQ pulls accomplishment data from WasteLAN and provides for:
1) Special program reports; and
2) Mid-Year Work Planning evaluation
7
HQ pulls national environmental indicators (EI) data from CERCLIS
16
NPMs issue National Program Guidance for FY 05-06
MAY 2004
7
HQ analysis of Regional pipeline (upcoming year and one year out) and historical performance
trends
14
HQ program offices characterize and submit their FY 05 program initiatives to the Regional
Administrator.
July 12, 2004
ii
Change 3, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
MAY 2004 (cont'd)
28 HQ program offices meet with the Administrator to review FY 05 program goals
28 HQ sends memorandum to Regions on proposed budgets and GPRA annual performance goals and
program targets/measures
Late Annual Goal Team Meetings with Deputy Administrator on FY 04 progress and FY 06 priorities
Late Superfund Focus Forum (technical)
JUNE 2004
3-25 Regions generate their plans for FY 05 and FY 06 by ensuring updated schedules and financial
information in WasteLAN
7 HQ pulls financial data for analysis of Regional obligation/commitment rates
7 HQ presents FY 05 Superfund goals and priorities and FY 06 investments to the Administrator and
Regional Administrators
11 Administrator and OC provide HQ program offices and Regions with policy for FY 06 budget
formulation
21 HQ submits 4th quarter AOA request to the AAs and places it in WasteLAN
28 Regions input AOA to IFMS
JULY 2004 QUARTER 4 (FY 04)
2 The AAs and OC approve the 4th quarter AOA
8 HQ pulls planning information from WasteLAN:
1) for fourth quarter AOA; and
2) to support FY 05 and FY 06 budget request
3) to prepare for FY 05 Workplanning
8 HQ pulls 3rd quarter accomplishment information from WasteLAN.
8 Enforcement provides:
1) Special program reports; and
2) 3rd quarter performance evaluations
Early HQ offices submit proposed FY 06 budgets
Change 3, FY 04/05 SPIM
iii
July 12, 2004
-------
OSWER Directive 9200.3-14-1G-Q
JULY 2004 (cont'd)
12-16 HQ program offices and lead Regions make presentation to Administrative/Deputy Administrator
on FY 06 program priorities [FY 04 Budget Forum]
Mid HQ/Regions begin work planning sessions on the final FY 05 GPRA annual performance goals and
program targets/measures and budget
19-23 Regional conference call on HQ analyses
Late Administrator passback of FY 06 budget request
AUGUST 2004
3 Draft GPRA commitments due to OCFO
Mid HQ develops FY 06 budget for submission to the Office of Management and Budget (OMB)
6 HQ pulls WasteLAN data to assist in preparation of the FY 06
Late HQ develops strategy for presenting the FY 06 budget to OMB
TBD Final revisions to FY 06 APGs and APMs due to OCFO
SEPTEMBER 2004
1 Final GPRA commitments due to OCFO
Early HQ submits FY 06 budget to OMB
8 HQ pulls data from WasteLAN for first quarter FY 05 AOA
Mid HQ performs final FY 05 Full Time Equivalent (FTE) distribution
20 HQ submits FY 05 first quarter AOA request to the AAs and places it in WasteLAN
271 Regions input AOA to IFMS
1 Dependent on approval of final appropriations.
July 12, 2004 iv
Change 3, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
FY 05
OCTOBER 2004 OUARTER 1 (FY 05)
41
The AAs and OC approve the first and second quarter AOA
7
HQ pulls national Environment Indicators (EI) data from WasteLAN
7
HQ pulls 4th quarter FY04 accomplishment data from WasteLAN and provides for:
1) Special program reports; and
2) Initial FY 04 end-of-year Program Assessment
7, 15
HQ pulls 4th quarter FY04 accomplishment data from WasteLAN for review of end of year
accomplishments and inclusion in Annual Performance Report
7
HQ pulls WasteLAN data to assist in preparation of the FY 05 work planning.
Mid
HQ sends memorandum to regions on final budgets, GPRA annual performance goals and program
targets/measures
Mid
Regions revise WasteLAN to reflect final negotiated budget and GPRA performance goals and
targets/measures
26-28
Superfund Focus Forum (SFF)
NOVEMBER 2004
TBD
SF National Policy Managers Meeting
15
Regions submit draft FY 05 deobligation plans to OERR and OSRE
Late
OMB passback of FY 06 budget request
TBD
AA/RA Priorities Meeting for FY 04
DECEMBER 2004
Late
Nov/
Early
Dec
HQ appeal of the OMB FY 06 budget passback
IDependent on approval of final appropriations.
Change 4, FY 04/05 SPIM v
September 20, 2004
-------
OSWER Directive 9200.3-14-1G-Q
JANUARY 2005 QUARTER 2 (FY 05)
7 SCAP Pull for First Quarter FY 05 Accomplishments - 5th working day of the month
FEBRUARY 2005
Early HQ submits FY 06 Annual Performance Plan (budget request) to the President
22 HQ distributes FY 04 EI analysis to HQ/Regional managers
MARCH 2005
7 HQ pulls data from WasteLAN for 3rd quarter AOA for FY 05
21 HQ submits 3rd quarter AOA request to the AA/SWER and places it in WasteLAN
28 Regions input AOA into IFMS
TBD Headquarters publishes Annual Performance Report for FY 04
APRIL 2005 QUARTER 3 (FY 05)
7 The AAs and OC approve the 3rd quarter AOA
7 HQ pulls accomplishment data from WasteLAN and provides for:
1) Special program reports; and
2) Mid-Year Work Planning evaluation
7 HQ pulls national Environmental Indicators (EI) data from CERCLIS
TBD NPMs issue consolidated guidance for FY 06-07
July 12, 2004
vi
Change 3, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
MAY 2005
6 HQ analysis of Regional pipeline (upcoming year and one year out) and historical performance
trends
16 HQ program offices characterize and submit their FY04 program initiatives to the Regional
Administrator
27 HQ sends memorandum to Regions on proposed budgets and GPRA annual performance goals and
program targets/meausres
31 HQ program offices meet with the Administrator to review FY 06 program goals
Late Annual Goal Team Meetings with Deputy Administrator on FY 05 progress and FY 07 priorities
Late Superfund Focus Forum (technical)
JUNE 2005
3-27 Regions generate their plans for FY 06 and FY 07 by ensuring updated schedules and financial
information in WasteLAN
7 HQ pulls planning information from WasteLAN:
1) for fourth quarter AO A; and
2) to support FY 06 and FY 07 budget request
7 HQ pulls financial data for analysis of Regional obligation/commitment rates
7 HQ presents FY 06 Superfund goals and priorities and FY 07 investments to the Administrator and
Regional Administrators
13 Administrators and OC provide HQ program offices and Regions with policy for FY 07 budget
formulation
20 HQ submits 4th quarter AOA request to the AAs and places it in WasteLAN
27 Regions input AOA to IFMS
JULY 2005 QUARTER 3 (FY 05)
5 The AAs and OC approve the 4th quarter AOA
8 HQ pulls planning information from WasteLAN:
1) for fourth quarter AOA; and
2) to support FY 06 and FY 07 budget request
3) to prepare for FY06 Workplanning
Change 3, FY 04/05 SPIM
vii
July 12, 2004
-------
OSWER Directive 9200.3-14-1G-Q
JULY 2005 (cont'd)
8 Enforcement provides:
1) Special program reports; and
2) 3rd quarter performance evaluations
Early HQ offices submit proposed FY 07 budgets
11-15 HQ program offices and lead Regions make presentations to Administrative/Deputy Administrator
on FY 07 program priorities [FY 07 Budget Forum]
Mid HQ/Regions begin work planning sessions on the final FY 06 GPRA annual performance goals and
program targets/measures and budget
18-22 Regional conference call on HQ analyses
Late Administrator passback of FY 07 budget request
AUGUST 2005
3 Draft GPRA commitments due to OCFO
5 HQ pulls WasteLAN data to assist in preparation of the FY 07 budget
Mid HQ develops FY 07 budget for submission to the Office of Management and Budget (OMB)
Late HQ develops strategy for presenting the FY 07 budget to OMB
SEPTEMBER 2005
1 Final GPRA commitments due to OCFO
Early HQ submits FY 07 budget to OMB
8 HQ pulls data from WasteLAN for first quarter FY 06 AOA
Mid HQ performs final FY 06 Full Time Equivalent (FTE) distribution
19 HQ submits FY 06 first quarter AOA request to the AAs and places it in WasteLAN
261 Regions input AOA to IFMS
1 Dependent on approval of final appropriations.
July 12, 2004 viii
Change 3, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Acronyms
FY 04/05 SPIM
April 7, 2004
-------
OSWER Directive 9200.3-14-1G-Q
This Page Left
Intentionally Blank
April 7, 2003
FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
AA
Assistant Administrator
AA OSWER
Assistant Administrator for the Office of Solid Waste and Emergency Response
AA OECA
Assistant Administrator for the Office of Enforcement and Compliance Assurance
AAU
Administrative Assistance Unit
AC
Area Committee
ACP
Area Contingency Plan
ADCR
Automated Document Control Register
ADR
Alternative Dispute Resolution
AHRC
Allowance Holder/Responsibility Center
AN
Account Number
AO
Administrative Order
AOA
Advice of Allowance
AOC
Administrative Order on Consent
AOG
Agency Operating Guidance
APG
Annual Performance Goal
APM
Annual Performance Measure
AR
Administrative Record
ARAR
Applicable or Relevant and Appropriate Requirements
ARCS
Alternative Remedial Contracting Strategy
ARIP
Accidental Release Information Program
ARM-
Administration and Resources Management
ASF
Above-ground Storage Facility
AST
Above-ground Storage Tank
ASTM
American Society for Testing and Materials
ASTSWMO
Association of State and Territorial Solid Waste Management Officials
ASTW
Above-ground Storage Tank Workgroup
ASU
Administrative Support Unit
ATSDR
Agency for Toxic Substances and Diseases Registry
ATSDR HAZDAT
Agency for Toxic Substances and Diseases Registry Hazardous Data System
BC/AOA
Budget Control/Advice of Allowance
BCT
Base Cleanup Team
BLM
Bureau of Land Management
BRAC
Base Realignment or Closure
BTAG
Biological Technical Assistance Group
BUREC
Bureau of Reclamation
CA
Cooperative Agreement
CADD
Corrective Action Decision Document
CAG
Community Advisory Group
CAS No.
Chemical Abstract Number
CBD
Commerce Business Daily
CD
Consent Decree
CEPP
Chemical Emergency Preparedness and Prevention Program
CEPPO
Chemical Emergency Preparedness and Prevention Office (OSWER)
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
CFO
Chief Financial Officer
CI
Community Involvement
CIAO
Citizen Information and Access Offices
CIC
Community Involvement Coordinator
CIOC
Community Involvement & Outreach Center (OERR)
CIP
Community Involvement Plan
FY 04/05 SPIM
xi
April 7, 2004
-------
OSWER Directive
9200
'.3
-14-1G-Q
CLP
CN
CO
COI
CPCA
CR
CRP
CWA
CWG
DA
DAS
DCN
DNAPL
DOD
DoD
DOE
DOI
DOJ
DOT
DPO
DRG
EBS
EE/CA
EI
EMSL
ENRD
EPA
EPA-ACH -
EPA ID
EPCRA
EPI
EPIC
EPS
ERA
ERCS
ERNS
ERRS
ERT
ESAT
ESD
ESF
ESI
ESI/RI
ESS
ETS
FAD
FCO
FCOR
FE
FEMA
FFA
FFCA
FFEO
April 7, 2003
Contract Laboratory Program
Commitment Notice
Contracting Officer
Conflict of Interest
Core Program Cooperative Agreement
Community Relations (Please see CI & CIP also)
Community Relations Plan (Please see CI & CIP also)
Clean Water Act
Community Work Groups
Deputy Administrator
Delivery of Analytical Services
Document Control Number
Dense Non-Aqueous Phase Liquids
Deputy Office Director
Department of Defense
Department of Energy
Department of the Interior
Department of Justice
Department of Transportation
Deputy Project Officer
District Response Group
Environmental Baseline Survey
Engineering Evaluation/Cost Analysis
Environmental Indicators
Environmental Monitoring Systems Laboratory
Environment and Natural Resources Division (DOJ)
Environmental Protection Agency
EPA Automated Clearing House
EPA Identification Number
Emergency Planning and Community Right to Know Act of 1986
Environmental Priorities Initiative
Environmental Photographic Interpretation Center
Environmental Protection Specialist
Expedited Response Action
Emergency Response Cleanup Services
Emergency Response Notification System
Emergency and Rapid Response Services
Environmental Response Team
Environmental Services Assistance Team
Explanation of Significant Differences
Emergency Support Function
Expanded Site Inspection
Expanded Site Inspection/Remedial Investigation
Enforcement Support Services
Electronic Timesheet System
Final Assessment Decision
Funds Certifying Officer
Final Close-Out Report
Federal Enforcement
Federal Emergency Management Agency
Federal Facility Agreement
Federal Facility Compliance Agreement
Federal Facilities Enforcement Office
xii FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
FFRRO
Federal Facilities Restoration and Reuse Office
FFIS
Federal Facilities Information System
FFS
Focused Feasibility Study
FMC-Ci
Financial Management Center - Cincinnati
FMD
Financial Management Division
FMFIA
Federal Managers Financial Integrity Act
FMO
Financial Management Office
FOIA
Freedom of Information Act
FOSL
Finding of Suitability to Lease
FOST-
Finding of Suitability to Transfer
ER
Federal Register
FRP
Facility Response Plan
FS
Feasibility Study
FTE
Full-time Equivalent
FUDS
Formerly Used Defense Sites
FY
Fiscal Year
FY/Q
Fiscal Year/Quarter
GAD
Grants Administration Division
GAO
General Accounting Office
GFO
Good Faith Offer
GICS
Grants Information Control System
GIS
Geographic Information System
GNL
General Notice Letter
GPRA
Government Performance and Results Act
HAZDAT
Hazardous Data System
HHS
Health and Human Services
HI
Hazard Index
HQ
Headquarters
HRS
Hazard Ranking System
HSWA
Hazardous and Solid Waste Amendments
HWC
Hazardous Waste Collection
IAG
Interagency Agreement
ICIS
Integrated Compliance Information System
IFMS
Integrated Financial Management System
IG
Inspector General
IMC
Information Management Coordinator
IMCenter
Information Management/Program Measurement Center (OERR)
IMS
Integrated Management Strategy
IOTV
Interoffice Transfer Voucher
LAN
Local Area Network
LEPC
Local Emergency Planning Committee
LERP
Local Emergency Response Plan
LOC
Letter of Credit
LOE
Level of Effort
LTCS
Long Term Contracting Strategy
LTRA
Long Term Response Action
MAD
Method Accuracy and Description (MAD Code)
MAG
Management Advocacy Group
MARS
Management and Accounting Reporting System
MM/DD/YY
Month/Day/Y ear
MMS
Minerals Management Service
MOA
Memorandum of Agreement
MOHR
Magnitude of Hazard Reduction
FY 04/05 SPIM
xiii
April 7, 2004
-------
OSWER Directive 9200.3-14-1G-Q
MORR
Magnitude of Risk Reduction
MOU
Memorandum of Understanding
MSCA
Multi-Site Cooperative Agreement
NACEPT
National Advisory Committee on Environmental Policy and Technology
NAPL-
Non-Aqueous Phase Liquid
NBAR
Non-Binding Allocation of Responsibility
NCP
National Oil and Hazardous Substances Pollution Contingency
Plan or National Contingency Plan
NEPPS
National Environmental Performance Partnership System
NFRAP
No Further Remedial Action Planned
NOAA
National Oceanic and Atmospheric Administration
NOS
Not Otherwise Specified
NPL
National Priorities List
NPM
National Program Manager
NRC
National Response Center
NRS
National Response System
NRT
National Response Team
NSEP
National Security Emergency Preparedness
NSFCC
National Strike Force Communication Center
NTC
Non-Time Critical
NTIS
National Technical Information Services
NTSD
National Technical Support Division
OAM
Office of Acquisition Management
OARM
Office of Administration and Resources Management
OBCR
Office of Brownfields Cleanup and Redevelopment
OC
Office of the Comptroller
OCFO
Office of the Chief Financial Officer
OD
Office Director
OECA
Office of Enforcement and Compliance Assurance
OERR (Now OSRTI)
Office of Emergency and Remedial Response (OSWER)
O&F
Operational and Functional
OGC
Office of General Counsel
OIG
Office of the Inspector General
O&M
Operation and Maintenance
OMB
Office of Management and Budget
OPA
Oil Pollution Act of 1990
OPAC
On-line Payment and Collections
OPC
Oil Program Center
OPRP
Oil Pollution Response & Prevention Center (OERR)
ORC
Office of Regional Counsel
ORD
Office of Research and Development
OSC
On-Scene Coordinator
OSRE
Office of Site Remediation and Enforcement (OECA)
OSRTI
Office of Superfund Remediation and Technology Innovation
OSW
Office of Solid Waste
OSWER
Office of Solid Waste and Emergency Response
OU
Operable Unit
OUST
Olfice of Underground Storage Tanks (OSWER)
PA
Preliminary Assessment
PAH
Polyaromatic Hydrocarbons
PARM
Policy Analysis & Resources Management Center (OERR)
PC
Personal Computer
PCB
Polychlorinated biphenyl
PCOR
Preliminary Close-Out Report
February 6, 2004 xiv Change 2, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
PECB
Program Evaluation & Coordination Branch (OSRE)
PNRS
Preliminary Natural Resource Surveys
PO
Project Officer
POLREP
Pollution Report
POS
Program Operations Staff (OSRE)
PPED
Policy & Program Evaluation Division (OSRE)
PPG
Performance Partnership Grants
PQOP
Pre-Qualified Officers Procurement
PR
Procurement Request
PPA
Prospective Purchaser Agreement
PREP
Preparedness Response Exercise Program
PRP
Potentially Responsible Party
PRSC
Post Removal Site Controls
PSO
Program Support Office
QA
Quality Assurance
QAPP
Quality Assurance Project Plan
QAT
Quality Action Team
RA
Remedial Action
RAC
Response Action Contract
RADS
Risk Assessment Data System
RAGS
Risk Assessment Guidance for Superfund
RCMS
Removal Cost Management System
RCP
Regional Contingency Plan
RCRA
Resource Conservation and Recovery Act
RCRC
Regional Cost Recovery Coordinator
RD
Remedial Design
RD/RA
Remedial Design/Remedial Action
RDT
Regional Decision Team
REMT
Regional Emergency Preparedness Team
RESAT
Regional Environmental Services Assistance Team
RFP
Request for Proposal
RI
Remedial Investigation
RI/FS
Remedial Investigation and Feasibility Study
RME
Reasonable Maximum Exposure
RMP
Risk Management Plan
ROC
Remedial Oversight Contract
ROD
Record of Decision
RPM
Remedial Project Manager
RPO
Regional Project Officer
RRT
Regional Response Team
RTP
Research Triangle Park
SACA
Site Assessment Cooperative Agreement
SACM
Superfund Accelerated Cleanup Model
SAM
Site Assessment Manager
SARA
Superfund Amendments and Reauthorization Act of 1986
SAS
Special Analytical Services
SB/RTC
Statement of Basis/Response to Comments
SCAP
Superfund Comprehensive Accomplishments Plan
SCORPIOS
Superfund Cost Recovery Package and Image On-Line System
SDMS
Superfund Document Management System
SEP
Supplemental Environmental Project
SERC
State Emergency Response Commission
SERP
State Emergency Response Plan
FY 04/05 SPIM
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SFO
SI
SIBAC
SIP
SITE
SME
SMOA
SMP
SMSA
SNAP
SNL
SOL
SOW
SPCC
SPIM
SRA
SRIS
SRP
SSA
SSAB
ssc
SSID
SSP
START
STSI
TAG
TAT
TDD
TOSC
TRC
TRW
TSCA
TSD
UAO
USCG
USACE
USFWS
USGS
VRP
WA
WAM
WasteLAN
ZPO
Servicing Finance Olfice
Site Inspection
Simplified Interagency Billing and Collection
Site Inspection Prioritization
Superfund Innovative Technology Evaluation
Subject Matter Expert
Superfund Memorandum of Agreement
Site Management Plan
Standard Metropolitan Statistical Area
Superfund National Assessment Program
Special Notice Letter
Statute of Limitations
Statement of Work
Spill Prevention Control and Countermeasure
Superfund Program Implementation Manual
Superfund Reform Act
Superfund Report Information System
Superfund Redevelopment Program
Site Screening and Assessment
Site Specific Advisory Board
Superfund State Contracts
Site/Spill Identification Number
Site Safety Plan
Superfund Technical Assistance and Response Team
State, Tribal, & Site Identification Center (OERR)
Technical Assistance Grants
Technical Assistance Team
Technical Direction Document
Technical Outreach Services for Communities
Technical Review Committee
Technical Review Workgroup
Toxic Substances Control Act
Treatment, Storage, Disposal Facility
Unilateral Administrative Order
United States Coast Guard
U.S. Army Corps of Engineers
United States Fish and Wildlife Service
United States Geological Survey
Vessel Response Plan
Work Assignment
Work Assignment Manager
CERCLA Information System
Zone Project Officer
April 7, 2003
xvi
FY 04/05 SPIM
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Organizational Charts
FY 04/05 SPIM
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Intentionally Blank
April 7, 2003
FY 04/05 SPIM
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Office of Solid Waste & Emergency Response
Office of the Assistant
Administrator (AA, DAA,
Innovation Partnerships,
& Communications
Office, Land
Revitaiization Group)
Federal Facilities
Restoration & Reuse
Office
Office of Brownfields
Cleanup &
Redevelopment
Technology Innovation
Office
Chemical Emergency
Preparedness &
Prevention Office
Office of Program
Management
Office of Emergency
& Remedial
Response
Office of
Underground
Storage Tanks
Office of Solid
Waste
(To be revised at a later date)
FY 04/05 SPIM
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April 7, 2004
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Office of Superfund Remediation and Technology Innovation
(as of January 5,2004)
Sue Sladek, Spec. Asst.
Vacant, Spec. Asst.
Information Management
Branch
Patrick Gowland, Chief
John Cunningham, AC
Contracts Management
Branch
Vacant, Chief
State, Tribe, & Site
Identification Branch
Vacant, Chief
William Ross, AC
Science Policy
Branch
JoAnn Griffith. Chief
Technology Integration
& Information Branch
Jeff Heimerman, Chief
Budget, Planning, &
Evaluation Branch
Arthur Flaks, Chief
Human Resources
Branch
Gary Turner
Acting Chief
Analytical
Services Branch
Bruce Means, Chief
OD/DOD
Michael B. Cook, Director
Dana Tulis, Acting Dep. Director
Community Involvement
and Outreach Branch
Suzanne Wells, Chief
Technology Assessment
Branch
John Kingscott,Chief
Regions 3,4,5, 7, 8
Support Branch
David Lopez, Chief
Larry Zaragoza, AC
Regions 1.2*6, 9,10
Support Branch
Rafael Gonzalez, Chief
John Smith, AC
Environmental
Response Team
Joe Lafarnara, Chief
David Wright, DBC (EAST)
Dennises Valdes, DBC (WEST)
Resources
Management Division
Jeff La pe, Acting DD
Paige Peck, ADD
Assessment and
Remediation Division
Elizabeth Southerland, DD
Phyllis Anderson, ADD
Technology Innovation
and Field Services Division
Walt Kovalick.DD
Dana Tuiis, ADD
o
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Office of Enforcement and Compliance Assurance
£
3.
Olio; of Planning
Policy Analysis
& Oommunolioris
Assistant Administrator for
Enforcement and
Compliance Assurance
Administration and
Resource; Management
Support Staff
Federal Facilities
Enforcement Office
Office of
Environmental Justice
Planning, Prevention
omolinnco!
Site Remediation and
Enforcement Staff
Office of Criminal
Fnlofcenonf
Forensics,
arid Training
Office of
Fed cm I
Activities
Office of
Ragulaloiy
Enforcement
1 of Site
Roralialion
Enforcement
Office of
Compliance
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Office of Site Remediation Enforcement
Policy and Program
Evaluation Division
Program Evaluation
Team
Policy Integration
Team
Program Coordination
Team
Remediation
Enforcement
Management Team
Policy and Guidance
Branch
Policy and Guidance
Development Team
Regional Support Division
Program Evaluation
and Coordination
Branch
Program Operations Staff
Office of Site Remediation
Enforcement
Regions 1, 2, 6 & 9
Branch
Regions 5, 7, & 10
Branch
Regions 3, 4, & 8
Branch
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OSWER Directive 9200.3-14-1G-Q
Regional Map
FY 04/05 SPIM
April 7, 2004
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San
Francisco
X
X
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OSWER Directive 9200.3-14-1G-Q
DISCLAIMER
The policies and procedures established in this document are intended solely for the guidance of employees of
the U.S. Environmental Protection Agency. They are not intended 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 act
at variance with these policies and procedures and to change them at any time without public notice.
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Left Blank
September 22, 2003
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USE AND STRUCTURE OF THE MANUAL
The information in this Manual is targeted to Information Management Coordinators (IMCs), Remedial Project
Managers (RPMs), and On-Scene Coordinators (OSCs), and Regional Counsels. Its primary purpose is to provide
guidance to this audience on management of the Superfund program.
~ The FY 04/05 Superfund Program Implementation Manual contains information on:
Managers' Schedule of Significant Events;
Introduction;
Program planning and reporting requirements; and
~ Financial management.
In addition, the appendices at the end of the manual contain pipeline specific planning and reporting definitions.
Appendix A presents measure definitions for Site Assessment/NPL Listing;
~ Appendix B provides measure definitions for Response Actions;
Appendix C presents measure definitions for Enforcement;
~ Appendix D contains program priorities and measure definitions for Federal Facilities;
Appendix E provides information on Superfund Information Systems;
Appendix F no longer part of the SPIM. Oil program now assigned to OEPPR
~ Appendix G contains Government Performance and Results Act (GPRA) objectives, subobjectives and reporting
measures.
Appendix H contains measure definitions for Community Involvement.
Appendix J contains measure definitions for Tribal Involvement.
Appendix M contains measure definitions for Removals (contains language removed from Appendix B).
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September 22, 2003
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Table of Contents
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Superfund Program Implementation Manual FY 04/05
DISCLAIMER
Table of Contents
The policies and procedures established in this document are intended solely for the guidance of employees of
the U.S. Environmental Protection Agency. They are not intended 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 act
at variance with these policies and procedures and to change them at any time without public notice.
MANAGERS' SCHEDULE OF SIGNIFICANT EVENTS i
ACRONYMS ix
ORGANIZATIONAL CHARTS xvii
OSWER xix
OSRTI xx
OECA xxi
OS RE xxii
REGIONAL MAP xxiv
PROGRAM GOALS AND PLANNING REQUIREMENTS
CHAPTER I INTRODUCTION 1-1
I.A. Purpose 1-1
I.B. Superfund 1-2
I.B.I Introduction 1-2
I.B.2 Superfund and its History 1-3
I.C. Subject Matter Experts 1-4
CHAPTER II PROGRAM PLANNING AND REPORTING REQUIREMENTS II I
II.A Introduction II-1
II.B Integrated Planning II-2
II.C Introduction to the Superfund Comprehensive Accomplishment Plan (SCAP) II-3
II.D Relationship of SCAP to other Management Tools II-3
II.D.l Management Tools II-3
II.D.2 Superfund Information Systems II-5
II.E Overview of the Planning Process (SCAP) II-5
II.E.l Planning Year II-6
II.E.2 Operating Year II-7
II.F Change Control Requirements II-7
II.G HQ/Regional Roles and Responsibilities II-8
II.G.l Maintaining Planning/Accomplishment Data in WasteLAN II-8
II.G.2 Program Evaluation 11-10
II.H Procedures for Annual Target Setting 11-11
II.I Work Planning 11-11
11.1.1 Planning Process 11-12
11.1.2 WasteLAN Reports for Planning/Target Setting 11-13
II. J Regional Accomplishment Reporting 11-14
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Table Of Contents
Chapter II (cont'd)
WasteLAN Reports for Accomplishment Reporting II-l 5
II.K HQ Evaluation of Regional Performance 11-16
U.K. 1 Mid-Year Assessment 11-16
II.K.2 End-of-Year Assessment 11-17
ILK.3 Management Reporting 11-18
a. Superfund Management Reports 11-18
b. Annual Reporting Requirements 11-19
ILL Larget and Definition Change Requests 11-19
Maintaining the Planning Estimates/Largets 11-20
II.M Special Reporting Lopics 11-20
II.M.l Site Assessment 11-20
II.M.2 Base Closure 11-20
II.M.3 Pre-SARA Sites Initiative 11-20
II.M. l Mega Sites 11-21
II.M.5 Superfund Alternative Sites 11-21
II.N General Work Planning and Reporting Requirements 11-21
II.N.l Data Lockout on Historical Accomplishments 11-21
II.N.2 Data Validation and Verification 11-22
II.N.3 Action Lead Codes 11-22
II.N. l I cad Changes 11-24
II.N.5. Anomalies and Phased Projects 11-26
II.O Subject Matter Experts 11-27
CHAPTER III - SUPERFUND BUDGET PLANNING PROCESS AND FINANCIAL MANAGEMENT.. III-l
III.A. Introduction III-l
III.B. Budget Planning and Priorities III-l
III.B.l Budget Development Process III-l
a. Budget Formulation III-l
b. Budget Review and Planning (Planning Year) III-2
c. Budget Execution (Current Year) III-2
III.B.2 Budget Structure III-5
Program Results Code and National Program Managers III-5
III.B.3 Lhe FY04/05 Superfund Program Goals and Priorities III-6
a. Response Program Budget III-6
b. Homeland Security and Removal III-7
c. Enforcement Budget III-7
d. Federal Facilities Response Budget III-8
e. Base Realignment and Closure III-8
f. Federal Facilities Enforcement Budget III-8
III.C. Regional Operating Plan and Advice of Allowance Development III-9
III.C. 1 Allocating Superfund Resources Among the Regions III-9
III.C.2 Remedial Response Program Budget Ill-10
a. Remedial Action AOA Ill-10
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Table of Contents
Chapter in (cont'd)
b. Pipeline Operations AOA Ill-10
III.C.3 Homeland Security/Removal Response Program Budget Ill-11
III.C.4 Federal Facilities Superfund Response Program Budget Ill-11
a. Base Realignment and Closure (BRAC) Budget Ill-11
III.C.5 Enforcement Program Budget Ill-12
III.C.6 Federal Facilities Enforcement Program Budget Ill-12
III.C.7 Deobligating Prior Year Ends Ill-12
III.C.8 Budget Object Classes Ill-13
III.C.9 Regional Change Requests for Reprogramming Among AO As Ill-13
III.C. 10 Budget Sources and Associated Action Codes Ill-13
III.D Superfund Financial Management 111-26
III.D.l Financial Management Roles and Responsibilities 111-26
a. Regional Financial Management Office 111-26
b. Regional Administrator 111-26
c. Regional Program Office 111-27
d. On Scene Coordinator 111-27
e. Remedial Project Manager 111-27
f. Regional Project Officer/Deputy Project Officer 111-28
g. Administrative Support Unit 111-28
h. Office of Financial Management/Office of the Chief Financial Officer 111-28
i. Office of Acquisition Management 111-28
j. Grants Administration Division/Office of Administration 111-29
k. Budget Division/OCFO 111-29
1. Cincinnati Finance Center (CFC)/OFS 111-29
m. Research Triangle Park (RTP) Finance Center/OFS 111-29
III.D.2 Superfund Accounting Information 111-29
III.D.3 Financial Data Management Systems and Tools 111-32
III.D.4 Handling Financial Data in the CERCLIS/WasteLAN Environment 111-33
a. Entering Response and Federal Facility Data into CERCLIS/WasteLAN 111-33
b. Entering Enforcement Extramural Budget Data into CERCLIS/WasteLANI-33
c. Correcting Financial Data 111-34
III.D.5 The Funding Process 111-36
a. Approvals 111-36
b. Commitments 111-36
c. Obligations 111-37
d. Payments 111-37
e. Deobligations 111-37
III.D.6 Financial Management of Contracts 111-38
a. Contracts for Site-Specific Work 111-38
b. Contracts for Non-Site Specific Work 111-38
III.D.7 Other Financial Vehicles 111-40
a. Interagency Agreements 111-40
b. Cooperative Agreements (CA) 111-40
c. Superfund State Contracts (SSCs) 111-41
III.E Cost Recovery Process 111-42
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Chapter in (cont'd)
III.E.l Cost Recovery Referral Development Process 111-43
a. Initiation of Cost Recovery Process 111-43
b. Cost Documentation and Reconciliation 111-43
c. Work Performed Documentation and Reconciliation 111-43
d. Site File Maintenance 111-43
e. Superfund Indirect Costs 111-43
f. Annual Allocation 111-44
g. Cashout/Special Accounts 111-44
h. Department of Justice Involvement 111-44
III.F Superfund Financial Contact Information 111-45
III.F.l Regional Cost Recovery Contacts 111-45
III.F.2 Headquarters Cost Recovery Contacts 111-46
III.F.3 Regional Budget Coordinators 111-47
III.F.4 Subject Matter Experts 111-48
INDEX A
PROGRAM IMPLEMENTATION PROCEDURES
APPENDIX A - Site Assessment/NPL Listing Targets and Measures
A.A. SITE ASSESSMENT/NPL LISTING FY 04/05 TARGETS AND MEASURES A-l
A.A.I Site Assessment Program & NPL Listing Priorities A-l
A.A.2 Site Assessment Backlogs A-l
A.A.3 Overview of FY 04/05 Site Assessment/NPL Listing Targets and Measures A-2
A.A.4 GPRA and Site Assessment A-2
A.A.5 Site Status Indicators A-4
A.A.6 Data Quality A-6
A.A.I Action Qualifiers for Site Assessment Actions (LANGUAGE FROM CH 2) A-6
a. No Further Remedial Action Planned (NFRAP) A-6
b. Former Evaluation A-6
c. Perform a Removal A-l
d. Defer the Site to RCRA (Subtitle C) or the NRC A-l
e. Sites addressed as part of existing NPL sites A-l
f. Sites addressed as part of other existing non-NPL sites A-l
A.A. 8 Special Initiatives A-8
A.A.9 Site Assessment/NPL Listing Definitions A-9
a. Pre-CERCLIS Screening Assessments A-9
b. Referred from RCRA A-11
c. Site Discovery A-12
d. Sites Archived A-13
e. Preliminary Assessments (PA) at Non-Federal Facility Sites A-14
f. Federal Facility Preliminary Assessment Reviews A-16
g. Site Inspections (SI) at Non-Federal Facility Sites A-18
h. Combined PA/SI Assessments at Non-Federal Facility Sites A-20
i. Federal Facility Combined PA/SI Reviews A-21
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Appendix A (cont'd)
j. Site Inspection Prioritizations (SIPs) at Non-Federal Facility Sites A-22
k. Site Reassessment A-24
1. Expanded Site Inspections (ESI) at Non-Federal Facility Sites A-25
m. Federal Facility SI Reviews A-26
n. Federal Facility ESI Reviews A-28
o. Integrated Expanded Site Inspection/Remedial Investigation (ESI/RI)
at Non-Federal Facility Sites A-29
p. State Deferral of Non-Federal Facility Sites A-30
q. Hazard Ranking System Package (HRS) A-32
r. Integrated Removal/Remedial Evaluation A-33
s. NPL Listing A-35
t. Other Cleanup Activity A-37
A.B. SUBJECT MATTER EXPERTS A-39
APPENDIX B - Response Action
B.A Current Program Priorities - B-l
BA.l Protecting Human Health and the Environment B-l
a. Removal Actions B-l
b. Homeland Security B-l
c. Pipeline Management Review/RA Construction B-2
d. Post Construction B-4
e. Superfund Alternative Sites B-5
BA.2 Maximizing Program Efficiency and Effectiveness B-6
a. Innovative Technologies B-6
b. Contract Management B-7
c. Redevelopment B-7
d. Reforms B-8
B.B FY 04/05 RESPONSE TARGETS AND MEASURES B-8
B.B.I Overview of FY 04/05 Response Actions Targets/Measures B-8
B.B.2 Superfund Durations B-9
B.B.3 Record of Decision B-12
a. ROD Changes B-12
i. Other Remedy Changes B-12
ii. Explanation of Significant Differences (ESDs) B-12
iii. ROD Amendments B-l3
b. RODs Requiring No Physical Construction B-13
B.B.4 Response Action Definitions B-14
Part I. Remedy Selection
a. Remedial Investigation (RI) Starts (NPL & Superfund Alternative) B-14
b. Feasibility Study (FS) Starts (NPL & Superfund Alternative) B-17
c. Combined RI/FS Start (NPL & Superfund Alternative) B-20
d. Treatability Studies B-24
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Appendix B (cont'd)
e. Start of Public Comment Period (Proposed Plan to Public) (NPL &
Superfund Alternative) B-24
f. RI/FS Duration (NPL & Superfund Alternative) B-25
g. Engineering Evaluation/Cost Analysis (EE/CA) B-26
h. Decision Document Developed B-27
i. Final Remedy Selected B-29
Part II. Remedial Implementation
j. Removal Starts and Removal Completions THESE MEASURES HAVE
BEEN MOVED TO APPENDIX M B-30
k. Remedial Design (RD) Start (NPL & Superfund Alternative) B-30
1. RD Completion (NPL & Superfund Alternative) B-33
m. Remedial Action (RA) Start (NPL & PRP-lead Superfund Alternative) B-34
n. RA Contract Award (NPL & PRP-lead
Superfund Alternative) B-39
o. Start of On-Site Construction B-40
Groundwater Monitoring B-41
p. Operational and Functional (O&F) B-44
q. Completion of a Response Action/Activity (NPL & PRP-lead
Superfund Alternative) B-45
r. NPL Site Construction Completions B-48
Part III. Post Construction Completion
s. Long-Term Remedial Response (LTRA and PRP LR) (NPL & PRP-
lead Superfund Alternative) B-52
t. Operation and Maintenance (O&M) B-54
u. Cleanup Goals Achieved B-55
v. NPL Site Completions B-56
w. Five-Year Reviews B-57
x. Partial NPL Deletion B-59
y. Final NPL Deletion B-60
z. Sites with Land Ready for Reuse B-61
aa. Acres at Sites with Land Ready for Reuse B-63
Part IV. Environmental Indicators
bb. Long-Term Human Health Protection Indicator B-64
cc. Migration of Contaminated Ground Water Under Control B-67
dd. Populations Protected B-69
ee. Cleanup Volumes B-70
Part V. Support Activities
ff. Support Agency Assistance B-71
gg. Technical Assistance B-72
hh. Pre-design Assistance B-72
B.C SUBJECT MATTER EXPERTS B-74
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APPENDIX C - Enforcement
C.A FY04/05 TARGETS AND MEASURES FOR ENFORCEMENT c-i
C.A.I Overview C-I
C.A.2 Promoting the Superfund Enforcement Program C-2
CA.3 Targets and Measures for Baseline Enforcement C-7
Criteria for Credit of Enforcement Activities at Superfund Alternative Sites C-7
a. Potentially Responsible Party (PRP) Search Starts C-8
b. PRP Search Completions C-8
c. Section 104(e) Referrals and Orders Issued C-9
d. Issuance of General Notice Letters (GNLs) C-10
e. Issuance of Special Notice Letters (SNLs) C-10
f. Expanded Site Inspection/Remedial Investigation/Feasibility Study (ESI/RI/FS)
Negotiation Starts C-10
g. Remedial Design/Remedial Action (RD/RA) Negotiation Starts
(NPL & Superfund Alternative) C-ll
h. Completion or Termination of Negotiations for RD/RA (NPL & Superfund Alternative) C-12
i. Completion or Termination of Negotiations for Cleanup
(RD/RA, Removals, and Other) (NPL & Superfund Alternative) C-13
j. Percentage of Remedial Action Starts Initiated by PRPs at Non-Federal Facility NPL and Superfund
Alternative Sites C-15
k. Total Response Commitments (Including Dollar Value) C-16
1. Enforcement Settlements/Instruments for RD/RA/Long-Term Response (LR) C-17
m. De Minimis Settlements and Number of Parties C-19
n. Cashout Settlements C-20
o. Section 106, 106 and 107, 107 Case Resolution C-21
p. Issuance of Demand Letter C-22
q. Total Cost Recovery Settlements (Including Dollar Value) C-22
r. Past Costs Addressed > $200,000 Via Settlements, Write-Offs, or Referrals C-23
s. Recoverable Past Costs That Have Been Addressed by Program-to-Date Via
Settlements, Write-offs, or Referrals C-24
t. Number and Amount of CERCLA Penalties Assessed C-26
u. Number and Amount of CERCLA Supplemental Environmental Projects (SEPs) C-27
v. Use of Alternative Dispute Resolution (ADR) C-27
w. Number of Settlements Where EPA Settled Based On Ability-to-Pay Determinations C-29
x. Prospective Purchaser Agreements (PPAs) - Assessed and Finalized C-29
y. Issuance Of Comfort/Status Letters C-30
z. Orphan Share - EPA Offer and Compensation C-31
aa. Non-exempt De Micromis Parties Settlements and Number of Parties C-33
bb. PRP Oversight Administration C-34
Change 7, FY 04/05 SPIM
September 8, 2005
-------
OSWER Directive 9200.3-14-G-Q
Superfund Program Implementation Manual FY 04/05
Table Of Contents
Appendix C (cont'd)
cc. Settlements Designating Deposits to Special Accounts C-35
dd. Deposits into Special Accounts C-36
ee. Settlements Designating Disbursements from Special Accounts to PRPs C-37
ff. Disbursements From Special Accounts for Response Actions C-38
gg. Closure of Special Accounts C-39
hh. Pre-Remedial Enforcement Action at Superfund Sites C-40
ii. Windfall Lien Filed C-42
jj. Windfall Lien Resolution - Assessed and Finalized C-42
C.B SUBJECT MATTER EXPERTS C-13
APPENDIX D - Federal Facilities
D A. FEDERAL FACILITIES PRIORITIES I)-1
DA.l Overview D-l
DA.2 Superfund Federal Facility Goals and Priorities D-l
a. Strategic Federal Facility Goals D-l
DA.3 RCRA Activities at Federal Facility NPL Sites D-3
D.A.4 BRAC Budget and Financial Guidance D-3
a. Resources and Tracking Mechanisms D-3
b. Accountability for Resources D-4
D.A.5 Federal Facility Site Discovery/Site Assessment D-5
a. Overview D-5
b. Federal Facility Site Discovery and the Federal Facility Docket Process D-5
c. Time Frames for Conducting Federal Facility Site Assessment D-5
d. Authority for Conducting Federal Facility Site Assessment - E.O. 12580 D-6
e. Federal Facility Site Assessment Reports & EPA Review and FIRS Evalutaion D-7
D.B. FACILITIES FY 04/05 TARGETS AND MEASURES D-8
D.B.I Overview of FY 04/05 Federal Facilities Targets and Measures D-8
a. Reporting of Non-NPL Federal Facilities Data D-8
D.B .2 Federal Facilities Site Discovery/Site Assessment Definitions D-ll
a. Site Discovery D-ll
b. Federal Facility Preliminary Assessment Reviews D-12
c. Federal Facility SI Reviews D-l3
d. Federal Facility ESI Reviews D-14
D.B.3 Federal Facilities Definitions D-15
a. Base Closure Decisions D-15
b. Federal Facility Agreement (FFA)ZInteragency Agreement (IAG) D-16
c. Federal Facility Dispute Resolution D-17
d. Use of Supplemental Environmental Projects (SEPs) D-17
e. Remedial Investigation/Feasibility Study (RI/FS) or RCRA Facility
Investigation (RFI) Starts D-18
f. Timespan from Final NPL Listing to RI/FS or RFI Start D-18
September 8, 2005 Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Superfund Program Implementation Manual FY 04/05
Table of Contents
Appendix D (cont'd)
g. Decision Documents D-19
h. Final Remedy Selected/Final ROD Authority D-19
i. Explanations of Significant Difference (ESD) and ROD Amendments D-20
j. Remedial Design D-21
k. Duration of ROD to IAG Negotiation Completion D-22
1. Remedial Action (RA) or RCRA Corrective Measure Implementation (CMI) Starts . . . D-22
m. Timespan from ROD Signature to RA Start D-23
n. RA or CMI Completions D-23
o. Removal or RCRA Interim/Stabilization Measure (ISM) Starts and Completions . . . D-27
p. NPL Site Construction Completions D-27
q. Operation and Maintenance (O&M) D-30
r. Cleanup Goals Achieved D-30
s. Federal Facility Five-Year Reviews D-31
t. Federal Facility Partial NPL Deletion D-32
u. Federal Facility Final NPL Deletion D-33
D.B.4 Community Involvement Definitions D-34
a. Restoration Advisory Boards (RABs)/Site-Specific Advisory Boards (SSABs) D-34
b. Technical Assistance Grants (TAGs) this section is pending review by OGC and EPA
GRANTS D-34
c. Technical Outreach Services for Communities (TOSC) D-35
D C. SUBJECT MATTER EXPERTS D-35
Appendix E - Information Systems
E.A Information Systems E-l
EA.l The Purpose of WasteLAN E-l
a. Site Assessment E-l
b. Remedy Selection E-2
c. Federal Facilities E-3
d. Community Involvement E-3
e. Removal E-4
f. Enforcement E-5
g. Project Management E-6
h. Program Management E-6
EA.2 Superfund Data Architecture E-7
EA.3 Reporting Superfund Information E-8
WasteLAN Users E-9
EA.4 Applicability of the Freedom of Information Act E-10
a. Reports Releasable under Freedom of Information Act (FOIA) E-10
b. Sensitive Information Not Releasable under FOIA E-10
c. Ad Hoc Reporting E-13
d. Accessing FOIA Information E-l4
Change 1, FY 04/05 SPIM
September 8, 2005
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OSWER Directive 9200.3-14-G-Q
Superfund Program Implementation Manual FY 04/05
Table Of Contents
Appendix E (cont'd)
E.A.5 Data Owners/Sponsorship E-15
K B DATA SPONSORS E-16
APPENDIX F - Oil Pollution Prevention and Response Program is no longer included in the SPIM. Oil
program now assigned to OEPPR.
APPENDIX G - Government Performance and Results Act (GPRA)
G.A. GOVERNMENT PERFORMANCE AND RESULTS ACT (GPRA) OF 1993 G-l
Background G-l
G.A.I. Strategic Plan Requirements G-3
a. Comprehensive Mission Statement G-3
b. General Goals and Objectives G-3
c. Description of Flow General Goals and Objectives Will Be Achieved G-3
d. Goals in the Annual Performance Plan and in a Strategic Plan G-3
e. Key Factors Affecting Achievement of General Goals and Objectives G-3
f. Program Evaluations G-4
G.A.2 Annual Performance Plan G-4
a. Performance Goals G-4
b. Resources G-4
c. Performance Indicators G-4
d. Verification and Validation G-4
G.A.3. Annual Performance Report G-4
G.B. SUPERFUND GPRA STRUCTURE G-5
G.C. SUBJECT MATTER EXPERTS G-7
APPENDIX H - Community Involvement
II.A FY04/05 TARGETS AND MEASURES II-1
FLA.l Overview of FY04/05 Community Involvement Targets/Measures H-l
a. Community Advisory Groups (CAGs)/Restoration Advisory Boards (RABs)/
Site-Specific Advisory Boards (SSABs) H-l
b. Technical Assistance Grants (TAGs) H-2
c. Technical Outreach Services for Communities (TOSC) H-3
I I B CIOC DATA SPONSOR RESPONSIBILITIES 11-3
H.B.I Role of CIOC as a Data Sponsor H-3
H.B.2 National Program Requirements and the Data Sponsor Role H-4
Program Goals and Objectives H-4
Statutory Mandates H-4
September 8, 2005
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Superfund Program Implementation Manual FY 04/05
Table of Contents
Regulatory and Policy Requirements H-4
Superfund Reforms H-ll
Reauthorization, Congressional Inquiries and Audits H-ll
H.B.3 CIOC Headquarters and Regional Organization H-ll
H.B.4 Program Monitoring and Reporting H-12
Data Quality H-12
Management Reports H-13
Coding Guidance H-13
Modifications H-13
H.C Subject Matter Experts H-13
APPENDIX I (This Section Intentionally Left Blank)
APPENDIX J - Tribal Involvement
J.A. BUILDING SUPERFUND PARTNERSHIPS
J.A.I. Enhanced State and Tribal Capabilities J-l
J.A.2. Superfund Block Funding/EPA Performance Partnership Grants J-2
J.A.3. Funding for States and Tribes J-2
J.B. FY 04/05 TARGETS AND MEASURES
J.B.I. Overview J-2
a. Superfund Assessments Conducted at Sites that are of Concern to Tribes (Current FY/Inception
to Date) J-3
b. Percentage of Sites that are of Concern to Tribes which have had a Superfund Assessment . . . J-4
c. Tribes Supported by Superfund Cooperative Agreements J-4
d. Superfund Dollars Provided for Building Tribal Capacity J-5
e. Percentage of Superlimd Sites that are of Concern to Tribes Where a Tribe is Actively Involved J-5
J.C. SUBJECT MATTER EXPERTS J-6
APPENDIX K (This Section Intentionally Left Blank - Previously Assigned to Brownfields)
APPENDIX L (This Section Intentionally Left Blank)
APPENDIX M - Removals
M.A FY04/05 TARGETS AND MEASURES M-l
M.A.I Overview of FY04/05 Removal Targets/Measures M-l
a. Removal Starts M-2
b. Removal Completions M-4
M.B Subject Matter Experts M-6
Change 2, FY 04/05 SPIM
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
Superfund Program Implementation Manual FY 04/05
List of Exhibits
CHAPTER I - PROGRAM GOALS AND PRIORITIES
EXHIBIT 1.1 SUBJECT MATTER EXPERTS 1-4
CHAPTER II - PROGRAM PLANNING AND REPORTING REQUIREMENTS
EXHIBIT II. 1 FLEXIBILITY SCALE FOR BUDGETING/PLANNING II-4
EXHIBIT II.2 HQ/REGIONAL INTEGRATED PLANNING RESPONSIBILITIES II-5
EXHIBIT II.3 HQ/REGIONAL SCAP AND WasteLAN RESPONSIBILITIES II-8
EXHIBIT II.4 EVALUATION RESPONSIBILITIES 11-10
EXHIBIT II.5 PROCEDURES FOR ANNUAL TARGET SETTING 11-12
EXHIBIT II.6 SCAP PLANNING/TARGET SETTING WasteLAN REPORTS 11-14
EXHIBIT II.7 PROGRAM EVALUATION WasteLAN REPORTS 11-16
EXHIBIT II.8 THE REGIONAL EVALUATION PROCESS 11-17
EXHIBIT II.9 ACTION LEAD CODES IN WasteLAN 11-23
EXHIBIT 11.10 CODING OF TAKEOVERS 11-26
EXHIBIT 11.11 REMEDIAL EVENTS, ANOMALIES, AND PROJECT PHASING 11-27
EXHIBIT 11.12 SCAP REPORT CONTACTS 11-27
EXHIBIT 11.13 SUBJECT MATTER EXPERTS 11-28
CHAPTER III - SUPERFUND BUDGET PLANNING PROCESS AND FINANCIAL
MANAGEMENT
EXHIBIT III-l BUDGET TIME LINE 111-3
EXHIBIT III-2 PROGRAM RESULTS CODE (PRC) III-6
EXHIBIT III-3 WHO PAYS FOR WHAT III-l I
EXHIBIT III-4 ACTION CODES FOR FINANCIAL TRANSACTIONS 111-21
EXHIBIT III-5 ACCOUNT NUMBER STRUCTURE 111-3 I
September 8, 2005 Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Superfund Program Implementation Manual FY 04/05
List of Exhibits
Chapter III (cont'd)
EXHIBIT III-6 HANDLING FINANCIAL DATA IN THE CERCLIS/WASTELAN ENVIRONMENT 111-35
EXHIBIT III-7 EPA FORMS COMMONLY USED FOR SUPERFUND PROCUREMENTS 111-39
EXHIBIT III-8 REGIONAL SUPERFUND COST RECOVERY CONTACTS 111-45
EXHIBIT III-9 HEADQUARTERS SUPERFUND COST RECOVERY CONTACTS 111-46
EXHIBIT III-10 REGIONAL BUDGET COORDINATORS Ill- T
EXHIBIT III-l 1 HEADQUARTERS SUBJECT MATTER EXPERT CONTACTS 111-48
APPENDIX A
EXHIBIT A.l SITE ASSESSMENT/NPL LISTING ACTIVITIES A-3
EXHIBIT A.2 SITE ASSESSMENT ACTION QUALIFIERS A-8
EXHIBIT A.3 SUBJECT MATTER EXPERTS A-39
APPENDIX B
EXHIBIT B.l RESPONSE ACTION ACTIVITIES B-10
EXHIBIT B.2 LONG-TERM HUMAN HEALTH PROTECTION INDICATOR B-66
EXHIBIT B.3 SUPERFUND MIGRATION OF CONTAMINATED GROUND WATER
UNDER CONTROL WORKSHEET B-68
EXHIBIT B.4 SUBJECT MATTER EXPERTS B-74
APPENDIX C
EXHIBIT C.l ENFORCEMENT ACTIVITIES C-4
EXHIBIT C.2 SUBJECT MATTER EXPERTS C-13
Change 1, FY 04/05 SPIM
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Superfund Program Implementation Manual FY 04/05
List of Exhibits
APPENDIX D
EXHIBIT D.l FEDERAL FACILITIES ACTIVITIES D-9
EXHIBIT D.2 REMEDIAL PIPELINE FLOW CHARTS D-26
EXHIBIT D.3 SUBJECT MATTER EXPERTS D-35
APPENDIX E
EXHIBIT I - I SUPERFUND DATA ARCHITECTURE E-8
EXHIBIT E.2 DATA SPONSORS E-16
APPENDIX F - Oil Pollution Prevention and Response Program is no longer included in the SPIM. Oil
program now assigned to OEPPR.
APPENDIX G
EXHIBIT G.l SUBJECT MATTER EXPERTS G-7
APPENDIX H
EXHIBIT H.l COMMUNITY INVOLVEMENT REQUIREMENTS H-5
EXHIBIT H.2 CIOC HQ AND REGIONAL ROLES AND RESPONSIBILITIES H-12
EXHIBIT H.3 SUBJECT MATTER EXPERTS II-1 3
APPENDIX J
EXHIBIT J. 1. TRIBAL INVOLVEMENT ACTIVITIES J-3
EXHIBIT J.2. SUBJECT MATTER EXPERTS J-6
APPENDIX M
EXHIBIT M.l REMOVAL ACTION ACTIVITIES M-l
EXHIBIT M.2 SUBJECT MATTER EXPERTS M-6
September 8, 2005 Change 7, FY 04/05 SPIM
-------
FY 04/05 SPIM
CHANGE 7 LOG
12 SEPTEMBER 05
Section
Requestor
Change Description
Chapter 2
Exhibit 11.13 SCAP Report Contacts
Randy Hippen
Delete Terry Jeng as a contact for the SCAP-13
report.
Exhibit 11.13 SCAP Report Contacts
Brenda Haslett
Remove Dan Dickson from exhibit.
Exhibit 11.14 Subject Matter Experts
Robert White
Add Julie Roemele.
Chapter 3
III.D.2 Superfund Accounting
Information
Robert White
Added new Appropriation Codes for Superfund
Homeland Security and for Superfund Carryover -
Deobs.
Exhibit III.7 Cost Recovery Contacts
Lynne Kershner
Remove Ruth Broome and add Diane Norton.
Appendix A
A.A.4 GPRA and Site Assessment
Randy Hippen
Corrected the 2008 FAD goal and added language
that will prevent removal-only sites from being
considered as FAD candidates.
A.A.9.a - A.A.9.t
Robert White
Modified the language of tlie"Data Must be
Entered By" column of the Data Entry Timeliness
Requirement section to read:
-It is good management practice to enter data regarding
the event as soon as practicable after the event occurs.
However, data must be entered prior to the end of the
quarter in which the event occurs."
A.A.8 Special Initiatives
Randy Hippen
Added a new section to Appendix A regarding
Special Initiatives.
A.A.9.b Referred from RCRA
Randy Hippen
Added a new section regarding Referred from
RCRA.
A.A.9.f FF Preliminary Assessment
Review
Lynne Kershner
Change the language in the start column (of the
Data Entry Timeliness table) to say "Region
begins review of Federal Facility PA report."
A.A.9.h FF Combined PA/SI Review;
A.A.9.m FF SI Review;
A.A.9.n FF ESI Review
Lynne Kershner
Add language in the start column (of the Data
Entry Timeliness table) to say "Region begins
review of Federal Facility SI report (or Combined
PA/SI report, or ESI report)." Also add
'Technical Direction Document."
A.A.9.q Hazard Ranking System
Package (HRS)
Randy Hippen
Added language regarding regional quality control
reviews of HRS Packages.
A.A.9.S NPL Listing
Randy Hippen
Removed NPL deletion text from NPL Listing
action section.
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FY 04/05 SPIM
CHANGE 7 LOG
12 SEPTEMBER 05
Section
Requestor
Change Description
Appendix B
B.B.3.a - B.B.3.hh
(Exceptions below)
Robert White
Modified the language of the"Data Must be
Entered By" column of the Data Entry Timeliness
Requirement section to read:
-It is good management practice to enter data regarding
the event as soon as practicable after the event occurs.
However, data must be entered prior to the end of the
quarter in which the event occurs."
B.B.3.i Final Remedy Selected
Brenda Haslett
Deleted language that Final Remedy Selected
determination can be made at Deletion, PC OR or
FCOR. This ensures consistency with CERCLIS.
B.B.3.V NPL Site Completions;
B.B.3.W Five Year Reviews;
B.B.3.x Partial NPL Deletion;
B.B.3.y Final NPL Deletion
Robert White
Modified the language of the"Data Must be
Entered By" column of the Data Entry Timeliness
Requirement section to read:
Within 5 working days, but no later than 10
working days.
Exhibit B.2 Long-Term Human Health
Protection Indicator
Brenda Haslett
Add Long-Term Human Health Protection
Indicator
B.C. Subject Matter Experts
Brenda Haslett/
Robert White
Remove Dan Dickson and James Konz and add
Mary Bell to SME list.
Appendix C
C.A.I Overview
Alice Ludington/
Myra Cypser
Modify the language in this section in the third,
fourth and fifth paragraph.
C.A.3 Targets and Measures for
Baseline Enforcement
Alice Ludington/
Myra Cypser
Modify the language in the first paragraph to read,
"WasteLAN coding requirements contained in the
definitions below are only for key data elements."
C.A.3.e Issuance of SpecialNotice
Letters
Alice Ludington/
Myra Cypser
Modify the language of the Definition.
C.A.3.g Remedial Design/Remedial
Action (RD/RA) Negotiation Starts
Alice Ludington/
Myra Cypser
Modify the language of the Definition of
Acc omp lishment.
C.A.3.k Total Response Commitments
Alice Ludington/
Myra Cypser
Modify the language of the Definition of
Acc omp lishment.
C.A.3.1 Enforcement Settlements/
Instruments for RD/RA/Long Term
Response (LR)
Alice Ludington/
Myra Cypser
Modify the language of the Definition and
Definition of Accomplishment.
C.A.3.mDe Minimis Settlements and
Number of Parties
Alice Ludington/
Myra Cypser
Modify the language of the Definition of
Acc omp lishment.
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FY 04/05 SPIM
CHANGE 7 LOG
12 SEPTEMBER 05
Section
Requestor
Change Description
C.A.3.r Past Costs Addressed
>$200,000 via Settlements, Write-offs
or Referrals
Alice Ludington/
Myra Cypser
Modify the language of the Definition of
Acc omp lishment.
Exhibit C.2 Subject Matter Experts
Alice Ludington/
Myra Cypser
Remove Dan Dickson and add Amy Tuberson and
Mary Bell.
Appendix D
Exhibit D.3 Subject Matter Experts
Josh Barber
Added Brandon Roache and Tracey Seymour.
Appendix E
Exhibit E.2 Data Sponsors
Trish Gowland
Update the list of Data Sponsors.
DQOs
Site Assessment Reports Completed
Robert White/
Randy Hippen
Deleted Angelo Carasea as an SME.
Modified the language of the T imeliness section to
include: "It is good management practice to enter
data regarding the event as soon as practicable
after the event occurs. However, data must be
entered prior to the end of the quarter in which the
event occurs."
Number of Final Assessment Decisions
Robert White/
Randy Hippen
Deleted Angelo Carasea as an SME.
Modified the language of the Timeliness section to
include: "It is good management practice to enter
data regarding the event as soon as practicable
after the event occurs. However, data must be
entered prior to the end of the quarter in which the
event occurs."
Final Remedy Selected
Robert White
Added Tracey Seymour as an SME.
Modified the language of the Timeliness section to
include: "It is good management practice to enter
data regarding the event as soon as practicable
after the event occurs. However, data must be
entered prior to the end of the quarter in which the
event occurs."
Sites with Land Ready for Reuse;
Acres at Sites with Land Ready for
Reuse
Robert White
Modified the language of the Timeliness section to
include: "It is good management practice to enter
data regarding the event as soon as practicable
after the event occurs. However, data must be
entered prior to the end of the quarter in which the
event occurs."
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FY 04/05 SPIM
CHANGE 7 LOG
12 SEPTEMBER 05
Section
Requestor
Change Description
Human Exposure/Groundwater Under
Control
Robert White
Deleted Melanie Hoff and added Rich Norris as
the SME.
Modified the language of the T imeliness section to
include: "It is good management practice to enter
data regarding the event as soon as practicable
after the event occurs. However, data must be
entered prior to the end of the quarter in which the
event occurs."
Construction Completion
Robert White/
Richard Jeng
Modified the language of the Timeliness section to
read: The PCOR and FCOR actions should be
entered as the activity is completed. It is good
management practice to enter data regarding the
event as soon as practicable after the event occurs.
However, data for these actions must be entered
prior to the end of the quarter in which the event
occurs. However, final Construction Completion
approval, on which the GPRA measure is based, is
based upon review of the PCOR/FCOR
documentation by the Headquarters Construction
Completion Manager. Headquarters confirmation
of CC sites must be entered by the end of the fiscal
year in which the event occurred.
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FY 04/05 SPIM
CHANGE 6 LOG
1 APRIL 05
Section
Requestor
Change Description
Chapter 3
Table of Contents
III.D.l.h;
III.D.l.k ;
III.D.1.1;
III.D.l.m
Barbara
Edmondson
Updated Chapter Subtitles in TOC.
III.D.l.h Office of Financial
Management (OFM)/Office of the Chief
Financial Officer;
III.D.l.k Budget Division/OCFO;
III.D.1.1 Cincinnati Finance Center
(CFCJ - Office of Financial Services;
III.D. 1 .m Research Triangle Park (RTP)
Finance Center Office of Financial
Services
Barbara
Edmondson
Updated Chapter Subtitles.
III.D.3 Financial Data Management
Systems and Tools
Barbara
Edmondson
Deleted EPAYs language and added a bullet for
PeoplePlus.
III.D.4.C Correcting Financial Data
Barbara
Edmondson
Updated acronym for the OFM.
III.D.5.C Obligations
Barbara
Edmondson
Updated the name of the Cincinnati Finance
Center.
Exhibit III-8 Regional Cost Recovery
Contacts
Robert White
Update list of Regional Superfund Cost Recovery
Contacts.
Exhibit III-9 Headquarters Superfund
Cost Recovery Contacts
Robert White
Update list of HQ Superfund Cost Recovery
Contacts.
III.F.4 Subject Matter Experts
Barbara
Edmondson
Updated name of the Office of Financial
Management.
-------
FY 04/05 SPIM
CHANGE 5 LOG
10 JAN 05 (corrected 1 APR 05)
Section
Requestor
Change Description
SPIM DQO Supplement
Reference: "Response to OIG Final Audit Report 'Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS) Data Quality Audit Report No. 2002-P-00016," dated 24 DEC 02, from
Marianne L. Horinko, Assistant Administrator, Office of Solid Waste and Emergency Response (OSWER), to
Patricia H. Hill, Director, OIG Business Systems.
One Recommendation is addressed in Change 5: Please see below. This Text Added 1 APR 05
DQO SPIM Supplement
Dave Reynolds
Data Quality Objectives for Superfund measures.
This document does not supercede the SPIM and if
a conflict occurs, SPIM language will be the
standard.
Addresses OIG Recommendation 2-1
Chapter 3
III.B.l.a Budget Formulation;
III.B.3.d Federal Facilities Response
Budget;
III.B.3.e Base Realignment and
Closure;
III.C.4 Federal Facilities Response
Superfund Budget;
III.C.4.a Base Realignment and
Closure (BRAC);
III.D.l.b Regional Administrator
Josh Barber
Added language updating Federal facilities budget
information and adding language referring to
BRAC.
Exhibit III-2 Program Results Codes
Alan Youkeles
Change the designation of one of the Program
Results Codes from 302ED1 to 302EH2.
Exhibit III-2 Program Results Codes
Josh Barber
Add PRCs for BRAC.
Exhibit III-4 Action Codes for
Financial Transactions
Alan Youkeles
Change the designation of one of the Program
Results Codes from 302ED1 to 302EH2.
Exhibit III-4 Action Codes for
Financial Transactions
Josh Barber
Change the PRC for Site Specific BRAC costs.
Exhibit III-8 Superfund Cost Recovery
Contacts
Robert White
Update list of Superfund Cost Recovery Contacts.
-------
FY 04/05 SPIM
CHANGE 5 LOG
10 JAN 05 (corrected 1 APR 05)
Section
Requestor
Change Description
Appendix A
A.A.I Site Assessment Program &
NPL Listing Priorities;
A.A.4 GPRA and Site Assessment;
A.A.5 Site Status Indicators
Randy Hippen
Updated language.
A.A.8.C Sites Archived
Angelo Carasea/
Randy Hippen
Added a bullet to the Definition of
Acc omp lishment.
A.A.8.e Federal Facility PA Reviews;
A.A.8.1 Federal Facility SI Reviews;
A.A.8.m Federal Facility ESI Reviews
Randy Hippen
Deleted language regarding leads and modified the
information in the Data Entry Timeliness
requirement.
A.A.8.h Federal Facility Combined
PA/SI Review
Randy Hippen
Added language for a new Federal facilities
Combined PA/SI Review measure.
A.A.8.r Other Cleanup Activity
Angelo Carasea/
Randy Hippen
Modified the language for OCA starts and
completions.
A.B Subject Matter Experts
Victoria Van
Ro den/Randy
Hippen
Update Subject Matter Experts.
Appendix B
B.B.4.h Decision Document Developed
Jim Konz
Add language to Special Planning/Reporting
Requirements regarding the Five Year Review
subaction.
B.B.4.i Final Remedy Selected/Final
ROD Authority
RobinM
Anderson
Modify language for Final Remedy Selected
measure.
B.B.4.S Long-Term Remedial
Response
Jennifer Griesert
Modify the timeliness table to make it less
confusing.
B.B.4. w Five-Year Reviews
Jim Konz
Added language to Five-Year Review measure
regarding the new FYR Report Due subaction.
Part IV - Environmental Indicators
Rich Norris
There have been major changes to the EI section
including new measures and new exhibits.
-------
FY 04/05 SPIM
CHANGE 5 LOG
10 JAN 05 (corrected 1 APR 05)
Section
Requestor
Change Description
Appendix D
D.A.2.a Strategic Federal Facility
Goals
Josh Barber
Added a bullet about Environmental Management
Systems and Pollution Reduction Targets.
D.A.4.a Resources and Tracking
Mechanisms
Josh Barber
Added language regarding EPA financial tracking
systems
DA.5 Federal Facility Site Discovery/
Site Assessment
Josh Barber
Added new section about Federal Facility Site
Discovery/Site Assessment.
D.B.2 Federal Facility Site Discovery/
Site Assessment Definitions
Josh Barber
Added new section with the definitions for Federal
Facility Site Discovery/Site Assessment measures.
D.B.2.S Federal Facility Five-Year
Reviews
Jim Konz/ Josh
Barber
Added language to Federal Facility Five-Year
Review measure regarding the new FYR Report
Due subaction.
-------
FY 04/05 SPIM
CHANGE 4 LOG
20 SEP 04
Section
Requestor
Change Description
Managers' Schedule
Page v, October 2004
Robert White
Modified date for HQ 4th quarter FY 04
accomplishment data pull. Corrected date of the
S up e rfun d F o cu s Fo rum.
Chapter II
II. J Regional Accomplishment
Reporting
Robert
White/
Eugene
Rainwater
Added note regarding new Data Entry Timeliness
tables.
Chapter III
Exhibit III-4
Alan
Youkeles
Added "Action Codes for Financial Transactions"
chart which takes effect in FY 2005.
Subject Matter Experts
Robert White
Updated the list of Subject Matter Experts.
Appendix A
Reference: "Response to OIG Final Audit Report 'Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS) Data Quality Audit Report No. 2002-P-00016," dated 24 DEC 02, from
Marianne L. Horinko, Assistant Administrator, Office of Solid Waste and Emergency Response (OSWER), to
Patricia H. Hill, Director, OIG Business Systems.
One Recommendation is addressed in Change 4: Please see "Timeliness" Change below.
General
Robert White
Added a new 'Data Entry Timeliness Requirements'
section for appropriate measures.
Addresses OIG Recommendation 2-2
Appendix B
Reference: "Response to OIG Final Audit Report 'Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS) Data Quality AuditReport No. 2002-P-00016," dated 24 DEC 02, from
Marianne L. Horinko, Assistant Administrator, Office of Solid Waste and Emergency Response (OSWER), to
Patricia H. Hill, Director, OIG Business Systems.
One Recommendation is addressed in Change 4: Please see " Timeliness" Change below.
General
Robert White
Added a new 'Data Entry Timeliness Requirements'
section for appropriate measures.
Addresses OIG Recommendation 2-2
B.B.4.p Operational and Functional;
B.B.4.q Completion of a Response
Actio n/Activity
Teresa Jones/
Debra Potter
Language changed for clarity.
Subject Matter Experts
Robert White
Updated the list of Subject Matter Experts.
Appendix C
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FY 04/05 SPIM
CHANGE 4 LOG
20 SEP 04
Section
Requestor
Change Description
C.A.3.hh Pre-Remedial Enforcement
Actions at Superfund Sites
Dan Dickson
Language changed for clarity.
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FY 04/05 SPIM
CHANGE 3 LOG
12 JULY 04
Section
Requestor
Change Description
Table of Contents/Use and Structure
General
Robert White
Change CEPPO to OEPPR.
Mangers' Schedule
Managers' Schedule
Sherri Clark
Updated dates for workplanning.
Chapter II
II.E Overview of the planning process &
II.E.l Planning Year
Sherri Clark
Updated dates for workplanning.
Exhibit II.5 Procedures for FY 04/05
Target Setting
Sherri Clark
Updated dates for workplanning.
II.M.l Site Assessment
Sherri Clark
Deleted unnecessary language.
Appendix A
Reference: "Response to OIG Final Audit Report 'Comprehensive Environmental Response,
Compensation, and Liability Information System (CERCLIS) Data Quality' Audit Report No.
2002-P-00016," dated 24 DEC 02, from Marianne L. Horinko, Assistant Administrator, Office
of Solid Waste and Emergency Response (OSWER), to Patricia H. Hill, Director, OIG Business
Systems.
Two Recommendations are addressed in Change 3: Please see below.
A.A.I Site Assessment Program and
NPL Listing Priorities
Angelo Carasea
Removed language regarding the NACEPT
Subcommittee.
A.A.4 GPRA and Site Assessment
Angelo Carasea
Updated section to reflect new GPRA
language and to include new GPRA measure:
Number of Site Assessments completed.
Exhibit A. 1 Site Assessment/NPL
Listing Activities
Angelo Carasea
Added new GPRA measure to the list of
activities
A.A.5 Site Status Indicators
Angelo Carasea
Added language to clarify the use of the non-
NPL status code of'SX'.
Addresses OIG Recommendation 3.3
to reduce the use of the 'SX" code.
A.A.6 Data Quality
Angelo Carasea
Added section on data quality which includes
a list of relevant Discovery and eFacts reports.
Addresses OIG Recommendation 3.1 to
"Revise SPIM to provide guidance on use of
reports "
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FY 04/05 SPIM
CHANGE 3 LOG
12 JULY 04
Section
Requestor
Change Description
Appendix B
B.B.4.p Operational and Functional
Tracy Hopkins/
Jennifer Griesert
Clarified language to indicate that fund is the
valid lead for O&F and updated O&F
completion definition.
B.B.4.q Completion of a Response
Action/Activity
Tracy Hopkins/
Jennifer Griesert
Clarified language regarding RA completion.
B.B.4.r NPL Site Construction
Completions
Tracy Hopkins/
Jennifer Griesert
Clarified language to indicate that fund is the
only valid lead for FCOR and PCOR.
B.B.4.S Long-Term Response Action
Tracy Hopkins/
Jennifer Griesert
Updated language to clarify definition.
B. B.4.t Operation and Maintenance
Tracy Hopkins/
Jennifer Griesert
Updated language to clarify the use of PRP
LR
B.B.4.III.u Cleanup Goals Achieved
Tracy Hopkins/
Jennifer Griesert
Definition revised to clarify what remedies the
subaction is applicable.
B.B.4.III.V NPL Site Completions
Tracy Hopkins/
Jennifer Griesert
Language revised to indicate that fund is the
only valid lead for the FCOR.
B.B.4.III.X Partial NPL Deletion
Tracy Hopkins/
Jennifer Griesert
Definition revised to clarify the use of start
dates.
B.BAIII.y Final NPL Deletion
Tracy Hopkins/
Jennifer Griesert
Definition revised to clarify the use of start
dates.
B.B.4.III.Z Sites with Land Ready for
Reuse
Melissa Friedland
Information for Sites with Land Ready for
Reuse will no longer be entered at pre-ROD
actions. Language was changed to clarify that
Reuse information will only be entered after
the Actual Completion dates are entered for
appropriate actions, except for Deletions.
B.B.4.III.aa Acres at Sites with Land
Ready for Reuse
Melissa Friedland
Information for Acres at Sites with Land
Ready for Reuse will no longer be entered at
pre-ROD actions. Clarified that Reuse
information will only be entered after the
Actual Completion dates are entered for
appropriate actions, except for Deletions.
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FY 04/05 SPIM
CHANGE 3 LOG
12 JULY 04
Section
Requestor
Change Description
Appendix E
Reference: "Response to OIG Final Audit Report 'Comprehensive Environmental Response,
Compensation, and Liability Information System (CERCLIS) Data Quality' Audit Report No.
2002-P-00016," dated 24 DEC 02, from Marianne L. Horinko, Assistant Administrator, Office
of Solid Waste and Emergency Response (OSWER), to Patricia H. Hill, Director, OIG Business
Systems.
One Recommendation is addressed in Change 3: Please see below.
E.A.4 b. Sensitive Information Not
Relea sable under FOIA
Dan Dickson
Revised text for clarification
E.A.5 Data Owners/Sponsorship
Angelo Carasea/
Randy Hippen
Revised section to reflect what data quality
checks (focus data studies) will be done.
Addresses OIG Recommendation 2.1
regarding Data Stewardship.
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FY 04/05 SPIM
CHANGE 2 LOG
24 FEB 04
Section
Requestor
Change Description
General
General - Changes through SPIM
Robert White
Change OERR to OSRLI and change CEPPO
to OEPPR.
Mangers' Schedule
Acronym List
Robert White
Added OSRLI to acronym list.
Organization Charts
Robert White
Added OSRLI organizational chart
Chapter I
Exhibit I.C Subject Matter Experts
Robert White
Updated Subject Matter Experts table.
Chapter II
II.L Larget and Definition Change
Requests
Jim Konz
Program Largets for Five Year Reviews have
been more clearly defined.
Chapter III
Exhibit III-2 Program Results Code
Lynne Kershner
Program layout and results codes have been
updated.
III.B.3 Superfund Program Goals and
Priorities
Lynne Kershner
Added a section on Homeland Security and
Removal goals and priorities. Updated the
description of Homeland Security and
Removal organization and corrected the
program results codes in subsection titles.
III.C.8 Budget Object Classes
Lynne Kershner
Corrected Budget Object Class names.
Exhibit III-3 Who Pays for What
Brenda Haslett/
Alan Youkeles
Leads have been modified for Five Year
Reviews in the "Who Pays for What" chart.
III.D.4.C Correcting Financial Data
Eugene Rainwater
Remove old reference to an Exhibit that has
been deleted.
Exhibit 111-10 Headquarters Subject
Matter Experts
Robert White
Lhe SME list has been updated.
Appendix A
Exhibit A.3 Subject Matter Experts
Robert White
Lhe SME list has been updated.
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FY 04/05 SPIM
CHANGE 2 LOG
24 FEB 04
Section
Requestor
Change Description
Appendix B
B.B.I Overview of FY 04/05 Response
Actions Targets/Measures
Jim Konz
Added language on Five-Year Reviews.
B.B.3.a ROD Changes
Flans Waetjen
Corrected address for EPA F1Q ROD
coordinator.
B.B.3.a.i, ii & iii Other Remedy
Changes, Explanation of Significant
Differences (ESDs), and ROD
Amendments
Flans Waetjen
Added language which describes the
requirements for an actual completion for the
Other Remedy Change, Explanation of
Significane Differences (ESDs) and ROD
Amendments.
B. B.4.I.h Decision Document
Developed
Flans Waetjen
Modified ROD Cost Data requirement to only
require cost data that is listed in the decision
document.
B.B.4.III.W Five Year Reviews
Jim Konz
Updated Five Year Reviews definition.
B.B.4.III.Z Sites with Land Ready for
Reuse
Flans Waetjen
Clarified definition for Sites with Land Ready
for Reuse.
Exhibit B.4 Subject Matter Experts
Robert White
The SME list has been updated.
Appendix C
Exhibit C.2 Subject Matter Experts
Robert White
The SME list has been updated.
Appendix D
D.B.2.S. Federal Facility Five-Year
Reviews
Jim Konz
Modified Five Year Review Special
Planning/R epo rting Re quirement.
Appendix E
E.A.4.a. Reports Releasable under
Freedom of Information Act (FOIA)
Eugene Rainwater/
Dan Dickson
Remove sentence on Section 106 and 107
litigation. Modified language on Section 106
and 107 litigation in section E .A.4.b.
Sensitive Information not Releasable under
FOIA.
Exhibit E.2 Data Sponsors
Robert White
The SME list has been updated.
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FY 04/05 SPIM
CHANGE 2 LOG
24 FEB 04
Section
Requestor
Change Description
Appendix G
G.A Background
Patricia Kennedy
Added language regarding measuring the
success of the Enforcement program.
G.B Superfund GPRA Structure
Peggy Scwebke
Updated Land Preservation and Restoration
goal language.
G.B Superfund GPRA Structure
Janet Weiner
Updated language based on FY 04 Strategic
Plan.
G.C Subject Matter Experts
Robert White
The SME list has been updated.
Appendix H
Exhibit H.3 Subject Matter Experts
Robert White
The SME list has been updated.
Appendix J
Exhibit J.2 Subject Matter Experts
Robert White
The SME list has been updated.
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FY 04/05 SPIM
CHANGE 1 LOG
22 SEP 03
Section
Requestor
Change Description
Manager's Schedule
Pull dates are the fifth working day of
the month.
Robert White
Modified pull dates to be the fifth working
day of the month.
Chapter II
II.L - Larget and Definition Change
Request
- Maintaining the Planning
Estimates/L argets
Alan Youkeles
Language updated to reflect site specific
targets listed in the Call Memo.
Chapter III
Exhibit III.6, Who Pays for What Chart
Alan Youkeles
Added a note to the LAG, FF Oversight,
Community Involvement and Five Year
Review actions for site designation noting that
these activities can be planed using 'WQ' but
must be obligated site-specifically.
III.D.l.e Remedial Project Manager
Lynne Kershner
Changed section title Remedial Program
Manager (RPM) to Remedial Project Manager
(RPM).
III.D.4 Entering Response and Federal
Facility Data into CERCLIS/WasteLAN
Leslie Peterson/
Lynne Kershner
Modified text reflect the current process.
III.D.6.b Contracts for Non-Site Specific
Work
Paige Peck
Modified text reflect the current process.
Appendix A
Exhibit A. 1 Site Assessment/NPL
Listing Activities
Randy Hippen
Non-NPL Site Status removed from Activity
column.
A.A.4 GPRA and Site Assessment
Randy Hippen
Added language to FAD decision to capture
OCAs.
A.A.5 Site Status Indicators
NEW SECTION
Randy Hippen
Added a new section for Site Status
Indicators. Also deleted the non-NPL Status
measure since it was captured in this new
section.
A.A.7.a Pre-CERCLIS Screening
Randy Hippen
Added language to the Pre-Screening
Definition to include language on sampling.
A.A.7.b Non-NPL Status
Randy Hippen
Section deleted.
A.A.7.C Sites Archived
Randy Hippen
Added link to access Guidance on Archiving
Sites.
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FY 04/05 SPIM
CHANGE 1 LOG
22 SEP 03
Section
Requestor
Change Description
A.A.7.C Sites Archived
Randy Hippen
Added language to the Changes in Definition
noting measure was updated concerning
unarchived sites.
AA.7.C Sites Archived
Randy Hippen
Added language to Special
Planning/Reporting Requirements describing
archive indicator in CERCLIS.
A.A.I.x Other Cleanup Activity
Randy Hippen/
Jennifer Griesert
Updated Other Cleanup Activity definition to
further define the start date.
Appendix B
BA.l.e Superfund Alternative Sites
Dela Ng
Deleted references to SACM in the Superfund
Alternative Sites summary. Also added
language to the summary to include Regions
seeking PRP-lead.
B.B.4.i Final Remedy Selected/Final
ROD Authority
NEW MEASURE
Robin M Anderson
Add language for new measure.
B.B.4.j Removal Starts and Removal
Completions
Dana Stalcup
Removed Removal Start and Removal
Completion measures and placed in new
Appendix M.
B.B.4.j Removal Starts and Removal
Completions
Dana Stalcup
References to Coast Guard lead removals
have been removed. Coast Guard lead
removal starts are recorded non-site-
spec ifically.
B.B.4.x Partial NPL Deletion
Jennifer Griesert
Deleted reference to NPL Status of Partially
Deleted from the NPL. This statement is
untrue as there is no NPL status of Partially
Deleted from the NPL.
B.B.4.z&aa. Sites with Land Ready for
Reuse & Acres at Sites with Land Ready
for Reuse
NEW MEASURES
Janet Weiner/John
Harris
Add language for new GPRA measures 'Sites
with Land Ready for Reuse" and "Acres at
Sites with Land Ready for Reuse."
B.B.4.bb
Melanie Hoff
Changed from a program measure to a GPRA
measure.
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FY 04/05 SPIM
CHANGE 1 LOG
22 SEP 03
Section
Requestor
Change Description
Appendix C
C.A.I Overview
Dela Ng
Updated GPRA goals example.
Exhibit C.l Enforcement Activities
Dela Ng
Corrected exhibit and added rows for Pre-
Remedial Enforcement Action at Superfund
Sites, Windfall Lien Filed, and Windfall Lien
Resolution - Assessed and Finalized
C.A.3 Criteria for Credit of Enforcement
Activities at Superfund Alternative Sites
Dela Ng
Deleted reference to SACM.
C.A.3.i Completion or Termination of
Negotiations for Cleanup
Dela Ng
Changed from a program target to program
measure.
C.A.3.j Percentage of Remedial Action
Starts Initiated by PRPs at Non-Federal
Facility NPL and Superfund Alternative
Sites
Dela Ng
Changed from GPRA annual performance
goal to program target.
C.A.3.k Total Response Commitments
(Including Dollar Value)
Dela Ng
Change UAO date for all response work to the
date of the PRPs written notice of intent to
comply with the order.
C.A.3.m DeMinimis Settlements and
Number of Parties
Dela Ng
Changed definition to a program measure.
C.A.3.X Prospective Purchaser
Agreements (PPAs) - Assessed and
Finalized
Dela Ng
Changed date CERCLA was amended.
C.A.3.X Prospective Purchaser
Agreements (PPAs) - Assessed and
Finalized
Dela Ng
Changed PPA assessments and PPAs signed
to program measures.
C.A.3.y Issuance of Comfort/Status
Letters
Dela Ng
Added requirement of qualifiers to note the
type of comfort/status letter.
C.A.3.Z Orphan Share - EPA Offer and
Compensation
Dela Ng
Changed Orphan Share Compensation
Offered to a program measure.
C.A.3.hh Pre-Remedial Enforcement
Action at Superfund Sites
Dela Ng
Added new GPRA annual performance goal.
C.A.3. ii, and jj Windfall Lien Filed,
and Windfall Lien Resolution - Assessed
and Finalized.
NEW MEASURES
Dela Ng
Added two new measures: Windfall Lien
Filed; and Windfall Lien Resolution -
Assessed and Finalized.
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FY 04/05 SPIM
CHANGE 1 LOG
22 SEP 03
Section
Requestor
Change Description
Appendix D
Exhibit D.l Federal Facilities NPL Sites
Josh Barber
Added ESD or ROD Amendment activity.
D.B.2.a Base Closure Decisions
Josh Barber
Updated the Base Closure Measure to include
a requirement for acreage data.
D.B.2.f Final Remedy Selected/Final
ROD Authority
Josh Barber
Added measure for Final Remedy
Selected/Final ROD Authority
D.B.2.i Explanations of Significant
Difference (ESD) and ROD
Amendments
Josh Barber
Added measure for Explanations of
Significant Difference (ESD) and ROD
Amendments.
D.B.2.r Federal Facility Partial NPL
Deletion
Jennifer Griesert
Deleted reference to NPL Status of Partially
Deleted from the NPL. This statement is
untrue as there is no NPL status of Partially
Deleted from the NPL.
D.B.3.b Technical Assistance Grants
(TAGs)
Debra Potter
TAG definition has been rewritten.
Appendix E
Exhibit E.2 Data Sponsors
Flans Waetjen
Updated data sponsors.
Appendix H
HA.l.b TAGs Measure
Debra Potter
TAG definition has been rewritten.
Appendix M
Entire Appendix
NEW APPENDIX
Dana Stalcup
Removal measure were taken from Appendix
B and moved to this new appendix to reflect
the changes in responsibilities for removals.
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Acronyms, xi
Administrative Reforms (see Reforms,
Superfund)
Construction Completions
NPL Site, B-38
RA Construction, B-2
Enforcement
Targets and Measures, C-l, C-7
Environmental Indicators, B-48
Federal Facilities
Priorities, D-l
Targets and Measures, D-5
Reporting Non-NPL Data, D-5
Government Performance Results Act (see
GPRA)
GPRA
Annual Performance Plan, G-4
Description, G-l
Goals, G-3
Objectives/Sub-objectives, G-3
Performance Goal, G-4
Resources, G-4
Strategic Plan Requirements, G-3
Structure, G-5
Information Systems, E-l
Manager's Schedule of Significant Events, i
Organizational Charts, xix
Program Goals and Priorities
Base Closures, D-3
Block Funding, J-2
Building Superfund Partnerships, J-l
Contract Management, B-7
Enforcement First, C-2
Environmental Indicators, B-48
Innovative Technologies, B-6
Maximizing Program Effectiveness,
Efficiency, B-6
NPL Listings, Clarifying Policy, A-2
OSWER Directive 9200.3-14-1G-Q
INDEX
Performance Partnership Grants, J-2
Post Construction Completions, 1-4
Promoting Superfund Enforcement
Program, C-2
Protect Human Health and Environment, B-l
Removal Actions, B-l
Site Assessment, A-1
State/Tribal Role, Enhancement, J-l
Program Planning and Reporting
Requirements, II-1
Accomplishments Reporting, 11-14
Action Lead Codes, 11-22
Action Qualifiers, Assessment, A-5
Annual Target Setting, II-11
Annual Reporting Requirements, 11-19
Anomalies and Phased Projects, 11-26
Change Control Requirements, II-7
Change Requests, 11-19
Data Lockout, 11-21
Data Validation, 11-22
HQ Evaluation of Regional
Performance, 11-16
Information Systems, Superfund, II-5
Integrated Planning, II-2
Leads, 11-22
Management Tools, II-3
Phased Projects, 11-26
Planning/Target Setting, 11-13
Program Evaluation. 11-10
Roles/Responsibilities, II-8
SCAP, II-3, II-5
Site Assessment, 11-20
Work Planning, 11-11,11-21
Records of Decision (see RODs)
Regional Accomplishment Reporting, 11-14
Regional Map, xxiv
Regional Performance,
HQ Evaluation of, 11-16
End-of-Year Assessment, 11-17
Management Reporting, 11-18
Mid-Year Assessment, 11-16
Response Actions
Targets and Measures, B-5
A
April 7, 2003
-------
OSWER Directive 9200.3-14-1G-Q
RODs
Amendments, B-9
ROD Amendments, B-8
Other Remedy Changes, B-9
Requiring No Physical Construction, B-10
ESDs, B-9
Definition of, B-8
SCAP
Change Control, II-7
Change Requests, 11-19
Information Systems, II-5
Introduction to, II-3
Maintaining in WasteLAN, II-8
Maintaining Planning Targets/
Accomplishments, II-8
Management Tools, Relationship to, II-3
Overview of Planning Process, II-5
Program Evaluation, 11-10
Roles and Responsibilities, HQ/Regional,
II-8
Target Setting, Annual, 11-12
WasteLAN Reports, 11-13,11-15
Work Planning, 11-11,11-21
Site Assessments
Action Qualifiers, A-5
GPRA, A-3
Program Priorities, A-l
Targets and Measures, A-l
Superfund
Annual Reporting Requirements, 11-19
Current Program Priorities, (see Program
Priorities)
GPRA, G-5
History of, 1-3
Management Reports, 11-18
Measures of Success (MOS), C-l
Performance Goal, B-6
Redevelopment Initiatives, B-7
Work Planning, II I 1,11-21
April 7, 2003
B
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OSWER Directive 9200.3-14-1G-Q
Superfund Program Implementation Manual FY04/05
Chapter I: Introduction
FY 04/05 SPIM
April 7, 2003
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OSWER Directive 9200.3-14-1G-Q
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Left Blank
April 7, 2003
FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Chapter I
Introduction
Table of Contents
CHAPTER I INTRODUCTION 1-1
I.A. Purpose 1-1
I.B. Superfund 1-2
I.B.I Introduction 1-2
I.B.2 Superfund and its History 1-3
I.C. Subject Matter Experts 1-4
List of Exhibits
EXHIBIT 1.1 SUBJECT MATTER EXPERTS 1-4
Change 2, FY 04/05 SPIM
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
This Page Intentionally
Left Blank
April 7, 2003
FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
CHAPTER I
INTRODUCTION
I.A PURPOSE
EPA, working in collaberation with the states, Indian tribes, and other Federal agencies, manages programs
designed to cleanup priority hazardous waste sites and releases. These programs include Superfund, Brownfields,
Resource Conservation and Recovery Act (RCRA), Underground Storage Tanks (UST), and Oil. The focus of those
programs is to maximize the protection of human health and the enviromnent and to allow these sites to be returned to
productive use to improve the quality of life in America's communities.
The Superfund Program Implementation Manual (SPIM) is a planning document that defines program
management priorities, procedures and practices for the Superfund Program (including response, enforcement, and
Federal Facilities). The SPIM provides the link between the Government Performance and Results Act (GPRA), EPA's
Strategic Plan and the Superfund programs' internal processes for setting priorities, tracking and planning performance,
and meeting program goals. It establishes the process to track overall program progress through program targets and
measures.
The Government Performance and Results Act (GPRA) holds federal agencies accountable for using resources
wisely and achieving program results. GPRA requires agencies to develop plans for what they intend to accomplish,
measure how well they are doing, make appropriate decisions based on the information they have gathered, and
communicate information about their performance to Congress and to the public. GPRA requires agencies to develop
a five-year Strategic Plan, including a mission statement and long-term goals and objectives. EPA's strategic plan is
divided into five goals: air; water; land; communities and ecosystems; and compliance and enviromnental stewardship.
The Superfund program contributes to the goal of preserving and restoring the land. GPRA also requires agencies to
develop annual Performance Plans, which provide annual performance commitments toward achieving the goals and
objectives presented in the Strategic Plan; and annual Performance Reports, which evaluate an agency's progress toward
achieving performance commitments.
The SPIM provides standardized and common definitions for the Superfund program and it is part of EPA's
internal control structure. As required by the Comptroller General of the United States, through government accepted
accounting standards and auditing practices, this document defines program scope and schedule in relation to budget,
and is used for audits and inspections by the General Accounting Office and the Office of the Inspector General. The
SPIM is developed on a biennial basis, and this document provides information for the period covering FY 2004 and FY
2005. Revisions to the SPIM are issued during the biennial cycle as needed.
The SPIM contains three chapters and a number of appendices. Chapter 1 provides a brief summary of the
Superfund Program and summarizes key program priorities and initiatives. Chapter 2 describes program planning and
reporting requirements and processes. Chapter 3 describes the budget process and financial management requirements.
Appendices A through J highlight program priorities and initiatives and provide detailed programmatic information,
including program targets and measures, for critical parts of the Superfund Program.
Notice To Readers: At the time of publication of the FY 04/05 SPIM, several actions were underway that
impacted the content of the document. These actions included: a re-organization of the Office of Emergency and
Remedial Response (OERR) and re-naming it "Office of Superfund Remediation and Technology Innovation (OSRTI)";
a complete revision to the Agency' s Strategic Plan and goal structure, and to the budgeting, accounting and performance
management procedures; a comprehensive review of CERCLIS and the SPIM as part of the CERCLIS modernization
project; and a reorganization within Office of Solid Waste and Emergency Response (OSWER) which will shift
responsibility for the Superfund removal program from the Office of Superfund Remediation and Technology Innovation
(OSRTI) to the Office of Emergency Preparedness, Prevention and Response (OEPPR), and consolidate responsibilities
for homeland security within OEPPR. The SPIM as of Change 2 reflects these changes.
Change 2, FY 04/05 SPIM
1-1
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
I.B SUPERFUND
I.B.1 Introduction
The Superfund program addresses contamination from uncontrolled releases at Superfund hazardous waste sites
that threaten human health and the environment. The Superfund program is comprehensive, yet flexible and innovative.
Its mission is both immediate and long-range. Its focus is specific enough to handle individual site cleanup with
precision, yet broad enough to encourage advances in a relatively new scientific and technical field. Today the hazardous
waste problem in the United States remains large, complex and long-term.
The overarching goals of the Superfund Program are ensuring the protection of human health and the
environment, and maximizing the involvement of potentially responsible parties in conducting cleanups at sites, also
known as "enforcement first". EPA will continue to address the worst sites first, while balancing the need to complete
response actions at sites.
To protect human health and the environment and address potential barriers to redevelopment, EPA works with
states, Indian tribes, and other Federal agencies to:
Assess sites and determine whether they meet the criteria for Federal Superfund response actions;
Prevent, minimize, or mitigate significant threats at Superfund sites through removal actions;
Generate risk assessments that consider the future use of the site and prepare accurate cost-performance data
as the technical foundation for environmental cleanup decisions;
Complete remedial cleanup construction at sites listed on the National Priorities List (NPL);
Control human exposure to and the migration of contaminated groundwater at NPL sites;
Develop technologies for cost-effective site characterization and remediation;
Ensure long-term protectiveness of remedies by overseeing operation and maintenance and conducting five-year
reviews;
Enhance the role of states and Indian tribes in the implementation of the Superfund program;
Pursue "enforcement first" throughout the Superfund cleanup process;
Work with communities surrounding Superfund sites to improve their direct involvement in every phase of the
cleanup process and their understanding of potential site risk;
Continue progress of cleanups while increasing consistency with other EPA cleanup programs; and
Promote reuse and redevelopment of Superfund sites.
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I.B.2 Superfund and its History
Congress passed the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),
commonly called Superfund, in 1980. Prior to this, there was no authority for direct Federal response to hazards posed
by abandoned and uncontrolled hazardous waste sites. Existing environmental laws, such as the Resource Conservation
and Recovery Act (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 disposal problems.
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.
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) is the major regulatory
framework that guides the Superfund response effort. The NCP outlines a step-by-step process for implementing
Superfund responses and defines the roles and responsibilities of EPA, other Federal agencies, states, private parties,
and the communities in response to situations in which hazardous substances are released into the environment. In 1992,
EPA introduced the Superfund Accelerated Cleanup Model (SACM). S ACM was designed to expedite the cleanup of
uncontrolled waste sites and redefine the way Superfund progress is measured.
The Omnibus Reconciliation Act of 1990, which extended Superfund authority, expired in 1994. Since 1994,
many Congressional bills have been advanced to reauthorize the program, but none have been enacted. Many aspects
of the program that have been subj ect 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. 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 also 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 of 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.
EPA and other Superfund stakeholders have worked since the inception of the program to reduce risks posed
by abandoned and uncontrolled hazardous waste sites. As of the end of FY 2002, EPA has evaluated more than 44,000
sites, conducted more than 7,000 removals, and completed construction at 846 of 1,498 sites on the NPL in an effort
to protect human health and the environment. Final remedies have been selected at more than 1,100 sites, and design
and implementation of the remedies is underway.
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I. C SUBJECT MATTER EXPERTS
The following exhibit identifies the subject matter experts for Chapter I Introduction.
EXHIBIT 1.1 SUBJECT MATTER EXPERTS
Subject Matter Expert
Subject Area
Phone #
Robert White
SPIM/SCAP Coordinator
(703) 603-8873
Dan Dickson
Enforcement
(202) 564-6041
Joshua Barber
Federal Facilities (FF)
(703) 603-0265
Lance Elson
Federal Facility Enforcement
(202) 564-2577
Janet Weiner
Patricia Kennedy
GPRA
(703)603-8717
(202)564-6061
Art Flaks
BPEB
(703) 603-9088
Jeff Lape
Resource Management
(703) 603-8914
To see a complete list of data sponsors, please refer to Data Sponsor List in Appendix E.
February 6, 2004
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Superfiind Program Implementation Manual FY 04/05
Chapter II: Program Planning and Reporting Requirements
FY 04/05 SPIM
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Chapter IE
Program Planning and Reporting Requirements
Table of Contents
CHAPTER II PROGRAM PLANNING AND REPORTING REQUIREMENTS II I
ILA Introduction II-1
II.B Integrated Planning II-2
II.C Introduction to the Superfund Comprehensive Accomplishment Plan (SCAP) II-3
II.D Relationship of SCAP to other Management Tools II-3
II.D.l Management Tools II-3
II.D.2 Superfund Information Systems II-5
II.E Overview of the Planning Process (SCAP) II-5
II.E.l Planning Year II-6
II.E.2 Operating Year II-7
II.F Change Control Requirements II-7
II.G HQ/Regional Roles and Responsibilities II-8
II.G.l Maintaining Planning/Accomplishment Data in WasteLAN II-8
II.G.2 Program Evaluation 11-10
II.H Procedures for Annual Target Setting 11-11
II I Work Planning 11-11
11.1.1 Planning Process 11-12
11.1.2 WasteLAN Reports for Planning/Target Setting 11-13
II. J Regional Accomplishment Reporting 11-14
WasteLAN Reports for Accomplishment Reporting II-l 5
II.K HQ Evaluation of Regional Performance 11-16
ILK. 1 Mid-Year Assessment 11-16
II.K.2 End-of-Year Assessment 11-17
ILK.3 Management Reporting 11-18
a. Superfund Management Reports 11-18
b. Annual Reporting Requirements 11-19
ILL Target and Definition Change Requests 11-19
Maintaining the Planning Estimates/Targets 11-20
II.M Special Reporting Topics 11-20
II.M. 1 Site Assessment 11-20
II.M.2 Base Closure 11-20
II.M.3 Pre-SARA Sites Initiative 11-20
II.M.4 Mega Sites 11-21
II.M.5 Superfund Alternative Sites 11-21
II.N General Work Planning and Reporting Requirements 11-21
II.N.l Data Lockout on Historical Accomplishments 11-21
II.N.2 Data Validation and Verification 11-22
II.N.3 Action Lead Codes 11-22
II.N. l Lead Changes 11-24
II.N.5. Anomalies and Phased Projects 11-26
II.O Subject Matter Experts 11-27
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Chapter IE
Program Planning and Reporting Requirements
List of Exhibits
EXHIBIT II. 1 FLEXIBILITY SCALE FOR BUDGETING/PLANNING II-4
EXHIBIT II.2 HQ/REGIONAL INTEGRATED PLANNING RESPONSIBILITIES II-5
EXHIBIT II.3 HQ/REGIONAL SCAP AND WasteLAN RESPONSIBILITIES II-8
EXHIBIT II.4 EVALUATION RESPONSIBILITIES 11-10
EXHIBIT II.5 PROCEDURES FOR ANNUAL TARGET SETTING 11-12
EXHIBIT II.6 SCAP PLANNING/TARGET SETTING WasteLAN REPORTS 11-14
EXHIBIT II.7 PROGRAM EVALUATION WasteLAN REPORTS 11-16
EXHIBIT II.8 THE REGIONAL EVALUATION PROCESS 11-17
EXHIBIT II.9 ACTION LEAD CODES IN WasteLAN 11-23
EXHIBIT 11.10 CODING OF TAKEOVERS 11-26
EXHIBIT 11.11 REMEDIAL EVENTS, ANOMALIES, AND PROJECT PHASING 11-27
EXHIBIT 11.12 SCAP REPORT CONTACTS 11-27
EXHIBIT 11.13 SUBJECT MATTER EXPERTS 11-28
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CHAPTER II
PROGRAM PLANNING AND REPORTING REQUIREMENTS
II.A INTRODUCTION
The Government Performance and Results Act (GPRA) establishes a general framework within which the Agency
plans its activities. It focuses the Agency on planning strategically (in consultation with both internal and external
customers), developing annual performance plans with annual performance goals, and carrying out regular program
evaluations to ensure these goals are met effectively and efficiently.
The Office of Superfund Remediation and Technology Innovation (OSRTI), Office of Site Remediation
Enforcement (OSRE), the Federal Facilities Enforcement Office (FFEO), and the Federal Facilities Restoration and
Reuse Office (FFRRO) are responsible for overall program planning, including implementing the requirements of GPRA
and reporting on Superfund program accomplishments. The Superfund Comprehensive Accomplishments Plan (SCAP)
is the process by which the Assistant Administrator for the Office of Solid Waste and Emergency Response (AA
SWER), Assistant Administrator for the Office of Enforcement and Compliance Assistance (AA OECA), and senior
Superfund managers monitor progress towards meeting GPRA annual performance goals. In addition, SCAP will
continue to be used as a management tool to project and track activities that contribute to these GPRA goals and support
resource allocation. Regions should continue to plan and report accomplishments in WasteLAN as they have done
traditionally.
To more clearly reflect the relationship between GPRA and the SCAP process, GPRA annual performance goals and
measures and program targets and measures are defined as follows:
GPRA Annual Performance Goals (APG) and GPRA Annual Performance Measures (APM) - The Agency's
Annual Plan describes the specific annual performance goals, annual measures of outputs and outcomes, and
activities aimed at achieving the performance goals that will be carried out during the year. APGs are the specific
activities that the Agency plans to conduct during the fiscal year in an effort towards achieving its long-term strategic
goals and objectives. APMs are used by managers to determine how well a program or activity is doing in achieving
milestones that have been set for the year. The annual performance goals will inform Congress and Agency
stakeholders of the expected level of achievement for the significant activities covered by the GPRA obj ective. The
goals are a subset of the overall planning and budgeting information that has traditionally been tracked by the
Superfund program offices.
Program Targets and Measures are activities deemed essential to tracking overall program progress. Program
targets are used to identify and track the number of actions that each Region is expected to perform during the year
and to evaluate program progress. Program measures are used to show progress made in achieving program
priorities. A subset of these program measures will be targeted for work planning purposes.
Successful planning requires the reflection and accurate costing of program priorities in the budget and workload
model, and translation of the priorities and resource requirements into specific commitments via the SCAP. Candid
evaluation of performance against these commitments is essential to assess the viability of program priorities, resource
requirements and overall program effectiveness.
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I LB INTEGRATED PLANNING
Integrated planning is the responsibility of HQ and Regional program offices; Regional finance offices; the States;
Tribes; affected communities; the Office of Regional Counsel (ORC); DOJ; and other Federal agencies. Information
on planned activities should also be coordinated with the Natural Resources Trustees and the Agency for Toxic
Substances and Disease Registry (ATSDR). To provide adequate resources to achieve Superfund's GPRA objectives
and sub-objectives, HQ allocates resources within and between the response, enforcement, and Federal facilities
programs. Regions are responsible for providing data on the level of resources needed to accomplish those priority
activities and negotiate commitments consistent with realistic site planning. Regions should not accept targets that
require completion of activities that cannot be funded or staffed within the resources provided. This requires Regions
to reconcile FY 04/05 targets and their Superfund pipeline with the financial operating plan proposed by HQ.
Flexibility is greatest in the budget planning years. Realistic out year planning data (milestones and funding needs)
allows HQ to prepare requests for resources based on Regional needs. Exhibit II. 1 summarizes levels of flexibility as
the operating year is entered. Major phases in the decision making continuum include:
Formulation of the out year GPRA annual performance plan and budget occurs 12 to 18 months prior to the FY.
The GPRA 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 includes identification of major program issues,
analysis of program costs, and alignment of resources among competing priorities. Activities receive resource
allocations that are established by the Administrator and the Assistant Administrator for the Office of Solid Waste
and Emergency Response (AA SWER) or the Assistant Administrator for the Office ofEnforcement and Compliance
Assurance (AA OECA).
Development of the initial operating plan occurs six months prior to the FY and generally is finalized early during
the FY. OSWER and OECA provide resources to support the program through the Advice of Allowance (AOA)
and workload process. Regions are expected to work within the annual Regional budgets established at the start of
the year until the mid-year evaluation. Regions have flexibility within the general budget and AOA structure to shift
funds as needed to meet priority activities. (See Chapter III for additional information on shifting funds.) Once the
operating plan is established at the start of the year, additional resources generally can be shifted to a Region only
at the expense of resources from other Regions. However, HQ may shift funds among the Regions depending on
the level of use and need.
Use of the mid-year evaluation 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 shifts within program areas
and among Regions, and revised annual funding levels. Estimates developed in April/May for the upcoming FY
represent the first formal opportunity for changing resources among program areas at a national level. The revised
resource estimates also serve as a "baseline" for examining program needs in the budget year.
Exhibit II.2 describes the information flow and HQ and Regional responsibilities associated with integrated planning.
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II.C INTRODUCTION TO THE SUPERFUND COMPREHENSIVE ACCOMPLISHMENT
PLAN (SCAP)
The SCAP process is used by the Superfund program to plan, budget, track, and evaluate progress toward achieving
Superfund GPRA objectives and sub-objectives. The SCAP planning process is a dynamic, ongoing effort that has a
significant impact on Superfund resource allocation and program evaluation. Planned obligations and reporting of GPRA
annual performance goals and measures are generated through SCAP and influence the Superfund budget and evaluation
process. Such planning is a day-to-day responsibility of the Regions. An annual process has been established through
which HQ and Regions formally develop work plans for the future. WasteLAN serves as the conduit for the SCAP
process by providing both HQ and Regions with direct access to the same data. Through WasteLAN, reports can be
produced allowing for daily interactive updates of planning and site cleanup progress information.
II.D RELATIONSHIP OF SCAP TO OTHER MANAGEMENT TOOLS
The SCAP process is crucial to Superfund program planning, tracking, and evaluation. As the Superfund program's
central planning mechanism, it is interrelated with all Agency and Superfund program specific planning and management
systems, including the GPRA annual performance plan, the Superfund budget, Agency Operating Plan, Memorandum
of Agreement/Management Agreements and the Superfund workload models. GPRA annual performance goals are
designed to reflect the strategic plans and the Agency's goals, objectives, and sub-objectives for the upcoming year. As
such, SCAP serves as the Superfund Program's Memorandum of Agreement. In some cases, new categories are
developed, or the projections for activities are adjusted, to match these goals.
II.D.l Management Tools
Most of the Superfund program's budget is based on planning and accomplishment data recorded in WasteLAN.
The operating year's budget is developed 18 months prior to its beginning. F or example, data existing in the third quarter
of FY 04 will be used to formulate the FY 06 budget. The site schedules reflected in WasteLAN serve as the foundation
for determining out year budget priorities, such as the dollar levels to be requested in the budget. Because dollars for
Fund-financed remedial actions (RAs), and remedial designs (RDs) dominate the overall Superfund budget, it is critical
that the Regions identify RD and RA candidates and projected funding needs. Cost estimates for RAs should be derived
using the draft feasibility study or record of decision estimates.
InFY 04/05, each Region's FTE distribution continues to be frozen at theFY 90 distribution ratio. While the freeze
ensures that the total Regional Superfund resources are not affected, shifting of resources within the Region among the
different program areas to support Agency/Regional program priorities may occur. All shifts will be based on the
national budget (see Chapter III) and program priorities (see Chapter I and Appendices). Guidance for reprogramming
between Program Results Codes (PRCs) are provided in the Agency's operating plan.
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EXHIBIT II. 1
FLEXIBILITY SCALE FOR BUDGETING/PLANNING
Minimum
Maximum
Operating Year Budget
(FY 04)
Planning Year Budget
(FY 05)
Out Year Budget
(FY 06)
1. Operating Plan establishes
funding ceiling (03/4)
2. Development of Operating Plan
begins 6 Months Prior to FY and is
based on prior years obligations and
Regional projections for the upcoming
years (Begins 04/2)
3. Formulations Begins 12-18 months prior to FY;
largely dependent on Regional planning data in
WasteLAN (Begins 04/3)
1. Semi-annual targets are set -
Targets can be changed only
through a written request from the
Regional Division Director to the
OSRTI, OECA, or FFRRO Office
Directors.
2. Regional GPRA annual
performance goals finalized in
September
3. National targets are set based on schedules and
estimated costs for program activities, which drive
budget request
1. Additional funds can only be
obtained through special requests
2. The budget is set but there is more
leeway to make adjustments based on
proven need
3. Budget is constrained based on resources cap
imposed by AA and Administrator unless exception
can be justified
1. Regions have flexibility
within general budget and AOA
structure to shift funds to meet
priority activities
2. Regions request funds to meet
GPRA annual performance and
Regional pipeline goals
3. Maximum flexibility to design budget to
optimize cross-program priorities
1. Mid-Year evaluation used to
realign current year resources
2. Final GPRA annual performance
goals set final resource levels (04/4)
3. N/A
1. Resources for response
actions will be funded based on
the Priority Panel decisions
2. Candidate sites are identified for
the Priority Panel
3. N/A
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EXHIBIT II.2
HQ/REGIONAL INTEGRATED PLANNING RESPONSIBILITIES
Regional Responsibilities
HQ Responsibilities
Manage projects to integrate Enforcement and Fund
milestones and to ensure schedules and time lines are
met
Involve the State, ORC, and finance offices in the
planning process
Provide accurate, complete, and timely project
planning data in WasteLAN
Follow established planning procedures and
requirements so that HQ has a common basis with
which to evaluate Regional proposals (See Chapter
III and the Appendices)
Assess Federal agencies environmental projects
identified as part ofthe Office of Management and
Budget (OMB) Circular A-l 1 process and the Federal
Agency Environmental Management Program
Planning Guidance (FEDPLAN)
Identify multi-media planning and cleanup
opportunities
Achieve program commitments
Improve program efficiency by identifying potential
unused funds and return them to HQ within
reasonable time frame for redistribution
Establish a combined Fund, Enforcement, and Federal facilities hierarchy
of program priorities in consultation with the Regions to be used in work
planning and adjustment of targets
Review integrated operating plans and site commitments proposed by the
Regions prior to work planning
Coordinate OSWER, OECA, DO.T, Financial Management Division
(FMD), and the Office of Administration and Resources Management
(OARM) activities throughout the planning process
Work with Regional managers to formulate preliminary resource requests
and determine how resources should be adjusted to meet program
priorities
Communicate with the Regions on changes/additions to schedules
Provide funding consistent with each Region's active pipeline phases,
shifting Regional resources if needed to support priority activities
Develop policy and guidance in response to Congressional or Agency
initiatives
II.D.2 Superfund Information Systems
Effective management ofthe Superfund program requires the availability of accurate information on Superfund sites
throughout the country. CERCLIS was developed in the mid-1980s as an integrated system to hold national site
assessment, remedial, removal, enforcement, and financial information. In FY 97, all Regions began using the third
generation of CERCLIS, now called WasteLAN, to record Superfund planning and accomplishment information. (See
Appendix E for more information on WasteLAN)
II.E OVERVIEW OF THE PLANNING PROCESS (SCAP)
The SCAP process generates data that fulfill the following functions:
Tracking of accomplishments against GPRA annual performance goals and measures and program targets;
Updating planning assumptions (schedules and funds) for the current FY;
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~ Developing planning data for the upcoming FY; and
Providing data for out year budget planning purposes.
The SCAP planning process follows a semi-annual work planning schedule. The cycle begins in late March/April
with a review of program progress and ends with a formal work planning session in July/August. Therefore, it is essential
that planning and accomplishment data in WasteLAN remain current and up-to-date throughout the year and
accomplishments be reported as soon as they occur. Site schedules and financial planning information should be reviewed
and updated on an ongoing basis (at a minimum on a monthly basis). Note: All sites should be planned out through the
deletion date as early as possible. By the time of the completion of a ROD, a site should have all planned dates entered
into WasteLAN. As conditions change, the dates should be updated accordingly.
Following is a summary of the SCAP planning cycle for non-Federal facilities:
II.E.l Planning Year
Third Quarter - Regions continue their site planning using WasteLAN. The Regions should focus on their individual
pipeline, the overall goals and priorities of the program as identified in the GPRA annual performance plan, and how
they can achieve their portion of the national effort given proposed resources. In May, HQ issues a Call
Memorandum that outlines the process and the procedures for the upcoming work planning sessions. The
memorandum will include the finalized AOA structure, GPRA annual program performance targets and procedures
to be used for developing the upcoming year's operating plan.
Fourth Quarter - HQ pulls actual data for the current fiscal year and planning data for the next two FYs from
WasteLAN on the fifth working day in July.
Regions can assume in FY 04 that their removal budget will be held at the same level as FY 03 and is unaffected
by this proposal Also, funding for a new start and on-going remedial actions will be unaffected by this proposal
OSRTI reviews the CERCLIS/WasteLAN data and begins to develop a funding plan for the Remedial Action Advice
of Allowance (AOA). OSRTI also uses these data to develop a draft Pipeline Operations AOA allocation that the
regions use to develop initial pipline-related targets for the upcoming year. Because a reorganization at the
headquarters level for managing the removal and homeland security programs is underway at the time of this writing,
the process for planning for these programs will be revised and the SPIM updated during FY 2004.
OSRE allocates the initial operating budget for technical enforcement for the upcoming fiscal year based on each
region's share of the usage rate for enforcement activities. Legal enforcement funds are allocated equally between
all ten regions. See Chapter 3 Section C for a more complete discussion on how funds are allocated.
July/August - Regional work planning sessions will establish Regionalbudgets and targets (mid-year and end-of-y ear)
and the operating plan (base budget plus increment) for the fiscal year.
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II.E.2 Operating Year
Fourth Quarter (Planning Year) /First Quarter (Operating Year) - Regional work planning sessions will establish
proposed Regional budgets and targets (mid-year and end-of-year) and the operating plan (base budget plus
increment) for the fiscal year. HQ will meet with the Division Directors to discuss the FY 04/05 Region-specific
commitments and allocation of Regional funds based on the national GPRA annual program performance targets.
The Superfund Federal Facilities Response Program will issue a memo that outlines Regional commitments and
allocation of funds to both the Division Directors and the Superfund Federal Facility Program Manager.
Third Quarter - At mid-year, HQ and the Regions will discuss Regional progress in achieving negotiated targets and
Regional budget utilization (obligation rates). Based on these discussions, remaining funds will be allocated to the
Regions to assure program targets are achieved. In some cases, this may involve a reallocation and shifting of
resources among Regions. Enforcement extramural budget carryover amounts are calculated and the FY Regional
enforcement budget allocation is finalized.
Regions are required to manage their funds and operate within the annual budgets established. Non-RA funds within
the Region's budget must be reprogrammed to meet unexpected needs.
II.F CHANGE CONTROL REQUIREMENTS
Stability in the SCAP process through the year is essential to the success of planning and accomplishment
reporting/evaluation procedures. The following procedures are used to control changes to items in SCAP:
Changes (including additions or deletions) to targets, measures, definitions, methodologies, planning processes,
accomplishment reporting, financial management, or any other process described in this Manual must be presented
to the division director by the program office proposing the change, and receive the comments/concurrence of OSRE,
OSRTI, FFRRO, and FFEO;
All proposed changes must be sent to the Regions and all other program offices for review and comment prior to
implementation; and
The decision on whether to proceed with the proposed change must be documented in writing. Copies of all final
decisions should be provided to all program offices and Regions. If the proposed change will be implemented, an
addendum to the Superfund Program Implementation Manual may be issued.
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II G HQ/REGIONAL ROLES AND RESPONSIBILITIES
ILG.l Maintaining Planning/Accomplishment Data in WasteLAN
Exhibit II.3 describes the HQ/Regional responsibilities for maintaining planning and accomplishment data inWasteLAN.
The Information Management CoordinatordMC) is a senior position which serves as Regional lead for all Superfund
program and WasteLAN systems management activities. The following lead responsibilities for Regional program
planning and management rest with the IMC:
~ Coordinate program planning, development, and reporting activities;
Ensure Regional planning and accomplishments are complete, current, and consistent, and accurately reflected in
WasteLAN by working with data sponsors and data owners;
Provide liaison to HQ on SCAP process and program evaluation issues;
Coordinate Regional evaluations by HQ; and
Ensure that the quality of WasteLAN data is such that accomplishments and planning data can be accurately retrieved
from the system.
~ Ensure there is "objective" evidence to support accomplishment data entered in WasteLAN.
NOTE: Objective Evidence Rule: "All transactions must be supported by objective evidence, that is, documentation that
a third party could examine and arrive at the same conclusion. "
EXHIBIT II.3
HQ/REGIONAL SCAP AND WASTELAN RESPONSIBILITIES
Regional Responsibilities
HQ Responsibilities
Planning and scheduling all actions from site assessment
and PRP search through NPL deletion
Keeping planning and accomplishment data in
WasteLAN up-to-date, including updating site schedules
established at the ESI/RI stage and cost estimates for
remedial actions when better planning data become
available
Reporting accomplishments in WasteLAN as they occur
Entering and maintaining quarterly planning, budget, and
accomplishment reporting tor non-site specific activities
Preparing change requests
Tracking and maintaining the enforcement extramural
budget and the Federal facilities budget
Ensure there is "objective" evidence to support
accomplishment data entered in WasteLAN
Negotiating final GPRA annual performance goals
Determining the AOA based on planned activities in WasteLAN
Responding to Regional requests for changes in plans through the change
requests process
Utilizing WasteLAN to obtain budget and other Superfund site
information to respond to special requests for information and planning
data
Communicating with Regions and HQ offices regarding changes in budget,
SCAP process, Superfund Program Implementation Manual, and other
program guidance that will impact WasteLAN, and subsequently
implementing these changes in WasteLAN
Ensure there is "objective" evidence to support accomplishment data
entered in WasteLAN by performing periodic reviews of a random
CERCLIS data sample.
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The Budget Coordinator serves as the Regional lead for all Superfund program resource activities. The Budget
Coordinator:
Coordinates the planning, development and reporting of resources;
Coordinates the planning and execution of Regional priorities;
Communicates and implements national and Regional Superfund budget policies;
Helps IMC to ensure Regional resources associated with accomplishments are complete, current, and consistent, and
accurately reflected in WasteLAN; and
~ Provides liaison to HQ on program issues.
With the implementation of WasteLAN, two roles, Data Sponsor and Data Owners, were identified for improving
the quality of data stored in WasteLAN. Data Sponsors include the Senior Process Managers or program offices in HQ.
Both HQ and the Regions are Data Owners. Following are the responsibilities assigned to each of these roles:
Data sponsors
Identify data needs;
Oversee the process of entering data into the system;
Use data for reporting purposes;
Conduct focus studies of the data entered;
NOTE: A "FOCUS STUDY" is where a data sponsor identifies a potential or existing data issue to a data
owner (see below), IMC or other responsible source to determine if a data quality problem exists, and to
solve the problem, if applicable. Focus studies can be informal via electronic messages.
Provide definitions for data elements;
Promote consistency across the Superfund program;
Initiate changes in WasteLAN as the program changes;
Provide guidance requiring submittal of these data;
Support the development of requirements for electronic data submission; and
Ensure there is "objective" evidence to support the accomplishment data entered in WasteLAN through
identifying data requirements and checks to assure compliance by performing periodic reviews of a random
CERCLIS data sample.
Data owners
Enter and maintain data in WasteLAN; and
Assume responsibility for complete, current, consistent, and accurate data.
FY 04/05 SPIM
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April 7, 2003
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OSWER Directive 9200.3-14-1G-Q
OS It TI Regional Centers
Measure regional data entry quality and records management quality and assist regions with problems;
Report data problems to Data Sponsors and responsible teams;
Sample data quality and records management quality when visiting regions by tracking selected dates of a
transaction in WasteLAN to the corresponding dates of the supporting paper document to ensure there is
"objective" evidence to support accomplishment data entered in WasteLAN.
II.G.2 Program Evaluation
HQ and the Regions have different roles and responsibilities in Superfund program evaluation and management, as
shown in Exhibit II. 4.
EXHIBIT II.4
EVALUATION RESPONSIBILITIES
Regional Responsibilities
HQ Responsibilities
Meet semi-annual program targets and solve
performance problems when they arise
Provide quarterly accomplishment and planning
data to HQ through WasteLAN
Maintain WasteLAN data quality at high levels for
Superfund program and project management
Negotiate perfonnance standards that provide
individual accountability for targets
Assess Federal agency needs identified during the
FEDPLAN and OMB Circular A-l 1 processes
Participate in the Regional reviews
Provide guidance to the Regions for the quarterly reporting, the mid-
year assessment, the year-end assessment, and Regional reviews
Implement and report on follow-up action items from the Superfund
mid-year assessment and Regional reviews
Review performance data reported by the Regions and assist Regions
having difficulties in meeting targets
Conduct Regional reviews
Continually assess program perfonnance and analyze timeliness and
quality of work
Recommend resource reallocation based on Regional needs and
perfonnance
Assure that all staff are infonned of results of perfonnance reporting
Compare Federal agency budget authorities, obligations, and outlays to
monitor cleanup activities
The Superfund evaluation process provides managers with an opportunity to meet program objectives by:
Examining program accomplishments;
Analyzing and discussing issues that affect the successful operation of the Superfund program; and
Initiating changes in program operations or reallocating/redirecting resources.
February 6, 2004
11-10
Change 2, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
The strategy for assessing the performance of the Superfund program is comprised of the following:
~ Establishing semi-annual and annual targets and planning measures;
Quarterly reporting of response, F ederal facilities, and enforcement/program accomplishments and planning measures
through WasteLAN;
Semi-annual performance evaluation; and
Regional reviews.
This strategy enables management to recognize high performance, concentrate Superfund resources in those Regions that
demonstrate success, and provide training and technical assistance to those Regions that are experiencing difficulties.
II.H PROCEDURES FOR ANNUAL TARGET SETTING
The process for developing GPRA annual performance goals and measures for a FY begins with the strategic plan.
National annual performance goals are established to support the program's strategic plan and provide the basis for out
year budget requests. All Regional targets are established in October/November only after work planning sessions with
OSRTI, OSRE, FFRRO, FFEO, and the Regions. In the Regions, a joint review of commitments should be undertaken
by the program office and ORC. The dates for pulling WasteLAN data that will be used in developing the proposed
Regional operating plan, generating the Regional workload and budget, and work planning can be found in the Manager's
Schedule of Significant Events presented at the beginning of this Manual.
The Region's focus in work planning should be on its individual pipeline (i.e., more site assessments or more
construction completion oriented), the overall goals and priorities of the program including GPRA objectives and sub-
objectives, and how it can achieve its portion of the national effort given proposed resources. E1Q compares Regional
plans with program goals and resource allocations. In addition, HQ reviews past 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. This provides HQ with a benchmark going into work planning on what the Region
should be able to accomplish based on its unique pipeline status.
II.I WORK PLANNING
Regions are required to keep the planning and accomplishment data in WasteLAN current, complete, consistent, and
accurate. Changes in planning information (schedules and funds) should be entered into WasteLAN within five days after
the data owner [e.g., Remedial Project Manager (RPM)/On-Scene Coordinator (OSC)/Site Assessment Manager (SAM)]
is aware of the need for the change.
Change 2, FY 04/05 SPIM
11-11
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
II. 1.1 Planning Process
Exhibit II.5 outlines the steps a Region must go through as part of its work planning responsibilities.
As a final check to ensure that planning data are current, complete, consistent, and accurate, Regions should routinely
generate SCAP, Enforcement, and Audit reports. At an absolute minimum, reports should be generated prior to HQ
development of the proposed operating plan and in late June for internal review of the planning data in WasteLAN. These
planning data should reflect any adjustments made to the annual plan.
As designated, HQ pulls SCAP and Enforcement reports from WasteLAN. The data in these reports serve as the basis
for HQ/Regional work planning. HQ will perform all work planning sessions based on the information in WasteLAN on
these pull dates.
EXHIBIT II.5
PROCEDURES FOR FY 04/05 TARGET SETTING
Month
Regional Responsibilities
HQ Responsibilities
December/
January
Distribute draft SPIM for review and comment
April/May
Consult with States and ORC on FY activities
Prepare program and enforcement Regional operating
plan based on average Regional obligations/tasking in
the current year, projections for the upcoming years,
and considering prior year expenditures.
Analyze Regional pipelines
May/June
Update site schedules and funding needs based
on plan, Regional pipeline, and national goals
and priorities
Issue Call Memorandum outlining work planning
process and procedures for work planning sessions
July/August/
September
Identify primary candidates for each
target/measure activity by checking the target
icon box on the Regional Planning screen.
Primary projects have the greatest
likelihood of meeting schedules and are
used to determine SCAP commitments.
Participate in HQ conference calls on analysis
of Regional plan
Enter proposed commitments for work
planning. Primary candidate counts become
the basis for commitments once target lockout
is selected. These counts can be modified and
non site specific target/measure activity counts
can be added via the Regional Planning
estimates/targets screen.
Participate in work planning sessions to
establish final targets and budget.
Review Regional plans in WasteLAN and pipeline
workload and budget
Review past Regional accomplishments and planned
durations/dollars
Review Regional requests for budget reserve
Conduct Regional conference calls on the results of the
analyses
Participate in work planning sessions to establish final
targets and budget
July 12, 2004
11-12
Change 3, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Month
Regional Responsibilities
HQ Responsibilities
October/
November
Participate in one day national meeting to
communicate commitments and allocation of
Regional funds based on national GPRA
commitments
Update primary candidate designations and
budget data as necessary based on results of
work planning sessions.
Participate in one day national meeting to
communicate commitments and allocation of Regional
funds based on national GPRA commitments
November
Revise targets during open season based on
appropriations
Revise Regional Enforcement operating plans
Revise Regional Response Operating Plans
WasteLAN data quality problems that affect the SCAP report update shall be resolved prior to the work planning
meetings. These problems are to be resolved on a Region-specific basis through telephone calls betweenHQ andthelMC
or program manager.
II.I.2 WasteLAN Reports for Planning/Target Setting
Exhibit II.6 presents the WasteLAN reports used by HQ and the Regions in the establishment of Regional
targets/measures. Following is a description of these reports:
The Site Summary Report (SCAP-02) is used by EPA to display enforcement sensitive WasteLAN data forNPL and
non-NPL sites.
The Response Financial Summary Report (SCAP-04R), Federal Facility Financial Summary (SCAP-04F), and
Enforcement Financial Summary Report (SCAP-04E) aggregate dollars by program area and provide both site-
specific and non-site specific backup from WasteLAN. These reports should be used to compare the funding requests
with the Regional budgets.
The Site Assessment Report (SCAP-13) is used by EPA for reporting estimates, plans, and accomplishments for
SCAP site assessment measures. The information provided by this report is used in conjunction with the SCAP-14
report to encompass the entire range of targets and measures.
The Super-fund Accomplishments Report (SCAP-14 and 14F) is used by EPA to track targeting, planning, and
accomplishment actions in support of the Response, Enforcement, and Federal Facility programs.
The GPRA Report (SCAP-15) is used by EPA to track GPRA performance goals and measures in support of the
Response program.
~ The Reconciliation (SCAP-14 Audit) Report (SCAP-16) is used to extract all potential candidates for a SCAP-14
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.
Change 7, FY 04/05 SPIM
11-13
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
The Cost Recovery Targeting Report (ENFR-17) estimates potential targets for cost recovery.
The Measures of Success Report (ENFR-62) provides the potential PRP oversight targets.
EXHIBIT II.6
PLANNING/TARGET SETTING WasteLAN REPORTS
SCAP-2:
Site Summary Report
SCAP-4E:
Enforcement Financial Summary Report
SCAP-4F:
Federal Facility Financial Summary
SCAP-4R:
Response Financial Summary Report
SCAP-13:
Site Assessment Report
SCAP-14/14 F:
Superfund Accomplishments Report
SCAP-15:
GPRA Report
SCAP-16:
Reconciliation (SCAP-14 Audit) Report
ENFR-17:
Cost Recovery Targeting Report
ENFR-62:
Measures of Success Report
II. J REGIONAL ACCOMPLISHMENT REPORTING
Accomplishments data are entered into Waste LAN by the IMC, RPM, OSC, SAM, or other designated program staff
(i.e., PRP search, cost recovery). Data on accomplishments should be entered into WasteLAN within five working days
of the action occurring. Only accomplishments correctly reported in WasteLAN will be recognized by HQ. If a
Region feels that it has correctly recorded an accomplishment that is not showing in the WasteLAN reports for
accomplishment reporting, please contact the appropriate HQ office.
Regions should perform data quality checks and make adjustments to WasteLAN if the database does not reflect
actual accomplishments. In any event, Regions need to be sure the information reflected in WasteLAN is up-to-date and
accurate.
Preliminary end-of-year accomplishments will be pulled on the fifth working day of September; it is the starting point
for preparing for the end-of-year assessment in November. Since many senior managers and Congress request final
accomplishments immediately following the end of the year, WasteLAN accomplishment reports will be pulled on the
fifth and the tenth working days of October and reported in late October to mid-November (see Manager's Schedule of
Significant Events at the beginning of this Manual for specific dates). This allows the Regions ample opportunity to
review end-of-year financial data, ensure that all accomplishments are accurately reflected in WasteLAN, and determine
which commitments were not met.
April 7, 2003
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FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
WasteLAN Reports for Accomplishment Reporting
Exhibit II.7 presents the WasteLAN reports HQ uses to evaluate Regional accomplishments. All are used for
reporting and crediting accomplishments for targets and measures. Following is a description of these reports:
The SCAP Response Financial Summary Report (SCAP-04R), Federal Facility Financial Summary (SCAP-04F),
and Enforcement Financial Summary (SCAP-04E) aggregate dollars by program area and provide both site-specific
and non-site specific backup from WasteLAN. These reports should be used to compare the funding requests
contained in WasteLAN to the Regional budgets. Regions are prompted for "Approved" or "Alternate."
The Site Assessment Report (SCAP-13) is used by EPA for reporting estimates, plans, and accomplishments for SCAP
site assessment measures.
The Superfund Accomplishments Report (SCAP-14 and 14F) is used by EPA to track targeting, planning, and
accomplishment actions in support of the Response, Enforcement, and Federal Facility programs.
The GPRA Report (SCAP-15) is used by EPA to track GPRA performance measures in support of the response
program.
The Reconciliation (SCAP-14 Audit) Report (SCAP-16) is used to extract all potential candidates for a SCAP-14
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.
Settlements Master Report (ENFR-3) - This report lists all settlements to date. Data are divided by settlement
category and summarized by FY, Region, and remedy.
De Minimis Settlements Report (ENFR-07) - This report lists all the de minimis settlements including the number of
parties.
Administrative/Unilateral Orders Issued (ENFR-25) - This report lists AOs and UAOs that have been issued.
Measures of Success Report (ENFR-62) - This report is intended to allow Regions to report progress on measures
of success relating to enforcement fairness and trust fund stewardship.
Environmental Indicators Report (ENVI-01) - This report provides EPA Regional management with a tool to easily
monitor environmental indicators (EI) data.
FY 04/05 SPIM
11-15
April 7, 2003
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT II.7
PROGRAM EVALUATION WASTELAN REPORTS
SCAP-4E:
Enforcement Financial Summary Report
SCAP-4F:
Federal Facility Financial Summary
SCAP-4R:
Response Financial Summary Report
SCAP-13
Site Assessment Report
SCAP-14/14 F:
Superfund Accomplishments Report
SCAP-15:
GPRA Report
SCAP-16:
Reconciliation (SCAP-14 Audit) Report
ENFR-3:
Settlements Master Report
ENFR-07
De Minimis Settlement Report
ENFR-25:
Administrative/Unilateral Orders Issued
ENFR-62:
Measures of Success Report
ENVI-01:
Environmental Indicators Report
ILK HQ EVALUATION OFREGLONAL PERFORMANCE
Accomplishment data associated with targets/measures are pulled fromW asteLAN at the close of business of the fifth
working day of the quarter; therefore, it is necessary that the Regions update their accomplishments data as
accomplishments occur, but in no case later than quarterly prior to the fifth working day pull date. HQ
management tracks and bases its evaluation of Regional program performance on these data. The data are pulled
on a selected number of key indicators of progress in the Superfund program (e.g., construction starts and completions,
removal completions, site characterization starts, response settlements and referrals, RODs, and cost recovery activities).
These numbers are the official numbers used in any reports ofprogress given to the Administrator, Deputy Administrator
(DA), AAs, Congress, and the media. Detailed HQ management evaluation occurs at two points during the FY: after the
second quarter (mid-year assessment) and after the fourth quarter (end-of-year assessment). (See Exhibit II.8.) In
addition, HQ may conduct Regional reviews in FY 04/05.
II.K. 1 Mid-Year Assessment
The purpose of the mid-year assessment is to evaluate the utilization of Regional programmatic budgets. Specifically,
the mid-year assessment will be used to:
~ Provide both HQ and the Regions with an opportunity to assess performance;
Provide data to HQ and the Regions to make decisions on distribution of remaining budget;
~ Consider the impact of Regional program performance on the Superfund pipeline;
~ Work with Regions experiencing difficulty in meeting their targets; and
Identify trends in program performance and adjust program management strategies accordingly.
April 7, 2003
11-16
FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
On the fifth working day of April, second quarter SCAP data are pulled from WasteLAN. Following the mid-year
assessments, OSRTI, FFEO, FFRRO, and OSRE Directors brief the AA SWER or AA OECA on the steps being taken to
ensure the accomplishment of annual targets. To ensure that these actions are implemented, E1Q will track follow-up items
and reallocate resources. The results of the mid-year assessment can result in increases or decreases to third or fourth
quarter AOAs based onRegional GPRA performance and obligation rates. The measure of a Region's ability to meet their
targets will be considered in October/November when final proposed FY commitments and Regional budgets,
respectively, are established for the year.
II.K.2 End-of-Year Assessment
Before the end of the fourth quarter, there is a preliminary pull for end-of-year accomplishments (the first week of
September). This pull is used to project end-of-year accomplishments. It is important to stress that this is only a
projection and that the actual pulls, on the fifth and tenth working days of October, are likely to be somewhat different
than the projected numbers. Since many Superfund managers and Congress request final accomplishments immediately,
Regions should make every attempt to update WasteLAN at the earliest possible date and, in no event, any later than the
fifth working day after the end of the FY.
EXHIBIT II.8
THE REGIONAL EVALUATION PROCESS
1st Quarter
Pull WasteLAN Reports on GPRA/Program Accomplishments
2nd Quarter
Mid-Year
Assessment
Pull WasteLAN Reports on GPRA/Program Accomplishments and Internal Measures
Perform Regional Mid-Year Reviews
Evaluate Program Status
Brief Senior Management
3rd Quarter
Pull WasteLan Reports on GPRA/Program Accomplishments
Report on Progress of Regions having difficulties meeting Targets
4th Quarter
End-of-Year
Assessment
Pull WasteLAN Reports on GPRA/Program Accomplishments and Internal Measures
Develop Senior Management Reports Package
Evaluate Annual Performance Status
Evaluate Annual Performance and produce National Progress Report
Provide input into next FY Work Planning
Brief Senior Management Process
In No vember, F1Q conducts the official end-of-year assessment. This assessment is an integrated analysis of program
performance activities for the year. The purpose of the end-of-year assessment is to emphasize pipeline issues (e.g.,
slipped targets and their impact on commitments for the next year). Missed targets may have resource implications for
the next FY. The end-of-year review also notes progress toward implementing strategies identified in the mid-year
assessment, and identifies Regions that might require additional HQ assistance as the new FY begins.
HQ considers the end-of-year assessment in developing the final GPRA annual performance goals. In this way, the
results of the end-of-year assessment have a double impact.
Change 2, FY 04/05 SPIM
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February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
II.K.3 Management Reporting
The following sections provide a brief description ofthe reports available to support Superfund program management.
a. Superfu nil Management Reports
The implementation of an integrated WasteLAN data base and the improvement of WasteLAN data quality led to
the development of a series of senior management reports. These management tools are designed to supplement
conventional quarterly accomplishment reporting by providing a more comprehensive examination of program
activity. The format and content ofthe reports has evolved over time to address a variety of project needs, providing
EPA senior managers with summary graphic reports and backup site detail information.
The reports provide graphical representations of the status of targets and accomplishments, as well as analytic
summaries of key aspects ofthe program including: status and duration of events; trend analysis ofPRP involvement;
cost recovery candidates; base closure joint indicators of progress; and the current status of negotiations, settlements,
and litigation.
The reports, produced daily through Superfund eFacts, (currently in development), illustrate the progress being made
by the Agency in both the movement of projects through the Superfund pipeline and in the trend toward increased
involvement by PRPs. Superfund eFacts provides information on Site Assessment, Federal Facilities, Construction
Completions, and SCAP and GPRA accomplishments. This data is available in regional, state, or national views.
Additional management reports produced by OSRE include:
~ Cost Recovery Targeting (ENFR-17) - This report estimates potential targets for cost recovery.
~ ROD Amendment and RD/RA Negotiations Report (ENFR-22) - This 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.
Ongoing RD/RA Negotiations Time Line (ENFR-11) - This 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).
Additional management reports produced by FFRRO include:
BRAC Pipeline Report (BRAC-01) - This report lists the pipeline actions within the current FY for any
BRAC site.
Environmental Baseline Study (EBS) Report (BRAC-02) - This report lists allFederal facility sites withEBS
starts or completions within the FY.
Finding of Suitability to Transfer/Lease (BRAC-03) - This report lists all sites for which EPA concurs on
a finding of suitability for transfer/lease within the current FY.
April 7, 2003 11-18 FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
b. Annual Reporting Requirements
Commencing March 31, 2000, and each year thereafter, the Agency is required to submit to the President and
Congress a GPRA annual performance report that summarizes the program performance for the previous fiscal year.
Specifically, each report will (a) review the success of achieving the program's objectives and sub-objectives during
the fiscal year; (b) evaluate the annual performance plan for the current fiscal year relative to the performance
achieved toward the performance objectives and sub-objectives in the fiscal year covered by the report; and (c)
explain and describe where a performance objective/sub-objective has not been met, why it was not met, and those
plans and schedules for achieving it.
ILL TARGET AND DEFLNLTLON CHANGE REQUESTS
After targets have been finalized and funding levels developed, the SCAP process provides certain flexibility to
modify plans during the year. Modifications to planned GPRA annual performance goals are termed change requests.
Regional requests for changes to targets established in the annual plan must be forwarded in writing from the
Regional Division Director to HQ OSRTI, OECA, or FFRRO Office Directors, as applicable, when the Region is
unable to make a site substitution for a target. Site Substitutions are not allowed for five-year review targets. Sites
targeted for Five-Year Reviews must be completed by the "due date" (planned completion date) established for each
site.
Any exceptions to the accomplishment definitions contained in the Appendices to this Manual are considered target
definition changes. Regions also should note that changes made in WasteLAN to site schedules and other planning data
will not automatically result in changes to targets.
Target changes that modify the Region's AOA require a financial change request. In these situations, the financial
change request becomes the target change request. Chapter III outlines the change request procedures.
Although Regions have the flexibility to alter plans, they are still accountable for meeting the targets established at
the beginning of the FY. Changes to commitments should not be made simply because targets will not be met. Regions
should discuss with HQ during the mid-year reviews any issues that may affect the meeting of negotiated annual targets.
In some cases, however, changes to targets may be necessary and may be revised under the following conditions:
Major, unforeseen contingencies arise that alter established priorities (i.e., Congressional action, natural disasters);
Major contingencies arise to alter established Regional commitments (i.e., State legislative action);
Measure or definition in system is creating an unanticipated negative impact;
~ Major shifts in project approach; or
~ Need to address newly identified site which represents a significant human health or ecological risk.
OSRTI, OECA, and FFRRO require that all target and definition changes be submitted to HQ no later than July.
Optimally, such requests should be submitted during discussions with HQ during mid-year reviews.
Regions should not initiate any obligations against change requests until the HQ Office of the Comptroller (OC) and
the Director of the appropriate office approve the revised AOA in IFMS. The site back-up in WasteTAN should be
revised by the Region if the change is approved.
Under the Pipeline Operations AOA allocation methodology, Regions are allocated resources, in part, based on their
targets for specific actions (e.g., RI/FS, RD, EE/CA) at specific sites. Because of this approach, Regions have flexibility
to alter their plans regarding at which sites they conduct work, but they may not change the overall numerical target within
each action category once the Pipeline Operations AOA resources are distributed among the Regions. The extentto which
a Region meets or exceeds its target will have funding implications in the next year's distribution of Pipeline Operations
AOA resources.
Change 2, FY 04/05 SPIM
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February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
Maintaining the Planning Estimates/Targets
Regions are responsible for initiating the work planning process and for entering the preliminary and final targets into
WasteLAN. Prior to work planning sessions with HQ, Regions can use the Regional Planning screen to identify which
sites meet the planning logic as potential accomplishments for the upcoming FY. From this universe of sites (shown in
red as Planning Data on the Regional Planning screen), Regions can identify primary candidate sitesthose that are most
likely to be accomplished. After identifying primary candidates (shown in blue on the Regional Planning screen), the
Regions can then use the target lockout feature found on the Regional Planning screen to copy the primary candidate
number to the Planning Estimates/Targets screen. This number is used as a starting point in identifying the Region's
planning estimates/targets during work planning sessions. After work planning sessions are completed, Regions use the
Planning Estimates/Targets screen to make any necessary changes. Once changes have been made and final
targets/planning estimates are reviewed by E1Q, E1Q will "lock out" Regions (i.e. Regions will not be able to make any
changes to these numbers). This final number is shown in red on the Accomplishments Tracking screen as the Planning
Estimates/Target number. During the FY if changes have been made to the number of target commitments approved, E1Q
will "unlock" the target numbers allowing the Region to make the approved change(s), and then "relock" the screens.
In general, E1Q does not require site-specific targeting. The four exceptions are Pipeline Operations AOA targets,
Cost Recovery actions at sites with potential Statute of Limitations (SOLs) so that they will be addressed prior to the
expiration of the SOL, de minimis settlements, and PRP Oversight Administration for each enforcement agreement.
Changes to sites identified as targets for the latter three measures require HQ approval.
II.M SPECIAL REPORTING TOPICS
II.M.l Site Assessment
As the nature of site assessments change, new reporting and accountability challenges to accurately portray the extent
of State, Federal, and local government site assessment activities need to be addressed. Traditional CERCLA-reported
site assessment accomplishments, including integrated assessments, should continue to be entered into WasteLAN when
they occur. As Regions provide States flexibility in Cooperative Agreement applications and work plans by expanding
the definition of types of assessment activities to be performed, the States also need to be accountable for the activities
performed and provide quarterly or annual reports of the number of sites assessed, types or nature of assessments
performed, and assessment results. Management systems at the State and probably Federal level will be needed to provide
the accountability necessary and, also, to identify program accomplishments.
II.M.2 Base Closure
EPA is providing resources to support the President's Fast Track Cleanup program. To facilitate EPA's justification
of these resources, Regions are required to support several data points for closing bases. WasteLAN has been modified
to include these items.
II.M.3 Pre-SARA Sites Initiative
The Superfund program has developed a Pre-SARA site initiative to promote the resolution of issues which have
delayed the completion of construction at hundreds of sites across the country. Prior to the enactment of the Superfund
Amendments and Reauthorization Act of 1986 (October 16,1986), EPA listed 711 sites (including 4 Federal facility sites)
on the National Priorities List. At the end of FY 2002, there were 203 Pre-SARA sites not yet construction complete or
deleted (including one RCRA deferral site). OSRTI is now considering a tracking system to supplement WasteLAN,
containing narrative information submitted by the Regions on the causes of delays over the past 1 to 2 decades, the
obstacles which remain to completing the sites, and the Region's plan of action to overcome site-specific obstacles.
July 12, 2004
11-20
Change 3, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-P
II.M.4 Mega Sites
Generally, a site is considered to be a mega-site if the combined extramural, actual and planned, removal and remedial
action costs incurred by Superfund or by PRPs are greater than $50 million. The mega-site designation may be applied
to any federal or non-federal facility NPL or non-NPL site. For the purposes of reporting in CERCLIS, a site is defined
as a mega-site (MS) if:
the cumulative value ofthe extramural capital costs of all selected remedies (as expressed in decision documents
such as RODs, ROD amendments, or action memoranda) exceeds $50 million; OR
the cumulative value ofallPRP or Federal Facility actual and expected extramural capital costs (as memorialized
in documents such as settlements, orders, or MO As) forremoval or remedial action response activities (excluding
long-term response) at the site exceeds $50 million; OR
the cumulative value of net actual extramural obligations for Fund-financed removal and remedial actions
(excluding LTRA) at the site exceeds $50 million; OR
the cumulative value of post-ROD (or post-action memorandum), removal and remedial action obligations
(excluding LTRA) planned in CERCLIS for the selected remedies at the site exceeds $50 million; OR
the cumulative value of any combination of the above costs exceeds $50 million.
A site is defined as a potential mega-site (MP) if the Region, using its best judgment, expects that the total costs of
removal and remedial actions will exceed $50 million, but the documentation of actual or expected costs (e.g., through
decision or settlement documents or actual obligations) does not currently exist. Once such documentation is developed,
the site should be reclassified as MS. Conversely, if new information suggests that the site is not a mega-site, the
designation of MP or MS should be removed. During annual workplanning discussions between Regions and
Headquarters, the Regions will confirm these designations on a site-specific basis.
II.M.5 Superfund Alternative Sites (Please see Appendices A and B.)
II.N GENERAL WORK PLANNING AND REPORTING REQUIREMENTS
The following section discusses some general work planning and reporting requirements of the various Superfund
offices.
II.N.l Data Lockout on Historical Accomplishments
WasteLAN has a historical accomplishment lockout feature that logs and controls changes to Superfund data sensitive
to Congressional inquiry. This feature uses the Accomplishment Change Log Screen and reports that list all changes that
have been made to historical accomplishments data. A Regional manager for Superfund shall approve either in writing,
or using the management review function in WasteLAN, each data change made by a Region to locked historical data.
Only Regional IMCs, individuals designated by the IMC and Remedial Project Managers (RPMs), shall have
access/authority to change/add/delete their own Region's data via a WasteLAN Smart Screen once written approval has
been received. All other Regional personnel will be denied access to the change system. Written approval documents
or records of approval via WasteLAN management review must be maintained by the IMC for the duration of the life
cycle of the data changed (up to seven years).
Please Note: In Regions that use Management Review, RPMs will be able to make changes to prior year accomplishment
data via the Accomplishment Change Log Screen. All changes made by RPMs will, however, need to be approved by
the Regional Manager Reviewer.
FY 04/05 SPIM
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April 7, 2003
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OSWER Directive 9200.3-14-1G-P
Each Region will establish a policy or procedure to ensure that the appropriate people have knowledge of and approve
of the change. All approval documents must bear a System Generated Reference Number or Document Number.
II.N.2 Data Validation and Verification
GPRA requires that an agency address its verification and validation procedures for performance data in the annual
performance plan. WasteLAN data verification and validation procedures were incorporated as part of Superfund
programs' submission to the EPA's annual performance plan.
A key component of WasteLAN verification/validation procedures is the Regional CERCLIS Data Entry Internal
Control Plan. The control plans include: (1) Regional policies and procedures for entering data into WasteLAN; (2) a
review process to ensure that all Superfund accomplishments are supported by source documentation; (3) delegation of
authorities for approval of data input into WasteLAN; and (4) procedures to ensure that reported accomplishments meet
accomplishment definitions. Also, Regions documented in their control plans the roles and responsibilities of key
Regional employees responsible for WasteLAN data (e.g., Regional project manager, information management
coordinator, supervisor, etc.), and the processes to assure that WasteLAN data are current, complete, consistent, and
accurate.
With the increased emphasis on verifiable and validated data by GPRA, the program offices are requesting that the
Regions review their current CERCLIS Data Entry Internal Control Plans and update their control plans according to the
requirements listed above.
In addition, Regions are required to submit to their Regional Superfund Records Center the document that constitutes
or justifies an accomplishment date (actual start or actual complete) recorded in WasteLAN. (Documentation
requirements for these dates can be found in the Appendices to this Manual in the "Definition of Accomplishment"
section of the applicable target or measure.) When submitting the documentation to its record center, the Region should
provide the target/measure category and the WasteLAN Operable Unit (OU)/actionname/sequence number. The Regional
Records Center is to include these S CAP data with the document index data, and provide the document index number from
its tracking system for entry into WasteLAN associated with the applicable accomplishment date.
II.N.3 Action Lead Codes
Action lead codes identify the entity performing the work at the site. Exhibit II.9 shows the valid project/action lead
codes in WasteLAN.
A lead code must be placed in WasteLAN for all Actions. Only the leads that are valid for the chosen Action can be
entered. Leads are not required for SubActions. Regions have the ability to code the lead for project support activities
(e.g., community relations, support agency assistance, etc.) based on Regional preference. All enforcement actions (e.g.,
orders, decrees, PRP searches, etc.) performed by EPA should have a lead of "FE" (Federal Enforcement). All
enforcement actions conducted by the State should have a lead of "SE" (State Enforcement). WasteLAN should not
contain planned obligations for projects with "SR" or "SN" leads. No funds will be provided for activities with these
leads.
The Agency acknowledges that States can and have assumed the lead role in reaching an agreement with the PRPs
for response activities atNPL sites without negotiating a cooperative agreement or other formal agreement withEPA (SR-
lead). However, the NCP has determined that in the absence of a formal agreement the State will not be officially
recognized as the "lead agency" for the project and EPA will not concur on the remedy selected.
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OSWER Directive 9200.3-14-1G-P
EXHIBIT II.9: ACTION LEAD CODES IN WASTELAN
Lead
Definition
F
Fund-financed response actions performed by EPA (applies to response actions)
RP
PRP- financed response actions performed by the PRP under a Federal order/ CD (applies to
response actions)
S
Fund- financed response actions performed by a State. Money provided through a Cooperative
Agreement (CA) (applies to response actions)
PS
PRP-financed response actions performed by PRP under a State order/ CD with PRP oversight paid
for or conducted by EPA through an EPA CA with the State, or, if oversight is not funded by EPA, a
state Superfund Memorandum of Agreement (SMOA) or other formal document between EPA and
the State exists which allows EPA review of PRP deliverables (applies to response actions)
SN
State-financed (no Fund dollars) response actions performed by the State (applies to response
actions)
SR
PRP response under a State order/ CD and no EPA oversight support or money provided through a
CA and no other formal agreement exists between EPA and the State (applies to response actions)
CG
Work performed by the Coast Guard - Limited to removals (applies to response actions)
MR
Work performed by PRP under a Federal CD with an agreement that the Fund will provide some
reimbursement to the PRP (preauthorization for mixed work), (applies to response actions)
SE
Enforcement actions performed by a State. Money provided through a CA or, if not funded by EPA,
a comparable enforcement document exists (applies to RODs and enforcement actions)
FE
Enforcement actions performed by EPA or work done by enforcement program at private or Federal
facilities sites (applies to RODs and enforcement actions). Flistorically (Pre-FY 89) applied to RI/FS
and RD response actions.
EP
Response actions performed by EPA using in-house resources
FF
Response actions performed by the Federal facility with oversight provided by EPA and/or the State
at sites designated as Federal facilities on the NPL (also applies to RODs at Federal facilities)
TR
Indian Tribal Governments
CO
Community Organization (Only valid for Community Involvement Activities)
SD
State Deferral is a PRP- or State-financed response action at a non-NPL or proposed NPL site
overseen or conducted by the State pursuant to a deferral agreement with the Region.
SC
State ROD with EPA concurrence
SW
State ROD without EPA concurrence
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April 7, 2003
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OSWER Directive 9200.3-14-1G-P
Lead
Definition
SA
PRP financed actions from a special account performed by EPA, where the majority1 of funding is
disbursed from a special account (applies to response actions) .
SG
PRP financed actions from a special account performed by the United States Coast Guard, where the
majority1 of funding is disbursed from a special account - Limited to removals (applies to response
actions) .
ST
PRP financed actions from a special account performed by tribal governments, where the majority1 of
funding is disbursed from a special account (applies to response actions)
SS
PRP financed actions from a special account performed by a state, where the majority1 of funding is
disbursed from a special account. Money provided through a Cooperative Agreement (CA) (applies
to response actions)
II.N.4 Lead Changes
A takeover or lead change occurs when the entity performing a response action changes after the action has started
and credithas been given. Typically, this occurs when a settlement with the PRP had been reached after the action started.
It may also occur when the Fund assumes an RP-lead project because of non-compliance with an Administrative Order
(AO) or Consent Decree (CD).
In order to avoid delays resulting from PRPs assuming the lead during a discrete phase of the project (a takeover),
a policy has been established that limits lead changes from EPA to PRPs in the middle of a phase of the Superfund
process, except in situations where the change will not cause undue delays (OSWER Directive 9800.1-01, Limiting Lead
Transfers to Private Parlies During Discrete Phases of the Remedial Process, November 14, 1991). The policy applies
to lead changes from EPA to PRPs only, not EPA takeovers of PRP work or lead changes involving States.
It is expected that much of the early site assessment activities will be Fund-lead. However, response lead changes
(i.e., changeovers) can occur at any of the following points in the process:
Prior to development of an EE/CA for a NTC removal action;
Prior to the ESI/RI or RI/FS;
~ Prior to the FS if the RI and FS are being done separately;
~ After the ROD is signed and prior to beginning the RD or RA; and
Prior to RA contract solicitation, when funding the RA would have significant implications for the Fund and when
no significant delays will occur.
1 Majority is defined to mean that the contribution from the Special Account for the total response cost (including direct and indirect
costs) would meet or exceed the amount contributed by the largest non-PRP entity (i.e., EPA or State, where applicable). For example for a
remedial action, based on the total estimated response cost, if 50% of that cost is derived from a Special Account, and 45% of the response cost
is paid for out of Fund monies, and the State pays the remaining 5% share of the response cost, the majority of the response cost is being paid
out of the Special Account. The appropriate use of Special Account funds is provided in the "Guidance on Key Decision Points in Using Special
Account Funds" dated September 28, 2001.
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OSWER Directive 9200.3-14-1G-P
When circumstances warrant passing the lead to PRPs during a phase of cleanup, steps should be taken to minimize
potential causes of delay. For example, if PRPs assume the lead during the RI/FS, they should be given a limit of 60 days
to enter into an Administrative Order on Consent (AOC) for performing the work.
If a PRP is allowed to take over a response action after dollars have been obligated, the Region should retain the funds
needed for oversight of the entire PRP action and deobligate the rest. Funds that are deobligated may be replaced in the
Region's A OA pursuant to the Agency's de obligation policy.
When dollars were originally obligated for Fund-financed actions and a takeover occurs, Regions will have to request
a change in the account number through their Regional Financial Management Office (FMO). The Action code within
the account number changes if the Agency is acting in an oversight role as opposed to performing the response action.
RP-lead projects that are deficient or where the PRPs are recalcitrant may be addressed by the response program.
If the project requires substantial Fund involvement to correct, it should be coded as a takeover in W asteLAN.
If a takeover of an action does occur, anew Action must be created in WasteLAN. A takeover does not create a new
OU. The completion date of the original Action must be the same as the start date of the new Action. Takeover/Phased
Indicators must be entered with both Actions. The "Original Action Takeover (TO)" indicator is used to flag the original
Action which has the change in lead, whereas a "New Action resulting from Takeover (TN)" indicator is used to flag the
new Action.
On rare occasions, an action that has been taken over requires an additional lead change. For example, EPA reaches
settlement with the PRPs after a Fund-financed action has begun. After the PRPs start work, EPA experiences problems
with the PRPs in meeting deadlines or in the quality of the work. As a result, EPA makes a decision to takeover the PRP-
financed action. The steps to be taken to indicate this scenario in WasteLAN are as follows:
1) A new Action is added to WasteLAN at the same OU. In our example, a new combined RI/FS with a 'F'- lead would
be added.
2) The start date of this new Action is the date of the takeover.
3) A Takeover/Phased Indicator of "New Action Resulting from Takeover (TN)" is entered with the new Action.
4) The completion date of the latest action that was taken over is the same as the start date of the new Action (date of the
takeover).
5) The Takeover/Phased Indicator of the latest action that was taken over is changed from a "New Action Resulting from
Takeover (TN)" to a "Takeover of an Action Taken Over (TT).
Exhibit 11.10 provides an example of the W asteLAN coding. In this situation, no changes are made to the original action.
FY 04/05 SPIM
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April 7, 2003
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OSWER Directive 9200.3-14-1G-P
EXHIBIT 11.10
CODING OF TAKEOVERS
Action Takeover
OU
Action
Name
Seq.
Lead
Actual
Start
Actual
Comp
Takeover/
Phased
Indicator
Comments
01
Combined
RI/FS
1
F
8/1/97
9/1/97
TO
Fund-financed
Action being
taken over by
PRPs
01
PRP RI/FS
1
RP
9/1/97
12/1/97
TT
PRP Action
initiated and
taken over by
Fund
01
Combined
RI/FS
2
F
12/1/97
TN
Fund-Financed
Action initiated
II.N.5. Anomalies and Phased Projects
Anomalies are those projects that do not fit the normal definitions of pipeline actions. Anomalies can be those projects
that 1) do not receive SCAP credit, but still need to be tracked, or 2) occur out of the ordinary pipeline progression.
An example of a SCAP anomaly occurs when different entities conduct FS work simultaneously that leads to a single
ROD. Since it is inconsistent to give credit for more FS starts than completions (the Agency would have to explain why
FS work is not leading to a ROD), only one FS can receive credit for a start and completion. These projects are coded
under the same OU with multiple sequence numbers and those FSs thatwillnot receive credit are given a Takeover/Phased
Indicator of "Other Start and Completion Anomaly (OA)."
At the RD and RA stages, a project may be phased or time-sequenced to accelerate the cleanup effort. Phasing is
complementary to OUs. Whereas OUs break large, complex projects into smaller, more manageable work elements,
phasing is a method to accelerate the implementation of the OUs. Phasing manipulates the internal steps required to
complete each OU, thereby optimizing the overall schedule; for example, a RA that requires site clearing prior to
constructing an incinerator. The clearing would be one phase of the RA, while the construction of the incinerator would
be a second phase.
Regions enter a separate RA for each phase. Phases of each response action are shown in WasteLAN by the use of the
Takeover/Phased Indicators of Phased Start (PS) and Phased Complete (PC) or Phased Start and Completion (PB) (See
Exhibit II. 11). Funding required for each of the phases is tracked against the phase. However, the duration of the project
is calculated from the date the first phase started to the date the last phase is completed.
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FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-P
EXHIBIT 11.11
REMEDIAL EVENTS, ANOMALIES, AND PROJECT PHASING
ou
Action
Name
Seq.
Lead
Plan
Start
Plan
Comp
Takeover/
Phased
Indicator
Comment
01
PRP
RI/FS
1
RP
96/2
98/3
01
PRP
FS
1
RP
97/3
98/3
OA
No Credit for
Start or
Completion
01
PRP
FS
2
RP
97/3
98/3
OA
No Credit for
Start or
Completion
01
R01
1
FE
98/3
AN01
01
RD1
RP
99/1
00/2
PC
PHASE I
01
RD2
RP
99/2
00/3
PS
PHASE II
01
RA1
RP
00/3
01/1
PC
PHASE I
01
RA2
RP
00/3
04/1
PS
PHASE II
II O Subject Matter Experts
Exhibit 11.12 identifies all SCAP report contacts. Exhibit 11.13 identifies the subject matter experts for Chapter II Program
Planning and Reporting Requirements.
EXHIBIT 11.12 SCAP REPORT CONTACTS
(Reports Owner: R White )
Designation
Title
Report/Data Owner
SCAP-2/11/12
Site Summary Report/FOIA
Robert White, (703) 603-8873
Margaret Brown, (703) 603-8876
et al
SCAP-4E
Enforcement Financial Summary
(Enforcement maintains this report)
Alice Ludington, (202) 564-6066
SCAP-4F
Federal Facility Financial Summary
Marie Bell, (703) 603-0050
SCAP-4R
Response Financial Summary
Report
Willie Griffin, (703) 603-8911
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OSWER Directive 9200.3-14-1G-P
Designation
Title
Report/Data Owner
SCAP-13
Site Assessment Report
Randy Hippen, (703) 603-8829
Juanita Standifer, (202) 566-2764
James Maas, (202) 566-2778
SCAP-14
The Superfund Accomplishments
Report
Robert White, (703) 603-8873
Renee Wynn, (703) 603-0049
Marie Bell, (703) 603-0050
et al
SCAP-15
GPRA Report
Janet Weiner, (703) 603-8717
SCAP-16
Reconciliation SCAP 14 Audit
Report
Robert White, (703) 603-8873
et al
EXHIBIT 11.13 SUBJECT MATTER EXPERTS
Subject Matter
Experts
Subject Area
Phone #
Sharon Blandford
Art Flaks
Chapter 2 Leads
(703) 603-8752
(703) 603-9088
Erin Conley
E-facts
(703) 603-8928
Mark Mjoness
Emergency Response/Removal
(703) 603-8727
Julie Roemele
OSRTI Work Planning
(703) 603-9097
Janet Weiner
OSRTI /GPRA
(703) 603-8717
Alan Youkeles
BPEB
(703) 603-8784
Melanie Hoff
Program Planning/EI
(703) 603-8808
Matthew Charsky
RODs/Remedy Selection
(703) 603-8777
Robert White
SCAP Reports Owner
(703) 603-8873
Kevin Hollingsworth
Work Planning
(703) 603-9058
Jeff Lape
Resource Management
(703) 603-8914
September 8, 2005
11-28
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OSWER Directive 9200.3-14-1G-P
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April 7, 2003
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OSWER Directive 9200.3-14-1G-Q
Superfund Program Implementation Manual FY04/05
Chapter III: Superfund Budget Planning Process And Financial
Management
FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
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OSWER Directive 9200.3-14-1G-Q
Chapter HI
Superfund Budget Process and Financial Management
Table of Contents
CHAPTER III SUPERFUND BUDGET PLANNING PROCESS AND FINANCIAL MANAGEMENT III-l
III.A. Introduction III-l
III.B. Budget Planning and Priorities III-l
III.B.l Budget Development Process III-l
a. Budget Formulation III-l
b. Budget Review and Planning (Planning Year) III-2
c. Budget Execution (Current Year) III-2
III.B.2 Budget Structure III-5
Program Results Code and National Program Managers III-5
III.B.3 The FY04/05 Superfund Program Goals and Priorities III-6
a. Response Program Budget III-6
b. Homeland Security and Removal III-7
c. Enforcement Budget III-7
d. Federal Facilities Response Budget III-8
e. Base Realignment and Closure III-8
f. Federal Facilities Enforcement Budget III-8
III.C. Regional Operating Plan and Advice of Allowance Development III-9
III.C. 1 Allocating Superfund Resources Among the Regions III-9
III.C.2 Remedial Response Program Budget Ill-10
a. Remedial Action AOA Ill-10
b. Pipeline Operations AOA Ill-10
III.C.3 Homeland Security/Removal Response Program Budget III-l 1
III.C.4 Federal Facilities Superfund Response Program Budget III-l 1
a. Base Realignment and Closure (BRAC) Budget III-l 1
III.C.5 Enforcement Program Budget Ill-12
III.C.6 Federal Facilities Enforcement Program Budget Ill-12
III.C.7 Deobligating Prior Year Ends Ill-12
III.C.8 Budget Object Classes Ill-13
III.C.9 Regional Change Requests for Reprogramming Among AOAs Ill-13
III.C. 10 Budget Sources and Associated Action Codes Ill-13
III.D Superfund Financial Management 111-26
III.D.l Financial Management Roles and Responsibilities 111-26
a. Regional Financial Management Office 111-26
b. Regional Administrator 111-26
c. Regional Program Office 111-27
d. On Scene Coordinator 111-27
e. Remedial Project Manager 111-27
f. Regional Project Officer/Deputy Project Officer 111-28
g. Administrative Support Unit 111-28
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OSWER Directive 9200.3-14-1G-Q
Chapter HI
Superfund Budget Process and Financial Management
Table of Contents (cont'd)
h. Office of Financial Management/Office of the Chief Financial Officer 111-28
i. Office of Acquisition Management 111-28
j. Grants Administration Division/Office of Administration 111-29
k. Budget Division/OCFO 111-29
1. Cincinnati Finance Center (CFC)/OFS 111-29
m. Research Triangle Park (RTP) Finance Center/OFS 111-29
III.D.2 Superfund Accounting Information 111-29
III.D.3 Financial Data Management Systems and Tools 111-32
III.D.4 Handling Financial Data in the CERCLIS/WasteLAN Environment 111-33
a. Entering Response and Federal Facility Data into CERCLIS/WasteLAN 111-33
b. Entering Enforcement Extramural Budget Data into CERCLIS/WasteLAN 111-33
c. Correcting Financial Data 111-34
III.D.5 The Funding Process 111-36
a. Approvals 111-36
b. Commitments 111-36
c. Obligations 111-37
d. Payments 111-37
e. Deobligations 111-37
III.D.6 Financial Management of Contracts 111-38
a. Contracts for Site-Specific Work 111-38
b. Contracts for Non-Site Specific Work 111-38
III.D.7 Other Financial Vehicles 111-40
a. Interagency Agreements 111-40
b. Cooperative Agreements (CA) 111-40
c. Superfund State Contracts (SSCs) 111-41
III.E Cost Recovery Process 111-42
III.E.l Cost Recovery Referral Development Process 111-43
a. Initiation of Cost Recovery Process 111-43
b. Cost Documentation and Reconciliation 111-43
c. Work Performed Documentation and Reconciliation 111-43
d. Site File Maintenance 111-43
e. Superfund Indirect Costs 111-43
f. Annual Allocation 111-44
g. Cashout/Special Accounts 111-44
h. Department of Justice Involvement 111-44
III.F Superfund Financial Contact Information 111-45
III.F.l Regional Cost Recovery Contacts 111-45
III.F.2 Headquarters Cost Recovery Contacts 111-46
III.F.3 Regional Budget Coordinators 111-47
III.F.4 Subject Matter Experts 111-48
September 8, 2005
Change 1, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Chapter HI
Superfund Financial Management
List of Exhibits
EXHIBIT III-l BUDGET TIME LINE 111-3
EXHIBIT III-2 PROGRAM RESULTS CODE (PRC) III-6
EXHIBIT III-3 WHO PAYS FOR WHAT III-l I
EXHIBIT III-4 ACTION CODES FOR FINANCIAL TRANSACTIONS 111-21
EXHIBIT III-5 ACCOUNT NUMBER STRUCTURE 111-3 I
EXHIBIT III-6 HANDLING FINANCIAL DATA IN THE CERCLIS/WASTELAN ENVIRONMENT 111-35
EXHIBIT III-7 EPA FORMS COMMONLY USED FOR SUPERFUND PROCUREMENTS 111-39
EXHIBIT III-8 REGIONAL SUPERFUND COST RECOVERY CONTACTS 111-45
EXHIBIT III-9 HEADQUARTERS SUPERFUND COST RECOVERY CONTACTS 111-46
EXHIBIT 111-10 REGIONAL BUDGET COORDINATORS III- l-*
EXHIBIT III-l 1 HEADQUARTERS SUBJECT MATTER EXPERT CONTACTS 111-48
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September 20, 2004
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OSWER Directive 9200.3-14-1G-Q
CHAPTER III
SUPERFUND BUDGET PLANNING PROCESS AND FINANCIAL MANAGEMENT
III.A. INTRODUCTION
This chapter discusses the impact of the Superfund Comprehensive Accomplishments Plan (SCAP) process on the
development of the outyear budget, the regional operating plan and the quarterly Advice of Allowance (AO A) process,
and outlines Superfund financial management responsibilities. Provided in this chapter is general information on the
Fiscal Year (FY) 04/05 response, enforcement, and Federal facility extramural budgets including funding priorities. Also
included is a comprehensive list of actions and the appropriate budget source to fund those actions.
Budget resources are categorized as programmatic and/or administrative resources. Examples of Superfund
programmatic expenses are obligations and expenditures for site assessment, cleanup, enforcement, regulation
development support, and Congressionally directed reports. Examples of administrative expenses are staff related costs,
salaries, and overhead. This chapter focuses on the programmatic budget process; it does not discuss administrative
resources. The latter half of the chapter focuses on financial management including E1Q and regional roles and
responsibilities, the tools and systems used to track financial information, the various funding mechanisms available to
EPA to support Superfund cleanup, and the cost recovery process. Finally, the last section of the chapter provides
listings of the Superfund contacts in both F1Q and the regions for various aspects of the budgeting and financial
management process.
III.B BUDGET PLANNING AND PRIORITIES
III.B.l Budget Development Process
The budget process is ongoing and in any given month activities may be taking place for several budget years at
the same time. For instance, in FY04, the FY06 (outyear) budget is being formulated, the FY05 budget (planning year)
is being reviewed and amended, and the FY04 budget (current year) is being implemented.
a. Budget Formulation (Outyear)
The budget formulation process begins in the spring, eighteen months prior to the start of the FY for which the
budget is being prepared. The budget is submitted to Office of Management and Budget (OMB) approximately sixteen
months prior to the start of that FY. This means that SCAP data existing in the second quarter of FY 04 is used to
formulate the FY 06 budget request. The schedules for all response, enforcement, F ederal facilities and base realignment
and closure (BRAC) activities, and the planned obligations for Remedial Actions (RAs) and non time-critical removal
actions reflected in CERCLIS/W asteLAN serve as the foundation for determining the dollar levels to be requested in
the budget and the total level of Full-time Equivalents (FTEs) to be made available for distribution. As such, high quality
site planning data are essential.
Priorities for budget formulation are guided by the Agency Strategic P lan. Output and outcome measures are defined
for a five year period. Program initiatives that help achieve strategic goals and emphasize emerging priorities are defined
annually through a series of executive level planning and decision meetings.
Budget requests, reflecting the Agency strategic plans approved initiatives and data in CERCLIS/W asteLAN, are
prepared and sent to the Administrator in June/July. The Administrator makes any changes to the budget requests and
passes them back to the program offices. The budget requests are revised and submitted to OMB in September. OMB
Change 5, FY 04/05 SPIM
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January 10,2005
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OSWER Directive 9200.3-14-1G-Q
makes any changes to the budget requests and passes them back to EPA in November/December, nine months prior to
the start of the budget FY. If the program offices do not agree with the budgets that are passed back from OMB, EPA
initiates an appeals process in December. In mid-January, EPA prepares and submits the President's budget request.
Generally, in the spring prior to the start of the FY, congressional hearings are held by appropriation committees on the
President's Budget and action is taken to enact appropriations by the start of the fiscal year.
b. Budget Review and Planning (Planning Year)
The second phase of the budgeting process involves revising the budget to the extent possible and determining the
allocation of funds for the regions for the upcoming fiscal year.
In the third quarter, HQ prepares the preliminary regional operating plan based on the President's budget request
to Congress. In addition, program goals and priorities are first reviewed with the Administrator and then presented to
the Regional Administrators. In some years, the appropriation is not enacted by the start of the fiscal year, and Congress
passes a Continuing Resolution to fund the government until a final appropriation is enacted. Any increases, reductions
or mandated redirections are reflected in the Agency's operating plan (generally 60 to 90 days after enactment of
appropriations). In the fourth quarter, HQ reviews and analyzes regional planned financial information from
CERCLIS/WasteLAN and discusses the proposed operating plan with the regions during the annual work planning
sessions.
c. Budget Execution (Current Year)
Once the fiscal year begins and the appropriation is made, an operating plan is submitted to Congress for approval
and a portion of the operating plan is allocated to the regions through advises of allowance (AOA).
Exhibit III. 1 provides a timeline of the FY 04, FY 05, and FY 06 budget/financial activities. Timing for some activities
is dependent on the completion of other actions; e.g., on occasion Congress does not pass an appropriation by the
beginning of the fiscal year. The first quarter AOA is not issued until there is an appropriation and the Interim Operating
Plan is loaded in the Agency's Budget Automated System. In recent years this has occurred as late as February.
April 7, 2003
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT III-l
BUDGET TIMELINE*
Month, Year
Outyear Budget
(FY 06)
Planning Year Budget
(FY 05)
Current Year Budget
(FY 04)
October 2003
Revision to the Agency
Strategic Plan begins.
Congress appropriates dollars
to the Agency in the form of
an annual appropriation or
continuing resolution.
EPA submits Agency
Operating Plan to Congress
for approval
AA SWER and OC approve
allocation of the first and
second quarter portion of the
AOA for the response budget
AA OECA and OC approve
allocation of the initial
technical enforcement AOA
and the full year AOA for the
legal case budget
November
2003
~ OMB passback of
budget request
December 2003
~ HQ appeal of the OMB
budget passback
December 31 is the end of
the first quarter.
January 2004
~ President's Budget
submitted to C ongress
March 2004
~ Congressional
Appropriation Hearing
on President's Budget
Agency typically has
determined how to allocate
prior year carryover.
Operating plan typically has
been enacted and loaded
into IFMS which becomes
opened to reprogrammings.
Third quarter response
AOAs and remaining
enforcement AOA
calculated
~ March 31 is the end of the
2nd quarter.
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OSWER Directive 9200.3-14-1G-Q
Month, Year
Outyear Budget
(FY 06)
Planning Year Budget
(FY 05)
Current Year Budget
(FY 04)
April 2004
~ Annual Planning
Meeting for FY06 held
HQ prepares
preliminary regional
operating plan
Mid-year assessment held to
evaluate utilization of
regional programmatic
budgets
AA SWER and OC approve
third quarter AOA for
response
AA OECA and OC approve
final planned AOA for
enforcement
HQ summarizes resource
distribution by function and
statutes
May 2004
~ Regions generate their
plan
Meeting with the
Administrator to review
program goals
June 2004
~ HQ pulls financial
planning information
from CERCLIS
Investments presented
to the Administrator/
Regional
Administrators
Administrator and OC
provide policy for
budget formulation
~ Regions generate their
plan. HQ pulls financial
planning information
from
CERCLI S/WasteLAN
Goals and priorities
presented to the
Administrator/Regional
Administrators
Fourth quarter response
AOAs calculated
June is the end of the 3rd
quarter.
July 2004
~ Superfund investment
summaries submitted
to the Administrator
and budget proposal to
OC
Presentation made to
Administrate r/Deputy
Administrator (DA) on
program priorities
Administrator
passback
~ HQ reviews and
analyzes regional
budget request
AA SWER and OC approve
fourth quarter response
AOAs
HQ pulls
target/accomplishment and
financial data from
CERCLIS/WasteLAN for
analysis of regional
oblig ation/c ommitment rate
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OSWER Directive 9200.3-14-1G-Q
Month, Year
Outyear Budget
(FY 06)
Planning Year Budget
(FY 05)
Current Year Budget
(FY 04)
August 2004
~ HQ pulls data from
CERCLIS for the
development of the
budget for submission
to OMB
HQ develops strategy
for presenting the
budget to OMB
HQ submits budget to
OMB
HQ/regional work
planning sessions held
to establish mid-year
and end-of-year
budget/targets and
operating plan (maybe
held off until first
quarter time frame).
HQ continues to pull
target/accomplishment and
financial data from
CERCLIS/WasteLAN for
analysis of regional
oblig ation/c omm itment ra te
September
2004
First and second quarter
AOA calculated
HQ continues to pull
target/accomplishment and
financial data from
CERCLIS/WasteLAN for
analysis of regional
oblig ation/c omm itment rate
~ September 30 is the end of
the 4th quarter and end of the
fiscal year.
* Reprogramming does not take place until the Agency has an operating plan enacted by Congress.
III.B.2 Budget Structure
Program Results Code (PRC) and National Program Managers (NPM)
Note: At the time this chapter was written, the Agency's Strategic Plan was in the process of being revised to adopt a
new five goal structure. In FY 04, the PRCs will be changed to reflect the new five goal structure. This chapter will be
revised once the changes to the budget structure are known.
The Agency's budget structure is designed to reflect the Agency's Strategic Plan and annual commitment made
under the Government Performance and Results Act (GPRA). Resources for Superfund cleanup and response activities
and the civil enforcement program are primarily found under Goal 5, objective 01, and are divided across several
subobjectives (primarily 02 for response and Federal facilities response and 03 for enforcement). The Program Results
code (PRC) is the account number for the program field and is structured so it identifies the goal, objective, sub-objective
and National Program Manager (NPM) associated with those resources. The NPM identifier is an alpha character used
in the 6th position of the PRC. For instance, common NPMs for Superfund are "D" for OSWER and "E" for OECA.
In addition, the Response Program includes a special tracking code, also referred to as an AOA code to identify each
allowance, e.g., Removal, Remedial, Pipeline and Federal Facility Response.
It is important to distinguish among Superfund resources because Congress establishes Superfund spending caps in
the appropriations report language. These spending caps are referred to as functions. Functions are currently defined
as 1) Response, 2) Enforcement, 3) Management and Support. Exhibit III.2 shows PRC s that support key program areas.
The exhibit also identifies the special tracking codes of the Advices of Allowance (AOA) that the Response program uses
to allocate resources to the Regions. See Section III.C.2.
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OSWER Directive 9200.3-14-1G-Q
Exhibit III-2
Program Results Code (PRC)
Program
Program Results
Code
Special Tracking Code
(AOA Code)
Response Program
Remedial Action
302DD2
R
Pipeline Operations
302DD2
P
Removal
Removal Actions
302DC6
E
Removal Support
302DC6
S
Flomeland Security
302D72
C
Federal Facility Response
302DC9
F
BRAC (non-site)
302D41
none
BRAC (site-specific)
302D41B4
none
Enforcement - Technical and Legal
302EC7
none
Federal Facility Enforcement
302EH2
none
For further discussion on Superfund accounting information, please see section III.D.2 in this chapter.
III.B.3 FY04/05 Superfund Program Goals and Priorities
The FY04/05 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 Program
Budget addresses a different set of goals and priorities to achieve these aims.
Please note OSWER has undergone reorganization shifting Homeland Security and Removal functions to a new
program budget under OEPPR.
a. Response Program Budget (302DD2)
The response program budget provides funds for:
Site assessment and listing the highest risk sites on the NPL;
~ Fund-financed Remediallnvestigation/Feasibility Study (RI/FS),RemedialDesign(RD), and Remedial Action (RA)
projects;
Oversight of all RP-lead RI/FS, RD, RA, and removal projects;
Post Construction activities including Five-Year Reviews;
Core Program cooperative agreements which assist states and tribes in developing infrastructure to support the
federal Superfund program.
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Support activities, such as laboratory support;
Community involvement;
Support for redevelopment and reuse of Superfund sites after cleanup;
~ Information management/data quality;
NewNon-time critical (NTC) removal actions above base removal budget;
b. Homeland Security and Removal (302DC61/302D72)
~ Emergency and time critical removal actions to address the region's highest priority response actions at NPL and
non-NPL sites to ensure that worst sites are being addressed first; and
Homeland security readiness and response.
The first priorities for response funding are classic emergencies and activities at sites that will be used to meet the
national construction completion goals. Ongoing RAs, mixed funding, and mixed work projects receive priority for
funding over new cleanup work. New Fund-financed cleanup work (with the exception of emergency and time-critical
removal actions) will be subject to priority ranking by the National Risk-Based Priority Panel and will be screened to
ensure actions have been taken to compel all appropriate PRPs to conduct the cleanup. The Panel consists of
representatives from each region and HQ (OSRTI and OSRE) and utilizes a risk-based environmental priority setting
approach. New cleanup work is funded based on actual or potential risks to human health and the environment as well
as the need to maintain construction progress. Determination on whether a project represents new or existing work will
be made by the Panel. New cleanup work consists of large removal actions that exceed funding levels available within
a region's baseline removal budget, as well as cleanup activities at sites where no previous actions have taken place. The
panel meets one or more times a year for evaluation of projects.
c. Enforcement Budget (302EC7)
The enforcement budget is a combination of technical enforcement and legal enforcement resources. Both are
funded under the OECA NPM. The enforcement case budget, both technical and legal, provides support for
accomplishing goals and priorities, including:
Addressing all cost recovery cases with total outstanding costs greater than $200,000 for SOLs that may expire
during or within six months of the budget year;
Issuing of oversight bills in a timely fashion;
Timely collection of Superfund accounts receivable;
Focusing on collection of outstanding monies due to the Fund;
Enhanced PRP searches (including those that support removal actions, orphan share determinations and de minimis
settlements);
Timely negotiations of PRP response actions;
Maintaining ongoing litigation for response and cost recovery;
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OSWER Directive 9200.3-14-1G-Q
Ensuring PRP compliance with all work and cost recovery settlements;
Settlements with de minimis parties and municipalities;
Orphan share determinations/offers; and
Issuing UAOs to the "largest manageable" number of PRPs.
d. Federal Facilities Response Budget (302DC9)
The Federal facilities response budget provides support for response work at all NPL Federal facilities.
The following activities are priorities:
Involving communities in the cleanup decision process;
Maintaining ongoing oversight activities; and
Expediting response where possible.
Extramural funds can be used for Base Realignment and Closure sites where oversight is needed.
e. Base Realignment and Closure (302D41 and 302D41B4)
The BRAC budget, with reimbursable resources coming from DoD, supports EPA's participation in expediting the
disposal and restoration of closing military bases to safe and productive reuse as quickly as possible while fulfilling its
mandate to protect human health and the environment. BRAC activities:
Promoting community involvement
Expediting environmental restoration and property transfer
Providing oversight and technical assistance
Supporting up-front planning and scoping
Maintaining remedies that protect human health and the environment
f Federal Facilities Enforcement Budget (302EH2)
The Federal facilities enforcement budget (50104E) provides support for Federal Facility Agreement (FFA) (also
known as Interagency Agreement (IAG)) negotiation activities as well as activities that ensure compliance with the FFA s.
Specifically, 50104E provides support for:
Negotiating FFAs /IAGs with Federal facilities listed on the NPL;
Negotiating FFA/IAG amendments;
Monitoring milestones and conducting oversight of all enforceable requirements to ensure proper
implementation of signed FFA/IAG,
Dispute resolution activities (as defined within each FFA) during FFA negotiations.
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III.C. REGIONAL OPERATING PLAN AND ADVICE OF ALLOWANCE
DEVELOPMENT
III.C.1 Allocating Superfund Resources Among the Regions
Superfund appropriation resources are primarily classified into three functional categories based on congressional
direction: Response, Enforcement, and Management and Support. Within these functions, several National Program
Managers and their Offices have responsibility for managing and allocating the Superfund appropriation resources.
W ithin the Response function, this manual focuses on the allocation of regional extramural resources for the Superfund
Remedial Response, Federal Facilities Response, and Elomeland Security/Emergency Response programs. Within the
Enforcement function, this manual applies to the extramural resources associated with the Superfund Enforcement and
Federal Facilities Enforcement programs. This manual does not discuss Superfund appropriation resources related to
the Management and Support function.
Each Superfund program addressed here has specific procedures for allocating extramural resources among the
Regions, using Advices of Allowance (AOAs) to control and track resource use. Within each AOA, Regions are required
to plan obligations in CERCLIS/WasteLAN. Obligations and expenditures are also tracked by AOA through the
Integrated Financial Management System (IFMS) accounting code structure.
The Superfund Comprehensive Accomplishments Plan (SCAP) refers to both the annual work planning process for
projecting accomplishments for a subject fiscal year and for the accomplishment reporting mechanism. Within the SCAP
process, Regions plan obligations either site-, project-, OU-, or non-site specifically within each AOA. 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., contract bulk funding). The CERCLIS/WasteLAN database has been
designed to accommodate site- and non-site specific planning, although Regions should plan obligations site-specifically
to the maximum extent practicable. Regions should also be certain all their extramural funding needs are reflected in
CERCLIS/WasteLAN and correspond with the appropriate program AOA.
Regions are responsible for managing the funds issued in each AOA, and for operating within budget ceilings, floors,
and other restrictions, and may not shift among functions (Response, Enforcement, and Management and Support). To
the extent practicable, the regional budget for each AOA must balance at all times with the sum of actual obligations,
open commitments to date, and remaining planned approved (discussed below) obligations. Planned and actual
obligations of funds recertified to the Regions should be included in the "approved" regional budget. Regions should
also enter planned obligations in CERCLIS/WasteLAN forreimbusable account resources (i.e., settlement and State cost
share resources) as "approved," using the appropriate AOA codes.
Generally, funds may be shifted within a function between programmatic and administrative budget object classes
(BOCs) and may be reprogrammed between Allowance Holders and/or Regions as long as they remain within the
designated function. In all cases, the Region must update CERCLIS/WasteLAN whenever funds are
redirected/reprogrammed from their planned use. Headquarters must approve in advance the reprogramming of any
resources among AOAs.
The Headquarters program offices regularly review IFMS obligations against the AOAs. During the last quarter of
the year, OSWER and OECA will work with the Regions as necessary to ensure that all AOAs and obligations are
aligned prior to year-end closing.
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OSWER Directive 9200.3-14-1G-Q
III.C.2 Remedial Response Program Budget
The Remedial Response program budget includes two AOAs, Remedial Action and Pipeline Operations, which are
managed by the Office of Superfund Remediation and Technology Innovation (OSRTI). Each year, Headquarters
determines the amount of resources to allocate these AOAs based on the process for developing the Agency's annual
Operating Plan.
III.C.2.a. Remedial Action AOA
Regions are required to enter all planned obligations site-specifically in CERCLIS/WasteLAN within the Remedial
Action AOA (AOA account code R), which includes remedial actions, long-term response actions, five-year reviews,
and non-time-critical removals at NPL sites. The funding status of all planned obligations initially must be designated
as "alternate" in the Remedial Action AOA in CERCLIS/WasteLAN.
Through the annual work planning pro cess, OSRTI will develop a Remedial Action AOA funding plan using planned
obligation data from CERCLIS/WasteLAN, projections of the availability of funds, and National Risk-Based Priority
Panel project rankings. Once OSRTI issues its initial funding plan, Regions must switch the funding status designation
in CERCLIS/WasteLAN from "alternate" to "approved" for the selected site-specific obligations. Planned obligations
of funds that are recertified to a Region in the Remedial Action AOA should also be designated as "approved." Those
planned obligations that maintain the "alternate" designation should include only the activities the Region would conduct
if additional resources become available and will form the basis for additional funding decisions. During the course of
the year, Regions must continuously update planned "alternate" obligations to accurately reflect the current year's
additional funding needs.
Once an appropriation is enacted, Headquarters will allocate, pursuant to the Agency Interim and Final Operating
Plans, funds to the Regions based on the OSRTI Remedial Action AOA funding plan. Regions are required to obtain
OSRTI approval of any proposed changes to the funding plan greater than $100,000, (e.g., shift resources among sites
or activities within the Remedial Action AOA) and record all changes to planned obligations in CERCLIS/WasteLAN.
If the fiscal year begins without an enacted appropriation, Headquarters will allocate available resources to each Region
on a case-specific basis until an appropriation is enacted and the Operating Plan is approved.
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 Remedial Action AOA resources. Based on mid-year regional reviews, OSRTI will
update the Remedial Action AOA funding plan to reflect changes in Regions' resource needs as well as additional
resourcesthat may be come available (e.g., through deobligations). However, on a case-specific basis, OSRTI also may
issue additional resources to a Region or allow it to use existing resources for work that is not included in the funding
plan. Unless otherwise directed by OSRTI, and except for deviations of $100,000 or less, Regions are required to return
to Headquarters, through the reprogramming process, allocated resources that will not be used according to the funding
plan. 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 Remedial Action AOA without prior OSRTI approval.
III.C.2.b. Pipeline Operations AOA
The Pipeline Operations AOA (AOA account code P) is distributed among the Regions based on the Pipeline
Allocation Model. A portion of the allocation is based on historical allocations and the remaining portion is based on
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 AOA. Using
this information, each Region will develop its Pipeline Operations AOA portion of its program operating plan and enter
its planned obligations and accomplishments into CERCLIS/W asteLAN. Pursuant to work planning discussions with
Headquarters and refined resource allocation projections based on the Pipeline Allocation Model, Regions will finalize
their program operating plans in CERCLI S/WasteL AN. OSRTI will then finalize the Pipeline Operation AOA allocation
using the Pipeline Allocation Model.
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OSWER Directive 9200.3-14-1G-Q
Planned obligations for regional activities within this AOA must fall within the total identified level, and should be
shown in CERCLIS/WasteLAN by selecting "approved" from the Funding Status drop down list associated with the
appropriate AOA category on the Budget Allowance Detail Backup screen. Funding needs above the Headquarters
proposed total budget level must be designated as "alternate."
At the beginning of the fiscal year Headquarters will issue 60% of the Pipeline Operations AOA among the Regions.
Headquarters will issue 20% of the AOA at the beginning of each of the 3rd and 4th quarters. If a Region's
commitment/obligation rate is less than 50% at the end of the second quarter, Headquarters may delay the remaining
allocation to the Region and renegotiate the Region's program operating plan 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, Headquarters will
allocate an equivalent share ofthe available resources to each Region until an appropriation is enacted and the Operating
Plan is approved. Funds from the Pipeline Operations AOA may not be moved to any other AOA without prior OSRTI
approval.
III.C.3. Homeland Security/Removal Response Program Budget
The Homeland Security/Removal response program budget is newly created for FY 2004. This budget has been
created as a result of increased emphasis on homeland security and a FY 2003 OSWER reorganization that shifted
responsibility for the removal program from OSRTI to the Office of Emergency Preparedness, Prevention and Response
(OEPPR). During FY 2003, two AOAs separately addressed homeland security (AOA account code C) and removal
(AOA account code E) within CEPPO, now OEPPR, and OERR, now OSRTI, respectively. The structure of the new
budget and the SCAP process associated with it is currently under development. This section of the SPIM will
be revised once the process for this budget is complete.
III.C.4 Federal Facilities Superfund Response Program Budget
In FY 2005, an 'A' allowance was established in IFMS for Federal Facilities Superfund response extramural
resources. Under the 'A' allowance (e.g., 1A00F = Region l's Federal Facility extramural resources) each Region will
receive 50% of its portion of the approved budget request during the first quarter, provided that the Agency has an
enacted budget, and the remainder during the third quarter. Regional Federal Facilities Superfund Response budgets are
determined during the annual workplanning sessions. If a Region has a low obligation rate, discussions will be held prior
to third quarter distribution as to whether there is a need for the remainder of the funds. To request additional funds, a
Region should contact FFRRO. Please include the amount needed and a justification for the funds.
Funds may be redirected within the Federal Facilities AOA to other BOCs and to other Regions or Headquarters
offices, but may not be moved out of the Federal Facilities AOA without FFRRO's prior approval.
III.C.4.a Base Realignment and Closure (BRAC) Budget
Base Realignment and Closure Resources - To assist the Department of Defense (DoD) with cleaning up and
transferring selected BRAC properties, DoD provides dollars to EPA to cover the cost for those employees working in
the BRAC program. Once DoD receives transfer authority, the U.S. Army transfers half ofthe BRAC allocation to EPA
via a Military Interdepartmental Purchase Request (MIPR). Once a fully executed Interagency Agreement (IAG) has
been processed by Headquarters Grants Administration Division, resources are distributed via a reprogramming to the
various Allowance Holders. Although resources are not loaded into IFMS on an installation-specific basis, DoD's
funding notification letter indicates the FTE ceiling for each installation. To increase or decrease the funding level for
any BRAC installation, regions must receive prior approval from Headquarters.
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OSWER Directive 9200.3-14-1G-Q
III.C.5 Enforcement Program Budget
The Enforcement program budget includes two components, technical and legal, which are managed by the Office
of Site Remediation Enforcement. No account code for the AOA currently exists. 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 year) for enforcement activities. Headquarters allocates 70% 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
Phase 1 and 2 Operating Plan. This initial allocation will be made available in the Interim Operating Plan for spending
as soon as the appropriation is passed by Congress and signed by the President.
An additional allocation will be made in the third quarter of the fiscal year for technical enforcement. OSRE will
issue a call to the Regions in early March 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 funding not previously
allocated, 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 around the beginning of May.
The legal enforcement budget is allocated equally between all ten Regions and made fully available in the Interim
Operating Plan. Funds must not move into or out of the Enforcement function without Congressional approval. Funds
may be redirected within the Enforcement AOA to other BOCs and to other Regions or Headquarters offices.
III.C.6 Federal Facilities Enforcement Program Budget
The Federal Facilities Enforcement program budget consists of two components, an EPM appropriation and a
Superfund appropriation, which are managed by the Federal Facilities Enforcement Office. No account code for the
AOA currently exists. Atthe beginning ofthe fiscal year, FFEO informs the regional Federal Facility Program Managers
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 Headquarters.
Funds may not move into or out of the Enforcement function without Congressional approval. Funds may be
redirected within the Federal Facility Enforcement AOA to other BOCs and to other Regions or Headquarters offices.
IIIC.7 Deobligating Prior Year Funds
Another potential source of funding are obligations made in prior years where all payments have been made, the
obligation is inactive, and there remains an unliquidated balance. Once it has been determined by the appropriate official
that the unliquidated obligation is not needed, that amount may be deobligated. As a no-year appropriation, Superfund
dollars which are obligated before the end of a given fiscal year and deobligated in a subsequent year may be recovered
by the Agency and obligated again in that same year. These funds are reapportioned to the Agency by OMB and reissued
to the Allowance Holders through a process called recertification. All recertified funds must be obligated within the
fiscal year of deobligation.
Each year, the Annual Planning and Budget Division in the Office of the Chief Financial Officer along with OSRTI,
OECA, and OEPPR jointly issues the Superfund Deobligation Guidance with OSRE. It explains the general procedures
for deobligation of funds and the specific procedures as required by the National Program Manager (NPM) for the
recertification of funds.
The deobligation of prior year funds is a good fiscal management practice and one which helps offset shortfalls in
the Superfund budget. Regions should actively pursue deobligation of prior year funds. Projects prime for deobligation
include Interagency Agreements (IAGs) with the U.S. Army Corps of Engineers (USACE) where the projects have been
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completed, Fund-lead RAs taken over by the PRPs, and Fund-lead RAs where the actual construction contract award and
oversight costs will be significantly less than the funds obligated. Expired contract are another prime course of funds
available for deobligation. Regions may request that their share of deobligated funds be recertified and returned to the
Region to address priority needs. Eleadquarters will work with the OCFO to ensure that any funds deobligated are
returned to the Region through the recertification process following the guidelines established in the Superfund
Deobligation Policy.
III.C.8 Budget Object Classes
Resources are used for funding programmatic needs and are divided into several different budget object classes
(BOCs). This includes Programmatic Contracts and Interagency Agreements (IAGs) -BOC 37; Grants and Cooperative
Agreements - BOC 41; and Programmatic expenses - BOC 36. In addition, Site-Specific Travel - BOC 28 is also funded
using programmatic dollars.
Site-specific travel is traditionally managed as an administrative expense, but in the Superfund budget structure, site-
specific travel is considered a programmatic expense. As such, program dollars can be used to fund site-specific travel.
Regions can use up to $150,000 or 0.5% (whichever is greater) of their Pipeline Operations AO A to support site-specific
travel. Regions need to prioritize their program funding needs since dollars for site-specific travel must come out of the
regional programmatic budget allocation. Funds may be reprogrammed between object classes without Headquarters
approval. Headquarters will not increase a Region's budget or AO A to replace extramural funds used for site-specific
travel.
IH.C.9 Regional Change Requests for Reprogramming Among AOAs
In some situations, a reprogramming is required as a result of regional changes to the SCAP. Exhibit III .4 identifies
flexible funding and other situations where an AOA change request is required. Headquarters will not approve a change
request unless CERCLIS/WasteLAN is revised to reflect the change. Regions should submit all change requests to the
appropriate OSWER or OECA contact via e-mail. The following information should be provided for a change request:
Purpose/justification;
Amount;
Site name and Site Spill Identification (SSID) if the AOA is issued site-specifically;
Program Results Codes; and
Allowance that is being increased and/or allowance that is being decreased.
If the change request is a reprogramming of funds between AOAs, the net change should equal zero. The change
request must be transmitted by authorized personnel in the Region's financial office. The site-specific record in
CERCLIS/WasteLAN should be revised when the change request is transmitted. Regions should not initiate any
obligations against the change until the OC and OSWER or OECA approve the revised AOA. Change requests generally
take two weeks to process and approve. There is a $500,000 limit for reprogramming between program results codes
(per action), and the request must be approved by the OC.
III.C.10 Budget Sources and Associated Action Codes
Exhibit III.6 identifies the major actions and the appropriate budget source (depending on the project/action lead)
for planned obligations, as well as the AOA category under which each action falls. Because of the recent creation
of the Homeland Security (counter-terrorism) AOA and due to the recent reorganization of management
responsibility of the removal program from OSRTI to OEPPR, the Budget Sources for action codes associated
with Homeland Security/Removal program will be revised during FY 2004. Until these revisions are issued,
Regions should use the most appropriate action codes for the costs of activities conducted within the Homeland
Security and Removal AOAs (AOA account codes C and E, respectively).
Change 5, FY 04/05 SPIM
III-13
January 10,2005
-------
OSWER Directive 9200.3-14-1G-Q
Disclaimer:
The Who Pays for What chart is valid for FY04. The new Action Codes for Financial Transactions chart will take effect
in FY05.
EXHIBIT III-3
WHO PAYS FOR WHAT FY 04
For FY 05 see Exhibit III-4
CERCLIS/WasteLAN ACTION NAME
ACTION
CODE
SITE
DESIGNATION
LEAD
BUDGET SOURCE/
AOA CATEGORY
Administrative Records
AR
S
CG. EP. F. S. TR
FF
FE. SE
Pipeline Operations
Federal Facility Response
Enforcement
Aerial Survey
AS
R
CG. EP. F. S. TR. RP.
PS. MR
FF
Pipeline Operations,
Removal
Federal Facility Response
Alternative Dispute Resolution
AD
B
CG. TR. F. PS. S. EP.
SE. FE
Pipeline Operations
Enforcement
Bulk Funding (outlays must not be charged to
the WQ code, and with the exception of Core
Program funding, outlays must be action-and
site-specific)
WQ
R
(with exception
for core program
funding)
F
FF
FE
Pipeline Operations
Federal Facility Response
Enforcement
Claim in Bankruptcy Proceedings
CB
S
FE
Enforcement
Combined RI/FS
CO
S
F. S. TR SA. SS. ST.
EP
Pipeline Operations
Combined PA/SI
Deleted - Use Generic PA/SI (QB)
NX
Community Involvement (non-federal facility)
CR
s
* Regions may plan
using 'WO'butmust
obligate site-
specifically.
EP. F. S. TR. RP. PS.
MR
Pipeline Operations
Compliance Enforcement
uz
s
FE. SE
Enforcement
Contract Management
JU
B
F
FE
FF
Pipeline Operations
Enforcement
Federal Facility Response
Contract Program Management
(Administrative) Deleted - Use Contract
Management (JU)
QC
Cost Recovery Negotiation
NE
S
FE. SE
Enforcement
Cost Recovery Decision Document
Deleted - Use NPL PRP Search (NS) or Non-
NPL PRP Search (RP)
DD
January 10,2005
III-14
Change 5, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
EXHIBIT III-3
WHO PAYS FOR WHAT FY 04
For FY 05 see Exhibit III-4
CERCLIS/WasteLAN ACTION NAME
ACTION
CODE
SITE
DESIGNATION
LEAD
BUDGET SOURCE/
AOA CATEGORY
Deletion from NPL
Deleted - Use Administrative Records (AR)
ND
Design Assistance
DA
S
EP. F. S. TR. RP. PS.
MR
FF
Pipeline Operations
Federal Facility Response
Ecological Risk Assessment
Deleted - Use Risk Assessment (ED)
JF
Enforcement Contract Management
Deleted - Use Contract Management (JU)
TM
Engineering Evaluation/Cost Analysis
EE
S
CG. EP. F. S. TR. RP.
PS. MR. SA. SS. ST
FF
Pipeline Operations
Federal Facility Response
ESI/RI
SS
s
EP. F. S. TR
FF
Pipeline Operations
Federal Facility Response
ESI (Expanded Site Inspection)
ES
s
EP. F. S. TR
Pipeline Operations
Feasibility Study
FS
s
EP. F. S. TR. SA. SS.
ST
Pipeline Operations
Federal Facility and BRAC General Support
and Management
TX
N
FF
Federal Facility Response
Federal Facility Docket
Deleted - Use Records Management (SW)
GA
FF FS
Deleted - Use FF Oversight (OX)
NI
FF Oversight
OX
s
* Regions may plan
using 'WO'butmust
obligate site-
specifically.
FF
Federal Facility Response
FF ESI Review
TZ
R
EP. F. S. TR
FF
Pipeline Operations
Federal Facility Response
FF Community Involvement
LZ
S
FF
Federal Facility Response
FF PA Review
RX
R
EP. F. S. TR
FF
Pipeline Operations
Federal Facility Response
FF RD
Deleted - Use FF Oversight (OX)
LX
Change 5, FY 04/05 SPIM
III-15
January 10,2005
-------
OSWER Directive 9200.3-14-1G-Q
EXHIBIT III-3
WHO PAYS FOR WHAT FY 04
For FY 05 see Exhibit III-4
CERCLIS/WasteLAN ACTION NAME
ACTION
CODE
SITE
DESIGNATION
LEAD
BUDGET SOURCE/
AOA CATEGORY
FF Removal
Deleted - Use FF Oversight (OX)
LV
FF RI
Deleted - Use FF Oversight (OX)
NH
FF RFFS
Deleted - Use FF Oversight (OX)
LW
FF SI Review
TY
R
EP. F. S. TR
FF
Pipeline Operations
Federal Facility Response
FF RA
Deleted - Use FF Oversight (OX)
LY
Final Listing on NPL
Deleted - Use Administrative Records (AR)
NF
Five Year Review
(Regions may bulk fund this action using the 'FE'
action code and the 'WQ' SSID, but outlays must be
site-spe cific.)
FE
S
EP. F. S. TR
RP. PS
FF
Remedial Action
Pipeline Operations
Federal Facility Response
Forward Planning /Redevelopment/Reuse
FM
S
F
Pipeline Operations
General Enforcement
GE
N
FE
Enforcement
Federal Facility
Enforcement
General Support and Management
BM
N
F
Pipeline Operations.
Removal
Generic PASI
QB
R
EP. F. S. TR
FF
Pipeline Operations
Federal Facility Response
Groundwater
Monitoring - Post ROD
GM
S
EP. F. S. TR. RP. PS.
MR
FF
Pipeline Operations
Federal Facility Response
Health Assessment
Deleted - Use Risk Assessment (ED)
HA
HRS Package
HR
S
EP. F. S. TR
Pipeline Operations
IAG Negotiation
Deleted - Use Negotiation - Generic (NG)
IN
Information Mgt Support
IJ
B
F
FE
FF
Pipeline Operations
Enforcement
Federal Facility Response
January 10,2005
III-16
Change 5, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
EXHIBIT III-3
WHO PAYS FOR WHAT FY 04
For FY 05 see Exhibit III-4
CERCLIS/WasteLAN ACTION NAME
ACTION
CODE
SITE
DESIGNATION
LEAD
BUDGET SOURCE/
AOA CATEGORY
Integrated Assessment
EA
R
EP. F. S. TR
FF
Pipeline Operations
Federal Facility Response
Integrated Assessment Combined PASI
Deleted - Use Generic PA/SI (QB)
OU
Integrated Assessment ESI
Deleted - Use Generic PA/SI (QB)
OY
Integrated Assessment ES1/RI
Deleted - Use Generic PA/SI (QB)
OV
Integrated Assessment HRS Package
Deleted - Use Generic PA/SA (QB)
OZ
Integrated Assessment PA
Deleted - Use Generic PA/SI (QB)
PX
Integrated Assessment SI
Deleted - Use Generic PA/SI (QB)
QJ
Laboratory Support
LA
B
F
FE
FF
Pipeline Operations
Enforcement
Federal Facility Response
Litigation - Generic
LT
S
FE. SE
Enforcement
Local Government Reimbursement
EV
S
F
Pipeline Operations
Long Term Response Action (LTRA)
LR
s
EP. F. S. TR. SA SS.
ST
Remedial Action
Management Assistance - Deleted - LTse State
Agency Support Cooperative Agreement
MA
Multi-Site Cooperative Agreement
Deleted - LTse State Support Agency
Cooperative Agreement (MA), Generic PASI
(QB), or Bulk Funding (WQ) as appropriate
MS
Negotiation - Generic
NG
s
FE. SE
Enforcement.
Federal Facility
Enforcement
Non-NPL PRP Search
RP
R
FE. SE
Enforcement
NPL RP Search
NS
s
FE. SE
Enforcement
Operations and Maintenance (for EPA-
conducted O & M, only reimburseable
resources may be used)
OM
s
RP. PS. MR. SS
FF
Pipeline Operations
Federal Facility Response
Change 5, FY 04/05 SPIM
III-17
January 10,2005
-------
OSWER Directive 9200.3-14-1G-Q
EXHIBIT III-3
WHO PAYS FOR WHAT FY 04
For FY 05 see Exhibit III-4
CERCLIS/WasteLAN ACTION NAME
ACTION
CODE
SITE
DESIGNATION
LEAD
BUDGET SOURCE/
AOA CATEGORY
PA (Preliminary Assessment)
PA
R
EP. F. S. TR
FF
Pipeline Operations
Federal Facility Response
Partial Deletion
Deleted - Use Administrative Records (AR)
GR
Pre-CERCLIS Screening
HX
R
F. S. TR
FF
Pipeline Operations
Federal Facility Response
Preparation of Cost Documentation
PC
S
FE. SE
Enforcement
Proposal to NPL
Deleted - Use Administrative Records (AR)
NP
PPA Assessments
QX
S
FE
Enforcement
PRPFS
NK
s
RP. PS. MR
Pipeline Operations
PRP LR
ME
s
RP. PS. MR
Pipeline Operations
PRP RA
BF
s
RP. PS. MR
Pipeline Operations
PRP RD
BE
s
RP. PS. MR
Pipeline Operations
PRP Removal
BB
s
RP. PS. MR
Removal
PRP RI
NA
s
RP. PS. MR
Pipeline Operations
PRP RI/FS
BD
s
RP. PS. MR
Pipeline Operations
PRP Community Involvement
Deleted - Use Community Involvement (CR)
EL
RCRA Facility Assessment
Deleted - Use Generic PA/SI (QB)
AA
RD/RA Negotiation
AN
s
FE. SE
Enforcement
Real Property Acquisition
RL
s
F. S. TR
Pipeline Operations
Records Management
SW
B
F
FE
FF
Pipeline Operations
Enforcement.
Federal Facility
Enforcement
Federal Facility Response
Remedial Action
RA
s
EP. F. S. TR. SA. SS.
ST
Remedial Action
Remedial Community Involvement Deleted -
use Community Involvement (CR)
CR
January 10,2005
III-18
Change 5, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
EXHIBIT III-3
WHO PAYS FOR WHAT FY 04
For FY 05 see Exhibit III-4
CERCLIS/WasteLAN ACTION NAME
ACTION
CODE
SITE
DESIGNATION
LEAD
BUDGET SOURCE/
AOA CATEGORY
Remedial Contract Management
Deleted - use Contract Management (JU)
JU
Remedial Support and Management
Deleted - Use General Support Management
(BM)
BO
Remedial Design
RD
S
EP. F. S. TR. SA. SS.
ST
Pipeline Operations
Remedial Investigation
RI
s
EP. F. S. TR. SA. SS.
ST
Pipeline Operations
Removal
RV
s
CG. EP. F. S. TR. SA.
SS. ST. SG
Removal
Removal Contract Management
Deleted- Use Contract Management (JU)
EZ
Removal Community Involvement
Deleted - Use Community Involvement (CR)
RC
Removal Support and Management
Deleted- Use General Support Management
(BM)
BN
Removal/Remedial Contract Management
Deleted- Use Contract Management (JU)
JT
Removal Negotiation
RN
s
FE
Enforcement
Removal Assessment
RS
R
CG. EP. F. S. TR. RP.
PS. MR
FF
Pipeline Operations.
Removal
Federal Facility Response
Removed from Proposed NPL
Deleted - Use Administrative Records (AR)
NR
Research & Development
BG
R
F. S. TR
Pipeline Operations
RI/FS Negotiation
FN
S
FE. SE
Enforcement
Risk Assessment/Health Assessment
ED
s
EP. F. S. TR. RP. PS.
MR
FF
Pipeline Operations
Federal Facility Response
Section 104(e) Ref Litigation (site access)
SF
s
FE. SE
Enforcement
Section 106 Litigation
SX
s
FE. SE
Enforcement
Section 106/107 Litigation
CL
s
FE. SE
Enforcement
Section 107 Litigation
sv
s
FE. SE
Enforcement
Change 5, FY 04/05 SPIM
III-19
January 10,2005
-------
OSWER Directive 9200.3-14-1G-Q
EXHIBIT III-3
WHO PAYS FOR WHAT FY 04
For FY 05 see Exhibit III-4
CERCLIS/WasteLAN ACTION NAME
ACTION
CODE
SITE
DESIGNATION
LEAD
BUDGET SOURCE/
AOA CATEGORY
SEE Program
SM
B
F
FE
FF
Pipeline Operations
Enforcement
Federal Facility Response
SI (Site Inspection)
SI
R
EP. F. S. TR
FF
Pipeline Operations
Federal Facility Response
Site Security and Maintenance
PD
S
F. S. TR
Pipeline Operations
Site Reassessment
Deleted - Use Generic Site Assessment (QB)
OO
Site-Specific BRAC Costs
PX
S
FF
Federal Facility Response
State Support Agency Cooperative Agreement
(Management Assistance)
MA
R
F
FF
Pipeline Operations
Federal Facility Response
State Core Program
SK
N
F
Pipeline Operations
Technical Assistance Grant
TG
S
* Regions way
plan using WO'
but must obligate
site-specifically.
F
FF
Pipeline Operations
Federal Facility Response
Technical Assistance
TA
B
EP. F. S. TR. RP. PS.
MR
FF
Pipeline Operations
Federal Facility Response
Training
TH
N
F
FE
Pipeline Operations
Enforcement
Tribal Support Agency Cooperative Agreement
(Management Assistance)
TJ
R
F
FE
Pipeline Operations
Federal Facility Response
Tribal Core Program
TK
N
F
Pipeline Operations
January 10,2005
111-20
Change 5, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Key to Leads:
SD =
State Deferral
CG =
Coast Guard
SE =
State Enforcement
EP =
EPA IN-HOUSE
SG =
PRP-Financed Action From a Special
F =
EPA Fund- Financed
Account Performed by USCG
FE =
Federal Enforcement
SN =
State, no Fund money
FF =
Federal Facilities Response
SR =
PRP LEAD UNDER STATE
MR =
Mixed Funding Federal/RP
ss =
PRP-Financed Action From a Special
PS =
PRP Response under State
Account Performed by State
RP =
Responsible Party
ST =
PRP-Financed Action From a Special
S =
State. Fund Financed
Account Performed by Tribal
SA =
PRP-Financed Action From a Special
Government
Account Performed by EPA
TR =
Tribal Lead. Fund Financed
Key to Site Designation:
S =
Site-specific only
R =
Site-specific and site-related (ZZ) only
B =
Site-specific, site-related (ZZ), and non-site
N =
Non-site-specific only
Disclaimer:
The Who Pays for What chart is valid for FY04. The new Action Codes for Financial Transactions chart will take
effect in FY05.
EXHIBIT III-4
FY 2005 Action Codes for Financial Transactions
Sorted by CERCLIS Action Name
FY 2005 Superfund Extramural Action Codes to Be Used for Financial Transactions, Sorted by CERCLIS Action Name
Action Name
Action
PRC
AOA
Site Des.
Lead
Code
Administrative Records
AR
302DC6&
S
S
CG. F. S. TR
302DC9&
FF
S
FF
302DD2&
P
s
CG. F. S. TR
302EC7&
E
s
FE. SE
Aerial Survey
AS
302DC6&
S
S. WQ. ZZ
CG. F. S. TR RP. PS. MR
302DC9&
FF
S. WQ. ZZ
FF
302DD2&
P
S. WQ. ZZ
CG. F. S. TR RP. PS. MR
Alternative Dispute Resolution
AD
302DD2&
P
S. WQ. ZZ. 00
CG. F. S. TR. PS
302EC7&
E
S. WQ. ZZ. 00
FE. SE
Bulk Funding
WQ
302DC6&
S
S. WQ. ZZ
F
(Outlays must not be charged to the
302DC9&
FF
S. WQ. ZZ
FF
WQ code, and with the exception of
302DD2&
P
S. WQ. ZZ
F
Core Program funding, must be action-
302EC7&
E
S. WQ. ZZ
FE
and site-specific)
CERCLA Criminal Litigation
CC
302EC7&
E
E
HQ only may use 302EC7&
501E52&
E
S
Not in CERCLIS
Claim in Bankruptcy Proceedings
CB
302EC7&
E
S
FE
Combined PA/SI
NX
Not Available-LTse Generic PA/SI (QB)
Combined RI/FS
CO
302DD2&
P
S
F. S. TR. SA SS. ST
Community Involvement (Non-federal
CR
302DC6&
S
S
F. S. TR. RP. PS. MR
facility) (Regions may plan using the
302DD2&
P
S
F. S. TR. RP. PS. MR
"WQ" SSID but must obligate site-
specifically)
Compliance Enforcement
uz
302EC7&
E
S
FE. SE
Change 5, FY 04/05 SPIM
111-21
January 10,2005
-------
OSWER Directive 9200.3-14-1G-Q
EXHIBIT HI-4
FY 2005 Action Codes for Financial Transactions
Sorted by CERCLIS Action Name
FY 2005 Superfund Extramural Action Codes to Be Used for Financial Transactions, Sorted by CERCLIS Action Name
Action Name
Action
Code
PRC
AOA
Site Des.
Lead
Contract Management
JU
302DC6&
302DC9&
302DD2&
302EC7&
S
FF
P
E
S. WQ. ZZ. 00
S. WQ. ZZ. 00
S. WQ. ZZ. 00
S. WQ. ZZ. 00
F
FF
F
FE
Contract Program Management
(Admini strati ve)
QC
Not Available-Use Contract Management (JU)
Cost Recovery Decision Document
DD
Not Available-Use NPL PRP Search (NS) orNon-NPLPRP Search (RP)
Cost Recovery Negotiation
NE
302EC7&
E
S
FE. SE
Deletion from NPL
ND
Not Available-Use Administrative Records (AR)
Design Assistance
DA
302DC9&
302DD2&
FF
P
S
S
FF
F. S. TR. RP. PS. MR
Ecological Risk Assessment
JF
Not Available-Use Risk/Health Assessment (ED)
Enforcement Contract Management
TM
Not AvailableUse Contract Management (JU)
Engineering Evaluation/Cost Analysis
(EE/CA)
EE
302DC6&
302DC9&
302DD2&
S
FF
P
S
S
S
CG. F. S. TR. RP. PS. MR. SA
SS. ST
FF
CG. F. S. TR. RP. PS. MR. SA
SS. ST
ESI/RI
SS
302DD2&
P
s
F. S. TR
Expanded Site Inspection (ESI)
ES
302DD2&
P
s
F. S. TR
Feasibility Study
FS
302DD2&
P
s
F. S. TR. SA SS. ST
Federal Facility and BRAC General
Support and Management
TX
302DC9&
302D41&
FF
FF
00
00
FF
FF
FF Community Involvement
LZ
302DC9&
FF
s
FF
FF Docket
GA
Not Available-Use Records Management (SW)
FF ESI Review
TZ
302DC9&
FF
S. WQ. ZZ
F. S. TR
FF Five Year Review
VY
Not Available-Use FF Oversight (OX)
FF FS
NI
Not Available-Use FF Oversight (OX)
FF LR
MZ
Not Available-Use FF Oversight (OX)
FF Oversight
OX
302DC9&
FF
s
FF
FF PA Review
RX
302DC9&
FF
S. WQ. ZZ
F. S. TR
FF RA
LY
Not Available-Use FF Oversight (OX)
FF RD
LX
Not Available-Use FF Oversight (OX)
FF Removal
LV
Not Available-Use FF Oversight (OX)
FF RI
NH
Not Available-Use FF Oversight (OX)
FF RI/FS
LW
Not Available-Use FF Oversight (OX)
FF SI Review
TY
302DC9&
FF
S. WQ. ZZ
F. S. TR
Final listing on NPL
NF
Not Available-Use Administrative Records (AR)
Five-Year Review
(Regions may bulk fund this action
using the "FE" action code and the
"WQ" SSID, but outlays must be site-
specific)
FE
302DD2&
302DD2&
P
RA
S. WQ
S. WQ
RP. PS
F. S. TR
Forward Planning/ Redevelopment
Reuse
FM
302DD2&
P
S
F
General Support and Management
BM
302DC6&
302DD2&
S
P
00
00
F
F
January 10,2005
111-22
Change 5, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
EXHIBIT HI-4
FY 2005 Action Codes for Financial Transactions
Sorted by CERCLIS Action Name
FY 2005 Superfund Extramural Action Codes to Be Used for Financial Transactions, Sorted by CERCLIS Action Name
Action Name
Action
PRC
AOA
Site Des.
Lead
Code
General Enforcement
GE
302EH2&
FFE
00
FE
302EC7&
E
00
FE
Generic PA/SI
QB
302DC9&
FF
S. WQ. ZZ
FF
302DD2&
P
S. WQ. ZZ
F. S. TR
Geophysical Support/ Mapping
GS
Not Available-Use Technical Assistance (TA)
Groundwater Monitoring (Post-ROD)
GM
302DC9&
FF
S
FF
302DD2&
P
S
F. S. TR. RP. PS. MR
Health Assessment
HA
Not Available-Use Risk/Health Assessment (ED)
HRS Package
HR
302DC9&
FF
S
FF
302DD2&
P
S
F. S. TR
Human Health Risk Assessment
ED
Renamed-See Risk/Health Assessment (ED)
Hydro/Geological Support
HG
Not Available-Use Technical Assistance (TA)
I AG Negotiation
IN
Not Available-Use Negotiation - Generic (NG)
Information Management Support
IJ
302DC6&
S
S. WQ. ZZ. 00
F
302DC9&
FF
S. WQ. ZZ. 00
FF
302DD2&
P
S. WQ. ZZ. 00
F
302EC7&
E
S. WQ. ZZ. 00
FE
Integrated Assessment
EA
302DC9&
FF
S. WQ. ZZ
FF
302DD2&
P
S. WQ. ZZ
F. S. TR
Integrated ESI
OY
Not Available-Use Generic PA/SI (QB)
Integrated ESI/RI
OV
Not Available-Use Generic PA/SI (QB)
Integrated HRS Package
OZ
Not Available-Use Generic PA/SI (QB)
Integrated PA/SI
OU
Not Available-Use Generic PA/SI (QB)
Integrated SI
QJ
Not Available-Use Generic PA/SI (QB)
Interviews
HV
Not Available-Use NPL PRP Search (NS) or Non-NPL PRP Search (RP)
Laboratory Support
LA
302DC6&
S
S. WQ. ZZ. 00
F
302DC9&
FF
S. WQ. ZZ. 00
FF
302DD2&
P
S. WQ. ZZ. 00
F
302EC7&
E
S. WQ. ZZ. 00
FE
Litigation - Generic
LT
302EC7&
E
S
FE. SE
Local Government Reimbursement
EV
302DD2&
P
S
F
(Evacuation State/Local)
Long-Term Response Action (LTRA)
LR
302DD2&
RA
S
F. S. TR. SA SS. ST
Management Assistance
MA
Renamed-See State Support Agency Cooperative Agreement (MA)
Multi-Site Cooperative Agreement
MS
Not Available-LTse State Support Agency Cooperative Agreement (MA), Generic
PA/SI (QB), or Bulk Funding (WQ), as appropriate
Negotiation - Generic
NG
302EC7&
E
S
FE. SE
302EH2&
FFE
S
FE. SE
Non-NPL PRP Search
RP
302EC7&
E
S. WQ. ZZ
FE. SE
NPL RP Search
NS
302EC7&
E
S. WQ
FE. SE
Operations and Maintenance
OM
302DC9&
FF
S
FF
(For EPA-conducted O&M, use only
302DD2&
P
S
RP. PS. MR. SS
reimbursable resources only)
Partial Deletion from NPL
GR
Not Available-LTse Administrative Records (AR)
PPA Assessment
QX
302EC7&
E
S
FE
Pre-CERCLIS Screening
HX
302DC9&
FF
S. WQ. ZZ
FF
302DD2&
P
S. WQ. ZZ
F. S. TR
Change 5, FY 04/05 SPIM
111-23
January 10,2005
-------
OSWER Directive 9200.3-14-1G-Q
EXHIBIT HI-4
FY 2005 Action Codes for Financial Transactions
Sorted by CERCLIS Action Name
FY 2005 Superfund Extramural Action Codes to Be Used for Financial Transactions, Sorted by CERCLIS Action Name
Action Name
Action
Code
PRC
AOA
Site Des.
Lead
Pre-Remedial/Remedial Aerial Survey
AS
Renamed-See Aerial Survey (AS)
Preliminary Assessment (PA)
PA
302DD2&
P
S. WQ. ZZ
F. S. TR
Preparation of Cost Documentation
PC
302EC7&
302JC7&
E
S
S
FE. SE
Proposal to NPL
NP
Not Available-Use Administrative Records (AR)
PRPFS
NK
302DD2&
P
S
RP. PS. MR
PRP LR
ME
302DD2&
P
S
RP. PS. MR
PRP Community Involvement
EL
Not Available-Use Community Involvement (CR)
PRP RA
BF
302DD2&
P
S
RP. PS. MR
PRP RD
BE
302DD2&
P
S
RP. PS. MR
PRP Removal
BB
302DC6&
RV
s
RP. PS. MR
PRP RI
NA
302DD2&
P
s
RP. PS. MR
PRP RI/FS
BD
302DD2&
P
s
RP. PS. MR
RCRA Facility Assessment
AA
Not Available-Use Generic PA/SI (QB)
RD/RA Negotiation
AN
302EC7&
E
s
FE. SE
Real Property Acquisition
RL
302DD2&
P
s
F. S. TR
Records Management
SW
302DC6&
302DC9&
302DD2&
302EC7&
302EH2&
S
FF
P
E
FFE
S. WQ. ZZ. 00
S. WQ. ZZ. 00
S. WQ. ZZ. 00
S. WQ. ZZ. 00
S. WQ. ZZ. 00
F
FF
F
FE
FE
Remedial Action
RA
302DD2&
RA
S
F. S. TR. SA SS. ST
Remedial Community Involvement
CR
Renamed-See Community Involvement (CR)
Remedial Contract Management
JU
Renamed-See Contract Management (JU)
Remedial Design
RD
302DD2&
P
S
F. S. TR. SA SS. ST
Remedial Investigation
RI
302DD2&
P
S
F. S. TR. SA SS. ST
Remedial Support and Management
BO
Not Available-Use General Support and Management (BM)
Removal (Regions may plan using Hie
"WQ" SSID but must obligate site-
specifically)
(RA AOA for Remedial Program
Projects only)
RV
302DC6&
302DD2&
RV
RA
S
s
CG. F. S. TR. SA. SS. ST. SG
F. S. TR
Removal/Remedial Contract
Management
JT
Not Available-See Contract Management (JU)
Removal Aerial Survey
AY
Not Available-See Aerial Survey (AS)
Removal Assessment
RS
302DC6&
S
S. WQ. ZZ
CG. F. S. TR RP. PS. MR
Removal Community Involvement
RC
Not Available-See Community Involvement (CR)
Removal Contract Management
EZ
Not Available-See Contract Management (JU)
Removal Negotiation
RN
302EC7&
E
S
FE
Removal Support and Management
BN
Not Available-Use General Support and Management (BM)
Removed from Proposed NPL
NR
Not Available-Use Administrative Records (AR)
Research and Development
BG
302DD2&
P
S. WQ. ZZ
F. S. TR
RI/FS Negotiation
FN
302EC7&
E
S
FE. SE
Risk/Health Assessment
ED
302DC9&
302DD2&
FF
P
S
S
FF
F. S. TR. RP. PS. MR
Section 104(E) Referral Litigation
SF
302EC7&
E
S
FE. SE
January 10,2005
111-24
Change 5, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT HI-4
FY 2005 Action Codes for Financial Transactions
Sorted by CERCLIS Action Name
FY 2005 Superfund Extramural Action Codes to Be Used for Financial Transactions, Sorted by CERCLIS Action Name
Action Name
Action
Code
PRC
AOA
Site Des.
Lead
Section 106 Litigation
SX
302EC7&
E
S
FE. SE
Section 106/107 Litigation
CL
302EC7&
E
S
FE. SE
Section 107 Litigation
sv
302EC7&
E
s
FE. SE
SEE Program
SM
302DC6&
302DC9&
302DD2&
302EC7&
S
FF
P
E
S. WQ. ZZ. 00
S. WQ. ZZ. 00
S. WQ. ZZ. 00
S. WQ. ZZ. 00
F
FF
F
FE
Site Inspection (SI)
SI
302DD2&
P
S. WQ. ZZ
F. S. TR
Site Reassessment
OO
Not Available-Use Generic PA/SI (QB)
Site Security and Maintenance
PD
302DD2&
P
S
F. S. TR
Site-Specific BRAC Costs
PX
302D41B4
FF
S
FF
State Core Program
SK
302DD2&
P
00
F
State Enforcement Management
Assistance
EM
Not Available-Use State Support Agency Cooperative Agreement (MA)
State Support Agency Cooperative
Agreement
MA
302DC9&
302DD2&
FF
P
S. WQ. ZZ
S. WQ. ZZ
FF
F
Technical Assistance
TA
302DC6&
302DC9&
302DD2&
S
FF
P
S. WQ. ZZ
S. WQ. ZZ
S. WQ. ZZ
F. S. TR. RP. PS. MR
FF
F. S. TR. RP. PS. MR
Technical Assistance Grant
(Regions may plan using the "WQ"
SSID but must obligate site-
specifically)
TG
302DC9&
302DD2&
FF
P
S
S
FF
F
Topographical Mapping
TO
Not Available-Use Technical Assistance (TA)
Training
TH
302DC6&
302DD2&
302EC7&
S
P
E
00
00
00
F
F
FE
Tribal Core Program
TK
302DD2&
P
00
F
Tribal Pilot Projects
TJ
Renamed-See Tribal Support Agency Cooperative Agreement (TJ)
Tribal Support Agency Cooperative
Agreement
TJ
302DC9&
302DD2&
FF
P
S. WQ. ZZ
S. WQ. ZZ
FF
F
Key to Leads:
CG = Coast Guard
EP = EPA IN-HOUSE
F = EPA Fund-Financed
FE = Federal Enforcement
FF = Federal Facilities Response
MR = Mixed Funding Federal/RP
PS = PRP Response under State
RP = Responsible Party
S = State, Fund Financed
SA = PRP-Financed Action From a Special
Account Performed by EPA
SD
SE
SG
SN
SR
ss
ST
TR
State Deferral
State Enforcement
PRP-Financed Action From a Special
Account Performed by USCG
State, no Fund money
PRP LEAD UNDER STATE
PRP-Financed Action From a Special
Account Performed by State
PRP-Financed Action From a Special
Account Performed by Tribal
Government
Tribal Lead. Fund Financed
Key to Site Designators:
S = Site-specific obligation
WQ = Unspecified-Site Obligation; Site-
specific Outlay
ZZ = SITE-RELATED (ZZ) OBLIGATION
OO = Non-site (oo) Obligation
Key to SPIM AO As:
E = Enforcement
FFE = Federal Facilities Enforcement
FF = Federal Facilities Response
RV = Removal
S = Removal Support
P = Pipeline Operations
RA = Remedial Action
Change 5, FY 04/05 SPIM
111-25
January 10,2005
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OSWER Directive 9200.3-14-1G-Q
III.D. SUPERFUND FINANCIAL MANAGEMENT
The purpose of this section is to assist regional program offices in carrying out their financial management
responsibilities. It discusses the financial management tools and systems used by HQ and the regions to enter and track
financial information. It also discusses the various financial management funding mechanisms available to EPA to
support Superfund cleanup work and it details specific HQ and regional financial management responsibilities. Finally
this section details the cost recovery process.
III.D.l Financial Management Roles and Responsibilities
Due to the complexities of the Superfund program, numerous organizational units within the Regional EPA offices
have responsibility for Superfund financial management. As described in this document, the Regional Management
Divisionis 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), Response Oversight Contract (ROC) and Emergency and Rapid Response Services (ERRS) contracts
are considered to be a part of this division. Please see Section III .F. 1 for a list of Regional Superfund Cost Recovery
Contacts. 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 to perform. The next section lists the
financial management roles and responsibilities of several staff positions.
a. Regional Financial Management Office
Participates with the Regional Program Office to Assign Account Number, Document Control Number, and
Cooperative Agreement identification numbers
Enters quarterly AOA into IFMS, controls regional allowance
Sets up regional account numbers in IFMS
Processes Procurement Requests (PRs), Interagency Agreements (IAGs), and Cooperative Agreements (CAs)
Enters commitments, obligations, and drawdowns into IFMS
Reviews invoices, monthly financial reports, and payment requests
~ Commits funds under regional contracts and modifications
Assists regional program office in the pre-application phases of the CA development
Maintains Superfund document files on regional costs and supports the preparation of documentation for cost
recovery
Maintains accounts receivable for cost recovery, cash outs, Superfund State Contracts (SSC) cost share, and
oversight billings, and maintains billing and collection system
Provides regional program office with financial data
b. Regional Administrator (unless delegated to Regional Program office)
Approves cleanup actions under removal authority
Approves consistency exemptions atNPL sites where the removal costs are more than $2 million
~ Awards CAs, IAGs, and Technical Assistance Grants (TAGs)
Enters into SSCs
~ Initiates response planning activities
Ensures reimbursable BRAC costs are accurate and appropriate (1996 BRAC Guidance, Section 3.2.1)
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
c. Regional Program Office
Assigns the Account Number
Provides technical support to the Contracting Officer (CO)
Reviews vouchers and/or financial reports
Manages CAs and IAGs
Issues S/SIDs
Prepares Commitment Notices (CNs) and PRs
~ Develops SSCs
~ Approves Request for Proposals (RFPs) or Request for Bids and contracts developed by the States
Monitors financial data on contracts, IAGs, and CAs into CERCLIS/WasteLAN
~ Maintains Superfund document files on regional work performed
Submits change requests
Initiates and manages obligations
d. On Scene Coordinator (OSC)
~ Is an employee ofEPA or U.S. Coast Guard (USCG)
Reacts to 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 and Prs
Initiates PRs, Work Assignments (WAs), CAs, IAGs, and contracts
Approves site-specific IAG 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
In some cases, an OSC may have a written "Delegation of Procurement Authority" signed by a Senior Procurement
Manager (also called "Warrant Authority") and thus becomes an Ordering Officer.
e. Remedial Project Manager (RPM)
Is an employee ofEPA
~ Initiates and manages removal actions and remedial actions
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 financial reports
Establishes and maintains official site files in coordination with the Records Center
Initiates PRs, WAs, CAs, IAGs, and contracts
Approves site-specific IAG invoices
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
/. Regional Project Officer (RPO)/Deputy Project Officer (DPO)
~ Is an employee of EPA
~ 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, IAGs, and contracts
Approves site-specific IAG invoices
Identifies regional and site-specific contract requirements
Reviews invoices
Provides general contract management support
g. Administrative Support Unit
Established in each regional program office
~ Staffed with EPA staff (the non-government functions may be performed by a contractor)
Provides administrative support to the OSC/RPM
~ Provides liaison between OSC/RPM and other groups involved in administrative matters
Provides support to regional program management
Assists in developing removal site budgets and Action Memoranda
~ Maintains the Removal Cost Management System (RCMS)
~ Sets up and maintains active site files
Completes PRs and CNs
Reviews IFMS reports
Selected program offices in HQ also have Superfund Financial Management responsibilities. The main point of
contact for technical program area specific financial management issues is the applicable OSRTI regional center. Contact
Headquarters Program Analysis & Resources Management Center (PARM), Program Evaluation & Compliance Branch
(PECB), Federal Facilities Enforcement Office (FFEO), or Federal Facilities Restoration and Reuse Office (FFRRO)
with any issues pertaining to the AOA or overall budget resources. The next section lists the responsibilities of the HQ
management offices.
h. Office of Financial Management (OFM)ZOffice of the Chief Financial Officer
~ Collects HQ's Superfund cost documentation for cost recovery
Oversees annual site-specific reporting process
Issues financial policies and procedures
~ Provides general accounting support
Records transfer allocations
Notifies Trust Fund to invest cost recoveries, fines, and penalties
Establishes Superfund account numbers in IFMS
i. Office of Acquisition Management (OAM)
Conducts Superfund contracting program
Negotiates, awards, monitors, modifies, and terminates contracts
Provides technical guidance on contract administration
~ Provides cost and price analysis
April 1, 2005
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Change 6, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
j. Grants Administration Division (GAD) /Office of Administration
~ Issues policies, regulations, and guidance for processing, awarding, and managing financial assistance
agreements and IAGs
Issues identification numbers for all IAGs
Processes and awards HQ IAGs
k. Budget Division/OCFO
~ Allocates Superfund allowances among HQ and regions
Approves regional allowances
Monitors obligations against regular and site allowances
Processes transfer allocations
Processes change requests
Reprogram allowances
L Cincinnati Finance Center (CFC) Office of Financial Services
Provides accounting support for all Superfund IAGs
Processes disbursement requests from other agencies
Processes billings for reimbursable activities
Enters IAG obligations and disbursements into IFMS
in. Research Triangle Park (RTP) Finance Center Office of Financial Services
Provides accounting support for all Superfund contracts
~ Enters contract award and obligation data into IFMS
Processes contractor invoices
Enters payments into IFMS via the Contract Payment System
HID.2. Superfund Accounting Information
Where EPA incurs costs that can be identified as solely benefitting Superfund, the Superfund Appropriation is to
be directly charged through the Agency's account number structure. 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; site project and cost organization. Exhibit III.7 provides specifics
and an example of how to fill out the account number.
Fund/Appropriation Code - EPA controls appropriated funds and sub -accounts by using an Appropriation
Code also known as the fund code. Superfund dollars are distinguished as appropriation code "T". Two and three
digit appropriations codes are sub-accounts. For instance, prior year carryover balances including deobligations of
prior year funds are distinguished as appropriation code "TC" and special accounts for cashout settlements are
distinguished as "TR2". The four digit appropriation codes are TR2A and TR2B represent miscellaneous, transfer,
deposit, and trust fund receipt accounts. The most frequently used codes for Superfund include the following:
Change 6, FY 04/05
111-29
April 1, 2005
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OSWER Directive 9200.3-14-1G-Q
Appropriation Code
Title
T
Superfund
T9
Superfund Homeland Security
TC
Superfund Carryover
TCD
Superfund Carryover - Deobs
TR
Superfund Reimbursable
TR1
Superfund Reimbursable -SSC
TR2
Non-Federal Special Accounts - unearned revenue (i.e.,
future costs)
TR2A
Federal Special Accounts - unearned revenue (i.e., future
costs)
TR2B
Special Accounts - earned revenue (i.e., past costs and
interest)
The Agency uses site/spill identifiers (SSIDs) to account for and accumulate Superfund costs by site. 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 take a response. When
committing or obligating funds at sites where a SSID has not been assigned yet, the region may use "ZZ" in position 3
and 4 of the site/project position of the Account Number for PAs and Sis only. The "ZZ" should be used only if a site
does not have an SSID. "WQ" is used for bulk or block funding only, i.e., where SSIDs exist but funds are not
committed site specifically. When "WQ" or "ZZ" is used in the SSID position, funds are obligated non-site specifically.
However, for WQ obligations, when the funds are paid out/disbursed, they must be associated with a site. (ZZ
obligations may be drawn down as ZZ funds.) "00" can be used for dispersement of non-site specific core activities.
Once a SSID has been established for the site, regions must revise all the financial accounting information (in IFMS and
on the obligating document) with the correct SSID. The "ZZ" should not be used for future obligations once a SSID has
been established at the site. (Information on changing IFMS data can be found later in this chapter.)
For IT-related transactions, a unique format is used for the site/project field. The following describes this format.
Note: IT-related transactions will always be associated with the non-site Information Management (I.T) action in
WasteLAN.
Position
Description
1
IT Identifier (this character will always be "L")
2-3
Major or Significant Project
4
System/Project Phase (preliminary design, development, or maintenance)
5-6
Cost Area
7-8
Special Reporting Requirements (currently there are no special reporting requirements so this will
always be zeros)
See the New Information Technology' Accounting Requirements Comptroller Policy Announcement # 01-10 for
additional information on the IT accounting requirements.
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT III-5
ACCOUNT NUMBER STRUCTURE
Budget Fiscal
Year
Fund
(Appropriations
)
Organization
Program Results Code
Site Project
Cost/Org
2 0 0 4
T
7 A O O P
5 0 1 0 2 D
0 723CO01
C 0 0 2
|Data Element Field Name
Definition
Sample Entry |
Budget Fiscal Year
(8 characters)
The first four positions in this field identify the budget fiscal
year (e.g., '2004'). The last four positions in this field
identify the ending fiscal year, but these positions are not
used by the Superfund program, and should be left blank.
2 0 04
Fund (Appropriations)
(6 characters)
The type of appropriation is entered in this field with up to
first four characters indicating appropriations accounts and
sub-actions (e.g., 'TR'). If the appropriation is billed or
received (for cost recovery), valid entries can be up to 4
characters in length (e.g., 'HSCR'), with the last two
positions left blank.
T
Budget Organization
(7 characters)
The Budget Organization field is the Allowance
Holder/Responsibility Center (AHRC) code (e.g, '07H').
The AHRC code can be between 3 and 6 characters in length.
For instance, the first two characters represent the allowance
holder (e.g. Region 7 maybe represented as 07 or 7 A); the
3rd character is an alpha character which designate the
responsibility center within the Region (see the Region's
budget office for a list of these codes). The last three digits
represent the Superfund AOA Code and a local option or
congressional add-on (e.g., CUD - counter-terrorism
response)"
7AOOP
Program Results Code
(9 characters)
The first 6 characters identify the PRC as discussed earlier in
this chapter in Section IILB.2 and in Exhibit M.2. The 7th
and 8th characters are only used when a major program
activity undertaken by the Agency needs to be represented.
The 9th character is left blank.
5010 2D
Site/Project (8 characters) -
consists of S/SID, Action code,
and Operable Unit
The first four digits are comprised of the site/spill identifier
(SSID). The S SID is comprised of the Region number in the
second position, e.g., '7' for Region 7 with a place holder of 0
in the first position. For Region 10, a '0' should be entered in
this position. This combined with the third and fourth
position is a unique numeric or alpha numeric site number.
The SSID is followed by the action code in position 5 and 6.
The action code is a 2 digit alpha character, a listing of which
can be found in Exhibit HI.6 the Who Pays for What Table.
Finally, the operable unit is entered in positions 7 and 8 (e.g.,
'01' for operable unit 01). A unique format is used for IT
related transactions (see reference to IT in section III.D.2).
07 23 CO 01
Cost Organization
(7 characters)
The leading 'C' is the WasteLAN identifier used by IFMS. It
is system generated in the first position of the Cost
Organization field for WasteLAN actions. 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.
CO 02
Change 5, FY 04/05 SPIM
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January 10,2005
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OSWER Directive 9200.3-14-1G-Q
III.D.3 Financial Data Management Systems and Tools
The following data management systems and tools are used to plan and track the use of extramural resources:
CERCLIS/WasteLAN - Superfund specific database that houses site- and non-site specific data including the
financial planning data used for generating SCAP 4 reports. WasteLAN is the system each region uses to enter
region-specific data; CERCLIS is the system in HQ that integrates the data from WasteLAN into a national
database.
SCAP Reports - Standardized reports generated from CERCLIS/WasteLAN that support program planning and
performance. The SCAP reports used by HQ to track the regional financial planning and execution are the
SCAP 4 reports including: SCAP 4R for the Response budget; SCAP 4E for the Enforcement budget; and
SCAP 4F for the Federal Facilities budget.
Budget Automated System (BAS) - The central Agency system used to integrate strategic planning, annual
planning, budgeting, and financial management. The system contains resource (dollars and FTE), planning,
and performance data. BAS is an Agency-wide application; registered users have desktop access across a
variety of platforms in all HQ and regional offices. The system supports budget formulation, annual planning
and operating plan development. BAS also delivers automated budget tools (e.g., payrollforecasts),automated
links to IFMS for comparison reports (operating plan and actual obligations/outlays), and automated links to
accountability. BAS also has the capacity to support allocations ofperformance targets within the Agency and
project-based planning/resource allocations within Offices.
Integrated Financial Management System (IFMS) - The Agency's core financial system which 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. IFMS interfaces with
a number of Agency "mixed" (financial and nonfinancial) systems that are primarily for administrative purposes
but contain limited financial data. An interface has been established between IFMS and CERCLIS to download
actual financial data into CERCLIS. An interface also exists between IFMS and BAS. IFMS is maintained by
the Administrative Systems Division of the Office of Information Resources Management.
Management and Accounting Reporting System (MARS) - IFMS application that identifies the status of
commitments, obligations, and payments for a site. MARS can select any data element maintained in IFMS,
arrange those elements in any desired format, and print a report. Regional program office staff can request
MARS reports from the regional Servicing Finance Office (SFO).
ORBIT is designed to consolidate, integrate, and streamline existing reporting capabilities and to develop a
corporate approach to the Agency's various reporting and information needs. ORBIT will improve the
Agency's financial reporting capabilities and significantly expands the ability to integrate critical financial,
administrative and program performance information useful for monitoring Agency operating activity,
conducting trend analysis, and developing program strategy. The ad hoc reporting capability allows advance
user groups to create custom reports useful to their organization and reporting needs.
Financial Data Warehouse (FDW) - FDW is an official Agency reporting tool that will eventually replace
MARS. FDW is a collection of data in an Oracle database from the following information systems: IFMS,
SCORPIOS, and the Contract Payment System (CPS). The data that is stored in FDW is available to EPA users
via the intranet at "intranet.epa.gov/fdw" and by direct desktop access through Lotus Approach, Impromptu,
MS Access (a User ID, password, and database host name must be established). IFMS data in FDW is
refreshed at least twice a day.
Superfund Cost Recovery Package and Image On-Line System (SCORPIOS) - organizes cost information and
produces reports that summarize the costs for a specific Superfund site. The SCORPIOS report is combined
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
with images of supporting cost and technical documentation to yield a complete cost recovery package. The
system also provides calculations for oversight billing and tracking, charging of indirect costs, and the charging
of annual allocation.
PeoplePlus (PPL), the Agency's new integrated Human Resources, Benefits, Payroll, Time, and Labor
Management System, is a time recording system as well as a labor distribution system. With PPL, both the time
card and time sheet functions are combined. The user must record and attest all site charges that are entered
in PPL each pay period. PeoplePlus electronically records this information and attributes it to the appropriate
accounts by site. The information is then automatically passed into the Integrated Financial Management
System (IFMS), EPA's accounting system, and then to the Superfund Cost Recovery Package Imaging and On-
Line System (SCORPIOS), which is used for cost recovery.
III.D.4 Handling Financial Data in the CERCLIS/WasteLAN Environment
This section discusses the process for entering response and enforcement financial data into CERCLIS/WasteLAN.
IFMS data is downloaded nightly into CERCLIS/WasteLAN through an automated link. This automatic transfer
of financial information from IFMS to CERCLIS/WasteLAN includes commitments and obligations data. Planned
financial data must be entered into CERCLIS/WasteLAN by the region; however, the IFMS Account Number is
generated by CERCLIS/WasteLAN 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 IFMS to CERCLIS/WasteLAN transfer will not work properly.
a. Entering Response and Federal Facility Data into CERCLIS/WasteLAN
Once the funding document has been processed by the region, and actual commitment or obligation data are entered
into IFMS and transferred to CERCLIS/WasteLAN, the planned financial data should be deleted from
CERCLIS/WasteLAN. The "Planned" Financial Type should not remain in the system once the funds are committed
or obligated. Failure to delete the Planned Financial Type could cause the region to overstate its planned annual budget,
which will result either in withholding AOA approval, or a reduction in next quarter's AOA.
b. Entering Enforcement Extramural Budget Data into CERCLIS/WasteLAN
Regions are responsible for entering planned financial data into CERCLIS/WasteLAN, actual commitments and
obligations for enforcement actions are entered solely into IFMS by the regional FMO. Data is downloaded from IFMS
into CERCLIS/W asteLAN on a nightly basis.
Account numbers must be established for each transaction before commitment and obligation. To ensure that all
appropriate financial data are reflected in CERCLIS/WasteLAN, the following information along with the Account
Number, should appear on obligation documents: EPA identification number (EPA-ID), S/SID, CERCLIS action or
SubAction codes and OU number, WA number, amendment number, and amount.
Account Numbers must be established for each transaction before commitment and obligation. A CA is considered
obligated when it is signed by the Regional Administrator. An IAG is considered obligated when it is signed by the other
agency. Contracts are considered obligated when the CO signs the obligating document or, in the case of anEnforcement
Support Services (ESS) WA, when the CO signs the WA. Regions also are responsible for reviewing and recommending
payment of the invoice/voucher for these mechanisms. Once invoices are paid, these dollars (outlays) are entered into
IFMS. If the obligation is generic and the invoice is site-specific, IFMS shows the funds deobligated from the generic
account and obligated and disbursed from the site-specific account.
Change 7, FY 04/05 SPIM
111-33
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
c. Correcting Financial Data
The IMC or Regional Superfund Budget Coordinator can request, on a regular basis, a report from the Regional
financial office that contains all Superfund financial transactions in IFMS. The information in this report can be
compared with the funding documents and the information in CERCLIS/WasteLAN. The Financial Data Warehouse
is another source for this information. If there is a discrepancy between the financial data in CERCLIS/WasteLAN and
IFMS, the funding document should be used to verify the information in both systems.
Upon determining that the data on the funding document are correct, the IMC should give the Regional FMO a copy
of the funding document and any other relevant documentation showing that the IFMS data has been entered incorrectly.
The Regional IFMS administrator is then responsible for correcting any data errors in IFMS. The IFMS administrator
is the only person authorized to correct data entry errors or change financial information in the IFMS database. The
OFM has issued standard procedures for correcting IFMS data. The IMC or designee should work with the Regional
FMO on a regular basis to make sure that all IFMS errors are corrected.
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 (by a contract/PA or by amendment of the IAG or CA).
April 1, 2005
111-34
Change 6, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT III-6
HANDLING FINANCIAL DATA IN THE CERCLIS/WasteLAN ENVIRONMENT
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Change 2, FY 04/05 SPIM
111-35
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
III.D.5 The Funding Process
EPA uses a variety of procurement mechanisms to carry out CERCLA-funded response actions. These include the
procurement of contracts, interagency agreements, and cooperative agreements.
The process by which these vehicles are funded is accomplished in distinct but interrelated steps. Approvals,
commitments, and obligations result in directing funds to a project and/or supplier. In addition, the payment and
deobligation processes result in drawdowns from obligated funds.
a Approvals
An approval by the AAs, Regional Administrator or official designee is authorization to undertake a CERCLA-
funded response action.
Removal Actions:
Regional Administrator approves actions costing up to $6 million, approves removals costing up to $6
million based on the emergency waiver, grants exemptions to the twelve months and $2 million
statutory limits based on consistency with the long-term action, and may re-delegate to the OSC the
authority to approve actions costing up to $250,000 in emergency situations and up to $50,000 in non-
emergency situations.
Before taking action, an Action Memorandum must be approved, except in emergency situations where
verbal approval by the Regional Administrator is sufficient. The Action Memorandum documents
whether the release meets the criteria of CERCLA and the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), and includes an estimated total project ceiling. The OSC uses the
estimate of duration and cost in order to determine the proper approval authority.
In extreme emergencies, the OSC may initiate activities without preparing the necessary documentation
in advance. The OSC must document the decision within 24 hours of initiating the response.
RI/FS, RD, RA, Site Screening and Assessment, Enforcement, and Federal facilities:
Planning is accomplished through the SCAP process. Funds should not be committed or obligated
unless the project is reflected in CERCLIS/WasteLAN.
Obligation planned and executed on an OU or site basis. Outlays (payments) should be attributed to
the appropriate OU.
A Record of Decision (ROD) is required for all remedial actions. The ROD is signed by the Regional
Administrator or designee, or the AA SWER. It documents the alternative decision-making process,
demonstrates that the requirements of CERCLA and the NCP have been met, and provides the basis for
future cost recovery actions.
b. Commitments
Commitments are a reservation of funds but not a legal promise to pay a supplier. Once the regional Funds
Certifying Officer (FCO) certifies the availability of funds, a spending action becomes a commitment. Funds
that are committed but not obligated are called open commitments.
There are two types of commitment documents: ProcurementRequests (PRs) and CommitmentNotices (CNs).
PRs commit funds for contracts; CNs commit funds for CAs and reimbursable IAGs.
September 20, 2004
111-36
Change 4, FY 04/05
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OSWER Directive 9200.3-14-1G-Q
Open commitments expire at the conclusion of the Budget Fiscal Year (BFY).
Each commitment is assigned a Document Control Number (DCN). The DCN is a 6- digit code assigned by
the regional Superfund Financial Office (SFO) to PRs and CNs. This same number is carried over from the PR
or CN to the obligating document. It identifies the spending action in IFMS, just as a check number identifies
a check.
When IFMS transfers an obligation, each obligation is accompanied with a matching decommitment.
The contract number/OSWER Directive Number (ODN) represents a specific contract. More than one actual
obligation could fund a contract. Similarly, more than one DCN can be associated with one contract
number/ODN.
c. Obligations
Obligations legally bind the government to pay a supplier for goods or services. Obligated funds can no longer
be used for any other purpose.
A contractor, another Federal agency, or State cannot start work until funds have been obligated. Funds can
be used only for the purpose for which they were obligated.
Obligating documents must be processed in accordance with guidance issued by Office of Acquisition
Management (OAM), Grants Administrative Division (GAD), and Office of Financial Management (OFM).
Some contracts are awarded by OAM and entered into IFMS by the SFO/RTP; others are handled by the
regions. Obligations for CAs are entered into IFMS by the regions; IAGs are entered by the Cincinnati Finance
Center (CFC)/OFS.
A CA is considered obligated when it is signed by the Regional Administrator. An IAG is considered obligated
when it is signed by the other agency. Contracts are considered obligated when the CO signs the obligating
document, or in the case of an ESS WA, when the CO signs the WA.
d. Payments (Outlays)
Regions are responsible for reviewing and recommending payment of the invoice/voucher.
Invoices from contractors/suppliers are submitted to the proper SFO for payment. Before payment, there must
be an obligating document and a receiving report to verify that the work was completed, or that the goods
received were satisfactory. Unpaid obligations remain in IFMS until paid, or until the allowance holder or
obligating official notifies the SFO that no further payments will be made. When financial records are
transferred from IFMS, each payment is accompanied with a matching deobligation.
If the obligation was generic and the invoice is site-specific, IFMS shows the funds deobligated from the generic
account and obligated and disbursed from the site-specific account.
e. Deobligations
Regions should regularly review the status of all contracts, IAGs, CAs, and grants. If all activities have been
completed, remaining funds should be deobligated immediately to make them available for other activities.
Change 6, FY 04/05
111-37
April 1, 2005
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OSWER Directive 9200.3-14-1G-Q
Regions should hold a small portion of contract obligations to fund site closeout activities. Also see Section
C.5 earlier in this chapter for discussion of the current Deobligation Policy.
III.D.6 Financial Management of Contracts
The Agency's Superfund Contracts 2000 Strategy identifies the long-term needs of the Superfund program and
provides a portfolio of Superfund contracts to meet those needs. During FY04/05, implementation of the strategy will
continue.
Superfund contracts are awarded through standard procurement procedures (see the Office of the Comptroller's
Resources Management Directives Systems 2550C, Chapter 2 of this document, and the EPA Contracts Management
Manual, or refer directly to the directives prepared for each contract). Exhibit III.9 contains information on the
procurement forms used for most Superfund contracts. The unique aspect of Superfund contract processing and financial
tracking stems primarily from the need to associate contractor costs incurred with specific Superfund sites and OUs to
support the cost recovery process. Cost recovery negotiations with PRPs, or court actions, require careful documentation
of Federal costs incurred at each site/spill.
a. Contracts for Site-Specific Work
These contracts are obligated and tracked on a site-specific basis. They include RAC, START, Regional Oversight
Contracts (ROC) and ERRS. Funds forRA may be obligated to specific sites, or bulk funded with site ID "WQ" and then
paid out site specifically.
b. Contracts for Non-Site Specific Work
Non-site specific contracts are generally support type contracts which generally are not obligated site specifically,
but can obligate site-specific funding on a task or delivery order basis, depending upon the type of contract.
General Site Support Contracts
Generally not obligated on a site-specific basis; however some of these contacts allow for site-specific task or
delivery orders which can be obligated on a site-specific basis.
Capable of providing broad technical and planning support on an "as needed" basis
Includes Response Action Contracts (RAC), Superfund Technical, Superfund Technical Assessment and
Response Team (START), Regional Oversight (ROC), Emergency and Rapid Response Services (ERRS),
Contract Laboratory Program (CLP), and Environmental Services Assistance Team (ESAT)
~ Where funding has not been obligated on a site-specific basis, contractors submit site-specific attachment that
includes invoiced costs for:
Each site with a S/SID;
All other sites;
Program management (if applicable);
Base and award fee (if applicable)
Fixed Fee (if applicable); and
Non-site activities (e.g., training).
Where site-specific funding is obligated on a task or delivery order basis, the contractor either submits a
separate monthly invoice for each site, or one invoice for the contract, with separate attachments for each
site.
Contractors submit original invoice to RTP and copies to HQ or regional PO
~ PO reviews invoice
September 20, 2004
111-38
Change 4, FY 04/05
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OSWER Directive 9200.3-14-1G-Q
Enforcement Support Services (ESS) / Zone Enforcement Support Services (ZESS)
~ Combination of general site support and site-specific contracts; however, not obligated on a site-specific basis
~ Regions issue WAs against the contract on a site-specific basis
Site-specific WAs are not entered into IFMS
Contractors submit site specific attachment that includes invoiced costs for:
Each site with a S/SID;
All other sites;
Cost plus/fixed/award fee; and
Non-site activities (e.g., training).
Contractors submit original invoice to RTP and copies to RPO
~ RPO reviews invoice
RPOs and WAMs may conduct concurrent reviews
Mission Support Contracts
Provides support to HQ and regional program offices
~ Not for site-specific work
Not obligated site-specifically
Administered totally by HQ
EXHIBIT III-7
EPA FORMS COMMONLY USED FOR SUPERFUND PROCUREMENTS
EPA Form
Number
Form Name
Purpose
Comments
1900-8
Procurement
Request/purchase
Order
The Agency's basic form for
requesting the procurement of
any goods or services. Used to
commit funds before obligating
funds on any of these
documents. Must be certified by
FMO.
This form is the basis for entering
a commitment in IFMS. The
FMO enters an obligation only
upon receiving a contract
document or purchase order.
1900-48
Order for Services-
Emergency Response to
Hazardous Substance
Release
Used by OSCs to obligate funds
and contract for services (up to
$250,000) from commercial
firms or a State or local
government (if site not owned by
State or subdivision at time
wastes were disposed of) to
respond to a release.
Results in a firm, fixed-price
contract. No price adjustment
may be made for work stated in
contract. Contractor may submit
only one invoice. FMO will
process contract as an obligation.
1900-49
Notice to Proceed with
Emergency Response to
Hazardous Substance
Release
Used by OSC to authorize a
contractor to begin work on an
emergency response (up to
$10,000 per incident).
Negotiation of definitive
contract and any modifications
performed by CO.
A preliminary contractual
instrument that must be made final
by a designated CO. FMO will
process notice as an obligation.
Change 2, FY 04/05
111-39
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
EPA Form
Number
Form Name
Purpose
Comments
1900-56
Letter contract for
State, Tribal
Government, or Local
Government Response
to Emergency
Hazardous Substance
Release
Used by OSC to procure
services from a State, local, or
Tribal government to begin
work on an emergency response
(up to $10,000 per incident) if
site was not owned by State or
subdivision at time of hazardous
waste disposal. Negotiation of
definitive contract and any
modifications performed by CO.
Results in a cost reimbursement
type agreement with a State, local,
or Tribal government. It is a
preliminary contractual instrument
that must be made final by a CO.
The appropriate FMO will process
a letter or contract as an
obligation.
1900-59
Delivery Order for
ERRS
Used by OSCs to order services
(up to $250,000) from the ERRS
contractor to respond to a
release. All modifications and
obligations greater than
$250,000 will be processed by
the CO.
Has time and material provisions
but uses fixed rates negotiated in
ERRS contract. Order must be
made final by a designated CO.
FMO will process orders as an
obligation.
III.D.7 Other Financial Vehicles
The following sections discuss interagency agreements, cooperative agreements, and Superfund State contracts.
a. Interagency Agreements (IA(is)
An IAG is a written agreement between Federal agencies under which goods and services are provided. The
Superfund program uses Disbursement IAGs and Allocation Transfer IAGs to request Federal agencies' assistance with
site cleanups and associated activities, and to provide ongoing support or services. The regional program office initiates
and manages site-specific IAGs. U.S. Coast Guard (USCG)-lead removal IAGs, Department of Justice (DO.T) IAGs, and
allocation transfer IAGs are negotiated, approved, awarded, and managed at HQ. The IAG specifies the services required
and identifies the method of payment.
b. Cooperative Agreements (CA)
A Superfund Cooperative Agreement (CA) is a legal instrument between the Federal government and a State,
political subdivision, or Indian T ribe that forms a working relationship in which both parties provide funding and services
related to the design and implementation of Superfund responses. The CA transfers money, goods or services to the State
or other recipient to lead or support Agency activities. It allows the State or other recipient to take responsibility for
leading the Superfund response. In addition, it defines the level of involvement of EPA and the recipient and secures
the State's CERCLA assurances. A CA for remedial action also should include provisions for obtaining required state
cost share and other assurances.
Several offices are involved in the commitment process for a CA. The Regional Program Office (RPO) prepares
the commitment notice and obtains the necessary program approvals; the Regional Comptroller's Office certifies
availability of funds, assigns accounting data and enters commitment in IFMS; and the Grants Administration Division
assigns the CA identification number. To obligate funds for a CA, the Regional Administrator (or his/her designee), first
signs the CA. The Regional Comptroller's Office processes the obligation in accordance with OAM, GAD, and FMD
requirements and then enters the obligation in IFMS.
September 20, 2004
111-40
Change 4, FY 04/05
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OSWER Directive 9200.3-14-1G-Q
For additional information on the financial management of CAs, refer to the Resources Management Directives
Systems 2550D, Chapter 9.
c. Superfund State Contracts (SSCs)
When EPA or a political subdivision has the lead for a Remedial Action, an SSC is used to describe the State's role.
A SSC is a legally binding agreement that provides the mechanism for obtaining required State cost share and other
assurances, outlines the statement of work for the response action, and documents responsibilities for implementation
of response activities at a site. When a political subdivision has the lead, the SSC is signed by EPA, the State, and the
political subdivision.
The SSC does not obligate funds. Funds for Federal-lead projects must be obligated through an EPA PR with a
contractor, or through an IAG with another agency. Funds forresponse actions conducted by a political subdivision are
provided through a CA (see previous section).
The SSC must be signed prior to the obligation of funds for a RA. EPA may obligate RD funds to initiate the RA
procurement process, up to the point of soliciting for construction bids. In cases of extreme urgency, a solicitation (for
bids on RA work) may be issued before a 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 a SSC. If the SSC is not signed
before the bid opening, one of the following decisions must be made:
The solicitation may be canceled; or
~ The bid opening date may be postponed (giving bidders an opportunity to withdraw, modify, or submit new
bids).
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.
For additional information on financial management responsibilities related to SSCs, refer to the Resources
Management Directives Systems 2550D, Chapter 9.
Requirements
As provided by law, the State must provide its assurances through an SSC before Superfund resources can be
used to finance a RA.
~ SSC must be in place before EPA or a political subdivision can begin Fund-financed RA or NTC removal
where the State is sharing costs.
If USACE will perform the response action, a SSC must be in place before construction contract/agreement
can be signed.
~ If an IAG is used for the response action, a SSC must be signed before the IAG can be issued
As part of its assurances, the State must agree to pay its cost share of 10 percent for a RA or NTC removal at
privately operated sites, or 50 percent of all prior and future Superfund activities at publicly operated sites.
These assurances are made prior to RA start.
Contains program assurances and cost share payment schedule.
Development
~ The SSC is developed by regional program office.
Change 2, FY 04/05
111-41
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
Accounts Receivable
In most cases, States are required to provide cash payments to EPA for cost shares.
As State cost share amounts become due, RPM/RPO forwards copy of SSC to Regional Comptroller's Office
to record accounts receivable in IFMS.
~ RPM/RPO will forward SSC modifications to Regional Comptroller's Office as required.
Payment Schedule
The State can make its cost share payment(s) either in a lump sum advance or incrementally based on a
payment schedule.
If a State's cost share payment is received in advance, this amount should be used in lieu of EPA's
appropriated funds. Matching amounts of reimbursable authority must be requested and issued before they
can be used. Similarly, incremental progress payments should be applied to project costs where feasible in
lieu of appropriated funds.
Billing
~ According to the SSC payment schedule, the Regional Comptroller's Office will send the State a bill for
collection indicating cost share amount to be paid.
~ Regional Comptrollers Office will reference the SSC, including site name and site/spill identifier number on
the bill.
The State's payment is remitted to respective regional lockbox account.
The State must include copy of bill with all remittances.
Receipt of Payment
~ If payment is not received when due, the Regional Comptroller's Office will follow up with the State via
dunning letters.
Interest does not accrue on the billed amount if the State provides dollars before EPA obligates funds for RA.
In this case, the Regional Comptroller's Office places amounts received in reimbursable account.
Closeout
~ The RPM/RPO is responsible for advising the Regional Comptroller's Office to close out a SSC.
~ Regional Comptroller's Office performs a reconciliation of financial data as part of the SSC close out
process.
State cost share funds remaining or received after the completion of work should be obligated to the project
and the commensurate amount of appropriated funds deobligated for use at other sites.
III.E COST RECOVERY PROCESS
CERCLA, as amended, imposes liability on responsible parties for the cost of responding to releases or threatened
releases of hazardous substances from hazardous waste sites or spills. When these PRPs fail to clean up sites on their
own, EPA may perform the cleanup and later attempt to recover the cleanup costs from the parties. Obtaining
reimbursement for these costs through negotiation or judicial action is one of the primary goals of the Superfund
program.
September 20, 2004
111-42
Change 4, FY 04/05
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OSWER Directive 9200.3-14-1G-Q
Cost recovery documentation is performed by a case development team composed of representatives from the Office
of Regional Council (ORC), the regional program office, and the Regional SFO. The involvement and distribution of
responsibilities of each of these offices during the cost recovery process varies among the regions, and may be defined
by a Regional Inter-Office Memorandum of Understanding.
III.E.l Cost Recovery Referral Development Process
a. Initiation of Cost Recovery Process
Regional program office prepares and submits cost recovery request through Regional Cost Recovery Coordinator
(RCRC) to Regional SFO. Request identifies date through which costs are to be documented and date documentation
is required.
RCRC requests site-specific reports generated by the Superfund Cost Recovery Package and Image On-Line System
(SCORPIOS) to provide cost basis for negotiations with PRPs.
b. Cost Documentation and Reconciliation
Involves collecting and reviewing documentation to ensure accounting and cost information are recorded correctly,
costs are properly charged, Account Numbers refer to the appropriate site, and costs on documents are accurately
reflected in IFMS.
~ SFO documents regional Superfund costs and prepares cost summary, computes indirect costs, provides expert and
factual financial witness testimony, and interprets financial documents and SCORPIOS reports.
ORC reviews final cost summary and documentation in preparation for litigation and takes appropriate action pursuant
to the Privacy Act and Confidential Business Information requirements.
c. Work Performed Documentation and Reconciliation
Involves collecting and reviewing documentation to ensure that costs are being pursued for appropriate site activities.
RCRC assembles copies of any task-creating document (WA, Purchase Order, Delivery Order, etc.) as well as
amendments, modifications, progress reports and close-out reports for the tasks included in the cost recovery
referral.
RCRC works with the SFO to ensure agreement between the cost and work performed documentation.
ORC reviews final work performed documentation package and takes appropriate action pursuant to the Privacy Act
and Confidential Business Information requirements.
d. Site File Maintenance
Diligent maintenance is crucial to cost recovery and is a regional responsibility.
Financial files are maintained by the FMO until two years after all cost recovery litigation is complete.
Work performed files are maintained by contracts officials or RCRC in accordance with Agency disposal
guidance.
~ Disposal of files is permitted 30 years after cost recovery is completed or upon completion of imaging or when no
longer needed, whichever is later.
Cost recovery documentation should be maintained by the RCRC until required by the litigation team.
e. Superfund Indirect Costs
EPA incurs costs that are attributable to individual Superfund sites and indirect costs which support the operation of
the Superfund program in general and which also support site cleanups, but cannot be directly accounted for by an
individual site. Annual indirect cost rates are computed linking the cleanup activity with the level of benefits received
from the support activities.
Change 7, FY 04/05 SPIM
111-43
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
f Annual Allocation
The Annual Allocation Reporting Process was implemented to allow the Agency to capture Superfund site-related
contract costs consistently and accurately for the purpose of cost recovery and external reporting. This process is the
means by which administrative and other non-site costs (program management, capital equipment, start-up and site-
supported costs) associated with the contractors' direct site work are redistributed to the appropriate Superfund sites.
The process requires that the contractors follow a documented methodology for allocating certain non-site specific costs
to sites and submit an annual allocation report.
g. Cashout/SpecialAccounts
A cashout is money received by EPA, a State, or another PRP under the terms of a settlement agreement [such as
a consent decree (CD), administrative order on consent (AOC) or consent agreement] to address future response action
costs at a specified Superfund site.
EPA is authorized to establish and maintain site-specific special accounts where PRPs agree to make cash payments
toward response costs at a site (i.e. cashout and/or cost recovery settlements). Cashouts accepted under this authority
should be placed in EPA site-specific special accounts before they are used. Once these cash payments have been
obtained, the Agency may begin obligating and outlaying the funds in accordance with the settlement agreement.
The Agency has developed a framework to manage and use special accounts to facilitate site cleanup. Regions are
encouraged to create and use special accounts as an incentive to secure private party cleanups and to fund EPA lead
response actions. Special account funds may also be used, where appropriate, to assist response actions performed by
a State or other Federal Agencies.
For more information on special accounts, please refer to the "Consolidated Guidance on the Establishment,
Management and Use of CERCLA Special Accounts" issued September 2002.
h. Department of Justice (DOJ) Involvement
DO J and the United States attorneys acton behalf of EPA in all cost recovery litigation. Only DOJ has the authority
to settle a claim for any dollar amount more than $500,000. EPA has the authority to settle for amounts less than
$500,000 in non-judicial actions. As a result, DOJ's involvement is essential to recovery of costs.
September 20, 2004
111-44
Change 4, FY 04/05
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OSWER Directive 9200.3-14-1G-Q
III.F. SUPERFUND FINANCIAL CONTACT INFORMATION
This section provides regional and HQ contact information to assist in resolving and clarifying any financial
management issues or difficulties that are encountered.
III.F.l Regional Superfund Cost Recovery Contacts
Exhibit III-8 identifies the Regional Superfund Cost Recovery Contacts.
EXHIBIT III-8
REGIONAL COST RECOVERY CONTACTS
Location/Region
Name of Contact
Phone Number
Region I
David Tomstrom
Lee Clouthier
Ruben Neira
Robert Pavluvcik
617/918-1135
617/918-1934
617/918-1939
617/918-1137
Region II
Richard Manna
Jo Ann Velez
Leslie Peterson
212/637-3480
212/637-3462
212 637-4298
Region III
Daria Arnold
Steven Pandza
Diane Malancone
215/814-5171
215/814-5178
215/814-5172
Region IV
Connie Dempsy
Sarah Franco
Vickie Tellis
404/562-8240
404/562- 8215
404/516-8218
Region V
Anthony Audia
Violet Stroggins
312/886-2196
312/353-4884
Region VI
Dennis McBride
214/665-7481
Region VII
David Piet
Gay Ranes
913/551- 7526
913/551- 7442
Region VIII
Cheryl Pressley
303/312-6507
Region IX
Yvonne Fong
David Wood
415/972-3698
415/972-3709
Region X
Diane Norton
206/553-2962
Cincinnati Finance Center
Pat Newman
513/487-2059
Las Vegas Finance Center
Alan Lewis
702/798-2480
Research Triangle Park
Finance Center
Gloria Owens
Betty Hamilton
919/541-0052
919/541-4280
Change 7, FY 04/05 SPIM
111-45
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
III.F.2 Headquarters Superfund Cost Recovery Contacts
Exhibit III-9 identifies the Headquarters Superfund Cost Recovery Contacts.
EXHIBIT III-9
HEADQUARTERS SUPERFUND COST RECOVERY CONTACTS
Staff Name
Position
Areas of Specialization
Phone #
Lex Barker
Program Analyst
Annual Allocation; Special Projects
202/564-1400
Kevin Brittingham
Accountant
National Cost Documentation Advisor;
Special Projects
202/564-4941
Tommy Brown
Financial Specialist
Cost Documentation and Reporting;
Headquarters SCORPIO S Administrator
202/564-4936
TomDeHoff
Accountant
Superfund Policy, Special Projects
202/564-4946
Bemadette Dunn
Accountant
Superfund Indirect Rates
202/564-4963
Barbara Edmondson
Accountant
National Cost Documentation;
Superfund Account Codes; Special
Projects
202/564-4927
Iantha Gilmore
Staff Director (Acting)
Superfund Policy Advisor, Financial Data
Integration
202/564-7654
Tanya Jenifer
Financial Specialist
Cost Documentation; Payroll
202/564-4986
Leslie Kelley-Huffman
Accountant
Annual Allocation
202/564-4805
Levy Mazyck
Accountant
Superfund Indirect Costs
202/564-5219
Tina Van Pelt
Accountant
Annual Allocation; Superfund Contractor
Invoice Accounting and Adjustment
202/564-4984
April 1, 2005
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III.F.3 Regional Budget Coordinators
Exhibit III-10 identifies the Regional Budget Coordinators. In each Region a Budget Coordinator serves as the
regional lead for all Superfund program resource activities. The Budget Coordinator:
Coordinates the planning, development and reporting of resources;
Coordinates the planning and execution of regional priorities;
Communicates and implements national and regional Superfund budget policies;
Helps IMC to ensure regional resources associated with accomplishments are complete, current, and consistent,
and accurately reflected in WasteLAN; and
~ Provides liaison to HQ on program issues.
EXHIBIT 111-10
REGIONAL BUDGET COORDINATORS
Name/Region
Phone #
Fax #
Susan W alter/Region I
(617) 918-1447
(617) 918-1291
Courtney McEnery /Region II
(212) 6374295
(212) 6374360
Robin Faux/Region III
(215) 814-3133
(215) 814-3015
Charlotte Whitley/Region IV
(404) 562-8863
(404) 562-8842
Jatinder Singh/Region V
(312) 353-6756
(312) 353-9306
Helen Newman/Region VI
Alternate/Carlene Chambers
(214) 665-6657
(214) 665-3181
(214) 665-6660
Teri Hankins/Region VII
(913) 551-7118
(913) 551-7145
Roger Hogerheide/Region VIII
(303) 312-6159
(303) 312-6065
(303) 312-6897
Linda Ma/Region IX
Alternate/Eugene Rainwater
(415) 972-3232
(415) 972-3217
(415) 947-3528
Lynne Kershner/Region X
(206) 553-6518
(206) 553-0124
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III.F.4 Subject Matter Experts
Exhibit III-11 identifies the Headquarters Subject Matter Experts (SMEs) for budget and financial information.
The following Headquarters program officers are responsible for Superfund budget planning and execution.
Office of Solid Waste and Emergency Response (OSWER)
- Response Budget - Planning, Analysis and Resource Management (PARM) Center in the Office of Superfund
Remediation and Technology Innovation (OSRTI)
- Federal Facilities Response Budget - Federal Facilities Restoration and Reuse Office (FFRRO)
Office of Enforcement and Compliance Assurance (OECA)
- Enforcement Budget (Technical and Legal) - Program Evaluation and Coordination Branch (PECB) and the
Program Operations Staff (POS) in the Office of Site Remediation Enforcement (OSRE)
- Federal Facilities Enforcement - Federal Facilities Enforcement Office (FFEO)
Office of Chief Financial Officer (OCFO)/ Office of Financial Management (OFM)
- Annual Budget process - Annual Planning and Budget Division (APBD)
EXHIBIT III-ll
HEADQUARTERS SUBJECT MATTER EXPERTS
Subject Matter Expert
Subject Area
Phone #
Alan Youkeles
Action Codes - PBEB/OSTRI
703/603-8784
Alice Ludington
Annual Budget Process - OSRE
202/564-6066
W illie Griffin
Annual Budget Process -
PBEB/OSRTI
703/603-8911
Art Flaks
BPEB
703/603-9088
Hortensia Coffee
BRAC
703/603-0053
Laura Milton
Enforcement Budget
202/564-6017
Marie Bell
Federal Facilities Budget
703/603-0050
Lance Elson
Federal Facilities Enforcement
Budget
202/564-2577
Larry Wilbon
OCFO
202/566-1903
Nancy Ortowski
Real Property Acquisitions
703/603-8785
Jeff Lape
Resource Management
703/ 603-8914
Steven Wilson
Resource Management
202/564-3646
Kevin Brittingham
Superfund Financial Management
202/564-4941
Robert White
SCAP Report Coordinator
703/603-8873
April 1, 2005
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Superfiind Program Implementation Manual FY 04/05
Appendix A: Site Assessment/NPL Listing
FY 04/05 SPIM
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Appendix A
Site Assessment/NPL Listing
Targets and Measures
Table of Contents
A.A. SITE ASSESSMENT/NPL LISTING FY 04/05 TARGETS AND MEASURES A-l
AA.l Site Assessment Program & NPL Listing Priorities A-l
A.A.2 Site Assessment Backlogs A-l
A.A. 3 Overview of FY 04/05 Site Assessment/NPL Listing Targets and Measures A-2
A.A.4 GPRA and Site Assessment A-2
A A. 5 Site Status Indicators A-4
A A. 6 Data Quality A-6
A.A.I Action Qualifiers for Site Assessment Actions (LANGUAGE FROM CH 2) A-6
a. No Further Remedial Action Planned (NFRAP) A-6
b. Former Evaluation A-6
c. Perform a Removal A-l
d. Defer the Site to RCRA (Subtitle C) or the NRC A-l
e. Sites addressed as part of existing NPL sites A-l
f. Sites addressed as part of other existing non-NPL sites A-l
AA. 8 Special Initiatives A-8
A.A.9 Site Assessment/NPL Listing Definitions A-9
a. Pre-CERCLIS Screening Assessments A-9
b. Referred from RCRA A-11
c. Site Discovery A-12
d. Sites Archived A-13
e. Preliminary Assessments (PA) at Non-Federal Facility Sites A-14
f. Federal Facility Preliminary Assessment Reviews A-16
g. Site Inspections (SI) at Non-Federal Facility Sites A-18
h. Combined PA/SI Assessments at Non-Federal Facility Sites A-20
i. Federal Facility Combined PA/SI Reviews A-21
j. Site Inspection Prioritizations (SIPs) at Non-Federal Facility Sites A-22
k. Site Reassessment A-24
1. Expanded Site Inspections (ESI) at Non-Federal Facility Sites A-25
m. Federal Facility SI Reviews A-26
n. Federal Facility ESI Reviews A-28
o. Integrated Expanded Site Inspection/Remedial Investigation (ESI/RI)
at Non-Federal Facility Sites A-29
p. State Deferral of Non-Federal Facility Sites A-30
q. Hazard Ranking System Package (HRS) A-32
r. Integrated Removal/Remedial Evaluation A-33
s. NPL Listing A-35
t. Other Cleanup Activity A-37
A.B. SUBJECT MATTER EXPERTS A-39
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Appendix A
Site Assessment/NPL Listing
Targets and Measures
List of Exhibits
EXHIBIT A.l SITE ASSESSMENT/NPL LISTING ACTIVITIES A-3
EXHIBIT A.2 SITE ASSESSMENT ACTION QUALIFIERS A-8
EXHIBIT A.3 SUBJECT MATTER EXPERTS A-39
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APPENDIX A
A.A. Site Assessment/NPL Listing
FY 04/05 TARGETS AND MEASURES
A. A. 1 SITE ASSESSMENT PROGRAM AND NPL LISTING PRIORITIES
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 also need to ensure that the backlog of sites needing Preliminary
Assessments (PAs), Site Inspections (Sis), or Expanded Site Inspections (ESIs) does not growunacceptably. The regions
should consider integrating assessments to reduce cost and time to assess sites. Regions should continue the use ofpre-
CERCLIS screening to assure only appropriate sites are placed in CERCLIS/WasteLAN. The regions should also ensure
the appropriate investigations of sites of Tribal concern that are on or near Indian Country.
To better accomplish the national priorities, the regions should continue negotiating work share agreements with
individual States (and Tribes if applicable). This will help divide up the site assessment work and potentially enhance
relations with the States and Tribes. This process will also serve to identify the current lead agency for the public.
Given sizeable workloads and constrained resources, regions are encouraged to pursue more cost- and time-efficient
methods of assessing sites without compromising the quantity and quality of site assessment decisions. Regions should
communicate progress and results of new assessment methods to other EPA regional and headquarters (HQ) site
assessment staff.
HQ and regions should continue the streamlined process for listing sites on the National Priority List (NPL) and evaluate
alternatives to listing sites while providing NPL quality cleanups.
Site assessment is the first step in determining whether a site meets the criteria for placement on the NPL. Listing a site
on the NPL is one tool among many that are available to EPA and State cleanup program managers to accomplish the
cleanup of contaminated waste sites. In lightofcurrentprogram resource realities, Fund-financedremedialaction atNPL
sites has become the tool of last resort. In 1992, EPA's Office of Emergency and Remedial Response (OERR, now
OSRTI) issued a directive entitled "Guidance on Setting Priorities forNPL Candidate sites" (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.
These can include recently identified sites, sites earlier in the site assessment process, or previously deferred RCRA sites.
The regions should ensure the appropriate investigation of sites of tribal concern including sites in or near Indian
Country.
A.A.2 SITE ASSESSMENT BACKLOGS
A key function of HQ is to report national progress in the 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 PA are collectively termed the "PA Backlog". Throughout this appendix, the
procedures HQ uses to derive backlog is provided for each step in the site assessment process.
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A.A.3 OVERVIEW OF FY 04/05 SITE ASSESSMENT/NPL LISTING TARGETS AND
MEASURES
The Superfund Comprehensive Accomplishments Plan (SC AP) is used by the Assistant Administrator for the Office
of Solid Waste and Emergency Response (AA OSWER), Assistant Administrator for the Office of Enforcement and
Compliance Assurance (AA OECA), and senior Superfund managers to monitor the progress each region is making
towards achieving the Government Performance and Results Act (GPRA) annual performance goals. In addition, SCAP
will continue to be used as an internal management tool to project and track activities that contribute to these GPRA
goals and support resource allocation. The program will set national goals based on historical performance and
performance expectations within a limited budget for the performance goals in GPRA and track accomplishments in the
activities contributing to those goals. Regions should continue to plan and report accomplishments in WasteLAN as they
have traditionally.
To more clearly reflect the relationship between GPRA and the SCAP process, GPRA annual performance goals
and measures and program targets and measures are defined as follows:
GPRA Annual Performance Goals (APG) and GPRA Annual Performance Measures (APM) - The
Agency's Annual Plan describes the specific annual performance goals, annual measures of outputs and
outcomes, and activities aimed at achieving the performance goals that will be carried out during the year.
APGs are the specific activities that the Agency plans to conduct during the fiscal year in an effort towards
achieving its long-term strategic goals and objectives. APMs are used by managers to determine how well a
program or activity is doing in achieving milestones that have been set for the year. The annual performance
goals will inform Congress and Agency stakeholders of the expected level of achievement for the significant
activities covered by the GPRA objective. The goals are a subset of the overall planning and budgeting
information that has traditionally been tracked by the Superfund program offices.
Program Targets and Measures are activities deemed essential to tracking overall program progress. Program
targets are used to identify and track the number of actions that each region is expected to perform during the
year and to evaluate program progress. Program measures are used to show progress made in achieving
program priorities.
The following pages contain, in pipeline order, the definitions of the FY 04/05 Superfund site assessment targets
and measures. ExhibitA.l displays the full list of site assessment and activities defined in this Appendix. ExhibitA.2,
at the end of this Appendix, identifies the Subject Matter Experts (SMEs).
A.A.4 GPRA AND SITE ASSESSMENT
Goal 3, Objective 3.2, Sub-objective 3.2.2: Clean Up and Reuse Contaminated Land contains the GPRA
subobjective for Superfund assessment work. This subobjective states: "By 2008, control the risks to human health
and the environment at contaminated properties or sites through cleanup, stabilization, or other action, and make land
available for reuse." The Strategic Target for Superfund assessment work is that by 2008, EPA will:
Make 41,086 final-assessment decisions under Superfund.
Perform 88,000 health and environmentally based site assessments.
Final Assessment Decisions (FADs)
Regions may assign a FAD designation to a site entered into CERCLIS with a discovery action and date if any of the
following conditions are met:
The site has been proposed to or placed on the National Priorities List (NPL);
The site has been removed from proposal to the NPL and no further assessment is needed;
The decision made at the last completed assessment at the site is either:
-*~D No further remedial action planned (NFRAP);
Referred to Removal-NFRAP
Deferred to RCRA or NRC; or
-*>'D Addressed as part of an NPL or non-NPL site;
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The site is being remediated under a formal state deferral agreement;
The site is being remediated as a Superfund Alternative Site;
The site has been cleaned up or is making progress towards cleanup as supported by documentation
(worksharing agreements, site-specific progress reports, AOCs, remedial action plans, VCP/other MOAs, etc.)
between the non-EPA party and EPA stating that the site has been or is being cleaned up or addressed according
to appropriate cleanup standards;
The site has been properly archived from the active CERCLIS site inventory.
Regions must delete the FADs designation should conditions change such that the site no longer meets any of the
above conditions.
EPA regions are responsible for maintaining FAD designations in WasteLAN. FAD status is captured in WasteLAN
by selecting the 'Final Assessment Decision' check box on the Site Description/Status/Operable Units screen.
WasteLAN populates the related 'Final Assessment Decision Date:' field with the current date. Regions can accept
or edit this date.
The net increase in number of final assessment decisions in a fiscal year and the total number of sites with
assessment decisions (inception to end of fiscal year) are included in EPA's Annual Report. These accomplishments
are tabulated on the SCAP-15 report.
Flealth and Environmental Based Site Assessments
The measure, "number of site assessments completed" is used to measure the strategic target for health and
environmental based site assessments. The measures looks at the existing site assessment actions with a completion
date. The actions included in the definition are: Pre-CERCLIS Screening, Preliminary Assessment, FF PA Review,
Site Inspection, FF SI Review, Combined PA/SI, Site Inspection Prioritization (SIP), Expanded Site Inspection, FF
ESI Review, ESI/RI, Site Reassessment, Integrated Removal and Preliminary Assessment, Integrated Removal and
Site Inspection, Integrated Removal and ESI, Integrated Removal and PA/SI, Integrated Removal and SIP,
Integrated Removal and HRS Package, Integrated Removal and ESI/RI, and HRS Package. A detailed definition for
completion of each of the actions is listed in this manual under the action's Definition of Accomplishment.
The total number of site assessments completed (inception to end of fiscal year) and the number of site assessments
completed (current fiscal year) are tabulated on the SCAP-15 report.
EXHIBIT A.l
SITE ASSESSMENT/NPL LISTING ACTIVITIES
ACTIVITY
GPRA
PROGRAM
APG
APM
TARGET
MEASURE
Pre-CERCLIS Screening Assessment
/~
Site Discovery
/~
Sites Archived
/~
Preliminary Assessment (PA) at Non-Federal Facility Sites
/~
Federal Facility PA Review
/~
Site Inspection (SI) atNon-Federal Facility Sites
/~
Federal Facility SI Review
/~
Combined PA/SI Assessment at Non-Federal Facilities
/~
Site Inspection Prioritization (SIP) atNon-Federal Facility Sites
/~
Site Reassessment
/~
Expanded Site Inspection (ESI) atNon-Federal Facility Sites
/~
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EXHIBIT A.l
SITE ASSESSMENT/NPL LISTING ACTIVITIES
ACTIVITY
GPRA
PROGRAM
APG
APM
TARGET
MEASURE
Federal Facility ESI Review
/~
Integrated ESI/RI at Non-Federal Facility Sites
/~
State Deferral of Non-Federal Facility Sites
/~
Hazard Ranking System (HRS) Package (Non-Federal Facility and
Federal Facility)
/~
Integrated Removal Assessment & PA at Non-Federal Facility Sites
/~
Integrated Removal Assessment & SI at Non-Federal Facility Sites
/~
Integrated Removal Assessment & Combined PA/SI at Non-Federal
Facility Sites
/~
Integrated Removal Assessments and Expanded Site Inspection
(ESI)
/~
Integrated Removal Assessments and Site Inspection Prioritizations
(SIPs)
/~
Integrated Removal Assessments and Hazard Ranking System (HRS)
/~
Integrated Removal Assessments and Expanded Site Inspection and
Remedial Investigation (ESI/RI)
/~
NPL Listing
/~
Other Cleanup Activities
/~
No. of Final Assessment Decisions *
/~
No. of Site Assessment Report *
/~
NOTE: Accomplishments are pulled from WasteLAN on a semi-annual basis.
* Italic text indicates that this activity is a goal or measure that is not specifically defined in the Appendices to the
Manual. Data to support reporting of these goals are already included in existing definitions.
A. A. 5 Site Status Indicators
These site status indicators are entered through the Site Status and Description/Operable Units screen in WasteLAN.
Archive Indicator - this checkbox indicates if the site has been archived. NOTE: Indicating that a site has been
archived will result in a pop-up message asking the user if they would like to make an NFFA determination at this
time. If the user clicks yes, the NFFA flag will be populated and an NFFA date will be system generated.
A site cannot be archived if there are any planned or ongoing 'archive prohibited actions' at the site. For a list of
'archive prohibited actions', refer to the CERCLIS Archived Sites QRG.
A site that has been archived represents a site-wide decision that no further interest exists at the site under the
Federal Superfund program based on available information. It is a comprehensive decision indicating there is no
further Superfund site assessment, remedial, removal, enforcement, cost recovery, or oversight activities being
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planned or conducted at the site. For more information about archiving sites in WasteLAN, refer to the CERCLIS
Archived Sites QRG or the EPA's "Refining CERCLIS" website at:
http://www.epa.gov/superfund/programs/reforms/reforms/2-4c.htm
Archive Date - this date is system generated with the current date when the checkbox is checked. This field is
editable and should reflect the date the site was archived.
NPL Status - displays the current NPL Status for the site. User may select from the drop down to enter or change
the NPL Status of the site. Regional users have access to change the NPL Status to 'Not a valid site or incident',
'Not on the NPL', 'Addressed as part of an existing NPL site', and 'Pre-proposed site'. All other NPL Status values
are added through a database revision and are uneditable.
Non NPL Status - displays the current Non-NPL Status for the site. User may select from the drop down to enter or
change the Non NPL status of the site. The available non-NPL status values will be limited based on the NPL Status
of the site.
Reporting non-NPL site status information allows EPA to clearly identify the progress a site has made in the Site
Assessment Pipeline at any given time. For a list of Non-NPL Status values and more information about entering
non-NPL status values in WasteLAN, refer to the Reporting Non-NPL Status QRG and the Understanding NPL and
Non-NPL Status Code Relationships QRG.
Status Not Specified (SX) is one of the codes available for selection as a Non NPL Status value. Regions may select
this code only if no other available Non NPL Status value is appropriate. If selected, the Region should notify the
EPA HQ Site Assessment Data Sponsor to determine whether a new Non NPL Status value needs to be created.
Regions should review sites with an 'SX' value at a minimum on a semi-annual basis (prior to mid year review, and
end-of-year assessment) and update this value as appropriate.
Non NPL Status Date - this field is system generated with the current date when the Non NPL status of a site is
changed. This field is editable and should reflect the date the non-NPL status of the site changed.
ERS Exclusion - this checkbox indicates if the region has made an eligible response site exclusion decision at the
site.
Under CERCLA Section 101(41)(C), EPA may determine to exclude sites from the Brownfields eligible response
universe if EPA "conducts or has conducted a preliminary assessment (PA) or site inspection (SI) and, after
consultation with the State, determines or has determined that the site obtains a preliminary score sufficient for
possible listing on the National Priorities List or otherwise qualifies for listing on the National Priorities List."
NOTE: This checkbox may not be selected if the site if the NFFA checkbox has been selected.
For more information regarding making an ERS exclusion at a site, please referto OSWER Directive 9230.0-170,
entitled Regional Determinations Regarding Which Sites are "Eligible Response Sites " under CERCLA Section
101 (41)(C)(i), as Added By the Small Business Liability' Relief and Brownfields Revitalization Act.
ERS Exclusion Date - this date is system generated with the current date when the checkbox is checked. This field
is editable and should reflect the date the site was determined to be excluded.
Final Assessment Decision (FAD) - this checkbox indicates if a final assessment decision has been made for the
site. Regions are responsible for maintaining FAD designations in WasteLAN. The number of FADs is a GPRA
measure.
Final Assessment Decision Date - this date is system generated with the current date when the checkbox is checked.
This field is editable and should reflect the date the final assessment decision was made.
NFFA - this checkbox only applies to sites that have been assigned an ERS exclusion decision and denotes that if the
site requires No Further Federal Action. CERCLA Section 101(41 )(C)(i) authorizes EPA to make a site which was
previously excluded as an Eligible Response Site, because it had obtained a preliminary score sufficient for possible
listing, an Eligible Response Site again when EPA determines that "no further federal action will be taken" (NFFA).
NOTE: Sites that have a NPL status of F, or P are not eligible for No Further Federal Action. In addition, if a site
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has any planned or ongoing enforcement, cost recovery or removal activities, the user will not be allowed to make an
NFFA determination.
NOTE: This checkbox may not be selected if the ERS Exclusion checkbox has been selected.
For more information regarding NFFA decisions, please refer to OSWER Directive 9230.0-170, entitled Regional
Determinations Regarding Which Sites are "Eligible Response Sites" under CERCLA Section 101 (41) (C) (i), as
Added By the Small Business Liability Relief and Brownfields Revitalization Act.
NFFA Date - this date is system generated with the current date when the checkbox is checked. This field is
editable and should reflect the date the determination that no further federal action would be taken at the site.
A.A. 6 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
CERCLIS/WasteLAN are available through the regional Discover application and through the national Superfund
eFacts application. Discoverer reports include: Non-archived sites with no recent action, Non-NPL actions on-going
and needed, SX Non-NPL status, Unallowable actions after archived, Invalid NPL/Non-NPL Status, and Discoverer
Actions Completions. Superfund eFacts reports include: Active/no action (similar to Discoverer report 'Non-
archived sites with no recent action'), Early DS date (similar to Discoverer report 'Discovery Actions Completions'),
Missing SA Status, and Invalid NPL/SA Status (similar to Discoverer report 'Invalid NPL/Non-NPL Status'). The
Regions should use these reports on a routine basis (at a minimum on a semiannual basis - prior to the mid-year
review and end-of-year assessment^ to better manage their site assessment data.
A. A. 7 Action Qualifiers for Site Assessment Actions
Site screening and assessment decisions are made upon completion of each site assessment action. These
decisions identify how the Region will proceed with site response and are recorded in WasteLAN as action qualifiers
(Qualifiers). These decisions include:
a. No Further Remedial Action Planned (NFRAP)
No further Superfund remedial assessment work will be taken at a site with a NFRAP determination [Qualifier = (N)
No Further Remedial Action Planned] unless new information warranting such action is presented to EPA.
NFRAP decisions should not be confused with WasteLAN 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 WasteLAN 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 during site
assessment activities.
b. Further Evaluation
Upon completion of each site assessment action, the Region may determine that additional, more complex evaluation
activities are required to determine whether or not the site should be pursued for placement on the NPL. A decision
to conduct further evaluations at a site is recorded differently in WasteLAN depending on what site assessment activity
is being performed.
ForPAs, Sis, Site Reassessment, Combined PA/SI, and SIPs, further evaluation is denoted by eithermaking a decision
of higher priority [Qualifier = (H) High], or lower priority [Qualifier = (L) Low] for further evaluation.
For ESIs and ESI/RIs, further evaluation is denoted by the decision of lower priority for further evaluation or to
recommend the site for HRS scoring [Qualifier = (G) Recommended for HRS Scoring],
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Further evaluation activities upon completion of a HRS Package consist of HQ quality assurance and ultimately a
decision on whether to propose the site to the NPL [Qualifier= (O) Site is being considered for proposal to theNPL],
c. Perform a Removal
Upon completion of PAs, Sis, SIPs, ESIs or ESI/RIs, the Region may determine that a time-critical or non-time critical
(NTC) removal is necessary. The decision recorded for these actions are "Referred to Removal, Needs Further
Remedial (Qualifier = F)" or "Referred to Removal, No Further Remedial (Qualifier = W)."
d. Defer the Site to RCRA (Subtitle C) or the NRC
Upon completion of PAs, Sis, ESIs, or SIPs at non-Federal facilities, the Region may determine that the site is
excluded from Superfund consideration under policy, regulatory, or legislative restrictions and defer it to either the
RCRA program [Qualifier = (D) Deferred to RCRA (Subtitle C)] or to the NRC [Qualifier = (DN) Deferred NRC],
e. Sites addressed as part of existing NPL sites
Upon completion of Site Assessment activities, such as PAs, Sis, SIPs, ESIs, or ESI/RIs, the Region may decide that
a site is best addressed as part of an existing NPL site. This would be done when contamination at a non-NPL site
is being addressed by cleanup actions at an existing NPL site. This most frequently occurs at Federal facilities and
sites with an area-wide groundwater contamination problem resulting from multiple sources. In this situation, the NPL
site is considered the 'parent' and the non-NPL site is referred to as the 'child'. The decision to address a site as part
of an existing NPL site requires the following information in WasteLAN:
Upon completion of the 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' (A) at the child site;
The 7-digit Site ID number of the parent site must be entered into the Parent Site ID field (Site Parent ID) for
the child site;
The 7-digit Site ID number of the child site must be entered into the Child Site ID field (Site Child ID) for the
parent site; and
The NPL Status for the child site must be changed to 'Site is part of NPL Site' (A).
After a site is collapsed into the parent site, no further response work should be recorded at the child site. Instead,
any further response work performed at that site should be recorded under the existing parent NPL site, possibly as
a separate operable unit.
f Sites addressed as part of other existing non-NPL sites
Upon completion of a site assessment activity, it is also possible for the Region to decide that a site is best addressed
as part of another existing non-NPL site. The decision to combine multiple non-NPL sites requires the following
information in WasteLAN:
Upon completion of the site assessment activity that led to the decision to combine the two sites, the Region
should enter a qualifier of 'Addressed as part of another non-NPL site' (B) at the child site;
The 7-digit Site ID number of the parent site must be entered into the Parent Site ID field (Site ParentID) for
the child site;
The 7-digit Site ID number of the child site must be entered into the Child Site ID field (Site Child ID) for the
parent site; and
The Non-NPL Status for the child site must be changed to 'Addressed as part of another non-NPL site' (B) .
After a site is collapsed into the parent site, no further actions should be recorded at the child site. Instead, any further
assessment or response work performed at that site should be recorded under the existing parent site. If the parent site
becomes a NPL site (NPL Status P, F, D, R, W), WasteLAN should be updated as described in section d. above.
Change 1, FY 04/05 SPIM
A-7
September 22, 2003
-------
OSWER Directive 9200.3-14-1G-Q
Exhibit A.2
Site Assessment Action Qualifiers
^ Available Action Decisions
SITE ASSESSMENT
ACTION NAMES S CODES
7/
Pre-CERCLIS Screening
MX
NOT APPLICABLE
Discovery
OS
NOT APPLICABLE
Preliminary Assessment
PA
~
~
~
~
~
~
~
~
~
~
Fed Fac FA Review
RX
~
~
~
~
~
~
~
~
Site inspedicm
SI
~
~
~
~
~
~
~
~
~
Combined PA/S!
W
~
~
~
~
~
~
~
~
~
~
Site Inspection Prioritization
SH
~
~
~
~
~
~
~
~
~
Site Reassessment
00
~
~
~
~
~
~
~
~
~
~
Expanded Sile Inspections
ES
~
~
~
~
~
~
~
~
~
~
Fed Fac SI Review
TY
~
~
~
~
~
~
~
~
Fed Fac ESI Review
TZ
~
~
~
~
~
~
~
~
ESI/Rt
SS
~
~
~
~
~
~
~
~
~
~
State Deferral
AQ
~
~
HRS Package
HR
~
~
~
~
~
~
~
Int Rnw Assess and Preliminary Assessment
OT
~
~
~
~
~
~
~
~
~
~
Int Rmvi Assess and Site Inspection
QJ
~
~
~
~
~
~
~
~
~
~
Int Rmvf Assess and Site Inspection Pnoritaalion 00
~
~
~
~
~
~
~
~
~
Int Rmv: Assess and Combined fWSt
CKJ
i/
~
~
~
~
~
~
~
~
~
Int Rmvi Assess and ESWI
OV
~
~
~
~
~
~
~
~
~
~
~
Int Rmvi Assess and Expanded Site Inspection
OY
~
~
~
~
~
~
~
~
~
~
~
Int Rmv< Assess and HRS Package
01
~
~
~
~
~
~
~
~
~
~
Other Cleanup Activity
VA
~
~
/ = Valid for this Acton
A.A. 8 Special Initiatives
A special initiative flag is used in WasteLAN to note a HQ or Regional site special priority or other program
initiative under which a Superfund site may be tracked, and that a planned or actual activity addresses. These special
initiatives are flagged on the Add Special Initiative screen via the Site Status and Description/Operable Units screen.
The special initiatives in WasteLAN apply to and are used by all program areas. The following are a listing of the most
commonly used special initiatives within the site assessment program:
Formally Used Defense Site (FUDS)
Federal Facility Docket Site
Vermiculite Investigation
Site Inspection Prioritization Needed
Tribal Inventory Site
Tribal Concern
Tribal Involvement
Tribal Land
RCRA 2005 Baseline
RCRA Deferral
RCRA Deferral - Further Supefund Assessment
RCRA Deferral - New Decision
RCRA Deferral - Lead Confirmed
RCRA Deferral Audit
Superfund Alternative
September 8, 2005
A-8
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
A.A.9 SITE ASSESSMENT/NPL LISTING DEFINITIONS
a. PRE-CERCLIS SCREENING ASSESSMENTS
Definition:
Pre-CERCLIS screening is the process of reviewing data on a potential site to determine whether it should be entered
into the CERCLIS inventory for further evaluation. The process can be initiated through the use of several mechanisms,
such as a phone call or referral by a State or other Federal agency. The information/collection pro cess is normally limited
to one or two days. Minimal sampling can be performed during the pre-CERCLIS screening action (less than $2,000
sampling costs per screened site).
A site should not be entered into CERCLIS if:
~It is currently in CERCLIS or has been removed from CERCLIS and no new data warrants re-entry into CERCLIS;
The site or contaminants found on the site are subject to certain limitations based on definitions in CERCLA;
~A State or Tribal remediation program is involved in response at the site and it is in the process of a final cleanup;
~The hazardous substance release at the site is regulated under a statutory exclusion (e.g., petroleum, natural gas,
natural gas liquids, synthetic gas usable for fuel, normal application of fertilizer, release located in a workplace,
naturally occurring, or covered by the Nuclear Regulatory Commission (NRC), or Uranium Mill Tailings Radiation
Control Act (UMTRCA), [see CERCLA section 101(22)];
~ The hazardous substance release at the site is deferred to another authority (e.g., RCRA Corrective Action);
~ Site data are insufficient to determine if CERCLIS entry is warranted (i.e., based on potentially unreliable sources or
with no information to support the presence of hazardous substances or CERCLA eligible pollutants or contaminants);
or
~Documentation clearly demonstrates that there is no potential for a release that could cause adverse environmental or
human health impacts.
For more information on pre-CERCLIS screening please refer to Pre-CERCLIS Screening Assessments fact sheet
(OSWER 9375.2-11FS). This fact sheet provides the minimum requirements for conducting these type of
assessments.
Definition of Accomplishment:
Pre-Screening Starts - A pre-screening (Action Name = Pre-CERCLIS Screening) is started when the region begins
collecting data and performing other tasks related to completion of the Pre-CERCLIS Screening Assessment Checklist;
and WasteLAN contains the actual pre-screening start date (Actual Start) and an action lead of: "Fund-Financed (F)";
"EPA-In House (EP)"; "State-Financed (S)"; "Tribal (TR)." Pre-CERCLIS screening start dates are not required.
Pre-Screening Completions - A pre-screening (Action Name = Pre-CERCLIS Screening) is completed when:
~ A Pre-CERCLIS Screening Assessment Checklist has been developed by EPA to document the decision and placed
in the site file. The Pre-CERCLIS Screening actual completion date is the date the Checklist is finalized; and
~WasteLAN contains the actual Pre-CERCLIS Screening completion date (Actual Complete), a valid lead (Lead), and
appropriate values in the NPL and Non-NPL Status fields.
In addition to the pre-screening action, entry of the following information is required:
Sites that require NPL assessment work, or both NPL assessment and removal work
- A Discovery Date on the Add Site screen, which corresponds to the actual completion date of the pre-screening action;
- An NPL Status of 'Not on the NPL' on the Add Site screen;
- A Non-NPL Status of'PA StartNeeded', 'Combined PA/SI Start Needed', or 'Integrated Removal AssessmentPA
Start Needed' on the Site Description/Operable Unit screen.
Change 4, FY 04/05 SPIM
A-9
September 20, 2004
-------
OSWER Directive 9200.3-14-1G-Q
Sites that require only removal work
- An Initiation Date on the Add Site screen, which corresponds to the actual completion date of the pre-screening action;
- An NPL Status of 'Not on the NPL' on the Add Site screen;
- A Non-NPL Status of 'Removal Only' on the Site Description/Operable Unit screen.
Sites that require no further evaluation beyond the pre-screening
- An NPL Status of 'Not a Valid Site or Incident' on the Add Site 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.'
For more information on tracking Pre-CERCLIS Screening activities, please refer to the March 2002 guidance
document entitled "Data Entry for Pre-Screening Sites. "
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
All pre-CERCLIS screening activities should be tracked in WasteLAN, including activities at sites not found to be
CERCL A-eligible. Sites that are screened out of CERCLIS will be tracked in WasteLAN through the "Not a Valid Site
or Incident" values in the NPL and N on-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 CERCLIS inventory by entering a Discovery
Date and valid NPL and Non-NPL Statuses. A Discovery action or date should not be entered into W asteLAN if the site
only needs a removal assessment/action and no NPL assessment work is necessary. For these sites with "removal-only"
interest, the Site Initiation Date on the Add Site screen needs to be entered for these sites to be considered part of the
CERCLIS inventory. Sites that are screened out of the CERCLIS inventory should be entered on the Add Site screen
with no Discovery or Initiation date, and the NPL status 'Not a Valid Site or Incident'. The region will maintain a record
based on a pre-screening action. This is a program measure.
Regions are responsible for maintaining the accuracy of the non-NPL status for every non-NPL site in the CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/Date
Requirements
Date Must Be Entered By
Action name =
Pre-CERCLIS
Screening (HX)
Program
Measure
F, EP,
S, TR
Pre-CERCLIS
Screening
Assessment
checklist.
The date the checklist is
final and WasteLAN
contains the Pre-CERCLIS
Screening completion date,
lead, and NPL or Non-NPL
status.
It is good management practice
to enter data regarding the
event as soon as practicable
after the event occurs.
However, data must be entered
prior to the end of the quarter
in which the event occurs.
September 8, 2005
A-10
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
b. REFERRED FROM RCRA
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.
Further, 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 action and actual completion date documented in WasteLAN.
Definition of Accomplishment:
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 is entered. The Referred
from RCRA date is entered as the completion (actual completion) at the site. Valid leads for Referred from RCRA
actions include: "Fund-Financed (F)"; "EPA-In House (EP)"; "State (S)", and "Tribal (TR)". 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.
Changes in Definition FY 04/05 - FY 06/07:
New measure in FY 06/07.
Special Planning/Reporting Requirements:
Actual start and planning dates are not required for the Referred from RCRA action. An action qualifier of 'financial'
should be added to the Referred from RCRA action if the site was referred to Superfund as a result of a failed financial
assurance. Special initiative flags of 'RCRA baseline 2005' and 'RCRA baseline 2008' have been added to CERCLIS.
These fields will be populated and maintained by F1Q.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/Date
Requirements
Date Must Be Entered By
Action name =
Referred from
RCRA
Program
Measure
F, EP,
S, TR
Documentation of
the site referral
from RCRA and
that the Superfund
accepts the site
warrants Superfund
NPL assessment
and potential
cleanup attention.
The date the documentation
of the referral from RCRA
is received from the
regional official and
WasteLAN contains the
Referred from RCRA
actual completion date and
lead.
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
Change 7, FY 04/05 SPIM
A-ll
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
c. SITE DISCOVERY
Definition:
Site discovery is the process by which a potential hazardous waste site is entered into the CERCLIS inventory for NPL
assessment activities. All sites moving through the NPL assessment process must have a Discovery action and actual
completion date documented in WasteLAN. Entry of the site discovery date initiates the NPL assessment process and
places the site on the Preliminary Assessment backlog.
Definition of Accomplishment:
Site discovery of non-Federal facilities is the date the region completes the pre-CERCLIS screening activities, and
documents the decision that the site warrants Superfund NPL assessment and potential cleanup attention. The site
discovery date for Federal facilities is the date the site is formally added to the Federal Facilities Flazardous Waste
Compliance Docket indicating Superfund involvement is required. The Site Name and Discovery Date must be entered
into WasteLAN for both Federal and non-Federal sites. Valid leads for site discovery actions include: "Fund-Financed
(F)"; "EPA-In Flouse (EP)"; "State (S)", "Tribal (TR)"; and "Federal Facility (FF)."
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Actual start and planning dates are not required for the Discovery action. The Discovery date is entered through the Add
Site screen. The Discovery date will automatically populate the actual completion date for the Discovery action.
Regions are now required to enter information on site type at the time of discovery on the Add Site or Site
Discovery/Initiation screen. Multiple discovery actions are not allowed. Site discovery is a program measure.
Note: A separate field has been added to WasteLAN to record site initiation dates for removal-only sites. Sites that are
subject only to removal interest generally do not require a discovery date. An exception is where a large scale removal
action has been completed and the region seeks credit for a non-NPL site completion. Non-NPL site completions require
site assessment review indicating the site has no further remedial actions planned. The discovery date for sites referred
from removal to 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/Date
Requirements
Data Must Be Entered By
Action name =
Discovery (DS)
Program
Measure
F, EP,
S, TR,
FF
Documentation of
the decision that
the site warrants
Superfund NPL
assessment and
potential cleanup
attention.
The Discovery date is
entered through the
Add Site screen. Hie
Discovery date will
automatically populate
the actual completion
date for the Discovery
action.
It is good management practice
to enter data regarding the
event as soon as practicable
after the event occurs.
However, data must be entered
prior to the end of the quarter
in which the event occurs.
September 8, 2005
A-12
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
d. SITES ARCHIVED
Definition:
Archiving represents a site-wide decision that no further interest exists at the site under the Federal Superfund program
based on available information. It is a comprehensive decision indicating there is no further Superfund site assessment,
remedial, removal, enforcement, cost recovery, or oversight activities being planned or conducted at the site. Regions
may perform re-evaluation work at a site while it is archived if site conditions change and/or new information becomes
available. Sites re-evaluated and determined to need substantial site characterization and/or cleanup work under the
Federal Superfund program must be returned to the CERCLIS inventory. Regions may also record general enforcement
related activities (e.g. issuance of comfort letter or prospective purchaser agreements) and Brownfields activities (e.g.
Targeted Brownfields Assessments) at archived sites. For more information on archiving sites in WasteLAN please refer
to EPA's "Refining CERCLIS" website at: http://www.epa.gov/superfund/programs/reforms/reforms/2-4c.htm.
Backlogs
The Archive site backlog consists of the potential archive candidate sites described below.
Definition of Accomplishment:
An archive decision is recorded in WasteLAN at the site level. To receive credit for an archive decision, the Archive
Indicator (Archive IND) must be checked, and the "Archive Date" entered on the Site Status and Description/Operable
Units screen. A note must be prepared and placed in the site file explaining that no further Federal Superfund interest
exists at the site based on available information. Since archiving is a comprehensive decision, the note must represent
the interests of the appropriate regional business units (e.g., site assessment, removal, etc.), including the regional RCRA
program for archive designations based on site deferral to RCRA. Regions should also consult with State and/or Tribal
partners prior to making an archive designation to ensure any issues related to archiving are considered and handled
appropriately. The date of the note is the Archive Date and entering this date automatically generates the Archive
Indicator in WasteLAN.
Although the underlying basis for archiving a CERCLIS site is whether or not Federal Superfund interest exists, several
categories of sites are used to generate lists of potential archive candidate sites. Based on review of sites in these
categories, regions should update the " Archive IND" and "Archive Date" field as appropriate in a timely fashion. These
categories are:
Sites that have only completed the site assessment process and have either been given a No Further Remedial Action
Planned (NFRAP) or Deferred decision at the conclusion of the last completed site assessment action, and no other
Federal Superfund activity is anticipated;
~Sites that have completed both the removal and site assessment process, or have completed the removal process and
require no site assessment work (removal-only sites), and which have completed all related oversight, cost
recovery/other enforcement work, and have no further Federal Superfund activity anticipated;
~Sites that have successfully completed State Deferral as described in the May, 1995 OSWER Directive 9375.6-11
titled "Guidance on Deferral of NPL Listing Determinations While States Oversee Response Actions" and no further
Federal Superfund activity is anticipated;
~Sites removed from the proposed NPL or final NPL (e.g., as a result of a lawsuit) that have no further Federal
Superfund activity anticipated;
~Child sites addressed as part of a parentNPL or non-NPL site, provided there is no further Federal Superfund interest
at the area represented by the child site. Parent non-NPL sites should not be archived until all related child sites have
been archived;
~Sites that have been entered into the CERCLIS inventory via entry of a site discovery and/or site initiation date which
have not had any work started and, based on review, do not warrant any type of additional Superfund activity. An
abbreviated preliminary assessment (PA) should be completed for these sites prior to designating archive status.
~Sites that have completed Other Cleanup Activities by a non-EPA party under the Site Assessment process and have
no other Federal Superfund activity anticipated.
Change 7, FY 04/05 SPIM
A-13
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
As appropriate, sites can be returned to the CERCLIS inventory by deleting the date in the Archive Date field. The
Archive Indicator will automatically be deleted. A note explaining why the site was returned to the CERCLIS inventory
must be prepared and placed in the site file.
Changes in Definition FY 02/03 - FY 04/05:
The measure has been updated to reflect the changes to WasteLAN adds a 'site unarchived' action to the project
schedule when a user unarchives a site.
Special Planning/Reporting Requirements:
The Archive Indicator field in WasteLAN is used as a filter on Superfund reports and data sets to delineate whether a
site is still in, or has been removed from, the CERCLIS inventory. Planning dates for archiving sites are not available.
It is important to note that an archive decision is not the same as no further remedial action planned (NFRAP) decision.
A NFRAP decision is recorded as an Action Qualifier, is made only at the conclusion of a site assessment action, and
does not take into account any other Superfund programmatic activity that may be going on at a site such as removals
or cost recovery. Archived sites is a program measure for both non-Federal and Federal facilities.
The WasteLAN application will prevent adding certain assessment, removal, remedial, and enforcement actions at
archived sites. The CERCLIS-Archive Quick Reference Guide lists the prohibited actions. Prohibited actions can be
added to a site by either: 1) returning the site to CERCLIS (e.g., substantial site characterization and/or cleanup is
needed); or 2) requesting a database revision through Headquarters (e.g., entry of historical data). The restriction will
not prevent users from entering action-related data such as start/completion dates, leads, qualifiers, etc., at existing
actions. WasteLAN will also prevent the archival of NPL sites (Proposed, Final, and Deleted) and sites having a start
and no completion date at an archive-prohibited action.
Archive designations need to be made in a timely fashion to accurately portray the status of sites to all users of Superfund
Program information. The site assessment program area within WasteLAN's reports module contains reports to help
EPA regions maintain the integrity of archive data. The Potential Archive Site Inventory Report lists sites that may be
eligible for archival. The Archived-To-Be-Reviewed Site Inventory Report lists sites that may warrant data
corrections/updates or return to the active CERCLIS site inventory.
The WasteLAN application now captures archive designations by automatically generating an archive action and
completion date when the Archive Date field is populated. In addition, a 'site unarchived' action and completion date
is generated when the archive date or indicator is deselected (i.e., a decision is made to unarchive a site). Multiple
Archive Site/Site Unarchived actions may be created at a site if the archive indicator is selected, deselected, and then
selected again. Each time the archive indicator is selected/deselected at a site, a new Archive Site or Site Unarchived
action will be created. These actions cannot be deleted except via a database revision.
e. PRELIMINARY ASSESSMENTS (PA) AT NON-FEDERAL FACILITY SITES
Definition:
A Preliminary Assessment (Action Name = Preliminary Assessment) is often the first phase of the NPL assessment
process following site discovery. The PA is used to determine what steps, if any, need to occurnext atthe site. Federal,
State, and local government files, geological and hydro logical 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.
Regions may combine PA and SI activities where warranted by site conditions to reduce repetitive tasks and ultimately
costs. The combining of PA and SI activities is known as a "C ombined PA/SI Assessment" and is discussed in a separate
measure below. The decision to perform a "Combined PA/SI Assessment" is made when site assessment activities are
initiated.
Regions also have been encouraged to further reduce repetitive tasks and costs by combining site assessment and removal
evaluation activities where warranted by site conditions. This integrated removal/remedial evaluation is further discussed
in a separate measure, below.
September 8, 2005
A-14
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
There are instances when an Abbreviated Preliminary Assessment (APA), as opposed to a full PA, is warranted.
Examples include, but are not limited to the following: 1) A site has been inappropriately listed in CERCLIS because
it is either not eligible or it could be deferred to another response program; 2) Available information allows EPA to make
an early decision to undertake a combined PA/SI, an SI, or another Superfund investigation; or 3) A no further remedial
action planned (NFRAP) designation can be made without completing a full PA. An abbreviated PA should be
conducted for sites entered into the CERCLIS inventory via a site discovery at which no work has started and, based on
review, do not warrant any type of additional Superfund activity. For such sites, the typical PA reporting requirements
are abbreviated. The APA Checklist or an APA report must address the requirements set forth in the Oil and Hazardous
Substances National Contingency Plan (NCP).
For more information on Abbreviated Preliminary Assessments please referto Abbreviated Preliminary Assessment fact
sheet (OSWER 9375.2-09FS) This fact sheet provides guidance for conducting this type of assessment.
Backlogs
The Preliminary Assessment backlog consists of sites with a Non-NPL Status of either "PA start needed" or "PA
ongoing".
Definition of Accomplishment:
PA Starts - A PA (Action Name = Preliminary Assessment) 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, 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 WasteLAN contains the actual PA start date
(Actual Start) and an action lead of: "Fund-Financed (F)"; "EPA-In House (EP)"; "State (S)"; or "Tribal (TR)". PA start
dates are required and are used by HQ as a program measure.
APA Starts - An Abbreviated 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, 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.
PA Completions - A Preliminary Assessment (Action Name = 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
~WasteLAN contains the actual PA completion date (Actual Complete), a valid lead (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 WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the PA. Please refer to Exhibit A.2 in section
A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
APA Completions - An Abbreviated Preliminary Assessment is completed when an APA checklist or equivalent report
has been completed 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 APA report. The APA actual completion date
is the date the APA report is approved.
Changes in Definition FY 02/03 - FY 04/05:
None.
Change 7, FY 04/05 SPIM
A-15
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
Special Planning/Reporting Requirements:
Regions should attempt to complete PAs at non-Federal Facility sites listed in WasteLAN within one year of the site
discovery completion date.
If a region decides to perform an Abbreviated Preliminary Assessment (APA) rather than a Preliminary Assessment, it
needs to be indicated on the SCAP Information screen. Once an APA is selected on the SCAP Information screen, the
definition, documentation, and special notes changes will be reflected on the screen. PA starts and completions (Actual
Start and Complete) are reported site-specifically in WasteLAN. 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action Name =
Preliminary
Assessment
(PA)
Program
Measure
F, EP,
S, TR
Starts:
Letter, form, memo;
Technical Direction
Document (TDD);
Written confirmation
from a State/Tribal
government that the
State/Tribal government
will conduct the PA.
Starts:
Signed by region.
Date TDD is issued.
Date EPA receives
confirmation.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Action Name =
Preliminary
Assessment
(PA)
Program
Measure
F, EP,
S, TR
Completions:
PA report;
Letter, form, or memo
approving the PA report;
Site decision Form
9100-3 in WasteLAN or
equivalent document.
Comnletions:
Signed by the
appropriate
Regional official.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
f FEDERAL FACILITY PRELIMINARY ASSESSMENT REVIEWS
Definition:
Federal Facility Preliminary Assessment Review is a quality assurance review of a PA report submitted by another
Federal Agency. EPA's involvement in PAs at Federal facilities differs from that at non-Federal facilities. While EPA
conducts or funds development of PAs at non-Federal facilities, EPA's role at Federal facilities is limited to reviewing
PA reports developed and submitted by the Federal agencies responsible for a given Federal facility. Upon reviewing
the PA 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 PA Review backlog consists of Federal facility sites with a Non-NPL Status of "FF-PA review
needed" or "FF-PA review ongoing."
September 8, 2005
A-16
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
Federal Facility PA Review Starts - A Federal Facility PA Review (Action Name = Federal Facility Preliminary
Assessment Review) is started when the EPA starts an in-house review of the Federal facility PA or sends a letter, form,
or memo to the EPA contractor requesting review of the Federal facility PA report, and WasteLAN contains the actual
PA start date (Actual Start) and a valid action lead.
Federal Facility PA Revietv Completions - A Federal Facility PA Review (Action Name = Federal Facility Preliminary
Assessment Review ) is completed when:
~The appropriate Regional official signs a letter, form, or memo approving the PA report. The Federal Facility
Preliminary Assessment Review actual completion date is the date the Federal facility PA report is approved;
~WasteLAN contains the actual Federal Facility Preliminary Assessment Review completion date (Actual Complete)
a 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 WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of a Federal facility PA Review. Please refer to
Exhibit A.2 in section A. A. 5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Regions should attempt to complete PA reviews at Federal facility sites listed in the CERCLIS inventory within 18
months of the site discovery completion date. Federal facility PA review starts and completions are reported site-
specifically in WasteLAN. Federal Facility Preliminary Assessment Review starts and completions are program
measures.
If the Federal facility PA report does not provide sufficient information to make a NPL assessment decision, the report
should be referred back to the Federal facility (SubAction Name = Referred back to Fed Fac). The date the report is
referred back to the Federal facility is entered into WasteLAN as the actual completion date (Actual Complete). The
actual completion date and qualifier for the Federal Facility Preliminary Assessment 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Change 7, FY 04/05 SPIM
A-17
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
Data Entry Timeliness Requirement:
SPIM Action/
Activity
SPIM
Documentation
Documentation
Data Must Be Entered
Activity
Type
Lead
Required
Approval/ Date
By
Requirements
Action Name
Program
F, EP,
Start:
Start:
It is good management
= Federal
Mea sure
S, TR
Region begins
practice to enter data
Facility
review of Federal
regarding the event as
Preliminary
facility PA report;
soon as practicable
Assessment
after the event occurs.
Review (RX)
Letter, form, memo;
Signed by region.
However, data must be
entered prior to the end
Technical Direction
Issued to EPA
of the quarter in which
Document (TDD).
contractor or State/
the event occurs.
Tribal government.
Completion:
Completion:
PA Report;
Signed by the
appropriate Regional
Letter, form, or
official
memo approving the
PA report;
Site Decision Form
9100-3 in
W asteLAN or an
equivalent
document.
g. SITE INSPECTIONS (SI) AT NON-FEDERAL FACILITY SITES
Definition:
The SI (Action Name = Site Inspection) 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 may combine PA and SI activities where warranted by site conditions to reduce repetitive tasks and, ultimately
costs. The combining ofPA and SI activities is known as a "Combined PA/SI Assessment" and is discussed in a separate
measure. The decision to perform a "Combined PA/SI Assessment" is made during initial PA activities or even before
a PA is conducted.
Regions have also been encouraged to further reduce repetitive tasks and co sts by combining site assessment and removal
evaluation activities where warranted by site conditions. This "Integrated Removal/Remedial Evaluation" activity is
discussed in a separate measure.
Backlogs
The Site Inspection backlog consists of sites with a Non-NPL Status of either "SI start needed" or "SI ongoing".
Definition of Accomplishment:
SI Starts - A SI (Action Name = Site Inspection) 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 Technical
Direction Document (TDD) is issued to the contractor at a site (refer to OSWER Publication #9345.1-03 FS for further
guidance on defining SI starts) and WasteLAN contains the actual SI start date (Actual Start) and an action lead of:
"Fund-Financed (F)"; "EPA-In House (EP)"; "State (S)"; or "Tribal (TR)". SI start dates are required.
September 8, 2005
A-18
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
SI Completions - A SI (Action Name = Site Inspection) 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, ormemo approving the SI report. The SI actual
completion date is the date the SI report is approved; and
~WasteLAN contains the actual SI completion date (Actual Complete), a valid lead (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 WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the SI. Please refer to Exhibit A.2 in section A.A.5
for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Planning dates are not required for Sis. Actual start and completion dates are required for Sis. SI starts (Actual Start)
and completions (Actual Complete) are reported site-specifically in WasteLAN. Site Inspection starts and completions
at non-Federal Facility sites are program measures.
Regions are responsible for maintaining the accuracy of the non-NPL status for every non-NPL site in the CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must be Entered
By
Action Name =
Site Inspection
(SI)
Program
Measure
F, EP,
S, TR
Start:
Letter, memo, or form
approving the site-
specific SI work plan,
Technical Direction
Document (TDD).
Start:
Signed by EPA or
the State/Tribal
government.
Issued to contractor
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
Completion:
SI Report and signed
letter, form, or memo
approving the SI report.
Site Decision Form
9100-3 in WasteLAN
or an equivalent
document.
Completion:
Signed by
appropriate Regional
official.
event occurs.
Change 7, FY 04/05 SPIM
A-19
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
h. COMBINED PA/SI ASSESSMENTS AT NON-FEDERAL FACILITY SITES
Definition:
Regions are encouraged to combine PA and SI activities where warranted by site conditions to reduce repetitive tasks
and, ultimately, costs. The combining of PA and SI activities is known as a "C ombined PA/SI Assessment". The results
of combined PA/SI assessment can be documented in one physical report, as long as the report contains all of the
elements that would have been addressed under separate PA and SI reports. The report should state specifically that it
covers both the PA and SI. The decision to conduct an SI as part of a combined assessment is made either prior to
initiation of the PA or during initial phases of the PA and is documented in the initial task assignment provided to the
contractor, by correspondence between EPA and the State, or by a form or memo to the file. As is the case with its
individual components, a combined PA/SI is performed to determine what steps, if any, need to occur next at a site.
Regions should employ FAS techniques wherever practical during PA/SI activities.
Regions are also encouraged to further reduce repetitive tasks and costs by combining site assessment and removal
evaluation activities where warranted by site conditions. Combined PA/SI assessments may be applied in an integrated
removal/remedial evaluation approach. Integrated Removal Assessment and Combined PA/SI (ActionName = Int. Rmvl
Assess and Combined PA/SI) activities are entered as one action in WasteLAN and tracked as an internal planning
measure.
Backlogs
The Combined PA/SI Assessment backlog consists of sites having a non-NPL status value of either "Combined PA/SI
start needed" or "Combined PA/SI ongoing."
Definition of Accomplishment:
Combined PA/SI Assessment Starts - A Combined PA/SI Assessment (Action Name = Combined PA/SI) starts when
the region begins collecting data and performing other tasks related to development of the combined PA/SI assessment
report; or when the region signs a letter, form, or memo to the EPA contractor or State/Tribal government (where
applicable) requesting performance of a combined PA/SI assessment at a specific site or group of sites; or when EPA
receives written confirmation from State/Tribal government thatthe State/Tribal government will conduct the combined
PA/SI assessment. The actual start date (Actual Start) of the Combined PA/SI and a valid lead of: "Fund-Financed (F)";
"EPA-In House (EP)"; "State (S)"; or "Tribal (TR)". Start dates are required.
Combined PA/SI Assessment Completions - A Combined PA/SI Assessment is completed when:
~A Combined PA/SI 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, ormemo approving the Combined
PA/SI report. The date the Combined PA/SI report is approved is entered into WasteLAN as the actual completion
date of the Combined PA/SI; and
~The decision is documented by completing the Site Decision Form 9100-3 in WasteLAN, or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the Combined PA/SI Assessment. Please refer to
Exhibit A.2 in section A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Actual start and completion dates are required for combined PA/SIs. Combined PA/SI Starts (Actual start) and
completions (Actual Complete) are reported site-specifically in WasteLAN. Combined PA/SI Assessment starts and
completions at non-Federal Facility sites are program measures.
Regions are responsible for maintaining the accuracy of the non-NPL status for every non-NPL site in the CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system will ask the user to confirm or change
this value as appropriate.
September 8, 2005
A-20
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Combined
PA/SI (NX)
Program
Measure
F, EP,
S, TR
Start:
Letter, form, or memo
requesting a combined
PA/SI;
Written confirmation that
the State/Tribal government
will conduct the PA/SI.
Start:
Signed by the
Region.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Completion:
Combined PA/SI Report;
Letter, form, or memo
approving the PA/SI report;
Site Decision form 9100-3
in WasteLAN or an
equivalent document.
Completion:
Signed by
appropriate
Regional official
i. FEDERAL FA CIUTY COMBINED PA/SI REVIEWS
Definition:
Federal facility PA/SI Reviews (Action Name = Federal Facility PA/SI Review) is an EPA quality assurance review of
a Combined PA/SI report submitted by another Federal agency. EPA's involvement in PA/SI activities at Federal
facilities differs from that at non-Federal facilities. While EPA conducts or funds development of PA/SIs at non-Federal
facilities, EPA's role at Federal facilities is limited to reviewing PA/SI reports developed and submitted by the Federal
agencies responsible for a given Federal facility. Upon reviewing the PA/SI 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.
Definition of Accomplishment:
Federal Facility PA/SI Review Starts - A Federal facility PA/SI review (Action Name = Federal Facility PA/SI Review)
is started when EPA starts in-house review of the Federal Facility PA/SI report, or sends a letter, form or memo to the
EPA contractor requesting review of the Federal facility PA/SI report; and WasteLAN contains the actual Federal
Facility PA/SI Review start date (Actual Start) and a valid lead action.
Federal Facility PA/SI Review Completions - A Federal facility PA/SI Review (Action Name = Federal Facility PA/SI
Review) is completed when:
~The appropriate Regional official signs a letter, form, or memo approving the Federal facility PA/SI report. The date
the Federal facility PA/SI report is approved is entered into W asteLAN as the actual completion date of the Federal
facility PA/SI report; and
~WasteLAN contains the actual completion date (Actual Complete) of the Federal Facility PA/SI Review, a 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 WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the Federal facility PA/SI reviews. Please refer
to Exhibit A.2 in section A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Change 7, FY 04/05 SPIM
A-21
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
Change in Definition FY 02/03 - FY 04/05:
This is a new measure for FY 2005.
Special Planning/Reporting Requirements:
Planning dates are not required for Federal facility PA/SI reviews. Actual start and completion dates are required for
Federal facility PA/SI reviews. Federal facility PA/SI Review starts (Actual Start) and completions (Actual Complete)
are reported site-specifically in WasteLAN. Federal facility PA/SI Review starts and completions are pro gram measures.
If the Federal facility PA/SI report does not pro vide sufficient information to make aNPL assessment decision, the report
should be referred back to the Federal facility (SubAction Name = Referred back to Fed Fac). The date the report is
referred back to the Federal facility is entered into WasteLAN as the actual completion date (Actual Complete). The
actual completion date and qualifier for the Federal Facility PA/SI 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
Federal Facility
PA/SI Review
Program
Measure
F, EP,
S, TR
Start:
Region begins review of
Federal Facility
Combined PA/SI.
Start:
Sent to EPA
contractor.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Completion:
Letter, form, or memo
approving the Federal
Facility PA/SI report;
Site Decision Form 9100-
3 or equivalent document.
Completion:
Signed by
appropriate
Regional official.
j. SITE INSPECTION PRIORITIZA TIONS (SIPS) AT NON-FEDERAL FACILITY SITES
Definition:
SIPs (SubAction Name = Site Inspection Prioritization) require the gathering of additional information to update site
inspections performed under the original Hazard Ranking System (HRS). SIPs are performed only at sites where the last
SI was completed prior to August 1, 1992, and further evaluation is required to determine what steps, if any, need to
occur next at the site. For most regions, the original SIP backlogs have been completed although a few still remain. SIPs
are currently recorded in WasteLAN as SubActions (SubAction Name = Site Inspection Prioritization) to the last
completed site inspection event (Action Name = Site Inspection).
In general, a finite number of sites were originally identified as needing SIPs and EPA has completed SIPs at nearly all
of these sites. Nonetheless, EPA anticipates that a number of older sites addressed under the original HRS, which were
not part of the original universe of sites needing SIPs, may now require SIPs based on new information received by EPA.
This would apply to sites that were evaluated and assigned a NFRAP or Deferred decision under the original HRS prior
to August 1, 1992, for which new information has been provided to EPA indicating further Superfund evaluation of the
site is warranted.
Regions should employ FAS techniques wherever practical during SIP activities.
September 8, 2005
A-22
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Backlogs
The Site Inspection Prioritization backlog consists of sites having a non-NPL status value of either "SIP start needed"
or "SIP ongoing."
Definition of Accomplishment:
SIP Starts - A SIP start is defined as the date the region signs a letter, form, or memo requesting a SIP be performed at
a specific site. The date should be entered into WasteLAN as the actual start date (Actual Start) of the SIP SubAction.
Valid leads for SIPs include: "Fund-Financed (F)"; "EPA In-House (EP)"; "State (S)"; or "Tribal (TR)". SIP start dates
are required, and are used by HQ as a program measure.
SIP Completions - A SIP (SubAction Name = Site Inspection Prioritizations) is complete when:
~A SIP 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 SIP report. The SIP
actual completion date is the date the SIP report is approved; and
~WasteLAN contains the actual SIP completion date (Actual Complete), and a "decision" on whether further activities
are necessary is recorded in the Qualifier field for the SubAction; and
~The decision is documented by completing the Site Decision Form 9100-3 in WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the SIP. Please refer to Exhibit A.2 in section
A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Actual start and completion dates are required for SIPs. SIP starts (Actual Start) and completions (Actual Complete)
are reported site-specifically in WasteLAN. Decisions reached at the conclusion of SIP activities must be recorded with
the SIP SubAction. Site Inspection Prioritization starts and completions at non-Federal facility sites are program
measures.
Regions are responsible for maintaining the accuracy of the non-NPL status for every non-NPL site in the CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
Site Inspection
(SI)
SubAction
Program
Measure
F, EP,
S, TR
Start:
Letter, form, or memo
requesting a site-specific
SIP.
Start:
Signed by region.
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
Name = Site
Inspection
Prioritization
(SH)
Comnletion:
SIP Report; letter, form, or
memo approving the SIP
report;
Site Decision Form 9100-3
in WasteLAN or an
equivalent document.
Comnletion:
Signed by
appropriate
Regional official.
data must be entered prior
to the end of the quarter in
which the event occurs.
Change 7, FY 04/05 SPIM
A-23
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
k. SITE REASSESSMENT
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 action. 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 action 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 WasteLAN, 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 WasteLAN and not as a new Site Reassessment action.
Definition of Accomplishment:
Site Reassessment Starts - A Site Reassessment (Action Name = 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 WasteLAN contains the actual Site Reassessment start date (Actual
Start) and an action lead (Lead) of: "Fund-Financed (F)"; "EPA-In Flouse (EP)"; "State (S)"; or "Tribal (TR)".
Site Reassessments Completions - A Site Reassessment (Action Name = 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 report. The Site Reassessment actual completion date is the date the Site Reassessment report is
approved, and
~WasteLAN contains the actual Site Reassessment completion date (Actual Complete), a valid lead (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 WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the Site Reassessment. Please refer to Exhibit A.2
in section A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Planning dates are not required for Site Reassessment. Actual start and completion dates are required for Site
Reassessment. Site Reassessment starts (Actual Start) and completions (Actual Complete) are reported site-specifically
in WasteLAN. Site Reassessment starts and 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
September 8, 2005
A-24
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action Name =
Site
Reassessment
(OO)
Program
Measure
F, EP,
S, TR
Start:
Letter, memo, or form
approving the site-specific
work plan or a TDD is
issued.
Start:
Signed by the
EPA or
State/Tribal
government.
It is good management
practice to enter data regarding
the event as soon as practicable
after the event occurs.
However, data must be entered
prior to the end ot the quarter
in which the event occurs.
Completion:
Site Reassessment report;
Letter, form, or memo
approving the report;
Site Decision Form 9100-
03, or an equivalent
document.
Completion:
Signed by
appropriate
Regional
official.
/. EXPANDED SITE INSPECTIONS (ESI) A TNON-FEDERAL FA CILITY SITES
Definition:
The ESI (ActionName = Expanded Site Inspection) 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 also have been encouraged to further reduce repetitive tasks and costs by combining site assessment and removal
evaluation activities where warranted by site conditions. This is called an integrated removal/remedial evaluation (Action
Name = Int. Rmvl Assess and Expanded Site Inspection).
Regions should employ FAS techniques wherever practical during ESI activities.
Backlogs
The Expanded Site Inspection backlog consists of sites where the Non-NPL Status is either "ESI start needed" or "ESI
ongoing".
Definition of Accomplishment:
ESI Starts - An ESI (Action Name = Expanded Site Inspection) 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 Document
is issued to the contractor at a site and WasteLAN contains the actual ESI start date (Actual Start) and an action lead
(Lead) of: "Fund-Financed (F)"; "EPA-In House (EP)"; "State (S)"; or "Tribal (TR)".
ESI Completions - An ESI (Action Name = Expanded Site Inspection) 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
~WasteLAN contains the actualESI completion date (Actual Complete), a valid lead (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 WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
A valid decision must be recorded in WasteLAN upon completion of the ESI. Please refer to Exhibit A.2 in section
A A. 5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Planning dates are not required for ESIs. Actual start and completion dates are required for ESIs. ESI starts (Actual
Start) and completions (Actual Complete) are reported site-specifically in WasteLAN. ESI starts and 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action Name =
Expanded Site
Inspection (ES)
Program
Measure
F, EP,
S, TR
Start:
Letter, memo, or form
approving the site specific
work plan or
TDD
Start:
Signed by the
EPA or
State/Tribal
government.
Issued to the
contractor at a
site.
It is good management
practice to enter data
regarding the event as soon as
practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the event
occurs.
Completion:
ESI report;
Letter, form, or memo
approving the ESI report;
Completion:
Signed by
appropriate
Regional official.
Site Decision Form 9100-
3 in WasteLAN or an
equivalent document.
m. FEDERAL FACILITY SI REVIEWS
Definition:
A Federal facility SI Review (Action Name = Federal Facility SI Review) is an EPA quality assurance review of a SI
report submitted by another Federal agency. EPA's involvement in SI activities at Federal facilities differs from that at
non-Federal facilities. While EPA conducts or funds development of Sis at non-Federal facilities, EPA's role at Federal
facilities is limited to reviewing SI reports developed and submitted by the Federal agencies responsible for a given
Federal facility. Upon reviewing the SI 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 SI Review backlog consists of sites with a Non-NPL Status of "FF-SI review needed" or "FF-SI
review ongoing."
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
Federal Facility SI Review Starts - A Federal facility SI review (Action Name = Federal Facility SI Review) is started
when EPA starts in-house review of the Federal Facility SI report, or sends a letter, form, or memo to the EPA contractor
requesting review of the Federal facility SI report; and WasteLAN contains the actual Federal Facility SI Review start
date (Actual Start) and a valid action lead.
Federal Facility SI Review Completions - A Federal facility SI Review (Action Name = Federal Facility SI Review)
is completed when:
~The appropriate Regional official signs a letter, form, or memo approving the Federal facility SI report. The date the
Federal facility SI report is approved is entered into WasteLAN as the actual completion date of the Federal facility
SI report; and
~WasteLAN contains the actual completion date (Actual Complete) of the Federal Facility SI Review, a 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 WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the Federal facility SI reviews. Please refer to
Exhibit A.2 in section A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Planning dates are not required for Federal facility SI reviews. Actual start and completion dates are required for Federal
facility SI reviews. Federal facility SI Review starts (Actual Start) and completions (Actual Complete) are reported site-
specifically in WasteLAN. Federal facility SI Review starts and completions are program measures.
If the Federal facility SI report does not provide sufficient information to make a NPL assessment decision, the report
should be referred back to the Federal facility (SubAction Name = Referred back to Fed Fac). The date the report is
referred back to the Federal facility is entered into WasteLAN as the actual completion date (Actual Complete). The
actual completion 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
Federal Facility
SI Review (TY)
Program
Measure
F, EP,
S, TR
Start:
Region begins review of
Federal Facility SI report.
Start:
Sent to EPA
contractor.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Completion:
Letter, form, or memo
approving the Federal
Facility SI report;
Site Decision Form 9100-
3 or equivalent document.
Completion:
Signed by
appropriate
Regional official.
Change 7, FY 04/05 SPIM
A-27
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
n. FEDERAL FACILITY ESI REVIEWS
Definition:
A Federal facility ESI Review (Action Name = Federal Facility ESI Review) is an EPA quality assurance review of an
ESI report submitted by another Federal agency. EPA's involvement in ESI activities at Federal facilities differs from
that at non-Federal facilities. While EPA conducts or funds development ofESIs at non-Federal facilities, EPA's role
at Federal facilities is limited to reviewing ESI reports developed and submitted by the Federal agencies responsible for
a given Federal facility. Upon reviewing the ESI 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 having a Non-NPL Status of "FF-ESI review needed" or FF-
ESI review ongoing".
Definition of Accomplishment:
Federal Facility ESI Review Starts - A Federal facility ESI review (Action Name = Federal Facility ESI Review) is
started when EPA starts in-house review of the Federal Facility ESI report, or sends a letter, form, or memo to the EPA
contractor requesting review of the Federal Facility ESI report; and WasteLAN contains the actual Federal Facility ESI
Review start date (Actual Start)and a valid action lead.
Federal Facility ESI Review Completions - A Federal Facility ESI Review (Action Name = Federal Facility ESI
Review) is completed when:
~The appropriate Regional official signs a letter, form, or memo approving the Federal facility ESI report. The date
the Federal facility ESI report is approved is entered into WasteLAN as the actual completion date of the Federal
Facility, ESI report; and
~WasteLAN contains the actual completion date (Actual Complete) of the Federal Facility ESI Review, a lead (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 WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the Federal facility ESI reviews. Please refer to
Exhibit A.2 in section A. A. 5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Planning dates are not required for Federal facility ESI reviews. Actual start and completion dates are required for
Federal facility ESI reviews. Federal Facility ESI Review starts (Actual Start) and completions (Actual Complete) are
reported site-specifically in WasteLAN. Federal Facility ESI Review starts and completions are program measures.
If the Federal facility ESI report does not provide sufficient information to make a NPL assessment decision, the report
should be referred back to the Federal facility (SubAction Name = Referred back to Fed Fac). The date the report is
referred back to the Federal facility is entered into WasteLAN as the actual completion date (Actual Complete). 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
September 8, 2005
A-28
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
Federal Facility
ESI Review
(TZ)
Program
Measure
F, EP,
S, TR
Start:
Region begins review of
Federal Facility ESI
report.
Start:
Sent to EPA
contractor.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Completion:
Letter, form, or memo
approving the Federal
Facility ESI report;
Site Decision Form 9100-
3 or equivalent document.
Completion:
Signed by
appropriate
Regional official.
o. INTEGRA TED EXPANDED SITE INSPECTION/REMEDIAL INVESTIGA TION
(ESI/RI) AT NON-FEDERAL FACILITY SITES
Definition:
The integrated ESI/RI (Action Name = 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 needed. The RI portion of an ESI/RI is intended to be a site-wide
activity. ESI/RIs actions should be entered into WasteLAN 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 RI/FS Completion and RI Completion (see
definitions in Appendix B) 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 action is recorded in WasteLAN, a stand-alone ESI
event (Action Name = Expanded Site Inspection) should not be recorded at that site.
Regions are also encouraged to further reduce repetitive tasks and costs by combining site assessment and removal
evaluation activities where warranted by site conditions. This is called an integrated removal/remedial evaluation (Action
Name = Int Rmvl Assess and ESI/RI) and is further discussed in a separate section below.
Backlogs
The ESI/RI backlog consists of sites with a Non-NPL Status of either "Integrated ESI/RI start needed" or "Integrated
ESI/RI ongoing".
Definition of Accomplishment:
ESI/RI Starts - ESI/RI (Action Name = ESI/RI) start date is defined as the date when EPA approves the site-specific
ESI/RI work plan and WasteLAN contains the actual ESI/RI start date (Actual Start) and an action lead of: "Fund-
Financed (F)"; "EPA-In House (EP)"; "State (S)"; or "Tribal (TR)".
ESI/RI Completions - An ESI/RI (Action Name =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 WasteLAN: the actual ESI/RI completion date (Actual Complete); a valid lead
(Lead); and a "decision" on whether further activities are necessary in the Qualifier field; and
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
~The decision is documented by completing the Site Decision Form 9100-3 in WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the ESI/RI. Please refer to Exhibit A.2 in section
A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Planned start and completion dates are not required for ESI/RIs. Actual start and completion dates are required for
ESI/RIs. ESI actions (Action Name = Expanded Site Inspection) should not be recorded separately in WasteLAN if they
are conducted as part of an ESI/RI. ESI/RI starts and completions at non-Federal Facility sites are program measures.
Regions are responsible for maintaining the accuracy of the non-NPL status for every non-NPL site in the CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
ESI/RI : SS
Program
Measure
F, EP,
S, TR
Start:
Site-specific ESI/RI work
plan.
Start:
Approved by EPA.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Completion:
Letter, form, or memo
approving the ESI/RI
report;
Site Decision Form 9100-
3, or an equivalent
document.
Completion:
Signed by
appropriate
Regional official.
p. STATE DEFERRAL OF NON-FEDERAL FACILITY SITES
Definition:
State Deferral (Action Name = State Deferral) is an administrative mechanism enabling States and Tribes, under their
own laws, to respond at sites in the CERCLIS 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.
Backlogs
The State Deferral backlog consists ofCERCLIS sites with a Non-NPL Status of "Deferral of NPL listing decision while
States oversee response".
Definition of Accomplishment:
State Deferral Starts - The State Deferral (Action Name = 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
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
the terms established in the deferral guidance. A State Deferral action must be recorded in WasteLAN with an action
lead (Lead) of "State Deferral (SD)". State deferrals are applicable only to non-Federal facility sites that are not on
the NPL.
State Deferral Completions The State Deferral (Action Name = 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 WasteLAN upon completion of the State Deferral. Please refer to
Exhibit A.2 in section A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Six SubActions can be entered for the State Deferral action to generically capture the different cleanup phases a site may
be undergoing. These SubActions include:
1. Comprehensive Site Investigation (SubAction Name = Comprehensive Site Investigation)
2. Remedy Selection (SubAction Name = Remedy Selection);
3. Design (SubAction Name = Design);
4. Construction (SubAction Name = Construction); and
5. Post-Construction Maintenance (SubAction Name = Post Construction Maintenance)
6. Short Term Cleanup (SubAction Name = Short Term Cleanup)
SubAction start and completion dates and SubAction 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.
Planned start and completion dates are not required for State Deferral actions. Actual start and completion dates are
required. Sites successfully completing the deferral process are eligible for archiving (removal) from the CERCLIS
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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
State Deferral
(AQ)
Program
Measure
SD
Start:
Document deferring the site
to the State.
Start:
Signed by Regional
Superfund program
director and State
program director.
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
Completion:
Formal regional document
confirming that the deferral
has been completed
successfully, or terminating
the deferral agreement; or
State certification that the
deferral has been completed.
Completion:
Signature
Received by EPA.
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
q. HAZARD RANKING SYSTEM PACKAGE (HRS)
Definition:
The HRS Package (Action Name = 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 Hazard Ranking System (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 the next steps, if
any, are appropriate for a site (e.g., NPL listing, NFRAP, etc.)
Backlogs
The HRS backlog consists of sites having Non-NPL Status of either "HRS start needed" or "HRS ongoing".
Definition of Accomplishment:
HRS Package Starts - An HRS Package (Action Name = 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 WasteLAN contains the actual
HRS Package start date (Actual Start) and a valid action lead of "Fund-Financed (F)"; "EPA-In House (EP)"; "State
(S)"; or "Tribal (TR)". HRS Package start 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 (Action Name = 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 WasteLAN: the approval date for the final version of the HQ QA reviewed (if
submitted to HQ) or regional QC reviewed (if not submitted to HQ) HRS Package date as the actual HRS Package
completion date (Actual Complete), a lead (Lead), and a "decision" on whether further activities are necessary in the
Qualifier field. Since HRS packages are pre-decisional, entry of HRS Package completion dates in WasteLAN may
be delayed until after the site is proposed to the NPL, if applicable; and
~The decision is documented by completing the Site Decision Form 9100-3 in WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
Note: Submission of HRS Packages to HQ for technical assistance does not represent an HRS Package completion.
A valid decision must be recorded in WasteLAN upon completion of the HRS Package. Please refer to Exhibit A.2 in
section A. A. 5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Planned start and completion dates are not required for HRS Packages. Actual start and completion dates are required
for HRS Packages. HRS Package starts and completions at both Federal and non-Federal Facilities are program
measures.
Regions are responsible for maintaining the accuracy of the non-NPL status for every non-NPL site in the CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
September 8, 2005
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Change 7, FY 04/05 SPIM
-------
for this field based on the traditional sequence of site assessment work,
appropriate.
OSWER Directive 9200.3-14-1G-Q
Regions must confirm or change this value as
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
HRS Package
(HR)
Program
Measure
F, EP,
S, TR
Start:
Letter, form, or memo
requesting site specific
development of a HRS
Package
Start:
EPA signature.
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
Completion:
Site Decision Form 9100-
3, or an equivalent
document.
Completion:
Signed by
appropriate
Regional official.
r. INTEGRATED REMOVAL/REMEDIAL EVALUATION
Definition:
Integrated Removal/Remedial Evaluations are actions integrating both site assessment (e.g., Preliminary Assessment,
Site Inspection) and removal assessment activities to reduce the overall time and money spent characterizing site
conditions. The scope of the Integrated Removal/Remedial Evaluation will depend on which activities are being jointly
conducted. Seven specific types of Integrated Removal/Remedial Evaluations will be tracked:
~Integrated Removal Assessments and Preliminary Assessments (Action Name = Int Rmvl Assess and Preliminary
Assessment);
~Integrated Removal Assessments and Site Inspections (Action Name = Int Rmvl Assess and Site Inspection);
~Integrated Removal Assessments and Combined PA/SI (Action Name = Int Rmvl Assess and Combined PA/SI);
~Integrated Removal Assessments and Expanded Site Inspections (Action Name - Int. Rmvl Assess and Expanded Site
Inspection);
~Integrated Removal Assessments and Hazard Ranking System (Action Name = Int. Rmvl Assess andHRS Package);
~Integrated Removal Assessments and ESI/RI (Action Name = Int. Rmvl Assess and ESI/RI); and
~Integrated Removal Assessments and Site Inspection Prioritizations (SubAction Name = Int Rmvl Assess and Site
Inspection Prioritization).
Regions are encouraged to make use of integrated assessment approaches wherever appropriate. Requirements of site
assessment actions (e.g., PA, SI) and removal assessments must still be met, even though they are conducted in an
integrated fashion. Refer to appropriate sections of the SPIM and Superfund assessment guidance documents for further
requirements of stand-alone assessment activities. The definitions and special planning/reporting requirements for all
seven types of Integrated Removal/Remedial Evaluations listed above follow the same general concept. Generic
definitions and requirements are provided below.
For more information on Integrated Removal/Remedial Assessments, please see OSRTI's Quick Reference Guidance
Series document titled: "Improving Site Assessment: Integrated Removal and Remedial Site Evaluations" OSWER
9360.0-39FS, PB99-963314; dated April 2000.
Regions should employ FAS techniques wherever practical during Integrated Removal/Remedial Evaluation activities.
Backlogs
The Integrated Removal/Remedial Evaluation backlog consists of sites having a Non-NPL Status of "Integrated
Removal/Remedial evaluation needed" or "Integrated Removal/Remedial evaluation ongoing".
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
Starts - An Integrated Removal/Remedial Evaluation (Action Name = Int. Rmvl Assess and Preliminary Assessment,
Int. Rmvl Assess and Site Inspection, Int. Rmvl Assess and Expanded Site Inspection, Int. Rmvl Assess and Combined
PA/SI, Int. Rmvl Assess andESI/RI, and Int. Rmvl Assess and HRS Package) and (SubactionName = Int. Rmvl Assess
and Site Inspection Prioritization) start date is defined as the date when EPA approves the site-specific Integrated
Removal/Remedial Evaluation work plan (e.g., Removal Assessment and SI work plan) and WasteLAN contains:
~The actual Integrated Removal/Remedial Assessment start date (Actual Start) and an action lead (Lead) of: "Fund-
Financed (F)"; "EPA-In House (EP)"; "State (S)"; or "Tribal (TR)"; and
Completions - An Integrated Removal/Remedial Evaluation (Action Name = Int. Rmvl Assess and Preliminary
Assessment, Int. Rmvl Assess and Site Inspection, Int. Rmvl Assess and Expanded Site Inspection, Int. Rmvl Assess and
Combined PA/SI, Int. Rmvl Assess and ESI/RI, and Int. Rmvl Assess and HRS Package) and (Subaction Name = Int.
Rmvl Assess and Site Inspection Prioritization) is complete when:
~The Integrated Removal/Remedial Evaluation report has been reviewed and accepted by the region and an appropriate
Regional official signs a letter, form, or memo approving the report. The report must contain all of the information
required for the related site assessment and must document the completion of a Removal Assessment to determine
whether a removal action is necessary. A note to the site file must also be prepared indicating that the Integrated
Removal/Remedial Evaluation report meets all the requirements for the related assessment activities; and
~The Integrated Removal/Remedial Evaluation report approval date is entered into WasteLAN as the actual Integrated
Removal/Remedial Assessment completion date (Actual Complete) with a valid lead (Lead); and
~The decision is documented by completing the Site Decision Form 9100-3 in WasteLAN or an equivalent document.
The decision document must be printed, signed by the appropriate Regional official, and placed in the file.
A valid decision must be recorded in WasteLAN upon completion of the PA. Please refer to Exhibit A.2 in section
A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Planning dates are not required for Integrated Assessments. Actual start and completion dates are required for Integrated
Assessments. Integrated Assessment action qualifiers are required. Integrated Removal Assessment and PA, Integrated
Removal Assessment and Site Inspection, Integrated Removal Assessment and Combined PA/SI , Integrated Removal
Assessment and E xpanded Site Inspection, Integrated Removal Assessment and S ite Inspection Prioritization, Integrated
Removal Assessment and ESI/RI and Integrated Removal Assessment and HRS Package starts and completions at non-
Federal facilities are program measures.
Regions are responsible for maintaining the accuracy of the non-NPL status for every non-NPL site in the CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
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Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
Int Rmvl Assess
and Preliminary
Assessment
(QT)
Int Rmvl Assess
and Site
Inspection (Q.T)
Int Rmvl Assess
and Combined
PA/SI (OU)
Int Rmvl Assess
and Expanded
Site Inspection
(OY)
Int Rmvl Assess
and HRS
Package (OZ)
Int Rmvl Assess
and ESI/RI
(OV)
Int Rmvl Assess
and SIP (QO)
Program
Measure
F, EP,
S, TR
Start:
Site-specific Integrated
Removal/Remedial
Evaluation work plan
(e.g., Removal
Assessment and SI work
plan);
Start:
EPA approval.
Completion:
Letter, form, or memo
approving the Integrated
Removal/Remedial
Evaluation report; or
Note indicating that the
report meets the
requirements for the
related assessment
activities;
Decision Fonn 9100-3, or
an equivalent document.
Completion:
Signed by
appropriate
Regional official.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
v. NPL LISTING
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 Hazard Ranking System (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 28.50 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.
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Backlogs
In general, the backlog for proposing sites to the NPL consists of sites having a Non-NPL Status of "HRS Package
Completed - Further Evaluation Needed".
Definition of Accomplishment:
Proposed NPL Listing - The process of proposing a site for placement on the NPL is complete (Actual Complete date)
when a Proposed Rule proposing the site to the NPL [Action Name = Proposal to NPL] is published in the Federal
Register.
Removal of Proposed NPL Listing - The process of removing a site from the list of proposed NPL sites starts (Actual
Start date) when a proposal to remove the site is published in the Federal Register and is complete (Actual Complete
date) when final notice of the removal is published intheFederal Register [Action Name = Removed from the Proposed
NPL],
FinalNPL Listing - The listing process for a site is complete (Actual Complete date) when a Final Rule adding the site
to the NPL [Action Name = Final Listing on NPL] is published in the Federal Register.
Withdrawn from the FinalNPL - The process of withdrawing a site is complete (Actual Complete date) when a Final
Rule withdrawing the site [Action Name - Withdrawn from the NPL] is published in the Federal Register.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
The following data are to be entered into WasteLAN:
Regional Responsibility
Regions are responsible for entering the following site-related information.
- Site name (Listing Site Name will not be editable)
- EPA Site ID
- Street Address
- City
- County
- State
- Zip Code
- Region
- Congressional district
- Regional Latitude and Longitude
HQ Responsibility
The NPL listing Actions (Proposal to NPL, Removed from Proposed NPL, Final Listing on NPL, and Withdrawn
from the NPL;
The actual completion date for these actions;
An action lead of Fund-financed (F);
The NPL Status of "Proposed for NPL (P)", Removed from list of proposed NPL sites (R)", "Currently on Final
NPL (F)", "Withdrawn from NPL (W)", and "Deleted from the NPL (D)";
The Federal Register citation;
The Federal facility status; and
Federal Register dates.
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NOTE:
Further information on Deletion and Partial Deletion from the NPL can be found in Appendix B of this Manual. NPL
Listing is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action name =
Proposal to
NPL (NP)
Program
Measure
F
Proposed Rule proposing
the site to the NPL.
Published in the
Federal Register.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. Flowever, data must
be entered prior to the end of
the quarter in which the
event occurs.
Removed from
the Proposed
NPL (NR)
Start:
Proposal to remove the
site.
Complete:
Final notice of the
removal.
Final Listing on
the NPL (NF)
Final Rule adding the site
to the NPL.
Withdrawn from
the NPL (TW)
Final Rule withdrawing
the site.
t. OTHER CLEANUP ACTIVITY (OCA)
Definition:
This action is used to document cleanup work at non-NPL sites being conducted by non-EPA parties without EPA
enforcement or oversight.
Definition of Accomplishment:
OCA Starts - An OCA (Action Name = Other Cleanup Activity) start date is defined as the date EPA acknowledges
that the site is being cleaned up by a non-EPA party as supported by documentation between EPA and the non-EPA party
leading the cleanup. Valid leads for Other Cleanup Activity are: State Enforcement (SE), PRP Lead Under State (SR),
State (S), No Fund Money (SN), Tribal (TR), Federal Facility (FF), PRP Response Under State (PS), and PRP (RP).
OCA FADs - The site has been cleaned up or is making progress toward cleanup as supported by written
documentation (work sharing agreement, site specific progress report, AOC, remedial action plan, VCP/other MOA,
etc.) between the non-EPA party and EPA stating that the site has been or is being cleaned up according to
appropriate cleanup standards.
OCA Completions - An OCA (Action Name = Other Cleanup Activity) completion date is defined as the date EPA
receives documentation from the non-EPA party that the site has been cleaned up in accordance with all applicable
standards and requirements. The date the documentation is received is entered into WasteLAN as the actual completion
date of the OCA;
and
The decision is documented by completing the Site Decision Form 9100-3 in WasteLAN, or an equivalent document.
The decision document must be printed, signed by the appropriate regional official, and placed in the site file.
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Valid decisions to be recorded in W asteLAN upon completion of the OCA include:.
(H) - High - Higher priority for further assessment; or
(L) - Low - Lower priority for further assessment; or
(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
(F) - Referred to the removal program with further remedial assessment needed; or
(W) - Referred to the removal program with no further remedial assessment needed.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
The following six SubActions can be entered under the Other Cleanup Activity Action to generically capture the
different cleanup phases a site may be undergoing.
1. Comprehensive Site Investigation (SubAction Name = Comprehensive Site Investigation)
2. Remedy Selection (SubAction Name = Remedy Selection);
3. Design (SubAction Name = Design);
4. Construction (SubAction Name = Construction);
5. Post-Construction Maintenance (SubAction Name = Post Construction Maintenance); and
6. Short Term Cleanup (SubAction Name = Short Term Cleanup).
SubAction start and completion dates and SubAction 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 action qualifiers are available for these SubActions:
(H) - High - Higher priority; and
(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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action name =
Other Cleanup
Activity (VA)
Program
Measure
SE, SR,
S, SN,
TR, FF,
PS, RP
Start:
Documentation between
EPA and the non-EPA
party leading the
cleanup.
Start:
EPA acknowledges
the site is being
cleaned up by a non-
EPA party.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Completion:
Date the non-EPA
party completes/
completed cleanup
work at a non-NPL
site.
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A. II SUBJECT MATTER EXPERTS
The following table identifies the subject matter experts for Appendix A: Site Assessment and NPL Listing Decisions.
EXHIBIT A 3 SUBJECT MATTER EXPERTS
Subject Matter Expert
Subject Area
Phone #
Randy Hippen
Site Assessment/NPL Listing
(703) 603-8829
Robert White
SPIM Lead
(703) 603-8873
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Superfiind Program Implementation Manual FY 04/05
Appendix B: Response Actions
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Appendix B
Response Action
Table of Contents
B.A Current Program Priorities - B-l
B.A. 1 Protecting Human Health and the Environment B-l
a. Removal Actions B-l
b. Homeland Security B-l
c. Pipeline Management Review/RA Construction B-2
d. Post Construction B-4
e. Superfund Alternative Sites B-5
B.A.2 Maximizing Program Efficiency and Effectiveness B-6
a. Innovative Technologies B-6
b. Contract Management B-7
c. Redevelopment B-7
d. Reforms B-8
B.B FY 04/05 RESPONSE TARGETS AND MEASURES B-8
B.B.I Overview of FY 04/05 Response Actions Targets/Measures B-8
B.B.2 Superfund Durations B-9
B.B.3 Record of Decision B-12
a. ROD Changes B-12
i. Other Remedy Changes B-12
ii. Explanation of Significant Differences (ESDs) B-12
iii. ROD Amendments B-l3
b. RODs Requiring No Physical Construction B-13
B.B.4 Response Action Definitions B-14
Part I. Remedy Selection
a. Remedial Investigation (RI) Starts (NPL & Superfund Alternative) B-14
b. Feasibility Study (FS) Starts (NPL & Superfund Alternative) B-17
c. Combined RI/FS Start (NPL & Superfund Alternative) B-20
d. Treatability Studies B-24
e. Start of Public Comment Period (Proposed Plan to Public) (NPL &
Superfund Alternative) B-24
f. RI/FS Duration (NPL & Superfund Alternative) B-25
g. Engineering Evaluation/Cost Analysis (EE/CA) B-26
h. Decision Document Developed B-27
i. Final Remedy Selected B-29
Part II. Remedial Implementation
j. Removal Starts and Removal Completions THESE MEASURES HAVE
BEEN MOVED TO APPENDIX M 15-30
k. Remedial Design (RD) Start (NPL & Superfund Alternative) B-30
1. RD Completion (NPL & Superfund Alternative) B-33
m. Remedial Action (RA) Start (NPL & PRP-lead Superfund Alternative) . . . B-34
n. RA Contract Award (NPL & PRP-lead
Superfund Alternative) B-39
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o. Start of On-Site Construction B-40
Groundwater Monitoring B-41
p. Operational and Functional (O&F) B-44
q. Completion of a Response Action/Activity (NPL & PRP-lead
Superfund Alternative) B-45
r. NPL Site Construction Completions B-48
Part III. Post Construction Completion
s. Long-Term Remedial Response (LTRA and PRP LR) (NPL & PRP-
lead Superfund Alternative) B-52
t. Operation and Maintenance (O&M) B-54
u. Cleanup Goals Achieved B-55
v. NPL Site Completions B-56
w. Five-Year Reviews B-57
x. Partial NPL Deletion B-59
y. Final NPL Deletion B-60
z. Sites with Land Ready for Reuse B-61
aa. Acres at Sites with Land Ready for Reuse B-63
Part IV. Environmental Indicators
bb. Long-Term Human Health Protection Indicator B-64
cc. Migration of Contaminated Ground Water Under Control B-67
dd. Populations Protected B-69
ee. Cleanup Volumes B-70
Part V. Support Activities
ff. Support Agency Assistance B-71
gg. Technical Assistance B-72
hh. Pre-design Assistance B-72
B.C SUBJECT MATTER EXPERTS B-74
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OSWER Directive 9200.3-14-1G-Q
Appendix B
Response Action
Targets and Measures
List of Exhibits
EXHIBIT B.l RESPONSE ACTION ACTIVITIES B-10
EXHIBIT B.2 LONG-TERM HUMAN HEALTH PROTECTION INDICATOR B-66
EXHIBIT B.3 SUPERFUND MIGRATION OF CONTAMINATED GROUND WATER
UNDER CONTROL WORKSHEET B-68
EXHIBIT B.4 SUBJECT MATTER EXPERTS B-74
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APPENDIX B
RESPONSE ACTIONS
OSWER Directive 9200.3-14-1G-Q
B.A CURRENT PROGRAM PRIORITIES
B.A. 1 Protect Human Health and the Environment
Protection of human health and the environment remains the highest priority for the Superfund Program. 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.
a. Removal Actions
The goal of EPA's emergency response and removal program is to provide quick response to immediate
threats to public health and the environment from releases of hazardous substances whenever and wherever they
occur.
EPA will continue to enhance its emergency response infrastructure through procurement of state-of- the-art
response equipment and continued training and exercising of response personnel. EPA will also ensure that the
appropriate resources and contract vehicles are available to conduct necessary removal actions.
b. Homeland Security
EPA played a crucial role in response to the terrorist attacks of September 11, 2001, particularly, through its
emergency response program. In FY 2004, the Agency will improve its ability to respond effectively to terrorist-
related chemical, biological, and radiological incidents. These enhancements will be achieved through continued
improvement of national coordination and decision-making for large-scale incidents; improved field response
capabilities in EPA Regions through better-trained responders and improved specialized equipment; improved
capabilities of National Response System (NRS) special forces such as the Environmental Response Team (ERT)
and the National Decontamination ("Decon") Team; and improved coordination with and enhancement of other
response agencies.
In FY 2004 Homeland Security activities will continue to concentrate on implementing recommendations in
the September 11 Lessons Learned Report. Efforts will include improving the operations of the National Incident
Coordination Team which serves that EPA focal point for coordinating response efforts and handling cross-program
and multi-program issues before and during terrorist incidents. The program will also continue to upgrade the EPA
Emergency Operations Center and coordinate development of a comprehensive EPA Continuity of
Operations/Continuity of Government plan that can be immediately activated when a catastrophic emergency occurs.
EPA's field response capability relies on a support infrastructure including specialized equipment, equipment
inventories, and laboratory support. The Agency will continue to build on its equipment support by identifying state-
of-the-art detection, monitoring, and response equipment designed to address chemical, biological, and radiological
agents. Also, EPA will build inventories of standard response equipment such as personal protective gear to ensure
that it is prepared to respond to multiple incidents. Equipment will be maintained and replaced as necessary to
ensure the Agency has the best technology available.
EPA's field responders and National Response System special forces require extensive training in a variety of
response-related areas, including scientific and technical training for detection, analysis, and response to chemical,
biological, and radiological agents; and training in incident command system response management processes.
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OSWER Directive 9200.3-14-1G-Q
Training courses will be developed and implemented for different levels of response experience and involvement,
including refresher courses for senior, experienced responders; in-depth training for newer responders in both
scientific and response management areas; and training for all responders in state-of-the-art response techniques and
emerging chemical, biological, and radiological threats.
EPA's Environmental Response Team (ERT) will continue to provide specialized field support to Regional
responders, including specialized air monitoring, health and safety support, and other scientific and technical
support. ERT will continue to enhance its capabilities in its Edison, New Jersey, Cincinnati, Ohio, and Las Vegas,
Nevada, locations to ensure that they are ready at all times to quickly and effectively meet the specialized field
support needs of EPA's responders, including those responses to terrorist incidents with biological, chemical, and
radiological agents.
EPA will continue the development of the National Response Decontamination Team (Decon Team) that
provides unique, immediate response capabilitiesto safely and effectively support decontaminationactivities related
to chemical, biological, and radiological terrorism events. While focused domestically, the Decon Team may
respond worldwide delivering scientific and engineering expertise for the decontamination of buildings, building
contents, public infrastructure, indoor environments and the associated environmental media. The primary function
of the Decon Team is to support EPA OSCs conducting or overseeing response activities under the authorities of
the National Contingency Plan (NCP) at the scene of the aftermath of a weapon of mass destruction (WMD) event.
The Decon Team is designed to integrate with and operate from within incident command structures, along with and
complementing other Special Forces. When not fully engaged, this team is devoted to preparedness activities related
to the team's primary function.
EPA's capability to respond effectively to chemical, biological, and radiological incidents will be measured
through the Core Emergency Response (Core ER) program. This continued enhancement in EPA's Regional
response capabilities will cover all aspects of the Core ER program, including Regional Response Centers,
transportation, coordination with backup Regions, health and safety, delegation and warrant authorities, response
readiness, response equipment, identification clothing, training and exercises, and outreach. The Agency will
establish measurable improvement goals in Core ER and will work toward that improvement through exercises and
other program enhancements.
EPA has established a criteria of excellence through the structure of the Core ER program. While EPA is
currently prepared to respond to chemical, biological, and radiological incidents, improvement in the emergency
response and homeland security readiness measure will demonstrate an increased ability to respond quickly and
effectively to national-scale events. The FY 2004 Core ER target is to improve emergency response and homeland
security readiness by 10% from the FY 2003 baseline performance.
c. Pipeline Management Review/RA Construction
The Agency initiated the Superfund Pipeline Management Review (PMR) during FY 2002 to evaluate and
address the reduction in construction completions during FY 2001 and the potential shortfall of remedial action
funding in FY 2002 and the out years. The purpose of the PMR is to ensure that Agency resources are properly
focused to achieve maximum results, including protection of human health and the environment, as well as, progress
towards completion of response actions at sites.
As of January 1, 2003, Superfund has 1,499 final and deleted sites on the NPL, of which approximately 650
require response actions (also called construction) to achieve protection of human health and the environment. As
the program has matured, more sites have advanced to the construction phase. Superfund construction projects are
technically complex and costly, and the growth in the number, size, duration and cost of these projects over time
has resulted in a backlog of construction projects awaiting funding. Superfund cleanups directly support the Agency
goal of ensuring that the Nation's land is protected.
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OSWER Directive 9200.3-14-1G-Q
Construction completion has been the primary performance measure for the Superfund program and the
Agency remains committed to completing construction at Superfund sites. The program achieved 42
construction completions during FY 2002, for a total of 846 completions since the inception of the program.
EPA projections indicate that construction completion accomplishments are likely to remain at approximately 40
during FY 2004. Since the beginning of the program, the Agency has averaged 42 construction completions per
year. Through the PMR, EPA is increasing the precision with which it tracks construction completion
candidates and projects future construction completion achievements, extending the planning horizon for
making funding decisions for Superfund construction projects, and implementing new policies and actions to
maximize the use of resources available for construction. The Agency has moved to a three year planning cycle
to identify and track construction completion candidate sites. EPA continues to closely follow site progress and
identify potential critical points as sites move toward construction completion.
Starting in FY 2003, as part of the three year cycle for construction completion planning and tracking, the
Agency will regularly conduct detailed and comprehensive reviews of construction completion candidates for the
current year and the following two years. The information collected from the discussions will be added to the
tracking system to better follow site progress, identify potential problems, and sharpen projections of future
construction completions.
Funding for Superfund construction projects is critical to achieving risk reduction and construction completion
measures. Although funding levels for the program have remained relatively stable in recent years, the cost of the
Superfund construction projects underway and those awaiting funding is increasing. As a result, a backlog of
projects ready to begin construction; but awaiting funding has developed.
Through the PMR, the Agency is continuing the following internal actions to address the shortfall in funding:
1. Review the scope, budget and schedule of ongoing construction projects to ensure available
resources are directed where they are immediately needed,
2. Review construction start candidates to ensure that sites that present an immediate risk to human
health are addressed, while balancing the programmatic need to complete construction at other
sites,
3. Emphasize "enforcement first" to maximize the involvement of responsible parties to conduct
cleanups, and
4. Aggressively pursue alternative sources of funding to supplement annual appropriations. Alternate
sources of funds include unexpended funds in program contracts and other funding agreements,
and responsible party settlement resources that are available and can be used to finance response
actions. EPA will use deobligated funds for remedial work at high priority sites.
The first priorities for response funding are classic emergencies and actions necessary to address immediate
threats to human health. Ongoing RAs, mixed funding, and mixed work projects receive priority for funding over
new cleanup work. New Fund-financed cleanup work (with the exception of emergency and time-critical removal
actions) will be subject to priority ranking by the National Risk-Based Priority Panel and will be screened to ensure
actions have been taken to compel all appropriate PRPs to conduct the cleanup. The Panel consists of
representatives from each region and F1Q (O SRTI and O SRE) and utilizes a risk-based environmental priority setting
approach. New cleanup work is funded based on actual or potential risks to human health and the environment as
well as the need to maintain construction progress. Determination on whether a project represents new or ongoing
work will be made by the Panel. New cleanup work consists of large removal actions that exceed funding levels
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OSWER Directive 9200.3-14-1G-Q
available within a region's baseline removal budget, as well as cleanup construction activities at sites. The panel
meets one or more times a year for evaluation of projects.
d. Post Construction
As a result of the increase in construction completion sites, the post construction workload required to ensure
thatthe Superfund response actions remain protective for human health and the environment also is increasing. Post
construction encompasses a number of discrete but related activities including: F ive Y ear Reviews; implementation,
monitoring and enforcement of institutional controls; operation and maintenance and long-term response actions;
optimization of remedies; and deletion of sites from the NPL. EPA, states, Federal facilities, PRPs, local
governments and communities all play an integral role in performing post construction activities. External
stakeholder interest in post construction activities is high. The EPA Inspector General has completed reviews of
the program's Five Year Review performance and corrective actions have been identified and implemented.
Resources for the Future (RFF) and other external organizations have completed research studies on long term
stewardship. In its report "Superfund's Future: What Will It Cost?", RFF is critical of the Agency's post
construction efforts, particularly in the quality of Five Year Re view reports and the implementation and management
of institutional controls.
Five Year Reviews are required by statute and program policy, generally when residual contamination remains
on site after cleanup. Five Year Reviews provide an opportunity to evaluate remedies, correct problems or
deficiencies, and adjust operations and maintenance where necessary. Five Year Reviews have been completed at
approximately 1000 sites as of October 2002. Between 150 and 180 reviews per year are scheduled over the next
several years. The Agency committed to eliminate the backlog of overdue reviews by the end of 2002 and achieved
this goal. Revised guidance on conducting Five Year Reviews was issued in June 2001 and training has been
provided to all regions with the goal of improving the quality of the Five Year Reviews and the resulting reports.
Institutional controls are administrative and/orlegal mechanisms intended to minimize the potential for exposure
to contamination and protect the integrity of a remedy. Examples of institutional controls include zoning
restrictions, excavation and building permits, easements, covenants, deed notices, and advisories. Although
institutional controls are recognized as critical remedy components, the challenge is that they are often implemented,
monitored and enforced by an entity other than those responsible for the cleanup. As a matter of policy, institutional
controls are necessary if a site cannot support unrestricted use and unlimited exposure due to residual contamination
and/or the presence of engineered remedy components that may be damaged by uncontrolled future site activities.
Institutional controls can be used at any point in the cleanup, however, implementation frequently lags behind the
completion of physical remediation. Institutional controls do not need to be in place to achieve construction
completion, however, delays in implementing institutional controls will impact the ability to delete sites from the
NPL. Guidance has been developed to aid with the identification, evaluation and selection of institutional controls
and guidance is being developed on the implementation, monitoring and enforcement of institutional controls;
estimating the costs of institutional controls; and planning for institutional controls. In addition, materials for
community stakeholders and an institutional control tracking system are under development.
Operation and maintenance (O&M) is an important component of a Superfund response to ensure that the
remedy performs as intended. Actions range from maintaining engineering containment structures (e.g., landfill
covers) to operating groundwater remediation systems. O&M is the responsibility of the Federal facility, PRP or
state. EPA is responsible for assuring that the work is adequately performed for the life of the project. One
exception is for Fund-financed groundwater remediation systems where EPA retains operating responsibility for up
to ten years (called Long Term Response Actions (LTRA)) prior to transferring the system to the state. Many sites
are nearing the end of the ten year period and regions must prepare these sites for transfer. A guidance summarizing
best practices is under development.
April 7, 2003
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Once groundwater remediation systems have been operating, opportunities may exist to optimize or more
efficiently operate the system. EPA has conducted pilot optimization studies and preliminary results indicate a
potential to improve system performance and reduce costs. Once implemented, optimization reviews should provide
assurances that these systems are operating efficiently prior to transfer to the state for long term operations.
Optimization protocols also can be made available to PRPs and Federal facilities.
Sites can be deleted from the NPL once all response actions are complete, including implementation of
institutional controls, and all cleanup levels have been achieved. As of October 2002, 265 sites were deleted from
the NPL. Expeditious deletion of sites is a post construction emphasis. InFY2003 andbeyond, EPA plans to delete
30 sites per year.
e. Superfund Alternative Sites
The category of "Superfund Alternative (SA) sites" has been identified in OSWER 92-08.0-17, "Response
Selection and Enforcement Approach for Superfund Alternative Sites," a directive issued on June 24, 2002, by
OSRE and OERR, now OSRTI. This "SA" designation is an important component of the work of the Superfund
program, with an increased number of sites addressed as SA sites. In order to provide accurate reporting of work
and appropriate credit to EPA Regions for cleanup of non-NPL sites as well as NPL sites, SA sites have been
incorporated into the SPIM.
For purposes of this appendix, references to remedial pipeline activities [i.e., Remedial Investigation (RI),
Feasibility Study (FS), Combined RI/FS, Remedial Design (RD), Remedial Action (RA)] at Superfund Alternative
sites apply only to those Fund-lead and PRP-lead activities at sites that the region has determined would achieve
a Hazard Ranking System (HRS) score greater than or equal to 28.5. Such response actions must be carried out in
a manner not inconsistent with the National Contingency Plan (NCP). Sites proposed to the NPL are included in
this category. Regions should maintain adequate site documentation to support the 'Superfund Alternative'
designationbasedon the criteria referenced above. Regions should seek PRP-lead for all remedial pipeline activities
at Superfund Alternative sites; these sites must be PRP-lead for RAs. Credit for PRP-lead remedial pipeline
activities at Superfund Alternative sites will only be given for activities conducted pursuant to enforceable order or
agreement. Sites that meet these criteria should be identified in WasteLAN using the special initiatives indicator
of "Superfund Alternative."1
:The measures outlined below for remedial pipeline activities at Superfund Alternative sites are established with the
intent of capturing environmental progress previously not accounted for in existing reporting systems. Their establishment is not
intended to affect established priorities for response resource allocation.
Change 2, FY 04/05 SPIM
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
B.A.2 Maximize Program Effectiveness and Efficiency
To maximize the effectiveness and efficiency of the Superfund program during FY04/05, EPA HQ and regions will
work to improve the implementation of the program based on the following processes.
a. Innovative Technologies
Environmental technology development and commercialization are a top national priority for this
Administration. EPA is committed to encouraging the use of new or innovative technologies for contaminated
soils and groundwater. Over the next decade, the Superfund program and other Federal agencies will spend
billions of dollars each year to cleanup sites contaminated with hazardous wastes. This commitment will require
the use of a wide range of site remediation processes. While existing technologies that characterize and
remediate contaminated sites have been successful, the investment in site clean up provides new opportunities
for the development of less expensive and more effective solutions.
The Agency has made considerable progress using new technologies in Superfund. More than half ofthe recent
remedial cleanup decisions for source control call for technologies that were not available when the law was
reauthorized in 1986. The large cleanup needs remaining in EPA programs, as well as the formidable future
requirements for state and other Federal agencies, provide a continuing impetus to find more effective and less costly
solutions.
The unique and varying problems posed by contaminated sites present a challenge that requires knowledge and
techniques from different technical disciplines. The solutions to these problems are not to be found in existing
design manuals or standards of practice. Rather, EPA is developing procedures as it goes along by creatively
applying technologies from various industrial applications to unique site conditions. This field of hazardous site
remediation is rapidly evolving and requires considerable effort to remain informed of recent developments.
EPA is attempting to expand the participation of responsible parties in technology development by altering the
Agency's historical role and working more closely with the private sector as a partner with shared objectives.
Conventionally, EPA has been viewed primarily as a regulator, permit issuer, and enforcer. These functions have
kept it at arms' length from industry, which tended to view the Agency with a negative bias. EPA has been working
to build new relationships with the private sector that are based on other EPA roles including technology broker,
researcher, and grant maker. These cooperative efforts are expected to result in better- directed research and more
joint demonstration projects. A number of significant collaborative endeavors in the areas of technology
development and evaluation are currently under way.
The Agency is also very committed to the dissemination of information on technology development, evaluation
and deployment. Electronic information resources offer the best hope for keeping pace with rapid developments
in this field. The Clean-Up Information (CLU-IN) web site at http://clu-in.org offers waste professionals a rich
source of current information on technologies and markets. The TechDirect monthly electronic-mail service offers
subscribers up-to-date information on new remediation technology products and services developed by EPA.
Federal facility sites provide an excellent testing ground for assessing and demonstrating the use of innovative
technologies. Many Federal facilities offer a number of benefits: sole responsible party; acknowledged liability;
controlled sites; funding; and willingness. For these reasons, the Agency expects to see more public-private
partnerships established at Federal facility sites.
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OSWER Directive 9200.3-14-1G-Q
b. Effective Contract Management
Good contract management is a Superfund priority, as well as an Agency-wide priority. In this regard, the
Agency established a national workgroup to develop a new Superfund acquisition strategy for the year 2000 and
beyond. The Contracts 2000 strategy builds upon the Long Term Contracting Strategy (LTCS) paradigm. The new
strategy retains two key tenets of LTCS - a one-program approach and decentralization of contracts management
to the regions - and keeps the LTCS contracts infrastructure in place.
The major goals of Contracts 2000 are: 1) balancing national consistency with regional flexibility; 2)
introducing more competition into the contracting process; 3) increasing small, small disadvantaged, and women-
owned business participation in the Superfund contracting program; 4) adopting new contracting vehicles and
methods such as performance-based contracting, and fixed price contracting; and 5) developing "performance
focused" statements of work for all of the follow-on contracts.
The Agency is currently in the implementation phase of the Contracts 2000 process. We have finalized national
implementation plans for the START (Superfund Technical Assessment and Response Team), ERRS (Emergency
and Rapid Response Services), ESS (Enforcement Support Services), ROC (Regional Oversight Contracts), and
ESAT (Environmental Services Assistance Teams) contracts and developed a strategy for acquiring Superfund
design and construction services when the current Response Action Contracts (RACs) expire starting in 2005.
c. Redevelopment
Superfund cleanups address real threats to public health and the environment and have been instrumental in
returning sites to productive uses. In the last six years, EPA has become increasingly aware of the importance of
fully exploring future use opportunities at Superfund sites with its partners before selecting and implementing
cleanup remedies. This shift in thinking has resulted in Superfund sites, which were once thought to be unusable,
being "recycled" back into productive use. EPA is encouraging the reuse of Superfund sites in several ways, such
as making cleanup decisions that are consistent with intended reuse and limiting the liability of interested developers.
Large and small businesses, shipping terminals, community libraries, sports fields, and golf driving ranges are just
a few of the many ways in which Superfund sites are being reused following their cleanup.
The Superfund program is undertaking a nationally coordinated effort the Superfund Redevelopment
Program (SRP) to facilitate the return of Superfund sites to productive use. Announced on July 23, 1999, this
program builds on the success noted above, as well as on the achievements of the Superfund reforms focused on
economic redevelopment. In carrying out this program, the priority remains the protection of human health and the
environment. While operating within the current regulatory and statutory framework, EPA will take full advantage
of its administrative flexibility in implementing SRP. The Superfund Program remains committed to accelerating
the pace of cleanups without compromising its "enforcement first" approach, which includes the recovery of costs
from those responsible for the pollution. SRP will focus on the activities that support remedy selection and design.
EPA does not anticipate reopening formal decisions already made, such as RODs and enforcement orders and
decrees.
Under SRP, pilot projects were selected to enhance the involvement of local governments in determining the
potential future uses of Superfund sites and to demonstrate tools that can be used to facilitate redevelopment. Ten
pilot sites were selected during FY 99, forty additional pilots were selected during FY 00, and 19 more sites in FY
02. All pilots are being monitored and evaluated for lessons learned and potential future program enhancements.
The other components of SRP include: revisions to policy and guidance, where needed, and new guidance and
technical tools; outreach to share information about site reuses, the tools that can help stakeholders repeat those
successes at other sites, and the reuse potential of specific sites; and partnerships with other public and private
entities with resources or other capabilities to support the redevelopment of the sites. (Please see the Superfund
FY 04/05 SPIM
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April 7, 2003
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OSWER Directive 9200.3-14-1G-Q
Redevelopment web site at www.epa.gov/superfund/programs/recvcle/index.htm). The reuse of Superfund sites is
taking place now, and with a coordinated national effort, EPA can accomplish even more.
d. Reforms
Since 1993, EPA has launched three rounds of reforms to Superfund to address criticisms raised by affected
parties and to improve the pace, cost, and fairness of the program. Each set of reforms consists of various initiatives
and pilots focusing on changes to the program that can be implemented within the existing statutory framework.
These reforms were intended to accomplish different goals, ranging from strengthening the program to testing
concepts developed during Congressional debate on reauthorization legislation. The reforms have helped to improve
the overall performance of the program. EPA has effectively reduced the pursuit of small volume (i.e., de minimis
and de micromis) contributors by private parties, increased public involvement in the cleanup process by establishing
Community Advisory Groups and promoting the availability of Technical Assistance Grants, promoted economic
development and environmental justice with Brownfields and job training initiatives, and saved in excess of $1
billion in estimated response costs through the National Remedy Review Board and the Remedy Update Reform.
EPA has streamlined cleanups, increased fairness and made common sense improvements to Superfund. As a result
of all the reforms, Superfund is a dramatically different program today than it was at its inception.
B.B. FY 04/05 RESPONSE TARGETS AND MEASURES
B.B. 1. OVERVIEW OF FY 04/05 RESPONSE ACTIONS TARGETS/MEASURES
The Superfund Comprehensive Accomplishments Plan (SC AP) is used by the Assistant Administrator for the Office
of Solid Waste and Emergency Response (AA OSWER), Assistant Administrator for the Office of Enforcement and
Compliance Assurance (AA OECA), and senior Superfund managers to monitor progress each region is making towards
achieving the Government Performance and Results Act (GPRA) annual performance goals. In addition, SCAP will
continue to be used as an internal management tool to project and track activities that contribute to these GPRA goals
and support resource allocation. The program will set national goals based on historical performance and performance
expectations within a limited budget for the performance goals in GPRA and track accomplishments in the activities
contributing to those goals. Regions should continue to plan and report accomplishments in WasteLAN as they have
traditionally.
To more clearly reflect the relationship between GPRA and the SCAP process, GPRA annual performance goals
and measures and program targets and measures are defined as follows:
GPRA Annual Performance Goals (APG) and GPRA Annual Performance Measures (APM) - The
Agency's Annual Plan describes the specific annual performance goals, annual measures of outputs and
outcomes, and activities aimed at achieving the performance goals that will be carried out during the year.
APGs are the specific activities that the Agency plans to conduct during the fiscal year in an effort towards
achieving its long-term strategic goals and objectives. APMs are used by managers to determine how well a
program or activity is doing in achieving milestones that have been set for the year. The annual performance
goals will inform Congress and Agency stakeholders of the expected level of achievement for the significant
activities covered by the GPRA objective. The goals are a subset of the overall planning and budgeting
information that has traditionally been tracked by the Superfund program offices.
Program Targets and Measures are activities deemed essential to tracking overall program progress. Program
targets are used to identify and track the number of actions that each region is expected to perform during the
year and to evaluate program progress. For Five Year Reviews, program targets are used to identify and track
the specific number of sites, not actions. These sites must be targeted site specifically and cannot be substituted
for other sites. Program measures are used to show progress made in achieving program priorities.
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
The following pages contain, in pipeline order, the definitions of the FY 04/05 removal and remedial activities,
GPRA annual performance goals, GPRA and program measures, and removal and remedial project support activities.
Exhibit B.l displays the full list of removal and remedial activities defined in this Appendix. Exhibit B.4, atthe end of
this Appendix, lists the subject matter experts for each relevant subject area.
B.B.2. SUPERFUND DURATIONS [To be updated later]
The Superfund program has tracked remedial pipeline durations for several years in the Superfund Senior
Management Reports as part of Superfund progress evaluation. As program management emphasis shifts from
administrative pro gress to more comprehensive measurement of program progress, OSRTI will track additional durations
besides the remedial pipeline durations. These durations include: Engineering Evaluation/Cost Analysis (EE/CA)
duration; Expanded Site Inspection/Remedial Investigation (ESI/RI) duration; removal duration; average duration
between proposed listing to first removal or remedial action; and average duration from action memorandum to first
removal completion. In FY 04/05, OSRTI will track the average action and site durations presented below. These
durations are not SCAP measures; they are presented here for informational purposes only. HQ is responsible for
calculating and publishing the durations in the Superfund Senior Management Reports; however, regions are responsible
for entering and maintaining accurate data from which durations can be derived.
The durations only cover non-Federal actions and are calculated based on actual dates. In addition, they do not include
takeovers (within actions) or phased actions. These durations are tracked by the response and enforcement programs.
Average Remedial Investigation/Feasibility Study (RI/FS) Duration
~ Duration from Record of Decision (ROD) to Remedial Design (RD) Start
Duration from ROD to Remedial Action (RA) Start
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT B.l
RESPONSE ACTION ACTIVITIES
ACTIVITY
GPRA
PROGRAM
APG
APM
Target
Measure
Remedial Investigation (RI) Starts (NPL & Superfund
Alternative)
/~
Feasibility Study (FS) Starts (NPL & Superfund Alternative)
/~
Combined RI/FS Starts (NPL & Superfund Alternative)
/~
Treatability Studies
/~
Start of Public Comment Period (Proposed Plan to Public) (NPL
& Superfund Alternative)
/~
RI/FS Duration (NPL & Superfund Alternative)
/~
Decision Document Developed
/~
Final Remedy Selected/Final ROD Authority
/~
Engineering Evaluation/Cost Analysis (EE/CA)
/~
Removal Starts
/~
Removal Completions
/~
RD Start (NPL & Superfund Alternative)
/~
RD Completion (NPL & Superfund Alternative)
/~
RA Start (NPL & PRP-lead Superfund Alternative)
/~
RA Contract Award (NPL & PRP-lead Superfund Alternative)
/~
Start of On-Site Construction
/~
Operational and Functional (O&F)
/~
Completion of a Response Action/Activity (NPL & PRP-lead
Superfund Alternative)
/~
NPL Site Construction Completions
/~
NOTE: Accomplishments are updated and reported on a daily basis. Selected National reports are run quarterly.
September 22, 2003
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT B.l (cont'd)
RESPONSE ACTION ACTIVITIES
ACTIVITY
GPRA
PROGRAM
APG
APM
Target
Measure
Long-Term Response Action (LTRA & PRP LR) (NPL &
PRP-lead Superfund Alternative)
/~
Operation and Maintenance (O&M)
/~
Cleanup Goals Achieved
/~
NPL Site Completions
/~
Five-Year Reviews
/~
Partial NPL Deletion
/~
Final NPL Deletion
/~
Sites with Land Ready for Reuse
/~
Acres at Sites with Land Ready for Reuse
/~
Human Exposure Under Control
/~
Migration of Contaminated Groundwater Under Control
/~
Populations Protected
/~
Cleanup Technologies Applied
/~
Support Agency Assistance
/~
Technical Assistance
/~
Pre-Design Assistance
/~
NOTE: Accomplishments are updated and reported on a daily basis. Selected National reports are run quarterly.
Change 1, FY 04/05 SPIM
B-ll
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OSWER Directive 9200.3-14-1G-Q
B.B.3 Record of Decision (ROD)
A ROD is prepared after completion of public comment period on the FS and proposed plan for an early action
(remedial authority) or long-term response action. The ROD identifies the Agency's selected remedy.
a. ROD Changes
After a ROD is signed, new information may be generated that could affect the remedy selected. Three types of
changes can occur: Other Remedy Change, Explanation of Significant Differences, and ROD Amendment. All of these
documents need to be sent to the below HQ address within 5 (five) days after signing:
Decision Document Coordinator
US EPA (MC 5202G) 12th Floor
Crystal Gateway 1
1235 Jefferson Davis Elwy
Arlington, VA 22202
i. Other Remedy Changes Document Non-Significant Remedy Changes
Non-significant remedy changes fall within the normal scope of changes occurring during the Remedial
Design/Remedial Action (RD/RA) or limited RA . These changes typically result from value engineering. This may
cause minor changes in the type/cost of materials, equipment facilities, services, and supplies. When such changes
do not significantly affect the scope, performance, or cost of the remedy, they are considered minor or non-
significant.
Other Remedy Changes should be documented in a Note to File or Memorandum to File, titled "Other Remedy
Change." Copies of these documents shall be placed into the Administrative Record (AR), and need to be mailed
to the above address at F1Q. Since the document is placed into the AR, it is available for public review. A formal
public comment period, public meeting and responsiveness summary are not needed. An Other Remedy Change
is not a new ROD and should not be coded as such in WasteLAN. It should be entered as a SubAction to the ROD
(Action Name = Record of Decision and SubAction Name = Other Remedy Change). Other Remedy Change data
are entered into WasteLAN at the time the document is signed. The date the Other Remedy Change at a NPL or
Superfund Alternative site is signed by the designated Regional Official or the AA OSWER is reported as the actual
completion date (Actual Complete) of the Other Remedy Change SubA ction (Action Name=Rec ord of Decision and
SubAction Name=Other Remedy Change). Response action and cost data only need to be entered when they
change. Other Remedy Changes are tracked as an internal reporting measure.
ii. Explanation of Significant Differences (ESDs) Document Significant Changes to a Component of a
Remedy
Significant changes to a component of a remedy generally are incremental changes to the hazardous waste approach
selected for the site (i.e., a change in timing, cost and implementation). These changes do not fundamentally alter
the overall approach intended by a remedy. When significant changes are made to a component of a remedy, an
Explanation of Significant Differences (ESD) should be prepared.
A copy of the ESD is placed into the AR, and a copy needs to be mailed to the above address at F1Q. The ESD
is made available to the public for review. A formal public comment period, public meeting, and responsiveness
summary are not required. While the ESD is being prepared and made available to the public, response activities
should continue. An ESD is not a new ROD and should not be coded as such in WasteLAN. It should be entered
as a SubAction to the ROD (Action Name = Record of Decision and SubAction Name = Explanation of Significant
Dif). ESD data are entered in WasteLAN at the time of ESD signature. The date the ESD at a NPL or Superfund
February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
Alternative site is signed by the designated Regional Official or the AA OSWER is reported as the actual completion
date (Actual Complete) of the ESD SubAction (Action Name = Record of Decision and SubAction Name =
Explanation of Significant Diff). Response action and cost data only need to be entered when they change. ESDs
are tracked as an internal reporting measure.
iii. ROD Amendments are Fundamental Changes to the ROD
When the hazardous waste management approach selected in the ROD is reconsidered, it is a fundamental change.
For example, the innovative technology originally selected in the RODdidnotperform satisfactorily during the pilot
scale testing, and a decision is made to switch to another remedy. This would represent a fundamental change. If,
as a result of PRP negotiations, the remedy in the ROD is changed from incineration to bioremediation, this also
represents a fundamental change. When such fundamental changes or amendments are made to a remedy, the ROD
process (revised proposed plan, public comment period, public meeting, responsiveness summary, and amended
ROD) should be repeated. The amended ROD must be placed in the AR and a copy must be mailed to the above
HQ address. A fundamental change to the ROD should be recorded as a ROD amendment SubAction in WasteLAN
(Action Name = Record of Decision and SubAction Name = ROD Amendment). The date the designated Regional
Official or the AA OSWER signs the amended ROD at a NPL or Superfund Alternative site should be recorded in
WasteLAN as the actual completion date (Actual Complete) of the ROD Amendment SubAction (Action Name =
Record of Decision and SubActionName = ROD Amendment). Regions must enter the actual completion date of
the ROD Amendment along with the Alternative Name, Media Name, Media Type, Selected Response Actions,
and cost data. ROD Amendments are tracked as an internal reporting measure.
b. RODs Requiring No Physical Construction
At some NPL sites, EPA may determine, through the Remedial Investigation/Feasibility Study (RI/FS) (or other
means), that no physical construction is necessary to protect human health and the environment. Such a determination
may be documented in no action/no further action RODs, including RODs that only require monitoring, and Limited
Action RODs requiring monitored natural attenuation or institutional controls only.
These ROD events should be coded into WasteLAN as follows:
Action Name = Record of Decision;
Alternative Name
~ Media Name
~ Media Type (Air, Groundwater, Leachate, Liquid Waste, Other, Residuals, Sediment, Sludge, Soil,
Solid Waste, Surface Waste); and
Selected Response Actions
No Action RODs:
No Action
~ No Further Action
~ Monitoring
Cost data should be entered as 0 (zero)
Limited Action RODs:
Natural Attenuation
~ Institutional Controls (Access Restriction, Access Restriction-Guards, Deed Restriction,
Drilling Restriction, Fishing Restriction, Institutional Controls Not Otherwise Specified
(N.O.S.), Land Use Restriction, Monitoring, Recreational Restriction, Revegetation,
Swimming Restriction, and Water Supply Use Restriction)
Change 2, FY 04/05 SPIM B-13 February 6, 2004
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OSWER Directive 9200.3-14-1G-Q
]>>.]>>. 4 RESPONSE ACTION DEFINITIONS
PART I. REMEDY SELECTION
a. REMEDIAL INVESTIGATION (RI) STARTS (NPL & Superfund Alternative)
Definition:
The purpose of the RI is to collect data necessary to adequately characterize the site for the purpose of developing and
evaluating effective remedial alternatives. The RI provides information to assess the risks to human health and the
environment and to support the development, evaluation, and selection of appropriate response alternatives.
The RI may be conducted alone, as part of a site-wide integrated ESI/RI assessment, or as a combined Remedial
Investigation/Feasibility Study (RI/FS). The start of an RI/FS is a program measure. The RI start and RI/FS start
definitions are the same. Regions are not required to enter the RI start date if the RI is being conducted as part of an
ESI/RI or RI/FS.
Obligation of funds for forward planning, community relations and/or other support activities do not constitute a RI start.
The appropriate use of Special Account funds for remedial investigations is provided in the "Guidance on Key Decision
Points in Using Special Account Funds" dated September 28, 2001.
Definition of Accomplishment:
Fund-financed (Including F-, TR - and S-lead actions) - Credit for a Fund-financed RI (Action Name = Remedial
Investigation) start at an NPL or Superfund Alternative site is received when funds are obligated and the actual start date
(Actual Start) has been recorded in WasteLAN. Funds are obligated when:
The contract modification or work assignment for the RI has been signed by the EPA Contracting Officer;
or
An IAG has been signed by the other Federal agency [Bureau of Reclamation (BUREC) or USACE]; or
A Cooperative Agreement has been signed by the Regional Administrator or designee to conduct a RI.
If a subsequent RI is initiated without a new obligation of funds, the start date as recorded in WasteLAN is defined as
EPA's written approval of the work plan for the subsequent RI.
PRP- financed from a Special Account (Including Special Account Financed Action performed by EPA (SA-lead),
the State (SS-lead), or Tribal Government (ST-lead) actions') - Credit for a special account-financed RI (Action Name
= Remedial Investigation) start at an NPL or Superfund Alternative site is received when funds are obligated and the
actual start date (Actual Start) of the RI has been recorded in W asteLAN. Funds are obligated when:
1 Actions qualify for SA, SS, and ST leads, when the majority of the funding for the total estimated cost of the RI
(including direct and indirect costs) is to be paid from a Special Account. The amount contributed from a Special Account
should meet or exceed the amount contributed by the largest non-PRP entity (i.e., EPA, State where applicable) toward the total
estimated cost of the RI at the site. For example, if 60% of the funds needed to finance the RI are to be derived from a Special
Account and 40% of the costs will be paid out of Fund monies (or a lesser amount if State cost share is received), the majority of
the cost is being paid for out of a Special Account and the action qualifies tor a SA, SS, or ST lead.
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
The contract modification or work assignment for the RI has been signed by the EPA Contracting Officer;
or
An IAG has been signed by the other Federal agency (BUREC or USACE); or
A Cooperative Agreement has been signed by the Regional Administrator or designee to conduct a RI.
If a subsequent RI is initiated without a new obligation of funds, the start date as recorded in WasteLAN is defined as
EPA's written approval of the work plan for the subsequent RI.
PRP-financed under Federal enforcement (Includes RP- andMR-lead actions) - A PRP- financed RI (Action Name
= PRP RI) under Federal enforcement at a NPL or Superfimd Alternative site starts when one of the following
enforcement actions occurs:
An Administrative Order on Consent (AOC), in which the Potentially Responsible Parties (PRPs) agree to
conduct the RI, is signed by the Regional Administrator or delegatee. The RI start date (Actual Start) is the
date the AOC is signed. This is reported in WasteLAN as the AOC (Action Name = Administrative Order
on Consent) completion date (Actual Complete); or
The date (Actual Complete) the PRPs provide notice of intent to comply (SubAction Name = PRP Notify
EPA of Intent to Comply) with a UAO for a RP-lead RI signed (Actual Complete) by the designated
Regional official (Action Name = Unilateral Admin Order) and the Response Act Pd by Parties of "PRP
RI"; or
A Consent Decree (CD), in which the PRPs agree to conduct the RI, is referred by the region to Department
of Justice (DO.T) or HQ. The RI start date (Actual Start) is the date the Regional Administrator signs the
memo transmitting the CD to HQ or DO.T. This is recorded in WasteLAN as the CD (Action Name =
Consent Decree) actual start date (Actual Start).
PRP-financed under State enforcement (PS-leadactions) - A PRP-financed RI (Action Name = PRP RI) under State
enforcement at a NPL or Superfund Alternative site starts when a State order or comparable enforcement document
(Action Name = State Order or State Decree), in which the PRPs agree to conduct the RI, is signed by the last appropriate
State official or party (Actual Complete) and the site is covered by one of the following:
State enforcement Cooperative Agreement signed by the Regional Administrator; or
Superfund Memorandum of Agreement (SMOA) signed by the appropriate State and Regional official
containing a schedule forRI work at the site; or
A general SMOA signed by the appropriate State and Regional officials covering remedial work to be
undertaken with schedules defined before work commences; or
Other State/EPA agreement signed by the appropriate State and Regional official.
If a subsequent RI is initiated without a new or amended AOC, CD, State order, or other comparable State enforcement
document, the start date for the RI as recorded in WasteLAN is documented by a letter, form, or memo from EPA or
the State approving the work plan for the subsequent RI.
If an AOC, State order, or other comparable State enforcement do cument is amended for the subsequent RI, the start date
is the date the last State official or Regional Administrator/delegatee signs the amendment. If a Federal CD is amended,
the start date is the date on which the memo transmitting the CD to HQ or DO.T is signed by the Regional Administrator.
Change 7, FY 04/05 SPIM
B-15
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
In-house (EP-lead action) - Credit for an in-house RI (Action Name = Remedial Investigation) start at a NPL or
Superfund Alternative site is received on the date that the region conducts the initial RI scoping meeting. The start
(Actual Start) is documented by a memo to file containing the minutes from the meeting.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Regions are not required to enter the RI start date if the RI is being conducted as part of an RI/FS or site-wide ESI/RI.
The RI actual start date is reported site-specifically in WasteLAN. For PRP-financed RIs, both the RI start (Actual Start)
and the CD start (Actual Start) or notice of intent to comply with a UAO, AOC, State order, or State decree completion
dates (Actual Complete) must be entered into WasteLAN. These dates should be the same. Funds for RIs and RI
oversight are found in the pipeline operations AOA. Superfund Alternative sites should be identified in WasteLAN using
the special initiatives indicator of "Superfund Alternative." This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Remedial
Investigation
(RI)
Program
Measure
F, TR,
S, SA,
SS,
ST
Contract modification
or work assignment;
or
An IAG; or
Cooperative
Agreement.
Signed by EPA
Contracting Officer; or
Signed by other Federal
agency;
Signed by Regional
Administrator or
designee.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the event
occurs.
Action name =
PRP RI (NA)
Program
Measure
RP,
MR
Administrative Order
on Consent (AOC)
A Consent Decree
(CD)
RP lead: Notice of
intent to comply with
a UAO
Signed by Regional
Administrator or
delegatee.
Not specified
PRP's provide notice and
RI is signed by
designated Regional
official
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the event
occurs.
September 8, 2005
B-16
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Program
PS
State order, or
Signed by all appropriate
It is good management
PRP Rl (NA)
Measure
comparable
State officials or parties;
practice to enter data
enforcement
regarding the event as soon
document
as practicable after the event
Signed by Regional
occurs. However, data must
A State Enforcement
Administrator,
be entered prior to the end of
Cooperative
the quarter in which the event
Agreement;
Signed by appropriate
occurs.
State and regional
A Superfund
official,
Memorandum of
Agreement (SMOA);
or
Signed by appropriate
State and Regional
A general SMOA; or
officials, or
Other State/EPA
Signed by the
agreement.
appropriate State and
Regional official.
Action name =
Remedial
Investigation
(Rl)
Program
Measure
EP
Memo containing
minutes regions'
initial Rl scoping
meeting.
Memo to file.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the event
occurs.
b. FEASIBILITY STUDY (FS) STARTS (NPL & Superfund Alternative)
Definition:
The primary objective of a FS is to ensure that appropriate remedial alternatives are developed and evaluated such that
an appropriate remedy may be selected.
The FS may be conducted alone or as part of a combined RI/FS. FS Starts and combined RI/FS starts is a program
measure. Regions are not required to enter the FS start date if the FS is being conducted as part of a combined RI/FS.
Obligation of funds for forward planning, community relations and/or other support activities does not constitute a FS
start.
The appropriate use of Special Account funds for feasibility studies is provided in the "Guidance on Key Decision Points
in Using Special Account Funds" dated September 28, 2001.
Definition of Accomplishment:
Fund-financed (Including F-, TR- and S-lead actions) - Credit for a Fund-financed FS (Action Name = Feasibility
Study) start at a NPL or Superfund Alternative site is received when funds are obligated and the actual start date (Actual
Start) is entered into WasteLAN. Funds are obligated when:
The contract modification or work assignment for the FS has been signed by the EPA CO; or
An IAG has been signed by the other Federal agency (USACE or BUREC); or
Change 7, FY 04/05 SPIM
B-17
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
A Cooperative Agreement has been signed by the Regional Administrator or his designee to conduct a FS.
If a first or subsequent FS is initiated without a new obligation of funds, the start date as recorded in WasteLAN is
defined as the date of EPA's written approval of the work plan for the FS.
PRP- financed from a Special Account (Including Special Account Financed Action performed by EPA (SA-lead),
the State (SS-Lead), or Tribal Government (ST-lead) actions2) - Credit for a special account-financed FS (Action
Name = Feasibility Study) start at a NPL or Superfund Alternative site is received when funds are obligated and the
actual start date (Actual Start) is entered into WasteLAN. Funds are obligated when:
The contract modification or work assignment for the FS has been signed by the EPA Contracting Officer;
or
An IAG has been signed by the other Federal agency (USACE or BUREC); or
A Cooperative Agreement has been signed by the Regional Administrator or designee to conduct a FS.
If a first or subsequent FS is initiated without a new obligation of funds, the start date as recorded in WasteLAN is
defined as the date of EPA's written approval of the work plan for the FS.
PRP-financed under Federal enforcement (Including RP- and MR-lead actions ) - A PRP- financed FS (Action
Name = PRP FS) under Federal enforcement at a NPL or Superfund Alternative site starts when one of the following
enforcement actions occurs:
An AOC that addresses FS activities is signed by the Regional Administrator or delegatee. The FS start
date (Actual Start) is the date the AOC is signed. This is recorded in WasteLAN as the AOC (Action
Name = Administrative Order on Consent) actual completion date (Actual Complete); or
The date (Actual Complete) the PRPs provide notice of intent to comply (SubAction Name = PRP Notify
EPA of Intent to Comply) with a UAO for a RP-lead FS signed (Actual Complete) by the designated
Regional official (Action Name = Unilateral Admin Order) and the Response Acts Pd by Parties of "PRP
FS"; or
The Regional Administrator signs the memorandum transmitting the CD to DO.T or HQ that addresses FS
activities is referred by the region to DO.T or HQ. The FS start date (Actual Start) is the date (Actual Start)
the Regional Administrator signs the memorandum transmitting the CD (Action Name = Consent Decree) to
DO J or HQ.
PRP-financed under State enforcement (PS- lead actions) - A PRP-financed FS (Action Name = PRP FS) under State
enforcement at a NPL or Superfund Alternative site starts when a State order or comparable enforcement document
(Action Name = State Order or State Decree), in which the PRPs agree to conduct the FS, is signed by the last
appropriate State official or party (Actual Complete), and the site is covered by one of the following:
2
"* Actions qualify for SA, SS, and ST leads, when the majority of the funding for the total estimated cost of the FS
(including direct and indirect costs) is to be paid from a Special Account. The amount contributed from a Special Account
should meet or exceed the amount contributed by the largest non-PRP entity (i.e., EPA, State where applicable) toward the total
estimated cost of the FS at the site. For example, if 60% of the funds needed to finance the FS are to be derived from a Special
Account and 40% of the costs will be paid out of Fund monies (or a lesser amount if State cost share is received), the majority of
the cost is being paid for out of a Special Account and the action qualifies tor a SA, SS, or ST lead.
September 8, 2005
B-18
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
State enforcement Cooperative Agreement signed by the Regional Administrator; or
SMOA signed by the appropriate State and Regional official containing a schedule for FS work at the site;
or
Other State/EPA agreement signed by the appropriate State and Regional official.
If a first or subsequent FS is initiated without a new or amended AOC, CD, State order, or other comparable State
enforcement document, the start date of the FS is documented by a letter, form, or memo from EPA or the State
approving the work plan for the subsequent FS.
If an AOC, State order, or other comparable State enforcement document is amended for the first or subsequent FS, the
actual start date is the date the last State official or the Regional Administrator/delegatee signs the amendment. If a
Federal CD is amended, the start date is the date the Regional Administrator signs the memo transmitting the CD to HQ
or DO.T.
In-house (EP-lead action) - Credit for an in-house FS (Action Name = Feasibility Study) start at a NPL or Superfund
Alternative site is received on the date that the region conducts the initial FS scoping meeting. The start date (Actual
Start) is documented by a memo to file containing the minutes from the meeting.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Regions are not required to enter the FS start date if the FS is being conducted as part of a combined RI/FS. The FS
actual start date is entered into WasteLAN site-specifically. For a PRP-financed FS, both the FS start date (Actual Start)
and the CD start date (Actual Start), or the notice of intent to comply with a UAO, AOC, State order or State decree
actual completion date (Actual Complete) must be entered into WasteLAN. These dates should be the same. Funds for
FS and FS oversight are contained in the pipeline operations AO A. Superfund Alternative sites should be identified in
WasteLAN using the special initiatives indicator by designating these sites as "Superfund Alternative." This is a program
measure.
Data Entry Timeliness
Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action name =
Feasibility Study
(FS)
Program
Measure
F, TR,
S
Contract modification
or work assignment; or
IAG; or
Cooperative
Agreement; or
Signed by the EPA CO;
Signed by other Federal
agency (USACE or
BUREC);
Signed by the Regional
Administrator or his
designee.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Change 7, FY 04/05 SPIM
B-19
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action name =
Feasibility Study
(FS)
Program
Measure
SA,
SS,
ST
Contract modification
or work assignment for
the FS; or
An IAG; or
Cooperative
Agreement.
Signed by EPA
Contracting Officer;
Signed by other Federal
agency (USACE or
BUREC);
Signed by Regional
Administrator or
designee.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Action name =
PRP FS (NK)
Program
Measure
RP,
MR
AOC; or
Notice of intent to
comply with a UAO; or
Memo transmitting CD
to DOJ or HQ.
Signed by Regional
Administrator or
delegatee;
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
Action name =
PRP FS (NK)
Program
Measure
PS
State order, or
comparable
enforcement document
State enforcement
Cooperative
Agreement;
SMOA; or
Other State/EPA
agreement.
Signed by all
appropriate State
officials or parties
Signed by Regional
Administrator
Signed by appropriate
State and Regional
official
Signed by the
appropriate State and
Regional official.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
c. COMBINED RI/FS START (NPL & Superfund Alternative)
Definition:
The purpose of the RI/FS is to assess site conditions and evaluate alternatives to the extent necessary to
The start of an RI/FS is a program measure. The RI/FS start and the RI start definition are the same,
required to enter the RI start date if the RI is being conducted as part of an RI/FS or a site-wide ESI/RI.
required to enter the FS start date if the FS is being conducted as part of a RI/FS.
Obligation of funds for forward planning, community relations and/or other support activities do not constitute a RI/FS
start.
The appropriate use of Special Account funds for remedial investigations/feasibility studies is provided in the "Guidance
on Key Decision Points in Using Special Account Funds" dated September 28, 2001.
select a remedy.
Regions are not
Regions are not
September 8, 2005
B-20
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
Fund-financed (Including F-, TR- and S-lead actions) - Credit for a Fund-financed RI/FS (Action Name = Combined
RI/FS) start at a NPL or Superfund Alternative site is received when funds are obligated and the actual RI/FS start date
(Actual Start) is reported in WasteLAN. Funds are obligated when:
The contract modification or work assignment for the RI/FS has been signed by the EPA CO; or
An IAG has been signed by the other Federal agency (USACE or BUREC); or
A Cooperative Agreement has been signed by the Regional Administrator or designee to conduct a RI/FS.
If a first or subsequent RI/FS is initiated without a new obligation of funds, the start date is defined as the date of EPA's
written approval of the work plan for the RI/FS.
PRP- financed from a Special Account (Including Special Account Financed Action performed by EPA (SA-lead),
the State (SS-Lead), or Tribal Government (ST-lead) actions3) - Credit for a special account-financed RI/FS (Action
Name = Combined RI/FS) start at a NPL or Superfund Alternative site is received when funds are obligated and the
actual RI/FS start date (Actual Start) is reported in WasteLAN. Funds are obligated when:
The contract modification or work assignment for the RI/FS has been signed by the EPA CO; or
An IAG has been signed by the other Federal agency (USACE or BUREC); or
A Cooperative Agreement has been signed by the Regional Administrator or designee to conduct a RI/FS.
If a first or subsequent RI/FS is initiated without a new obligation of funds, the start date is defined as the date of EPA's
written approval of the work plan for the RI/FS.
PRP-financed under Federal enforcement (Includes RP- and MR-lead actions) - A PRP-fmanced RI/FS (Action
Name = PRP RI/FS) under F ederal enforcement at a NPL or Superfund Alternative site starts when one of the following
enforcement actions occurs:
An Administrative Order on Consent (AOC), in which the PRPs agree to conduct the RI/FS, is signed by
the Regional Administrator or delegatee. The RI/FS start date (Action Name = PRP RI/FS) is the date the
AOC is signed. This is recorded in WasteLAN as the AOC (Action Name = Administrative Order on
Consent) completion date (Actual Complete); or
The date (Actual Complete) the PRPs provide notice of intent to comply (SubAction Name = PRP Notify
EPA of Intent to Comply) with a UAO for a RP-lead RI/FS signed (Actual Complete) by the designated
Regional official (Action Name = Unilateral Admin Order), and the Response Acts Pd by Parties of "PRP
RI/FS"; or
3
Actions qualify for SA, SS, and ST leads, when the majority of the funding for the total estimated cost of the RI/FS
(including direct and indirect costs) is to be paid from a Special Account. The amount contributed from a Special Account
should meet or exceed the amount contributed by the largest non-PRP entity (i.e., EPA, State where applicable) toward the total
estimated cost of the RI/FS at the site. For example, if 60% of the funds needed to finance the RI/FS are to be derived from a
Special Account and 40% of the costs will be paid out of Fund monies (or a lesser amount if State cost share is received), the
majority of the cost is being paid tor out of a Special Account and the action qualifies for a SA, SS, or ST lead.
Change 7, FY 04/05 SPIM
B-21
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
A Consent Decree (CD) in which the PRPs agree to conduct the RI/FS, is referred by the region to DO.T or
HQ. The RI/FS start date (Actual Start) is the date the Regional Administrator signs the memo transmitting
the CD to HQ or DO.T. This is recorded in WasteLAN as the CD (Action Name = Consent Decree) actual
start date (Actual Start).
PRP-financed under State enforcement (PS-lead actions) -A PRP-financed RI/FS (Action Name = PRP RI/FS) under
State enforcement at a NPL or Superfund Alternative site starts when a State order or comparable enforcement document
(Action Name = State Order or State Decree), in which the PRPs agree to conduct the RI/FS, is signed by the last
appropriate State official or party (Actual Complete) and the site is covered by one of the following:
State enforcement Cooperative Agreement signed by the Regional Administrator; or
SMOA signed by the appropriate State and Regional official containing a schedule for RI/FS work at the
site; or
Other State/EPA agreement signed by the appropriate State and Regional officials.
If a first or subsequent RI/FS is initiated without a new or amended AOC, CD, State order, or other comparable State
enforcement document, the start date of the RI/FS is documented by a letter, form, or memo from EPA or the State
approving the work plan for the subsequent RI/FS.
If an AOC, State order, or other comparable State enforcement document is amended for the first or subsequent RI/FS,
the start date is the date on which the last State official or Regional Administrator/delegatee signs the amendment. If
a CD is amended, the start date is the date the Regional Administrator signs the memorandum transmitting the CD to
DO.T or HQ.
In-house (EP-leadaction) - Credit for an in-house RI/FS (Action Name = Combined RI/FS) start at a NPL or Superfund
Alternative site is received when the region has the initial RI/FS scoping meeting and the date is entered into WasteLAN.
The start (Actual Start) is documented by a memo to file containing the minutes from the meeting.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Regions are not required to report a combined RI/FS start if a separate RI and FS are being conducted. The combined
RI/FS actual start date is entered into WasteLAN site-specifically. For a PRP-financed RI/FS, the RI/FS start date
(Actual Start) and the CD start date (Actual Start), or notice of intent to comply with a UAO, AOC, State order, or State
decree actual completion date (Actual Complete) must be entered into WasteLAN. These dates should be the same.
Funds for RI/FS and RI/FS oversight are contained in the pipeline operations AOA. The Superfund Alternative sites
should be identified in WasteLAN using the special initiatives indicator by designating these sites as "Superfund
Alternative." This is a program measure.
September 8, 2005
B-22
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action name =
Combined RI/FS
(CO)
Program
Measure
F, TR,
S, SA,
SS,
ST
Contract modification or
work assignment; or
IAG; or
Cooperative Agreement
Signed by EPA CO;
Signed by other Federal
agency (USACE or
BUREC);
Signed by the Regional
Administrator or
designee.
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
Action name =
PRP RI/FS (BD)
Program
Measure
RP,
MR
Administrative Order on
Consent (AOC); or
Notice of intent to
comply with a UAO for a
RP-lead RI/FS and the
Response acts Pd; or
Memo transmitting
Consent Decree (CD) to
HQ orDOJ.
Signed by Regional
Administrator or
delegatee,
Signed by designated
Regional official and the
Response acts Pd signed
by parties of "PRP
RI/FS",
Signed by Regional
Administrator
transmitting the Consent
Decree.
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
Action name =
PRP RI/FS (BD)
Program
Measure
PS
State order or
comparable
enforcement document
State enforcement
Cooperative Agreement;
SMOA; or
Other State/EPA
agreement.
Signed by all appropriate
state officials and parties
Signed by Regional
Administrator,
Signed by the
appropriate State and
Regional official,
Signed by the
appropriate State and
Regional officials.
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
Action name =
Combined RI/FS
(CO)
Program
Measure
EP
Memo containing the
minutes from initial
RI/FS scoping meeting.
Not specified.
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
Change 7, FY 04/05 SPIM
B-23
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
(1. TREATABILITY STUDIES
Definition:
Treatability studies are laboratory or field tests used to evaluate and implement one or more remedial alternatives.
Definition of Accomplishment:
Fund-financed (Including F-, S- or TR- lead) - The start date is the date of EPA's written approval, as reflected in
WasteLAN, of the treatability study work plan. The completion is the written approval of the report on the results of
the treatability study.
PRP-financed (Including RP-, MR- or PS- lead) - The treatability study starts when EPA approves, in writing, the
treatability study work plan submitted by the PRP. The completion is the approval of the report on the results of the
treatability study.
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
Treatability study (Action Name = Treatability Studies) planned and actual start and completion dates are not required
in WasteLAN. Treatability studies are funded as part of an ESI/RI, RI/FS, or RD. Dollars are not budgeted, planned,
or obligated separately. This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action name =
Treatability
Studies (TS)
Program
Measure
F, S,
TR
and
RP,
MR,
PS
Start:
EPA's written approval of
Treatability study work plan.
Complete:
Written approval of report
on results of treatability
study.
Start:
Not specified.
Comolete:
Not specified.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the
event occurs.
e. START OF PUBLIC COMMENT PERIOD (PROPOSED PLAN TO PUBLIC) NPL &
Superfund Alternative)
Definition:
The FS or RI/FS report is released to the public when the contamination at the site has been characterized and alternatives
for remediation have been evaluated.
Definition of Accomplishment:
The Start of Public Comment Period (Proposed Plan to Public) is accomplished at a NPL or Superfund Alternative site
either (1) on the date the appropriate Regional official signs a letter transmitting RI/FS reports and the proposed plan
to the site repository for public review, or (2) when the first page of the approved proposed plan, which lists the dates
the public comment period starts and ends, is included in the site file. This date must be recorded in WasteLAN as the
actual start date (Actual Start) of the SubAction, Public Comment Period (Action Name = Feasibility Study or Combined
September 8, 2005
B-24
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
RI/FS or PRP FS or PRP RI/FS and SubAction Name = Public Comment Period).
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Accomplishments are based on the first proposed plan released to the public for eachFS or RI/FS, regardless of lead.
Superfund Alternative sites should be identified in WasteLAN using the special initiatives indicator designating these
sites as "Superfund Alternative." This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Feasibility Study
(FS) or
Combined RI/FS
(CO) or PRP
RI/FS (BD)
SubAction
Name = Public
Comment
Period (PB)
Program
Measure
F, S, TR,
SA, SS,
ST, EP
RP, MR,
PS,
Letter transmitting
RI/FS reports and
proposed plan
1st page of approved
proposed plan.
Signed by appropriate
Regional official
Not specified.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the event
occurs.
f RI/FS DURATION (NPL & Superfund Alternative)
Definition:
The purpo se of the RI/FS is to assess site conditions and evaluate alternatives to the extent necessary to select a remedy.
The RI/FS starts with the obligation of Fund monies; or the signature of an AOC, State order, or State decree for the RI
or RI/FS; or the date the Regional Administrator signs the memorandum transmitting the CD to DO.T or HQ for RI or
RI/FS; or the date the PRPs provide notice of intent to comply with a UAO; or the conduct of the RI/FS scoping meeting
and culminates with the signature of the ROD.
The objective of this measure is to focus on good project management of critical portions of the traditional remedial
pipeline and establish a methodology which accurately assesses program performance. Duration trends provide
indicators of areas that require attention.
Only RI/FS projects that started post-SARA will be used for comparison and evaluation purposes.
Definition of Accomplishment:
This measure includes all RI/FS projects at a NPL or Superfund Alternative site that have a targeted completion date in
FY 04/05. The RI/FS duration will be calculated based on the RI or Combined RI/FS Start and Decision Document
Developed (ROD completion) definitions specified in this Manual. Regional performance in FY 04/05 will be compared
to:
The regional and national average duration of RI/FS projects completed in FY 02/03 or FY 03/04;
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
The regional and national average duration of RI/FS projects completed in previous quarters of FY 04/05.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
WasteLAN will automatically look at actual RI or RI/FS start dates and actual ROD completion dates. HQ will perform
the analysis of the average durations. Fund and PRP durations at NPL or Superfund Alternative sites will be tracked.
Superfund Alternative sites should be identified in WasteLAN using the special initiatives indicator. RI/FS duration is
a program measure.
g. ENGINEERING EVALUATION/COST ANALYSIS (EE/CA)
Definition:
The EE/CA identifies objectives for a Non-Time Critical (NTC) response action, and includes an analysis of cost,
effectiveness, and implementability of the various alternatives that may be used to satisfy these objectives.
Definition of Accomplishment:
The actual start date of an EE/CA is the date that the appropriate Regional official signs the EE/CA Approval
Memorandum. This information should be recorded in W asteLAN as the actual start date (Actual Start) of the EE/CA
(Action Name = Engineering Eval/Cost Analysis). The actual completion date of an EE/CA is the date that the
appropriate Regional official signs the Action Memorandum. This information should be recorded as the actual
completion date (Actual Complete) of the EE/CA (Action Name = Engineering Eval/Cost Analysis).
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
EE/CAs are reported site-specifically in WasteLAN. Funds for EE/CAs are contained in the pipeline operations AO A.
This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Engineering
Eval/Cost
Analysis (EE)
Program
Measure
F, S, TR,
SA, SS,
ST, EP,
RP, PS,
MR, CG
Start:
EE/CA Approval
Memorandum.
Complete:
Action
Memorandum.
Start:
Signed by appropriate
Regional official.
Comolete:
Signed by appropriate
Regional official.
It is good management practice
to enter data regarding the event
as soon as practicable after the
event occurs. However, data
must be entered prior to the end
of the quarter in which the event
occurs.
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
h. DECISION DOCUMENTS DEVELOPED
Definition:
A "Decision Document" is developed to document decisions or changes to decisions (at NPL, non-NPL, and Superfund
Alternative sites) to:
Perform an emergency, time-critical, or Non-Time Critical (NTC) removal; or
Perform a remedial action.
Definition of Accomplishment:
Removals (Emergency, Time Critical, or NTC) - The date the On-Scene Coordinator (OSC), AA OSWER, or designated
Regional official signs the first or original Action Memorandum for each removal. [Regions will not receive credit for
subsequent Action Memos, (e.g., ceiling increases) at the same removal.] The date of the signature is recorded in
WasteLAN as the actual completion date (Actual Complete) of the SubAction, Approval of Action Memo or Removal
Action Memo Document. To receive credit for the Action Memo, the region must enter the OU, the media addressed,
the media name, the selected alternative, the response technology, remedy cost data, Institutional Control information,
and Five Year Review information.
Remedial - The date the designated Regional Official or the AA OSWER signs the ROD at a NPL or Superfund
Alternative site for each RA. This date is reported in WasteLAN as the ROD (Action Name = Record of Decision)
completion date (Actual Complete). To receive credit for the ROD, the region must enter the OU, the media addressed,
the media name, the selected alternative, the response technology, remedy cost data, Institutional Control information,
and Five Year Review information.
For State-lead ROD s under CERCLA that result from a F, S, TR, EP lead FS or RI/FS; or a PS orMR-lead, PRP RI/FS
or PRP FS where EPA concurs on the ROD should have a lead of SC. Accomplishments are reported as the date of the
latest signature from EPA or the State, on the ROD at NPL or Superfund Alternative sites.
For State-lead RODs without EPA concurrence, the ROD should have a lead of 'SW\ The ROD will not be included
in accomplishment reporting, however the ROD date should be recorded in WasteLAN as the date the State signs the
ROD.
ROD Amendments - The date the designated Regional Official or the AA OSWER signs the amended ROD at a NPL
or Superfund Alternative site should be recorded in WasteLAN as the actual completion date (Actual Complete) of the
ROD Amendment SubAction (Action Name = Record of Decision and SubAction Name = ROD Amendment). The
regions must use Copy Technical Data and update the information based on changes made by the current document.
Changes may be made affecting the response technologies of the selected alternative, remedy cost data, Institutional
Control information and Five Year Review information.
ESDs - The date the ESD at a NPL or Superfund Alternative site is signed by the designated Regional Official or the
AA OSWER is reported as the actual completion date (Actual Complete) of the ESD SubAction (Action Name = Record
of Decision and SubAction Name = Explanation of Significant Diff). The regions must use Copy Technical Data and
update the information based on changes made by the current document. Changes may be made affecting the response
technologies of the selected alternative, remedy cost data, Institutional Control information and Five Year Review
information.
Other Remedy Changes - The date the Other Remedy Change at a NPL or Superfund Alternative site is signed by the
designated Regional Official or the AA OSWER is reported as the actual completion date (Actual Complete) of the Other
Remedy Change SubAction (Action Name=Record of Decision and SubAction Name=Other Remedy Change). The
regions must use Copy Technical Data and update the information based on changes made by the current document.
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Changes may be made affecting the response technologies of the selected alternative, remedy cost data, Institutional
Control information and Five Year Review information.
These decisions will be tracked separately but reported on a combined basis.
Changes in Definition FY 02/03 - FY 04/05:
Added requirements in order to receive credit for RODs, Action Memos or other decision documents.
Special Planning/Reporting Requirements:
To receive credit for an Action Memo, the region must enter the following data into WasteLAN:
the media addressed through the action (Media Type and Media Name),
the Selected Response Actions,
the response action cost data,
the Institutional Control information, and
the Five Year Review year review information
To receive credit for a ROD, ROD amendment, ESD or Other Remedy Changes the Region must enter the following data
into WasteLAN:
the name of the selected alternative (Alternative Name),
the media addressed in the ROD (Media Type and Media Name),
the Selected Response Actions (which include Institutional Controls where anticipated). If Institutional
Controls are anticipated at the site, Institutional Control Objectives need to be defined and entered into
WasteLAN.
associated cost data that are listed in the decision document that may be any or all of the following costs
(Capital Cost (must always be entered even if 0), Annual O&M Cost, Total O&M Cost, Present Worth Cost,
O&M Duration, and Discount Rate), and
the Five Year Review type (if you select discretionary, provide the Five Year Review date. This will system
generate a Five Year Review action, Five Year Review Report Due subaction, and planned date). (Planned RA
On-Site Construction and planned PCOR and FCOR should be in the system by the time the ROD is entered).
WasteLAN will system generate the RI/FS or FS actual completion date if one does not already exist and a predecessor
relationship was established between the RI/FS and the ROD.
Superfund Alternative sites should be identified in WasteLAN using the special initiatives indicator by designating these
sites as "Superfund Alternative." This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Record of
Decision (RO)
Program
Measure
Only state
leads are
specified
(SC and
SW)
ROD.
Signed by
designated
Regional Official or
the AA OSWER.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the
quarter in which the event occurs.
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
ROD
Amendment
(JQ)
Program
Measure
No leads
specified
Amended ROD.
Signed by
designated
Regional Official or
AA OSWER at a
NPL or Superfund
Alternative site.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the
quarter in which the event occurs.
Action name =
Record of
Decision (RO):
SubAction
Name =
Explanation of
Significant Diff
(EH)
Program
Measure
No leads
specified
ESD.
Signed by
Regional Official or
the AA OSWER.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the
quarter in which the event occurs.
Action name =
Record of
Decision (RO)
SubAction
Name = Other
Remedy
Change (OT)
Program
Measure
No leads
specified
Other Remedy
Change.
Signed by
designated
Regional Official or
the AA OSWER.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the
quarter in which the event occurs.
i. Final Remedy Selected
Definition:
This measure will track the Government Performance and Results Act (GPRA) Final Remedy Selected measure atNPL
sites. Final Remedy Selected decisions will also be tracked in CERCLIS for non-NPL sites but will not count towards
the GPRA goal. 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 for a site). This can include the signature of the final ROD, or ROD Amendment, or
removal action memo at a site. In general an Explanation of Significant Difference will not constitute a Final Remedy
Selected since that documents 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.
Definition of Accomplishment:
Credit under CERCLA for a Final Remedy Selected will be given when:
Site has a Final ROD or ROD Amendment and no existing planned ROD, ROD Amendment, Removal Action
memorandum, RI/FS or EE/CA and the action is designated as the Final Remedy. This is reported in
WasteLAN as a ROD (Action Name = Record of Decision) or ROD Amendment (Action Name = ROD
Amendment) with the date the designated Regional Official or the AA OSWER signs the ROD (Actual
Complete) and the action has been designated a Final Remedy (Qualifier = 'R'); or
Site has a Removal Action Memorandum and no existing planned ROD, RI/FS, or planned action
memorandum and the action is designated as the Final Remedy. This is reported in WasteLAN as an Action
Memorandum (Action Name = Action Memorandum) with the date the removal decision was completed (Actual
Complete) and the action is designated a Final Remedy (Qualifier = 'R'); or
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Changes in Definition FY02/03 - FY04/05:
This is a new measure for FY 04.
Special Planning/Reporting Requirements:
WasteLAN will automatically look for planned ROD, ROD Amendments, Removal Action Memorandums, RI/FS and
EE/CAs when a user assigns the Final Remedy Selected qualifier at a ROD, ROD Amendment or Action Memorandum
action. Final Remedy determinations for sites deleted from the NPL are part of the SNAP process. The system will not
assign the Final Remedy for a deleted site if a Final Remedy determination has already been made at the site.
Construction Completion sites for which a Final Remedy determination has not been made will be reviewed by F1Q for
the Final Remedy determination. F1Q will perform the analysis of the total Final Remedies Selected. Dollars are not
budgeted, planned, or obligated separately for this measure. This is a GPRA measure.
PART II. REMEDIAL IMPLEMENTATION
/. REMOVAL STARTS - THIS SECTION HAS BEEN MOVED TO APPENDIX M
Any SUPERFUND FINANCED Removals shall adhere to APPENDIX M, Removals.
REMOVAL COMPLETIONS - THIS SECTION HAS BEEN MOVED TO
APPENDIXM
Any SUPERFUND FINANCED Removals shall adhere to APPENDIX M, Removals.
k. REMEDIAL DESIGN (RD) START (NPL & Superfund Alternative)
Definition:
The RD converts the remedy selected in the ROD into a final design document for the RA. The obligation of funds for
design assistance or technical assistance does not constitute a RD start.
Pre-design activities will not be counted as a RD start.
Definition of Accomplishment:
Fund-Financed (Including F-, TR-, and S-lead actions) - A Fund-financed RD (Action Name = Remedial Design) at
a NPL or Superfund Alternative site is started (Actual Start) when funds are obligated. An obligation is made when:
The EPA CO signs the contract modification or work assignment for the RD; or
~ A Cooperative Agreement is signed by the Regional Administrator or his designee; or
~ An IAG is signed by the other Federal agency.
In those instances where design assistance is conducted prior to ROD signature, and there is not a new obligation of funds
for a subsequent RD, the start of RD is defined as the written approval of the work plan to conduct these activities. If
there is a new obligation of funds, the start of RD is defined as the date funds are obligated. When a RD has been
prepared by other parties (e.g., water lines where the city already prepared plans and specifications) or plans developed
for a similar remedy will be used, the RD actual start date is the same as the RA actual start date.
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
PRP-financed RD from a Special Account (including Special Account Financed A ction performed by EPA (SA-lead),
the State (SS-Lead), or Tribal Governments (ST-lead) actions4) - A PRP-financed RD from a Special Account (Action
Name = Remedial Design) at an NPL or Superfund Alternative site is started (Actual Start) when funds are obligated.
An obligation is made when:
The EPA CO signs the contract modification or work assignment for the RD; or
~ A Cooperative Agreement is signed by the Regional Administrator or his designee; or
~ An IAG is signed by the other Federal agency.
In those instances where design assistance is conducted prior to ROD signature, and there is not anew obligation of funds
for a subsequent RD, the start of RD is defined as the written approval of the work plan to conduct these activities. If
there is a new obligation of funds, the start of RD is defined as the date funds are obligated. When a RD has been
prepared by other parties (e.g., water lines where the city already prepared plans and specifications) or plans developed
for a similar remedy will be used, the RD actual start date is the same as the RA actual start date.
PRP-financed under Federal enforcement (RP-lead) - The start (Actual Start) of a RP-lead RD (Action Name = PRP
RD) at a NPL or Superfund Alternative site is credited on the date the earlier of the following actions takes place:
The enforcement document under which the RD is to be conducted becomes effective;
For an Administrative Order on Consent (AOC), this is the date of signature of the AOC for RD by
the Regional Administrator or his delegatee, or the date of signature of an amendment to an existing
AOC to include RD;
For a Unilateral Administrative Order (UAO), this is the date of the PRP's written notice of intent to
comply with the UAO;
For a CD, this is the date the Regional Administrator signs the memorandum transmitting the CD to
DO.T or HQ; or
~ An official written notice to proceed is issued by EPA to the PRP.
PRP-financed under Federal enforcement (MR-lead) - The start (Actual Start) of a MR-lead RD (ActionName = PRP
RD) at an NPL or Superfund Alternative site is credited on the date the earlier of the following actions takes place:
The enforcement document under which the RD is to be conducted becomes effective:
For an Administrative Order on Consent (AOC), this is the date of signature of the AOC for RD by
the Regional Administrator or his delegatee, or the date of signature of an amendment to an existing
AOC to include RD;
For a CD, this is the date the Regional Administrator signs the memorandum transmitting the CD to
DO.T or HQ; or
4
Actions qualify for S A ST, aid SS leads, when the majority of funding for Hie total estimated response cost (including direct and
indirect costs) is to be paid from a Special Account. The amount contributed from a Special Account should meet or exceed the amount
contributed by the largest non-PRP entity (i.e. EPA, State where applicable) toward the total estimated response cost at the site. For example, if
60% of the funds needed to finance the estimated response are to be derived from a Special Account, and 40% of the response cost will be paid
out of Fund monies (or a lesser amount if State cost share is received), the majority of the response cost is being paid for out of a Special
Account and the action qualifies for a SA, ST, or SS lead.
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
An official written notice to proceed is issued by EPA to the PRP.
PRP-financed under State enforcement (PS-lead actions) - Credit will be given (Actual Start) for a PS-lead RD (Action
Name = PRP RD) at a NPL or Superfimd Alternative site based on the issuance or effective date of a State order or other
comparable State enforcement document for RD (or combined RD/RA). If the RD is covered by a pre-existing State
order, credit will be based on the notice to proceed date.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
The actual start date (Actual Start) of the RD (Action Name = Remedial Design or PRP RD) must be entered into
WasteLAN. Accomplishments are reported site-specifically. Funds for RDs are in the pipeline operations AO A. This
is a program measure. Superfund Alternative sites should be identified in WasteLAN using the special initiatives
indicator by designating these sites as "Superfund Alternative."
Data Entry Timeliness Requirement:
SPIM Action/
Activity
SPIM
Documentation
Documentation
Data Must Be Entered
Activity
Type
Lead
Required
Approval/ Date
By
Requirements
Action name =
Program
F, TR,
Contract modification
Signed by the EPA CO; or
It is good management
Remedial
Measure
S, SA,
or work assignment for
practice to enter data
Design (RD)
SS,
the RD,
regarding the event as soon
ST
as practicable after the
Cooperative
Signed by the Regional
event occurs. However,
Agreement,
Administrator or his
data must be entered prior
designee; or
to the end of the quarter in
which the event occurs.
or IAG.
An IAG signed by the
other Federal agency.
Action name =
Program
RP,
Official written notice
Official written notice from
It is good management
PRP RD (BE)
Measure
MR
from the EPA to the
the EPA
practice to enter data
PRP or the
regarding the event as soon
enforcement document
AOC signed by the
as practicable after the
under which the RD is
Regional Administrator or
event occurs. However,
to be conducted
his delegatee for the RD
data must be entered prior
becomes effective
to the end of the quarter in
(this can be either the
which the event occurs.
AOC , or an
amendment to an
existing AOC to
include RD; or
PRP's written notice
The PRP's written
notice of intent to
comply with the UAO;
or
Signed by Regional
Administrator.
Memo transmitting the
CD to DOJ or HQ).
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action name =
PRP RD (BE)
Program
Measure
PS
State order or other
comparable State
enforcement
document.
Signature and date on the
enforcement document.
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
/. RD COMPLETION (NPL & Superfund Alternative)
Definition:
The RD converts the remedy selected in the ROD into a final design document for RA.
Definition of Accomplishment:
A RD at an NPL or Superfund Alternative site is complete when:
Fund-financed (Including F-, TR-, and S-lead actions) - EPA approves, in writing, the final design document.
PRP-financed under Federal enforcement (IncludingMR- andRP-lead actions) - EPA approves, in writing,
the final design document.
PRP-financed under State enforcement (PS-lead actions) - the State approves the final design document.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
The actual completion date (Actual Complete) of the RD (Action Name = Remedial Design or PRP RD) must be entered
into WasteLAN. Accomplishments are reported site-specifically. This is a program measure. Superfund Alternative sites
should be identified in WasteLAN using the special initiatives indicator by designating these sites as "Superfund
Alternative." Regions are required to copy technical data from the ROD at completion of the RD. The regions are
required to update any technical or cost data if there are any changes. This can be accessed through the Selected Remedy
Summary screen.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Remedial
Design (RD)
Program
Measure
F, TR,
S, SA,
SS,
ST
Written EPA
approval of the
final design
document.
Not specified
It is good management practice to
enter data regarding the event as soon
as practicable after the event occurs.
However, data must be entered prior to
the end of the quarter in which the
event occurs.
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
PRP RD (BE)
Program
Measure
RP,
MR
Written EPA
approval of the
final design
document.
Not specified.
It is good management practice to
enter data regarding the event as soon
as practicable after the event occurs.
However, data must be entered prior to
the end of the quarter in which the
event occurs.
Action name =
PRP RD (BE)
Program
Measure
PS
State approval of
final design
document.
Not Specified
It is good management practice to
enter data regarding the event as soon
as practicable after the event occurs.
However, data must be entered prior to
the end of the quarter in which the
event occurs.
m. REMEDIAL ACTION (RA) START (NPL & PRP-leadSuperfund Alternative)
Definition:
A RA is the implementation of the remedy selected in the ROD. Fund-financed remedial actions (including RAs financed
from a Special Account) can only be funded at sites that are final on the NPL. PRP-fmanced (except RAs financed from
a Special Account) actions may be performed at NPL and Superfund Alternative sites.
The appropriate use of Special Account funds for remedial actions is provided in the "Guidance on Key Decision Points
in Using Special Account Funds" dated September 28, 2001.
DISCLAIMER: Regions will receive credit in the management of the Superfund program for "start" of a remedial action
even though "initiation of physical on-site construction" may not have occurred for purposes of calculating a cost
recovery statute of limitations. The date found in the remedial action actual start column of a CERCLIS 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.
Definition of Accomplishment:
Remedial Action
Fund-financed (Including F-, TR-, and S-lead actions) - Credit for a RA start at a final NPL site is given on
the date a contract modification for the RA is signed by the EPA CO or the IAG is signed by the other Federal
agency or Cooperative Agreement is awarded, and funds are obligated.
Credit for a subsequent RA start under an existing IAG is given on the date the amendment to the IAG to
include the new work is approved.
The actual start date (Actual Start) of the RA (Action Name = Remedial Action) is entered into WasteLAN.
If the action is initially funded by a bulk funding obligation, the start date is defined as the date the contracting
officer signs the work assignment form or equivalent which initiates the action at the site.
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
PRP- financed HA from a Special Account (including Special Account Financed Action performed by EPA
(SA-lead), the State (SS-Lead), or Tribal Governments (ST-lead) actions 5) - Credit for a RA start at a final
NPL site is given on the date a contract modification for the RA is signed by the EPA CO or the IAG is signed
by the other Federal agency or Cooperative Agreement is awarded, and funds are obligated. Such actions will
be counted towards the PRP-lead portion of the annual program target of 70% new PRP lead RA starts at NPL
and Superfund Alternative sites (see Enforcement Appendix C of the FY 04/05 SPIM, pages CI and C4).
Credit for a subsequent RA start under an existing IAG is given on the date the amendment to the IAG to
include the new work is approved.
The actual start date (Actual Start) of the RA (Action Name = Remedial Action) is entered into WasteLAN.
If the action is initially funded by a bulk funding obligation, the start date is defined as the date the contracting
officer signs the work assignment form or equivalent which initiates the action at the site.
PRP-financed under Federal enforcement (MR- lead actions) - Credit for a RA (Action Name = PRP RA)
start (Actual Start) at a NPL or Superfund Alternative site is given when either one of the following occurs and
has been recorded in WasteLAN:
If work is performed by the PRPs under the same CD as the RD, the RA start is the date EPA
approves, in writing, the PRP RD document (RD completion); or
Where the Fund performed the RD or the RD was done under a settlement/order for RD only and the
PRPs are doing the RA under the terms of a separate CD or judgment for RA only, the RA start date
(Actual Start) is either: (1) the same as the date (Actual Start) the Regional Administrator signs the
memorandum transmitting the CD (Action Name = Consent Decree) to DO.T or HQ, (2) the date
(Actual Complete) the judgment (Action Name = Judicial/Civil Judgment) was signed by the Federal
judge, or (3) the date EPA approves, in writing, the final design document for the RD (RD
completion), whichever of these dates that are applicable occur last.
PRP-financed under Federal enforcement (RP- lead actions) - Credit for a RA (Action Name = PRP RA)
start (Actual Start) at a NPL or Superfund Alternative site is given when one of the following occurs and has
been recorded in WasteLAN:
If work is performed by the PRPs under the same CD or UAO (RP-lead RA only) as the RD, the RA start is the
date EPA approves, in writing, the PRP RD document; or
Where the Fund performed the RD or the RD was done under a settlement/order for RD and the PRPs are doing
the RA under the terms of a separate CD, UAO (RP-lead RA only) or judgment for RA only, the RA start date
(Actual Start) is either: (1) the same as the date (Action Complete) of the PRP's written notice of intent to
comply with the UAO for the RP-lead RA (Action Name = Unilateral Admin Order and SubAction Name =
PRPs Ntfy EPA, Intent to Comply), (2) the date (Actual Start) the Regional Administrator signs the
memorandum transmitting the CD (Action Name = Consent Decree), (3) the date (Actual Complete) the
judgment (Action Name = Judicial/Civil Judgment) was signed by the Federal judge, or (4) the date EPA
5 Actions qualify for SA, ST, and SS leads, when the majority of funding toward the total estimated response cost
(including direct and indirect costs) is to be paid from a Special Account The amount contributed from a Special Account,
should meet or exceed the amount contributed by the largest non-PRP entity (i.e., EPA, State), toward the total estimated
response cost at the site. For example, if 50% of the funds needed to finance the estimated response are to be derived from a
Special Account, and 45% of the response cost will be paid out of Fund monies, and the State pays the remaining 5% share of the
response cost; the majority of the response cost is being paid out of a Special Account and the action qualifies for a SA, ST, or
SS lead.
Change 7, FY 04/05 SPIM
B-35
September 8, 2005
-------
OSWER Directive 9200.3-14-1G-Q
approves, in writing, the final design document for the RD (RD completion), whichever of these dates that are
applicable occur last. Where the PRP is in significant non-compliance with the UA O for the RP-lead RA, credit
will be with drawn.
PRP-financed under State enforcement (PS-lead actions) - If the PRP is doing work under a State order or
comparable enforcement document, and the NPL or Superfund Alternative site is covered by a State
enforcement cooperative agreement or State Memorandum of Agreement (SMO A) with a schedule for remedial
action work at the site, and EPA approved the ROD, the RA (Action Name = PRP RA) start (Actual Start) is
the date the State approves, in writing, the PRP RD document.
For both Fund- and PRP-financed actions - The region must identify the technologies to be constructed. To do this,
the following information must be entered into WasteLAN: the Alternative Name, Media Name, Media Type, and the
technology of the RA into the Response Action T ype field (Selected Response Actions). Regions must also indicate if
the RA is a long-term action (Critical Indicator = Long-Term Action).
Limited Remedial Action - RODs where the only action selected is Monitored Natural Attenuation and/or Institutional
Controls. Limited actions are distinguished from remedial actions because there is typically no remedial design and are
distinguished from no action/no further action RODs because there is at least some remedial action component. In the
case of monitored natural attenuation, natural processes are used to attain cleanup goals, and the remedial action may
only consist of adding monitoring wells and determining that the remedial action is complete. For institutional controls,
the remedial action consists of ensuring the institutional controls are in place. Regions should enter monitored natural
attenuation and institutional controls as remedial actions (Action Name = Remedial Action or PRP RA) with the Limited
RA critical indicator in WasteLAN.
Fund-financed (Including F-, TR-, andS-lead actions) - Credit for a Limited Action RA start at a final NPL
site is given on the date ROD selecting a limited remedial action is signed. The actual start date (Actual Start)
is entered into WasteLAN with the RA (Action Name = Remedial Action).
PRP-financed RA from a Special Account (including Special Account Financed Action performed by EPA
(SA-lead), the State (SS-Lead), or Tribal Governments (ST-lead) actions6) - Credit for a Limited Action RA
start at a final NPL site is given on the date the ROD selecting a limited remedial action is signed. The actual
start date (Actual Start) is entered into WasteLAN with the RA (Action Name = Remedial Action).
PRP-financed under Federal enforcement (RP-lead actions) - When the PRPs are doing the Limited Action
RA (Action Name = PRP RA) at a NPL or Superfund Alternative site under the terms of a CD, UAO or
judgment for RA only, the RA start date (Actual Start) is the same as the date (Action Complete) of the PRP's
written notice of intent to comply with the UAO (Action Name = Unilateral Admin Order and SubActionName
= PRPs Ntfy EPA, Intent to Comply); or the date the Regional Administrator signs the memorandum
transmitting the CD (Action Name = Consent Decree) to DO.T or HQ; or the date (Actual Complete) the
judgment (Action Name = Judicial/Civil Judgment) was signed by the Federal judge. Where the PRP is in
significant non-compliance with the UAO, credit will be withdrawn.
PRP-financed under Federal enforcement (MR-leadactions) - When the PRPs are doing the Limited Action
RA at a NPL or Superfund Alternative site under the terms of a CD or judgment for RA only, the RA start date
(Actual Start) is the same as the date (Actual Start) the CD (Action Name = Consent Decree) is transmitted by
6Actions qualify for SA, ST, and SS leads, when the majority of funding toward total estimated response cost
(including direct and indirect costs) is to be paid from a Special Account The amount contributed should meet or exceed the
amount contributed by the largest non-PRP entity (i.e., EPA, State), toward the total estimated response cost at the site. For
example, if 50% of the funds needed to finance the estimated response are to be derived from a Special Account, and 45% of the
response cost will be paid out of Fund monies, and the State pays the remaining 5% share of the response cost; the majority of
the response cost is being paid out of a Special Account and the action qualifies for a SA, ST, or SS lead.
September 8, 2005
B-36
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
the Regional Administrator to HQ or the DO.T; or the date (Actual Complete) the judgment (Action Name =
Judicial/Civil Judgment) was signed by the Federal judge.
PRP-financed under State enforcement (PS-lead actions) - When the PRPs are doing the Limited Action RA
(Action Name = PRP RA) at a NPL or Superfund Alternative site under a State order or comparable
enforcement document, and the site is covered by a State cooperative agreement or SMOA with a schedule for
work at the site, and EPA approved the ROD, the Limited Action RA starts (Actual Start) on the issuance or
effective date of the enforcement instrument.
For both Fund, Special Account, and PRP-financed actions - The region must identify the technologies to be constructed.
To do this, the following information must be entered into W asteLAN: the Alternative Name, Media Name, Media Type,
and the technology of the RA into the Response Action Type field (Selected Response Actions). Regions must also
indicate the RA is a limited remedial action (Critical Indicator = Limited Remedial Action).
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
This is a program measure. The actual start date (Actual Start) of the RA (Action Name = Remedial Action or PRP RA),
the critical indicator (Long-Term Action or Limited Remedial Action), and, for PRP-lead RAs, the appropriate
enforcement information must be entered into WasteLAN. The region must enter the Alternative Name, Media Name,
Media Type, and the remedial response actions (Selected Response Actions) associated with the RA into WasteLAN.
Funds for Fund-financed RAs are planned on a site-specific basis and are placed by name in the RA AOA. Funds for
oversight of RP-leadRAs are planned on a site-specific basis and are found in the pipeline operations AOA. Superfund
Alternative sites should be identified in WasteLAN using the special initiatives indicator by designating these sites as
"Superfund Alternative."
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Remedial Action
(RA)
Program
Measure
F, TR,
S, SA,
SS,
ST
Contract
modification for the
RA or IAG.
RA signed by the
EPA CO; or
IAG signed by the
other Federal
agency.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
PRP RA (BF)
Program
Measure
MR
Written approval by
the EPA of the PRP
RD document or,
Memo transmitting
the CD to DOJ or
HQ
The judgment, or
written approval
from the EPA of the
final design
document for the
RD.
Not specified
Signed by the
Regional
Administrator
Signed by the
Federal judge
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Change 7, FY 04/05 SPIM
B-37
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
PRP RA (BF)
Program
Measure
RP
Written approval
from EPA of the
PRP RD document;
or
PRP's written notice
of intent to comply
with the UAO
Memo transmitting
the CD and
judgment
EPA written
approval of the final
design document.
Not specified
Not specified
Memo signed by
the Regional
Administrator;
judgment signed
by the Federal
judge
100% design
approval by EPA
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
PRP RA (BF)
Program
Measure
PS
Written approval
from the State of the
PRP RD document.
Not specified
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
Remedial Action
(RA):
Limited
Remedial Action
Program
Measure
F, TR,
S, SA,
SS,
ST
Signed ROD.
ROD signature
date
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
PRP RA (BF):
Limited
Remedial Action
Program
Measure
RP
PRP's written notice
of intent to comply
with the UAO; or
Memo transmitting
the CD to DOJ or
HQ; or
A judgment.
Not specified
Signed by the
Regional
Administrator
Signed by the
federal judge.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
PRP RA (BF):
Limited
Remedial Action
Program
Measure
MR
CD transmitted by
the regional
Administrator to HQ
or the DOJ; or
Judgment.
Not specified
Signed by the
Federal judge.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
PRP RA (BF):
Limited
Remedial Action
Program
Measure
PS
Enforcement
instrument.
Not specified
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
n. RA CONTRACT A WARD (NPL & PRP-lead Superfund Alternative)
Definition:
Award of RA contract is the date a contract for construction of the remedy is awarded.
Definition of Accomplishment:
Fund-financed (Including F-, TR-, and S-lead actions) - Date (recorded in WasteLAN as an Actual Complete) when
the EPA, State, USACE, orBUREC awards (signs) a contract to initiate a Fund-financed RA.
If a RAC contractor is assigned RA responsibility, the award of RA contract at a final NPL site is defined as the date the
RA subcontract is signed by the contractor. If an ERRS contractor will be performing the RA, award ofRA contract is
defined as the date (Actual Complete) the contract modification for the RA is signed by the EPA CO.
PRP-financed under Federal enforcement (Including MR-, RP-, and PS-lead actions) - Date (recorded in WasteLAN
as an Actual Complete) when the PRP awards a contract to initiate the RA at a NPL or Superfund Alternative site, as
documented in a memorandum to the site file.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
The actual completion date (Actual Complete) must be placed in WasteLAN with the RA SubAction, Award of RA
Contract (Action Name = Remedial Action or PRP RA and SubAction Name = Award of Contract). This is a program
measure. Superfund Alternative sites should be identified in WasteLAN using the special initiatives indicator by
designating these sites as "Superfund Alternative."
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Remedial
Action(RA)
Program
Measure
F, TR,
S
Contract,
subcontract, or
contract
modification.
EPA, State, USACE, or
BUREC signed contract.
RA subcontract signed by
the RAC contractor or the
contract modification for the
RA signed by the EPA CO.
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the event
occurs.
Action name =
PRP RA (BF)
Program
Measure
MR,
RP,
PS
Memo
documenting PRP
awarded contract.
Not specified
It is good management
practice to enter data
regarding the event as soon
as practicable after the event
occurs. However, data must
be entered prior to the end of
the quarter in which the event
occurs.
Change 7, FY 04/05 SPIM
B-39
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
o. START OF ON-SITE CONSTRUCTION
Definition:
This measure counts all removal actions, remedial actions, limited remedial actions, or RODs for groundwatermonitoring
at non-NPL, NPL, or Superfund Alternative sites.
Remedial Actions - A remedial action is the implementation of the remedy selected in the ROD. Remedial actions can
only be funded at sites that are on the final NPL. This measure tracks each remedial action on-site construction at a site.
Limited Remedial Action - Limited remedial actions result from RODs which select monitored natural attenuation to
attain cleanup goals and/or institutional controls as the only response actions. Limited actions are distinguished from
no action/no further action RODs, such as those where groundwater monitoring is the only response activity selected.
Regions should enter monitored natural attenuation and institutional controls as remedial actions (Action Name =
Remedial Action or PRP RA) in WasteLAN.
Groundwater monitoring is defined as the collection and analysis of groundwater samples as a result of a ROD that
addresses groundwater contamination at a site or operable unit. The purpose of the groundwater monitoring is to ensure
that ROD assumptions regarding no action on the groundwater are correct rather than to verify performance of a
groundwater restoration or containment remedy. If the ROD specifies that groundwater monitoring is the only activity
that will be implemented during an operable unit groundwater cleanup, then it is a no action or no further action ROD.
For this type of activity, regions should enter a groundwatermonitoring activity/action: [Action Name = Grndwtr Monitor
(Post-ROD)] into WasteLAN.
Definition of Accomplishment:
Remedial Action (RA On-Site Construction) - A site is addressed through a remedial action when the EPA, RAC, the
USACE,BUREC, State or PRP, or their contractors have begun on-site construction work at a site for the remedial action
remedy selected in the ROD.
Fund-financed (Including F-, TR-, and S- lead actions) - EPA, the State or their contractors have begun work
for on-site construction of the remedy at a site on the final NPL. A memo to file documenting that the
contractor has mobilized and began substantial and continuous physical on-site remedial action is required.
This date is entered into WasteLAN as the RA On-Site Construction SubAction (Action Name = Remedial
Action and SubAction Name = RA On-Site Construction Start) actual completion date (Actual Complete).
PRP-financed under Federal enforcement (Including RP- and MR- lead actions) - The PRPs or their
contractors have begun work at a NPL or Superfund Alternative site for on-site construction of the remedy.
The date of on-site construction must be documented in a memorandum to the site file stating when the
contractor began substantial and continuous physical on-site remedial action. A copy of a report of start up
from the contracting party is also acceptable. The date of on-site construction must be entered into WasteLAN
as the RA On-Site Construction SubAction (Action Name = PRP RA and SubAction Name = RA On-Site
Construction Start) actual completion date (Actual Complete).
In addition, to receive credit under this measure, the PRPs must be in compliance with a UAO, or an enforcement
instrument signed by EPA and the PRPs, or a judgment signed by a Federal judge. The following information must be
entered into WasteLAN for the enforcement instrument:
The date (Actual Complete) the PRPs provide notice of intent to comply (Action Name = PRP Notfy
EPA of Intent to Comply) with a UAO for the RP-lead RA signed (Actual Complete) by the designated
Regional official (Action Name = Unilateral Admin Order), and the Response Acts Pd by Parties of
"PRP RA"; or
September 8, 2005
B-40
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
The date the CD (Action Name = Consent Decree) was signed by the PRPs, the designated Regional
official, and the Federal judge (Actual Complete), and the Response Acts Pd by Parties of'PRP RA";
or
The date a judgment (Action Name = Judicial/Civil Judgment) was signed by the Federal judge
(Actual Complete), and the Response Acts Pd by Parties of'PRP RA."
PRP-financed under State enforcement (PS-lead actions) - The PRPs or their contractors have begun work
at a NPL or Superfund Alternative site for on-site construction of the remedy. The date of on-site construction
must be documented in a memorandum to the site file stating when the contractor began substantial and
continuous physical on-site remedial action. A copy of a report of start up from the contracting party is also
acceptable. The date of on-site construction must be entered into WasteLAN as the RA On-Site Construction
SubAction (ActionName = PRP RA and SubActionName = RA On-Site Construction Start) actual completion
date (Actual Complete). In addition, to receive credit under this measure, the PRPs must be working under a
State enforcement instrument.
Limited Remedial Action - Credit for the start of a Limited Action RA is given when:
Fund-financed (Including F-, TR-, and S-lead actions) - The ROD selecting a limited remedial action is
signed at a site on the final NPL. The actual start date (Actual Start) is entered into WasteLAN with the RA
(Action Name = Remedial Action).
PRP-financed under Federal enforcement (Including MR- andRP- lead actions) - When the PRPs are doing
the Limited Action RA at a NPL or Superfund Alternative site under the terms of a CD, UAO or judgment for
Limited Action RA only, the RA start date (Actual Start) is the same as the date (Action Complete) of the
PRP's written notice of intent to comply with the UAO for the RP-leadRA (ActionName = Unilateral Admin
Order and SubActionName = PRPsNtfy EPA, Intent to Comply); or the date the Regional Administrator signs
the memorandum transmitting the CD (Action Name = Consent Decree) to DO.T or HQ [as recorded in
WasteLAN as the actual CD (Action Name = Consent Decree) start (Actual Start)]; or the date a judgment
(Action Name = Judicial/Civil Judgment) is signed by the Federal judge (Actual Complete). Where the PRP
is in significant non-compliance with the UAO for the RP-lead RA, credit will be withdrawn.
PRP-financed under State enforcement (PS-lead) - When the PRPs are doing the Limited Action RA (Action
Name = PRP RA) at a NPL or Superfund Alternative site under a State order or comparable enforcement
document, and the site is covered by a State cooperative agreement or SMOA with a schedule for work at the
site, and EPA approved the ROD, the Limited Action RA start (Actual Start) is the issuance or effective date
of the enforcement instrument;
Groundwater Monitoring (as the only activity taken at the site or groundwater operable unit) - Credit is given for
a groundwater monitoring activity [Action Name = Grndwtr Monitor (Post-ROD)] start (Actual Start) when:
Fund-financed (Including F-, TR-, and S- lead actions) - Fund-financed Groundwater Monitoring starts at
a site on the final NPL when:
EPA, the State, or their contractors take the first sample of an existing well after the ROD is signed;
or
EPA, the State, or their contractors have begun work for on-site construction of a new well, if
necessary, after the ROD is signed.
This date is documented in a memo to the file.
Change 7, FY 04/05 SPIM
B-41
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
PRP-financed under Federal enforcement (Including MR- and RP- lead actions) - PRP-financed
groundwater monitoring under Federal enforcement starts at a NPL or Superfund Alternative site when:
The PRPs or their contractors take the first sample of an existing well after the ROD is signed; or
The PRPs or their contractors have begun work at a site for on-site construction of a new well, if
necessary, after the ROD is signed.
This date is documented in a memo to the file.
PRP-financed under State enforcement (PS-leadactions) - PRP-financed groundwater monitoring under State
enforcement starts at a NPL or Superfund Alternative site when a State order or comparable State enforcement
document is signed by the last State official.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
RAs, limited remedial actions, and groundwater monitoring (post-ROD) starts will be tracked separately for management
purposes. Groundwater monitoring and oversight of groundwater monitoring is covered under the Pipeline Operations
AOA. The date of RA on-site construction (Action Name = Remedial Action and SubAction Name = RA On-site
Construction Start) will be used for purposes of establishing the Statute of Limitation (SOL) determination. It is also
used as the trigger date for a statutory Five-Year Review, if applicable. The Five Year Review planned completion date
is set for five years after the RA On-Site Construction Start planned start date. The Five Year Review planned
completion date will be greyed out and uneditable once the actual start date for the RA On-Site Construction Start is
entered. This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Remedial Action
(RA):
SubAction name
= RA On-Site
Construction
(RG)
Program
Measure
F, TR,
S
Memo
Not specified
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
PRP RA (BF):
SubAction name
= RA On-Site
Construction
(RG)
Program
Measure
RP,
MR
Memo or a copy of
a report of start up
from the
contracting party
Memo to site file.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
PRP RA (BF):
SubAction name
= RA On-Site
Construction
(RG)
Program
Measure
PS
Memo or a copy of
a report of start up
from the
contracting party.
State enforcement
instrument
Memo to site file.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
September 8, 2005
B-42
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Limited
Remedial Action
(RA)
SubAction name
= RA On-Site
Construction
(RG)
Program
Measure
F, TR,
S
Signed ROD.
Not specified
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
Unilateral Admin
Order (UA)
Consent Decree
(CD)
Judicial/Civil
Judgement (JG)
Program
Measure
MR,
RP
PRP's written
notice of intent to
comply with UAO;
or
Memo transmitting
the CD to DOJ or
HQ; or
Judgment signed
by the Federal
judge.
Not specified
Signed by the
Regional
Administrator
Signed by the
Federal judge.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
Limited PRP RA
(BF)
Program
Measure
PS
State order or
comparable
enforcement
document and a
State cooperative
agreement of MOA
EPA approved
ROD Enforcement
instrument.
Not specified
Not specified
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
Grndwtr Monitor
(Post-ROD)
(GM)
Program
Measure
F, TR,
S
Start:
Signed ROD and
Memo.
Start:
Not specified
Memo to site file.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Action name =
Grndwtr Monitor
(Post-ROD)
(GM)
Program
Measure
MR,
RP
Start:
Signed ROD and
Memo.
Start:
Not specified
Memo to site file.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Grndwtr Action
name = Monitor
(Post-ROD)
(GM)
Program
Measure
PS
Start:
State order or
comparable State
enforcement
document.
Start:
Signed by last State
official
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Change 7, FY 04/05 SPIM
B-43
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
p. OPERA TIONAL AND FUNCTIONAL (O&F)
Definition:
O&F activities are conducted after physical construction of the remedy is complete to ensure that it is functioning
properly and operating as designed. A remedy is determined to be operational and functional either one year after
construction is complete, or when EPA and the state concur that the remedy is functioning properly and is performing
as designed. EPA may grant extensions to the one-year period, as appropriate. O&F activities occur during the last year
of the RA activities. O&F determinations are only made for those remedies that have an operation and maintenance
(O&M), Long-term response action (LTRA), or PRP Long-term response action (PRP LR) component. All leads except
Federal facilities may have an O&F determination. Monitored natural attenuation also has a simplified O&F
determination. EPA is responsible for the O&F determination (with concurrence from the appropriate parties); therefore
all O&F subactions are given a Fund-financed lead code.
Definition of Accomplishment:
O&F activities are completed when the appropriate parties (e.g., State, PRP) concur that the remedy is operational and
functional, and the completion (Actual Completion Date) of O&F (SubAction Name = Operational and Functional) is
documented by a letter from EPA to the appropriate parties. The date of O&F is also documented in the Interim or Final
RA Report, which is to be approved by the Region within 90 days after the remedy is O&F.
Changes in Definition FY 02/03 - FY 04/05:
The applicability of the O&F determination has been clarified.
Special Planning/Reporting Requirements:
The completion (Actual Complete) of O&F (Action Name = Operational and Functional) are reported site and OU
specifically in WasteLAN. This is a program measure. As a subaction, O&F does not receive funding.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
SubAction
Name =
Operational and
Functional (OF)
Program
Measure
F
Interim or Final RA
Report
Letter to the
interested parties.
Approved by the
Region within 90 days
after the remedy is
O&F
Not specified
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the
quarter in which the event occurs.
September 8, 2005
B-44
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
q. COMPLETION OF A RESPONSE A CTION/A CTIVITY (NPL & PRP-lead Superfund
Alternative)
Definition:
Remedial Actions - A Fund-financed remedial action at a final NPL site or PRP-lead remedial action at a NPL or
Superfund Alternative site is the implementation of the remedy selected in the ROD. Remedial actions can only be
funded at sites that are final on the NPL. This measure tracks each remedial action completion at a site.
Limited Remedial Action - Fund-financed limited remedial actions at a final NPL site or PRP-lead limited remedial
actions at NPL or Superfund Alternative sites result from RODs which select monitored natural attenuation to attain
cleanup goals and/or institutional controls as the only response actions. Limited actions are distinguished from remedial
actions because there is typically no remedial design; and are distinguished from no action/no further action RODs
because there is at least some remedial action component. In the case of monitored natural attenuation, the remedial
action may only consist of adding monitoring wells and sampling until it is determined that the cleanup goals are met.
For institutional controls, the remedial action consists of ensuring the institutional controls are in place. Regions should
enter monitored natural attenuation and institutional controls as remedial actions (Action Name = Remedial Action or
PRP RA) with the Limited RA critical indicator in WasteLAN.
Groundwater Monitoring (Post-ROD) - Fund-financed groundwater monitoring at a final NPL site or PRP-lead
groundwater monitoring at a NPL or Superfund Alternative site is defined as the collection and analysis of groundwater
samples as a result of a ROD that addresses groundwater contamination at a site or operable unit. The purpose of the
groundwater monitoring is to ensure that ROD assumptions regarding no action on the groundwater are correct rather
than to verify performance of a groundwater restoration or containment remedy. If the ROD specifies that groundwater
monitoring is the only activity that will be implem ented during a operable unit groundwater cleanup, then it is a no action
or no further action ROD. Enter groundwater monitoring actions [Action Name = Grndwtr Monitor (Post-ROD)] into
WasteLAN.
Remedial action, limited remedial action, and groundwater monitoring (post ROD) completion swill be tracked separately
but accomplishments will be reported on a combined basis.
Definition of Accomplishment:
Remedial Action Completion (Fund- or PRP-financed) - A Fund-financed RA completion at final NPL or a PRP-lead
RA completion at a NPL or Superfund Alternative (Formerly NPL-Equivalent) site is achieved when the designated
Regional official (Branch Chief or above, as determined by the EPA region) approves, in writing, the Interim or Final
Remedial Action Report. 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. The date of the acceptance of the Interim or Final RA Report must be
entered into WasteLAN as the RA (Action Name = Remedial Action or PRP RA) actual completion date (Actual
Completion).7 If the Interim or Final RA report is delayed beyond 90 days, then the O&F determination (not RA
completion) will be used for LTRA start, PRP LR start, or O&M start, as applicable.
An action qualifier must be entered into W asteLAN indicating the RA was completed via an Interim or Final RA Report
(Action Qualifier = Interim RA or Final RA).
7
The Interim or Final RA report may take some time to compile; however, the goal is to have the report submitted to
the Region for approval within 90 days of the final inspection or O&F determination.
Change 7, FY 04/05 SPIM
September 8, 2005
B-45
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OSWER Directive 9200.3-14-1G-Q
Interim Remedial Action Report
Criteria for EPA approval of the Interim RA Report are:
~ The remedy includes groundwater or surface water restoration, with active treatment or monitored natural
attenuation, to reduce contaminant concentrations to meet cleanup goals (and cleanup goals have not been
achieved);
For active treatment, the construction of the treatment system is completed, and the system is operating as
intended (operational & functional);
For monitored natural attenuation, any necessary RA, such as monitoring wells, has been constructed;
~ If the OU includes remedy components other than groundwater, construction activities are complete and
cleanup goals specified in the ROD have been achieved for these components;
A contract final inspection or equivalent has been conducted; and
The Interim RA Report contains the information described in, OSWER Directive 9320.2-09A-P, "Close Out
Procedures for National Priorities List Sites."
Note: When an Interim RA Report has already been prepared, the Interim RA report can simply be amended to create
the Final RA Report. The amendment would add information on activities that occurred after the Interim RA Report was
completed.
Final Remedial Action Report
Criteria for approval of the Final RA Report for a given OU are:
~ All construction activities are complete, including site restoration and demobilization;
All cleanup goals specified in the ROD have been achieved, including those for ground- and surface water
restoration, if applicable;
If containment, the remedy is operating as intended (operational & functional)
A contract final inspection or equivalent has been conducted; and
The Final RA Report contains the information described in, OSWER Directive 9320.2-09A-P, "Close Out
Procedures for National Priorities List Sites."
The following table provides examples of remedial actions and indicates when Remedial Action Completion can be
achieved.
Remedial Action Completion Examples
Example RA
RA Complete
Excavation and off-site disposal of contamination.
After all wastes have been excavated and removed from the
site to an approved location; site has been restored; cleanup
goals have been achieved; and the Final RA Report is
approved.
On-site treatment of wastes, other than
groundwater or surface water, to achieve cleanup
goals (e.g., soil vapor extraction, bioremediation,
incineration).
After cleanup goals have been achieved for the treated
wastes, site has been restored, and the Final RA Report is
approved.
Containment remedies.
After construction of the designed remedy is complete,
cleanup goals have been achieved, and the Final RA Report
is approved.
September 8, 2005
B-46
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Example RA
RA Complete
Groundwater and surface water restoration
remedies that involve active treatment to reduce
contaminant concentrations to meet cleanup goals.
After construction of the treatment plant and monitoring
system are completed, the plant/system is operating as
intended, (also called operational and functional, O&F) and
the Interim RA Report is approved. (The Final RA Report
is prepared when cleanup levels are achieved.)
Groundwater and surface water restoration
remedies where restoration is later determined to
be technically impracticable (TI waiver).
RA completion has already been documented by an interim
RA Report, as above; however, the region, must prepare a
ROD amendment to document the TI waiver.
Limited Remedial Action Completion (Fund- or PRP-financed)
The following table provides examples of limited remedial actions and indicates when Limited Remedial Action
Completion can be achieved.
Limited Remedial Action Completion Examples
Example RA
RA Complete
Groundwater and surface waterrestoration remedies
that involve monitored natural attenuation to reduce
contaminant concentrations to meet cleanup goals.
After the ROD is signed, any necessary RA is conducted, and
the Interim RA Report is approved. (Final RA Report is
prepared when natural attenuation cleanup goals are
achieved.)
Implement institutional controls.
When institutional controls are implemented as summarized
in the Final RA Report.
Groundwater Monitoring (as the only activity taken at the site or groundwater operable unit)
Groundwater monitoring [Action Name = Grndwtr Monitor (Post-ROD)] completion at a final NPL site or PRP-lead
groundwatermonitoring completion at a NPL or Superfund Alternative site is defined as the date (Actual Complete) EPA
determines that groundwater monitoring is no longer necessary. This determination may be documented in the Final
Superfund Close-Out Report, five-year review report, or memorandum signed by the appropriate Regional official. A
RA Report is not prepared since a RA is not being performed.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Remedial action, limited remedial action and groundwater monitoring (po st ROD) completions will be tracked separately
but accomplishments will be reported on a combined basis. Regions must enter an action qualifier into WasteLAN
indicating the RA was completed via an Interim or Final RA Report (Action Qualifier = Interim RA or Final RA).
Superfund Alternative sites should be identified in WasteLAN using the special initiatives indicator by designating these
sites as "Superfund Alternative."
Change 7, FY 04/05 SPIM
B-47
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Remedial Action
(RA)
Completion
Program
Measure
F, S,
TR,
MR,
RP, PS
Written approval of
the Interim or Final
Remedial Action
Report.
Written approval from
the designated
Regional official of
the Interim or Final
Remedial Action
Report.
It is good management practice
to enter data regarding the event
as soon as practicable after the
event occurs. However, data
must be entered prior to the end
of the quarter in which the event
occurs.
Action name =
Limited
Remedial Action
(RA)
Completion
Program
Measure
F, S,
TR,
MR,
RP, PS
ROD
Interim or Final RA
Report.
Signed by
appropriate Regional
official
Approved by the
Region within 90
days after the remedy
is O&F
It is good management practice
to enter data regarding the event
as soon as practicable after the
event occurs. However, data
must be entered prior to the end
of the quarter in which the event
occurs.
Action name =
Grndwtr Monitor
(Post-ROD)
(GM)
F, S,
TR,
MR,
RP, PS
Completion:
Final Superfund
Close-Out Report,
Five Year review
report,
memorandum .
Completion:
Not specified
Not specified
Signed by
appropriate Regional
official.
It is good management practice
to enter data regarding the event
as soon as practicable after the
event occurs. However, data
must be entered prior to the end
of the quarter in which the event
occurs.
r. NPL SITE CONSTRUCTION COMPLETIONS
Definition:
Construction at a NPL site is considered complete when physical construction is complete for the entire site as a result
of one or several removal or remedial actions; and a Preliminary orFinal Close Out Report (PCOR or FCOR) has been
signed by the designated Regional official and concurred with by HQ. The report must address construction activities
for the entire site. There is only one NPL site construction completion per NPL site. For more detailed information, see
OSWER Directive 9320.2-09A-P, "Close Out Procedures for National Priorities List Sites."
September 8, 2005
B-48
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
The following table explains coding and accomplishment requirements.
NPL Site Construction Completion
Examples of last OU or activity
When Construction is Complete
Coding Requirements
1) Excavation and off-site
disposal of contamination,
2) On-site treatment of wastes
(except for groundwater
restoration, bioremediation or soil
vapor extraction), or
3) Containment remedies.
Pre-final inspection has been
conducted, only minor punch list
items remain, and the designated
Regional official has signed the
Preliminary or Final Close-Out
Report (PCOR or FCOR).
The region enters completion date of
the report into WasteLAN as the
actual completion date (Actual
Complete) of the Preliminary Close-
Out Report [Action Name = Prelim
Close-Out Rep Prepared], or the
actual completion date (Actual
Complete) ot the Final Close-Out
Report [Action Name = Close Out
Report]
AND
F1Q enters the Construction
Completion indicator into WasteLAN.
This action constitutes F1Q
concurrence with the PCOR or FCOR
documentation.
In-situ bioremediation, ex-situ
bioremediation, or soil vapor
extraction.
Treatment unit has been
constructed, is operating as
designed, studies show that
technology will achieve cleanup
goals, and the designated Regional
official has signed the PCOR.
Groundwater and surface water
restoration remedies that involve
active treatment to reduce
contaminant concentrations to
meet cleanup goals.
Remedy is documented in final
ROD (interim action RODs must
be finalized), physical construction
of the remedy is complete, and the
designated Regional official has
signed the PCOR.
Groundwater and surface water
restoration remedies that involve
monitored natural attenuation to
reduce contaminant
concentrations to met cleanup
goals
Remedy is documented in final
ROD (interim action RODs must
be finalized),any necessary
physical construction is complete,
and the designated Regional
official has signed the PCOR.
RODs with contingency remedies
Physical construction of the
remedy is complete, a pre-fmal
inspection has been conducted,
only minor punch list items
remain, the PCOR or FCOR
demonstrates that use of the
contingency is not anticipated, and
the designated Regional official
has signed the PCOR or FCOR.
Sites deleted from the NPL prior to
reaching Construction Completion.
When (1) EPA determines that all
physical construction is complete
under all statutory authorities, and
(2) all other applicable
construction completion policy
criteria have been satisfied.
Consistent with requirements for final
NPL sites.
Change 7, FY 04/05 SPIM
B-49
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
NPL Site Construction Completion
Examples of last OU or activity
When Construction is Complete
Coding Requirements
Sites requiring no remedial action
or no further remedial action in
the last OU. This includes
groundwater monitoring if that is
the only activity specified in the
ROD.
No action or no further action
ROD has been signed, and the
designated Regional official has
signed the PCOR or FCOR.
Effective in FY99, No Action
RODs will not be accepted for
Construction Completion.
The region enters the completion date
of the report into W asteLAN as the
actual completion date (Actual
Complete) of the PCOR (Action
Name = Prelim Close-Out Report
Prepared) or the actual completion
date (Actual Complete) of the Final
Close-Out Report (Action Name =
Close Out Report).
AND
HQ enters the Construction
Completion indicator into WasteLAN.
This action constitutes HQ
concurrence with the PCOR or FCOR
documentation.
Institutional controls
as the only remedy in the ROD.
The PCOR indicates that the
institutional controls are in the
schedule for site completion, and
the designated Regional official
has signed the PCOR. If
institutional controls have been
implemented, region can go
directly to FCOR.
NPL site entirely addressed
through removal actions. For
removals with institutional
controls, see above.
Fund-Financed:
Contractor has demobilized, as
recorded in POLREP.
PRP-Fin an ced:
Region certifies that PRPs or their
contractor have completed the
removal specified in the Action
Memorandum and fully met the
terms of the AO, CD or judgment
Both Fund- and PRP-Financed:
The designated Regional official
has signed the FCOR. The FCOR
must demonstrate that the removal
process included an EE/CA, which
complies substantially with NCP
requirements.
The region enters the following into
WasteLAN: The removal (Action
Name = Removal Action or PRP
Removal) actual completion date
(Actual Complete) as reported in the
POLREP; and the Qualifier that
indicates that the site is Cleaned Up;
and the actual completion date
(Actual Complete) of the Final Close-
Out Report (Action Name = Close Out
Report);
AND
HQ enters the Construction
Completion indicator into WasteLAN.
This action constitutes concurrence
with the FCOR documentation.
If an FCOR can be prepared initially, then the site can achieve the NPL Construction Completion and NPL Site
Completion measure simultaneously. EPA is responsible for documenting construction completion, therefore all
PCOR and FCOR actions are given a Fund-financed lead code.
Changes in Definition FY 02/03 - FY 04/05:
Changes made to the coding requirements column as a result of the PCOR and FCOR becoming an action level
activity rather than a subaction. All PCOR and FCOR actions are now given a Fund-financed lead code.
September 8, 2005
B-50
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Special Planning/Reporting Requirements:
Regions will not receive credit for a NPL Site Construction Completion until the actual completion date of the
Preliminary or Final Close-Out Report is entered into WasteLAN, the necessary documentation is submitted to HQ, and
HQ enters the construction completion indicator into WasteLAN. Regions identify sites to meet the goal prior to the start
of the FY. Regions may receive credit under this measure and the NPL Site C ompletion measure as a result of the same
remedial action or removal action. This is a GPRA annual performance goal.
Policy Five Y ear Review planned completion date is set for five years after the PC OR orFCOR planned completion date.
The Five Year Review planned completion date will be greyed out once the actual completion date of the PCOR or
FCOR is entered.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
Prelim Close-
Out Rep
Prepared (CM)
or Close Out
Report (CQ)
GPRA Annual
Performance
Goal
F
Preliminary or
Final Close-Out
Report (PCOR or
FCOR)
Signed by designated
Regional official and
concurred with by HQ.
Within five working days,
but no later than ten
working days.
Action Name =
Removal Action
(RV)
GPRA Annual
Performance
Goal
F, S, TR,
SA, SS,
ST
POLREP
FCOR
Final POLREP
Signed by designated
Regional Official
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
Action Name =
PRP Removal
(BB)
GPRA Annual
Performance
Goal
MR, RP,
PS
Action
Memorandum
FCOR
Not specified
Signed by designated
Regional Official
It is good management
practice to enter data
regarding the event as soon
as practicable after the
event occurs. However,
data must be entered prior
to the end of the quarter in
which the event occurs.
Change 7, FY 04/05 SPIM
B-51
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
PART III. POST CONSTRUCTION COMPLETION
v. LONG-TERM RESPONSE ACTION (LTRA and PRPLR) (NPL & PRP-lead
Superfund Alternative)
Definition:
LTRA at a final NPL site is defined as the Fund-financed, or PRP-fmanced from a special account, operation of
groundwater and surface water restoration actions (including monitored natural attenuation) involving treatment or other
measures to restore ground- or surface-water quality to a level that assures protection of human health and the
environment. The period of LTRA is administratively complete when:
Measures restore ground- or surface-water quality to a level that assures protection of human health
and the environment;
Measures restore ground- or surface-water to such a point that the reductions in contaminant
concentrations are no longer significant; or
Ten years have elapsed; whichever is earliest.
PRP LR (PRP long-term response) is a specific type of O&M for those remedies with operation of ground-water and
surface-water restoration actions (including monitored natural attenuation) involving treatment or other measures to
restore ground- or surface-water quality to a level that assures protection of human health and the environment. The
period of PRP LR is administratively complete when:
Measures restore ground- or surface-water quality to a level that assures protection of human health
and the environment; or
Measures restore ground- or surface-water to such a point that the reductions in contaminant
concentrations are no longer significant; whichever is earliest.
Note that LTRA and PRP LR do not apply to other remedies that require a long time to achieve cleanup goals, such as
bioremediation, or soil vapor extraction. LTRA and PRP LR also do not apply to groundwater or surface water
containment measures, groundwater monitoring, groundwater or surface water measures initiated for the primary purpose
of providing a drinking water supply.
The appropriate use of Special Account funds is provided in the "Consolidated Guidance on the Establishment,
Management and Use ofCERCLA Special Accounts" dated October4, 2002.
Definition of Accomplishment:
Fund-financed LTRA, PRP-financed from a Special Account (Including Special Account Financed Action
performed by EPA (SA-lead), the State (SS-lead), or Tribal Government (ST-lead) actions) or PRP LR Start:
LTRA at a final NPL site or PRP-LR at a NPL or Superfund Alternative site (Action Name = Long Term Response or
PRP LR) begins (Actual Start Date) on the date the remedy is determined to be O&F. Note that RA completion may
occur later than LTRA start because the Interim RA Report is to be submitted to the Region for approval within 90 days
of the O&F determination.
Fund-financed LTRA or PRP-financed from a Special Account Completion: LTRA at a final NPL site is complete
(Actual Complete Date) ten years after it begins, when cleanup goals are achieved as documented in the final RA Report,
or when a technical impracticability determination is made, whichever is earlier. LTRA transitions to O&M if cleanup
goals have not been achieved within the ten-year period.
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
PRP LR Completion: PRP LR at a NPL or Superfund Alternative site is complete (Actual Complete Date) when
cleanup goals are achieved as documented in the final RA Report or when a technical impracticability determination is
made, whichever is earlier.
Changes in Definition FY 02/03 - FY 04/05:
The date of LTRA and PRP LR start have been changed to be the O&F date.
Special Planning/Reporting Requirements:
LTRA and PRP LR are planned on a site-specific basis (Action Name = Long-term Response or PRP LR) in WasteLAN
and are used for resource allocation purposes only. Funds for LTRA are issued site-specifically in the RA AO A. Funds
for oversight of the PRP LR are contained in the pipeline operations AO A.
Superfund Alternative sites should be identified in WasteLAN using the special initiatives indicator by designating these
sites as "Superfund Alternative."
Data Entry Timeliness Requirement:
SPIM Action/
Activity
SPIM
Documentation
Documentation Approval/
Data Must Be
Activity
Type
Lead
Required
Date Requirements
Entered By
Action name =
Program
F, S,
Start
Start
It is good
Long Term
Measure
TR,
Interim Remedial
Written approval from the
management practice
Response (LR)
SA,
Action Report.
designated Regional Official.
to enter data regarding
SS,
the event as soon as
ST
Complete
Complete
practicable after the
Letter to the State
Signed by the appropriate
event occurs.
confirming LTRA
Regional official. Date is 10 years
However, data must
transfer; or
after LTRA began; or
be entered prior to the
end of the quarter in
Final RA Report; or
Written approval from the
which the event
designated Regional Official
occurs.
(Branch Chief or above). Date is
when cleanup goals are achieved;
Technical
impracticability
Written approval from the
determination
designated Regional Official
Action name =
Program
RP,
Start
Start
It is good
PRP LR (ME)
Measure
MR,
Interim Remedial
Written approval from the
management practice
PS,
Action Report
designated Regional Official
to enter data regarding
SR
the event as soon as
Complete
Complete
practicable after the
Final RA Report; or
Written approval from the
event occurs.
designated Regional Official
However, data must
(Branch Chief or above). Date is
be entered prior to the
when cleanup goals are achieved;
end of the quarter in
or
which the event
Technical
occurs.
impracticability
Written approval from the
determination
designated Regional Official
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
t. OPERA TION AND MAINTENANCE (O&M)
Definition:
O&M are the activities required to maintain the effectiveness or the integrity of the remedy, and, in the case of Fund-
financed or PRP-financed from a special account8 measures to restore ground- or surface- waters, continued operation
of such measures beyond theLTRA period until cleanup goals are achieved. Except for Fund-financed or PRP-financed
from a special account ground- or surface- water restoration actions covered under Section 300.435(f)(4) of the NCP,
O&M measures are initiated after the remedy has achieved the remedial action objectives and remediation goals in the
ROD, and is determined to be O&F (see definition of O&F).
Depending on the remedy that was implemented at the site/OU, O&M may not be required, may only be required for a
defined timeframe, or may be required to be performed indefinitely. Examples of remedies where O&M may have an
indefinite period of performance are sites where waste is contained on-site and the integrity of the cap must be maintained
or sites where institutional controls must be maintained. In some instances, O&M may be complete when the ground-
or surface- water restoration goals are met. The State or PRP is totally responsible for O&M.
Groundwater and surface water restoration measures, including monitored natural attenuation, conducted by the PRPs
is technically defined as O&M. Elowever, to better track these types of restoration remedies, regions should use PRP
LR to indicate that these activities are being performed at the site.
The appropriate use of Special Account funds is provided in the "Consolidated Guidance on the Establishment,
Management and Use of CERCLA Special Accounts" dated October 4, 2002.
Definition of Accomplishment:
O&M [ActionName = Operations and Maintenance] starts when the State or PRPs assume responsibility for all activities
necessary to operate and/or maintain the long-term effectiveness or integrity of the actions selected in the ROD. O&M
starts (Actual Start Date) on the date the remedy is declared O&F. Note that RA completion may occur later that O&M
start because the Final RA Report is to be submitted to the Region for approval within 90 days of the O&F determination.
For OUs where Fund-financed or PRP-financed through a Special Account LTRA is required, O&M (Action Name =
Operation and Maintenance) begins when LTRA is complete [see Definition of Long-Term Response Action (LTRA)].
Where appropriate, the completion of O&M is defined as the date (Actual Complete) the performance standards or
conditions specified in the Cooperative Agreement that provides funds for the RA, Superfund State Contract (SSC), or
CD signed by EPA, the PRPs and Federal judge have been met with respect to O&M. If O&M must be conducted
indefinitely, regions should not enter an actual completion date.
Changes in Definition FY 02/03 - FY 04/05:
O&M start is the date of O&F or LTRA completion.
Special Planning/Reporting Requirements:
This is a program measure. O&M is planned site-specifically (ActionName = Operation and Maintenance) in WasteLAN
and used for resource allocation purposes only. Funds for oversight of O&M are contained in the pipeline operations
AOA and/or a site specific special account. IfO&M is notrequired, regions should not enter the action in WasteLAN.
Where O&M must be conducted indefinitely, regions should not enter a planned or actual completion date for the O&M
action.
8 Actions qualify for PRP-financed from a Special Account performed by the State (SS lead), when the majority of
funding for the total estimated O&M cost (including direct and indirect costs) is to be paid from a Special Account The amount
contributed from a Special Account should meet or exceed the amount contributed by the largest non-PRP entity (i.e., State
where applicable) toward the total estimated O&M cost at the site. For example for O&M, if 60% of the funds needed to finance
the estimated cost are to be derived from a Special Account and 40% of the costs will be paid by the State, the majority of the
cost is being paid for out of a Special Account and the action qualifies for a SS lead.
September 8, 2005
B-54
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
If the only O&M activities being conducted by the PRPs at the site are groundwater or surface water restoration,
including monitored natural attenuation, regions should use the 'PRP LR' Action instead of the 'Operations and
Maintenance' Action. In this situation, regions should not enter both Actions.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be
Entered By
Action Name =
Operations and
Maintenance
(OM)
Start
Program
Measure
RP, PS,
MR, SS,
SR, SN
O&F determination in
Final RA Report
Letter to the State
confirming LTRA
transfer
Start:
Signed by the designated
Regional official.
Signed by the appropriate
Regional official. Date is
10 years after LTRA
began.
It is good management
practice to enter data
regarding the event as
soon as practicable
after the event occurs.
However, data must be
entered prior to the end
of the quarter in which
the event occurs.
u. CLEANUP GOALS ACHIEVED
Definition:
This measure is used to indicate when cleanup goals are achieved for groundwater and surface water restoration
remedies, including monitored natural attenuation. It tracks achievement of cleanup goals for these remedies because
they have not yet been achieved at Remedial Action completion. This subaction is not used for other remedies.
Definition of Accomplishment:
Cleanup goals are achieved when the designated Regional official (Branch Chief or above) approves in writing the Final
Remedial Action Report for a groundwater or surface water restoration remedy. This report should update information
previously prepared in the Interim Remedial Action Report. For more detailed information, see OSWER Directive
9320.2-09A-P, "Close Out Procedures for National Priorities List Sites."
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
Cleanup Goals Achieved is planned on a site-specific basis (Action Name = LTRA or PRP LR or Operations &
Maintenance and SubAction Name = Cleanup Goals Achieved) in WasteLAN. This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action Name =
LTRA (LR) or
PRP LR (ME) or
O&M. SubAction
= Cleanup Goals
Achieved (OQ)
Program
Measure
F
Final Remedial
Action Report
Written approval
from Regional
official (Branch
Chief or above)
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the
quarter in which the event occurs.
Change 7, FY 04/05 SPIM
B-55
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
v. NPL SITE COMPLETIONS
Definition:
An NPL site must meet all six criteria below to be eligible for site completion:
Cleanup goals specified in the RODs or removals are met;
Institutional controls are in place;
All Remedial Action Reports, On-Scene Coordinator Reports, and Pollution Reports have been completed;
~ All RODs, ROD Amendments, and Explanation of Significant Differences (ESD) have been completed;
~ The site is protective of human health and the environment; and
The only remaining activities, if any, at the site are operation and maintenance activities that are performed by
the State, Federal facility, or responsible parties.
There is only one NPL Site Completion per NPL site, and the site must be final on the NPL. For more detailed
information, see OSWER Directive 9320.2-09A-P, "Close Out Procedures for National Priorities List Sites."
Definition of Accomplishment:
A NPL Site Completion occurs when the Final Close-out Report (FCOR) has been signed by the Regional Administrator
and concurred with by F1Q. The region must enter the completion date (Actual Complete) of the Final Close-Out Report
[ActionName = Remedial Action or PRP RA orO&M and SubActionName = Close-Out Report] into WasteLAN. EPA
is responsible for documenting site completion, therefore all FCOR actions are given a Fund-financed lead code.
For examples of when to prepare FCORs, see the table in section B.A.3.q, Completion of Response Action/Activity.
Changes in Definition FY 02/03 - FY 04/05:
All FCOR actions are now given a Fund-financed lead code.
Special Planning/Reporting Requirements:
Regions may receive credit under this measure and the NPL Site Construction Completion measure as a result of the
same Final Closeout Report. This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Remedial Action
(RA) or PRP RA
(BF) or O&M (OM)
SubAction: Close-
Out Report (CQ)
Program
Measure
F
Final Close-out
Report (FCOR).
Signed by the
Regional
Administrator and
concurred with by
HQ.
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the
quarter in which the event occurs.
September 8, 2005
B-56
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
w. FIVE- YEAR REVIEWS
Definition:
A five-year review is a review of remedial action(s) selected under CERCLA § 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 still under
construction, 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 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. EPA conducts policy reviews at sites where remedial actions will attain cleanup levels
but will take longer than five years to complete, sites with pre-SARA remedies at which the cleanup levels do not allow
unlimited use and unrestricted exposure, and at NPL removal only sites where cleanup levels do not allow unlimited use
and unrestricted exposure. EPA may also conduct five-year reviews at its discretion for other sites.
Definition of Accomplishment:
Five-Year Review Starts - Credit is given for a five-year review start when:
Fund-financed (Including F-, TR-, S- or EP-leadactions) - EPA or the State begins any ofthe tasks discussed
in the latest Five-Year Review Guidance. This action may be documented by a memo to the file or EPA
approval of a workplan for the five-year review. Note: EP-lead five-year reviews should have no associated
funding.
PRP-financed (Including RP- or PS-lead actions) - EPA approves the five-year review workplan submitted
by the PRPs under the terms of an enforcement instrument. These lead codes indicate who finances and may
perform some of the work. The five-year review is still required to be approved and signed by EPA.
The actual start date (Actual Start) for the five-year review (Action Name = Five Year Review) must be entered into
WasteLAN.
Five-Year Review Completions
Planned Completion Date: Five-year review planned completion dates, and the Report Due (SubAction Name = FYR
Report Due) date are system generated based on five-year review type entered at the time of ROD completion.
Statutory: The five-year review and FYR Report Due planned completion date fields are populated for five years after
the RA On-Site Construction Start SubAction planned completion date. Both the five-year review planned completion
date and the FYR Report Due planned completion date willbe updated by the system based on the changes to the planned
or actual completion dates for the triggering RA On-Site Construction Start subaction. The five-year review planned
completion date will be editable. The FYR Report Due planned completion date will be greyed out and uneditable and
will be locked once the actual completion date for the RA On-Site Construction Start subaction is entered.
Policy: The five-year review and FYR Report Due planned completion dates are populated for five years after the PC OR
or FCOR planned completion date. Both the five-year review planned completion date and the FYR Report Due planned
completion date will be updated by the system based on changes to the planned or actual completion dates for the
triggering PCOR or FCOR. The five-year review planned completion date will be editable. The FYR Report Due
planned completion date will be greyed out and un-editable and will be locked once the actual completion date of the
PCOR or FCOR is entered.
Discretionary: The five-year review planned completion date is based on the date set by the user at the time of entry of
five-year review type.
No Review: No five-year review action will be generated.
Change 7, FY 04/05 SPIM
B-57
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Actual Completion Date: The five-year review is complete on the date the designated Regional official signs the five-
year review report stating whether the remedy is, or is not, protective of human health and the environment. The actual
completion date (Actual Complete) for the five-year review (Action Name = Five Year Review) must be entered into
WasteLAN.
Changes in Definition FY 02/03 - FY 04/05:
Changed RA On-Site Construction Sub Action name to RA On-Site Construction SubAction Start. The date changed
from planned start to planned completion for Statutory five-year reviews. Removed MR-lead and added language
clarifying other leads for five-year reviews. Expanded the Definition of Accomplishment to include specifics about
system-generated five-year review and F YR Report Due planned completion dates.
Special Planning/Reporting Requirements:
In order to receive credit for a five-year review completion the region must enter the following data into WasteLAN
through the SCAP screens:
applicable OUs
the associated remedy(ies)
associated issue for eachremedy (when issue is identified, a determination must be made as to whether the issue
'Affects Current Protectiveness" and "Affects Future Protectiveness")
recommendations or followup actions (a party responsible, oversight agency, and milestone date must be
identified for each recommendation or followup 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:
1. site protectiveness determination
2. site-wide protectiveness statement as it appears in the five-year review
All Sites must have the following information:
1. If future five-year reviews are necessary at the site indicate if this is the final five-year review at the site
Five-year review completes must be planned and reported site-specifically (Action Name = Five Year Review) in
WasteLAN. Funds are allocated in the Remedial Action AOA. This is a program target for Superfund. Five-year
review completes are a Program Measure for Federal facilities (See Exhibit B.l in Appendix B and Exhibit D.l in
Appendix D).
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be
Entered By
Action name =
Five-Year
Review
Program
Target
F, TR, S, EP
Start:
Memo; or
Workplan
Not specified
EPA approval
Within 10
working days
Action name =
Five-Year
Review
Program
Target
MR, RP, PS
Start:
Five-year review
workplan
EPA approval
Within 10
working days
Action name =
Five-Year
Review
Program
Target
F, TR, S,
EP, MR, RP,
PS
Complete:
Five-year review report
Signed by Regional official.
Within 10
working days
September 8, 2005
B-58
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
x PARTIAL NPL DELETION
Definition:
EPA will consider partial deletion for portions of sites when no further response is appropriate for that portion of the site.
Such portion may be a defined geographic unit of the site, perhaps as small as a residential unit, or may be a specific
medium at the site (e.g., groundwater), depending on the nature or extent of the release(s). The criteria for partial
deletion are the same as for final deletion. EPA must consider, in consultation with the State, whether the following
criteria have been met for that portion of the site:
Responsible or other parties have implemented all appropriate response actions required;
~ All appropriate Fund-financed response under CERCLA has been implemented, and no further cleanup by
responsible parties is appropriate; or
~ The remedial investigation has shown that the release poses no significant threat to public health, or the
environment and, therefore, taking of remedial measures is not appropriate.
Definition of Accomplishment:
The partial NPL deletion process begins when a Notice of Intent to Partially Delete (Action Name = Notice of Intent to
Partially Delete) is published in the Federal Register for the specified portion of a site on the NPL. Notice of Intent to
Partially Delete is completed (Actual Complete) the day the Federal Register is published. If the Direct Final Process
for Partial Deletions is used, the process begins when the Direct Final Action Notice is published in the Federal Register
[Action Name = Notice of Intent to Partially Delete],
The partial NPL deletion pro cess (Action Name = Partial NPL Deletion) is complete (Actual Complete) when the Notice
of Partial Deletion is published in the Federal Register for the specified portion of a site on the NPL. If the Direct Final
Proc ess for Partial Deletions is used and the comment period has ended with no adverse comments, the actual completion
(Actual Complete) is the effective date of deletion specified in the Direct Final Action Notice.
Start dates are not required for either the Notice of Intent to Partially Delete (NOIPD) or the Partial NPL Deletion
actions. The completion of the NOIPD action signifies the start of the partial deletion action.
HQ will enter the Partial Deletion and the Notice of Intent to Partially Delete from the NPL Action and the completion
dates into WasteLAN.
For more detailed information, see OSWER Directive 932 0.2-09 A-P, "Clo se Out Procedures for National Priorities List
Sites."
Changes in Definition FY 02/03 - FY 04/05:
Definition revised to clarify the use of start dates.
Special Planning/Reporting Requirements:
PartialNPL deletions are tracked separately from finalNPL deletions. Partial siteNPL deletions willbe entered by HQ
if a portion, or portions of the release remain listed on the NPL following completion of the partial deletion.
Partial deletions will be coded at specific Operable Units (OUs) when appropriate. Partial deletion actions that
address multiple OUs or areas that do not directly correspond to a specific OU will be coded at OU00 (sitewide).
A site deletion (Action Name = Deletion from NPL) will be entered by HQ if the deletion activity addresses the
remaining release listed on the NPL (either as a one-time deletion activity for the entire site as originally listed, or as the
last deletion activity associated with a site subject to previous partial deletions). This is a program measure.
Change 7, FY 04/05 SPIM
B-59
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Data Entry Timeliness Requirement
:
SPIM Action/
Activity
Activity
Type
SPIM Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be
Entered By
Action name =
Partial NPL
Deletion (GR)
Program
Measure
F
Start:
Notice of Intent to
Partially Delete or Direct
Final Action Notice.
Complete:
Notice of Partial
Deletion or Direct Final
Action Notice.
Start:
Published in the Federal
Register.
Complete:
Published in the Federal
Register.
Within 5 working
days, but no
later than 10
working days.
y. FINAL NPL DELETION
Definition:
With State concurrence, EPA may delete sites from the NPL when it determines that no further response is appropriate
under CERCLA. In making that determination, EPA considers:
Responsible or other parties have implemented all appropriate response actions required;
~ All appropriate Fund-financed response under CERCLA has been implemented, and no further cleanup by
responsible parties is appropriate; or
~ The remedial investigation has shown that the release poses no significant threat to public health, or the
environment and, therefore, taking of remedial measures is not appropriate.
Definition of Accomplishment:
The deletion process for the entire site begins when a Notice of Intent to Delete [Action Name = Notice of Intent to
Delete] is published in the Federal Register. If the Direct Final Process for Deletions is used, the process begins when
the Direct Final Action Notice is published in the Federal Register [Action Name = Notice of Intent to Delete],
The deletion process for the entire site [Action Name = Deletion from the NPL] is complete (Actual Complete) when
the Notice of Deletion is published in the Federal Register. If the Direct Final Process for Deletions is used and the
comment period has ended with no adverse comments, the actual completion (Actual Complete) is the effective date
of deletion specified in the Direct Final Action Notice.
Start dates are not required for either the Notice of Intent to Delete (NOID) or the Deletion from the NPL actions.
The completion of the NOID action signifies the start of the deletion action.
HQ will enter the Final Deletion from the NPL Action and the actual completion dates into WasteLAN. For more
detailed information, see OSWER Directive 9320.2-09A-P, "Close Out Procedures for National Priorities List Sites."
Changes in Definition FY 02/03 - FY 04/05:
Definition revised to clarify the use of start dates.
Special Planning/Reporting Requirements:
An entire site deletion action (Action Name = Deletion from NPL) will be entered by HQ if the deletion activity
addresses the remaining release listed on the NPL (either as a one-time deletion event for the entire site as originally
listed, or as the last deletion activity associated with a site subject to previous partial deletions). The Action, Final
September 8, 2005
B-60
Change 7, FY 04/05 SPIM
-------
OSWER Directive 9200.3-14-1G-Q
Deletion from the NPL, will be used whether deletion is accomplished through the Notice of Deletion or the Direct Final
Action Notice. When the Notice of Deletion is published or the date of deletion is effective, HQ will change the NPL
Status in CERCLIS to "Deleted from Final NPL." This is a program target.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be
Entered By
Action name =
Deletion from
the NPL (ND)
Program
Target
F
Start:
Notice of Intent to
Delete or Direct Final
Action Notice.
Complete:
Notice of Deletion or
Direct Final Action
Notice.
Start:
Published in the Federal
Register.
Comolete:
Published in the Federal
Register.
Within 5 working
days, but no
later than 10
working days.
Z. SITES WITH LAND READY FOR REUSE
Definition:
Sites with land ready for reuse applies to
Non-NPL sites where a non-time-critical removal action was performed;
NPL sites; and
Superfund alternative sites.
A site has land ready for reuse when:
The site or a portion of the site is currently in productive use, such as for commercial, recreational,
ecological, residential, or public service purposes; or
The Agency makes a determination that either: (1) Superfund response actions are unnecessary for the site
or portion of the site ready for reuse (as a result of an investigation of the property), and EPA is not
currently aware of any potential circumstances or any EPA or State or local restrictions that would make
the site conditions not protective for reuse; or (2) the land has been remediated and all physical
requirements in the response decision document have been fully implemented and successful (i.e.,
construction is complete and engineering and institutional controls are in place and operating properly).
Please refer to "Guidance for Preparing Superfund Ready for Reuse Determination," OSWER 9365.0-33-d
for more information on making risk based reuse decisions. For additional information on this measure,
please refer to the "Guidance for Documenting and Reporting the Superfund Revitalization Performance
Measures."
Definition of Accomplishment:
A site is considered to have land ready for reuse when a property reuse evaluation has been conducted and the Agency
has documented this decision in one or more of the following documents:
Record of Decision (ROD)
Interim/Final RA Report
Preliminary Close-Out Report
Final Close-Out Report
Final OSC Report (at the completion of the Removal action)
Notice of Deletion/Partial Deletion, including Direct Final Notice of Deletion/Partial Deletion
Five-Year Review
Change 7, FY 04/05 SPIM
B-61
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Finding of Suitability to Lease (Federal facilities)
Finding of Suitability to Transfer (Federal facilities)
Finding of Suitability to Early Transfer (Federal facilities)
Ready for Reuse Determination
Property Reuse Evaluation Checklist
A site has land ready for reuse on the date of the actual completion (as defined in other sections of the SPIM) of the
applicable document(s)(e.g.,ROD signature date), except Deletion notices. A site has land ready for reuse on the actual
start date of the Deletion notice (as defined in other sections of the SPIM). A site may also be ready for reuse on the date
the Ready-for-Reuse Determination or Property Reuse Evaluation Checklist is signed by the Regional division director
or designee. This date is entered into CERCLIS as the action completion date of these Actions.
The total number o f sites with land ready for reuse will be derived using data entered into WasteLAN on the acres ready
for reuse (see the Acres at Sites with Land Ready for Reuse measure).
Changes in Definition FY 03 - FY 04:
This is a new reporting measure in FY 04. Clarified definition for sites with land ready for reuse.
Special Planning/Reporting Requirements:
This GPRA reporting measure includes Federal facility and non-Federal facility NPL sites, Superfund alternative sites,
and Federal and non-Federal facility non-NPL sites where a non-time critical removal has been conducted. For non-
Federal facilities, Regions will enter, on a site-specific basis at the Action level, the acres of land ready for reuse with
the actual completion date of the appropriate Action (See the Acres at Sites with Land Ready for Reuse measure). Any
acres of land ready for reuse that are determined as a result of a decision to delete the site from the NPL are entered with
the actual start date of the Deletion Actions. At Federal facilities, the land ready for reuse will continue to be
documented in a FOST, FOSL, or FOSET (as defined in Appendix D). The acres ready for reuse are entered in
CERCLIS on the FOST and FOSL screens. Headquarters will use that information to derive the number of sites ready
for reuse.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
Ready-for-Reuse
Determination
(PS)
GPRA
APM
EP
Ready-for-Reuse
Determination
Signed by Regional
division director or
designee.
It is good management practice
to enter data regarding the
event as soon as practicable
after the event occurs.
However, data must be entered
prior to the end of the quarter in
which the event occurs.
Action Name =
Property Reuse
Evaluation
Checklist (UG)
GPRA
APM
EP
Property Reuse
Evaluation Checklist
Signed by Regional
division director or
designee.
It is good management practice
to enter data regarding the
event as soon as practicable
after the event occurs.
However, data must be entered
prior to the end of the quarter in
which the event occurs.
*For other actions that are applicable to Land Ready for Reuse see the appropriate Data Entry Timeliness
Requirement.
September 8, 2005
B-62
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
aa. ACRES AT SITES WITH LAND READY FOR REUSE
Definition:
Acres at sites with land ready for reuse is an estimate of the total land area, reported in acres, that either has been returned
to productive use, or is ready for reuse based on the determination that either: (1) Superfund response actions are
unnecessary for the site or portion of the site ready for reuse (as a result of an investigation of the property), and EPA
is not currently aware of any potential circumstances or any EPA or State or local restrictions that would make the site
conditions not protective for reuse; or (2) the land has been remediated and all physical requirements in the response
decision document have been fully implemented (i.e., construction is complete and engineering and institutional controls
are in place and operating properly). Please refer to "Guidance for Preparing Superfund Ready for Reuse
Determination," OSWER 9365.0-33-d for more information on making risk based reuse decisions. For additional
information on this measure, please referto the "Guidance for Documenting and Reporting the Superfund Revitalization
Performance Measures."
In addition, the acres at sites with land ready for reuse will be further designated as either ready for restricted use or
ready for unrestricted uses, unless the site is a Federal facility. For further direction on reporting Acres at Sites with
Land Ready for Reuse at Federal Facilities, see Appendix D of the SPIM: Base Closure Decisions. A site or portion of
a site is ready for unrestricted use when response activities for the site/portion of the site are unnecessary or the cleanup
goals for the land support residential use. A site or portion of a site is ready for restricted use when the cleanup goals
for the land support other types of use (e.g., industrial, commercial, recreational). For Federal facility sites, Regions
will only be required to report the total acres that are ready for reuse.
Definition of Accomplishment:
Regions will report the acres ready for reuse when a property reuse evaluation has been conducted and the Agency has
documented this decision in one or more of the following documents:
Record ofDecision (ROD)
Interim/Final RA Report
Preliminary Close-Out Report
Final Close-Out Report
Final OSC Report (at the completion of the Removal action)
Notice of Deletion/Partial Deletion, including Direct Final Notice of Deletion/Partial Deletion
Five-Year Review
Finding of Suitability to Lease (Federal facilities)
Finding of Suitability to Transfer (Federal facilities)
Finding of Suitability to Early Transfer (Federal facilities)
Ready for Reuse Determination
Property Reuse Evaluation Checklist
Acres are ready for reuse on the date of the actual completion (as defined mother sections of the SPIM) of the applicable
document(s) (e.g., ROD signature date), except Deletion notices. A site has land ready for reuse on the actual start date
of the Deletion notice (as defined in other sections of the SPIM). Acres may also be ready for reuse on the date the
Ready-for-Reuse Determination or Property Reuse Evaluation Checklist is signed by the Regional division director or
designee.
Changes in Definition FY 03 - FY 04:
This is a new reporting measure in FY 04.
Change 7, FY 04/05 SPIM
B-63
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Special Planning/Reporting Requirements:
This GPRA reporting measure includes Federal facility and non-Federal facility NPL sites, Superfund alternative sites,
and Federal and non-Federal facility sites where a non-time critical removal has been conducted. At non-Federal facility
sites, when entering the actual completion or actual start date (for Deletion Actions) for the Actions associated with the
Agency documents listed above the Region must enter the following information into WasteLAN: (1) the number of acres
that are ready for unrestricted reuse; and/or (2) the number of acres that are ready for restricted reuse. At Federal
facilities, Regions will only report the total number of acres that are ready for reuse. The total number of acres at F ederal
facilities will continue to be entered ontheFOST or FOSL screens. Headquarters will use this information to calculate
the total acres of land ready for reuse. The completion and start dates for these Actions, except the Ready-for Reuse
Determination and the Property Reuse Evaluation Checklist, are defined in other sections of the SPIM. The completion
dates for the Ready-for-Reuse Determination and the Property Reuse Evaluation Checklist are defined above.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered
By
Action Name =
Ready-for-Reuse
Determination
(PS)
GPRA
APM
EP
Ready-for-Reuse
Determination
Signed by Regional
division director or
designee.
It is good management practice
to enter data regarding the event
as soon as practicable after the
event occurs. However, data
must be entered prior to the end
of the quarter in which the event
occurs.
Action Name =
Property Reuse
Evaluation
Checklist (UG)
GPRA
APM
EP
Property Reuse
Evaluation Checklist
Signed by Regional
division director or
designee.
It is good management practice
to enter data regarding the event
as soon as practicable after the
event occurs. However, data
must be entered prior to the end
of the quarter in which the event
occurs.
*For other actions that are applicable to Land Ready for Reuse see the appropriate Data Entry Timeliness
Requirement.
PART IV. ENVIRONMENTAL INDICATORS
bb. LONG-TERM HUMAN HEALTH PROTECTION INDICA TOR
Definition:
The Long-Term Human Health Protection indicator documents the progress achieved towards providing long-term
human health protection by measuring the incremental progress achieved in controlling unacceptable human exposures
at a site.
"Unacceptable human exposures" are potential exposures associated with complete human exposure pathways that
present an "unacceptable risk"-pathways by which an individual could reasonably be exposed to a hazardous substance,
pollutant, or contaminant at levels that could result in injury, disease, or death. Unacceptable human exposures can be
controlled by:
Reducing the level of contamination associated with complete exposure pathways to the point where the
exposure is no longer "unacceptable" and
Controlling or eliminating contaminant migration to human receptors, preventing human receptors from
contracting contaminants in-place, or controlling human receptor activity patterns (e.g., by reducing the
potential frequency or duration of exposure).
September 8, 2005
B-64
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
The Progress Categories that describe the level of incremental human health protection achieved at a site are as
follows:
Insufficient data to determine human exposure control status;
Current human exposures not controlled;
Current human exposures not controlled but some human exposures control achieved;
Current human exposures controlled;
Current human exposures controlled and protective remedy in place; and
Long-term human health protection achieved.
Definition of Accomplishment:
The criteria for determining the status of long-term human health protection at a site can be found in the Environmental
Indicators Guidance Manual, the Long-Term Human Health Protection Data Quality Objectives document, and on the
Superfund Environmental Indicators Website.
Changes in Definition FY 02/03 - FY 04/05:
This is a GPRA measure for FY 05.
Special Planning/Reporting Requirements:
The Long-Term Human Health Protection worksheet (on the Program Management/Environmental Indicators screen)
must be completed in CERCLIS and/or reviewed by October 15 of each year to reflect the status at each site as of the
end of the prior fiscal year.
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT B.2
Superfund Long-Term Human Health Protection Worksheet
Definition; The Long-Term Human Health Protection El documents the progress achieved towards providing long-term
human health protection by measuring the incremental progress achieved in controlling unacceptable human exposures at a
site.
No
Yes
Yes
No
No
Yes
Yes
No
No
Yes
No
Yes
Current Human
Exposures
Controlled
Long-Term Human
Health Protection
Achieved
Current Human
Exposures Not
Controlled
Insufficient Data to
determine Human
Exposure Control
Status
Current Human
Exposure Controlled
and Protective
Remedy in Place
Current Human
Exposures Not
Controlled But Some
Exposure Control
Achieved
Step 4, Are the potential human exposures associated with complete pathways
within acceptable limits under current conditions?
List Reference Document(s) and SDMS Numberfs).
Step 1. Is enough Information available to evaluate the status of human exposure
control using this Indicator?
List Reference Documents) and SDMS Number(s):
Step 2. Have all human exposure-related cleanup goals been met for the entire
site?
List Reference Document(s) and SDMS Numbers):
Step 6, Is the site Construction Complete, is the remedy operating as Intended,
and are engineering and institutional controls, if required, in place and effective?
List Reference Documents) and SDMS Numbers)"
Step 5. Have any actions been taken since EPA first exercised removal or
remedial authority at the site that have significantly reduced the level of previously
unacceptable human exposure under current conditions?
List Reference Document(s) and SDMS Number(s):
Step 3. Are there complete human exposure pathways between contaminated
groundwater, surface water, soil, sediment or air media and human receptors such
that exposures can be reasonably expected under current conditions?
List Reference Documents) and SDMS Number(s):
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
cc. MIGRATION OF CONTAMINATED GROUND WATER UNDER CONTROL
Definition:
The Migration of Contaminated Groundwater Under Control indicator assesses whether groundwater contamination is
below protective, risk-based levels or, if not, whether the migration of contaminated groundwater is stabilized and there
is not unacceptable discharge to surface water and monitoring will be conducted to confirm that affected groundwater
remains in the original area of contamination. This indicator is limited to sites with known past and/or present
groundwater contamination.
Definition of Accomplishment:
The criteria for determining if groundwater migration is controlled are found in the Migration of Contaminated
Groundwater Under Control Survey (refer to Exhibit B.3), the Environmental Indicators Guidance Manual, the Human
Health Protection/GroundwaterUnder Control Data Quality Objectives document, and on the Superfund Environmental
Indicators Website.
Changes in Definition FY 02/03 - FY 04/05:
This is a GPRA measure for FY 05.
Special Planning/Reporting Requirements:
The Migration of Contaminated Groundwater survey (on the Program Management/Environmental Indicators screen)
must be completed and/or reviewed by October 15 of each year in CERCLIS to reflect the status at each site as of the
end of the prior fiscal year.
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT B.3
Superfund Migration of Contaminated
Ground Water Under Control Worksheet
Definition: Is the migration of contaminated ground water from the site being controlled through engineered or natural processes?
Region:
State:
EPA ID:
Site Name:
Insufficient
_ Data
Insufficient
Data
Insufficient
Data
Insufficient
Data
Insufficient
Data
Does or did the site have contaminated ground water?
|Ye:
STOP, you do not need to
complete the GM El
Step 1. Based on the most current data on the site, has all available relevant/significant information on
known and reasonably suspected releases to the ground water been considered in this El determination?
Explain Rationale:
List Site Reference Document:
yYe:
Step 2. Is ground water known or reasonably suspected to be "contaminated" above appropriately
protective risk-based "'levels" (applicable promulgated standards, as well as other appropriate standards,
guidelines, or criteria) as a result of a release from the site?
Explain Rationale:
List Site Reference Document:
~^rYe
No
YES,
Site Does
Meet
Definition
Step 3. Is the migration of contaminated ground water stabilized (such that contaminated ground water
is expected to remain within "existing area of contaminated ground water") as defined by the monitoring
locations designated at the time of this determination?
Explain Rationale:
List Site Reference Document:
|Ye;
No
Step 4. Does "contaminated" ground water discharge into surface water bodies?
Explain Rationale:
List Site Reference Document:
No
Step 5. Can the discharge of "contaminated" ground water into surface water be shown to be "currently
acceptable" as defined (i.e, not cause unacceptable impacts to surface water, sediments, or ecosystems
that should not be allowed to continue until a final remedy decision can be made and implemented)?
Explain Rationale:
List Site Reference Document:
|Ye:
No
Step 6. Will ground water monitoring/measurement data (and surface water/sediment/ecological data
as necessary) be collected in the future to verify that contaminated ground water has remained within
the horizontal (or vertical, as necessary) dimensions of the "existing area" of contaminated ground water?
Explain Rationale:
List Site Reference Document:
No
INSUFFICIENT DATA,
More Information Needed
to Make Determination
Yes
YES, Site Does Meet Definition
NO, Site Does Not
Meet Definition
September 8, 2005
B-68
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
dd. POPULA TIONS PROTECTED
Definition:
This measure tracks the environmental progress achieved at NPL, Superfund Alternative and non-NPL sites through the
protection of human receptors from immediate threats of exposure to contaminated media. The following information
will be reported under this measure:
The number of human receptors protected during removals and remedial actions that result in:
Relocation of affected populations; or
Provision of an alternate water supply.
Definition of Accomplishment:
Population Protected data is required upon a removal or remedial action start where a population has been either
relocated and/or provided an alternative drinking water supply in association with the following actions: Removal;
PRP Removal; FF Removal; Remedial Action; PRP RA; FF RA; PRP Emergency Removal; or Initial Remedial
Measure.
The following information must be entered into WasteLAN for each action resulting in a population being relocated
or provided an alternative source of drinking water:
Action - action associated with the population relocation or the provision of alternative drinking water;
Affected Date - date the population was relocated or provided alternative drinking water;
Protection Level - level (permanently, temporarily, or returned/reinstated) at which the population was
relocated and or provided alternative drinking water; and
Number Affected- number of people relocated or provided alternative drinking water.
The Populations Protected screen can be accessed through the one of the following: Program
Management/Environmental Indicators or the EI icon can be used on the Removal or Remedial schedule when one of
the following actions are selected: Removal; PRP Removal; FF Removal; Remedial Action; PRP RA; FF RA; PRP
Emergency Removal; or Initial Remedial Measure.
Changes in Definition FY 02/03 - FY 04/05:
Definition revised to reflect restructure of Population Protected data. Population Protected data is now captured
incrementally at the action level rather than the action-media level. Population Protected data entry is permitted
without the selection of the associated population relocated or alternative drinking water supplied response action via
the Add/Edit Response Action screen; however, for completeness it is recommended that both screens be updated
during data entry.
Special Planning/Reporting Requirements:
See Definition of Accomplishment. Population Protected data is required to be updated once per year. Data
documenting relocation or provision of alternative drinking water can typically be found in RODs, Action
Memoranda, Pollution Reports, Remedial Actions Reports and Close Out Reports. This is a program measure.
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OSWER Directive 9200.3-14-1G-Q
ee. CLEANUP VOLUME
Definition:
This measure tracks the amount of contaminated media that has been treated, stabilized, contained, or removed through
the use of risk management technologies or engineering techniques.
Definition of Accomplishment:
Cleanup Volume data is required in association with a removal action (Removal, PRP Removal, FF Removal) start or
complete as defined in the Removal Start and Removal Completion measures or a remedial action (Remedial Action,
PRP RA, FF RA, PRP Emergency Removal, Initial Remedial Measure) start or complete as defined in the Start of a
Response Action/Activity or Completion of a Response Action/Activity measures
The following information must be entered into WasteLAN for each medium addressed by the completed response
action:
Cleanup Date - date contaminated media was addressed
Media Name - media name as documented in the Add/Edit Media screen and media type
Original Amount - amount of contaminated media addressed
Original Unit - volumetric unit of contaminated media
The Cleanup Volumes screen can be accessed through the following: Program Management/Environmental
Indicators or the EI icon can be used on the Removal or Remedial schedule when one of the following actions are
selected: Removal, PRP Removal, FF Removal, Remedial Action, PRP RA, FF RA, PRP Emergency Removal,
or Initial Remedial Measure.
Changes in Definition FY 02/03 - FY 04/05:
Measure has been renamed from Cleanup Technologies Applied. Definition revised to reflect restructure of Cleanup
Volume data. This measure is no longer directly tied to technology, and is captured incrementally rather than
cumulatively.
Special Planning and Reporting Requirements:
Cleanup Volume data is required to be updated at a minimum of once per year. Data documenting volumes of
contaminated media addressed can typically be found in RODs, Action Memoranda, Pollution Reports, Remedial Actions
Reports and Close Out Reports. This is a program measure.
September 8, 2005
B-70
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PART V. SUPPORT ACTIVITIES
OSWER Directive 9200.3-14-1G-Q
ff. SUPPORT AGENCY ASSISTANCE
Definition:
The activities performed by another entity to support an EPA response is support agency assistance. The support agency
furnishes necessary data to EPA, reviews response data and documents, and provides other assistance to EPA.
EPA may provide States, political subdivisions, and Indian Tribes with funding to carry out a variety of management
responsibilities via a support agency Cooperative Agreement to ensure the meaningful and substantial involvement in
response activities.
Unless otherwise specified in the Cooperative Agreement, all support agency costs, with the exception of RA support
agency costs, may be planned under a single Superfund account number designated specifically for support agency
activities. RA support agency activities must be planned site-specifically and require cost share provisions.
Definition of Accomplishment:
The start of support agency assistance (Action Name = Management Assistance) is the signature of the Cooperative
Agreement by the Regional Administrator or his designee. The completion of support agency assistance is the expiration
or termination of the assistance agreement.
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
Funds for support agency assistance are contained in the pipeline operations, enforcement, or Federal facility AOA.
Planned and actual start and completion dates are not required in WasteLAN. Funds may be planned or obligated site
or non-site and OU specifically; however, they must be outlayed site-specifically. This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Management
Assistance (MA)
Program
Measure
F
Start:
Cooperative
Agreement.
Complete:
Expiration or
termination of the
assistance
agreement.
Start:
Signed by Regional
Administrator or his
designee
Comolete:
Expiration or
termination of the
assistance agreement.
It is good management practice
to enter data regarding the event
as soon as practicable after the
event occurs. However, data
must be entered prior to the end
of the quarter in which the event
occurs.
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
gg. TECHNICAL ASSISTANCE
Definition:
Technical assistance is support provided by a third party to EPA regions to conduct response activities. Third parties
that may provide assistance include U.S. Army Corps of Engineers (USACE), U. S. EPA laboratories, U.S. Fish and
Wildlife Service, Superfund Technical Assistance and Response Team (START), and Response Action Contracts (RAC)
contractors.
Definition of Accomplishment:
The start of technical assistance (Action Name = Technical Assistance) is the obligation of funds for technical assistance.
The completion is defined as the completion of the response activities for the stage at which technical assistance was
requested.
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
Technical assistance is paid for by the response program and is contained in the pipeline operations A OA. Planned and
actual start and completion dates are not required in WasteLAN. Funds may be planned or obligated site- or non-site
and OU specifically; however, they must be outlayed site-specifically. This is a program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Technical
Assistance (TA)
Program
Measure
EP, F,
S, TR,
RP,
PS, MR
Start:
Obligation of
funds.
Not specified
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
hh. PRE-DESIGN ASSISTANCE
Definition:
Pre-design assistance activities are undertaken by the USACE in preparation for initiating RD activities. This includes:
Synopsizing RD requirements in the Commerce Business Daily (CBD);
Developing architect/engineer (A/E) firm pre-selection list;
Contacting A/E firms on the pre-selection list to ascertain interest in project;
Developing A/E selection list; and
Selecting A/E firm.
September 8, 2005
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Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
The initiation of pre-design assistance (Action Name = Design Assistance) is the signature of the IAG by USACE
(obligation of funds). The completion of design assistance is the start of RD.
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
Funds for pre-design assistance should be obligated prior to the signature of the ROD. Planned and actual start and
completion dates are not required in WasteLAN. Funds may be planned site-or non-site and OU specifically; however,
they must be obligated site-specifically. Funds for design assistance are in the pipeline operations AOA. This is a
program measure.
Data Entry Timeliness Requirement:
SPIM Action/
Activity
Activity
Type
SPIM
Lead
Documentation
Required
Documentation
Approval/ Date
Requirements
Data Must Be Entered By
Action name =
Design
Assistance (DA)
Program
Measure
EP, F,
S, TR,
RP,
PS, MR
Start:
IAG
Complete:
Not specified
Start:
Signed by USACE
Complete:
Start of RD
It is good management practice to
enter data regarding the event as
soon as practicable after the event
occurs. However, data must be
entered prior to the end of the quarter
in which the event occurs.
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
B. C. SUBJECT MA TTER EXPERTS
The following table identifies the subject matter experts for Appendix B Response Actions.
EXHIBIT B.4 SUBJECT MATTER EXPERTS
Subject Matter Expert
Subject Area
Phone #
Richard Jeng
Construction Completion
703-603-8749
RichNorris
Environmental Indicators
703-603-9053
RobinM Anderson
Final Remedy Assessment
703-603-8747
Carolyn Kenmore
Final Remedy Assessment
703-308-8644
Silvina Fonseca
Five-Year Reviews
703-603-8799
James Konz
Five-Year Reviews
703-603-8841
Jeff Heimerman
Innovative Technology
703-603-7191
JoAnn Griffith
Contaminant of Concern
703-603-8774
Michael Bellot
Institutional Controls
703-603-8905
Tracy Hopkins
Po st-C onstruction
703-603-8788
Jennifer Griesert
Po st-C onstruction
703-603-8888
John J Smith
Remedial Implementation
703-603-8802
Robert White
Response Appendix Coordinator
703-603-8873
DavidE Cooper
Risk Assessment
703-603-8763
Matthew C harsky
RODs/Remedy Selection
703-603-8777
Janet Weiner
Superfund Redevelopment/GPRA
703-603-8717
Melissa Friedland
Superfund Redevelopment
703-603-9075
September 8, 2005
B-74
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Superfiind Program Implementation Manual FY04/05
Appendix C: Enforcement
Change 1, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
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OSWER Directive 9200.3-14-1G-Q
Appendix C
Enforcement
Table of Contents
C.A FY04/05 TARGETS AND MEASURES FOR ENFORCEMENT c-i
C.A.I Overview C-I
C.A.2 Promoting the Superfund Enforcement Program C-2
C.A.3 Targets and Measures for Baseline Enforcement C-7
Criteria for Credit of Enforcement Activities at Superfund Alternative Sites C-7
a. Potentially Responsible Party (PRP) Search Starts C-8
b. PRP Search Completions C-8
c. Section 104(e) Referrals and Orders Issued C-9
d. Issuance of General Notice Letters (GNLs) C-10
e. Issuance of Special Notice Letters (SNLs) C-10
f. Expanded Site Inspection/Remedial Investigation/Feasibility Study (ESI/RI/FS)
Negotiation Starts C-10
g. Remedial Design/Remedial Action (RD/RA) Negotiation Starts
(NPL & Superfund Alternative) C-ll
h. Completion or Termination of Negotiations for RD/RA (NPL & Superfund Alternative) . . C-12
i. Completion or Termination of Negotiations for Cleanup
(RD/RA, Removals, and Other) (NPL & Superfund Alternative) C-13
j. Percentage of Remedial Action Starts Initiated by PRPs at Non-Federal Facility NPL and
Superfund Alternative Sites C-15
k. Total Response Commitments (Including Dollar Value) C-16
1. Enforcement Settlements/Instruments for RD/RA/Long-Term Response (LR) C-17
m. De Minimis Settlements and Number of Parties C-19
n. Cashout Settlements C-20
o. Section 106, 106 and 107, 107 Case Resolution C-21
p. Issuance of Demand Letter C-22
q. Total Cost Recovery Settlements (Including Dollar Value) C-22
r. Past Costs Addressed > $200,000 Via Settlements, Write-Offs, or Referrals C-23
s. Recoverable Past Costs That Have Been Addressed by Program-to-Date Via
Settlements, Write-offs, or Referrals C-24
t. Number and Amount of CERCLA Penalties Assessed C-26
u. Number and Amount of CERCLA Supplemental Environmental Projects (SEPs) C-27
v. Use of Alternative Dispute Resolution (ADR) C-27
w. Number of Settlements Where EPA Settled Based On Ability-to-Pay Determinations ... C-29
x. Prospective Purchaser Agreements (PPAs) - Assessed and Finalized C-29
y. Issuance Of Comfort/Status Letters C-30
z. Orphan Share - EPA Offer and Compensation C-31
aa. Non-exempt De Micromis Parties Settlements and Number of Parties C-33
bb. PRP Oversight Administration C-34
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Appendix C
Enforcement
Table of Contents (continued..)
cc. Settlements Designating Deposits to Special Accounts C-35
dd. Deposits into Special Accounts C-36
ee. Settlements Designating Disbursements from Special Accounts to PRPs C-37
ff. Disbursements From Special Accounts for Response Actions C-38
gg. Closure of Special Accounts C-39
hh. Pre-Remedial Enforcement Action at Superfund Sites C-40
ii. Windfall Lien Filed C-42
jj. Windfall Lien Resolution - Assessed and Finalized C-42
C.B SUBJECT MATTER EXPERTS C-13
September 8, 2005
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Appendix C
Enforcement
List of Exhibits
EXHIBIT C.l ENFORCEMENT ACTIVITIES C-4
EXHIBIT C.2 SUBJECT MATTER EXPERTS C-43
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OSWER Directive 9200.3-14-1G-Q
C.A FY04/05 TARGETS AND MEASURES FOR ENFORCEMENT
C.A.1 OVERVIEW
The Superfund Comprehensive Accomplishments Plan (SCAP) is used by the Assistant Administrator for the Office
of Solid Waste and Emergency Response (AA OSWER), the Assistant Administrator for the Office of Enforcement and
Compliance Assurance (AA OECA), and senior Superfund managers to monitor the progress each region is making
towards achieving the Government Performance and Results Act (GPRA) annual performance goals. In addition, SCAP
will continue to be used as an internal management tool to project and track activities that contribute to these GPRA goals
and support resource allocation. The program will set national goals based on historical performance and performance
expectations within a limited budget for the performance goals in GPRA and track accomplishments in the activities
contributing to those goals. Regions should continue to plan and report accomplishments in WasteLAN as they have
traditionally.
To more clearly reflect the relationship between GPRA and the SCAP process, program targets and GPRA
performance goals are defined as follows:
GPRA Annual Performance Goals are a subset of the overall planning and budgeting information that has
traditionally been tracked by the Superfund program offices. They are numerical goals that are established nationally
prior to the start of the operating year. For cost recovery, the emphasis will be on addressing all sites with total
outstanding costs greater than or equal to $200,000 prior to the expiration of the Statute of Limitations (SOL).
Measures are activities deemed essential to tracking overall program progress. There are two types of measures:
GPRA annual performance reporting measures and program measures. GPRA measures are used to track regional
accomplishments that occur throughout the year and are used to evaluate program progress relative to projected
targets that are set for each measure. Program measures are used to track and/or project the number of actions that
each region expects to perform during the year using anticipated resources; for example, the number of PRP search
starts. A subset of these program measures will be selected for work planning purposes. They are identified with
a T in Exhibit C. 1.
Appendix C includes the enforcement Measures of Success that were devised by Headquarters in consultation with
the regions to address enforcement reforms. These measures have been incorporated into the enforcement program as
routine ways of doing business. With these measures, the program can produce a more complete picture of enforcement-
related successes and accomplishments at Superfund sites.
In addition to the measures in this manual, the regions should continue to provide information in WasteLAN regarding
Potentially Responsible Parties (PRPs) as requested in OSRE memorandum dated July 26, 1999, and Prospective
Purchaser Agreements (PPAs) as requested in OSRE's memorandum dated December 6, 1999 entitled "Tracking the
Prospective Purchaser Agreement Process in CERCLIS/WasteLAN." Compliance Monitoring should continue as
requested in OSWER directive 9872.50. Regions should also use the WasteLAN Environmental Justice Indicator to
identify potential Environmental Justice Sites.
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
C.A.2 PROMOTING THE SUPERFUND ENFORCEMENT PROGRAM
The Superfund enforcement program GPRA goals and measures will continue to ensure a fairer, more effective, and
more efficient Superfund program. The program goals continue to focus on maximizing PRP participation,
addressing past costs, reducing transaction costs, entering into fair settlements, and eliminating barriers to
redevelopment. The major areas of emphasis for the Superfund enforcement program include the following:
Maximizing PRP Involvement/Enforcement First: Maximizing PRP participation is critical to
achieve the greatest possible number of cleanups, and to conserve Trust Fund resources. Key areas of
emphasis are early initiation of PRP searches, completing negotiations in a timely manner, and
maximizing PRP-lead cleanup activities. EPA will continue to seek to maximize PRP participation at
Superfund sites including NPL and Superfund Alternative sites. As a result of the enforcement first
strategy, PRPs have undertaken the majority of new cleanup actions over the past years, leveraging
Fund resources to maximize total cleanups.
Addressing Past Costs > $200,000: For cost recovery, the emphasis will be on addressing all sites
with total outstanding costs greater than or equal to $200,000 prior to the expiration of the Statute of
Limitations (SOL).
Completing Clean-up Negotiations in a Timely Manner: Remedial Design/Remedial Action
(RD/RA) negotiations should be completed withinl20 days of the issuance of Special Notice Letters
(SNLs). Normally, SNLs are issued at the same time as the signature of the Record of Decision (ROD).
Reducing Transaction Costs through De minimis Settlements: EPA will continue to pursue § 122(g)
de minimis settlements, and resolve the potential liability of qualified small volume waste contributors,
at the earliest date possible.
Entering Into Fair Settlements/Orphan Share Offers: EPA will compensate a portion of the
Superfund cleanup costs attributable to parties that are financially insolvent as a way to ensure that
remaining viable PRPs are not asked to pay for substantially more than their share of the site costs.
Eliminating Barriers to Redevelopment/Asses sing Request for Prospective Purchaser Agreements
(PPAs): Under the new Brownfields Amendment, parties who qualify as bonafide prospective
purchasers, should no longer need PPAs with the Federal government to purchase contaminated
property. EPA may consider entering into PPAs in instances where the public interest is served (i.e.
where there is likely to be a significant windfall lien, and the prospective purchaser needs to resolve the
lien, or where the purchase could potentially provide substantial environmental or community benefit).
Providing PRP Oversight : EPA will continue to focus on efforts to engage in dialogue with PRPs
that have settlements with EPA to promote oversight that ensures the development and implementation
of protective cleanups; gives careful consideration to the associated costs being charged to PRPs; and
maximizes EPA recovery of oversight EPA will continue to offer to discuss EPA's oversight
expectations for upcoming activities with settling PRPs who conduct non-time critical removals,
remedial investigations/feasibility studies, remedial designs, or remedial actions during the fiscal year;
and issue oversight bills that include appropriate cost documentation.
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OSWER Directive 9200.3-14-1G-Q
Providing for Responsible Fiscal Management: EPA will place a high priority on sound fiscal
management by managing and collecting Superfund accounts receivable. To accomplish this, program
focus will be on:
Maximizing site-specific charging (intramural and extramural);
Maintaining prompt, current and accurate oversight billing;
Maximizing collections of monies due the Trust Fund; and
Resolving outstanding collection disputes.
Ensuring Compliance with Orders/Settlements: EPA will continue to monitor compliance of PRP
performance and payment obligations under administrative orders, consent decrees, and judgments;
ensure compliance; and address substantial noncompliance in a timely manner.
Using Special Accounts for Site Cleanup: EPA will continue to emphasize the use of special accounts
for site cleanup. This includes finalizing settlements that provide for deposits to and disbursements
from special accounts, approving actual deposits and disbursements, reclassifying special account
funds, where appropriate, and closing out such accounts in a timely manner, thus freeing up such funds
for future use at other sites, through the general appropriation process.
Using Alternative Dispute Resolution (ADR): EPA is continuing to use ADR as a way to reduce the
costs of achieving settlement with PRPs. Also, ADR can be used in other contexts (e.g., disputes with
states regarding cleaning up sites).
Issuing Unilateral Administrative Orders (UAOs) Equitably: EPA will issue UAOs to the
maximum manageable number of PRPs wherever there is sufficient basis to include them. Issuance of
these UAOs will compel those PRPs to participate in, and share the cost of, the specific response
actions. The participation of these PRPs, even if only through a financial contribution, will reduce the
portion of the cleanup cost that is borne by PRPs who have settled with EPA.
FY 04/05 SPIM
C-3
April 7, 2003
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT C.l
ENFORCEMENT ACTIVITIES
FY04/05 Enforcement Performance Measures
The following table represents the FY04/05 Enforcement Performance Measures. This table is only relevant for Appendix
C: Enforcement.
ACTIVITY
GPRA
EPA SR.
MANAGERS
INQUIRIES:
CONGRESS/
GAO/OIG/OMB
RESOURCE
WORK
PLANNING*
Potentially Responsible Party
(PRP) Search Starts
P
PRP Search Completions
P
Section 104(e) Referrals and Order
Issued
P
Issuance of General Notice Letters
(GNLs)
P
Issuance of Special Notice Letters
(SNLs)
P
Expanded Site
Inspection/Remedial
Investigation/Feasibility Study
(ESI/RI/FS) Negotiation Starts
P
Remedial Design/Remedial Action
(RD/RA) Negotiation Starts (NPL
& Superfund Alternative)
/~
P
Completion or Termination of
Negotiations for RD/RA (NPL &
Superfund Alternative)
/~
P
Completion or Termination of
Negotiations for Cleanup (RD/RA,
Removals, and Other) (NPL &
Superfund Alternative)
/
P
Percentage of Remedial Action
Starts Initiated by PRPs at non-
Federal Facility NPL & Superfund
Alternative Sites
/~
/~
T
* T = Program Target
P = Program Measure
September 22, 2003
C-4
Change 1,FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
ACTIVITY
GPRA
EPA SR.
MANAGERS
INQUIRIES:
CONGRESS/
GAO/OIG/OMB
RESOURCE
WORK
PLANNING*
Total Response Commitments
(Including Dollar Value)
Report
dollar
value
/~
P
Enforcement Settlements/
Instruments for RD/R A/Long-
Term Response (LR)
(Including Dollar Value)
/~
P
De Minimis Settlements and
Number of Parties
/~
/
P
Cashout Settlements
/~
P
Section 106, 106 and 107, 107
Case Resolution
/~
P
Issuance of Demand Letter
P
Total Cost Recovery Settlements
(Including Dollar Value)
Report the
value of
costs
recovered
/~
P
Past Costs Addressed > $200,000
Via Settlements, Write-Offs, or
Referrals
/~
/~
/~
Recoverable Past Costs That Have
Been Addressed by Program to
Date Via Settlements, Write-Offs,
or Referrals
/~
P
Number and Amount of CERCLA
Penalties Assessed
/~
P
Number and Amount of CERCLA
Supplemental Environmental
Projects (SEPs)
/~
P
Use of Alternative Dispute
Resolution (ADR)
/~
P
Number of Settlements Where
EPA Settled Based on Ability-to-
Pay Determinations
/~
P
* T = Program Target
P = Program Measure
Change 1, FY 04/05 SPIM
C-5
September 22, 2003
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OSWER Directive 9200.3-14-1G-Q
ACTIVITY
GPRA
EPA SR.
MANAGERS
INQUIRIES:
CONGRESS/
GAO/OIG/OMB
RESOURCE
WORK
PLANNING*
Prospective Purchaser Agreements
(PPAs) Assessed and Finalized
/~
P
Issuance of Comfort/Status Letters
/~
P
Orphan Share - EPA Offer and
Compensation
/~
P
Non Exempt De Micromis Parties
Settlements and Number of Parties
/~
P
PRP Oversight Administration
/~
/~
T
The number of enforcement
actions taken at NPL sites to have
PRPs conduct or participate in
response activities compared to the
total number of sites on the NPL.
The percentage and estimated
value of PRP commitments to
response activities at non-Federal
facility sites on the NPL
/~
The total value of cost recovery
settlements and judicial actions
achieved, and past costs
considered recoverable
/~
The amount of money EPA has
collected from PRPs compared to
the total amount achieved in co st
recovery settlements and judicial
actions
/~
The estimated amount of money
PRPs have committed legally to
site cleanup compared to the total
amount of funds expended by the
Superfund enforcement program
/~
Settlements Designating Deposits
to Special Accounts
/~
/~
P
* T = Program Target
P = Program Measure
September 22, 2003
C-6
Change 1,FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
ACTIVITY
GPRA
EPA SR.
MANAGERS
INQUIRIES:
CONGRESS/
GAO/OIG/OMB
RESOURCE
WORK
PLANNING*
Deposits into Special Accounts
/~
/~
P
Settlements Designating
Disbursements from Special
Accounts to PRPs
/~
/~
P
Disbursements from Special
Accounts for Response Actions
/~
/~
P
Closure of Special Accounts
/~
/~
P
Pre-Remedial Enforcement Action
at Superfund Sites
/~
/~
/~
Windfall Lien Filed
/~
/~
P
Windfall Lien Resolution -
Assessed and Finalized
/~
/~
P
T = Program Target
P = Program Measure
NOTE: Acc omplishments are pulled from W asteLAN on a quarterly basis. Measures are planned and reported quarterly.
C.A. 3 TARGETS AND MEASURES FOR BASELINE ENFORCEMENT
Note: WasteLAN coding requirements contained in the definitions below are only for key data elements. For a full
list of requirements and suggested data elements, see the SCAP Coding Guide for the current FY.
Criteria for Credit of Enforcement Activities at Superfund Alternative Sites
For the purposes of this section, references to enforcement activities (i.e. RD/RA negotiation starts and completions)
at Superfund Alternative sites apply only to those enforcement activities at sites that the region has determined would
achieve a Hazard Ranking System (HRS) score greater than or equal to 28.5 Such response actions must be carried
out in a manner not inconsistent with the National Contingency Plan (NCP). Proposed NPL sites are included in this
category. Regions should maintain adequate site documentation to support the "Superfund Alternative" designation
based on the criteria referenced above. Credit for PRP-lead remedial actions at Superfund Alternative sites will only
be given for activities conducted pursuant to enforceable order or agreement. Sites that meet these criteria should be
identified in WasteLAN using the special initiatives indicator designating these sites as "Superfund Alternative."
Change 7, FY 04/05 SPIM
C-7
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
a. POTENTIALLY RESPONSIBLE PARTY (PRP) SEARCH STARTS
Definition:
A PRP search identities PRPs at the site and establishes PRP liability, capability, and financial viability. At all sites, the
PRP search activities should be initiated as soon as po ssible after the region decides that a response (removal or remedial)
action is likely to be required at the site. For sites where remedial actions will be conducted, the PRP search should be
initiated in time to send a SNL (at least 90 days prior to the obligation of funds for an ESI/RI, RI/FS or RA). For sites
where removal actions will be conducted, the PRP search should be initiated as soon as the need for the removal has been
identified in order to give a verbal notice of potential liability or to issue a general notice letter.
Definition of Accomplishment:
If the Nati onal Priorities List (NPL) PRP search (Action Name = NPL RP Search) or non-NPL PRP search (Action Name
= Non-NPL PRP Search) is being conducted by a contractor, the actual start date (Actual Start) is considered to be the
date the PRP search work assignment or procurement request is signed by the Contracting Officer (CO) or the designated
Contracting Officer Representative (COR). The start for both the NPL and non-NPL PRP search is documented by the
signed procurement request or work assignment. If the NPL or non-NPL PRP search is conducted by EPA in-house, the
actual start date (Actual Start) is the date EPA staff develops the PRP search plan, the date the On-Scene Coordinator
(OSC) receives confirmation of a spill identification number from the Regional Finance Office, or the date EPA initiates
and documents search activities by some other means.
Changes in Definition FY02/03- FY04/05:
None
Special Planning/Reporting Requirements:
PRP searches (Action Name = Non-NPL PRP Search or NPL RP Search) are planned and funds requested on a site-
specific basis. PRP Search Starts is a program measure.
b. PRP SEARCH COMPLETIONS
Definition:
A PRP search completion constitutes the completion of the activities taken by the region to identify PRPs at a site. In
conducting the PRP search, the region must consider which of the criteria outlined below are cost effective and reasonable
to meet relative to the anticipated overall cleanup costs at the site. Upon completion, regions should document in the site
file that they have met all reasonable achievable criteria. Criterion 1 is mandatory for all PRP search completions. The
PRP search should ideally be completed prior to completion of cleanup negotiations; however, it is recognized that this
may not be achievable in all situations.
The recommended criteria for a thorough PRP search are:
1. Initiate a dialogue with early identified PRPs for the purpose of providing an opportunity for PRP input into the
PRP search;
2. Collect the financial and contribution data needed to perform equitable share calculations;
3. Follow-up on all leads as a way to identify parties to the site;
4. Make de minimis and non-exempt de micromis determinations for all parties at the site;
5. Categorize all parties (e.g., Generator/Transporter, Owner/Operator, Small Business ($2 million or less gross annual
revenue and 25 or less employees), Municipal Solid Waste Contributor, etc.); and
6. Perform a financial viability determination on all PRPs asserting ability-to-pay problems.
April 7, 2003
C-8
FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
The PRP search (Action Name = NPL RP Search or Non-NPL PRP Search) is complete when all applicable activities
described in the Agency's PRP Search Manual have been completed and documentation has been placed in the site file
that the region has met all reasonable achievable criteria for the PRP search, a PRP search outcome report with a list of
PRPs has been prepared and both the actual completion date (Actual Complete) and the outcome (Qualifier) of the search
have been entered into WasteLAN. If no PRPs are found, the region must document in the site file that it has met all
reasonable achievable criteria for the PRP search and enter the actual completion date (Actual Complete) and the Qualifier
of 'No PRPs Identified (NP)' into WasteLAN. This definition applies to both Phase I (single owner, operator site) and
Phase II (multi-generator site) PRP searches.
Changes in Definition FY02/03- FY04/05:
Revised de m icrom is to non-exempt de micromis in the Definition.
Special Planning/Reporting Requirements:
PRP search completions (Action Name = Non-NPL PRP Search or NPL RP Search) are planned on a site-specific basis.
The search outcome (Qualifier) is to be entered into WasteLAN. The number of PRPs found may be system generated
by entering and associating PRPs with sites and selecting an Identification Source of "PRP Search." PRP search
completions is a program measure.
c. SECTION 104(e) REFERRALS AND ORDERS ISSUED
Definition:
Section 104(e) referrals/orders are enforcement actions to compel PRPs to respond to EPA requests for information or
to obtain site access.
Definition of Accomplishment:
The date of the memo from the Regional Administrator transmitting the Section 104( e) referral to HQ or to the Department
of Justice (DO.T) is recorded in WasteLAN as the actual start date (Actual Start) of the Section 104(e) referral (Action
Name = Section 104(e) Ref. Litigation). The date a Section 104(e) Unilateral Administrative Order (UAO) or
Administrative Order on Consent (AOC) is signed by the Regional Administrator or delegatee is recorded in WasteLAN
as the actual completion date (Actual Complete) of the UAO (Action Name = Unilateral Admin Order) or AOC (Action
Name = Admin Order on Consent).
Changes in Definition FY02/03- FY04/05:
None.
Special Planning/Reporting Requirements:
The actual start date (Actual Start) of the referral (Action Name = Section 104(e) Ref. Litigation) or the actual completion
date (Actual Complete) of the order (Action Name = Unilateral Admin Order or Admin Order on Consent) is entered into
WasteLAN site-specifically. The Law/Section reported in WasteLAN should be "CERCLA 104(e)" [(Law/Section =
CERCLA 104(e)], This is a program measure.
Change 7, FY 04/05 SPIM
C-9
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
d. ISSUANCE OF GENERAL NOTICE LETTERS (GNLs)
Definition:
Letter sent by EPA under Section 122 of CERCLA informing recipients of their potential liability for cleanup actions at
the site. It is usually sent out during the PRP search or during preparation for negotiations.
Definition of Accomplishment:
This action is accomplished on the date the GNL is signed by the appropriate EPA official and entered into WasteLAN
as the SubAction, Notice Letters Issued, with an actual completion date (Actual Complete).
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
General Notice Letters are recorded as a SubAction to PRP search or negotiation actions. Issuance of GNLs is a program
measure.
e. ISSUANCE OF SPECIAL NOTICE LETTERS (SNLs)
Definition:
An SNL is a letter under Section 122(e)ofCERCLAfrom EPA to a PRP informing it of its potential liability and soliciting
an offer to conduct the planned response action(s) at the site. The SNL triggers a moratorium on certain EPA actions
allowing the PRP to consider EPA's invitation to negotiate. The moratorium period varies depending on the response
action (ESI/RI/FS, RD, or RA) and can be extended if necessary.
Definition of Accomplishment:
This action is accomplished on the date the SNL is signed by the appropriate EPA official and entered into WasteLAN
as a SubAction, Special Notice Issued, with an actual completion date (Actual Complete). The date of issuance of the
SNL also constitutes the start of negotiations [Action Name = RI/FS Negotiations, RD/RA Negotiations, Negotiations
(Generic), or Removal Negotiations],
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
SNLs are recorded as a SubAction to PRP search or negotiation actions. The actual completion date of the SNL is the
same as the actual start date (Actual Start) of the applicable negotiation action. Issuance of SNLs is a program measure.
f EXPANDED SITE INSPECTION/REMEDIAL INVESTIGA TION/FEASIBILITY
STUD Y (ESI/RI/FS) NEGOTIATIONSTARTS
Definition:
ESI/RI/FS negotiations are discussions between EPA and the parties on their liability, willingness, and ability to conduct
the ESI/RI/FS.
September 8, 2005
C-10
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
ESI/RI/FS negotiations start when:
The first SNL is signed by the appropriate EPA official. This date is reported in WasteLAN as the start (Actual Start)
of negotiations [ActionName = Negotiations (Generic) or RI/FS Negotiations] and the completion (Actual Complete)
of the SNL SubAction (SubAction Name = Special Notice Issued); or
~ A Section 122(a) waiver of SNL is signed by the appropriate EPA official with the intent to pursue negotiations
without moratorium procedures. This date is reported in WasteLAN as the start (Actual Start) ofnegotiations [Action
Name = Negotiations (Generic) or RI/FS Negotiations] and the completion (Actual Complete) of the SNL waiver
SubAction (SubAction Name = Notice of S 122 Waiver Issued).
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
If the region does not plan to perform ESI/RI/FS negotiations at a site, negotiation dates should not be placed in
WasteLAN. The start of ESI/RI/FS negotiations [Action Name = Negotiations (Generic) or RI/FS Negotiations] should
be planned site-specifically. The "Response Actions Sought" are to be entered into WasteLAN. The Response Actions
Sought" must include one or more of the following actions: PRP RI/FS, RI/FS, FS, PRP FS, RI, PRP RI, or ESI/RI. The
actual start of the negotiation action is the same as the actual complete date (Actual Complete) of the SNL or waiver of
SNL. ESI/RI/FS negotiation starts is a program measure.
g. REMEDIAL DESIGN/REMEDIAL ACTION (RD/RA) NEGOTIATION STARTS (NPL &
Superfund Alternative)
Definition:
RD/RA negotiations are discussions between EPA and the parties on their liability, willingness, and ability to implement
the long-term remedy selected in the Record of Decision (ROD) for the site or Operable Unit (OU).
Credit is given atNPL and Superfund Alternative sites (NPL Status = Proposed for NPL, Currently on Final NPL, or
Deleted from Final NPL; or Special Initiatives Indicator = "Superfund Alternative" with NPL Status = Not on the NPL,
Removed from the Proposed NPL, Pre-Proposed Site, or Withdrawn) that are not Federal facility sites (Federal Facility
Indicator = Not a Federal Facility or Status Undetermined).
Definition of Accomplishment:
RD/RA negotiations start when:
The first SNL is signed by the appropriate EPA official. This date is reported in WasteLAN as the start (Actual Start)
of negotiations [Action Name = Negotiations (Generic) or RD/RA Negotiations]; or,
A Section 122(a) waiver of SNL is signed by the appropriate EPA official with the intent to pursue negotiations
without moratorium procedures. This date is reported in WasteLAN as the start (Actual Start) ofnegotiations [Action
Name = Negotiations (Generic) or RD/RA Negotiations],
Subsequent Negotiations - An interim settlement arises/order is issued for a portion of the site work from an existing
set of RD/RA negotiations and the Region does not plan to issue new special notice letter(s). The Region shall
establish a new RD/RA negotiation event in WasteLAN with a start date the same as the completion date of the first
set of RD/RA negotiations from which the interim settlement/order arose (i.e. Referral of Consent Decree for RD/RA,
Change 7, FY 04/05 SPIM
C-ll
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Issuance of UAO forRD/RA). This date is reported in WasteLAN as the start (Actual Start) of negotiations [Action
Name = Negotiations (Generic) or RD/RA Negotiations],
Concurrent Negotiations - The next phase of negotiations begins before the completion of the current RD/RA
negotiations and the Region does not plan to issue new special notice letter(s). The Region shall establish a new
RD/RA negotiation event in WasteLAN using as the start date of the new RD/RA negotiations whichever is earlier
either the date concurrent negotiations are first documented in meeting minutes or in a Memorandum for the Record
or the date the letter is signed by the appropriate EPA official accepting the Good Faith Offer (GFO) from PRPs that
delineates the negotiations. This date is reported in WasteLAN as the start (Actual Start) of negotiations [Action
Name = Negotiations (Generic) or RD/RA Negotiations],
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
If the region does not plan to conduct RD/RA negotiations, dates should not be entered into WasteLAN. The start of
RD/RA negotiations [Action Name = Negotiations (Generic) or RD/RA Negotiations] is planned site-specifically. The
"Response Actions Sought" are to be entered into WasteLAN. The "Response Actions Sought" must include one or more
of the following actions: Remedial Design, Remedial Action, PRP RD, or PRP RA. The actual start of the negotiation
action is the same as the actual completed date (Action C omplete) of the SNL or waiver of SNL. Superfund Alternative
sites should be identified in WasteLAN using the Special Initiatives Indicator of "Superfund Alternative". RD/RA
negotiation starts is a program measure.
h. COMPLETION OR TERMINA TION OF NEGOTIA TIONS FOR RD/RA (NPL &
Superfund Alternative)
Definition:
RD/RA negotiations are discussions between EPA and the parties on their liability, willingness, and ability to implement
the long-term remedy selected in the ROD for the site or Operable Unit (OU).
RD/RA negotiations end when the region decides how to proceed with the RD/RA.
Definition of Accomplishment:
Credit is given at NPL and Superfund Alternative sites (NPL Status = Proposed for NPL, Currently on Final NPL, or
Deleted from FinalNPL; or Special Initiatives Indicator = "Superfund Alternative" with NPL Status = Not on the NPL,
Removed from the Proposed NPL, Pre-Proposed Site, or Withdrawn) that are not Federal facility sites (Federal Facility
Indicator = Not a Federal Facility or Status Undetermined) when:
A signed Consent Decree (CD) under Section 106 or Sections 106 and 107 and a 10-point analysis forRD or RA is
referred by the Regional Administrator to either DO.T or HQ. The negotiation [Action Name = Negotiations (Generic)
or RD/RA Negotiations] actual completion date (Actual Complete) is the date of the signed transmittal memo, which
is the CD (Action Name = Consent Decree) actual start date (Actual Start); or
A Unilateral Administrative Order (UAO) for RD or RA is signed by the Regional Administrator or delegatee. The
negotiation [Action Name = Negotiations (Generic) or RD/RA Negotiations] actual completion date (Actual
Complete) is the date the UAO (Action Name = Unilateral Admin Order) is signed, which is the UAO actual
completion date (Actual Complete); or
September 8, 2005
C-12
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
~ A Section 106 or Sections 106 and 107 injunctive referral to compel the PRP to perform the RD or RA as specified
in a UAO is referred by the Regional Administrator to DOJ or HQ. The negotiation [Action Name = Negotiations
(Generic) or RD/RA Negotiations] actual completion date (Actual Complete) is the date of the Regional
Administrator's transmittal memo, which is the litigation [Action name = Litigation (Generic), Section 106 & 107
Litigation, or Section 106 Litigation] actual start date (Actual Start); or
~ EPA and PRPs are notified by a letter from DOJ of the date (Actual Complete) on which they will proceed to trial
under an existing case [Action Name = Negotiations (Generic) or RD/RA Negotiations]; or
An Administrative Order on Consent (AOC) or Consent Agreement (CA) for RD only is signed by the Regional
Administrator or delegatee. Where an AOC or CA for RD only is issued, no credit will be given for the subsequent
RA negotiation starts and completions. Credit will, however, be given under Total Response Settlements for the
referral of a CD for RA to DOJ or HQ. The negotiation [Action Name = Negotiations (Generic) or RD/RA
Negotiations] actual completion date (Actual Complete) is the date the AOC or CA is signed, which is the AOC
(Action Name = Admin Order on Consent or Consent Agreement) actual completion (Actual Complete); or
~ If Special Notice Letters are issued specifically to initiate RD/RA Negotiations and the negotiations result in an
amendment to an existing settlement to include RD/RA, the negotiation [Action Name = Negotiations (Generic) or
RD/RA Negotiations] actual completion date (Actual Complete) is the date the amended settlement is signed. This
amendment date is tracked as the actual completion date (Actual C omplete) of the settlement SubAction, Enforcement
Action Amended; or
~ Funds are obligated through a contract modification or work assignment signed by the CO, an IAG signed by the
other Federal agency, or a Cooperative Agreement signed by the designated Regional official for a Fund-financed
RD at NPL or Superfund Alternative sites or RA at NPL sites. The negotiation [Action Name = Negotiations
(Generic) or RD/RA Negotiations] actual completion date (Actual Complete) is the date funds are obligated. If funds
are not available and the region decides a UAO is not appropriate, the negotiation [Action Name = Negotiation
(Generic) or RD/RA Negotiations] actual completion date (Actual Complete) is the date of the written documentation
of the region's decision not to issue a UAO.
Changes in Definition FY02/03- FY04/05:
None.
Special Planning/Reporting Requirements:
This is a program measure. RD/RA negotiation completions are planned site-specifically. The negotiation completion
date is reported in WasteLAN as the actual completion date (Actual Complete) of either generic negotiations or RD/RA
negotiations [Action Name = Negotiations (Generic) or RD/RA Negotiations]. The "Response Actions Sought" and the
outcome of the negotiations [Other Outcome(s) Selected or Outcome Actions Selected] also must be reported in
WasteLAN. The "Response Actions Sought" must include one or more of the following actions: Remedial Design,
Remedial Action, PRP RD, or PRP RA. Superfund Alternative sites should be identified in WasteLAN using the Special
Initiatives Indicator of "Superfund Alternative".
i. COMPLETION OR TERMINA TION OF NEGOTIA TIONS FOR CLEANUP (RD/RA,
REMOVALS, AND OTHER) (NPL & Superfund Alternative)
Definition:
Cleanup negotiations are discussions between EPA and the parties on their liability, willingness, and ability to conduct
the cleanup. Negotiations are complete (for NPL and Superfund Alternative sites) when a decision has been made as to
how the region will proceed with the cleanup.
Change 7, FY 04/05 SPIM
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September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
Credit is given at NPL and Superfund Alternative sites (NPL Status = Proposed for NPL, Currently on Final NPL, or
Deleted from Final NPL; or Special Initiatives Indicator = "Superfund Alternative" with NPL Status = Not on the NPL,
Removed from the Proposed NPL, Pre-Proposed Site, or Withdrawn) that are not Federal facility sites (Federal Facility
Indicator = Not a Federal Facility or Status Undetermined) when:
A signed Consent Decree (CD) under Section 106 or Sections 106 and 107 and a 10-point analysis forRD, RA,
groundwater monitoring activities post ROD, institutional controls, or a time-critical or NTC removal is referred by
the Regional Administrator to either DO.T or HQ. The negotiation [Action Name = Negotiations (Generic), RD/RA
Negotiations, or Removal Negotiations] actual completion date (Actual Complete) is the date of the signed transmittal
memo, which is the CD (Action Name = Consent Decree) actual start date (Actual Start); or
~ A Unilateral Administrative Order (UAO) for RD, RA, groundwater monitoring activities post ROD, institutional
controls, or a time-critical or NTC removal is signed by the Regional Administrator or delegatee. The negotiation
[Action Name = Negotiations (Generic), RD/RA Negotiations, or Removal Negotiations] actual completion date
(Actual Complete) is the date the UAO (Action Name = Unilateral Admin Order) is signed which is the UAO actual
completion date (Actual Complete); or
~ An Administrative Order on Consent (AOC) or Consent Agreement (CA) for RD only, or groundwater monitoring
activities post-ROD, or institutional controls is signed by the Regional Administrator or delegatee. Where an AOC
or CA forRD only is signed, no credit will be given for the subsequent RA negotiation starts and completions. Credit
will, however, be given under Total Response Settlements for the referral of a CD for RA to DO.T or HQ. The
negotiation [Action Name = Negotiations (Generic) or RD/RA Negotiations] actual completion date (Actual
Complete) is the date the AOC or C A is signed, which is the AOC (Action Name = Admin Order on Consent) or C A
(Action Name = Consent Agreement) actual completion (Actual Complete); or
~ An AOC or CA for a time-critical or NTC removal is signed by the Regional Administrator or delegatee. The
negotiation [Action Name = Negotiations (Generic) or Removal Negotiations] actual completion date (Actual
Complete) is the date the AOC or CA is signed, which is the AOC (Action Name = Admin Order on Consent) or CA
(Action Name = Consent Agreement) actual completion date (Actual Complete); or
~ A Section 106 or Sections 106 and 107 injunctive referral to compel the PRP to perform the cleanup (RD or RA) as
specified in a UAO is referred by the Regional Administrator to DO.T or HQ. The negotiation [Action Name =
Negotiations (Generic) or RD/RA Negotiations] actual completion date (Actual Complete) is the date of the Regional
Administrator's transmittal memo, which is the litigation [Action Name = Litigation (Generic), Section 106 & 107
Litigation, or Section 106 Litigation] actual start date (Actual Start); or
~ A Prospective Purchaser Agreement (PPA) implementing the entire remedy is signed by the Regional Administrator
or delegatee. Credit is not given for negotiation completions as a result of a PPA which implements part of the
remedy. The negotiation [Action Name = Negotiations (Generic), Removal Negotiations or RD/RA Negotiations]
actual completion date (Actual Complete) is the date the PPA (Action Name = Admin Order on Consent or Consent
Agreement and Enf. Instrument Category = Prospective Purchaser Agreement) is signed by the Regional
Administrator or delegatee which is the actual completion date (Actual Complete) of the AOC or CA; or
~ EPA and PRPs are notified by a letter from DO.T of the date (Actual Complete) on which they will proceed to trial
under an existing case [Action Name = Negotiations (Generic) or RD/RA Negotiations]; or
September 8, 2005
C-14
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
For settlements that are amended to include cleanup actions, the negotiation [Action Name = Negotiations (Generic),
RD/RA Negotiations, or Removal Negotiations] actual completion date (Actual Complete) is the date the amended
instrument is signed. This amendment date is tracked as the actual completion date (Actual Complete) of the
settlement SubAction, Enforcement Action Amended; or
Funds are obligated through a contract modification or work assignment signed by the CO, an IAG signed by the
other Federal agency, or a Cooperative Agreement signed by the designated Regional official for a Fund-financed
time-critical or NTC removal or RA. Only those sites that are final on the NPL are eligible for Fund-financed RAs.
The negotiation [Action Name = Negotiations (Generic), Removal Negotiations, or RD/RA Negotiations] actual
completion date (Actual Complete) is the date funds are obligated. If funds are not available and the region decides
aUAO is not appropriate, the negotiation [Action Name = Negotiations (Generic), Removal Negotiations, or RD/RA
Negotiations] actual completion date (Actual Complete) is the date of the written documentation of the region's
decision not to issue the UAO.
Changes in Definition FY02/03 - FY04/05:
Changed from a program target to a program measure.
Special Planning/Reporting Requirements:
This is a program measure. The negotiation completion date is reported in WasteLAN as the actual completion date
(Actual Complete) of either generic negotiations, RD/RA negotiations, or removal negotiations [Action Name =
Negotiations (Generic), RD/RA Negotiations, or Removal Negotiations], The "Response Actions Sought" and the
outcome of the negotiations [Other Outcome(s) Selected or Outcome Actions Selected] also must be reported in
WasteLAN. Regions will receive credit for the completion of cleanup negotiations that result in the signature of an AOC
or CA with a prospective purchaser that is implementing the entire remedy. Superfund Alternative sites should be
identified in WasteLAN using the Special Initiatives Indicator of "Superfund Alternative".
j. PERCENTAGE OF REMEDIAL ACTION STARTS INITIATED BY PRPS AT NON-
FEDERAL FACILITY NPL AND SUPERFUND ALTERNA TIVE SITES
Definition:
A Remedial Action (RA) is the implementation of the remedy selected in the ROD, and for the purposes of this measure,
occurs at non-Federal facility NPL and Superfund Alternative sites.
Definition of Accomplishment:
This measure is the percentage of enforcement lead (i.e., PRP-financed in the RA Start Definition of Accomplishment
in Appendix B) RA starts at non-Federal facility NPL and Superfund Alternative sites. It is calculated as the enforcement
percentage of the total number of non-Federal facility RA starts. The program target is to achieve 70 percent or more
PRP-lead RA starts at non-Federal facility NPL and Superfund Alternative sites.
DISCLAIMER; Regions will receive credit in the management of the Superfund program for "start" of a remedial action
even though "initiation of physical on-site construction" may not have occurred for purposes of calculating a cost recovery
statute of limitations. The date found in the remedial action actual start column of a CERCLIS/WasteLAN report is a
programmatic measure only, and cannot be relied on upon to create any rights, substantive or procedural, enforceable by
any party in litigation with the United States. EPA reservesthe right to change such data atany time without public notice.
Changes in Definition FY02/03 - FY04/05:
Change from GPRA annual performance goal to program target.
Change 1, FY 04/05 SPIM
C-15
September 22, 2003
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OSWER Directive 9200.3-14-1G-Q
Special Planning/Reporting Requirements:
This is a program target. See special planning requirements in Appendix B, Section B.B.3.m, RA Start definition.
Superfund Alternative sites should be identified in WasteLAN using the Special Initiatives Indicator of "Superfund
Alternative".
k. TOTAL RESPONSE COMMITMENTS (INCL UDING DOLLAR VAL UE)
Definition:
Total Response Commitments is the total universe of CERCLA enforcement instruments where the parties agree to
conduct cleanup work and/or make cash payments toward future response costs at a site. This measure will require
reporting of both the number of enforcement instruments as well as the estimated value of the response work and/or cash
payments toward future response costs pursuant to each of those instruments.
Definition of Accomplishment:
Enforcement Instruments at non-Federal facility NPL, Superfund Alternative, and non-NPL sites include:
A Consent Decree (CD) signed by the Regional Administrator and PRPs and 10-point analysis is transmitted by the
Regional Administrator to DO.T or HQ, under Section 106 or Sections 106 and 107 for PRPs to conduct or pay for
the response action [ESI/RI, RI, RI/FS, FS, RD, RA, groundwater monitoring activities post-ROD, institutional
controls, time-critical or NTC removal]. Credit for the CD referral (Action Name = Consent Decree) is given on the
date on which the Regional Administrator's transmittal memo is sent to DO.T or to HQ. This date is recorded in
WasteLAN as the actual start date (Actual Start). Types of CDs include CDs for mixed work, preauthorized mixed
funding.de minimis, andcashout settlements. The appropriate Enforcement Instrument Categories Selected also must
be entered into WasteLAN.
A Unilateral Administrative Order (UAO) is signed by the Regional Administrator or delegatee for response work,
and at least one of the PRPs has provided notice of intent to comply unconditionally. Commitment credit is given
on the date of the PRP 's written notice of intent to comply with the order. This is reported in WasteLAN as the actual
completion date (Actual Complete) of the Notice of Intent to Comply SubAction (SubAction Name = PRPs Ntfy
EPA, Intent to Comply). The actual completion date (Actual Complete) of the order (Action Name = Unilateral
Admin Order) is the date it is signed.
If a PRP initially complies with a UAO, credit will be given for the UAO when the first PRP provides written notice
of intent to comply. If, at a later date, the PRP agrees to a CD for the same work, credit will be given for the CD
when it is referred by memo to DO.T or HQ. At this point the region will receive credit for the CD only and not the
UAO. When adding the Consent Decree Action, the region should identify the UAO as the predecessor action
through Action Relationships and enter the estimated value of the UAO as the estimated value of the CD if the CD
covers the same work. If the CD covers more work than the UAO it replaces, a revised estimate may be necessary.
The WasteLAN reporting requirements for the CD apply.
An Administrative Order on Consent (AOC) or Consent Agreement (CA) is signed by the Regional Administrator
or delegatee for PRPs to perform or pay for an ESI/RI, RI, RI/FS, FS, time-critical or NTC removal, RD, monitored
natural attenuation, institutional controls, or groundwater monitoring post-ROD. The date the AOC or CA is signed
(Action Name = Admin Order on Consent or Consent Agreement (CA)) is reported in WasteLAN as the actual
completion date (Actual Complete).
September 8, 2005
C-16
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Commitment credit is also given when an AOC or C onsent Agreement (C A) is signed that provides protection from
potential future liability to a prospective purchaser that is implementing the remedy. The actual completion date
(Actual Complete) is the date the AOC or CA (Action Name = Admin Order on Consent or Consent Agreement (CA)
and Enf Instrument Category Selected = Prospective Purchaser Agreement) is signed by the Regional Administrator
or delegatee.
Total Response Commitments will be reported as a combined total of CDs, CAs , AOCs, and UAOs, where response
actions have been achieved and/or parties agree to make cash payments toward future response co sts at a site. The value
of Total Response Commitments is based on the estimated value of PRP response work and/or payments made by
responsible parties toward future response costs at a site.
An enforcement instrument is active until the provisions of the instrument or another document incorporated by
reference is completed including payment provisions and monitoring (with the exception of any activity related to
record retention). (The CD, AOC, CA, or UAO has an Overall Compliance Status of "Closed Order/Settlement"; and
the SubAction = Closed Order or Settlement, or the SubAction = Closed Order or Settlement with Potential for
Penalty Claim has an Actual Completion Date). In addition, a UAO that is converted to a CD is no longer active.
Changes in Definition FY02/03- FY04/05:
Added closed order or settlement. For UAOs for response work, commitment credit is given on the date of the PRP's
written notice of intent to comply with the order.
Special Planning/Reporting Requirements:
The applicable "Response Actions Pd by Parties," the "Work the PRP Will Perform - Value" (see supplement to: OSWER
Directive #9200.3-14-la) or the "Federal Costs Settled - Future", "Other Relief Achieved" , if applicable; and, if
necessary, the "Enforcement Instrument Categories Selected" are to be reported in WasteLAN. Settlement credit will
be given for an AOC or CA with a prospective purchaser if "Prospective Purchaser Agreement" is the selected
enforcement instrument category. Existing settlements for ESI/RI, RI/FS or FS that are amended to include RD should
be reported in WasteLAN. The date the amendment is signed is the actual completion date (Actual Complete) of the
SubAction "Enforcement Action Amended." The region should also indicate the "Response Actions Pd by Parties" added
under the settlement. Amended Instruments will not count for credit in the current year; however, the Total Response
Commitments will be included in the program to-date dollar amount. Dollars received in a cashout settlement should be
deposited in an interest bearing special account if site-specific conditions warrant. See the measure, Settlements
Designating Deposits to Special Accounts, for more information. This is a program measure. The "Work the PRP Will
Perform - Value" and "Federal Costs Settled - Future" (i.e., the value of total response commitments) will be reported for
GPRA.
/. ENFORCEMENT SETTLEMENTS/INSTRUMENTS FOR RD/RA/Long-Term Response
(LR) (Including Dollar Value)
Definition:
This measure is a subset of the universe of "Total Response Commitments." This is a measure of CERCLA enforcement
settlements (CDs, AOCs, or CAs), or other enforcement instruments (UAOs) where the parties agree to conduct remedial
(RD, RA, or LR) response work. This measure will require reporting of both the number of enforcement
settlements/instruments, as well as the estimated value of the response work pursuant to each of those
settlements/instruments.
Definition of Accomplishment:
Enforcement Instruments at non-Federal facility NPL, Superfund Alternative, and non-NPL sites include:
Change 7, FY 04/05 SPIM
C-17
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
A Consent Decree (CD) signed by the Regional Administrator and PRPs and 10-point analysis is transmitted by
the Regional Administrator to DO.T or HQ, under Section 106 or Sections 106 and 107, for PRPs to conduct or
pay for the remedial or long-term response action [RD, RA, or LR], Credit for the CD referral (Action Name =
Consent Decree) is given on the date on which the Regional Administrator's transmittal memo is sent to DO.T or
to HQ. This date is recorded in WasteLAN as the actual start date (Action Start). Types of CDs include CDs for
mixed work, preauthorized mixed funding, de_ minimis, and cashout settlements. The appropriate Enforcement
Instrument Categories Selected also must be entered into WasteLAN.
Unilateral Administrative Order (UAO) for RD, RA, or LR is signed by the Regional Administrator or delegatee,
and at least one of the PRPs has provided notice of intent to comply unconditionally. For UAOs for RD, RA, or
LR, commitment credit is given on the date of the PRP's written notice of intent to comply with the order. This is
reported in W asteLAN as the actual completion date (Actual Complete) of the Notice of Intent to Comply
SubAction (SubAction Name = PRPs Ntfy EPA, Intent to Comply). The actual completion date (Actual
Complete) of the order (Action Name = Unilateral Admin Order) is the date it is signed.
If a PRP initially complies with a UAO, credit will be given for the UAO when the first PRP provides written
notice of intent to comply. If, at a later date, the PRP agrees to a CD for the same work, credit will be given for
the CD when it is referred by memo to DO.T or HQ. At this point, the region will receive credit for the CD only
and not the UAO. When adding the Consent Decree Action, the region should identify the UAO as the
predecessor Action through Action Relationships and enter the estimated value of the UAO as the estimated value
of the CD if the CD covers the same work. If the CD covers more work than the UAO it replaces, a revised
estimate of response value may be necessary. The WasteLAN reporting requirements for the CD apply; or
An Administrative Order on Consent (AOC) or Consent Agreement (CA) is signed by the Regional Administrator
or delegatee for RD only, or a cashout settlement of de_ minimis parties for RA, or a LR such as groundwater
monitoring post-ROD, or institutional controls. The date the AOC or CA is signed (Action Name = Admin Order
on Consent (AOC) or Consent Agreement (CA)) is reported in WasteLAN as the actual completion date (Actual
Complete).
Credit is also given when an AOC or CA is signed for RD, RA, or LR work, and provides protection from
potential future liability to a prospective purchaser that is implementing the remedy. The actual completion date
(Actual Complete) is the date the AOC or CA (Action Name = Admin Order on Consent (AOC) or Consent
Agreement (CA) and Enf Instrument Category Selected = Prospective Purchaser Agreement) is signed by the
Regional Administrator or delegatee.
Enforcement Settlements/Instruments for RD, RA, or LR will be reported as a combined total of CDs, UAOs (with
Notice of Intent to Comply), AOCs, and CAs where RD, RA or LR actions have been achieved. The value of RD,
RA, or LR commitments is based on the estimated value of PRP response work and/or payments made by responsible
parties toward future response work (i.e., cashouts).
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
The applicable "Response Actions Pd by Parties," the "Work PRP Will Perform - Value" of the response actions the PRPs
are performing (see supplement to: OSWER Directive #9200.3-14-la), or the "Federal Costs Settled - Future" and, if
necessary, the "Enforcement Instrument Categories Selected" are to be reported in WasteLAN. Existing settlements for
ESI/RI, RI/FS, or FS that are amended to include RD should be reported in WasteLAN. The date that the amendment
is signed is the actual completion date (Actual Complete) ofthe SubAction "Enforcement Action Amended." The region
should also indicate the "Response Actions Pd by Parties" added under the settlement/ instrument. Amended Instruments
will not count for credit in the current year; however, the settlement/instrument will be included in the program to-date
September 8, 2005
C-18
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
amount. Enforcement Settlements/Instruments for RD/RA/ LR will be reported in the ENFR-03 report - Settlement type
= "RD/RA/LR Only" category. This is a program measure.
m. DE MINIMIS SETTLEMENTS AND NUMBER OF PARTIES
Definition:
This measure reports the total number of administrative or judicial settlements that are reached under Section 122(g) of
CERCLA, with PRPs qualified as de_ minimis. This type of settlement results in PRPs paying a minor portion of the
estimated response costs at the site, and is embodied in a CD or an AOC. If the total response costs at the site exceed
$500,000 (excluding interest), the AOC can only be signed by the Regional Administrator or delegatee after prior written
approval from DO.T. If DO.T does not approve or disapprove the order within 30 days, the order is considered approved
and can then be signed by the region. The DO.T and the Regional Administrator or delegatee can agree to extend the 30-
day period if necessary.
This measure will examine the total number of de minimis settlements under Section 122(g), the number of PRPs who
sign such settlements, and the number of sites at which de_ minimis settlements were signed.
Definition of Accomplishment:
Credit is given at non-Federal facility NPL, Superfund Alternative, and non-NPL sites for de_ minimis settlements in
the following two categories.
Category 1: De_ minimis settlements include:
~ An Administrative Order on Consent (AOC) (Action Name = Admin Order on Consent) signed by the Regional
Administrator or delegatee. The date the AOC is signed is reported in WasteLAN as the actual completion date
(Actual Complete) of the AOC (Action Name = Admin Order on Consent).
A memorandum transmitting the Consent Decree (CD) (Action Name = Consent Decree) signed by the Regional
Administrator and the de_ minimis parties to DO.T or HQ. The date of the transmittal memorandum is reported in
WasteLAN as the actual start date (Actual Start).
The number of signatories to the settlement is system generated in WasteLAN from the identification of the PRPs who
have signed the settlement.
Category 2: Early de_ minimis settlements include:
An Administrative Order on Consent (AOC) (Action Name = Admin Order on Consent) signed by the Regional
Administrator or delegatee prior to the first remedy selection (ROD) at the site, or prior to a subsequent ROD which
addresses response costs that are included in the settlement. The date the AOC is signed is reported in WasteLAN
as the actual completion date (Actual Complete) of the AOC (Action Name = Admin Order on Consent).
A memorandum transmitting the Consent Decree (CD) (Action Name = Consent Decree) signed by the Regional
Administrator and the de_ minimis parties and the Regional Administrator to DO.T or HQ prior to the first remedy
selection (ROD) at the site or prior to a subsequent ROD which addresses response costs that are included in the
settlement. The date of the transmittal memorandum is reported in W asteLAN as the actual start date (Actual Start)
of the CD (Action Name = Consent Decree).
The number of signatories to the settlement is system generated in WasteLAN from the identification of the PRPs who
have signed the settlement.
Change 7, FY 04/05 SPIM
C-19
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Changes in Definition FY02/03- FY04/05:
Removed the request for the Regions to complete the de minimis Settlement Survey Form from Additional Reporting
Requirements. Changed De micromis Settlements to Non-exempt De micromis Parties Settlements. Changed from
program target and a GPRA annual performance reporting measure to a program measure.
Special Planning/ Reporting Requirements:
This is a program measure. The following information should be entered into WasteLAN for both Category 1 and
Category 2 settlements:
~ Enforcement Instrument Categories Selected of de minimis;
PRPs that signed the settlement (Parties Associated with Action, Party Name);
Dollar amount that will be used for current, future, or past work covered by the settlement [W ork PRP W ill Perform -
Value, Federal Costs Settled - Past and/or Federal Costs Settled - Future (as applicable)]; and
Applicable Response Actions Pd by Parties, Other Relief Achieved, or Response Actions Reimbursed.
To indicate the de minimis PRPs that signed the settlement, the following information must be entered for each
party on the Party Search/Information, Involvement tab:
Basis of Liability of "De Minimis party"; and
Involvement Type of "Owner", "Generator" or "Transporter".
Since many de_ minimis settlements are cashouts, regions also must enter an Enforcement Instrument Category of
"Cashout." Dollars received in a de minimis cashout settlement should be deposited in an interest bearing special account
if site-specific conditions warrant. See the Settlements Designating Deposits to Special Accounts measure foradditional
information. The number of signatories to the settlement is system generated from the identification of the PRPs who have
signed the settlement.
Additional Reporting Requirements:
Regions are requested to provide site-specific targets for de minimis settlements. During the fiscal year, regions can
change sites within the target number without OSRE approval, but OSRE should be informed of any changes.
(Also see Non-exempt De Micromis Parties Settlements and Number of Parties.)
n. CASHOUT SETTLEMENTS
Definition:
This measure reports the total number of administrative or judicial settlements where the parties agree to make cash
payments toward future response costs at a site.
Definition of Accomplishment:
Credit is given when:
The Regional Administrator transmits the cashout CD (Action Name = Consent Decree) to DO.T or HQ as recorded
in WasteLAN as the actual start date (Actual Start); or
September 8, 2005
C-20
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
The Regional Administrator or delegatee signs the AOC (Action Name = Admin Order on Consent) for the cashout
settlement as recorded in WasteLAN as the actual completion date (Actual Completion).
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
This is a program measure. Regions must enter the appropriate Enforcement Instrument Category "Federal Costs Settled -
Future", "Response Actions Pd by Parties", and/or "Other Relief Achieved". Dollars received in a cashout settlement
should be deposited in an interest bearing special account if site-specific conditions warrant. See the measure, Settlements
Designating Deposits to Special Accounts, for more information.
o. SECTION 106,106 and 107,107 CASE RESOLUTION (Including Claim in Bankruptcy)
Definition:
Case resolution is the conclusion of a Section 106, 106 and 107, 107 judicial action, or Claim in Bankruptcy by full
settlement, final judgment, case dismissal, or case withdrawal, or final judgment.
Definition of Accomplishment:
Credit for case resolution is given at non-Federal facility NPL, Superfund Alternative, and non-NPL sites when:
A Consent Decree (CD) is entered in the court and signed by the judge fully addressing the complaint with all parties;
The region receives a memo or letter from DO.T withdrawing the case;
A decision document is submitted by the judge dismissing the case; or
~ A trial has concluded and a judgment rendered and signed by the judge fully addressing the complaint.
The Litigation or case resolution (Action Name = Litigation (Generic), Section 106 & 107 Litigation, Section 107
Litigation, Section 106 Litigation, or Claim in Bankruptcy Proceeding) actual completion date (Actual Complete) is
defined as follows:
Date full settlement CD is entered. This is the actual completion date (ActualComplete) oftheCD, actual completion
date of the SubAction = Entered by Court, and the litigation or bankruptcy action actual completion date (Actual
Complete);
Date case is withdrawn (SubAction Name = Case Withdrawn) as the SubAction completion and litigation or
bankruptcy actual completion date (ActualComplete);
Date case is dismissed (SubAction Name = Case Dismissed) as the SubAction and litigation or bankruptcy actual
completion date (Actual Complete); or
Date judgment is entered (Action Name = Judicial/Civil Judgment) as the judgment and the litigation or bankruptcy
actual completion date (Actual Complete).
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
This is a program measure.
Change 7, FY 04/05 SPIM
C-21
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
p. ISSUANCE OF DEMAND LETTER
Definition:
A Section 122(e) letter issued from EPA to the PRP requesting that the PRP reimburse the Fund for a specific amount
associated with one or more response activities. Demand letters are typically sent for each separate response activity.
Definition of Accomplishment:
This Action is accomplished on the date (Actual Complete) the demand letter is signed by the appropriate EPA official
and recorded in WasteLAN as a Action (Action Name = Demand Letters Issued) to the negotiation actions,
Administrative/Voluntary Cost Recovery action, UAO, Litigation actions, or Decision Documents.
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
This is a program measure.
q. TOTAL COST RECOVERY SETTLEMENTS (INCLUDING DOLLAR VALUE)
Definition:
Total Cost Recovery Settlements is the total universe of CERCL A enforcement cost recovery settlements where the parties
agree to pay past costs to the Agency. This measure will require reporting of both the number of settlements as well as
the value of the past costs to be recovered pursuant to each of these settlements.
Definition of Accomplishment:
Settlements at non-Federal facility NPL, Superfund Alternative, and non-NPL sites include:
Consent Decrees - Credit is given for CD settlements (Action Name = Consent Decree) for RD/RA with a cost
recovery component, or CDs for cost recovery only that were not a result of a previous litigation referral, on the date
of the Regional Administrator's memo transmitting the settlement to DO J or HQ and recorded in WasteLAN as the
actual start date (Actual Start).
For CD settlements that are for cost recovery only and result from a previous litigation referral, regions should not
add a CD start date (Actual Start). Only the lodged (SubAction Name = Lodged by DOJ) and entered (SubAction
Name = Entered by Court) SubActions, their actual completion dates (Actual Complete), and the actual completion
date (Actual Complete) of the CD are recorded. The actual completion date of the CD is the date it is entered by the
court. If the actual completion date for the Lodged by DOJ SubAction exists, credit will be given in the FY identified
by this completion date.
Administrative Settlements - Credit is given on the date that the Regional Office or DOJ receives payment from the
PRPs in direct response to a demand letter for voluntary cost recovery or the date the Regional Administrator or
delegatee signs the Administrative Order on Consent (AOC) or Consent Agreement (CA) for cost recovery. The date
must be reported in WasteLAN as the actual completion date (Actual Complete) of the administrative/voluntary cost
recovery (Action Name = Admin/Voluntary Cost Recovery), AOC (Action Name = Admin Order on Consent), or
CA (Action Name = Consent Agreement).
Total Cost Recovery Settlements will be reported as the combined total of CDs, CAs, Administrative/Voluntary Cost
Recovery actions and AOCs where cost recovery has been achieved.
April 7, 2003
C-22
FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
An enforcement instrument is active until the provisions of the instrument or another document incorporated by
reference is completed including payment provisions and monitoring (with the exception of any activity related to
record retention). (The CD, AOC, or CA has an Overall Compliance Status of "Closed Order/Settlement"; and the
SubAction = Closed Order or Settlement, or the SubAction = Closed Order or Settlement with Potential for Penalty
Claim has an actual completion date (Actual Complete)).
Changes in Definition FY02/03 - FY04/05:
Added closed order or settlement.
Special Planning/Reporting Requirements:
This is a program measure. The "Federal Costs Settled - Past "must be entered into WasteLAN. This measure will be
reported in the ENFR-03 report. The "Federal Costs Settled - Past" (i.e. the value of costs recovered) will be reported
forGPRA.
r. PAST COSTS ADDRESSED > $200,000 VIA SETTLEMENTS, WRITE-OFFS, OR
REFERRALS
Definition:
Past Costs Addressed > $200,000 is the decision either to take cost recovery action by use of administrative cost recovery
settlement, to transmit a Sections 106 and 107 or 107 judicial referral for cost recovery, including settlements for past
costs under a 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.
It only covers cases where EPA has incurred costs> $200,000. It is vital to the management of the cost recovery program
that sites with upcoming Statute ofLimitations(SOLs)be addressed prior to the expiration of the SOL. Therefore, regions
will not be allowed to substitute FY 04/05 targeted sites that have SOLs occurring in or before FY 04/05 or the first
quarter of FY 04/05.
Definition of Accomplishment:
Credit is given at non-Federal facility NPL, Superfund Alternative, and non-NPL sites.
Administrative Settlements - Credit is given on the date the Regional office or DO J receives payment from the PRPs in
direct response to a demand letter for voluntary cost recovery, or the date the Regional Administrator or delegatee signs
the Administrative Order on Consent (AOC) or Consent Agreement (CA) that recovers 100 percent of the Trust Fund
expenditures or settles a claim where the total response costs are less than $500,000. The accomplishment of the
administrative settlement is recorded in WasteLAN as the actual completion date (Actual Complete) of the
administrative/voluntary cost recovery (ActionName = Admin/Voluntary Cost Recovery), AOC (ActionName = Admin
Order on Consent), or CA (Action Name = Consent Agreement). If the settlement is compromised and total response
costs are more than $500,000, the AOC must be sent to DO.T for approval prior to signature by the Regional Administrator
or delegatee.
Section 107 or 106 and 107 Judicial Referrals - Credit is given on the date of the Regional Administrator's memo
transmitting the referral to DO.T or HQ [Action Name = Litigation (Generic), Section 107 Litigation, or Section 106 &
107 Litigation] as recorded in WasteLAN as the actual start date (Actual Start).
This includes Consent Decree (CD) settlements (Action Name = Consent Decree) for RD/RA with a cost recovery
component or CD settlements for cost recovery only that were not the result of a prior litigation referral. Credit is given
for these C D settlements on the date of the Regional Administrator's memo transmitting the settlement to DO.T or HQ and
recorded in WasteLAN as the actual start date (Actual Start).
Change 7, FY 04/05 SPIM
C-23
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
CD settlements that are for cost recovery only and result from a previous litigation referral do not count towards this
target. The start date (Actual Start) for these actions is not reported in WasteLAN. Only the lodged (SubAction Name
= Lodged by DO.T) and entered (SubAction Name = Entered by Court) SubActions, the SubAction actual completion date
(Actual Complete), and the actual completion date (Actual Complete) of the CD are recorded. The actual completion date
of the CD is the date it is entered by the court.
Decision Documents not to Pursue Cost Recovery - Credit is given when the decision document (Action Name = Cost
Recovery Decsn Docmt - No Sue) is signed by the Regional office and recorded in WasteLAN as the actual completion
date (Actual Complete). The decision not to pursue cost recovery also may be documented in an enforcement instrument
10-point settlement analysis. For both the Cost Recovery Decision Document Not to Sue and the 10-point analysis, the
past costs that will not be recovered (Past Costs Written Off) and the reason the costs were written off should be reported
in WasteLAN.
Bankruptcy Filing - Credit is given based on the date that the bankruptcy strategy package is prepared or on the date of
the first creditor committee meeting as documented by the summary of the meeting. These dates are reported in
WasteLAN as the SubAction "Creditors Committee Meeting" and/or "Bankruptcy Strategy Package" actual completion
dates (Actual Complete). These SubActions are entered with the Claim in Bankruptcy action. For each Claim in
Bankruptcy, the "Federal Costs Sought - Past" must be entered into WasteLAN.
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
All dates must be entered into WasteLAN. Credit for referrals is based on the referral package, not on the number of sites.
Credit will be withdrawn if a case is returned to the region by DO.T or HQ for additional work but will be reinstated upon
re-referral. For each settlement, the region must enter "Federal Costs Settled - Past" into WasteLAN. For each judicial
referral, regions must enter "Federal Costs Sought - Past." For each decision not to pursue cost recovery, the "Past Costs
Written Off" must be entered. Accomplishments are reported on a site-specific basis. Any changes to the target require
prior approval by the OSRE. This is a GPRA annual performance goal.
v. RECOVERABLE PAST COSTS THAT HA VE BEEN ADDRESSED BY PROGRAM
TO DATE VIA SETTLEMENTS, WRITE-OFFS, OR REFERRALS
Definition:
This measure supports the goal of Trust Fund Stewardship by reporting the amount and percentage of recoverable past
costs that were addressed versus all recoverable past costs (i.e., past costs eligible for recovery, program-to-date). The
regions are encouraged to address all of the recoverable past costs through enforcement activities so that the maximum
amount of recoverable funds can be obtained to support Superfund cleanups.
Recoverable past costs are past costs that are considered potentially recoverable. These costs include EPA direct and
indirect costs, plus contractor program management costs which are allocated to sites annually.
Some Superfund past costs are considered unrecoverable, including funds expended at orphan sites, costs that were
compromised during previous cost recovery efforts, and costs that were previously written off. Indirect costs over and
above those that are recoverable under the current indirect rates are also considered not recoverable.
Past Costs Addressed axe. costs addressed through administrative settlements, Section 107 or 106 and 107 judicial referrals
including settlements for past costs under a CD, decision documents or 10-point settlement analysis documents not to
pursue cost recovery, or bankruptcy filing. Depending on the enforcement action, the "Federal Costs Settled - Past," "Past
Costs Written Off," or "Federal Costs Sought - Past" must be entered into WasteLAN.
September 8, 2005
C-24
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Recoverable Past Costs include all past costs at the site, regardless of cost recovery status or previous cost recovery
efforts. Recoverable costs include direct response costs, indirect costs allocated to the site using the applicable indirect
rates, an estimate of contractor program management costs as allocated to the site, and any other costs charged to the site,
as indicated by the appropriate Financial Management Division (FMD) system such as, Integrated Financial Management
System (IFMS), the Superfund Cost Organization and Recovery Enhancement System (SCORES), or Superfund Cost
Recovery Package and Image On-Line System (SCORPIOS). The percentage of recoverable past costs addressed is the
amount of past costs addressed compared to the estimated total amount of recoverable past costs.
Definition of Accomplishment:
Credit is given at non-Federal facility NPL, Superfund Alternative, and non-NPL sites. Cost may be addressed through
one or more of the following actions:
Administrative Settlements - Credit is given on the date the Regional office or DO.T receives payment from the PRPs in
direct response to a demand letter for voluntary cost recovery, or the date the Regional Administrator or delegatee signs
the Administrative Order on Consent (AOC) or Consent Agreement (CA) that recovers 100 percent of the Trust Fund
expenditures or settles a claim where the total response cost are less than $500,000. The accomplishment of the
administrative settlement is recorded in WasteLAN as the actual completion date (Actual Complete) of the
administrative/voluntary cost recovery (ActionName = Admin/Voluntary Cost Recovery), AOC (ActionName = Admin
Order onConsent), orCA (ActionName = Consent Agreement). If the settlement is compromised and total response costs
are more than $500,000, the AOC must be sent to DO.T for approval prior to signature by the Regional Administrator.
Section 107 or 106 and 107 Judicial Referrals - Credit is given on the date of the Regional Administrator's memo
transmitting the referral to DO.T or HQ [Action Name = Litigation (Generic), Section 107 Litigation, or Section 106 &
107 Litigation] as recorded in WasteLAN as the actual start date (Actual Start).
This includes CD settlements (Action Name = Consent Decree) for RD/RA with a cost recovery component and CD
settlements for cost recovery only. For CD settlements for RD/RA with a cost recovery component and CD settlements
that were not the result of prior litigation, credit is given on the date of the Regional Administrator's memo transmitting
the settlement to DO.T or HQ. This date is reported in WasteLAN as the actual start date (Actual Start) of the CD (Action
Name = Consent Decree). For CD settlements that are for cost recovery only and result from a previous litigation referral,
the CD actual start date (Actual Start) is not reported in WasteLAN. Only the lodged (SubAction Name = Lodged by
DO.T) and entered (SubAction Name = Entered by Court) SubActions, the SubAction actual completion date (Actual
Complete), and the actual completion date (Actual Complete) of the CD are recorded. The actual completion date of the
CD is the date it is entered by the court.
Decision Documents not to Pursue Cost Recovery - Credit is given when the decision document (ActionName = Cost
Recvry Decsn Docmt - No Sue) is signed by the Regional office and recorded in WasteLAN as the actual completion date
(Actual Complete). The decision not to pursue cost recovery also may be documented in a 10-point settlement analysis.
For both the Cost Recovery Decision Document Not to Sue and the enforcement instrument 10-point settlement analysis,
the past costs that will not be recovered (Past Costs Written Off) and the reason(s) the costs were written off should be
reported in WasteLAN.
Bankruptcy Filing - Credit is given based on the date that the bankruptcy strategy package is prepared or on the date of
the first creditor committee meeting as documented by the summary of the meeting. These dates are reported in
WasteLAN as the SubAction "Creditors Committee Meeting" and/or "Bankruptcy Strategy Package" actual completion
dates (Actual Complete). These SubActions are entered with the Claim in Bankruptcy action. For each Claim in
Bankruptcy, the "Federal Costs Sought - Past" must be entered into WasteLAN.
Changes in Definition FY02/03- FY04/05:
None.
Change 7, FY 04/05 SPIM
C-25
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Special Planning/Reporting Requirements:
This is a program measure. See Definition and Definition of Accomplishment.
t. NUMBER AND AMOUNT OF CERCLA PENALTIES ASSESSED
Definition:
This measure supports the goal of Trust Fund Stewardship by providing information on the amount and number of final
CERCLA penalties assessed. The measure identifies monies that are provided for the TrustFund as a result of penalties
assessed for violations of the CERCLA statute. The measure also supports the systematic reporting on the programmatic
impacts of compliance and enforcement.
This measure is expressed as the dollar amount of the final assessed penalty under CERCLA. For civil judicial cases, this
amount is the penalty assessed against the defendant(s) as specified in the Consent Decree or Court Order entered by the
court or agreed to by the defendants). For administrative cases, it is the penalty agreed to in the final AOC or assessed
directly by EPA under Section 109(a) and (b) of CERCLA.
The number of CERCLA penalties assessed is the number of civil, judicial, or administrative enforcement actions where
a penalty was assessed under a CERCLA statute.
Definition of Accomplishment:
The number of CERCLA penalties assessed is the total number of enforcement actions (CDs, AOC s, judgments, or court
orders) where a penalty was assessed under a CERCLA statute, including actions that are only for CERCLA or multi-
media actions that contain a CERCLA component.
The value of CERCLA penalties assessed is the total dollar amount of penalties assessed under the CERCLA statute for
violations of requirements contained in civil, judicial, and administrative enforcement actions. If the enforcement action
consists of multi-media actions, this measure will only include the amount that is assessed under the CERCLA statute,
to the extent that it can be specified.
Changes in Definition FY02/03 - FY04/05:
Changed Enforcement Docket System to Integrated Compliance Information System (ICIS) which was implemented in
FY 02.
Special Planning/Reporting Requirements:
The "Stipulated Penalty Assessed - Amount Imposed" and/or "Statutory Penalty Assessed - Amount Imposed" should be
entered into WasteLAN through the Penalty/SEP screens associated with the enforcement instrument. The number and
value of CERCLA penalties will be obtained from the Office of Compliance using information reported in the Integrated
Compliance Information System (ICIS) . This is a program measure.
April 7, 2003
C-26
FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
u. NUMBER AND AMOUNT OF CERCLA SUPPLEMENTAL ENVIRONMENTAL
PROJECTS (SEPs)
Definition:
SEPs are environmentally beneficial projects which a violator agrees to undertake in settlement of an enforcement action,
but which the violator is not otherwise legally required to perform. The SEP could be for public health, pollution
prevention, pollution reduction, environmental restoration and protection, assessments and audits, environmental
compliance promotion, emergency planning and preparedness, or other program-specific projects.
This measure supports the goal of Trust Fund Stewardship by measuring the number and value of SEPs under CERCLA.
The measure provides the opportunity for the violator to undertake environmentally beneficial proj ects that will potentially
prevent the creation of additional Superfund sites, thus avoiding the need for using Trust Fund monies for future cleanups.
The measure also supports the systematic reporting on the programmatic impacts of compliance and enforcement.
Definition of Accomplishment:
The number of CERCLA SEPs is the total number of cases where a SEP was agreed upon under a CERCLA statute,
including cases that are only for CERCLA or multi-media cases that contain a CERCLA component.
The value of the CERCLA SEPs agreed upon is the estimated value of the SEP under the CERCLA statute for civil,
judicial, and administrative enforcement actions. If the action is a multi-media action, the SEP will be the total value
for all media not just media covered under CERCLA.
Changes in Definition FY02/03 - FY04/05:
Changed Enforcement Docket System to Integrated Compliance Information System (ICIS) which was implemented in
FY 02.
Special Planning/Reporting Requirements:
The following information should be entered into WasteLAN through the Penalty/SEP screens associated with the
enforcement instrument: the SEP Information - EPA Estimated Value and SEP Information - Category. The number and
value of SEPs agreed upon under CERCLA will be obtained from the Office of Compliance using the information reported
in the Integrated Compliance Information System (ICIS) . This is a program measure.
v. USE OF ALTERNATIVE DISPUTE RESOLUTION (ADR)
Definition:
This measure reports the number of sites where ADR techniques are employed in an attempt to reach settlement under
CERCLA or to resolve disputes over cleanup standards and Applicable or Relevant and Appropriate Requirements
(ARARs). Sites using ADR tools are divided into two categories: sites where the Agency employs and funds ADR in the
CERCLA process; and sites where the Agency supports private party use of ADR in the CERCLA process. It does not
include cases where the private parties use ADR without the Agency's support. This measure includes use of ADR in
disputes regarding allocation of liability; in disputes with PRPs regarding alleged noncompliance with a settlement
agreement; and in disputes with States and tribes regarding ARARs and cleanup standards. This measure will report site-
specific use of ADR.
Definition of Accomplishment:
Credit is given at non-Federal facility NPL, Superfund Alternative, and non-NPL sites for ADR activities when:
FY 04/05 SPIM
C-27
April 7, 2003
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OSWER Directive 9200.3-14-1G-Q
~ Allocation of Shares of Responsibility - The parties involved choose a neutral allocator. The date on which the
allocator is chosen is recorded in WasteLAN as the actual start date (Actual Start) of the Alternative Dispute
Resolution action. The ADR Process of "Allocation" should also be entered.
~ Arbitration - The parties involved in binding or advisory negotiation (in a judicial setting) choose an arbitrator. The
date on which the arbitrator is selected is recorded in WasteLAN as the actual start date (Actual Start) of the
Alternative Dispute Resolution action. The ADR Process of "Arbitration" should also be entered.
~ Convening - A neutral third party is selected to organize disputants for negotiations, assist them in the decision to
use ADR, and assist in the selection of an ADR professional. The date on which the neutral third party is selected
is recorded in W asteLAN as the actual start date (Actual Start) of the Alternative Dispute Resolution action. The
ADR Process of "Convening" should also be entered.
~ Fact Finding - A specialized neutral party with subject matter expertise is selected to resolve technical or factual
issues. The date that the specialized neutral party is selected is recorded in WasteLAN as the actual start date (Actual
Start) of the Alternative Dispute Resolution action. The ADR Process of "Fact Finding" should also be entered.
~ Mediation - The parties select a neutral third party with no decision-making authority to assist during non-binding
negotiations. The date on which the neutral party is selected is recorded in WasteLAN as the actual start date (Actual
Start) of the Alternative Dispute Resolution action. The ADR Process of "Mediation" should also be entered.
~ Mini-Trial - The involved parties begin the mini-trial. The date on which the mini-trial begins is recorded in
WasteLAN as the actual start date (Actual Start) of the Alternative Dispute Resolution action. The ADR Process
of "Mini-Trial" should also be entered.
~ NeutralEvaluation - A neutral party is selected to assist a negotiation team in evaluating the potential for settlement
or use of ADR professionals. The date on which the neutral party is selected is recorded in WasteLAN as the actual
start date (Actual Start) of the Alternative Dispute Resolution action. The ADR Process of "Neutral Evaluation"
should also be entered.
~ Settlement Judge - A settlement judge (other than the one hearing the case) is selected (or agreed upon) to act as a
mediator during the negotiation and settlement discussions of the parties. The date on which the settlement judge
is selected is recorded in WasteLAN as the actual start date (Actual Start) of the Alternative Dispute Resolution
action. The ADR Process of "Settlement Judge" should also be entered.
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
This is a Federal enforcement-lead (FE) action with an action name of "Alternative Dispute Resolution". The response
actions being discussed during the ADR process ("Response Actions Addressed") and the ADR Process may be entered
into WasteLAN. Credit will be based on the start date (Actual Start) of the ADR (Action Name = Alternative Dispute
Resolution). This is a program measure.
April 7, 2003
C-28
FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
w. NUMBER OF SETTLEMENTS WHERE EPA SETTLED BASED ON ABILITY-TO-
PAY DETERMINATIONS
Definition:
The measure will help assess the extent to which EPA is using ability-to-pay determinations to achieve its goal of
Enforcement Fairness. The measure will report the number of administrative or judicial settlements that are reached under
CERCLA with PRPs qualified as limited ability-to-pay parties. This type of settlement results in: (1) PRPs paying less
than their respective portion of the cost for site cleanup based on an ability-to-pay determination; (2) Payment overtime
for parties with limited ability to raise annual revenues; or (3) Parties providing in-kind service in lieu of cash payments.
Definition of Accomplishment:
Total ability-to-pay settlements are counted as follows:
When an AOC (Action Name = Admin Order on Consent) or Consent Agreement (CA) (Action Name = Consent
Agreement) with the ability-to-pay PRPs is signed by the Regional Administrator or delegatee and reported in
WasteLAN as the actual completion date (Actual Complete).
When the Regional Administrator signs the memorandum transmitting the CD (Action Name = Consent Decree)
signed by the ability-to-pay parties (and the Regional Administrator) to DO J or HQ as reported in WasteLAN as the
actual start date (Actual Start).
Changes in Definition FY02/03- FY04/05:
None.
Special Planning/Reporting Requirements:
This is a program measure. An Enforcement Instrument Categories Selected of "Ability to Pay" needs to be entered into
WasteLAN .
x. PROSPECTIVE PURCHASER AGREEMENTS (PPAs) -ASSESSED AND FINALIZED
Definition:
In January 2002, CERCLA was amended through enactment of Public Law 107-118, titled the Small Business Relief and
BrownfieldRevitalization Act ("Brownfields Amendments"). Among otherthings,theBrownfields Amendments provide
a limitation on liability for persons who qualify as bona fide prospective purchasers. Congress' intent in enacting this
provision was to remove certain liability barriers to purchases of property and encourage redevelopment. While EPA
believes the necessity for PPAs has been largely addressed by congressional action, the Agency recognizes that in limited
instances the public interest will be served by entering into PPAs or some other form of agreement. This measure,
therefore, will continue to report progress toward both the goals of enforcement fairness, and redevelopment of
contaminated properties in these limited instances. This measure will quantify the number of prospective purchaser
requests received and addressed by the Agency and the number of prospective purchaser agreements signed.
For the purpose of reporting, this measure will count:
1) The number of written requests (containing all necessary information required by EPA) for prospective purchaser
agreements received by the Agency.
2) The number of written requests (with all necessary information required by EPA) that the Agency has denied, or
the prospective purchasers have withdrawn.
3) The number of final proposed settlements sent to prospective purchasers for signature, in the form of
Administrative Orders on Consent (AOC), Consent Agreements (CA), or Consent Decrees (CD).
4) The number of finalized settlement agreements (AOCs, CAs, CDs) that include prospective purchaser provisions.
Change 1, FY 04/05 SPIM
C-29
September 22, 2003
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
Credit is given at non-Federal facility NPL, Superfund Alternative, and non-NPL sites:
Prospective Purchaser Requests Assessed: This is the point at which the Agency has completed its work towards
addressing a requestfor a prospective purchaser agreement, and the PPA request hasbeen received from the potential
or actual purchaser, with all necessary information required by EPA (Action Name = PPA Assessment and SubAction
Name = All Necessary Information Received by EPA and the Action Actual Start Date and SubAction Actual
Complete Date are entered into WasteLAN). The request has been assessed when the Agency denies the request, or
the prospective purchaser withdraws the request, or the Agency has written and forwarded a final proposed settlement
to the prospective purchaser for signature (Action Actual Complete with Action Qualifier = Request Denied or
W ithdrawal of Application by Requesting Party; or SubAction Name = Final Proposed Settlement Sentto Prospective
Purchaser and SubAction Actual Complete Date).
Prospective Purchaser Agreement: This is the completion of a PPA based on the date (Actual Complete) the
Administrative Order on Consent (AOC) or Consent Agreement (CA) (Action Name = Admin Order on Consent or
Consent Agreement) with a PPA component is signed by the Regional Administrator or delegatee or the date (Actual
Start) the CD (Action Name = Consent Decree) with a PPA component is referred by the Regional Administrator
or delegatee to either DOJ or E1Q. Regions also must enter the Enforcement Instrument Category to indicate a PPA
(Enforcement Instrument Categories Selected = Prospective Purchaser Agreement).
Changes in Definition FY02/03- FY04/05:
Changed PPA assessments and PPAs signed to program measures.
Special Planning/Reporting Requirements:
For each settlement, the region should enter the following information into WasteLAN: "Work PRP W illPerform - Value"
and/or "Federal Costs Settled - Future" and "Response Actions Pd by Parties;" and/or "Federal Costs Settled - Past",
"Response Actions Reimbursed", and/or "Other Relief Achieved" of "Other Activities for Cost Recovery"; and an
Enforcement Instrument Categories Selected of "Prospective Purchaser Agreement". The number of PPA assessments
and PPAs signed are program measures .
y. ISSUANCE OF COMFORT/STATVS LETTERS
Definition:
This measure supports EPA's Brownfields Program goals by facilitating the cleanup and reuse of previously used
properties. Parties interested in purchasing, developing, or operating these properties are provided information, upon
request, regarding the potential for EPA actions. Comfort/status letters, while providing some assurances, are intended
solely for informational purposes and only communicate EPA's intent with regard to enforcement orresponse authorities.
Comfort/status letters do not provide a release from CERCLA liability, and therefore, are not considered "no action
assurances." Any response to a solicitation for information on EPA's involvement or potential involvement/interest in
a property qualify as a comfort/status letter.
Definition of Accomplishment:
The start date (Actual Start Date) for this action is the date that a written request is received by the Agency for a
comfort/status letter from an interested party. If the comfort/status letter is a windfall lien or reasonable steps
comfort/status letter, Regions must indicate this in WasteLAN (Action Qualifier = W indfall Lien or Reasonable Steps).
A comfort/status letter is accomplished (Actual Complete Date) the day it is signed by the appropriate Regional Official.
September 22, 2003
C-30
Change 1,FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Changes in Definition FY02/03 - FY04/05:
Changed Definition to reflect the Small Business Liability Relief and Brownfields Revitalization Act. Added entry oftype
of comfort/status letter in WasteLAN.
Special Planning/Reporting Requirements:
This is a program measure. Regions should track the property/site specific issuance of comfort/status letters electronically
in WasteLAN. For each comfort/status letter that is a windfall lien or reasonable steps one, Regions should enter the
Action Qualifier of" Windfall Lien" or "Reasonable Steps" respectively into WasteLAN.
7, ORPHAN SHARE - EPA OFFER AND COMPENSA TION
Definition:
This measure reports on EPA efforts to compensate parties for the portion of the response costs attributable to
insolvent and defunct parties (orphan share).
This measure includes negotiations and settlements for RI/FS, RD/RA, time-critical (TC) or non time -critical (NTC)
removals, or appropriate cost recovery cases. This measure will report: 1) the number of negotiations where EPA offered
to compensate for a portion of the orphan share; 2) the Maximum Amount Appropriate for Compensation (MAAC) under
the 1996 Interim Guidance on Orphan Share Compensation for Settlors of Remedial Design/Remedial Action and Non-
Time-Critical Removals and the 1997 Cost Recovery Addendum (dated: September 30, 1997); 3) the actual amount of
compensation offered; 4) the number of settlements where EPA compensated for a portion of the orphan share; 5) the
actual dollar amount of the orphan share compensated by EPA; and 6) the actual date the region made the offer.
Orphan share compensation offers are subject to the adequacy of cleanup program funding, and eligibility requirements
under the policies. Orphan share compensation is not available at sites where there are no orphan parties, federal facilities,
sites where every PRP is liable as a current or former owner and/or operator and the region has not identified any
generator/transporter (i.e. "owner-operator only" sites), or sites where PRPs are performing work pursuant to a UAO,
unless such parties are willing to convert the UAO to a CD. All other sites are eligible sites for purposes of this measure
for work (i.e., Remedial Design/Remedial Action and Non-Time Critical Removal) negotiations atNPL sites. The method
for determining the appropriate compensation to be offered by EPA is provided in the "Interim Guidance on Orphan Share
Compensation for Settlors of Remedial Design/Remedial Action and Non-Time-Critical Removals" dated June 3, 1996
and the 1997 Cost Recovery Addendum (dated: September 30, 1997). The MAAC should not exceed the lesser of the
following ceilings: 1) the orphan share; 2) the sum of all EPA unreimbursed past costs and EPA's projected costs of
overseeing the design and implementation ofthe Record ofDecision (ROD) remedy, TC or NTC removal costs; or 3) 25
percent ofthe projected ROD remedy, TC or NTC removal costs at the site.
It should be noted that orphan share compensation at RI/FSs, time critical removals and non-NPL sites/Superfund
Alternative sites is discretionary under the 1996 Orphan Share Policy. Although Regions should offer orphan share
compensation during settlement negotiations for RD/RA and non-time critical removal actions at NPL sites, it is not
required to offer orphan share compensation at time critical removals and non-NPL sites/ Superfund Alternative sites.
Definition of Accomplishment:
Credit is given at eligible non-Federal facility non-owner/operator only NPL, Superfund Alternative, and non-NPL sites
for negotiations where EPA offered to compensate for a portion of the orphan share. In order to receive credit for orphan
share compensation in any case, at a minimum, the PRP must have been informed that part of the Federal compromise
at the site is attributable to orphan share. In negotiations for work, the PRP must be informed about the amount of the
Federal compromise attributable to orphan share under the MAAC analysis. Credit is given where EPA offered to
compensate for orphan share when:
Change 1, FY 04/05 SPIM
C-31
September 22, 2003
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OSWER Directive 9200.3-14-1G-Q
The General Notice Letter (GNL) (for removals), first Special Notice Letter (SNL), Letter for Orphan Share
Compensation (for on-going negotiations), orMemorandum for the Record for oral offers is signed by the appropriate
EPA official for the site or operable unit (OU). The Memorandum of Records for oral offers may be, for example,
a memorandum to the case file memorializing the oral offer. This date is reported in WasteLAN as the actual start
date (ActualStart) of negotiations [ActionName = RI/FS Negotiations, RD/RA Negotiations,RemovalNegotiations,
or Negotiations (Generic)] or the completion date (Actual Complete) of the Letter for Orphan Share Compensation
SubAction [SubAction Name = Letter for Orphan Share Compensation] or Memorandum for the Record SubAction
[SubAction Name = Memorandum for the Record]; or
~ A Section 122(a) waiver ofSNL signed by the appropriate EPA official with the intentto pursue negotiations without
moratorium procedures. This date is reported in WasteLAN as the actual start date (Actual Start) of negotiations
[Action Name = RI/FS Negotiations, RD/RA Negotiations, Negotiations (Generic), or Removal Negotiations]; or
~ A Demand Letter, Letter for Orphan Share Compensation (for on-going negotiations), or Memorandum for the
Record for oral offers for cost recovery signed by the appropriate EPA official is sent to the parties. This date is
reported in WasteLAN as the actual start date (Actual Start) of negotiations [Action Name = Cost Recovery
Negotiations] or the completion date (Actual Complete) of the Letter for Orphan Share Compensation SubAction
[SubAction Name = Letter for Orphan Share Compensation] or Memorandum for the Record SubAction [SubAction
Name = Memorandum for the Record],
Credit is given at eligible non-Federal facility on-owner/operator only NPL, Superfund Alternative, and non-NPL sites
where EPA compensated for a portion of the Orphan Share as follows:
A CD (ActionName = Consent Decree) and a 10-point settlement analysis for RD or RA is signed under Section 106,
106 and 107,104(a), 104(b), or for cost recovery only under Section 107. The date when the Regional Administrator
signs the memorandum transmitting the CD, signed by the parties and the Regional Administrator, to DO.T is reported
in WasteLAN as the actual start date (Actual Start); or
An AOC (ActionName = Admin Order on Consent) for RI/FS, a time-critical orNTC removal, or RD only is signed
by the Regional Administrator or delegatee. The date on which the AOC is signed is reported in WasteLAN as the
actual completion date (Actual Complete). For AOCs that are amended to include a time-critical or NTC removal,
or RD only, the SubAction "Enforcement Action Amended" and the SubAction actual completion date (Actual
Complete) must be entered into WasteLAN; or
An AOC or Consent Agreement (CA) (Action Name = Admin Order on Consent or Consent Agreement) for cost
recovery under Section 122(h) is signed by the Regional Administrator or delegatee. The date on which the AOC
or CA is signed is reported in WasteLAN as the actual completion date (Actual Complete). For AOCs or CAs that
are amended to include cost recovery, the SubAction "Enforcement Action Amended" and the SubAction actual
completion date (Actual Complete) must be entered into WasteLAN.
Changes in Definition FY02/03 - FY04/05:
Changed Orphan Share Compensation Offered to a program measure.
Special Planning/Reporting Requirements:
Orphan Share Compensation Offered ioxwork (i.e. Remedial Design/Remedial Action and Non-Time Critical Removal)
negotiations at NPL sites is a program measure. The program measure is to offer orphan share compensation at 100%
of eligible sites in work (i.e. Remedial Design/Remedial Action and Non-Time Critical Removal) negotiations at NPL
sites. In addition, Orphan Share Compensated is a program measure. The applicable "Response Actions Pd by Parties,"
must be entered into WasteLAN. Indicators on the existence of an orphan share at a site, including whether the orphan
share policy applies for work at a site, an orphan share compromise was offered or compensated by EPA, the MAAC and
ceiling type, the past and anticipated future costs offered and compensated by EPA will be entered into WasteLAN.
September 8, 2005
C-32
Change 7, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
(id. NON-EXEMPT DE MICROMIS PARTIES SETTLEMENTS AND NUMBER OF
PARTIES
Definition:
This measure reports the total number of administrative or judicial settlements that are reached solely under Section 122
of SARA, with PRPs qualified as non-exempt demicromis. It is rather unusual in that it measures success inversely. The
lower the number of non-exempt de micromis parties settlements, the more successful the Agency's non-exempt de
micro mis policy.
Definition of Accomplishment:
Non-exempt de micromis parties settlements at non-Federal facility NPL, Superfund Alternative, and non-NPL sites
include:
An AOC (Action Name = Admin Order on Consent) signed by the Regional Administrator or delegatee, as reported
in WasteLAN, as the actual completion date (Actual Complete).
When the Regional Administrator signs the memorandum transmitting the Consent Decree (Action Name = Consent
Decree), signed by the non-exempt de micromis parties and the Regional Administrator to DOJ or HQ, as reported
in WasteLAN, as the actual start date (Actual Start).
The number of signatories to the settlement is system generated in WasteLAN from the identification of the PRPs
associated with the settlement.
The following information should be entered into WasteLAN:
Enforcement Instrument Categories Selected of "Non-exempt De Micromis";
PRPs that signed settlement (Parties Associated with Action, Party Name).
To indicate the non-exempt de micromis parties that signed the settlement, the following information must be entered for
each party on the Involvement screen:
Basis of Liability of " Non-exempt De Micromis Party"; and
Involvement Type of "Generator" or "Transporter".
Changes in Definition FY02/03 - FY04/05:
Changed to non-exempt de micromis parties and settlements.
Special Planning/Reporting Requirements:
While EPA will enter into non-exempt de micromis parties settlements when extremely small volume contributor parties
are threatened with suit, the ultimate measure of success of this policy will be that non-exempt de micromis parties are
no longer pursued and there is no need to enter into such settlements (see above). This is a program measure.
The number of signatories to the settlement will be system generated from the identification of the parties associated with
the settlement.
Change 1, FY 04/05 SPIM
C-33
September 22, 2003
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OSWER Directive 9200.3-14-1G-Q
bb. PRP OVERSIGHT ADMINISTRATION
Definition:
Through the Superfund Reform on the Administration of PRP Oversight (OS), EPA recognizes the value of working
together with PRPs with whom the Agency has settlement agreements as a means to promote appropriate oversight that
ensures the development and implementation of protective cleanups; gives careful consideration to the associated costs
being charged to PRPs; and maximizes EPA recovery of oversight cost. This measure reports EPA's efforts to work with
PRPs to maximize the effectiveness and efficiency of EPA oversight and to send timely bills for oversight.
This measure applies to all PRPs at non-Federal facility NPL, Superfund Alternative, and non-NPL sites who:
~ Are conducting, under Federal oversight, the non-time-critical removal action (NTCRA), remedial
investigation/feasibility study (RI/FS), remedial design (RD), or remedial action (RA) phase of a cleanup, AND
Elave an Administrative Order on Consent (AOC), Consent Decree (CD), or other settlement document in place with
EPA that provides for payment of oversight costs.
Definition of Accomplishment:
The annual accomplishment target shall be based on the number of agreements (as described in 2 above) in place for RP-
lead events that will take place during the fiscal year. The regions will accomplish the following objectives for each PRP
or group of PRPs that has such an agreement and is required to pay oversight costs:
The date of the accomplishment for this target is the later of the dates documenting completion of each of the actions
below. Credit is given based on the date that:
An offer (personal contact is strongly encouraged) is made to PRPs to discuss EPA's oversight expectations for
upcoming activities. This date is reported in WasteLAN as the SubAction "Offer to Discuss EPA Oversight
Expectations w/ PRPs" actual completion date (Actual Complete); AND
An oversight bill consistent with the enforcement instrument is issued to PRPs or an accounting of costs is provided
to PRPs. This date is reported in WasteLAN as the SubAction "Issuance of Oversight Bill" or as "Accounting of
Oversight Co sts Incurred" actual completion date (A ctual C omp lete). If the settlement document is signed or referred
within the current fiscal year only the "Offer to discuss EPA Oversight Expectations with PRPs" subaction is
required.
Changes in Definition FY02/03 - FY04/05:
Removed reference to work planning process in Special Planning/Reporting Requirements since that information will
be provided in the annual Superfund Work Planning memorandum.
Special Planning/Reporting Requirements
This is a program target. For the purposes of this measure only, Headquarters shall assume, unless otherwise informed
by the regions, that PRPs that have entered into agreements with EPA will receive annual oversight bills unless the
settlement was entered into in the current fiscal year. In that event no bill is required; however, the region will be expected
to offer to meet with the PRPs to discuss oversight expectations. The regions will identify those actions for which PRPs
are required to pay oversight costs.
September 22, 2003
C-34
Change 1,FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
cc. SETTLEMENTS DESIGNATING DEPOSITS TO SPECIAL ACCOUNTS
Definition:
This measure will assess the extent to which EPA is able to direct the deposit of settlement funds into Special Accounts
under CERCLA Section 122(b)(3), in its efforts to increase fairness and promote PRP settlements. EPA is able to retain
and apply the interest from these accounts to clean up the site at which the settlement occurred. Funds deposited in
Special Accounts are immediately accessible for response costs, but may only be used to support response actions at the
site(s) covered by the settlement. Funds deposited into a Special Account may be the result of response costs achieved
under: de minimis, ability to pay, bankruptcy, cashout, Prospective Purchaser Agreement (PPAs), or other settlements.
For all CERCLA settlements where PRPs agree to make cash payments toward response costs at a site (i.e. cashout and/or
cost recovery settlements), the measure will report the following:
The total number of cashout and cost recovery settlements, and the estimated amount of response costs achieved from
those settlements;
The number of settlements which designate funds to Special Accounts for response co sts, and the percentage of these
settlements compared to the total number of cashout and cost recovery settlements; and
The amount of funds designated to Special Accounts by the settlement for response costs and the percentage of these
funds compared to the total amount of response costs achieved from all cashout and cost recovery settlements.
Definition of Accomplishment:
This measure counts any settlement where there is a payment provision where funds will be deposited in a Special
Account as follows:
An Administrative Order on Consent (AOC) or Consent Agreement (CA) (ActionName = Admin Order on Consent
or Consent Agreement) is signed that includes a payment provision, where funds will be placed in a special account.
The date on which the Regional Administrator or delegatee signs the AOC or CA is reported in WasteLAN as the
actual completion date (Actual Complete); or
A signed Consent Decree (CD) (Action Name = Consent Decree) referred to DO.T/E1Q under Section 106, 107, or
106 and 107 that includes a payment provision where funds will be placed in a Special Account. The date on which
the Regional Administrator signs the memorandum transmitting the CD, signed by the parties and the Regional
Administrator to DO.T or F1Q is reported in WasteLAN as the actual start date (Actual Start). For CD settlements that
are for cost recovery only and result from a previous litigation referral, regions should not add a CD start date (Actual
Start). Only the lodged (SubAction = Lodged by DO.T) and entered (SubAction name = Entered by Court)
SubActions, their actual completion dates (Actual Complete), and the actual completion date (Actual Complete) of
the CD will be recorded. The actual completion date of the CD is the date it is entered by the court. If the actual
completion date for the "Lodged by DO.T" SubAction exists, credit will be given in the FY identified by this
completion date.
Changes in Definition FY02/03 - FY04/05:
None.
Change 7, FY 04/05 SPIM
C-35
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
Special Planning/Reporting Requirements:
This is a program measure. Data that must be entered into WasteLAN for these settlements include:
~ Federal Costs Settled - Past (for Cost Recovery Settlements);
Federal Costs Settled - Future (for Cashout Settlements):
Enforcement Instrument Categories Selected of "Cashout" (for Cashout Settlements);
Response Actions Pd by Parties (for Cashout Settlements);
Deposit to EPA Special Account; and
~ Special Account Deposit Provision Flag.
dd DEPOSITS INTO SPECIAL ACCOUNTS
Definition:
This measure will report the amount of all actual deposits into Special Accounts. This measure will be used to answer
the question: Flow much money hasEPA deposited into Special Accounts for response actions at Superfund sites? Funds
deposited into a Special Account may be the result of response costs achieved under: de minimis, ability to pay,
bankrup tcy, cashout, Prospective Purchaser Agreement (PPAs), or other settlements. Funds deposited in Special Accounts
are immediately accessible for response costs at the site(s) covered by that Special Account. The source of the information
reported under this measure is periodic extraction of information from EPA's Integrated Financial Management System
(IFMS).
The measure will report the following:
For each site for that fiscal year, the total amount of actual deposits into Special Accounts; and
For each region for that fiscal year, the total amount of actual deposits into Special Accounts.
Definition of Accomplishment:
Regions transfer the funds to the Cincinnati Financial Management Center (CFMC) for deposit in the Special Account.
Deposit dates are recorded by CFMC in IFMS. CFMC extracts data from IFMS for tracking and reporting purposes. This
measure counts all deposits made at the time that Special Accounts are established and any subsequent deposits made to
these accounts as follows:
The date on which a Special Account is established by the CFMC with the initial deposit amount; and
~ The date on which any subsequent deposits are made by CFMC to existing Special Accounts.
Changes in Definition FY02/03 - FY04/05:
None.
September 22, 2003
C-36
Change 1,FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Special Planning/Reporting Requirements:
This is a program measure. Data that must be entered into IFMS includes:
Amount of deposits into Special Accounts; and
The date of deposits into Special Accounts.
ee. SETTLEMENTS DESIGNATING DISBURSEMENTS FROM SPECIAL ACCOUNTS
TO PRPS
Definition:
This measure will quantify the number of settlements in which EPA has agreed to disburse Special Account funds to PRPs
for response actions at the site where the Special Account funds were collected. Response actions can be removal or
remedial, under administrative or judicial settlements (under Agency guidance, Special Account funds are not available
to parties performing work under a UAO).
For all CERCLA settlements where PRPs agree to conduct response actions at the site for which the Special Account was
created, the measure will report the following:
The number of response settlements which designate disbursement from Special Accounts to PRPs who conduct the
response action; and
The amount of funds designated to be disbursed from Special Accounts to PRPs in response action settlements.
Definition of Accomplishment:
This measure counts all settlements where there is a provision for disbursement of Special Account funds to PRPs as
follows:
A signed Consent Decree (CD) (Action Name = Consent Decree) is referred to DO.T/HQ under Section 106 or 106
and 107 that includes a disbursement provision. The date on which the Regional Administrator signs the
memorandum transmitting the CD, signed by the parties and the Regional Administrator to DO.T or HQ is reported
in WasteLAN as the actual start date (Actual Start); or
An Administrative Order on Consent (AOC) or Consent Agreement (CA) (Action Name = Admin Order on Consent
or Consent Agreement) is signed that includes a disbursement provision. The date on which the Regional
Administrator or delegatee signs the AOC or CA is reported in WasteLAN as the actual completion date (Actual
Complete).
Changes in Definition FY02/03 - FY04/05:
None.
Special Planning/Reporting Requirements:
This is a program measure. Data that must be entered into WasteLAN for these settlements include:
Response Actions Pd by Parties;
W ork PRP W ill Perform - Value;
Paid from Special Account; and
Special Account Disbursement Provisions Flag.
Change 7, FY 04/05 SPIM
C-37
September 8, 2005
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OSWER Directive 9200.3-14-1G-Q
ff. DISBURSEMENTS FROM SPECIAL ACCOUNTS FOR RESPONSE ACTIONS
Definition:
This measure will assess the extent to which EPA uses Special Account funds for site cleanup by reporting the amount
of all actual disbursements from Special Accounts for response actions. This measure will be used to answer the question:
How much money has EPA disbursed from Special Accounts for response actions at Superfund sites? This measure will
capture disbursements to all recipients, whether for PRP-lead, State-lead, or EPA-lead response actions since Special
Account funds can be used to pay PRPs', States', and EPA's response costs .
This measure has sub-measures, which will report the amount of all actual disbursements from Special Accounts to PRPs,
EPA, and States for response actions. The PRP sub-measure will be used to answer the question: How much money has
EPA disbursed from Special Accounts to PRPs for response actions at Superfund sites? This sub-measure follows the
measure entitled, "SettlementsDesignating Disbursements from Special Accounts to PRPs." Together, these answer the
question: Of the amount designated in settlements to be disbursed to PRPs for response actions, what is the amount
actually disbursed to PRPs? This measure and this sub-measure will be used to answer the question: Of the total amount
disbursed from Special Accounts for response actions, what percentage is disbursed to PRPs? The State sub-measure will
be used to report the amount of money disbursed from Special Accounts to States for response actions at Superfund sites.
The EPA sub-measure will be used to report the amount of money disbursed from Special Accounts to EPA for response
actions at Superfund sites. The latter sub-measure will include amounts given to EPA which the Agency subsequently
sends to entities other than PRPs and States for response actions at Superfund sites.
The source of the information reported under this measure is periodic extraction of information from EPA's Integrated
Financial Management System (IFMS).
The measure will report the following:
For each site for that fiscal year, the total amount of actual disbursements from Special Accounts for response actions;
For each site for that fiscal year, the total amount of actual disbursements from Special Accounts to PRPs for response
actions;
For each site for that fiscal year, the total amount of actual disbursements from Special Accounts to States for
response actions;
For each site for that fiscal year, the total amount of actual disbursements from Special Accounts to EPA for response
actions;
For each region for that fiscal year, the total amount of actual disbursements from Special Accounts for response
actions;
For each region for that fiscal year, the total amount of actual disbursements from Special Accounts to PRPs for
response actions;
For each region for that fiscal year, the total amount of actual disbursements from Special Accounts to States for
response actions; and
For each region for that fiscal year, the total amount of actual disbursements from Special Accounts to EPA for
response actions.
September 22, 2003
C-38
Change 1,FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
Regions make disbursements from Special Accounts. Disbursements are recorded by the regions in IFMS. CFMC
extracts data from IFMS for tracking and reporting purposes. This measure counts all disbursements made from Special
Accounts for response actions as follows:
The date on which the region disburses funds from the Special Account as recorded in IFMS.
The three sub-measures count all disbursements from Special Accounts to PRPs, States, and EPA for response actions
as follows:
The date on which the region disburses funds to PRPs from Special Accounts as recorded in IFMS.
The date on which the region disburses funds to States from Special Accounts as recorded in IFMS.
The date on which the region disburses funds to EPA from Special Accounts as recorded in IFMS.
Changes in Definition FY02/03- FY04/05:
None.
Special Planning/Reporting Requirements:
This is a program measure. Data that must be entered into IFMS includes:
Actual disbursements from Special Accounts for response actions;
Actual disbursements from Special Accounts to PRPs for response actions;
Actual disbursements from Special Accounts to States for response actions;
Actual disbursements from Special Accounts to EPA for response actions (This sub-measure is derived by
subtracting the sum of the disbursements to PRPs and States from the disbursements from Special Accounts for
response actions.); and
The dates of disbursements from Special Accounts.
gg. CLOSURE OF SPECIAL ACCOUNTS
Definition:
This measure will report the closure of Special Accounts. This measure will be used to answer the question: Which
Special Accounts were closed in a fiscal year? How much money was transferred from the Special Account to the general
part of the Superfund Trust Fund? What are the dates of these closures? The source of the information reported under
this measure is periodic extraction of information from EPA's Integrated Financial Management System (IFMS).
The measure will report the following:
For each site at which a Special Account was closed for that fiscal year, the name of the site and the total amount of
money transferred to the general part of the Superfund Trust Fund.
For each region for that fiscal year, the total number of Special Accounts closed and the amount of money transferred
to the general part of the Superfund Trust Fund.
Change 1, FY 04/05 SPIM
C-39
September 22, 2003
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
Upon receipt of the signed memorandum requesting closure of a Special Account from the Regional Program
Office/Financial Management Officer, the Cincinnati Financial Management Center (CFMC) will close out the Special
Account and record the closeout date in IFMS. CFMC extracts data from IFMS for tracking and reporting purposes. This
measure counts all transfers made at the time that Special Accounts are closed as follows:
The date on which a Special Account is closed by the CFMC with the amount to be transferred to the general part
of the Superfund Trust Fund.
Changes in Definition from FY 02/03 - FY 04/05:
This is a new measure for FY 04/05.
Special Planning/Reporting Requirements:
This is a program measure. Data that must be entered into IFMS include:
Amount transferred from the Special Account; and
The date that the Special Account is closed with the amount to be transferred from Special Accounts to the
general part of Superfund Trust Fund.
hh. Pre-Remedial Enforcement Action at Superfund Sites
Definition:
This measure will support the Government Performance and Results Act (GPRA) goal of maximizing PRP participation
at Superfund sites, thus promoting "Enforcement First". The GPRA goal is for EPA to reach a settlement or take an
enforcement action by the time of the Remedial Action (RA) start at 90% of non-federal Superfund sites (with RA starts
during the fiscal year) that have known viable, liable parties. The objective of this measure is to take an enforcement
action or to reach a settlement with PRPs prior to an RA start1 at a site.
For purposes of GPRA reporting, this measure will count:
The number of PRP-financed RA starts (in the FY);
The number of Fund-financed RA starts (in the FY) with an enforcement action (i.e., Consent Decree (CD),
Administrative Order on Consent (AOC), Consent Agreement (CA), Unilateral Administrative Order (UAO) ,
voluntary cost recovery action, or litigation referral) at the site, prior to the Fund-financed RA start (in the FY).
The number of Fund-financed RA starts (in the FY) at sites with identified viable, liable Potential Responsible
Parties (PRPs), but no enforcement actions prior to a Fund-financed RA start (in the FY).
The GPRA accomplishment is the percentage resulting from the division of the numerator by the denominator as follows:
Numerator = The number of PRP-financed RA starts (in the FY) + the number of Fund-financed RA starts (in the
FY) with enforcement actions prior to the RA start.
1 As defined in Appendix B of the SPIM.
September 20, 2004
C-40
Change 4, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Denominator = The number of PRP-fmancedRA starts (in the FY) + Fund-financed R A starts (in the FY) with prior
enforcement actions at the site + Fund-financed RA starts (in the FY) with viable, liable PRPs, at the site, but no
enforcement actions prior to the RA start.
DISCLAIMER: Regions will receive credit in the management of the Superfund program for "start" of a remedial action
even though "initiation ofphy sical on-site construction" may not have occurred for purposes of calculating a cost recovery
statute of limitations. The date found in the remedial action actual start column of a CERCLIS/ WasteLAN 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.
Definition of Accomplishment:
This measure counts non-Federal facility NPL and PRP-financed Superfund Alternative sites with:
1. PRP-financed RA starts fin the FY) as defined in Appendix B.
2. Fund-financed RA starts fin the FY) with prior enforcement actions at the site: These are Fund- financed RA starts
as defined in Appendix B with enforcement actions at the site where the following dates of these actions are prior to
the start date of the Fund-financed RA:
+ Date (Actual Complete) that the AOC, CA or UAO (Action Name = Admin Order on Consent,
Consent Agreement, or Unilateral Admin Order) is signed by the Regional Administrator or
delegatee. This does not include orders that are for access or information only.
+ Date (Actual Start) that the CD settlements (Action Name = Consent Decree) is referred by the
Regional Administrator or delegatee to either DOJ or F1Q.
+ Date (Actual Complete) that the CD for cost recovery only and resulting from a previous
litigation referral is entered by the court. If the actual completion date for the Lodged
(SubAction Name = Lodged by DOJ) exists, that date will be used instead of the entered date.
+ Date (Actual Complete) that the Regional Office or DOJ receives payment from the PRPs in
direct response to a demand letter for voluntary cost recovery (Action Name = Admin/Voluntary
Cost Recovery).
+ Date (Actual Start) of the litigation referral (Action Name = Section 106 & 107 Litigation,
Litigation (Generic), Section 106 Litigation, or Section 107 Litigation).
3. Fund-financed RA starts (in the FY) with PRPs, at the site, but no enforcement actions prior to the RA start: These
are Fund-financed RA starts as defined in Appendix B with no enforcement actions at the site where the date of these
actions as specified in #2 above are prior to the start date of the RA, but have viable, liable PRPs designated at the
site (Parties Associated with Site, Noticed/Enf Act flag is set, and Not PRP Determination Made flag is not set).
Calculation of Accomplishment:
The numerator (the number of PRP-financed RA starts (in the FY) + Fund-financed RA starts (in the FY) with
enforcement actions prior to the RA start), is divided by the denominator (the number of PRP-financed RA starts (in
the FY) + Fund-financed RA starts (in the FY) with prior enforcement actions at the site + Fund-financed RA starts
(in the FY) with viable, liable PRPs, at the site, but no enforcement actions prior to the RA start), to arrive at the
GPRA percentage of RA starts with enforcement actions at sites with viable, liable PRPs.
[This measure will not include Fund-financed RAs at sites without enforcement actions prior to the RA start and
where PRPs have not been identified.]
Change 4, FY 04/05 SPIM
C-41
September 20, 2004
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OSWER Directive 9200.3-14-1G-Q
Changes in Definition from FY 02/03 - FY 04/05:
This is a new GPRA annual performance goal for FY 04.
Special Planning/Reporting Requirements:
This is a GPRA annual performance goal beginning in FY 04.
ii. WINDFALL LIEN FILED
Definition:
In January 2002, CERCLA was amended through enactment of Public Law 107-118, titled the Small Business Relief and
Brownfield Revitalization Act ("Brownfields Amendments"). Section 107(r) provides that bona fide prospective
purchasers are not liable as owner/operators for CERCLA response costs, but the property they purchase may be subject
to a windfall lien where an EPA response action has increased the fair market value of the property. This lien arises "at
the time at which costs are first incurred by the United States with respect to a response action at the facility." CERCLA
§ 107(r)(4)(B). To "perfect" the lien, EPA must file a notice of the lien in accordance with CERCLA's statutory
requirements. This measure will quantify the number of windfall liens that are filed by the Agency.
Definition of Accomplishment:
The start date (Actual Start Date) for the windfall lien (Action Name = 107(r) Windfall Lien) is the date the lien was filed
in the court by EPA in accordance with statutory requirements. The completion date (Actual Compete Date) is the date
the lien was removed by the court.
Changes in Definition FY02/03- FY04/05:
This is a new measure for FY 04.
Special Planning/Reporting Requirements:
This is a program measure.
.//. WINDFALL LIEN RESOLUTION - ASSESSED AND FINALIZED
Definition:
In January 2002, CERCLA was amended through enactment of Public Law 107-118, titled the Small Business Relief and
Brownfield Revitalization Act ("Brownfields Amendments"). Congress provided liability protection under CERCLA for
bona fide prospective purchasers to encourage the purchase and reuse of contaminated properties. EPA may enter into
a windfall lien resolution agreement with a purchaser if there is likely to be a significant windfall lien needing resolution.
This measure will quantify the number of windfall lien resolution requests received and addressed by the Agency and the
number of windfall lien resolution agreements signed.
For the purpose of reporting, this measure will count:
1) The number of written requests (containing all necessary information required) for windfall liens resolutions
received by the Agency.
2) The number of written requests (with all necessary information required) that the Agency has denied, or the "bona
fide prospective purchasers" have withdrawn.
3) The number of final proposed agreements sent to potential or actual purchasers for signature, in the form of
Consent Agreements (CA).
4) The number of finalized agreements (CAs) that include the windfall lien resolution provisions.
September 22, 2003
C-42
Change 1,FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
Credit is given at non-Federal facility NPL, Superfund Alternative, and non-NPL sites:
Windfall Liens Resolutions Assessed: This is the point at which the Agency has completed its work towards
addressing a request for a windfall lien resolution (WLR) agreement. The WLR request has been received from the
potential or actual purchaser, with all necessary information required (Action Name = Windfall Lien Assessment
and SubActionName = AllNecessary Information Received by EPA and the Action Actual StartDate and SubAction
Actual Complete Date are entered into WasteLAN). The request has been assessed when the Agency denies the
request, or the potential or actual purchaser withdraws the request, or the Agency has written and forwarded a final
proposed agreement to the potential or actual purchaser for signature (Action Actual Complete with Action Qualifier
= Request Denied, Withdrawal of Request by Requesting Party; or Final Proposed Agreement Sent to Purchaser).
Windfall Lien Resolution Agreement: This is the completion of a WLR Agreement based on the date (Actual
Complete Date) the Consent Agreement (CA) (Action Name = Consent Agreement) with a WLR component is
signed by the Regional Administrator or delegatee. Regions also must enter an Enforcement Instrument Category
to indicate a WLR Agreement (Enforcement Instrument Categories Selected = Windfall Lien Resolution Agreement).
Changes in Definition FY02/03- FY04/05:
This is a new measure for FY 04.
Special Planning/Reporting Requirements:
WLR assessments and agreements are program measures. For each agreement, the region should enter the following
information into WasteLAN: "Work PRP Will Perform - Value" and/or "Federal Costs Settled - Future" and "Response
Actions Pd by Parties;" and/or "Federal Costs Settled - Past", "Response Actions Reimbursed", and/or "Other Relief
Achieved" of "Other Activities for Cost Recovery"; and an Enforcement Instrument Categories Selected of "Windfall
Lien Resolution Agreement".
C.B SUBJECT MATTER EXPERTS
The following exhibit identifies the subject matter experts for Appendix C (Enforcement).
EXHIBIT C.2 SUBJECT MATTER EXPERTS
Subject Matter Expert
Subject Area
Phone #
Scott Blair
Enforcement Data
(202) 564-6023
Monica Gardner
Enforcement Data
(202) 564-6053
Amy Tuberson
Enforcement Data
(202) 564-5152
Change 7, FY 04/05 SPIM
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Superfiind Program Implementation Manual FY 04/05
Appendix D: Federal Facilities
FY 04/05 SPIM
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Appendix D
Federal Facilities
Table of Contents
D A. FEDERAL FACILITIES PRIORITIES I)-1
D.A.I Overview D-l
D.A.2 Superfund Federal Facility Goals and Priorities D-l
a. Strategic Federal Facility Goals D-l
D.A.3 RCRA Activities at Federal Facility NPL Sites D-3
D.A.4 BRAC Budget and Financial Guidance D-3
a. Resources and Tracking Mechanisms D-3
b. Accountability for Resources D-4
D.A.5 Federal Facility Site Discovery/Site Assessment D-5
a. Overview D-5
b. Federal Facility Site Discovery and the Federal Facility Docket Process D-5
c. Time Frames for Conducting Federal Facility Site Assessment D-5
d. Authority for Conducting Federal Facility Site Assessment - E.O. 12580 D-6
e. Federal Facility Site Assessment Reports & EPA Review and FIRS Evalutaion D-7
D.B. FACILITIES FY 04/05 TARGETS AND MEASURES D-8
D.B.I Overview of FY 04/05 Federal Facilities Targets and Measures D-8
a. Reporting of Non-NPL Federal Facilities Data D-8
D.B.2 Federal Facilities Site Discovery/Site Assessment Definitions D-ll
a. Site Discovery D-ll
b. Federal Facility Preliminary Assessment Reviews D-12
c. Federal Facility SI Reviews D-l3
d. Federal Facility ESI Reviews D-l4
D.B.3 Federal Facilities Definitions D-15
a. Base Closure Decisions D-15
b. Federal Facility Agreement (FFA)ZInteragency Agreement (IAG) D-16
c. Federal Facility Dispute Resolution D-17
d. Use of Supplemental Environmental Projects (SEPs) D-17
e. Remedial Investigation/Feasibility Study (RI/FS) or RCRA Facility
Investigation (RFI) Starts D-18
f. Timespan from Final NPL Listing to RI/FS or RFI Start D-18
g. Decision Documents D-19
h. Final Remedy Selected/Final ROD Authority D-19
i. Explanations of Significant Difference (ESD) and ROD Amendments D-20
j. Remedial Design D-21
k. Duration of ROD to IAG Negotiation Completion D-22
1. Remedial Action (RA) or RCRA Corrective Measure Implementation (CMI) Starts . . . D-22
m. Timespan from ROD Signature to RA Start D-23
n. RA or CMI Completions D-23
o. Removal or RCRA Interim/Stabilization Measure (ISM) Starts and Completions . . . D-27
p. NPL Site Construction Completions D-27
Change 5, FY 04/05 SPIM
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Appendix D
Federal Facilities
Table of Contents
(Continued)
q. Operation and Maintenance (O&M) D-30
r. Cleanup Goals Achieved D-30
s. Federal Facility Five-Year Reviews D-31
t. Federal Facility Partial NPL Deletion D-32
u. Federal Facility Final NPL Deletion D-33
D.B.4 Community Involvement Definitions D-34
a. Restoration Advisory Boards (RABs)/Site-Specific Advisory Boards (SSABs) D-34
b. Technical Assistance Grants (TAGs) this section is pending review by OGC and EPA
GRANTS D-34
c. Technical Outreach Services for Communities (TOSC) D-35
D C. SUBJECT MATTER EXPERTS D-35
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Appendix D
Federal Facilities
List of Exhibits
EXHIBIT D.l FEDERAL FACILITIES ACTIVITIES D-9
EXHIBIT D.2 REMEDIAL PIPELINE FLOW CHARTS D-26
EXHIBIT D.3 SUBJECT MATTER EXPERTS D-35
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APPENDIX D
FEDERAL FACILITIES PRIORITIES
D.A FEDERAL FACILITIES PRIORITIES
D.A.1 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 EPA's Superfund Federal facility response program. The FFLC
is comprised of Superfund and/or the Resource Conservation and Recovery Act (RCRA) program and
enforcement/counselrepresentatives from allregions, as well as representatives from the Federal facilities Headquarters
(HQ) offices and other HQ offices that handle Federal facility issues.
Federal agencies conducting the cleanups have seen their budgets level out or reduced over the last few years. The
FY 03 Department of Defense's (DoD) cleanup budget was $1.8 billion including work at Base Closing installations,
and the FY 03 Department of Energy's (DOE) environmental management budget was about $6.7 billion. Other Federal
agencies' budgets are considerably smaller. There are approximately 107 BRAC Installations where EPA supports the
DoD cleanup and transfer process. EPA's FY 03 BRAC funding request to DoD provides $8.6 million to fund 73.5 Full
Time Equivalent (FTE) positions.
D.A. 2 SUPERFUND FEDERAL FACILITY GOALS AND PRIORITIES
a. Strategic Federal Facility Goals
Superfund Federal facility activities have high visibility because of the significant threats posed by military and
weapons sites, the impact of military base closings, the resources needed to implement DoD/DOE cleanup efforts at
facilities listed on the NPL and other non-NPL facilities, and heightened State, Tribal and other stakeholder interests.
Federal facility program goals for FY 02/03 are based on a number of related factors, including overall Superfund
program goals, anticipated resource constraints, Congressional interest, and statutory requirements. Program activities
and resources should be planned to achieve the following goals of the Federal facility program's strategic plan:
Expediting Property Reuse - When installations are slated for closure or realignment, 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. 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
cleanup objectives, BRAC installations focus on efficient property transfer, providing beneficial reuse of the
property by the local community. At BRAC installations, both environmental restoration and property disposal
activities are carried out pursuant to environmental and Federal property management laws (Defense
Environmental Restoration Program (DERP), National Environmental Act, (NEPA), and CERCLA. Three
overarching principles guide expedited cleanup: 1) protect human health and the environment; 2) make
property available for reuse and transfer as soon as possible; and 3) provide for effective community
involvement. In an effort to ensure that cleanup is addressed in a systematic and safe manner, with the worst
sites remediated first, DoD developed the Relative-Risk Site Evaluation system. With revitalization being one
of OSWER's six priorities, property reuse is aGPRA initiative OSWER is currently establishing for the cleanup
program. The number of BRAC acres planned for transfer or lease, and the number of acres transferred or
leased are currently being tracked by DoD.
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Site Construction Completions - Regional efforts should be focused on getting to completion of
construction at Federal facilities whether they are accomplished under remedial or removal authority.
Meeting this goal will help build the Superfund program's credibility, which is vital to Superfund's long-
term success.
Involving Citizens in Environmental Decision Making - The publication of the Final Report of the Federal
Facilities Environmental Restoration Dialogue Committee 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) atDOE
facilities. Other Federal agencies are also starting to form 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, participation and support fornon-NPL facilities is expected to be minimal. In addition,
because many of the communities surrounding the F ederal facilities are communities of color, low-income, and
have been historically politically and economically disenfranchised, regions should give close scrutiny to
environmental justice issues at the NPL Federal facilities. 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.O. 12898).
Environmental Indicators - In addition to Construction Completions, Environmental Indicators (EI) provide
current site information regarding risk reduction at sites where cleanup is ongoing. It is important to focus on
EI data because it will ensure that those who monitor the Superfund program will be aware of progress at sites
where construction has not been completed.
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 greater citizen involvement, pollution
prevention, technology development, and natural resource management.
Environmental Management Systems and Pollution Reduction Targets - Executive Order 13148, Greening
the Government Through Leadership in Environmental Management, established a framework for integrating
environmental considerations into each Federal agency's mission through a variety of directives and goals,
including the implementation of environmental management systems, reductions in releases of toxic chemicals,
and elimination of procurement of ozone depleting substances. The E.O. requires that an EMS be implemented
at appropriate Federal facilities by the end of 2005, based on a facility's size, complexity, and environmental
aspects. Additionally, the E.O. requires Federal agencies to have a program in place to periodically audit
facilities' compliance with environmental regulations. Findings from those audits are to be included in the
budget and planning activities of the agency to ensure that non-compliance is adequately addressed.
Executive Order 13148 also call for further improvement in the Toxics Release Inventory (TRI) reduction
success achieved under a previous E.O. The E.O. requires a 40% reduction in reported Federal releases by
December 31, 2006, from a baseline year of 2001. Similarly, the E .O. reflects ongoing efforts to identify
substitute chemicals or processes to reduce environmental damage, risk and liability. The language in the
E.O. calls for development of a list of priority chemicals used by the Federal Government that may result in
significant harm to human health or the environment and that have known, readily available, less harmful
substitutes for identified applications and purposes. Agencies are directed to reduce the use of those
priority chemicals.
Regions should continue to strive to place these priorities and project milestones in enforceable Federal Facility
Agreements(FFAs)/Interagency Agreements (IAGs) at NPL sites. FFAs and IAGs should be viewed as living, dynamic
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documents reflecting not only the best judgments by all parties of cleanup priorities and milestones at the time of
agreement, but also that reflect the changing circumstances of environmental cleanup.
D.A.3 RCRA ACTIVITIES AT FEDERAL FACILITY NPL SITES
EPA has long recognized that because most of the Federal facility sites are also active facilities, RCRA requirements
may also apply to certain work management and site cleanup activities. Consistent with the Federal facility
RCRA/CERCLA coordination policy developed under the One Clean up Prog ram, regions must strive to eliminate
RCRA/CERCLA duplications wherever appropriate. To get abetter overall picture of a facility's cleanup activities,
FFRRO has integrated into the Government Performance and Results Act (GPRA) and program measures severalRCRA
activities that are generally analogous with CERCLA activities. They include: RCRA Facility Investigation (RFI);
Corrective Measures Study (CMS); Corrective Measure Design (CMD); Interim/Stabilization Measure (ISM); and
Corrective Measure Implementation (CMI), Human Exposures Under Control and Migration of Contaminated
Groundwater Under Control. FFEO has already accomplished a similar exercise through the Federal Facility Tracking
System.
D.A.4 BRAC BUDGET AND FINANCIAL GUIDANCE
a. Resources and Tracking Mechanisms
The primary mission of the BRAC program is to ensure that the hazardous waste sites owned or operated by the
Federal government are addressed and cleaned up as quickly as possible and made available to support the reuse of
properties. Regional efforts should be focused on achieving completion of cleanup construction activities at Federal
facilities whether they are accomplished under remedial or removal authority.
Under the Base Realignment and Closure Acts (BRAC) of 1988, 1991, 1993, and 1995, 490 military installations
were scheduled for closure or realignment. Of this total, 107 are covered through anMOU between EPA andDOD, and
of this total 33 BRAC sites are on the NPL. The remaining are classified as non-NPL sites which require some degree
of decontamination. The Agency continues to assist DoD in assessing these properties, accelerating cleanup actions
wherever possible, listing sites on the NPL when appropriate, and ensuring that remedies selected reflect the views of
the affected communities surrounding the sites and the proposed future reuse. HQ and Regional managers must work
with DoD, tribal, state, local governments, and private interests to expedite cleanup and support property transfer, reuse
and economic development.
Program management guidance is include din EPA's 1996 BRAC Fast Track guidance. Beginning inFY 1994, DoD
provided EPA, via an interagency funding agreement, with funding to support EPA's cleanup, property transfer and
public involvement activities. DoD, EPA, and the Office of Management and Budget (OMB) worked togetherto develop
the details of this agreement, which included 100 additional FTEs for EPA and $7 million starting in FY 1994. In early
FY 1996, EPA reached agreement with DoD to fund EPA support for BRAC 4 (1995) installations designated as Fast
Track Cleanup sites. As a result, interagency funding agreement for BRAC rounds I, II, III, and IV was assured through
FY 01. Although the program is ramping down, DoD is currently funding 62.0 BRAC reimbursable FTEs. EPA and
DOD finalized the FY 2002 EPA/DoD BRAC memorandum of understanding ensuring funding will be provided through
FY 2005 to EPA for its continued support at BRAC installations. EPA's participation in the BRAC program has
afforded DOD an estimated cost savings of $344M and 403 project years through FY 2001. BRAC has enabled EPA
to facilitate property reuse through expedited cleanup. The FY 2002 National Defense Authorization Act authorized a
new round of BRAC for 2005. EPA and DOD are currently working on a new memorandum of understanding to ensure
funding post-September 2005 when the current MOU expires, and it will include sites slated for closure in the next round
of BRAC.
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The majority of EPA's BRAC resources are directed to the regions for technical, regulatory and property transfer
oversight at BRAC installations. EPA uses Base Closure funding for EPA personnel to participate on BRAC Base
Cleanup Teams (BCT) as either the EPA designated team member or as technical experts. EPA Regional Federal Facility
programs, in conjunction with the Office of Regional Counsel, Regional NEPA teams, State environmental regulatory
agencies, and DoD, have formed a BCT for each of the BRAC installations. The BCT is comprised of one
representative from the EPA region, one representative from the State, and one representative from DoD. The BCT
serves as the primary forum in which issues affecting the execution of cleanup to facilitate reuse will be addressed. EPA
relies upon in-house expertise; no BRAC funds are used for contractor support. Contractor support is provided under
the Agency's Superfund Federal Facility response budget.
Regions are allocated work years and personnel, travel, and administrative funding based on negotiations between
EPA and DoD. The level of EPA support varies depending on regional and base specific circumstances.
The Agency monitors these DoD reimbursable resources via the Office of the Comptroller's (OC) Integrated
Financial Management System (IFMS), which tracks F1Q and regional expenditures separately for each BRAC round.
EPA utilizes site-specific charging to track resource utilization back to actual site work. This separate tracking of BRAC
round expenditures is required by BRAC legislation. EPA reports quarterly on their utilization to DoD and annually to
OMB. [OC, Financial Management Division (FMD), Cincinnati, Ohio invoices DoD on actual program obligations
incurred by EPA.]
F1Q receives regular program activity reports from the regional offices, on the progress of work at all BRAC
installations. These reports are generated by the EPA Regional BRAC Cleanup Team personnel and provide F1Q and
DoD with pertinent program information related to cleanup and reuse. FFRRO and the Cincinnati Finance Office use
MARS, IFMS, Business Objects and Financial 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.
b. Accountability for Resources
BRAC reimbursable work years and funding must be used only for EPA related Base Closure activities. Military
Base Closure activities are activities related to cleanup of specific installations identified by the Office of Solid Waste
and Emergency Response (O SWER) (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 (EBS), RI/FS, RODs, RD, andRAs] andRCRA documents (e.g., RFI Starts,
CMD Starts, and 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 participation in the BRAC program. These activities are outlined in the Memorandum of Understanding
between EPA and DoD dated February 3, 1994, 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 (AA 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 AA OSWER with programmatic and financial reviews of regions. Reprogramming of funds submitted to
the OC require notification of FFRRO for their approval.
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HQ and regional personnel utilizing BRAC resources should receive authorization from their appropriate regional
senior managers and use the established BRAC budget program. 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 CDR concurrence), who have in turn redelegated the
authorities to other levels 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.
Note: Additional specific BRAC information can be found in EPA's 1996 Fast Track Program Guidance.
D.A.5 FEDERAL FACILITY SITE DISCOVERY/SITE ASSESSMENT
a. Overview
The Federal Facility Site Discovery and Site Assessment Process is different from the non-Federal site process in at least
four aspects:
(1) The process for Federal facilities involves listing Federal facility sites on the EPA Federal Agency Flazardous
Waste Compliance Docket prior to conducting FF PAs;
(2) Time frames for completing site assessment activities;
(3) The authority for conducting Federal facility site assessments has been delegated to the Federal Agencies under
Executive Order 12580; and
(4) EPA is required to review Federal facility site assessment reports and evaluate such facilities in accordance with
the FIRS criteria.
b. Federal Facility Site Discovery and the Federal Facilities Docket Process
Section 120(c) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requires
EPA to establish a Federal Agency Flazardous Waste Compliance Docket which contains information reported to EPA
by Federal facilities that manage hazardous waste or have or may have released hazardous waste.
Section 120(d)(1) of CERCLA requires that EPA take steps to assure that a PA be conducted for each Federal facility
included on the published list of Federal facilities reported pursuant to Section 120(c) of CERCLA (the "Federal facilities
docket"). Section 120(d)(3) of CERCLA requires that such evaluation be completed within a reasonable schedule. The
PA is designed to provide information for EPA to consider when evaluating the site for potential listing on the National
Priorities List. Any potential site is usually first entered into CERCLIS as a Site Discovery. Subsequent to this entry,
the site is proposed as an addition to the Federal Docket11.
c. Time Frames for Conducting Federal Facility Site Assessments
SARA section 120(d) originally required that a preliminary assessment (PA) be performed at federal facility sites
within 18 months following placement on the docket, and listing on the National Priorities List (NPL) be completed
within 30 months, if appropriate. This time frame was amended by section 330 of the 1997 Defense Authorization
Act. The new language required that evaluation and listing be completed "in accordance with a reasonable schedule
established by the Administrator."
1 There may be instances when a facility included in the docket may not be listed in the CERCLIS database.
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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 Superfund s CERCLIS
hazardous waste site database. Potential budgeting issues of the 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 PA within 1 year of
discovering a non-federal facility site (inclusion on CERCLIS). However, the need of federal agencies to wait for
the next budget cycle to obtain funding may make the 1 year time frame problematic in many 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 submit completed PAs within 18
months from inclusion on the federal facility 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 4 years of CERCLIS
listing. EPA believes this is a reasonable time frame for making listing decisions at federal facility sites as well.
Following receipt of a PA, EPA typically evaluates the PA and determines if further work in the form of a Site
Inspection (SI) is necessary. If so, the federal facility then performs the SI and submits it to EPA. Then, EPA
evaluates the SI and determines if more information or sampling from the federal facility is needed. If it is, the
federal agency obtains the information and/or performs the sampling. In some cases, an expanded SI may be needed
to prepare an HRS package. Then, EPA prepares the HRS listing package, based on the data provided by the federal
facility, and formally proposes the site for NPL listing. Historically, it was extremely 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 for both the federal facility and EPA.
Thus, the appropriate federal agency should conduct a preliminary assessment within 18 months of placement of its
site on the Federal facility docket, and subsequent data should be provided to EPA to ensure a final listing decision
within four years of docket placement. 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 or a Site
Inspection (SI). The Presidenthas delegated this authority through Executive Order 12580 to the heads of the respective
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 in CERCLIS (see 40 CFR Part 300.420(b)
(1) and (c)(1)). Section 300.5 of the NCP defines "lead agency" generally to be the 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.
EPA must take steps to assure 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.
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e. Federal Facility Site Assessment Reports & EPA Review and HRS Evaluation
For Federal facilities, the Superfund site assessment process begins when the facility has been listed on the Federal
Agency Hazardous Waste Compliance Docket. When a Federal facility submits a PA report, or if warranted an SI
report, EPA evaluates the site in accordance with the Flazard Ranking System (FIRS) final rule22 to determine
whether the site poses a threat to human health and/or 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 "No Further Remedial Action Planned"
(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 the State or other Federal
agency. If the results of the SI or combined PA/SI indicate that the site warrants further investigation based on the
HRS evaluation, EPA will prepare an HRS scoring package to propose placing the site on the NPL. To make such
an NPL decision, EPA may collect further data to complete the HRS package.
FF Docket sites can be tracked through the Federal Facility docket screen in CERCLIS. The Federal Facility Docket
screen allows users to enter new Federal Facility Docket sites, select sites from the Federal Facility Docket universe,
and to manage site assessment activities (i.e., Federal facility Preliminary Assessment Review and Federal facility
Site Inspection review actions) at these sites. The Federal Facility Docket screen will assure that site assessment
activities are being or have been conducted for all Federal Facilities listed on the docket per CERCLA Section
120(d). For more in depth understanding of the site assessment process for Federal Facilities see the new Summary
Guide to Conducting PAs at Federal Facilities (2004) and the complete PA Guidance - Guidance for Performing
Preliminary Assessments Under CERCLA (1991)', and the new Federal Facilities SI Summary Guide (2004) and the
complete SI Guidance - Guidance for Performing Site Inspections Under CERCLA (1992), and Appendix A:
Statutory and Reglatorv Requirements Summary (2004) to the Summary Guides.
2Hazard Ranking System; Final Rule, 40 CFR Part 300, Appendix A, Federal Register, Vol. 55, No. 241, December
14, 1990.
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D.B. FEDERAL FACILITIES FY 04/05 TARGETS AND MEASURES
D.B.I OVERVIEW OF FY 04/05 FEDERAL FACILITIES TARGETS AND MEASURES
The Superfund Comprehensive Accomplishments Plan (SCAP) is used by the AA SWER, Assistant Administrator
forOECA (AA OECA), and senior Superfund managers to monitor the progress each region is making towards achieving
the Government Performance and Results Act (GPRA) targets and annual performance goals. In addition, SCAP will
continue to be used as an internal management tool to project and track activities that contribute to these GPRA goals
and support resource allocation. The program (regions and HQ) will set national goals based on historical performance
and performance expectations within a limited budget for the performance goals in GPRA and track accomplishments
in the activities contributing to those goals. Regions should continue to plan and report accomplishments in WasteLAN
as has been done traditionally.
To more clearly reflect the relationship between GPRA and the SCAP process, GPRA annual performance goals
and measures and program targets and measures are defined as follows:
GPRA Annual Performance Goals (APG) and GPRA Annual Performance Measures (APM) - The
Agency's Annual Plan describes the specific annual performance goals, annual measures of outputs and
outcomes, and activities aimed at achieving the performance goals that will be carried out during the year.
APGs are the specific activities that the Agency plans to conduct during the fiscal year in an effort towards
achieving its long-term strategic goals and objectives. APMs are used by managers to determine how well
a program or activity is doing in achieving milestones that have been set for the year. The annual performance
goals will inform Congress and Agency stakeholders of the expected level of achievement for the significant
activities covered by the GPRA objective. The goals are a subset of the overall planning and budgeting
information that has traditionally been tracked by the Superfund program offices.
Program Targets and Measures are activities deemed essential to tracking overall program progress.
Program targets are used to identify and track the number of actions that each region is expected to perform
during the year and to evaluate program progress. Program measures are used to show progress made in
achieving program priorities.
The following pages contain, in pipeline order, the definitions of the FY 04/05 Federal facilities targets and
measures. Exhibit D.l displays the full list of Federal facilities activities that are defined in the remainder of the
Appendix, and identifies the FY 04/05 targets and measures. Exhibit D.3, at the end of this Appendix, describes the
planning requirements for Federal facilities activities.
a. Reporting of Non-NPL Federal Facilities Data
Regions are responsible for entering data into WasteLAN for Non-NPL Federal facility sites, especially theBRAC
Sites.
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EXHIBIT D.l (1 of 3)
FEDERAL FACILITIES NPL SITES
ACTIVITY
GPRA
PROGRAM
APG
APM
Target
Measure
Site Discovery
Federal Facility Preliminary Assessment Reviews
Federal Facility SI Reviews
Federal Facility ESI Reviews
Base Closure Start (if applicable)
Base Closure Completion (if applicable)
Federal Facility Agreement (FFA)/Interagency Agreement (IAG)
Federal Facility Dispute Resolution
Use of Supplemental Environmental Projects (SEPs)
RI/FS or RCRA Facility Investigation (RFI) Starts
Final NPL Listing to RI/FS Start
Decision Documents
Final Remedy Selected/Final ROD Authority
ESD or ROD Amendment
Remedial Design
Duration of ROD to IAG Completion
RA or Corrective Measure Implementation (CMI) Starts
Timespan from ROD Signature to RA Start
RA or CMI Completion
Removal or RCRA Interim/Stabilization Measure (ISM) Starts
Removal or RCRA Interim/Stabilization Measure (ISM)
Completions
NPL Site Construction Completions
Operation and Maintenance (O&M)
Cleanup Goals Achieved
Federal Facility Five-Year Reviews
Federal Facility Partial NPL Deletion
Federal Facility Final NPL Deletion
Restoration Advisory Boards (RABs)/Site-Specific Advisory Boards
(SSABs)
Technical Assistance Grants (TAGs)
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NOTE: Accomplishments are pulled from WasteLAN on a bi-annual basis.
EXHIBIT D.l (2 of 3)
FEDERAL FACILITIES BRAC SITES
ACTIVITY
GPRA
PROGRAM
APG
APM
Target
Measure
Site Discovery
/~
Federal Facility Preliminary Assessment Reviews
/~
Federal Facility SI Reviews
/~
Federal Facility ESI Reviews
/~
Base Closure Decision Starts (if applicable)
/~
Base Closure Decision Completions (if applicable)
/~
RI/FS Start or RCRA Facility Investigation (RFI) Starts
/~
Decision Documents
/~
Final Remedy Selected/Final ROD Authority
/~
ESD or ROD Amendment
Remedial Design
RA or Corrective Measure Implementation (CM!) Starts
RA or CM! Completion
Removal or RCRA Interim/Stabilization Measure (ISM) Starts
Removal or RCRA Interim/Stabilization Measure (ISM)
Completions
/~
NPL Site Construction Completions (if on NPL)
Operation and Maintenance (O&M) (if applicable)
Federal Facility Five-Year Reviews (if applicable)
Federal Facility Partial NPL Deletion (if applicable)
Federal Facility Final NPL Deletion (if applicable)
Restoration Advisory Boards (RABs)/Site-Specific Advisory
Boards (SSABs)
Technical Assistance Grants (TAGs)
/~
Technical Outreach Support for Communities (TOSC)
/~
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EXHIBIT D.l (3 of 3)
FEDERAL FACILITIES NON-NPL SITES
ACTIVITY
GPRA
PROGRAM
APG
APM
Target
Measure
RA or Corrective Measure Implementation (CMI) Starts
/~
RA or CMI Completion
/~
Removal or RCRA Interim/Stabilization Measure (ISM) Starts
/~
Removal or RCRA Interim/Stabilization Measure (ISM)
Completions
Restoration Advisory Boards (RABs)/Site-Specific Advisory
Boards (SSABs)
Technical Outreach Support for Communities (TOSC)
/~
NOTE: Definitions apply to all site categories.
D.B.2 FEDERAL FACILITIES SITE DISCOVERY/SITE ASSESSMENT DEFINITIONS
a. SITE DISCOVERY
Definition:
Site discovery is the process by which a potential hazardous waste site is entered into the CERCLIS inventory for NPL
assessment activities. The process 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
CERCLIS database.
All sites moving through the NPL assessment process must have a Discovery action and actual completion date
documented in WasteLAN. Entry of the site discovery date initiates the NPL assessment process and places the site on
the FF Preliminary Assessment Review backlog.
Definition of Accomplishment:
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 to the Federal Flazardous Waste Compliance Docket. The Site Name and Discovery
Date must be entered into WasteLAN for sites. Valid leads for site discovery actions include: "Fund-Financed (F)";
"EPA-In Flouse (EP)"; "State (S)", "Tribal (TR)"; and "Federal Facility (FF)."
Changes in Definition FY 02/03 - FY 04/05:
This measure has been modified to reflect FF sites only.
Special Planning/Reporting Requirements:
Actual start and planning dates are not required for the Discovery action. The Discovery date is entered through the Add
Site screen. The Discovery date will automatically populate the actual completion date for the Discovery action.
Regions are now required to enter information on site type at the time of discovery on the Add Site or Site
Discovery/Initiation screen. Multiple discovery actions are not allowed. Site discovery is a program measure.
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Note: A separate field has been added to WasteLAN to record site initiation dates for removal-only sites. Sites that are
subject only to removal interest generally do not require a discovery date. An exception is where a large scale removal
action has been completed and the region seeks credit for a non-NPL site completion. Non-NPL site completions require
site assessment review indicating the site has no further remedial actions planned. The discovery date for sites referred
from removal to 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
b. FEDERAL FACILITY PRELIMINARY ASSESSMENT REVIEWS
Definition:
Federal Facility Preliminary Assessment 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. Upon reviewing the PA or PA-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 PA Review backlog consists of Federal facility sites with a Non-NPL Status of "FF-PA review
needed" or "FF-PA review ongoing."
Definition of Accomplishment:
Federal Facility PA Review Starts - A Federal Facility PA Review (Action Name = Federal Facility Preliminary
Assessment Review) is started when the EPA starts an in-house review of the Federal facility PA or PA-equivalent, and
WasteLAN contains the actual PA start date (Actual Start) and a valid action lead of "Fund-Financed (F)"; "EPA-In
Flouse (EP)".
Federal Facility PA Revietv Completions - A Federal Facility PA Review (Action Name = Federal Facility Preliminary
Assessment Review ) is completed when:
The appropriate Regional official signs a letter, form, ormemo approving the PA report. The Federal Facility
Preliminary Assessment Review actual completion date is the date the Federal facility PA report is approved;
WasteLAN contains the actual Federal Facility Preliminary Assessment Review completion date (Actual
Complete) a 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 WasteLAN or an equivalent
document. The decision document must be printed, signed by the appropriate Regional official, and placed
in the file.
A valid decision must be recorded in WasteLAN upon completion of a Federal facility PA Review. Please refer to
Exhibit A.2 in section A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
State and Tribal leads were deleted as valid leads for this action.
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Special Planning/Reporting Requirements:
Regions should attempt to complete PA reviews at Federal facility sites listed in the CERCLIS inventory within a
reasonable schedule upon receipt of a sufficient PA. PA review starts and completions are reported site-specifically in
WasteLAN. Federal Facility Preliminary Assessment Review starts and completions are program measures.
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 (SubAction Name = Referred back to Fed Fac). The date the report is referred back to the
Federal facility is entered into WasteLAN as the actual completion date (Actual Complete) of the SubAction, 'Referred
back to Fed Fac'. The actual completion date and qualifier for the Federal Facility Preliminary Assessment 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
c. FEDERAL FACILITY SI REVIEWS
Definition:
Federal Facility Site Inspection Review is a quality assurance review of a 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. Upon reviewing the SI or Si-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 SI Review backlog consists of sites with a Non-NPL Status of "FF-SI review needed" or "FF-SI
review ongoing."
Definition of Accomplishment:
Federal Facility SI Review Starts - A Federal Facility SI Review (Action Name = Federal Facility Site Inspecation
Review) is started when the EPA starts an in-house review of the Federal facility SI or Si-equivalent, and WasteLAN
contains the actual SI start date (Actual Start) and a valid action lead of "Fund-Financed (F)"; "EPA-In House (EP)".
Federal Facility SI Review Completions -A Federal Facility SI Review (Action Name = Federal Facility Site Inspection
Review ) is completed when:
The appropriate Regional official signs a letter, form, or memo approving the SI report. The Federal Facility
Site Inspection Review actual completion date is the date the Federal facility SI report is approved;
~ WasteLAN contains the actual Federal Facility Site Inspection Review completion date (Actual Complete)
a 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 WasteLAN or an equivalent
document. The decision document must be printed, signed by the appropriate Regional official, and placed
in the file.
A valid decision must be recorded in W asteLAN upon completion of a Federal facility SI Review. Please refer to Exhibit
A.2 in section A. A. 5 for a list of valid qualifiers for this action and a description of each qualifier.
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Changes in Definition FY 02/03 - FY 04/05:
State and Tribal leads were deleted as valid leads for this action.
Special Planning/Reporting Requirements:
Regions should attempt to complete SI reviews at Federal facility sites listed in the CERCLIS inventory within a
reasonable schedule upon receipt of a sufficient SI. SI review starts and completions are reported site-specifically in
WasteLAN. Federal Facility Site Inspection Review starts and completions are program measures.
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 (SubAction Name = Referred back to Fed Fac). The date the report is referred back to the
Federal facility is entered into WasteLAN as the actual completion date (Actual Complete) of the SubAction, 'Referred
back to Fed Fac'. The actual completion 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new value
for this field based on the traditional sequence of site assessment work. Regions must confirm or change this value as
appropriate.
(I. FEDERAL FACILITY ESI REVIEWS
Definition:
Federal Facility Expanded Site Inspection Review is a quality assurance review of a ESI or ESI-equivalent report
submitted by another Federal Agency. EPA's role at 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."
Definition of Accomplishment:
Federal Facility ESI Review Starts - A Federal Facility ESI Review (Action Name = Federal Facility ESI Review) is
started when the EPA starts an in-house review of the Federal facility ESI or ESI-equivalent, and WasteLAN contains
the actual ESI start date (Actual Start) and a valid action lead of "Fund-Financed (F)"; "EPA-In House (EP)".
Federal Facility ESI Review Completions - A Federal Facility ESI Review (Action Name = Federal Facility ESI
Review) is completed when:
The appropriate Regional official signs a letter, form, or memo approving the ESI report. The Federal
Facility Expanded Site Inspection Review actual completion date is the date the Federal facility ESI report
is approved;
~ WasteLAN contains the actual Federal Facility Expanded Site Inspection Review completion date (Actual
Complete) a 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 WasteLAN or an equivalent
document. The decision document must be printed, signed by the appropriate Regional official, and placed
in the file.
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A valid decision must be recorded in WasteLAN upon completion of a Federal facility ESI Review. Please refer to
Exhibit A.2 in section A.A.5 for a list of valid qualifiers for this action and a description of each qualifier.
Changes in Definition FY 02/03 - FY 04/05:
State and Tribal leads were deleted as valid leads for this action.
Special Planning/Reporting Requirements:
Regions should attempt to complete ESI reviews at Federal facility sites listed in the CERCLIS inventory within a
reasonable schedule upon receipt of a sufficient ESI. ESI review starts and completions are reported site-specifically
in WasteLAN. Federal Facility Expanded Site Inspection Review starts and completions are program measures.
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 (SubAction Name = Referred back to Fed Fac). The date the report is referred back
to the Federal facility is entered into WasteLAN as the actual completion date (Actual Complete) of the SubAction,
'Referred back to Fed Fac'. 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 CERCLIS
inventory. As new actions and new dates are entered into WasteLAN, the system automatically calculates a new
value for this field based on the traditional sequence of site assessment work. Regions must confirm or change this
value as appropriate.
1X113 FEDERAL FACILITIES DEFINITIONS
a. BASE CLOSURE DECISIONS: START AND COMPLETIONS
Definition:
A base closure action occurs when EPA is involved in either a CERFA Section 120(h)(4) uncontaminated parcel
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 Operating Properly and Successfully (OPS) at BRAC locations pursuant to
CERFA/CERCLA Section 120(h)(3). Under CERFA/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 Section 120(h)
of CERCLA. A FOSL documents that property at a BRAC location is environmentally suitable for 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; and, 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.
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Definition of Accomplishment:
Base Closure Decision Start Date: Date that a document is received by EPA that identifies a facility or a parcel as a
candidate to be transferred by deed or lease (e.g., EBS submitted); or a clean parcel determination is received by EPA
for concurrence as required by CERFA; or the date of the written request submitted by the other Federal agency for
concurrence on suitability to transfer or lease; or the date on which a written request for EPA concurrence is received
that a 120(h)(3) remedy is operating properly and successfully.
Base Closure Decision Completion Date: The date the appropriate Regional official signs a letter, form, or memo stating
that EPA has completed its review and provided comments or concurrence on the FOST or FOSL; or the date the
appropriate Regional official signs a 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); or the
date the appropriate Regional official signs a letter concurring on a clean parcel identified under CERFA. In addition
to entering the date of completion, also enter the acreage covered by the Base Closure Decision Document.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
Base Closure Completions is a GPRA measure. Base Closure Starts is a program measure. Regions may enter acreage
information through the FOST or FOSL screen in WasteLAN.
b. FEDERAL FACILITY AGREEMENT (FFA)/INTERAGENCY AGREEMENT (IAG)
Definition:
FFAs/IAGs are legal agreements between Federal agencies responsible for cleanup, EPA, and the States. A State may
elect not to participate in FFA/IAG negotiations. FFA/IAGs set forth detailed requirements for performance of site
response activities as well as appropriate enforcement responses to non-compliance with the FFA/IAG. The FFA/IAG
requirement is set forth in Section 120(e) of CERCLA. They are required at NPL facilities no later than 6 months after
the first ROD is signed at the facility.
Definition of Accomplishment:
FFA/IAG Start Date: Date notice letteris sent by EPA to the Federal facility, reported in WasteLAN as the actual start
date (Actual Start) of FFA/IAG negotiations (Action Name = IAG Negotiation).
FFA/IAG Completion Date: Latter of the dates that the Federal agency, EPA, and/or State sign the IAG, or the date
the Letter of Intent to sign an IAG is signed by all parties. This date must be reported in WasteLAN as the actual
completion date (Actual Complete) of the FFA/IAG (Action Name = Federal Interagency Agreements).
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
FFA/IAG starts will be tracked as IAG negotiations (Action Name = IAG Negotiation). FFA/IAG completions will be
tracked as the completion (Actual Complete) of the FFA/IAG (Action Name = Federal Interagency Agreement). For
those FFAs/IAGs that are elevated for dispute resolution, record the date elevated as the actual completion date of the
SubAction "IAG Dispute Admin Referral" and not as the FFA/IAG completion date. Regions do not receive credit for
FFA/IAG completion when the FFA/IAG is elevated to HQ for dispute resolution. This is a Program Measure.
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c. FEDERAL FACILITY DISPUTE RESOLUTION
Definition:
When the Federal agency, State, and/or EPA make an effort to formally or informally resolve a FFA/IAG dispute after
the FFA/IAG is signed.
Definition of Accomplishment:
Dispute Resolution Start Date: Date that any party to the FFA/IAG sends a letter to the other parties notifying them as
to the issue in dispute. This is reported in W asteLAN as the actual start date (Actual Start) of dispute resolution (Action
Name = Alternative Dispute Resolution).
Dispute Resolution Completion Date: Date the document resolving the issue is signed (e.g., letter of agreement,
agreement document). This is reported in WasteLAN as the actual completion date (Actual complete) of dispute
resolution (Action Name = Alternative Dispute Resolution).
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
Federal Facility Dispute Resolution is reported in WasteLAN as Alternative Dispute Resolution (Action Name =
Alternative Dispute Resolution) with a Federal facility (FF) lead. This is a program measure.
(I. USE OF SUPPLEMENTAL ENVIRONMENTAL PROJECTS (SEPs)
Definition:
SEPs are environmentally beneficial projects which a Federal agency agrees to undertake to mitigate a monetary penalty,
but which the violator is not otherwise legally required to perform. The SEP could be for public health, pollution
prevention, pollution reduction, environmental restoration and protection, assessments and audits, environmental
compliance promotion, emergency planning and preparedness, or other pro gram-specific projects.
Definition of Accomplishment:
The date of agreement between EPA and Federal agency to implement a SEP is reported in WasteLAN as the SubAction
"Supplemental Envir Projects". The estimated dollar value of the SEP must also be entered.
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
This is a program measure. Both the number of SEPs and their estimated value will be tracked. The estimated value
of the SEP is reported on the Penalty/SEP screen in the Federal Facilities module in WasteLAN.
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e. REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS) OR RCRA FACILITY
INVESTIGATION (RFI) STARTS
Definition:
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
Interim/Stabilization Measure (ISM).
Definition of Accomplishment:
The RI/FS (Action Name = FF RI/FS or FF RI) or RFI (Action Name = RCRA Facility Investigation) start is defined
as follows:
Sites where there has been no RI/FS or RFI work started prior to the effective date of the FFA/IAG, the actual
start date (Actual Start) is the EPA or State receipt of a draft work plan for the RI/FS or RFI; or
Sites where RI/FS or RFI work has been started prior to the FFA/IAG 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), the actual start date (Actual Start) is also the date of receipt of a draft RI/FS or
RFI work plan (Note: this date will be prior to IAG completion date); or
~ Sites where RI/FS or RFI work starts prior to the FFA/IAG effective date and there has been limited EPA or
State involvement, the date of the RI/FS or RFI actual start date (Actual Start) is the latter date that EPA or
the State and the other agency sign the FFA/IAG.
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
This is a program measure.
f. TIMESPAN FROM FINAL NPL LISTING TO RI/FS
Definition:
Superfund Amendments and Reauthorization Act (SARA) Section 120(e) states "not
inclusion of any facility on the NPL, the department, agency, or instrumentality shall
facility." This measure calculates the days and the time frame from final NPL Listing to
time frames greater that 180 days will be deemed not to have met this requirement.
Definition of Accomplishment:
This measure will calculate, by site, the interval between final NPL listing (publication of final listing in the Federal
Register) and the actual date for the first RI/FS start. The timespan will be calculated based on the RI/FS start definition
outlined above and the final NPL listing (Action Name = Final Listing on NPL) actual completion date (Actual
Complete).
Changes in Definition FY 02/03 - FY 04/05:
None.
later than six months after the
... commence a RI/FS for such
the first RI/F S start. Sites with
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Special Planning/Reporting Requirements:
This is a GPRA APM reporting measure. Data in WasteLAN will be used to calculate the timespan on an annual basis.
HQ will perform the analysis at the end of the fiscal year.
g. DECISION DOCUMENTS
Definition:
Upon completion ofa Federal facility RI/FS, CMS, 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
Difference (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.
Definition of Accomplishment:
Date (Actual Complete) the ROD (Action Name = Record of Decision), the appropriate RCRA Statement of
Basis/Response to Comments (ActionName = RCRA SB/RTC), Action Memo (Action Name = Approval of Action
Memo), Removal Action Decision Document (Action Name = Removal Action Decision Doc), ROD Amendment
(ActionName = Record of Decision and SubActionName = ROD Amendment) or Explanation of Significant Difference
(ActionName = Record of Decision and SubAction Name = Explanation of Significant Diff) or is signed by the Regional
Administrator or delegatee, or the date of EPA concurrence/approval on the clean-up decision document pursuant to
FFA/IAG or other enforceable decision document, or the date of EPA's letter of concurrence.
Changes in Definition FY 02/03 - FY 04/05:
Removal Action Decision Document, ROD Amendment and Explanation of Significant Difference completion dates
have been added to the accomplishment definition.
Special Planning/Reporting Requirements:
The ROD Completion date is the same as the RI/FS completion date. The EE/CA completion date is the same as the
Action memo or Removal Action Decision Document completion date. The date of the RCRA Corrective Measure
Decision document is the CMS Completion date. This is a program target.
h. Final Remedy Selected/Final ROD Authority
Definition:
This measure will track the Government Performance and Results Act (GPRA) Final Remedy Selected at NPL Sites.
Final Remedy Selected documents will also be tracked in CERCLIS for non-NPL sites but will not count towards
the GPRA goal. 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 for a site). This can include the signature of the final ROD, ROD Amendment or
Removal Action at a site. Sites which are Construction Complete or sites deleted from the NPL may also be eligible
for a Final Remedy Determination. In general, Explanation of Significant Difference will not constitute a Final
Remedy Selected since that documents 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.
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Definition of Accomplishment:
Credit under CERCLA for a Final Remedy Selected is received when:
A site has a Final ROD or ROD Amendment and no existing planned ROD, ROD Amendment, Removal
Action Memorandum, RI/FS orEE/CA. The date the designated Regional Official or the AA OSWER
signs the ROD at a site for each RA is reported in WasteLAN as the ROD (Action Name = Record of
Decision) completion date (Actual Complete); or
Site has a Removal Action Memorandum and no existing planned ROD, RI/FS, EE/CA or planned action
memorandum.
Site is Construction Complete as documented by the actual completion date (Actual Complete) of the
Preliminary Close-Out Report (Action Name = Prelim Close-Out (PCOR) Rep Prepared), or the actual
completion date (Actual Complete) of the Final Close-Out Report (Action Name = Close-Out Report) and
F1Q has entered the Construction Completion indicator in WasteLAN and no future ROD, ROD
Amendment, Action Memorandum, RI/FS or EE/CA is planned. (The Final Remedy Selected
designation may only be applied to the PCOR if there is no previous ROD, ROD Amendment, or Action
Memorandum that constitutes the Final decision.)
Site has been deleted from the NPL (Action Name = Final Deletion from NPL), which is documented
when the Notice of Deletion is published in the Federal Register and no future ROD, ROD Amendment,
Action Memorandum, RI/SF or EE/CA is planned. (The Final Remedy Selected designation may be
applied to the Final Notice of Deletion if there is no PCOR and if there is no previous ROD, ROD
Amendment or Action Memorandum that constitutes the Final decision.)
Changes in Definition FY02/03 - FY04/05:
This is a new measure for FY 04.
Special Planning/Reporting Requirements:
This is a GPRA measure.
i. EXPLANA TIONS OF SIGNIFICANT DIFFERENCE (ESD) AND ROD
AMENDMENTS
Definition:
An Explanation of Significant Difference (ESD) documents significant changes to a Record of Decision (ROD).
Significant changes generally involve a change to a component of a remedy that does not fundamentally alter the overall
cleanup approach. 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.
Definition of Accomplishment:
Explanation of Significant Difference: The Date (Actual Complete) the ESD (Action Name = Record of Decision and
SubAction Name = Explanation of Significant Diff) is signed by the Regional Administrator or delegate, or the date of
EPA concurrence/approval on the clean-up decision document pursuant to FFA/IAG or other enforceable decision
document, or the date of EPA's letter of concurrence.
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ROD Amendment: The date (Actual Complete) the ROD Amendment (Action Name = Record of Decision and
SubAction Name = ROD Amendment) is signed by the Regional Administrator of delegate, or the date of EPA
concurrence/approval on the cleanup decision document pursuant to FFA/IAG or other enforceable decision document,
or the date of EPA's letter of concurrence.
Changes in Definition FY 02/03 - FY 04/05:
This is a new Program Measure
Special Planning/Reporting Requirements:
This is a Program Measure but also counts towards the Program Target for Decision Documents.
j. REMEDIAL DESIGN
Definition:
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 CMC 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.
Definition of Accomplishment:
RD Start - If post-ROD, the RD (Action Name = FF RD) or CMD (Action Name = Corrective Measure Design) start
date (Actual Start) is the date of submission of the RD or CMD work plan or other appropriate documents or statement
of work . If work begins prior to the ROD, the RD or CMD actual start date (Actual Start) will be the ROD signature
date or submission date of RD or CMD work plan or any other major deliverable (e.g., 30% design complete).
RD Completion - RDs and CMDs are considered complete the date a letter is signed by the appropriate Regional official
approving the entire final RD or CMD package. If EPA does not approve the final RD or CMD package, the RD or
CMD is considered complete the date of the Commerce Business Daily (CBD) or other appropriate publication
requesting bids on the final RD or CMD package. This date is reported in CERCLIS as the actual completion date
(Actual Complete) of the RD (Action Name = FF RD) or CMD(Action Name = Corrective Measure Design).
Changes in Definition FY 02/03 - FY04/05
New measure for FY 04/05.
Special Planning/Reporting Requirements:
This is a SCAP reporting measure. RD or CMD starts and completions are reported site-specifically (Action Name =
FF RD or Corrective Measure Design) in CERCLIS.
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OSWER Directive 9200.3-14-1G-Q
k. DURATION OF ROD TO IAG NEGOTIATION COMPLETION
Definition:
The objective of this measure is to focus attention on the statutory requirement for an IAG to be entered into within 180
days after signature of the ROD. SARA Section 120(e) (2) states that "within 180 days [after signature of the ROD],
the head of the department, agency, or instrumentality concerned shall enter into a IAG with the administrator for the
expeditious completion by such department, agency, or instrumentality of all necessary remedial action at such facility."
This measure tracks compliance against the CERCLA Section 120 statutory requirements.
Definition of Accomplishment:
The duration of ROD to IAG will be calculated based on the actual completion date of the ROD (Action name = Record
of Decision) and the latter of the dates that the Federal agency, EPA, and/or State sign the IAG, or the date the Letter
of Intent to sign an IAG is signed by all parties, as reported in WasteLAN as the actual completion (Actual Completion)
of FFA/IAG negotiations (Action Name = IAG Negotiation).
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
This is a GPRA APM reporting measure. Data in WasteLAN will be used to calculate the timespan on a semi-annual
basis. HQ will perform the analysis.
l. REMEDIAL A CTION (RA) OR RCRA CORRECTIVE MEASURE IMPLEMENTA TION
(CMI) STARTS
Definition:
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.
Definition of Accomplishment:
Date on which substantial, continuous, physical, on-site, remedial actions begin pursuant to SARA Section 120(e) as
documented by a memo or letter to EPA. This date is reported in WasteLAN as the actual RA (Action Name = FF RA)
or CMI (Action Name = Corrective Measure Implementation) start date (Actual Start).
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
This is a program measure. RA or CMI starts are reported site specifically (Action Name = FF RA or Corrective
Measure Implementation) in WasteLAN.
January 10,2005
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OSWER Directive 9200.3-14-1G-Q
nt TIMESPAN FROM ROD SIGN A TURE TO RA START
Definition:
The objective of this measure is to focus attention on the statutory requirement for an RA start within 15 months of the
ROD signature.
SARA Section 120(e) states that "substantial, physical, on-site remedial action shall be commenced at each Federal
facility no later than 15 months after completion of the investigation and study." This measure tracks compliance against
the CERCLA Section 120 statutory requirements.
Definition of Accomplishment:
This measure will look at Federal agency performance by comparing the average timespan from ROD signature to RA
start for all sites where a RA actually started in FY 04/05. Sites exceeding the 15 month requirement will be identified.
Comparisons will be made to previous Agency performance to determine trends.
The durations will be calculated using the actual ROD (Action Name = Record of Decision) completion date (Actual
Complete) and the actual RA (Action Name = FF RA) start date (Actual Start) in WasteLAN. The ROD signature and
RA start definition contained in Decision Documents and RA or Corrective Measure Construction Starts, respectively,
will be used in the analysis.
Changes in Definition FY 02/03 - FY 04/05:
None.
Special Planning/Reporting Requirements:
This is a GPRA APM reporting measure. Data in WasteLAN will be used to calculate the timespan on a semi- annual
basis. HQ will perform the analysis.
n. RA OR CMI COMPLETIONS
Definition:
A RA or CMI is complete when construction activities are complete, a final inspection has been conducted, and an
interim or final 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 120(h)(3) BRAC
requirements for base closure.
Definition of Accomplishment:
The RA or CMI is complete the date that the designated Regional official (Branch Chief or above, as determined by the
EPA Region) approves in writing the interim or final RA Report or signs the interim or final report or appropriate CMI
reporting vehicle for the RA or CMI that documents the completion of construction activities. 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.
The appropriate date must be recorded in WasteLAN as the actual completion date (Actual Complete) of the RA (Action
Name = FF RA) or CMI (Action Name = Corrective Measure Implementation).
An action qualifier must be entered into WasteLAN indicating the RA was completed via an Interim or Final RA
Report (Action Qualifier = Interim RA or Final RA).
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January 10,2005
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OSWER Directive 9200.3-14-1G-Q
Interim Remedial Action Report
Criteria for approval of the Interim Remedial Action Report are:
The remedy includes groundwater or surface water restoration, with active treatment or natural attenuation,
to reduce contaminant concentrations to meet cleanup goals and cleanup goals have not been achieved;
~ The construction of the treatment and/or monitoring system is completed and the system is operating as
intended;
~ If the RA includes remedy components other than groundwater, construction activities are complete and
cleanup goals specified in the ROD have been achieved for these components;
~ A contract final inspection or equivalent has been conducted;
~ Institutional controls, if applicable, are in place; and
The Interim Remedial Action Report contains the information described in "Close Out Procedures for
National Priorities List Sites."
Note: When an Interim RA Report is prepared as indicated above, a Final RA Report is later required once cleanup
goals for the groundwater or surface water restoration are achieved.
Final Remedial Action Report
Criteria for approval of the Final Remedial Action Report are:
All construction activities are complete, including site restoration and demobilization;
All cleanup goals specified in the ROD have been achieved, including ground and surface water restoration;
A contract final inspection or equivalent has been conducted;
~ Institutional controls, if applicable, are in place; and
The Final Remedial Action Report contains the information described in "Close Out Procedures for National
Priorities List Sites."
January 10,2005
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OSWER Directive 9200.3-14-1G-Q
The following table provides examples of Remedial Actions and indicates when Remedial Action Completion can be
achieved.
Remedial Action Completion Examples
Example RA
RA Complete
Excavation and off-site disposal of contamination.
After all wastes have been excavated, removed from the site
to an approved location, site has been restored, cleanup goals
have been achieved, and the Final RA Report is approved.
Since wastes have been removed, no O&M activities for this
remedy are expected.
On-site treatment of wastes, other than
groundwater or surface water, to achieve cleanup
goals (e.g., soil vapor extraction, bioremediation,
incineration).
After cleanup goals have been achieved for the treated
wastes, site has been restored, and the Final RA Report is
approved. Since wastes have been treated to achieve
cleanup levels, no O&M activities for this remedy are
expected.
Containment remedies (e.g., caps, flood/erosion
control measures, barrier walls, leachate
collection/treatment measures, groundwater
measures to capture or prevent migration of plume,
or surface water interception/diversion measures).
After construction of the designed remedy is complete,
cleanup goals have been achieved, and the Final RA Report
is approved. O&M activities follow.
Groundwater and surface water restoration
remedies that involve active treatment to reduce
contaminant concentrations to meet cleanup goals.
After construction of the treatment plant and monitoring
system are completed, the plant/system is operating as
intended, and the Interim RA Report is approved. O&M
activities follow. The Final RA Report is prepared when
cleanup levels are achieved.
Groundwater and surface water restoration
remedies where restoration is later determined to
be technically impracticable (TI waiver).
After ROD Amendment has documented the TI waiver,
other cleanup goals have been achieved and Final RA
Report is approved. O&M activities may follow if further
monitoring is needed.
Change 5, FY 04/05 SPIM
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January 10,2005
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OSWER Directive 9200.3-14-1G-Q
EXHIBIT D.2
Remedial Pipeline Flow Charts
Treatment and Off-site Disposal Remedies Pipeline
Final
RA Report
OPS
(no O + M rcqutwdl
RA
For example; b lore mediation, SVE
Containment Remedies Pipeline
Final
RA Report
f
i RA »
O +M
(no need For OPS)
Ground Water and Surface Water Restoration Pipeline
and Monitored National Attenuation
Interim
RA Report
Final RA Report
(Cleanup Goals
Achieved j
RA
O + M
OPS
OPS= Operating Properly & Successfully and applies only to BRAG sites.
January 10,2005
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Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
This is a program target. RA or CMI (Action Name = FF RA or Corrective Measure Implementation) completions are
reported site specifically in WasteLAN. An action qualifier must be entered into WateLAN indicating the RA was
completed via an Interim or Final RA Report (Action Qualifier = Interim RA or Final RA).
o. REMOVAL OR RCRA INTERIM/STABILIZATION MEASURE (ISM) STARTS AND
COMPLETIONS
Definition:
Removal actions are defined as the cleanup or removal ofreleased 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, and non-time critical (NTC) situations at
BRAC , non-NPL or NPL sites. Under the Defense Environmental Restoration Program (DERP), DoD is required to
notify EPA of its removal actions. Long-term O&M should not be conducted under the removal.
Definition of Accomplishment:
Removal/ISM Start Date: Date the Federal agency begins actual on-site removal work, or the date of Action
Memorandum signature, or the date the lead Federal agency provides notice to EPA, or other decision document
signature/approval. The date must be reported in W asteLAN as the actual start date (Actual Start) of the removal (Action
Name = FF Removal) or ISM (Action Name = RCRA Interim/Stabilization Measure).
Removal/ISM Completion Date: Actual date the Federal agency has demobilized and notified EPA, completing the
scope of work delineated in the Action Memorandum or other decision document. The date must be reported in
WasteLAN as the actual completion date (Actual Complete) of the removal (Action Name = FF Removal), or ISM
(Action Name = RCRA Interim/Stabilization Measure).
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
See Definition of Accomplishment. Removal or RCRA ISM starts is a GPRA measure; Removal or RCRA ISM
completions is a program measure.
p. NPL SITE CONSTRUCTION COMPLETIONS
Definition:
Construction at a NPL site is considered complete when physical construction is complete for the entire site as a result
of one or several removal or remedial actions; and a Preliminary or Final Close Out Report (PCOR or FCOR) has been
signed by the designated Regional official and concurred with by HQ. The report must address construction activities
for the entire site. There is only one NPL site construction completion per NPL site, and the site must be final on the
NPL. For more detailed information, see OSWER Directive 9320.2-09A-P, "Close Out Procedures for National
Priorities List Sites."
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January 10,2005
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OSWER Directive 9200.3-14-1G-Q
Definition of Accomplishment:
The following table explains coding and accomplishment requirements.
NPL Site Construction Completion
Examples of last OU or activity
When Construction is Complete
Coding Requirements
1) Excavation and off-site
disposal of contamination,
2) On-site treatment of wastes
(except for groundwater
restoration, bioremediation or soil
vapor extraction), or
3) Containment remedies.
Pre-final inspection has been
conducted, only minor punch list
items remain, and the designated
Regional official has signed the
Preliminary or Final Close-Out
Report (PCOR orFCOR).
The region enters completion date of
the report into WasteLAN as the
actual completion date (Actual
Complete) of the Preliminary Close-
Out Report [Action Name = Prelim
Close-Out Rep Prepared], or the
actual completion date (Actual
Complete) ot the Final Close-Out
Report [Action Name = Close Out
Report]
AND
HQ enters the Construction
Completion indicator into WasteLAN.
This action constitutes HQ
concurrence with the PCOR or FCOR
documentation.
In-situ bioremediation, ex-situ
bioremediation, or soil vapor
extraction.
Treatment unit has been
constructed, is operating as
designed, studies show that
technology will achieve cleanup
goals, and the designated
Regional official has signed the
PCOR.
Interim action RODs for
groundwater restoration to reduce
contaminant concentrations to
meet cleanup goals.
Remedy is documented in final
ROD, physical construction of the
remedy is complete, and the
designated Regional official has
signed the PCOR.
RODs with contingency remedies
Physical construction of the
remedy is complete, a pre-fmal
inspection has been conducted,
only minor punch list items
remain, the PCOR orFCOR
demonstrates that use of the
contingency is not anticipated,
and the designated Regional
official has signed the PCOR or
FCOR.
Sites deleted from the NPL prior to
reaching Construction Completion.
When (1) EPA determines that all
physical construction is complete
under all statutory authorities, and
(2) all other applicable
construction completion policy
criteria have been satisfied.
Consistent with requirements for final
NPL sites.
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OSWER Directive 9200.3-14-1G-Q
NPL Site Construction Completion (cont'd.)
Examples of last OU or activity
When Construction is Complete
Coding Requirements
Sitesrequiring no remedial action or
no further remedial action in the last
OU. This includes groundwater
monitoring if that is the only activity
specified in the ROD.
No action or no further action
ROD has been signed, and the
designated Regional official has
signed the PC OR or FC OR.
Effective in FY 99, No Action
RODs will not be accepted for
Construction Completion.
The region enters the completion date
of the report into WasteLAN as the
actual completion date (Actual
Complete) of the PCOR (Action
Name = Prelim Close-Out Report
Prepared) or the actual completion
date (Actual Complete) of the Final
Close-Out Report (Action Name =
Close Out Report).
AND
HQ enters the Construction
Completion indicator into WasteLAN.
This action constitutes HQ
concurrence with the PCOR or FCOR
documentation.
Institutional controls
as the only remedy in the ROD.
The PC OR indicates that the
institutional controls are in the
schedule for site completion, and
the designated Regional official
has signed the PCOR. If
institutional controls have been
implemented, region can go
directly to FCOR.
NPL site entirely addressed
through removal actions. For
removals with institutional
controls, see above.
Actual date the Federal agency
has demobilized and notified
EPA, completing the scope of
work delineated in the Action
Memorandum or other decision
document. The date must be
reported in WasteLAN as the
actual completion date (Actual
Complete) of the removal
(Action Name = FF Removal), or
ISM (Action Name = RCRA
Interim/Stabilization Measure).
The region enters the following into
WasteLAN: The removal (Action
Name = Removal Action or PRP
Removal) actual completion date
(Actual Complete) as reported in the
POLREP; and the Qualifier that
indicates that the site is Cleaned Up;
and the actual completion date
(Actual Complete) of the Final Close-
Out Report (Action Name = Close Out
Report);
AND
HQ enters the Construction
Completion indicator into WasteLAN.
This action constitutes concurrence
with the FCOR documentation.
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
Regions will not receive credit for a NPL Site Construction Completion until the actual completion date of the
Preliminary or Final Close-Out Report is entered into WasteLAN, the necessary documentation is submitted to HQ, and
HQ enters the construction completion indicator into WasteLAN. Regions identify sites to meet the goal prior to the start
of the FY. This is a GPRA annual performance goal.
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OSWER Directive 9200.3-14-1G-Q
q. OPERATION AND MAINTENANCE (O&M)
Definition:
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.
O&M [Action Name = Operations and Maintenance] starts when the designated EPA Regional Official (Branch Chief
or above, as determined by the EPA region) approves in writing the Interim or Final Remedial Action Report.
Where appropriate, the completion of O&M is defined as the date (actual complete) specified in the FFA/IAG. If O&M
must be conducted indefinitely, regions should not enter as actual completion date.
Changes in Definition for FY 02/03 - FY 04/05:
O&M also includes maintenance of institutional controls.
Special Planning/Reporting Requirements:
This is a program measure.
r. CLEANUP OBJECTIVES ACHIEVED
Definition:
This measure is used to indicate when cleanup objectives are achieved for
including monitored natural attenuation. It tracks achievement of cleanup
have not yet achieved cleanup objectives at Remedial Action completions.
Definition of Accomplishment:
Cleanup objectives are achieved when the designated Regional Official (Branch Chief or above) approves in writing the
Final Remedial Action Report. This report should update information previously prepared in the Interim Remedial
Action Report. For more detailed information, see OSWER Directive 9320.2-09A-P, "Close Out Procedures for
Completion and Deletion of National Priorities List Sites."
Changes in Definition FY 02/03 - FY 04/05:
Cleanup Goals are now referred to as Cleanup Objectives.
Special Planning/Reporting Requirements:
Cleanup Objectives Achieved is planned on an action specific basis (Action Name = Operations & Maintenance and
SubAction Name = Cleanup Goals Achieved) in WasteLAN. This is a program measure.
groundwater and surface water restoration,
objectives for these remedies because they
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OSWER Directive 9200.3-14-1G-Q
v. FEDERAL FACILITY FIVE-YEAR REVIEWS
Definition:
Five-year reviews are intended to evaluate whether the response action implemented at NPL site remains protective of
public health and the environment, is functioning as designed, and necessary operation and maintenance is being
performed. At a minimum of every five years, EPA, or the lead F ederal agency, conducts a statutory review any site at
which a post-SARA remedy, upon, attainment of cleanup levels specified in the ROD, will not allow unlimited use and
unrestricted exposure. EPA, or the lead Federal agency conducts policy reviews at sites where remedial actions will take
longer than five years to complete, and sites with pre-SARA remedies at which the cleanup levels do not allow unlimited
use and unrestricted exposure. EPA may conduct five-year reviews at their discretion for other sites.
Definition of Accomplishment:
Federal Facility Five-Year Review Starts - Credit is given for a five-year review start when EPA approves the five-year
review work plan submitted by the other F ederal agency, or when the Federal facility actually starts the reviewor submits
the draft document for review, as outlined in the ROD or IAG. The actual start date (Actual Start) for the five-year
review (Action Name = FF FYR) must be entered into WasteLAN. There are multiple triggers for five-year reviews.
Please reference policy to select the appropriate method for calculating the five-year review date.
Federal Facility Five-Year Review Planned Completions - The FF FYR planned completion date and the report due
(SubActionName = FYR Report Due) date are system generated based on the Five-year review type entered at the time
of ROD completion.
Statutory: TheFF FYR and FYR Report Due planned completion date fields are populated for five years after the Federal
facility RA action planned start date. Both the FF FYR planned completion date and the FYR Report Due planned
completion date will be updated by the system based on changes to the planned or actual start dates for triggering FF RA
action. The FF FYR planned completion date will be editable. The FYR Report Due planned completion date will be
greyed out and uneditable and will be locked once the actual start date for the FF RA is entered. Please see the Five-Year
Review section of Appendix B for the definition of Statutory Five -Year review.
Policy: The FF FYR and FYR Report Due planned completion dates are populated for five years after the PCOR or
FCOR planned completion date. Both the FF FYR planned completion date and the FYR Report Due planned
completion date will be updated by the system based on changes to the planned or actual completion dates for the
triggering PCOR or FCOR. The FF FYR planned completion date will be editable. The FYR Report Due planned
completion date will be greyed out and un-editable and will be locked once the actual completion date of the PCOR or
FCOR is entered. Please see the Five-Year Review section of Appendix B for the definition of Policy Five-Year review.
Federal Facility Five-Year Review A dual Completions - The five-year review is complete on the date the designated
Regional official either signs the five year review report stating whether the remedy is, or is not, protective of human
health and the environment, or has concurred on the five year review report, or has made their own protectiveness
determination. The actual completion date (Actual Complete) for the five-year review (ActionName = FF FYR) must
be entered into WasteLAN.
Changes in Definition FY 02/03 - FY 04/05:
Expanded the description of Definition of Accomplishment to include specifics about system-generated FF FYR and
FYR Report Due planned completion dates. Updated Action Name.
Change 5, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
Special Planning/Reporting Requirements:
Five-year Review Completes is a program measure. Five-year review completes must be planned and reported site-
specifically (Action Name = FF FYR) in WasteLAN. The trigger for a statutory five-year review is the actual start date
of the FF RA Start.
Note: Five-Year Review Completions are a program measure for Federal facilities. For Superfund, Five-Year Review
Completions are program targets (See Exhibit B.l in Appendix B and Exhibit D.l in Appendix D).
t FEDERAL FACILITY PARTIAL NPL DELETION
Definition:
EPA will consider partial deletion for portions of sites when no further response is appropriate for that portion of the site.
Such portion may be a defined geographic unit of the site, perhaps as small as a residential unit, or may be a specific
medium at the site (e.g., groundwater), depending on the nature or extent of the release(s). The criteria for partial
deletion are the same as for final deletion. Given State concurrence, EPA considers:
Whether responsible or other parties have implemented all appropriate and required response actions;
Whether all appropriate Fund-financed responses under CERCLA have been implemented and EPA has
determined that no further cleanup by responsible parties is appropriate; or
D Whether the release of hazardous substances poses no significant threat to the public health, welfare or the
environment, thereby eliminating the need for remedial action.
The partial deletion action should only be used when the deletion does not address all releases listed on the NPL. If a
deletion does cover the remaining release listed on the NPL, the action should be treated as a FinalNPL Deletion (Action
Name = Deletion from NPL), discussed below.
Definition of Accomplishment:
The partial NPL deletion process (Action Name = Partial NPL Deletion) starts (Actual Start) when a Notice of Intent
to Delete is published inthe Federal Register for that specified portion of the site. If the Direct Final Process for Partial
Deletions is used, the process begins when the Direct Final Action Notice is published in the Federal Register [Action
Name = Notice of Intent to Delete],
The partial NPL deletion process (Action Name = Partial NPL Deletion) is complete (Actual Complete) when the Notice
of Partial Deletion is published in the Federal Register for that specified portion of the site. If the Direct Final Process
for Partial Deletions is used and the comment period has ended with no adverse comments, the actual completion (Actual
Complete) is the effective date of deletion specified in the Direct Final Action Notice.
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
Partial NPL deletions are tracked separately from finalNPL deletions (Action Name = Deletion from NPL). Partial site
deletions will be entered by the regions if a portion, or portions, of the release remain listed on the NPL following
completion of the partial deletion.
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OSWER Directive 9200.3-14-1G-Q
A site deletion (Action Name = Deletion from NPL) will be entered by the regions if the deletion activity addresses all
remaining releases listed on the NPL (either as a one-time deletion action for the entire site as originally listed, or as the
last deletion activity associated with a site subject to previous partial deletions). This is a program measure.
u. FEDERAL FACILITY FINAL NPL DELETION
Definition:
With State concurrence, EPA may delete sites from the NPL when it determines that no further response is appropriate
under CERCLA. In making that determination, EPA considers:
Whether responsible or other parties have implemented all appropriate and required response actions;
Whether all appropriate Fund-financed responses under CERCLA have been implemented and EPA has
determined that no further cleanup by responsible parties is appropriate; or
Whether the release of hazardous substances poses no significant threat to the public health, welfare or the
environment, thereby eliminating the need for remedial action.
EPA will consider deleting the entire site or portions of sites from NPL, as appropriate. EPA will consider partial
deletion for portions of sites when no further response is appropriate for that portion of the site. Such portions may be
a defined geological unit of the site, or may be a specific medium at the site. If a decision does cover the remaining
release listed on the NPL, the action should be treated as a Final NPL Deletion. State concurrence is required for any
deletion.
Definition of Accomplishment:
The deletion process for the entire site [Action Name = Deletion from the NPL] starts (Actual Start) when a Notice of
Intent to Delete is published for the Federal Register. If the Direct Final Process for Partial Deletions is used, the
process begins when the Direct Final Action Notice is published in the Federal Register [Action Name = Notice of Intent
to Delete],
The deletion process for the entire site [Action Name = Deletion from the NPL] is complete (Actual Complete) when
the Notice of Deletion is published in the Federal Register. If the Direct Final Process for Partial Deletions is used and
the comment period has ended with no adverse comments, the actual completion (Actual Complete) is the effective date
of deletion specified in the Direct Final Action Notice.
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
An entire site deletion action (Action Name = Deletion from the NPL) will be entered by the regions if the deletion
activity addresses the remaining release listed on the NPL (either as a one-time deletion event for the entire site as
originally listed, or as the last deletion activity associated with a site subject to previous partial deletions). When the
Notice of Deletion is published, the regions will change the NPL Status in WasteLAN to "Deleted from Final NPL."
This is a program measure.
Change 5, FY 04/05 SPIM
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OSWER Directive 9200.3-14-1G-Q
D.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 Appendix J.
a. RESTORATION ADVISORY BOARDS (RABs)/SITE-SPECIFIC ADVISORY BOARDS
(SSABs)
Definition:
Site-Specific Advisory Boards (SSABs) are a forum for experts and concerned stakeholders to provide advice and
recommendations on DOE's Environmental Management strategic decisions. Restoration Advisory Boards (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.
Definition of Accomplishment:
RAB/SSAB Start (Established) Date: The actual start date of the RAB/SSAB is defined as the actual start date (Actual
Start) of the initial RAB/SSAB information meeting (SubAction Name = Site-Specific Advisory Board Meeting or
SubAction Name = Restoration Advisory Board Meeting).
RAB Completion (Adjourned) Date: Theactualcompletion(ActualComplete)dateofthe 'Restoration Advisory Board'
(SubAction Name = Restoration Advisory Board) is the date the RAB is adjourned by DoD (SubAction Name =
Restoration Advisory Board).
SSAB Completion (Terminated) Date: The actual completion (Actual Complete) date of the 'Site-Specific Advisory
Board' (SubAction Name = Site-Specific Advisory Board) is the date the SSAB is terminated by the Secretary of Energy
(SubAction Name = Site-Specific Advisory Board).
Changes in Definition FY 02/03 - FY 04/05:
The RAB and SSAB start definitions were modified.
Special Planning/Reporting Requirements:
This is a GPRA measure. The data management approach for tracking the adjournment of RABs and the termination
of SSABs is still under development. Site Specific Advisory Board Meeting and Restoration Advisory Board Meeting
are valid Sub Actions under Federal Facility Community Relations.
b. TECHNICAL ASSISTANCE GRANTS (TAGs)
This measure is being withheld pending OGC & EPA Grants approval.
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c. TECHNICAL OUTREACH SERVICES FOR COMMUNITIES (TOSC)
Definition:
TOSC provides independent scientific and technical assistance to communities dealing with hazardous substance
contamination questions. TOSC provides information and education to empower communities with an understanding
of technical issues to more effectively participate in environmental decisions. TOSC is a service of the University-based
Hazardous Substance Research Centers (HSRCs) which are, in part, supported by grants from EPA.
Definition of Accomplishment:
The start of a TOSC is the date when the MOU (Memorandum of Understanding) is signed, which is the date of the
commitment between the community and the HSRCs. The date the MOU is signed should be reported in WasteLAN
as the actual start date (Actual Start) of the TOSC (Action Name = Technical Outreach Services to Communities).
Changes in Definition FY 02/03 - FY 04/05:
None
Special Planning/Reporting Requirements:
The region must indicate on the Community Organizations Information screen that the organization is a TOSC recipient.
This is a program measure.
D.C SUBJECT MATTER EXPERTS
Exhibit D.3 identifies the subject matter experts for Appendix D: Federal Facilities.
EXHIBIT D.3
SUBJECT MATTER EXPERTS
Subject Matter Experts
Subject Area
Phone #
Brandon Roache
Federal Facility Response
(703) 603-8704
Tracey Seymour
Federal Facility Response
(703) 603-8712
Joshua Barber
Federal Facility Response
(703) 603-0265
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Superfund Program Implementation Manual FY04/05
Appendix E: Information Systems
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Appendix E
Information Systems
Table of Contents
E.A Information Systems E-l
E.A.I The Purpose of WasteLAN E-l
a. Site Assessment E-l
b. Remedy Selection E-2
c. Federal Facilities E-3
d. Community Involvement E-3
e. Removal E-4
f. Enforcement E-5
g. Project Management E-6
h. Program Management E-6
E.A.2 Superfund Data Architecture E-7
E.A.3 Reporting Superfund Information E-8
WasteLAN Users E-9
E.A.4 Applicability of the Freedom of Information Act E-10
a. Reports Releasable under Freedom of Information Act (FOIA) E-10
b. Sensitive Information Not Releasable under FOIA E-10
c. Ad Hoc Reporting E-13
d. Accessing FOIA Information E-l4
E.A.5 Data Owners/Sponsorship E-15
E.B DATA SPONSORS E-16
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Appendix E
Information Systems
List of Exhibits
EXHIBIT E-l SUPERFUND DATA ARCHITECTURE E-8
EXHIBIT E.2 DATA SPONSORS E-16
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APPENDIX E
Information Systems
E.A Information Systems
E.A. 1 THE PURPOSE OF WasteLAN
WasteLAN is the official repository of nationally defined and nationally required data for planning, tracking, and
describing all activities at sites and removal incidents.
The following categories of site/incident activity have national definitions and national requirements:
Site Assessment
Remedy Selection
~ Federal Facilities
Community Involvement
Removal
Enforcement
Project Management
Program Management
a. Site Assessment
To support the site assessment process, WasteLAN provides the following capability:
Enter, store, and retrieve basic site discovery information, including site identification (name and location), narrative
description, contaminants, and site setting;
Distinguish between removal program or site assessment program discoveries;
~ Review and compare results of the Preliminary Assessment (PA), Site Inspection (SI), Expanded Site Inspection
(ESI), and Site Inspection Prioritization (SIP), including overall Hazard Ranking System (HRS) site score and
component pathway scores;
Access to detailed information on each pathway score;
~ Enter, store, and retrieve site assessment decision information, including qualifiers and text rationale and referrals
to States or other program areas;
Manage site assessment schedules through the Project Management module;
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Generate site assessment reports and perform ad hoc queries on basic site level and decision information, as well
as site and pathway score information;
Review contaminant information from the PA, SI, ESI, removal evaluation, or HRS;
~ Access Superfund National Priorities List Assessment Program (SNAP) information in WasteLAN. Only the Site
Assessment Manager and the Construction Completion Manager have the rights to change these data; and
~ Create Headquarters (HQ) site assessment reports,
b. Remedy Selection
To support the remedy selection process, WasteLAN provides the following capability:
Add and delete Actions and SubActions to the site schedule and add operable units (OUs);
Add, edit, and review an Action and its associated operable unit, actual and planned start dates, and actual and
planned completion dates;
View and update site information, including medium, contaminants, concentrations, and regulations that possibly
apply to the contaminant;
Record and review Record of Decision (ROD) risk assessment information for each medium and media area
including the worst risk scenarios;
Review ROD contaminants of concern data and relevant standards, a summary of the contaminant-specific risks for
each medium area, and cleanup levels for the contaminants;
Review ROD risk data exposure scenarios by time frame for each medium area; scenarios contain pertinent factors
(i.e. land use, exposure time frame, location, receptor, exposure route) and reflect at least one scenario for each land
use assessed;
~ Review a summary ofpertinent ecological risk assessment information from the ROD including potential receptors,
sensitive habitats, and endangered/threatened species;
View site descriptions which can be used to aid in the development of remedial documents, such as proposed plans
and ROD;
View and compare data among pipeline actions for site and OU contaminants, contaminated medium, site and OU
risk/threats, and selected remedy information;
~ Identify program initiative sites, such as contaminated sediments or presumptive remedy sites;
Perform queries to identify "like sites";
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~ Review selected or amended remedies at sites with RODs, ROD amendments, and Explanation of Significant
Differences (ESDs) including remedial response actions associated with the selected remedy;
Review ROD abstracts; and
Create HQ remedy reports.
c. Federal Facilities
To support Federal facilities, WasteLAN provides the following capability:
Track the proper relationship between Federal facilities, Federal facility sites, parcels and OUs;
Add, update, and delete Actions and SubActions and associated information;
View, edit, and track information pertaining to dispute resolutions such as the issue triggering dispute, compliance
status, and dispute type (i.e., informal or formal);
Record, display, and view information pertaining to Interagency Agreement/Federal Facility Agreement (IAG/FFA)
negotiations and agreements;
Record, display, and update information pertaining to Base Realignment and Closure (BRAC) sites, including BRAC
types, Fast Track sites, Environmental Baseline Survey (EBS) information, detailed parcel information, Finding of
Suitability to Lease (FOSL) information, and Finding of Suitability to Transfer (FOST) information;
~ Record key community involvement and outreach activities at Federal facilities;
Display listings of all IAG milestones to be reviewed within a user specified time frame;
Record and display a site abstract;
~ Record and display Federal Facility Docket information;
Provide the capability to track penalty and Supplemental Environmental Project (SEP) information;
Provide access to all modules in WasteLAN (e.g., Removal, Remedy Selection, etc.) to view all technical and
administrative data pertaining to a site; and
~ Provide Headquarter Federal facility Reports.
d. Community Involvement
To support the community involvement process, WasteLAN provides the following capability:
View Community Involvement Schedule information;
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Enter and access online directions to the site;
Enter and view listings and directions to potential locations in the area to hold public meetings;
Enter and view information on scheduled public meetings and directions to the meeting location;
Enter and view information on public meetings that were held related to a site;
Access current site information from any user view;
Enter and view a profile of demographic data for the community surrounding the site;
Enter and view information about products such as fact sheets and community relations plans;
Plan and report accomplishments and activities related to Community Involvement;
Enter and view the address of site information repositories and identify which repositories contain Administrative
Records; and
~ Create HQ community involvement reports,
e. Removal
To support the removal process, WasteLAN provides the following capability:
Add, update, and delete Actions and SubActions and associated information;
Document On-Scene Coordinators (OSCs) assigned to the removal, EPA branch that is addressing the removal, site
operable unit name, category of removal and outcome of the removal action, attorney assigned to the removal,
planning status, removal media, contaminants data and risk, remedy implemented, and site funding rank;
Track Action Memo types, support the Action Memo approval process, and capture response action scientific and
location information;
Develop removal fact sheets;
Assist in the management of removal budgets for various contract vehicles and other EPA costs;
Enter and store regional removal assessment detail description information including date assigned to OSC, where
the site was referred from, referral date, response date, site visitdate, media, flags for sampling performed, eligibility
for removal, referred to remedial program office, and returned to State;
Generate regional cost/financial management reports; and
Create HQ removal reports.
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f. Enforcement
To support the enforcement process, WasteLAN provides the following capability:
Add, update, and delete Actions and SubActions and associated information;
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 (PPAs);
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 wasused, the outcome of the ADR,
and the mediator used;
~ 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 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 Limitations (SOLs);
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; and
~ Create HQ enforcement reports.
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g. Project Management
To support the site management process, WasteLAN provides the following capability:
Maintain schedule for site activities;
Add and delete Actions, SubActions, and new operable units to/from the schedule;
View and edit action-specific information including operable unit, sequence number (system generated), lead,
planned and actual start/complete dates, and planned start/complete Fiscal Year/Quarter (system generated);
View the targeted Fiscal Year/Quarter for actions defined as regional targets;
Define associations among actions and add user-defined actions to schedules;
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 action-specific comments;
Prepare Gantt charts, generate reports such as a Site Summary report, a Management Review report, and a Target
Comparison report, and create/print weekly "notes" to keep managers apprised of "hot" issues;
Access Smartscreens, which provide online SCAP definitions and apply SCAP logic during data entry and updates
or edits;
Enter or copy technical data through Smartscreens (e.g., remedy, media type). Data can be copied to subsequent
actions to avoid duplicate data entry;
View financial data by site, action, or financial transaction and track Superfund State Contracts (SSC) cost share
payment and reimbursable account information;
Generate Tike dates' for actions that, by definition, have the same actual start or actual complete date;
Allow reviewers (e.g., Section Chiefs) to approve or disapprove schedule changes and financial transactions before
they become official and notify Remedial Project Managers (RPMs) if any of their sites have been reviewed; and
Generate HQ project management reports.
h. Program Management
To support the program management process, WasteTAN provides the following capability:
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;
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View aggregate site planning data to support program planning and reporting measures and access data on a national
(at 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;
Identify the funding priority for Remedial Actions (RAs) and removals based on factors such as the status of PRP
negotiations, whether the Remedial Design (RD) has reached 95% complete, and estimated cost;
Associate sites with a specific national and/or regional priority;
Enter Environmental Indicator (EI) data at the site/action level, and view summary information for Indicators
identified in Appendix B at the national (at HQ only) and regional levels;
Transfer financial data from Integrated Financial Management System (IFMS) on a daily basis; and
Generate HQ program management reports.
E.A.2 SUPERFUND DATA ARCHITECTURE
The Superfund data architecture is comprised of various components that reside in the regions or at HQ. The goal of
this architecture is to allow regions, the data owners, to enter data locally while still ensuring a national database is
maintained for national reporting purposes.
Exhibit E-l outlines the relationship among various components of the Superfund data architecture. Each region enters
their information into the regional WasteLAN system. Each night, data from the regional systems are sent via the
"snapshot" process to the Agency Information Managementrepository, which is the Superfund pro gram's comprehensive
data repository. HQ owned or regionally shared data are "snapshot" back to the regions on a regular basis. The
following is the information that is updated as a result of this "reverse snapshot" process:
Instantly: NPL Listing information
~ Nightly: Construction Completion data
Weekly: PRP data
Data that are snapshot nightly to the Agency Information Management is then divided into different, single purpose
datasets to meet specific needs of the program. These datasets include, but are not limited to:
CERCLIS: This dataset contains active sites and related program management information tracked through the
SCAP process.
FOIA: This dataset contains active sites and related information that is releasable to the public.
Archive: This dataset contains archived sites and related information.
Others, as needed: Additional datasets can be created to meet additional program needs and special initiatives as
they are defined. For example, a "Pre-Discovery" dataset could be created to track information on sites prior to
beginning the listing process.
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EXHIBIT E.l
SUPER FUND DATA ARCHITECTURE
National IFMS
\ Data from /
\ FMD /
Regional WasteLAN
Headquarters
WasteLAN
(C3PR)
CERCLJS 3
Test
WasteLAN
(C3TE)
FOIA
Agency
Information
Management
Repository
Archive
Sites
Brownfields
In addition, each day, financial data from the IFMS are transferred via Agency Information Management to the
regional WasteLAN databases.
E.A.3 REPORTING SUPERFUND INFORMATION
The WasteLAN Reports Module is accessible to all users, and contains both nationally- and regionally-defined
reports. The reports are categorized by the following program areas: Site Assessment, Risk Assessment, Remedy
Selection, Federal Facilities, Community Involvement, Removal, Enforcement, Project Management, and Program
Management. 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.
Reports in the Reports Module are being developed from a Select Logic Database (SLDB). The SLDB is a
warehouse of select logic queries; because each query has been created using pieces of reusable code (RC ), the select
logic stored in the SLDB can be reused across multiple reports. The SLDB approach to developing reports has many
benefits. By reusing select logic queries that have already undergone testing and validation, the SLDB approach
promotes consistency and accuracy in program-wide reporting. In addition, because all select logic queries reside in one
location, the effort required to maintain the Reports Library is significantly reduced.
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The SLDB stores nationally- and regionally-defined queries. Queries that are nationally defined and used in national
reports will be tested and validated by third-party testers. National queries will be sponsored by query owners at HQ.
Query owners are responsible for updating queries in a timely manner when new system requirements are established
to ensure that queries remain consistent with programmatic changes.
The regions can use national queries from the SLDB for regional reporting purposes. The regions also have the
ability to develop and store regionally-defined queries in the SLDB. Regionally defined queries and reports are managed
and maintained by the regions themselves.
If a particular report is similar in several regions, that report may be identified as a candidate for a national report.
Also, if a regional query is identified for national implementation, the query will be validated, tested, and released as a
national query. National queries and reports are managed by the HQ Reports Librarian.
The Reports Librarian role has been expanded to include the coordination and management of all national queries
and reports. The Reports Librarian will continue to coordinate with query and report owners and developers, ensuring
that reports and queries are developed consistently, in accordance with standards, and third-party tested. It is also the
Reports Librarian's responsibility to see that all national queries and reports are unique (but reused when appropriate)
and released to the user community on schedule.
The Reports Librarian is responsible for coordinating all steps of the reports development life cycle:
requirements/design, specifications, coding, testing, maintenance, change management, standards development/adherence
and documentation. This includes coordinating and facilitating bi-weekly Reports Status meetings with the reports team,
maintaining the Lotus Notes Reports Status database, and communicating status with the reports community.
The Reports Librarian coordinates the addition ofnew national and/or HQ reports to the database. This process is
framed by the forms available in the Reports Status Notes Database: the Reports Request form; Specifications, Code
Delivery form; and the Sign-off form. The Reports Librarian ensures the Reports Request form is completed
comprehensively and that the report being requested is not a duplication of an existing report. The Reports Librarian
ensures that specifications are completed prior to a report being installed on the national menu, and assists in the
coordination of hanging a report by ensuring that all the information on the Code Delivery form is completed by the
reports developer. It is the Reports Librarian function to ensure that the process is documented by ensuring that the
Sign-Off form is completed. All members of the reports community can contact the Reports Librarian for status
information on any national and/or HQ report.
In addition to coordinating the addition of new reports, the Reports Librarian is responsible for monitoring changes
to existing national and/or HQ reports and deleting obsolete reports from the menu. This means coordinating with the
development team at large on behalf of the reports team. Attending Configuration Control Board meetings, reviewing
change requests and monitoring regional comments in Lotus Notes, the suggestion box and e-mails are some of the
methods used by the Reports Librarian to monitor changes. Usage reports and feedback from the regions and HQ are
the methods used to determine obsolescence of a report.
WasteLAN Users
The WasteLAN application is for use by EPA staff with Superfund program responsibilities. WasteLAN may allow
data owners to enter and manage their own data, however, region swill publish specific data management procedures that
may implement a centralized or decentralized approach to data management. The information collected via the
application is for unrestricted use by all parties except for that portion of the information identified as sensitive and not
releasable under FOIA.
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E.A.4 APPLICABILITY OF THE FREEDOM OF INFORMATIONACT
a. Reports Releasable under Freedom of Information Act (FOIA)
There is a setof system-generated reports that have sensitive information (records or information that are protected
under FOIA and cannot be released to the public) removed and may be released under FOIA. These reports include:
~ SCAP 12 (Site Summary Report forNon-NPL Sites);
List 8E (Site/Response Action Listing Report/External);
List 8T (Site/Event Listing, Archived Sites);
List 9 (Site Comprehensive Listing);
Enforcement 10 (The Settlements Master Report Public Version); and
Enforcement 25 (Administrative and Unilateral Orders Issued).
Note: The SCAP 11, SCAP 12, List 8T, and List 9 are currently available to the public on the Superfund Home Page.
In addition, the Records of Decision System (RODS) may be released under FOIA. It provides the justification for
the remedial action (treatment) chosen under the Superfund program and stores information on the technologies being
used to clean up sites.
b. Sensitive Information Not Releasable under FOIA
FOIA is intended as a disclosure law, not a withholding law. In handling all FOIA requests, there should be a
presumption in favor of releasing information. There are certain types of information, particularly enforcement
information, that have been designated as sensitive and, therefore, are not releasable to the public because disclosure
could cause significant harm to the Agency. All planning data fit into this category including:
Section 106 and 107 litigation, Consent Decrees (CDs), and all related information where the planning
information indicates that the action has been or will be referred to HQ or to the Department of Justice
(DOJ). If the case is filed or CD lodged, the information may be released.
PRP lead Remedial Investigation/Feasibility Study (RI/F S) projects and all related information where only
planning data exist. If there is an actual PRP RI/FS start, the planned completion date (Fiscal
Year/Quarter) can be released.
Administrative Order and all related information where only planning data exist. This information is only
releasable where an actual completion date exists.
Information pertaining to cost recovery decision documents such as rationale for write off;
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Planned obligation amounts related to regional enforcement extramural budget activity associated with the
following activities:
Litigation (106, 106/107, 107) support;
Removal Negotiations;
Non-NPL and NPL PRP search;
RI/FS negotiations;
RD/RA negotiations; and
Cost recovery negotiations.
RD and RA planned events where the lead is the RP with no actual starts. When there is an actual start,
the planned completion can be released.
~ RI/FS and RD/RA negotiations planned start and completion dates. When there is an actual start, the
planned completion can be released.
~ Planned removal/remedial obligations.
All planned activities for sites that have not been designated as final or proposed NPL sites in the Federal
Register.
The following enforcement data also cannot be released:
~ Information pertaining to the financial viability of PRPs;
PRPs excluded from a UAO and reasons why PRP was not issued a UAO;
Comments;
Parties not issued a General and/or Special Notice Letter or associated with an actual enforcement
instrument;
~ Party identification under Section 104(e); and
Compliance data
This information is protected from mandatory disclosure by the following FOIA exemptions and provisions:
EXEMPTION 7 - Records or information compiled for law enforcement purposes. Specifically,
EXEMPTION 7 (a) - could reasonably be expected to interfere with enforcement proceedings.
Exemption 7 - Records or Information Compiled For Law Enforcement Purposes
This exemption provides that records or information compiled for law enforcement purposes need not
be disclosed in six specific instances. Even though a document falls under Exemption 7, the Agency,
in its discretion, encourages release of the document unless release would significantly harm the
Agency. Under this section, records or information can be withheld from disclosure if:
Exemption 7 (a) - Disclosure could reasonably be expected to interfere with enforcement
proceedings. Harm to the government's case in court by premature release of evidence or
information or damage to the Agency's ability to conduct an investigation constitutes interference
under the exemption.
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Exemption 7 (b) - Disclosure would deprive a person of a right to fair trial.
Exemption 7 (c) - Disclosure could reasonably be expected to constitute an unwarranted invasion
of personal privacy.
Exemption 7 (d) - Disclosure could reasonably be expected to disclose the identity of a
confidential source. This includes protection of information provided by the source on a criminal
law enforcement investigation.
Exemption 7 (e) - Disclosure would reveal a special technique or procedure for law enforcement
investigations or prosecutions.
Exemption 7 (f) - Disclosure could reasonably be expected to endanger the life or safety of any
person.
As a result of 1986 Amendments to FOIA Exemption 7, the general coverage of Exemption 7 is no
longer investigatory records but records of information compiled for law enforcement purposes. As
long as some law enforcement authority exists and the record meets the threshold test for exemption
7, the record need no longer reflect or result from specifically focused inquiries by the Agency.
EXEMPTION 5 - Privileged Interagency or Intra-Agency Memoranda. Specifically, EXEMPTION 5,
Privilege 1 - Deliberate Process Privilege, and EXEMPTION 5, Privilege 4 - Government Commercial
Information Privilege.
Exemption 5 - Privileged Interagency or Intra-Agency Memoranda
Intra-agency records include reports prepared by outside consultants at the request of the agency.
Recommendations from State officials to Environmental Protection Agency (EPA) may be considered
intra-agency records when EPA has solicited State comments, has a formal relationship with the State,
and the records concern a specific deliberative process.
This exemption allows the Agency to withhold from disclosure interagency or intra-agency memoranda or letters
which fall under the following privileges:
The Deliberative Process Privilege protects the quality of the Agency's decision-making process
(i.e., to protect against premature disclosure of proposed policies before they are adopted), to
encourage candid discussions among Agency officials, and to avoid premature disclosure which
could mislead the public.
Only pre-decisional, deliberative documents may be withheld. These are written prior to the Agency's
final decision, and are not likely to be those that are written by a person with final decision-making
authority. Drafts of documents usually fall under this category, and documents transmitted between
the government and third parties during settlement negotiations are occasionally protected under this
privilege.
The deliberative process privilege does not allow the withholding of purely factual portions of
documents. These portions must be released if they can be segregated from the remainder of the
document (partial denial). This requirement presents a problem where the facts themselves reflect on
the Agency's deliberative process; in this instance, the factual portions may be withheld.
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The Attorney-Work Product Privilege allows the withholding of documents prepared in
anticipation of possible litigation. Litigation need not have commenced but it must be reasonably
contemplated. This privilege does not extend to purely factual documents unless they reflect the
results of an attorney's evaluation.
The Attorney-Client Privilege applies to confidential communications between attorney and
client, including communications between an Agency attorney and Agency employee.
The Government Commercial Information Privilege is available to the government for
information it generates in the process leading up to the award of a contract. This privilege
expires once the contract is awarded or upon withdrawal of the contractual offer. An example of
this privilege is cost estimates prepared by the government and used to evaluate the construction
proposals of private contractors.
The Expert Witness Privilege is commonly invoked to allowthe withholding ofrecords generated
by an expert witness.
The Confidential Witness Statement Privilege allows statements obtained from confidential
witnesses to be withheld.
The Agency encourages the discretionary release of documents falling under any of the privileges,
unless release would significantly harm the Agency's decision-making process. All ofthe privileges
may be waived if the Agency has disclosed the document to third parties.
The sensitive information listed above covers the information restricted from public disclosure as of the compilation of
this Manual. Additional information may be added to this category and information may be restricted in specific instances
(though the prior disclosure rule must be satisfied). If requested information is potentially able to be restricted under
aFOIA provision (in this case, under Exemptions 5 or 7), the official receiving the request should contact the appropriate
FOIA office to determine whether the information should be restricted.
c. Ad Hoc Reporting
In general, all regional requests for ad hoc reporting, a special request for records, or information that is not part of
the approved public reports should be referred to the Office of Site Remediation and Enforcement (OSRE) Director
immediately. The Regional official receiving the request should inform the requestor of this policy and advise the
requestor to contact HQ for a decision on whether this information may be released. If the requested information is only
available from a specific region, and HQ has decided to release this information, HQ will inform the responsible region
that the information should be compiled and disclosed to the requestor.
Ad hoc reporting requests should be treated like FOIA requests. The following guidelines apply:
If the information is protected under one of the FOIA exemptions, the information will not be disclosed (except in
cases of discretionary release);
Absent FOIA exemption protection, the information will be disclosed if it can be compiled or obtained in a
reasonable amount of time by an Agency employee familiar with the subject area; and
Fees for ad hoc reporting requests will be charged in accordance with the fee structure used for FOIA requests.
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d. Accessing FOIA Information
There are several methods to access FOIA information.
On the Internet, via the World Wide Web, several standard reports can be viewed or downloaded from the
Superfund Information Systems area of the EPA Web site(http://www.epa.gov/superfund/sites/siteinfo .htm), through
the "Order Superfund Products" link on the sidebar. Reports available for viewing or download include:
Inventory of CERCLIS and Archived Sites by State. This report, updated monthly, displays the number of sites
by state/possession that are currently in CERCLIS; it also displays the number of sites by state/possession that
have been archived or require no further remedial action.
CERCLIS and Archived Site Database and Text Files with Record Layout. These databases and text files,
updated monthly, provide detailed information on sites that are currently in CERCLIS and sites that have been
archived or require no further remedial action. The Record Layout identifies and provides the layout of the
fields used.
National Priorities List (NPL) Site Map. The NPL Site Map, updated quarterly, displays the location (based
on latitude and longitude coordinates) of sites across the nation that have been proposed, finalized, or deleted
from the NPL
Several standard reports and products can also be ordered from the Superfund Information Systems area of the EPA
Web site (www.epa.gov/superfund/sites/siteinfo.htm), through the "Order Superfund Products" link on the sidebar.
Reports and products that can be ordered online include:
List 8T- Archive Listing. This report, updated monthly, lists all sites that were previously listed as
contaminated or were suspected of being contaminated, but have subsequently been cleared of contamination
or are no longer suspected of contamination. The report lists the sites/incidents, addresses, and Congressional
districts, and the remedial, removal, and community involvement activities associated with each site/incident.
This report was previously called the "Transition Site/Event Listing."
List 9- Site Comprehensive Listing. This report, updated monthly, lists all Superfund sites/incidents, addresses,
and Congressional districts, and the remedial, removal, and community involvement activities associated with
each site/incident.
SCAP 11- Site Summary Report for NPL Sites. This report, updated quarterly, provides detailed information
on Superfund sites/incidents on the National Priorities List (NPL). Only the sites/incidents that have planned
or actual remedial/removal activities are selected for inclusion on the report. The remedial/removal activities
(planned or actual) as well as the enforcement activities (actual) related to each site/incident are listed.
SCAP 12- Site Summary Report for Non-NPL Sites. This report, updated quarterly, provides detailed
information on Superfund sites/incidents that are not on the NPL. Only the sites/incidents that have planned
or actual remedial/removal activities are selected for inclusion on the report. The remedial/removal activities
(planned or actual) as well as the enforcement activities (actual) related to each site/incident are listed.
CERCLIS Reports CD. Produced quarterly, this CD includes the List 8T, List 9, SCAP 11, and SCAP 12
reports. The reports are produced in PDF format, utilize Adobe Acrobat, and are bookmarked, allowing users
to follow a link directly to a desired report section (e.g., specific state, site) or search for and jump directly to
any word or phrase in the report.
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Superfund Public Information System (SPIS) CD. The SPIS CD contains the complete text of official Records
of Decision (ROD), Explanation of Significant Differences (ESD), and ROD Amendments signed and issued
by EPA. Users are able to access ROD documents by conducting searches across all of the ROD documents
using Adobe's search capabilities and by accessing the master list by EPA Regions of all documents contained
on the CD. This CD is released on a quarterly basis and includes a summary section detailing new information
that has become available since the previous release.
NPL Fact Sheets CD. This CD contains a compilation ofNPL Fact Sheets available from the ten EPA Regional
Web sites, where the fact sheets are stored and updated. NPL Fact Sheets provide site history and descriptions,
NPL listing history, threats and contaminants, cleanup approach, response action status, and environmental
progress. Additionally, some fact sheets include information on community involvement and enforcement
activities.
The Superfund Order and Information Line (800-775-5037 or202-260-8321) is an interactive phone/fax system that
provides information from CERCLIS. By following voice prompts, the Superfund Order and Information Line
allows users to request List 8T, List 9, SCAP 11, and SCAP 12 reports on CD-ROM.
FOIA requests may also be submitted to an EPA region or HQ office for any FOIA reports or information. FOIA
report requests should include the name of the FOIA report being requested, or the site name, city, county, state,
and/or ZIP code for which information is being requested.
E.A.5 DATA OWNERS/SPONSORSHIP
HQ managers are taking an active role in improving the quality of data stored in WasteLAN by acting 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 is captured and stored
properly in WasteLAN. To meet this goal, HQ data sponsors identify their data needs, develop data field definitions,
distribute guidance requiring submittal of these data. Data owners are normally site managers that need the data in
support of site work. 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. Periodically, Data sponsors conduct focused data studies to
determine if there are systematic data problems (e.g., incorrect use of codes, data gaps, etc.) across the regions.
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E.B DATA SPONSORS
The following exhibit identifies the data sponsors for Appendix E, Information Systems.
EXHIBIT E.2
DATA SPONSORS
Data Sponsor
Subject Area
Phone #
Robert King
Project Management
(703) 603-8792
Sherry Clark
Work Planning (Response)
(703) 603-8736
Alice Ludington
Sharon Cullen
Scott Blair
Work Planning (Enforcement)
(202) 564-6066
(202) 564-6023
(202) 564-2256
W illie Griffin
Alan Youkeles
Budget/Financial (Response)
(703) 603-8911
(703) 603-8784
Alice Ludington
Budget/Finaneial (Enforcement)
(202) 564-6066
Richard Jeng
Construction Completion
(703) 603-8749
Mary Bell
Cost Recovery
(202) 564-2256
Rich Norris
Environmental Indicators
(703) 603-9053
Joshua Barber
Brandon Roache
Federal Facilities
(703) 603-0265
(703) 603-8704
Tracey Seymour
Federal Facilities Budget
(703) 603-8712
Lance Elson
Federal Facility Enforcement
(202) 564-2577
Carolyn Kenmore
Final Remedy
(703) 308-8644
Emily Johnson
Silvina Fonseca
5-Yr Review
(703) 603-8764
(703) 603-8799
Janet Weiner
GPRA (OSRTI)
(703) 603-8717
Pat Kennedy
GPRA(OSRE)
(202) 564-6061
Matthew Charsky
Groundwater
(703) 603-8777
David Reynolds
Superfund e-Facts
(703) 603-8895
Michael Bellot
Institutional Controls
9703) 603-8905
Melissa Friedland
Land Ready for Reuse
(703) 603-8864
Shahid Mahmud
Mining Sites
(703) 603-8789
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Data Sponsor
Subject Area
Phone #
Tracy Hopkins
Jennifer Griesert
Post Construction
(703) 603-8788
(703) 603-8888
Scott Blair
PRP D ata
(202) 564-6023
Schatzi Fitz James
Radioactive Sites
(202) 343-9478
Matthew Charsky
Remedial Remedy Selection
(703) 603-8777
Dana Stalcup
Removal/Counter Terrorism
(202) 603-8735
Bill Finan
Dana Robinson
Removal Implementation
(202) 564-7981
(202) 564-8018
David E Cooper
Risk
(703) 603-8763
Randy Elippen
Site Assessment NPL Listing
(703) 603-8829
Filomena Chau
Special Accounts
(202) 5644224
Bob Myers
Tribal Involvement
(703) 603-8851
David Reynolds
FOIA
(703) 603-8895
Alice Ludington
Scott Blair
Mary Bell
SCAP & Enforcement (ENFR) CERCLIS
Reports
(202) 564-6066
(202) 564-6023
(202) 564-2256
John Cunningham
David Reynolds
Data Quality
(703) 603-8708
(703) 603-8895
Robert White
CERCLIS SCAP Reports
(703) 603-8873
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Superfund Program Implementation Manual FY 04/05
Appendix F: Oil Pollution Prevention and Response Program
(Oil Prevention and Response Program is no longer included in the SPIM. Oil
program now assigned to CEPPO.)
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Superfund Program Implementation Manual FY 04/05
Appendix G: Government Performance and Results Act (GPRA)
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Appendix G
Government Performance and Results Act (GPRA)
Table of Contents
G.A. GOVERNMENT PERFORMANCE AND RESULTS ACT (GPRA) OF 1993 G-l
Background G-l
GA.l. Strategic Plan Requirements G-3
a. Comprehensive Mission Statement G-3
b. General Goals and Objectives G-3
c. Description of How General Goals and Objectives Will Be Achieved G-3
d. Goals in the Annual Performance Plan and in a Strategic Plan G-3
e. Key Factors Affecting Achievement of General Goals and Objectives G-3
f. Program Evaluations G-4
GA.2 Annual Performance Plan G-4
a. Performance Goals G-4
b. Resources G-4
c. Performance Indicators G-4
d. Verification and Validation G-4
GA.3. Annual Performance Report G-4
G.B. SUPERFUND GPRA STRUCTURE G-5
G.C. SUBJECT MATTER EXPERTS G-7
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Appendix G
Government Performance and Results Act (GPRA)
G.A GOVERNMENT PERFORMANCE AND RESULTS ACT (GPRA) OF 1993
Superfund's program planning and reporting requirements have evolved and matured in recent years. The National
Goals Project of 2005 and the Chief Financial Officer's (CFO) Act started the evolution of Superfund program
management by shifting the focus from tracking administrative and program outputs to a results-oriented future (e.g.,
Superfund Environmental Indicators) in which the program is held accountable for achieving quantifiable environmental
results. Superfund has continued its evolution towards more outcome-oriented measures under the Congressionally
mandated GPRA, which provides the overarching principles for Superfund program management.
Background
In 1993, Congress enacted the Government Performance and Results Act of 1993 (Public Law 103-62) based on
its findings that:
Waste and inefficiency in Federal programs undermine the confidence of the American people in the
government and reduces the Federal government's ability to adequately address vital public needs;
Federal managers are seriously disadvantaged in their efforts to improve program efficiency and
effectiveness because of insufficient articulation of program goals and inadequate information on program
performance; and
Congressional policy making, spending decisions, and program oversight are seriously handicapped by
insufficient attention to program performance and results.
The purposes of the Act are to:
Improve the confidence of the American people in the capability of the Federal government, by
systematically holding Federal agencies accountable for achieving program results;
Initiate program performance reform with a series of pilot projects in setting program goals, measuring
program performance against those goals, and reporting publicly on their progress;
Improve Federal program effectiveness and public accountability by promoting a new focus on results,
service, quality, and customer satisfaction;
Help Federal managers improve service delivery, by requiring that they plan for meeting program
objectives and by providing them with information about program results and service quality;
Improve Congressional decision making by providing more objective information on achieving statutory
objectives, and on the relative effectiveness and efficiency of Federal programs and spending; and
Improve internal management of the Federal government.
The Government Performance and Results Act (GPRA) holds federal agencies accountable for using resources
wisely and achieving program results. GPRA requires agencies to develop plans for what they intend to accomplish,
measure how well they are doing, make appropriate decisions based on the information they have gathered, and
communicate information about their performance to Congress and to the public.
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The Superfund Remedial Program continually seeks to improve its ability to measure progress in achieving its true
enviromnental mission: to control the risks to human health and the enviromnent at contaminated properties, and to make
land available for reuse.
In FY 2004, the Superfund Remedial Program will measure its progress in achieving enviromnental results
through five key strategic targets. These five strategic targets include: (1) performing site assessments and making
final assessment decisions , (2) selecting final remedies designed to clean up contamination to risk levels that are
protective of human health and the enviromnent and appropriate for reasonably anticipated future land use, (3)
completing construction of the selected remedies, (4) protecting the public from the health effects of exposure to
contamination, (5) controlling the migration of contaminated groundwater. Each strategic target represents an
important milestone in achieving risk reduction; no one measure can itself adequately capture the total enviromnental
benefits derived from the Superfund program.
Strategic targets (1) and (3), above, have been in place for several years. Two of the strategic targets, (4) and (5),
were implemented for the first time in FY 2003. Strategic target (2) is new for FY 2004.
Strategic targets (4) and (5) highlight EPA's efforts to control human exposure pathways and the migration of
contaminated groundwater at NPL and non-NPL sites. In FY 2002, these two strategic targets first provided baseline
information about whether human exposures and the migration of contaminated groundwater are currently under control
under the existing conditions at NPL sites. These two strategic targets focus on the current conditions at sites (i.e.,
current exposures and current land use) and highlight sites where some risk reduction has occurred as a result of EPA's
activities. As such these indicators seek to quantify the benefits resulting from intermediate cleanup and investigative
activities.
The Human Exposure Under Control strategic target is designed to describe whether adequately protective controls
are in place to prevent any unacceptable human exposure under current land and groundwater use conditions only. This
strategic target does not consider potential future land or groundwater use conditions or ecological receptors. As of
September 30, 2002, over 80% of NPL sites had human exposures under control. The Superfund program expects to
control human exposures at an additional 10 sites for FY 2003 and FY 2004.
The Groundwater Migration Under Control strategic target is meant to describe whether the migration of
contaminated groundwater from a Superfund site is being controlled through engineered remedies or natural processes.
As of September 30,2002, the migration of contaminated groundwater was under control at over 60% of NPL sites with
contaminated groundwater. The Superfund program expects to control the migration of contaminated groundwater at
an additional 10 sites for FY 2003 and FY 2004.
The Superfund Remedial program is committed to returning underutilized land to productive reuse through its
cleanup and other actions. Superfund initiated a workgroup in FY 2003 to develop a strategic target for this activity.
As a result of its efforts, Superfund is introducing a GPRA performance measure entitled "Acres of Land Available for
Reuse" in FY 2004. This GPRA performance measure will be tracked under Appendix G, and SCAP 15, even though
this measure is not a strategic target under the Strategic Plan. The purpose of this performance measure is to gather
crucial data to support the ultimate development of a strategic target in the future.
The Superfund Enforcement program will continue to measure its success by applying the "Enforcement First"
strategy and by recovering costs.
Other performance measure related activities include the One Cleanup Program Initiative, in which Superfund is
an active participant. The Measuring for Results component of the One Cleanup Program Initiative involves developing
an unified, cohesive set of performance measures for all cleanup programs. As a result of this effort, Superfund is
introducing Strategic Target (2), which mirrors a similar performance measure used for years in the RCRA program.
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In FY 2004, Superfund will also be working with Regions to extend the traditional and evolving performance
measures, including construction completions, to the Superfund Alternative Sites. The current focus of this effort is
to improve the quality of CERCLIS data, particularly on sites in the alternative universe. A HQ/regional workgroup
is being formed to finalize the approach for tracking and counting construction completions.
G.A.1 Strategic Plan Requirements
Agencies were required to submit their first strategic plan no later than September 1997. The strategic plan must
be updated once every three years or when there are significant policy, programmatic, or other changes to any element
of the current plan. Minor changes to the strategic plan can be incorporated in advance of the three-year cycle by
including the changes in the annual performance plan.
The strategic plan covers a minimum period of six years, beginning in the fiscal year that it is written. The first
EPA strategic plan was published in September 1997 and covered the nine years of FY 1997 through FY 2005. The
latest strategic plan was published in October 2003 and covers the five years of FY 2004 through FY 2008. Strategic
plan elements required by GPRA are as follows:
a. Comprehensive Mission Statement
The mission statement is a brief statement which defines the basic purpose of the agency. It focuses on the core
programs and activities, including a brief discussion of the enabling or authorizing legislation and issues Congress
specifically charged the agency to address.
b. General Goals and Objectives
The strategic plan documents the long-term programmatic, policy, and management goals of the agency, including
the planned accomplishments and the schedule for their implementation. The general goals and objectives elaborate
how the agency will carry out its mission. To the extent possible, this should be in the form of outcome-type goals.
In the EPA strategic plan objectives are broken down into subobjectives to address specific issues not captured in
the broad objective statements. These subobjectives correspond with program result codes (PRCs) in the EPA
planning and budget structure.
The criteria for the general goals and objectives are as follows: (a) the goals/objectives need to be precise in order
to direct and guide the staff to fulfill the mission of the agency; (b) the goals/objectives should be within the
agency' s span of influence; and (c) the goals/obj ectives should be defined in a manner that allows future assessment
to be made on whether the goals/objectives were or are being achieved.
c. Description of How General Goals and Objectives Will Be Achieved
This section describes the means the agency will use to meet the general goals and objectives. This includes, when
applicable: (a) operational processes; (b) skills and technologies; and (c) human, capital, information, and other
resources.
d. Relationship Between Goals in the Annual Performance Plan and in a Strategic Plan
The strategic plan should briefly outline: (a) the type, nature, and scope of performance goals to be included in a
performance plan; (b) the relationship between the performance goals and the general goals and objectives; and ©
the relevance and use of performance goals in helping determine the achievement of general goals and objectives.
e. Key Factors Affecting Achievement of General Goals and Objectives
The strategic plan identifies key external factors that are bey ond the Agency' s control that could significantly affect
the achievement of the general goals and objectives. The external factor needs to be linked to a goal(s) and describe
how the achievement of the goal could be affected by the factor.
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f. Program Evaluations
Program evaluations that were used in preparing the strategic plan should be briefly described. Also, a schedule
for future program evaluations needs to be included.
Development of the strategic plan is considered to be an inherently governmental function; therefore, it can only
be performed by Federal employees.
G.A.2 Annual Performance Plan
Agencies submit an annual performance plan to Congress with the enacted operating plan for each fiscal year. The
performance plan includes:
a. Performance Goals
Objective, quantifiable, and measurable performance goals that define the level of performance to be achieved by
a program activity. At EPA these are called annual performance goals (APGs).
b. Resources
A brief description of the operational processes, skills and technology, and the human, capital, information, or other
resources required to meet performance goals.
c. Performance Indicators
Performance indicators to assess the relevant outputs, service levels, and outcomes of each activity. At EPA these
are called annual performance measures (APMs).
d. Verification and Validation
A basis for comparing actual program results with the established performance goals, and a description of the
methodology to be used to verify and validate measured values.
The development of the annual performance plan is considered to be an inherently governmental function; therefore,
it can only be performed by Federal employees.
G.A.3 Annual Performance Report
Agencies are required to submit an annual performance report to the President and Congress no later than March
3 lof each year. The performance report includes:
The performance indicators in the agency performance plan with a comparison of the program performance
achieved against the performance goal(s) that were set;
A review of the success in achieving the performance goals;
An assessment of the performance plan for the current fiscal year relative to the performance achieved in the
preceding fiscal year;
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An explanation and description where a performance goal was not met, of: (a) why the goal was not met, (b)
plans and schedules for achieving the performance goal; or (c) recommended action if the performance goal
is impractical or infeasible (e.g., current or future funding is inadequate, an unforeseen occurrence impedes
achievement);
A description of the use and effectiveness of a managerial flexibility waiver in achieving the performance goal;
An indication of any individual or organizational consequences resulting from a failure, after using the
waiver, to maintain the previous level of performance;
A brief explanation of the reasons for suspending or ending prematurely any waiver that was in effect for
the fiscal year;
A summary of the program evaluations completed during the fiscal year;
Performance trend data for the three preceding fiscal years. These data will phase into the report (e.g., for FY
00, FY 99 data; for FY 01, FY 99 - FY 00 data; for FY 02, FY 99 - 01 data; for FY 03, FY 00 - 02 data); and
An acknowledgment of the role and a description of the contributions made by non-Federal entities in the
preparation of the report.
Development of the annual performance report is considered to be an inherently governmental function; therefore,
it can only be performed by Federal employees.
G.B. SUPERFUND GPRA STRUCTURE
The following is EPA's planning and budgeting architecture for Superfund appropriations. These correspond to
the 2003 Strategic Plan. Changes to both the architecture and annual performance goals and measures may occur if a
new strategic plan is written or as part of the FY 2004 enacted operating plan process. The strategic plan and FY
2004 budget request can be found on the EPA internet at http://www.epa. gov/ocfopage/ The numerical goals
indicated in each APG are national. Regions negotiate their own specific targets with Headquarters during the
annual work planning sessions held in mid-October.
Goal 3: Land Preservation and Restoration
Preserve and restore the land by using innovative waste management practices and cleaning up contaminated
properties to reduce risks posed by releases of harmful substances.
Objective 3.2: Restore Land
By 2008, control the risks to human health and the enviromnent by mitigating the impact of accidental or intentional
releases and by cleaning up and restoring contaminated sites or properties to appropriate levels.
Sub-objective 3.2.1: Prepare for and Respond to Accidental and Intentional Releases
By 2008, reduce and control the risks posed by accidental and intentional releases of harmful substances by
improving our Nation's capability to prepare for and respond more effectively to these emergencies.
Strategic Targets:
Each year through 2008, improve the Agency's emergency preparedness by achieving and maintaining the
capability to respond to simultaneous large-scale emergencies and by increasing response readiness by 10
percent from a baseline established by the end of 2003 using the core emergency response criteria.
Each year through 2008, respond to 350 hazardous substance releases and 300 oil spills.
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Each year through 2008, minimize impacts of potential oil spills by inspecting or conducting exercises or drills
at 6 percent of approximately 6,000 oil storage facilities required to have Facility Response Plans. (Between FY
1997 and FY 2002, 30 percent of these facilities were inspected.)
Sub-objective 3.2.2: Clean Up and Reuse Contaminated Land
By 2008, control the risks to human health and the enviromnent at contaminated properties or sites through cleanup,
stabilization, or other action, and make land available for reuse.
Strategic Targets:
By 2008, perform 88,000 health and environmentally based site assessments and make 41,700 final-assessment
decisions under Superfund, and assess 100 percent (approximately 1,714) RCRA baseline facilities. Universe of
RCRA baseline facilities will be evaluated and, if necessary, adjusted in FY 2004.
By 2008, control all identified unacceptable human exposures from site contamination to at or below health-
based levels for current land and/or ground-water use conditions at 95 percent (approximately 1,628) of RCRA
baseline facilities and 84 percent (1,259) of 1,494 Superfund human exposure sites (as of FY 2002).
By 2008, control the migration of contaminated ground water through engineered remedies or natural
processes at 80 percent (approximately 1,371) of RCRA baseline facilities and 65 percent (832) of 1,275
Superfund ground-water exposure sites (as of FY 2002).
By 2008, select final remedies (cleanup targets) at 30 percent (approximately 514) of RCRA baseline facilities
and approximately 82 percent (1,223) of 1,498 Superfund sites (as of FY 2002).
By 2008, clean up and reduce the backlog of approximately 140,000 leaking UST sites by 50 percent, and
complete construction of remedies at 20 percent (approximately 343) of RCRA baseline facilities and
approximately 72 percent (1,086) of 1,498 Superfund sites (as of FY 2002). (Construction completion is a
benchmark used to show that all significant construction activity has been completed, even though additional
remediation may be needed for all cleanup goals to be met.)
Sub-objective 3.2.3: Maximize Potentially Responsible Party Participation at Superfund Sites
Through 2008, conserve Superfund trust fund resources by ensuring that potentially responsible parties conduct or
pay for Superfund cleanups whenever possible.
Strategic Targets:
Each year through 2008, reach a settlement or take an enforcement action before the start of a remedial action
at 90 percent of Superfund sites having viable, liable responsible parties other than the federal government.
Each year through 2008, address all Statute of Limitations cases for Superfund sites with unaddressed total
past costs equal to or greater than $200,000.
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G. C SUBJECT MATTER EXPERTS
The following table identifies the subject matter experts for Appendix G.
EXHIBIT G.l SUBJECT MATTER EXPERTS
Subject Matter Expert
Subject Area
Phone #
Richard Jeng/
Rafael Gonzalez
Construction Completion
(703) 603-8749
(703) 603-8892
Patricia Kennedy
Enforcement
(202) 564-6061
Melanie Hoff
Environmental Indicators
(703) 603-8808
Lance Elson
Federal Facility Enforcement
(202) 564-2577
Augusta Wills
Federal Facility Enforcement
(202) 564-2468
Joshua Barber
Federal Facility Response
(703) 603-0265
Robin M Anderson/
Carolyn Keninore
Final Remedy Selection
(703)603-8714
(703) 308-8644
Melissa Friedland
Land Re-use
(703) 603-8864
Janet Weiner
OSRTI/GPRA
(703)603-8717
Terry Eby/
Dana Stalcup/
Charlotte Englert
Removals
(703) 603-8741
(703) 603-8725
(202) 564-8888
Robert White
Response Appendix Coordinator
(703)603-8873
Angelo Carasea
Site Assessment
(703) 603-8828
Bill Ross
Site Assessment
(303) 312-7007
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Superfund Program Implementation Manual FY04/05
Appendix H: Community Involvement
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Appendix H
Community Involvement
Table of Contents
H.A FY04/05 TARGETS AND MEASURES II-l
H.A.I Overview of FY04/05 Community Involvement Targets/Measures H-l
a. Community Advisory Groups (CAGs)/Restoration Advisory Boards (RABs)/
Site-Specific Advisory Boards (SSABs) H-l
b. Technical Assistance Grants (TAGs) H-2
c. Technical Outreach Services for Communities (TOSC) H-3
H.B CIOC DATA SPONSOR RESPONSIBILITIES 11-3
H.B. 1 Role of CIOC as a Data Sponsor H-3
H.B.2 National Program Requirements and the Data Sponsor Role H-4
Program Goals and Objectives H-4
Statutory Mandates H-4
Regulatory and Policy Requirements H-4
Superfund Reforms H-ll
Reauthorization. Congressional Inquiries and Audits H-ll
H.B.3 CIOC Headquarters and Regional Organization H-ll
H.B.4 Program Monitoring and Reporting H-12
Data Quality H-12
Management Reports H-l3
Coding Guidance H-l3
Modifications H-l3
H.C Subject Matter Experts H-13
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Appendix H
Community Involvement
List of Exhibits
EXHIBIT H.l COMMUNITY INVOLVEMENT REQUIREMENTS 11-5
EXHIBIT H.2 CIOC HQ AND REGIONAL ROLES AND RESPONSIBILITIES H-12
EXHIBIT H.3 SUBJECT MATTER EXPERTS 11-13
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APPENDIX H
COMMUNITY INVOLVEMENT
H.A FY04/05 TARGETS AND MEASURES
H.A.I OVERVIEW OF FY04/05 COMMUNITY INVOLVEMENT TARGETS/MEASURES
The Superfund Comprehensive Accomplishments Plan (SCAP) is used by the Assistant Administrator for the Office of
Solid Waste and Emergency Response (AA OSWER), Assistant Administrator for the Office of Enforcement and
Compliance Assurance (AA OECA), and senior Superfund managers to monitor the progress each Region is making
towards achieving the GPRA targets and annual performance goals. Actual GPRA objectives do not include any
community involvement activities.
The following pages contain the definitions of the FY04/05 community involvement activities:
Community Advisory Group Program, Restoration Advisory Group Program, Site Specific Advisory Group Program,
Technical Assistance Grant Program, and Technical Outreach Services for Communities.
a. COMMUNITY ADVISORY GROUPS (CAGs)/RESTORATION ADVISORY BOARDS
(RABs)/SITE-SPECIFIC ADVISORY BOARDS (SSABs)
Definition:
Community Advisory Groups (CAGs) are public forums for people with diverse community interests to formally present
and discuss their needs and concerns about a site in their neighborhood. CAGs may receive help from EPA; State, Tribal
and local governments; and universities in such areas as supporting and participating in training, and assisting with
administrative support and meeting facilitation.
Site-Specific Advisory Boards (SSABs) are a forum for experts and concerned stakeholders to provide advice and
recommendations on DOE's Environmental Management strategic decisions. Restoration Advisory Boards (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.
Definition of Accomplishment:
CAG Established Date: The establishment of the Community Advisory Group is defined as the date (Actual Start) of
the first meaningful (not interest finding) Community Advisory Group Meeting (Action Name = Community Advisory
Group).
CAG Closeout Date: Date CAG (Action Name = Community Advisory Group) is completed/closed out (Actual
Complete) by EPA and the CAG.
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RAB/SSAB Start (Established)Date: The actual start of the RAB/SSAB is defined as the actual start date (Actual Start)
of the initial RAB/S SAB information meeting (SubAction Name = Site-Specific Advisory Board Meeting or Sub Action
Name = Restoration Advisory Board Meeting).
RAB Completion (Adjourned) Date: The actual completion (Actual Complete) date of the 'Restoration Advisory Board'
(SubAction Name = Restoration Advisory Board) is the date the RAB is adjourned by DoD.
SSAB Completion (Terminated) Date: The actual completion (Actual Complete) date of the 'Site-Specific Advisory
Board' (SubAction Name = Site-Specific Advisory Board) is the date the SSAB is terminated by the Secretary of Energy.
Changes in Definition FY02/03 - FY04/05:
Added definition for CAG Closeout date. Modified RAB and SSAB start definition.
Special Planning/Reporting Requirements:
None
b. TECHNICAL ASSISTANCE GRANTS (TAGs)
Definition:
The Superfund Amendments and Reauthorization Act of 1986 (SARA) established the T AG program to provide technical
assistance to eligible communities. This technical assistance allows communities to improve the decision making process
at their sites.
Definition of Accomplishment:
The start of the TAG (Action Name = Technical Assistance Grant) is the date the award document is signed by the
regional award official. For Superfund programmatic purposes, the completion of the TAG is the ending date of the
budget and project period as documented in the award document; as documented in the one year extension document;
as documented in a time period extension document; or as documented in other documents, such as a memo to the file
prepared by the TAG coordinator to document these decisions. The planned or actual completion date in CERCLIS
(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 CERCLIS data,
including data prior to FY 89, which is the first fiscal year TAG appeared in the SPIM. In addition, the TAG completion
definitions from previous years may also be used for TAGs completed within those years.
Changes in Definition FY02/03 - FY04/05:
Updated TAG language for definition of start and definition of completion.
Special Planning/Reporting Requirements:
TAG is a program measure. Planned start and completion dates are required in WasteLAN. 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 AOA.
c. TECHNICAL OUTREACH SERVICES FOR COMMUNITIES (TOSC)
Definition:
TOSC provides independent scientific and technical assistance to communities dealing with hazardous substance
contamination questions. TOSC provides information and education to empower communities with an understanding
of technical issues to more effectively participate in environmental decisions. TOSC is a service of the university-based
Hazardous Substance Research Centers (HSRCs) which are, in part, supported by grants from EPA.
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Definition of Accomplishment:
The start of the TOSC is the date when the MOU (Memorandum of Understanding) is signed, which is the date of the
commitment between the community and the HSRCs. The date the MOU is signed should be reported in WasteLAN
as the actual start date (Actual Start) of the TOSC (Action Name = Technical Outreach Services to Communities).
Changes in Definition FY02/03 - FY04/05:
None
Special Planning/Reporting Requirements:
The Region must indicate on the Community Organizations Information screen that the organization is a TOSC recipient.
H.B CIOCDATA SPONSOR RESPONSIBILITIES
H.B.1 ROLE OF CIOC AS A DATA SPONSOR
This document clarifies the relationship among data sponsors and data owners. Under the direction of the Community
Involvement and Outreach Center (CIOC), this document presents Superfund data and reporting requirements needed
to accomplish the following goals:
Enhance discussion among data sponsors and data owners;
Improve data quality; and
Update Superfund reporting requirements by fully employing the information in WasteLAN to meet all statutory
and management reporting requirements (e.g., CFO Act, CERCLA) on a real-time basis.
In the past, Headquarters has pulled CERCLIS data on the fifth working day of each month to support national reporting
and significant calendar events. During FY 97, WasteLAN was implemented nationally and is the official data source
for all national reporting. The transition to WasteLAN enables EPA to conduct real-time reporting which requires data
to be current, complete, and consistent. Real-time reporting supports ad hoc requests, as well as statutory and
management reporting requirements.
Community Involvement data are to be made available to Headquarters to support the purpose and to assist the data
sponsor in meeting the program objectives. Significant calendar events for Community Involvement are included to
identify what is current (i.e., reporting, special initiatives, etc.), complete (i.e., planned project schedules), and consistent
with programmatic drivers.
H.B. 2 NATIONAL PROGRAM REQUIREMENTS AND THE DATA SPONSOR ROLE
The following statutory, policy, and management requirements establish the mandate for meeting the program
requirements described in the rest of this Appendix. A description of program goals and objectives, statutory mandates,
regulatory and policy requirements, as well as subsequent program reforms and redirection in measuring program results
are included in this section.
Program Goals and Objectives
The goal of Superfund's community involvement program is to encourage communications with affected citizens and
participation in decision-making. Community involvement is not a phase in Superfund, like a removal or remedial
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cleanup action, but rather it is an integral part of the entire process that benefits both the public and EPA. The program
has three main objectives:
Giving the public the opportunity to comment on and provide input into technical decisions that affect their lives;
Informing the public of planned or ongoing activities and keeping them apprised of the nature of the environmental
problem, the threats it may pose, the responses under consideration, and the progress that is being made; and
Focusing and resolving conflict (conflict may be unavoidable in some circumstances, but it can be constructive if
it brings into the open alternative viewpoints).
Statutory Mandates
Sections 113, 117, and 122 of CERCLA, as amended by the Superfund Amendments and Reauthorization Act (SARA), established eight principle
requirements for community involvement:
Developing a locally available administrative record;
Establishing a locally available information repository;
Notifying the public of the release of the Remedial Investigation/Feasibility Study (RI/FS) and Proposed Plan, and
in the case of removal actions with a planning period of at least six months, the engineering evaluation/cost analysis
(EE/CA);
Providing a public comment period on the RI/FS, Proposed Plan, and EE/CA;
Holding a public meeting on the RI/FS and Proposed Plan; Developing a meeting transcript;
Providing notice and comment period on the Administrative Order on Consent or Consent Decree; and
Developing a responsiveness summary on comments received on the RI/FS, Proposed Plan and EE/CA.
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 presented Exhibit H.2.
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EXHIBIT H.l
COMMUNITY INVOLVEMENT REQUIREMENTS
Site Activity
Req uirement(s)
Citation (Source)
For All Removal Actions
Designate an Agency
Spokesperson (Community
Involvement Coordinator)
The Agency must designate a spokesperson to inform the public
about the release and actions taken, to respond to questions, and
to notify immediately affected citizens, State and local officials
and, when appropriate, civil defense or emergency management
agencies.
NCP, Section 300.415(m)(l)
Administrative Record
The Agency must establish an administrative record and make
the administrative record available to the public at a central
location at or near the site, if applicable.
SARA Section 113(k); NCP Section
300.820
For Removal Actions with Planning Period of Less Than Six
Months
Notice and Availability of
Administrative Record
Within 60 days of the start of on-site removal activity, the lead
Agency must make the administrative record available to the
public and issue a notice of availability in a major local
newspaper of general circulation.
NCP Sections
300.415(m)(2)(I) and
300.820(b)(1)
Public Comment Period
The Agency must provide a public comment period, if
appropriate, of not less than 30 days from the time the
administrative record is made available for public inspection.
NCP Section 300.415(m)(2)(ii)
Response to Significant
Comments
The Agency must prepare a written response to significant
comments.
NCP Section
300.415(m)(2)(iii)
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Site Activity
Req uirement(s)
Citation (Source)
For Removal Actions Expected to Extend Beyond 120 Days
Community Interviews
By the end of the 120-day period, the Agency must conduct
interviews with local officials, public interest groups, or other
interested parties to determine their concerns and information
needs, and to learn how citizens would like to be involved in the
Superfund process.
NCP Section 300.415(m)(3)(I)
Community Involvement
Plan
(CIP)
The Agency must prepare a CIP, based on community interviews
and other relevant information, that specifies the community
involvement/outreach activities the Agency plans to undertake
during the response. The Agency must complete this CIP within
120 days of the start of on-site removal activity.
NCP Section 300.415(m)(3)(ii)
Information Repository
Establishment and
Notification/
Notice of Availability of
Administrative Record
Within 120 days of the start of on-site removal activity, the
Agency must establish at least one information repository at or
near the location of removal actions that contains items available
for public inspection and copying. The Agency must inform the
public of the establishment of the information repository and
provide notice of the availability of the administrative record in
the repository.
NCP Section 300.415(m)(3)(iii)
For Removal Actions with a Planning Period
of at Least Six Months
Community Interviews and
Community Involvement
Plan
(CIP)
The Agency must follow the same procedures as outlined in the
previous section, except that staff must conduct interviews and
prepare a CIP prior to completion of the engineering
evaluation/cost analysis (EE/CA)
NCP Section 300.415(m)(4)(I)
Information Repository
Establishment and
Notification/
Notice of Availability of
Administrative Record
The Agency must follow the same procedures as outlined in the
previous section, except that staff must establish the information
repository and make the administrative record available no later
than the signing the EE/CA approval memorandum
NCP Section 300.415(m)(4)(I)
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Site Activity
Req uirement(s)
Citation (Source)
For Removal Actions with a Planning Period
of at Least Six Months
Notice of Availability/
Description of EE/CA
The Agency must publish a notice of availability and a brief
description of the EE/CA in a major local newspaper of general
circulation.
NCP Section 300.415(m)(4)(ii)
Public Comment Period
Upon completion of the EE/CA, the Agency must provide at
least 30 days for the submission of written and oral comments.
The Agency must extend this comment period at least 15 days
upon timely request.
NCP Section 300.415(m)(4)(iii)
Responsiveness Summary
The Agency must prepare a written response to significant
comments and make this responsiveness summary available to
the public in the information repository.
NCP Section 300.415(m)(iv)
Remedial Responses
Prior to Remedial Investigation (RI)
Community Interviews
The Agency must hold on-site discussions with local officials
and community members to assess their concerns and determine
appropriate community involvement activities.
NCP Section 300.430(c)(2)(I)
Community Involvement
Plan
(CIP)
The Agency must develop and approve a complete CIP based on
community interviews before RI field activities start.
NCP Section 300.430(c)(2)(ii)
(A-C)
Information Repository
The Agency must establish an information repository to contain
items developed, received, published, or made available pursuant
to SARA Section 117. The Agency must make these items
available for public inspection and copying and inform
interested citizens of the establishment of the information
repository.
SARA Section 117(d); NCP Section
300.430(c)(2)(iii)
Technical Assistance Grant
(TAG) Notification
The Agency must inform the public of the availability of TAGs
and include in the information repository material that describes
the TAG application process.
NCP Section 300.430(c)(2)(iv)
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Site Activity
Req uirement(s)
Citation (Source)
Upon Commencement of Remedial Investigation
Administrative Record
The Agency must establish an administrative record. The
Agency must consider the participation of interested persons
when developing the administrative record.
SARA Section 113(k); NCP Section
300.815
Administrative Record
Notification
The Agency must publish a notice of availability of the
administrative record in a major local newspaper of general
circulation.
NCP Section 300.815
Upon Completion of the Feasibility Study (FS) and Proposed
Plan
RI/FS and Proposed Plan
Notification and Analysis
The Agency must publish a notice of the availability of the
RI/FS and proposed plan, including a brief summary of the
proposed plan, in a major local newspaper of general circulation.
The notice also must announce a comment period.
SARA Section 117(a); NCP Section
300.430(f)(3)(I)(A)
Public Comment Period on
RI/FS and Proposed Plan
The Agency must provide at least 30 days for the submission of
written and oral comment on the RI/FS and proposed plan. This
comment period will be extended by a minimum of 30 additional
days upon timely request.
SARA Section 117(a)(2); NCP Section
300.430(f)(3)(c)
Public Meeting
The Agency must provide an opportunity for a public meeting to
be held at or near the site during the comment period.
SARA Sections 113 and 117(a)(2); NCP
Section 300.430(f)(3)(I)(E)
Meeting Transcript
The Agency must prepare a meeting transcript and make it
available to the public.
SARA Section 122(1); NCP Section
300.430(c)(5)(I)
Responsiveness Summary
The Agency must prepare a response to significant comments,
criticisms, and new data submitted on the proposed plan and
RI/FS, and ensure that this response document accompanies the
ROD.
SARA Sections 113 and 117(b); NCP
Section 300.430(f)(3)(I)(F)
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Site Activity
Req uirement(s)
Citation (Source)
Pre-ROD Significant Changes
Discussion of Significant
Changes
Upon determination that such changes could be reasonably
anticipated by the public, the Agency must include in the ROD a
discussion of significant changes and the reasons for such
changes.
NCP Section 300.430(f)(3)(ii)(A)
Revised Proposed Plan and
Public Comment
Upon determination that such changes could not have been
reasonably anticipated by the public, the Agency must issue a
revised proposed plan that includes a discussion of the
significant changes and the reasons for such changes. The
Agency must seek additional public comment on the revised
proposed plan.
NCP Section 300.430(f)(3)(ii)(B)
After the ROD is Signed
ROD Availability and
Notification
The Agency must make the ROD available for public inspection
and copying at or near the site prior to the commencement of any
remedial action. Also, the Agency must publish a notice of the
ROD's availability in a major local newspaper of general
circulation. The notice must state the basis and purpose of the
selected action.
NCP Section 300.430(f)(6)
Revision of the CIP Site
Activity
Prior to the remedial design, the Agency should revise the CIP,
if necessary, to reflect community concern, as discovered during
interviews and other activities, that pertains to the remedial
design and construction phase.
NCP Section 300.435(c)(1)
Post-ROD Significant Changes
Differs significantly from remedy in terms of scope,
performance, or costs:
Notice and Availability of
Explanation of Significant
Differences
The Agency must publish a notice that briefly summarizes the
explanation of significant differences and the reasons for such
differences in a major local newspaper, and make the
explanation of significant differences and supporting
information available to the public in the administrative record
and information repository.
NCP Section 300.435(c)(2)(I)(A) and (B)
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Site Activity
Req uirement(s)
Citation (Source)
Post-ROD Significant Changes (cont'd)
Fundamentally alters the basic features of the selected remedy
with respect to scope,
performance, or cost;
Notice of Availability/Brief
Description of Proposed
ROD Amendment
The Agency must propose an amendment to the ROD and issue a
notice of availability and a brief description of the proposed
amendment in a major local newspaper of general circulation.
NCP Section 300.435(c)(2Xii)(A)
Public Comment Period,
Public Meeting, Meeting
Transcript, and
Responsiveness Summary
The Agency must follow the same procedures as that required
for completion of the FS and proposed plan.
NCP Section 300.435(c)(2XiiXB)-(F)
Notice and Availability of
Amended ROD
The Agency must publish a notice of availability of the amended
ROD in a major local newspaper and make the amended ROD
and supporting information available for public inspection and
copying in the administrative record and information repository
prior to commencement of the remedial action affected by the
amendment.
NCP Section 300.435(c)(2Xii)(G) and (H)
Remedial Design (RD)
Fact Sheet and Public
Briefing
Upon completion of the final engineering design, the Agency
must issue a fact sheet and provide a public briefing, as
appropriate, prior to beginning remedial action.
NCP Section 300.435(c)(3)
NPL Additions
Publication of Proposed
Rule and Public Comment
Period
EPA must publish the proposed rule in the Federal Register and
seek comments through a public comment period.
NCP Section 300.425(d)(5)(I)
Publication of Final Rule
and Response to Comments
EPA must publish the final rule in the Federal Register and
respond to significant comments and significant new data
submitted during the public comment period.
NCP Section 300.425(d)(5)(ii)
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Site Activity
Req uirement(s)
Citation (Source)
NPL Deletions
Public Notice and Public
Comment Period
EPA is required to publish a notice of intent to delete in the
Federal Register and provide notice of the availability of this
announcement in a major local newspaper. EPA must also
provide a comment period of at least 30 days on the proposed
deletion.
NCP Section 300.425(e)(4)(I) and (ii)
Public Access to
Information
Copies of information supporting the proposed deletion must be
placed in the information repository for public inspection and
copying.
NCP Section 300.425(e)(4)(iii)
Response to Significant
Comments
EPA must respond to each significant comment and any
significant new data submitted during the comment period and
include these responses in the final deletion package.
NCP Section 300.425(e)(4)(iv)
Availability of Final
Deletion Package
The final deletion package must be placed in the local
information repository once the notice of final deletion has been
published in the Federal Register.
NCP Section 300.425(e)(5)
Superfund Reforms
Since 1993, EPA has launched three round of reforms to address criticisms raised by affected parties and to improve the
pace, cost and public participation aspects of the program. Each set of reforms consists of various initiatives and pilots
focusing on changes to the program that can be implemented within the existing statutory framework. The following
are reforms related to the Community Involvement area: Community Advisory Groups; Technical Assistant Grants
(TAGs), Community Involvement in the Enforcement Process Pilots, Pilot Remedy Selection by Selected States and
Tribes, Pilot Community Based Remedy Selection Superfund Ombudsman in Every Region, and Improve
Communication with Superfund Stakeholders.
Reauthorization, Congressional Inquiries, and Audits
Waste LAN is the primary data source to support Reauthorization and Congressional inquiries, as well as questions from the Inspector General (IG),
and General Accounting Office (GAO). An example of inquires specific to the Community Involvement program area is the number of Technical
Assistance Grants provided.
H.B.3 CIOC HEADQUARTERS AND REGIONAL ORGANIZATION
To meet these national program requirements, specific roles and responsibilities have been identified for the
Headquarters' and Regional staff that work in the Community Involvement program area. The table below summarizes
each of these positions along with their responsibilities.
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EXHIBIT H.2
CIOC HQ AND REGIONAL ROLES AND RESPONSIBILITIES
Title
Responsibilities
Community Involvement and Outreach
Center (CIOC) (HQ)
Facilitate WasteLAN 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 gathering, reviewing and entering the data into WasteLAN.
Director, CIOC (HQ)
Provide a synergy to create useful program policy and guidance to help the Regions achieve
program goals. Act as the central point of contact for the Regions and is responsible for
providing Regional coordination support.
CIOC Staff (HQ) and Community
Involvement Managers (CIMs) (Regions)
Participate in program reviews, as well as prepare periodic reports on Regional
accomplishments, progress on problems, and respond to quick tum-around, site specific
requests for information from senior management for Congressional requests, Regional visits or
other needs. Serves as a forum for sharing information, lessons learned and issues on
community involvement activities.
CIMs, Remedial Project Managers
(RPMs) and On Site Coordinators (OSCs)
(Regions)
Ensure all data necessary to meet the requirements(s) are in WasteLAN to support their
Regional reporting needs and commitments to Headquarters.
Community Involvement Coordinators
(CICs) (Regions)
As the data owner, provide current, complete, and consistent data into WasteLAN that are
necessary to met real-time reporting requirements and review data that are provided in hard
copy or electronically submitted.
Information Management Coordinator
(IMC) (Regions)
Coordinate with the CICs to ensure all data necessary to support reporting requirements are in
WasteLAN on a real-time basis.
Budget Coordinator (Regions)
Ensure all data necessary to support the Regional budget are in WasteLAN prior to specified
calendar events.
H.B.4 PROGRAM MONITORING AND REPORTING
Each reporting and associated data acquisition requirement specific to Community Involvement is discussed below.
The detail includes: data quality objectives, data needs, as well as reports and associated coding guidance.
Data Quality
One of the goals of the Community Involvement data sponsor is to ensure data quality which requires data to be correctly
entered into WasteLAN. Although the methodology of acquiring and reviewing data may change over time, both will
contain a quality assurance (QA) process to ensure data quality.
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Current, complete, and consistent data in WasteLAN will meet the Community Involvement data sponsor goals and
objectives, as well as support real-time reporting. The following defines what the Community Involvement data sponsor
views as current, complete, and consistent data:
Current - Data need to be entered as actions occur.
Complete - For the particular data element, all needed information is provided.
Consistent - Data should be consistent nationally. Also, within WasteLAN, data should be entered consistent
with the data element definitions. The data entered should be entered using the same standard across all
Regions/HQ.
Management Reports
SCAP-04 (TAGs)
WasteLAN provides the data necessary to support ad hoc requests as they relate to Reauthorization, GAO, and IG.
Coding Guide
The coding guidance for SCAP measures will be reflected in the Coding Guide.
Modifications (since last update)
Send all proposed changes to the appropriate data sponsor for review and approval and copy the Regional IMC. After
the review of the proposed changes is completed, the data sponsor will send the changes to Robert White for review by
Headquarters and Regional principals including Subject Matter Experts, Data Sponsors, and Senior Process Managers,
if applicable. The preferred method is to mark-up a photo-copy of text you seek to change. The SPIM is a numbered
EPA publication in loose leaf 3-ring binder format so that changes can be incorporated accordingly.
H. C Subject Matter Experts
The following exhibit identifies the subject matter experts for Appendix H, Community Involvement.
EXHIBIT H.3 Subject Matter Experts
Subject Matter Expert
Subject Area
Phone #
Leslie Leahy
Community Involvement
(703) 603-9929
Suzanne Wells
Community Involvement
(703) 603-8863
Freya Margand
TAGs
(703) 603-8889
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Superfund Program Implementation Manual FY 04/05
Appendix J: Tribal Involvement
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Appendix J
Tribal Involvement
OSWER Directive 9200.3-14-1G-Q
Table of Contents
J. A. BUILDING SUPERFUND PARTNERSHIPS
J.A.I. Enhanced State and Tribal Capabilities J-l
J. A.2. Superfund Block Funding/EPA Performance Partnership Grants J-2
J.A.3. Funding for States and Tribes J-2
J.B. FY 04/05 TARGETS AND MEASURES
J.B.I. Overview J-2
a. Superfund Assessments Conducted at Sites that are of Concern to Tribes (Current
FY/Inception to Date) J-3
b. Percentage of Sites that are of Concern to Tribes which have had a Superfund
Assessment J-4
c. Tribes Supported by Superfund Cooperative Agreements J-4
d. Superfund Dollars Provided for Building Tribal Capacity J-5
e. Percentage of Superfund Sites that are of Concern to Tribes Where a Tribe is Actively
Involved J-5
J.C. SUBJECT MATTER EXPERTS J-6
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Appendix J
Tribal Involvement
List of Exhibits
EXHIBIT J. 1. TRIBAL INVOLVEMENT ACTIVITIES J-3
EXHIBIT J.2. SUBJECT MATTER EXPERTS J-6
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APPENDIX J
TRIBAL INVOLVEMENT
J.A. BUILDING SUPERFUND PARTNERSHIPS
FY04/05 goals to support building Superfund partnerships and leveraging existing resources are:
Provide tools for regions to use to promote and continue early community involvement in key cleanup
decisions, specifically regarding land use, risk assessment, and RODs;
Work with state, tribal, and business associations to determine ways to improve their capabilities to clean up
hazardous substances and respond to spills; and
Implement a cooperative program with oil companies to prevent and respond to leaking above ground tanks.
Initiatives include continuing the implementation of the Brownfields Economic Redevelopment Initiative and
SRP, enhancing the state/tribal role, providing states/tribes with increased funding allocation decision authority,
clarifying the policy for NPL listings and deletions of sites based on RCRA deferral, and providing states and
tribes with an increased role in remedy selection.
J.A.I. ENHANCED STATE AND TRIBAL CAPABILITIES
States and Indian tribes are key partners in the cleanup of Superfund hazardous waste sites. Regions should continue
their efforts to enhance the role of states and tribes in the Superfund program. HQ strongly encourages the use of the
full range of cooperative agreements to provide financial support for state and tribal Superfund programs and site-
specific involvement in NPL and non-NPL sites. In particular, core funding is critical to develop, maintain and
enhance states' and tribes' capacity to manage and implement CERCLA responses.
During FY 99-00, all regions participated in the National effort to pilot the "Plan to Enhance the Role of States and
Tribes in the Superfund Program." In a January 2001 memorandum and accompanying evaluation report, HQ shared
the lessons learned from pilot implementation with the regions, and provided direction for future on-going efforts to
enhance EPA's partnership with states and tribes in the implementation of Superfund.
In FY 00, OERR developed four new annual performance measures (APM) for tribes under GPRA Goal 5.2.2:
Respond to Superfund Hazardous Waste Sites, Objective 1. These were implemented as reporting APMs in FY 01.
OERR will continue to emphasize increasing the number of Indian tribes participating in the Superfund program, as
expressed through the number of tribes supported by Superfund cooperative agreements (APM 1). This will be
evidenced by an increase in the number of site assessments (PA/SI) conducted in Indian Country (APM 2), the
amount of funding for building tribal capacity (APM3), and the percentage of Superfund sites impacting Indian
country where a tribe is involved as either the lead or support agency (APM 4). OERR manually gathered the
information directly from the regions to establish a baseline for these performance measures for FY 02. As of FY
03, two new special initiative indicators, Tribal Concern (TC) and Tribal Involvement (TI), have been added to
WasteLAN to aid in tracking these measures.
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J.A.2. SUPERFUND BLOCK FUNDING/EPA PERFORMANCE PARTNERSHIP
GRANTS
EPA has developed an Agency-wide system for providing states/tribes with increased funding allocation decision
authority. The National Environmental Performance Partnership System (NEPPS) establishes a structure for
Performance Partnership Grants (PPG), a single grant made to a state or tribe from grant funds allocated and
otherwise available for existing categorical grants programs. PPGs are voluntary and provide states and tribes with
the option to combine funds from two or more categorical grants into one or more PPG(s).
By statute, Superfund monies cannot be included in PPGs, however Superfund is utilizing consolidated (aka, block)
cooperative agreement funding to move in a direction consistent with PPGs. EPA will be working to encourage
further progress toward the goals of flexible funding within the context of strong program commitments to
Superfund outcomes. The Superfund cooperative agreement regulation, Subpart O, is being revised to facilitate use
of consolidated funding where appropriate.
J.A.3. FUNDING FOR STATES AND TRIBES
For FY 04/05 it is important that regions provide funding for state and tribal Core needs at a level approximately
equivalent to the FY 1996-2001 average annual funding, within available resources. If, due to resource constraints
or a reduced level of eligible state/tribal Core needs, regions plan to fund a state or tribe at less than 90% of the FY
1996-2001 average level for that state or tribe, notification to Headquarters is required.
Starting in FY03, Superfund Core Program Cooperative Agreements will no longer be the vehicle for funding the
Brownfields Voluntary Cleanup Program. Due to the passage of the new Brownfields law (Public Law 107-118), FY
04/05 funding for state and tribal response programs (which includes Brownfields VCP's) will be provided under the
authority of CERCLA 128(a). If the President's FY 04/05 budget passes, the CERCLA 128 grant program will be
financed from new appropriations under categorical State and Tribal Assistance Grants (STAG) money, not Superfund
money. Superfund money from FY02 and before that was allocated to Brownfields Voluntary Cleanup Programs or
Targeted Brownfields Assessments (including money that is deobligated and reobligated) may continued to be used in
Superfund Core Program Cooperative Agreements. Please note that this Brownfields-related Superfund money may not
be used to fund CERCLA 128(a) cooperative agreements with states and tribes.
J.B. FY 04/05 TARGETS AND MEASURES
J.B.I. OVERVIEW
There are five measures which illustrate the extent to which the Superfund Program is active at sites which are of
concern to tribes and the level of involvement of the tribes at those sites. The universe of sites considered for these
measures is all Superfund sites-including NPL, NPL-equivalent, removal, and emergency response-which are of
concern to a tribe, regardless of where the site is located in relation to tribal lands. These sites are determined by the
site manager and regional tribal liaisons, in discussions with the tribes, and are identified in WasteLAN by use of the
tribal flag [Special Initiative = Tribal Concern], Regions should enter this flag when a site is first entered into
WasteLAN or at any point after that at which a tribe expresses that the site is of concern to them.
Brownfields sites which are of concern to tribes are not included in these Superfund measures.
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EXHIBIT J.l.
TRIBAL INVOLVEMENT ACTIVITIES
ACTIVITY
GPRA
PROGRAM
APG
APM
Target
Measure
Superfund Assessments Conducted at Sites that are
of Concern to Tribes (Current FY/Inception to Date)
/
Percentage of Sites that are of Concern to Tribes which
have had a Superfund Assessment
/
Tribes Supported by Superfund Cooperative
Agreements
/
Superfund Dollars Provided for Building Tribal
Capacity
/
Percentage of Superfund Sites that are of Concern to
Tribes where a Tribe is Actively Involved
/
a. SUPERFUND ASSESSMENTS CONDUCTED AT SITES THAT ARE OF CONCERN
TO TRIBES (CURRENT FY/INCEPTION TO DATE)
Definition:
This measure counts all Superfund assessments conducted at sites that are of concern to tribes, regardless of whether
USEPA, a state, or a tribe performs the assessment.
Definition of Accomplishment:
This number includes all types of assessments-including preliminary assessments (Action Name = Preliminary
Assessment), site inspections (Action Name = Site Inspection), combined PA/SIs (Action Name = Combined
PA/SI), expanded site inspections (Action Name = Expanded Site Inspections), removal assessments (Action Name
= Removal Assessment), integrated removal assessments (Action Name = Int Rmvl Assess and Preliminary
Assessment, Action Name = Int Rmvl Assess and Site Inspection, Action Name = Int Rmvl Assess and Combined
PA/SI, Action Name = Int. Rmvl Assess and Expanded Site Inspection, Action Name = Int. Rmvl Assess and HRS
Package, and Action Name = Int. Rmvl Assess and ESI/RI) and any reassessments (Action Name = Site
Reassessment)-conducted at sites. A site that is of concern to a tribe is indicated by the Tribal Concern (TC) Special
Initiative. There are two separate counts to this measure: one for the current fiscal year and one for the cumulative
number of assessments from the inception of the Superfund program.
Changes in Definition FY 02/03- FY 04/05:
None.
Special Planning/Reporting Requirements:
This is a GPRA reporting measure. In order to receive credit for this measure, the Tribal Concern (TC) Special
Initiative must be added to the Site Description/Operable Units screen in WasteLAN.
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b. PERCENTAGE OF SITES THAT ARE OF CONCERN TO TRIBES WHICH HAVE
HAD A SUPERFUND ASSESSMENT
Definition:
This measure tracks the percentage of sites that are of concern to tribes that have had a Superfund assessment
performed at the site versus those that have not had any assessment performed to date.
Definition of Accomplishment:
This measure counts all sites that have a Tribal Concern (TC) special initiative that have also had any type of
Superfund assessment-preliminary assessment (Action Name = Site Assessment), site inspection (Action Name =
Site Inspection), combined PA/SI (Action Name = Combined PA/SI), expanded site inspections (Action Name =
Expanded Site Inspections), integrated removal assessments (Action Name = Int Rmvl Assess and Preliminary
Assessment, Action Name = Int Rmvl Assess and Site Inspection, Action Name = Int Rmvl Assess and Combined
PA/SI, Action Name = Int. Rmvl Assess and Expanded Site Inspection, Action Name = Int. Rmvl Assess and HRS
Package, and Action Name = Int. Rmvl Assess and ESI/RI) or removal assessment (Action Name = Removal
Assessment)-at any point in time, as compared to the total universe of sites with a Tribal Concern (TC) Special
Initiative.
Changes in Definition FY 02/03- FY 04/05:
None.
Special Planning/Reporting Requirements:
This is a program reporting measure. In order to receive credit for this measure, the Tribal Concern (TC) Special
Initiative must be added to the Site Description/Operable Units screen in WasteLAN.
c. TRIBES SUPPORTED BY SUPERFUND COOPERATIVE AGREEMENTS
Definition:
This measure tracks the total number of tribes receiving Superfund assistance or support.
Definition of Accomplishment:
This measure counts all tribes supported by any Superfund cooperative agreement (i.e., core, support agency,
pre-remedial, remedial, removal, or enforcement) regardless of the purpose of the agreement. If the cooperative
agreement is with an inter-tribal consortium, the total number of tribes in that consortium are included in the count,
regardless of the number of tribes which might receive direct support from the specific agreement in a given year.
The measure counts all open cooperative agreements, regardless of the year in which it was awarded to the tribe. A
cooperative agreement is identified as being with a tribe or tribal consortium if the fourth digit in the bud/org. field
of the account number is "A" (tribal).
Changes in Definition FY 02/03- FY 04/05:
None.
Special Planning/Reporting Requirements:
This is a program reporting measure. In order to receive credit for this measure, the fourth digit in the bud/org. field
of the account number for the cooperative agreement must be "A".
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d. SUPERFUND DOLLARS PROVIDED FOR BUILDING TRIBAL CAPACITY
Definition:
This measure tracks the total amount of Superfund dollars obligated through cooperative agreements with tribes to
support their efforts to build tribal capacity.
Definition of Accomplishment:
This measure counts the total dollar amount obligated in the current fiscal year for any Superfund cooperative
agreement with a tribe or inter-tribal consortium, regardless of the purpose of the agreement. A cooperative
agreement is identified as being with a tribe or tribal consortium if the fourth digit in the bud/org. field of the account
number is "A" (tribal).
Changes in Definition FY 02/03- FY 04/05:
None.
Special Planning/Reporting Requirements:
This is a program reporting measure. In order to receive credit for this measure, the fourth digit in the bud/org. field
of the account number for the cooperative agreement must be "A".
e. PERCENTAGE OF SUPERFUND SITES THAT ARE OF CONCERN TO TRIBES
WHERE A TRIBE IS ACTIVELY INVOLVED
Definition:
This measure tracks the percentage of Superfund sites that are of concern to a tribe, where a tribe plays an active
role, versus those Superfund sites that are of concern to a tribe, where no tribe plays an active role.
Definition of Accomplishment:
A tribe is defined as playing an active role at a site if it has a written agreement (e.g., cooperative agreement,
site-specific memorandum of agreement, or tribal environmental agreement (TEA)) with USEPA to participate at
that site. These sites are identified in WasteLAN with a Tribal Involvement (TI) Special Initiative.
Changes in Definition FY 02/03- FY 04/05:
None.
Special Planning/Reporting Requirements:
This is a GPRA reporting measure. In order to receive credit for this measure, the Tribal Involvement (TI) Special
Initiative must be added to the Site Description/Operable Units screen in WasteLAN.
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J.C. SUBJECT MATTER EXPERTS
The following table identifies the subject matter experts for Appendix J, Tribal Involvement.
EXHIBIT J.2. SUBJECT MATTER EXPERTS
Subject Matter Expert
Subject Area
Phone #
Kirby Biggs
OSRTI Tribal GPRA Contact
(703) 308-8506
Robert Myers
OSWER Tribal Contact
(703) 603-8851
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Superfund Program Implementation Manual FY 04/05
Appendix K: Brownfields
(Brownfields is no longer included in the SPIM. Appendix K is expected to
become the Brownfields Program Manual assigned to OBCR)
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Superfund Program Implementation Manual FY04/05
Appendix M: Removals
(Applicable to all OSWER Removals regardless of financing)
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Appendix M
Removals
Table of Contents
M.A FY04/05 TARGETS AND MEASURES M-l
MA.l Overview of FY04/05 Removal Targets/Measures M-l
a. Removal Starts M-2
b. Removal Completions M-4
M.B Subject Matter Experts M-6
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Appendix M
Removals
List of Exhibits
EXHIBIT M. 1 REMOVAL ACTION ACTIVITIES M-1
EXHIBIT M.2 SUBJECT MATTER EXPERTS M-6
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M.A. FY04/05 REMOVAL TARGETS AND MEASURES
M.A. 1. OVERVIEW OF FY 04/05 REMOVAL ACTIONS TARGETS/MEASURES
The Superfund Comprehensive Accomplishments Plan (SCAP) is used by the Assistant Administrator for the Office
of Solid Waste and Emergency Response (AA OSWER), Assistant Administrator for the Office of Enforcement and
Compliance Assurance (AA OECA), and senior Superfund managers to monitor progress each region is making
towards achieving the Government Performance and Results Act (GPRA) annual performance goals. In addition,
SCAP will continue to be used as an internal management tool to project and track activities that contribute to these
GPRA goals and support resource allocation. The program will set national goals based on historical performance
and performance expectations within a limited budget for the performance goals in GPRA and track
accomplishments in the activities contributing to those goals. Regions should continue to plan and report
accomplishments in WasteLAN as they have traditionally.
To more clearly reflect the relationship between GPRA and the SCAP process, GPRA annual performance goals
and measures and program targets and measures are defined as follows:
GPRA Annual Performance Goals (APG) and GPRA Annual Performance Measures (APM) - The
Agency's Annual Plan describes the specific annual performance goals, annual measures of outputs and
outcomes, and activities aimed at achieving the performance goals that will be carried out during the year.
APGs are the specific activities that the Agency plans to conduct during the fiscal year in an effort towards
achieving its long-term strategic goals and objectives. APMs are used by managers to determine how well a
program or activity is doing in achieving milestones that have been set for the year. The annual performance
goals will inform Congress and Agency stakeholders of the expected level of achievement for the significant
activities covered by the GPRA objective. The goals are a subset of the overall planning and budgeting
information that lias traditionally been tracked by the Superfund program offices.
Program Targets and Measures are activities deemed essential to tracking overall program progress.
Program targets are used to identify and track the number of actions that each region is expected to perform
during the year and to evaluate program progress. Program measures are used to show progress made in
achieving program priorities.
The following pages contain the definitions of the FY 04/05 removal activities, GPRA annual performance goals,
GPRA and program measures, and removal project support activities. Exhibit M. 1 displays the full list of removal and
activities defined in this Appendix. Exhibit M.2, at the end of this Appendix, lists the subject matter experts for each
relevant subject area.
EXHIBIT M.l
REMOVAL ACTION ACTIVITIES
ACTIVITY
GPRA
PROGRAM
APG
APM
Target
Measure
Removal Starts
/
Removal Completions
/
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a. REMOVAL STARTS
Definition:
Removal actions are responses performed at NPL and non-NPL sites that eliminate or reduce threats to public health or
the enviromnent from the release, or potential release, of hazardous substances or pollutants or contaminants which may
pose an imminent and substantial danger to public health or welfare. These risk reduction activities can be conducted
as emergency, time-critical, or NTC removal actions. This measure tracks each removal action. The appropriate use
of Special Account funds for removal actions is provided in the "Guidance on Key Decision Points in Using Special
Account Funds" dated September 28, 2001.
Definition of Accomplishment:
A site is addressed by a removal action when the EPA, Response Action Contract (RAC), Emergency and Rapid
Response Services (ERRS), State, or PRP, or their contractors, have mobilized for construction of the removal action
specified in the Action Memorandum.
Fund-financed (Including F-, TR-, or S-lead) actions - EPA, State or their contractors have begun work at a site
for construction of the removal (emergency, time-critical, or non-time critical) as documented by a Pollution Report
(POLREP). The date of on-site construction is reported in WasteLAN as the removal (Action Name = Removal
Action) actual start date (Actual Start).
PRP- financed from a Special Account (Including Special Account Financed Action performed by EPA (SA-
lead), the State (SS-Lead), or Tribal Government (ST-lead) actions ') - EPA, State, tribal government or their
contractors have begun work at a site for construction of the PRP-financed removal (emergency, time-critical, or
non-time critical) as documented by a Pollution Report (POLREP). The date of on-site construction is reported
in WasteLAN as the removal (Action Name = Removal Action) actual start date (Actual Start).
PRP-financed (Including RP-and MR-lead) actions under theterms of anAOC, UAO, CD, orjudgment-The
PRPs or their contractors have begun work on-site for construction of the removal (emergency, time critical, or
non-time critical) as documented in a POLREP AND the PRPs provide written notice of intent to comply with a
UAO, or an enforcement instrument has been signed by EPA and the PRPs, or a judgment has been signed by a
Federal judge.
The date of on-site construction is reported in WasteLAN as the removal (Action Name = PRP Removal) actual start
date (Actual Start). The following information must be entered into WasteLAN for the enforcement instrument:
- The date the AOC (Action Name = Admin Order on Consent) was signed by the PRPs and the designated
Regional official (Actual Complete), and the Response Acts Pdby Parties of "PRP Removal"; or
- The date (Actual Complete) the PRPs provide notice of intent to comply (Action Name = PRP Notfy EPA of
Intent to Comply) with a UAO for a RP-lead removal signed (Actual Complete) by the designated Regional
Actions qualify for SA, SS, and ST leads, when the majority of the funding for the total estimated response cost
(including direct and indirect costs) is to be paid from a Special Account. The amount contributed from a Special Account
should meet or exceed the amount contributed by the largest non-PRP entity (i.e., EPA, State where applicable) toward the total
estimated response cost at the site. For example for a removal action, if 60% of the funds needed to finance the estimated
response are to be derived from a Special Account and 40% of the response costs will be paid out of Fund monies (or a lesser
amount if State cost share is received), the majority of the response cost is being paid for out of a Special Account and the action
qualifies for a SA, SS, or ST lead.
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official (Action Name = Unilateral Admin Order), and the Response Acts Pd by Parties of "PRP Removal"; or
- The date the Regional Administrator signs the memorandum transmitting the CD (Action Name = Consent
Decree) to DOJ or HQ and the Response Acts Pd by Parties of "PRP Removal"; or
- The date a judgment (Action Name = Judicial/Civil Judgment) was signed by the Federal judge (Actual
Complete), and the Response Acts Pd by Parties of "PRP Removal."
PRP-financed (PS-lead actions) under terms of a State Order or decree - The PRPs or their contractors have
begun work on-site for construction of the removal (emergency, time critical, or non-time critical) as documented
in a Pollution Report (POLREP) and the State enforcement instrument has been signed by the appropriate State
official.
PRP-financed (RP- lead actions) emergency actions where no enforcement instrument exists - The PRP or their
contractors have begun construction work on-site in response to an emergency incident, and EPA provides on-site
technical oversight and/or is part of an incident command system/unified command (as documented in a POLREP.
The date of construction is reported in WasteLAN as the removal (Action Name = PRP Emergency Removal),
actual start date (Actual Start).
For both Fund- and PRP-financed removals, the following additional information must be entered into WasteLAN:
- The Critical Indicator classification of the removal [(1) Time Critical, (2) Non-Time Critical, or (3)
Emergency];
- The media addressed through the removal (Media Type);
- The Media Name;
- The Response Action being conducted (Selected Response Actions);
- The response action cost data;
- The Institutional Control information; and
- The five year review information (at NPL sites only).
An endangennent determination should be documented when an Action Memo or Removal Action Decision Document
or an enforcement instrument is prepared. Regions identify which of the documents contain the endangennent
determination when they enter the actual completion date (Actual Complete) for the corresponding action into
WasteLAN.
Changes in Definition FY 02/03 - FY 04/05:
Added requirements to be entered into WasteLAN for both Fund- and PRP-financed removals. Removal measure were
taken from Appendix B and moved to this new appendix to reflect the changes in responsibilities for removals.
References to Coast Guard lead removals have been removed. Coast Guard lead removal starts are recorded non-site-
specifically.
Planning/Reporting Requirements:
Fund-financed removal, PRP removals under the terms of an enforcement instrument, and PRP emergency actions with
no enforcement instrument starts will be tracked separately for management purposes. Removals are covered under the
removal AOA. Removal starts and Emergency Responses (PRP emergency actions where no enforcement instrument
exists) are a GPRA annual performance goal. Removal start totals will not include Coast Guard leads. Coast Guard lead
removals are recorded non-site-specifically in WasteLAN through the program management screen.
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b. REMOVAL COMPLETIONS
Definition:
Removal actions are responses performed at NPL or non-NPL sites that eliminate or reduce threats to public health or
the enviromnent from the release, or potential release, of hazardous substances or pollutants or contaminants which may
present an imminent and substantial danger to public health or welfare. These risk reduction activities can be conducted
as emergency, time-critical or NTC removal actions. This measure tracks each removal completion at a site.
DISCLAIMER: Regions will receive credit in the management of the Superfund programfor "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 designforthat activity). The date found in the removal action,
actual complete column of a WasteLAN 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.
Definition of Accomplishment:
Following are the conditions under which a removal is considered complete:
A Fund-financed removal is considered complete when the actions specified in the Action Memorandum are met,
OR when the contractor lias demobilized and left the site (as documented in the POLREP) and recorded as the
removal (Action Name = Removal Action) actual completion date (Actual Complete) in WasteLAN.
A PRP-financed removal performed by the PRP under the terms of a Federal enforcement instrument, is considered
complete when the Region has certified that the PRPs have fully met the terms of an AOC, UAO, CD, or judgment
and have completed the actions specified in the Action Memorandum (as documented in the POLREP) and
recorded as the removal (Action Name = PRP Removal) actual completion date (Actual Complete) in WasteLAN.
A PRP-financed removal performed by the PRPs under the terms of a State enforcement document is considered
complete when the State has certified the PRPs have fully met the terms of the instrument AND have completed
the actions specified in the Action Memorandum (as documented in the POLREP) and recorded as the removal
(Action Name = PRP Removal) actual completion date (Actual Complete) in WasteLAN.
A PRP-financed emergency action where no enforcement instrument exists is considered complete when the OSC,
in consultation with the unified command/incident command system if applicable, lias determined that the
emergency is stabilized (as documented in a POLREP) and recorded as the removal (Action Name = PRP
Emergency Removal) actual completion date (Actual Complete) in WasteLAN.
In order to receive credit for a removal completion an endangennent determination must be performed. This
endangennent determination may be documented in an Action Memo, Removal Action Decision Document or
enforcement instrument. Regions identify which of these documents contain the endangennent detenninationby entering
the actual completion date (Actual Complete) into WasteLAN.
For either Fund- or PRP-financed removals, an action qualifier (Qualifier) must be recorded to identify whether the
action resulted in the site being " Cleaned Up" or " Stabilized."
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OSWER Directive 9200.3-14-1G-Q
Action qualifiers are defined as follows:
- Cleaned Up: All threats have been addressed as defined in the Action Memo and the region determines that it
has addressed all threats posed by the site (will not be returning for subsequent response activity). Also, all
removal obligations and related work have been completed.
- Stabilized: All threats identified in the Action Memo have been addressed. The region may take additional
removal actions as new threats are identified/investigatory information is available. Example: Leaking drums
and contaminated soil in the area of the drums are excavated and disposed of in an approved off-site facility.
Site is stabilized.
Exceptions:
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 enviromnent.
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:
The Action Memorandum requires the EPA contractor to monitor the hazardous substances stored on-site or
additional contractor expenditures are anticipated; or
Hazardous substances are being stored at an off-site facility, other than the ultimate TSD facility required in the
Action Memorandum.
A removal would be considered complete if:
The scope of work for the action does not specify final off-site disposal of hazardous substances; the substances
have been stabilized and are stored on-site due to circumstances such as the unavailability of a final
treatment/disposal remedy; and no additional Comprehensive Enviromnental Response, Compensation and
Liability Act (CERCLA) removal authority funds are anticipated to be expended on this action. In this instance,
no CERCLA removal authority funds will be expended for remedial-term site O&M. Any remedial-term site O&M
(greater than 6 months) should be performed by the PRP or another agency (e.g., the State); or
Hazardous substances are being stored off-site at the location of final disposal, and no additional contractor
expenditures are anticipated for this action.
Changes in Definition FY 02/03 - FY 04/05:
Removal measure were taken from Appendix B and moved to this new appendix to reflect the changes in responsibilities
for removals. References to Coast Guard lead removals have been removed. Coast Guard lead removal completions
are recorded non-site-specifically.
Special Planning/Reporting Requirements:
Upon completion of a removal, an action Qualifier must be recorded to identify whether the removal resulted in the site
being " Cleaned Up" or " Stabilized." This is a program measure. Removal completion totals will not include Coast
Guard leads. Coast Guard lead removals are recorded non-site-specifically in WasteLAN through the program
management screen.
Change 1, FY 04/05 SPIM
M-5
September 22, 2003
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OSWER Directive 9200.3-14-1G-Q
M.B Subject Matter Experts
The following exhibit identifies the subject matter experts for Appendix M, Removals.
EXHIBIT M.2 Subject Matter Experts
Subject Matter Expert
Subject Area
Phone #
Terry Eby
Removal Implementation
703-603-8741
Mark Mjoness
Removal Implementation
703-603-8727
Kevin Mould
Removal Implementation
703-603-8728
Charlotte Englert
Removal Financial
202-564-8888
Dana Stalcup
Removal Implementation
703-603-8735
Ray Worley
Removal Implementation
703-603-8724
September 22, 2003
M-6
Change 1, FY 04/05 SPIM
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