U.S. ENVIRONMENTAL PROTECTION
OFFICE OF INSPECTOR GENERAL
EPA Needs to Improve Its
Process for Accurately
Designating Land as Clean
and Protective for Reuse
Report No. 14-P-0364
September 29, 2014

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Report Contributors:
Christina Lovingood
Patrick Milligan
Chad Kincheloe
Anne Bavuso
Bakari Baker
Kate Robinson
Roopa Batni-Mulchandani
Abbreviations
ACRES
Assessment, Cleanup, and Redevelopment Exchange System
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act
CPRM
Cross-Program Revitalization Measures
EPA
U.S. Environmental Protection Agency
FY
Fiscal Year
OIG
Office of Inspector General
OSWER
Office of Solid Waste and Emergency Response
PFP
Protective for People
RAU
Ready for Anticipated Use
RCRA CA
Resource Conservation and Recovery Act Corrective Action
RCRAInfo
RCRA's database
UST
Underground Storage Tank
Are you aware of fraud, waste or abuse in an
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More information at www.epa.gov/oiq/hotline.html.
EPA Office of Inspector General
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Washington, DC 20460
(202) 566-2391
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
14-P-0364
September 29, 2014
Why We Did This Review
The purpose of this evaluation
was to determine whether the
U.S. Environmental Protection
Agency's (EPA's) designation
of sites that have achieved the
"protective for people" and/or
"ready for anticipated use"
(RAU) performance measures
include effective controls to
ensure long-term protection to
human health and the
environment.
A primary goal of the EPA's
Office of Solid Waste and
Emergency Response
(OSWER) is to ensure that the
cleanup of contaminated sites
is protective of human health
and the environment. OSWER
developed the Cross-Program
Revitalization Measures
(CPRM) to promote and
communicate its cleanup
accomplishments and benefits
of restoring contaminated
properties to environmental and
economic vitality.
This report addresses the
following EPA goal or
cross-agency strategy:
• Cleaning up communities
and advancing sustainable
development.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
The full report is at:
www.epa.aov/oia/reports/2014/
20140929-14-P-0364.pdf
EPA Needs to Improve Its Process for Accurately
Designating Land as Clean and Protective for Reuse
What We Found
The EPA has limited controls for verifying or
testing the accuracy of CPRM information that
states and grantees provide to show sites are
protective for people and RAU. The EPA also
does not have adequate controls to verify that
these designations continue to be valid and the
sites remain protective in the long term.
The EPA's lack of controls
over designating sites as
protective and ready for reuse
calls into question the
reliability and value of the
designations for protecting
human health.
The Resource Conservation and Recovery Act Corrective Action (RCRA CA)
program does not require documentation to support the designations. The EPA
could not obtain supporting documentation for six of the 16 reuse designations
we reviewed. While the Brownfields program does receive the supporting
documentation, it does not sufficiently review the documentation to verify
accuracy. We could not verify the accuracy of the reuse designation for 10 of 32
Brownfields sites we examined. Three of these Brownfields sites were
prematurely designated as RAU. These sites had asbestos contamination
cleaned up after they were designated as RAU.
The Underground Storage Tank (UST) program has the fewest EPA controls for
accurate RAU site designations, even though UST sites represent 99 percent of
the more than 400,000 sites the EPA has designated as RAU. States submit the
number of UST RAU sites to EPA, but not names or supporting documentation.
Further, states do not provide information on whether institutional controls are
needed at the sites, but the EPA's definition of RAU indicates it is improper to
provide an RAU designation without knowing if institutional controls are needed.
Given that nearly all the EPA's RAU designations are at UST sites and that the
EPA inaccurately designated sites as RAU or failed to support some of the
Brownfields and RCRA CA designations, the reliability and value of the RAU
measure are marginal. This creates the risk that the designations may not be
sufficiently protective of human health, which is even more important when
considering some of these sites may be reused as playgrounds, schools or child
care facilities. Also, the EPA's public reports may contain unreliable information
on site conditions.
Recommendations and Agency Corrective Actions
We recommend that the OSWER Assistant Administrator improve controls over
its guidance, review and reporting of the CPRM measures. The agency agreed
with two recommendations but disagreed with the remaining three
recommendations, and resolution efforts are in progress.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 29, 2014
MEMORANDUM
SUBJECT: EPA Needs to Improve Its Process for Accurately Designating Land as
Clean and Protective for Reuse
Report No. 14-P-0364
FROM: Arthur A. Elkins Jr.
TO:
Mathy Stanislaus, Assistant Administrator
Office of Solid Waste and Emergency Response
This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems
the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of
the OIG and does not necessarily represent the final EPA position. Final determinations on matters in
this report will be made by EPA managers in accordance with established audit resolution procedures.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this report
within 60 calendar days. You should include planned corrective actions and completion dates for all
unresolved recommendations. Your response will be posted on the OIG's public website, along with our
memorandum commenting on your response. Your response should be provided as an Adobe PDF file
that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as
amended. The final response should not contain data that you do not want to be released to the public;
if your response contains such data, you should identify the data for redaction or removal along with
corresponding justification.
We will post this report to our website at http://www.epa.gov/oig.

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EPA Needs to Improve Its Process for Accurately
Designating Land as Clean and Protective for Reuse
14-P-0364
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Scope and Methodology		5
2	EPA's Performance Measures for Some Cleanup Programs Missing
Needed Controls to Ensure Long-Term Protection of Human Health		7
EPA Has Limited Controls to Assure Accurate
Initial Site Designations as PFP and RAU		8
EPA Has Limited Controls for Identifying Changes in
Site Conditions and Uses in the Long Term		10
EPA Can Improve Controls by Finalizing CPRM Interim Guidance		13
Conclusions		14
Recommendations		14
Summary of Agency Response to Draft Report and OIG Evaluation		15
Status of Recommendations and Potential Monetary Benefits		16
Appendices
A Agency Response to Draft Report and OIG Evaluation	 17
B Distribution	 25

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Chapter 1
Introduction
Purpose
We sought to determine whether the U.S. Environmental Protection Agency's
(EPA's) designation of assessed and cleaned-up sites that have achieved the
"ready for anticipated use" (RAU) and/or "protective for people" (PFP)
performance measures include effective controls to ensure long-term protection to
human health and the environment.
Background
Office of Management and Budget Circular A-123, Management's Responsibility
for Internal Controls, states that management has a fundamental responsibility to
develop and maintain effective internal control and that organization, policies and
procedures are tools to help program managers achieve results and safeguard the
integrity of their programs. The Government Performance and Results Act of
1993, amended in 2010, requires the EPA to clearly describe the goals and
objectives of its programs, identify resources and actions needed to accomplish
these goals and objectives, develop a means of measuring their progress, and
regularly report on achievements.
The primary objective the Office of Solid Waste and Emergency Response
(OSWER) cleanup program is to ensure that the cleanup of contaminated sites is
protective of human health and the environment. In 2006, OSWER issued interim
guidance for reporting performance measures, including site reuse measures.
OSWER describes the measures as "a first step toward reporting data as a common
set of measures." The guidance describes the reuse measures' benefits to society as
helping reassure interested parties (property owners, workers, investors, potential
buyers or developers, etc.) that the sites are protective not only for the current use
but for reuse in the reasonably anticipated future. OSWER indicated the reuse
measures help communicate broader cross-programmatic, regional and national
progress in getting properties through the cleanup process.
Cross-Program Revitalization Measures (CPRM) include sites from a range of
OSWER programs:
•	Superfund.
•	Brownfields.
•	Resource Conservation and Recovery Act Corrective Action (RCRA CA).
•	Underground Storage Tank (UST).
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The PFP performance measure is the number of sites and acres at which there is
no complete pathway for human exposures to unacceptable levels of
contamination based on current site conditions, and is achieved through:
•	Environmental investigations.
•	Response actions that treat, contain or remove contaminated media that
make it protective for current use/conditions.
•	Solutions that limit or restrict human use and associated exposures through
engineering controls such as caps or institutional controls such as notices
and easements.
The RAU performance measure is the number of acres and sites at which all three
of the following are achieved:
•	There are no complete pathways for human exposure to unacceptable
levels of contamination based on current site conditions.
•	All cleanup goals have been achieved for media that may affect current
and reasonably anticipated future land uses of the acres or sites so that
there are no unacceptable risks.
•	All institutional or other controls identified as part of the response action
to help ensure long-term protections have been put in place.
There are also two voluntary indicators used to promote the collection of
information needed to help describe revitalization accomplishments—the
Status of Use and Type of Use indicators. The Status of Use indicator captures
information about whether a site is being used; sites and acres will be classified as
unused, in continued use, reused or planned reuse. The Type of Use indicator
describes how the acres at a site are being used when the site reuse determinations
are made. There are six categories of Type of Use Indicators:
•	Commercial and Public Service.
•	Green Space.
•	Industrial.
•	Military and Other Federal.
•	Mixed.
•	Residential.
Implementation of CPRM Performance Measures
As shown in Table 1, between the adoption of guidance for the reuse performance
measures in 2006 and the end of fiscal year (FY) 2013, OSWER designated over
400,000 reuse sites, the majority of which are UST sites.
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Table 1: Total number of RAU sites as of September 30, 2013
Program
Number of RAU sites
Superfund
662
RCRA CA
904
Brownfields
1,694
UST
437,914
Total
441,174
Sources: OSWER's programs for FY 2011 data and OSWER's
FYs 2012 and 2013 accomplishment reports.
The EPA reported these sites in its FYs 2010, 2012 and 2013 accomplishment
reports to the public. The sites are reported cumulatively, beginning in 2008 when
the EPA first began measuring site reuse progress.
EPA maintains oversight authority over all states whether delegated or not. But,
for delegated programs (RCRA CA and UST) - - and for the Brownfields
program, states have primary authority. For those states where the program is
delegated, the agency establishes a Memorandum of Agreement with the state that
promotes coordination and clarifies the general roles and responsibilities between
the EPA and the states. As a result, the EPA relies primarily on the states to
ensure these cleanup programs are effectively implemented. States are required to
report information confirming effective implementation into the EPA's
Brownfields and RCRA CA databases, and the EPA regions review the
information to determine whether the required data were submitted and that sites
were cleaned up and met the PFP and RAU criteria. Table 2 provides a
description of how RAU designations are made.
Table 2: How RAU designations are made
Program
How RAU designations are made
Superfund
EPA regions determine when a site has achieved the reuse
measures. The regions complete a checklist and enter the data in the
EPA's Comprehensive Environmental Response, Compensation and
Liability Information System.
RCRA CA
EPA regions determine when a site has achieved the reuse
measures. States enter the information into OSWER's RCRA CA
database to indicate that a site meets OSWER's reuse definition.
Brownfields
EPA regions determine when a site has achieved the reuse
measures. Grantees enter the information into OSWER's Brownfields
database to indicate that a site meets OSWER's reuse definition.
UST
EPA regions determine when a site has achieved the reuse
measures. States determine when sites are cleaned up and report
the number of sites that meet OSWER's reuse definition.
Source: OIG analysis of each program's process for designating sites RAU.
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Responsible Offices
The Immediate Office within OSWER has overall responsibility for the CPRM.
Within OSWER, the following offices have responsibilities related to the
performance measures.
Office of Superfund Remediation and Technology Innovation
EPA regions determine when a site has achieved the reuse measures. The
regions complete a checklist and enter the data in the EPA's Comprehensive
Environmental Response, Compensation and Liability Information System.
The checklist also documents information for the two voluntary indicators
(Status of Use and Type of Use). A Five-Year Review is required for sites
where hazardous substances remain onsite above levels which permit
unlimited use and unrestricted exposure, and provides an opportunity to
evaluate the implementation of a remedy to determine whether it remains
protective of human health and the environment. The federal Superfund
program is not delegated to the states, although some sites are state-led.
Office of Resource Conservation and Recovery
Although the EPA is ultimately responsible for the RCRA CA cleanup
program, it has delegated the program to most states. As a result, those
states determine when sites achieve the reuse performance measures using
the agency's definitions of PFP and RAU. The regions check the program
database to verify that the performance measure data have been input.
Office of Brownfields and Land Revitalization
The Brownfields program uses a Property Profile Form, which grantees
access and update in the Brownfields database—the Assessment, Cleanup,
and Redevelopment Exchange System (ACRES). States oversee a phase 1
assessment of the site to determine whether a cleanup is necessary. If
further assessment and/or a cleanup and institutional controls are not
required, the site meets the RAU definition. If a cleanup is needed, the site
receives the reuse designation after the cleanup is completed and no
further action is necessary. Once the site meets the reuse criteria, OSWER,
through ACRES, designates the site as RAU.
Office of Underground Storage Tanks
The reuse measures for the UST program are achieved when a state cleanup
of a confirmed release is completed. The state determines when these sites
are cleaned up and reports the number of cleaned-up sites to its regional EPA
office. Regional offices then submit these numbers to EPA headquarters,
which reports these sites as RAU in EPA accomplishment reports.
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Scope and Methodology
We performed our work from April 2012 to July 2014. We conducted this
performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objectives.
Included in our evaluation was OSWER's implementation of two CPRMs—
PFP and RAU. We reviewed these two reuse measures for three OSWER
programs—Brownfields, RCRA CA and UST. We did not include Superfund sites
because we issued a report1 on OSWER's management controls to ensure
Superfund Five-Year Reviews are thorough, meet policy, and lead to well-
supported determinations that accurately report how well cleanup remedies
protect human health and the environment.
We reviewed information supporting OSWER's site reuse determinations for
90 sites in the RCRA CA, Brownfields and UST programs. The sites are located
in Florida, Georgia, Louisiana, New Mexico, South Carolina and Texas, and
represented 29 RCRA CA sites, 32 Brownfields sites and 29 UST sites. All states
we reviewed were delegated for RCRA CA and UST. We selected sites based on
the age of the site, number of acres designated PFP or RAU, the type of facility,
and the proximity of sites to each other. For the RAU sites, we requested
supporting documentation from OSWER. We compared the supporting
documentation with the information in the database to test the accuracy of the
databases and determine whether the site reuse designations were adequately
supported.
To accomplish our objective, we interviewed EPA managers and staff in the
following OSWER Offices: Superfund Remediation and Technology Innovation,
Resource Conservation and Recovery, Underground Storage Tanks, and
Brownfields and Land Revitalization. We also interviewed managers and staff in
Regions 4 and 6 for each of the four OSWER programs.
We reviewed key documents, including: Interim Guidance for OSWER Cross-
Program Revitalization Measures, Guidance for Documenting and Reporting
Performance in Achieving Land Revitalization, Guidance for Documenting and
Reporting RCRA CA Land Revitalization Indicators and Performance Measures,
Guidance for Preparing Superfund Ready for Reuse Determinations, Superfund
Five-Year Review Guidance, OSWER's December 2010 Cross-Program
Revitalization Measures report and FYs 2011 and 2013 accomplishment reports,
1 EPA Office of Inspector General (OIG) Report No. 12-P-0251, Stronger Management Controls Will Improve EPA
Five-Year Reviews of Superfund Sites, issued February 6, 2012.
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FY 2013 National Program Manager's Guidance, and UST Performance
Measures Definitions.
We reviewed how EPA Regions 4 and 6 oversee measurement and tracking of
sites that achieve the reuse performance measures. We reviewed the
Memorandums of Agreement between regions and states. We reviewed
No Further Action letters, Completion Letters, and Site Rehabilitation Completion
Orders. We reviewed RCRA CA facility permits, RAU documentation forms, and
Institutional Controls Tracking Information forms. We reviewed Brownfields
Property Profile forms, State Certificates of Completions, site assessment reports,
and technical documents related to the selected sites. We also reviewed UST
Closure Reports.
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Chapter 2
EPA's Performance Measures for
Some Cleanup Programs Missing Needed Controls
to Ensure Long-Term Protection of Human Health
OSWER does not have adequate procedures to verify the accuracy of sites that
have been designated PFP and RAU. Due to ineffective oversight controls:
•	The RCRA CA program does not always require documentation to support
designations. Region 4 was unable to provide supporting documentation
for six of the 16 RCRA CA reuse designations we sampled.
•	Although the Brownfields program receives supporting documentation, it
does not sufficiently review the documentation to verify accuracy. We
could not verify the reuse designation for 10 of the 32 Brownfields sites
we sampled. OSWER was unaware that three of the 10 sites were
designated RAU but were later remediated for asbestos contamination.
•	The UST program, which represents 99 percent of the 441,174 RAU sites,
has the least controls; states do not provide site specific information or
supporting documentation for the designations. States with delegated
authority submit the number of UST RAU sites, but do not provide the
names of those sites or documentation to support RAU designations.
Further, OSWER qualifies in public reports that it is unable to identify
whether any institutional controls, if needed, are in place at UST reuse
sites. OSWER acknowledges that this is a limitation in meeting the
definition of RAU. The regions were able to obtain adequate RAU support
from the states for the 29 RAU designations we sampled, but we were
only able to verify designations where states made the lists of cleaned-up
UST sites publicly available.
The lack of details and support for information provided to the EPA causes
questions about the value of the RAU measure, and OSWER's public reports may
contain unreliable information. Human health and environmental risks may occur
if sites are prematurely designated as protective and ready for use.
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EPA Has Limited Controls to Assure Accurate Initial Site Designations
as PFP and RAU
Our review of Brownfields, RCRA CA and UST sites found that OSWER
prematurely designated some sites as PFP and RAU. Also, OSWER was unable to
provide support for other sites, and some regional staff were not aware of
OSWER's tracking and reporting of contaminated sites achieving reuse
performance measures. These weaknesses occurred because OSWER senior
management over-relied on delegated states and grantees and focused on
reporting the accomplishments. We found the following for each program
reviewed.
Brownfields Program
The EPA incorrectly reported 10 of the 32 Brownfields sites we reviewed, or
31 percent, as RAU before ensuring that the requirements for sites achieving
RAU status were fulfilled. The sites were reported incorrectly because guidance
did not require EPA Brownfields staff to review the documents submitted by the
grantees to verify the accuracy of the reported RAU.
Currently, the EPA relies primarily on the Brownfields grantees and states to
provide site information needed to verify that the site meets the conditions for
achieving OSWER's reuse performance measures. OSWER's Office of
Brownfields and Land Revitalization staff said Brownfields grantees enter site
information into the EPA's Brownfields database—ACRES. They also said that
the EPA Regional Project Officer reviews that information to ensure the database
contains the information needed for OSWER to accurately make site reuse
designations. As part of the grant agreement, grantees are asked to complete a
Property Profile Form. The form includes data on environmental assessments,
cleanup activities, contaminants found at the site, institutional and engineering
controls, and basic geographic information. The grantee completes the form,
which is located in ACRES. According to the Brownfields staff, the EPA reviews
the database to determine whether the required fields that meet the site reuse
definition are completed.
Although EPA regional offices receive site assessment and site cleanup reports—
which include information on site conditions, contaminants found and cleanup
remedies used—the regions do not regularly review these reports to verify the
accuracy of the database. Region 4 staff said this was because there are too many
documents to review. When the assessment grant is awarded, the grantee
performs an assessment of the site and reports on what it finds. The assessment
report either recommends that there are no "Recognized Environmental
Concerns," in which case it makes a No Further Assessment recommendation, or
that further assessment and cleanup is needed. After the site has been cleaned up,
the state would issue a No Further Action notification.
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According to the EPA's interim CPRM guidance, when no cleanup is required the
site is considered PFP, and because no cleanup is required the site is also
considered RAU. CPRM guidance does not require the EPA to read these reports.
EPA regional staff did not review the state's assessment reports to ensure sites
were entirely cleaned up and ready for reuse. EPA regional staff were unaware
that three of the 10 Brownfields sites were remediated for asbestos contamination
after the sites had received the RAU designation. If region staff had reviewed the
assessment reports, they would have identified the presence of asbestos and
accurately determined that the sites should not be considered RAU.
RCRA CA Program
The RCRA CA CPRM guidance requires state project managers to document on
the RAU determination form when a facility has met the criteria for the RAU
performance measure. States with delegated RCRA CA authority submit the
determination forms to the EPA and the EPA enters the information into the
EPA's RCRA CA's database, called RCRAInfo. Both Regions 4 and 6 use the
data to verify that sites have met the criteria to meet the reuse performance
measures. In addition, a Region 6 manager stated that the region uses an RAU
checklist to compare to RCRAInfo, and that other support for information entered
into RCRAInfo is maintained at the state.
Region 6 provided us with RAU determination forms for the 13 sites in the region
reviewed, and the forms were adequate support for the reuse determinations.
However, when we requested from Region 4 supporting documentation for the
16 RAU sites reviewed for that region, the region needed to contact the states for
the information. The states provided a mix of documentation, providing adequate
support for 10 initial reuse designations but not for the remaining six. Region 4
managers said the region does not keep the supporting documents (RAU
determination forms and institutional control documents) because they review the
information used to support the initial RAU designations in RCRAInfo at the end
of each fiscal year. This review, however, does not verify that sufficient
documentation exists to justify the states' reuse designations, which could result
in the EPA wrongly designating sites as PFP and RAU.
UST Program
Despite the fact that the UST sites comprise over 99 percent of the reuse sites
reported through the end of FY 2013, the EPA receives and reviews the least
information for those sites. At the end of FY 2013, we found that 437,914 of the
441,174 RAU sites were UST sites. Considering this large number, it would not be
feasible or practical for the EPA to receive and review site-specific documentation
for all of the UST sites. However, obtaining supporting documents for a sampling
of sites would enable the EPA to test the accuracy and completeness of the
information used to support the reuse designations.
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The UST program is delegated to 38 of the 50 states. The delegated states are not
required to submit information to the EPA supporting cleanups, and they provide
limited information. States send the EPA regional offices reports on the number
of sites that have been cleaned up without a list of site names or verification of
state-reported information. These submittals are done quarterly in Region 4 and
semiannually in Region 6. Some states in Regions 4 and 6 had publicly available
lists of cleaned-up UST sites while other states did not. As a result, to verify reuse
status, we had to alter our sample to select states that had the cleaned-up site lists.
OSWER reports the number of cleaned-up sites as the number of sites achieving
reuse status in annual accomplishment reports. For Regions 4 and 6, we requested
the supporting documents for 34 sites designated as RAU. The information
provided, which the regions needed to request from the states, showed evidence
that the sites were cleaned to the level of meeting the definition of the reuse
performance measures.
EPA Has Limited Controls for Identifying Changes in Site Conditions
and Uses in the Long Term
After sites have been designated PFP and RAU, OSWER has limited controls to
verify that the designations continue to be valid and the sites remain protective of
human health and the environment. While agency guidance states that the PFP
measure has to be accomplished for a site to be RAU, the PFP is only good for the
"point in time" in which the determination is made. However, the EPA
cumulatively reports the RAU sites, without qualifying that it is a "point in time"
or without citing limitations on the continued validity of the measures reported.
The accuracy of the PFP measure is needed in order for EPA to help reassure
interested parties, including communities, that there is no current complete
pathway for human exposures to unacceptable levels of contamination.
Brownfields, RCRA CA and UST managers at both headquarters and the regions
stated that their programs do not include mechanisms that require an additional
review to verify that sites remain protective of human health and the environment
after the initial designation is made. This is consistent with the CPRM interim
guidance, which does not require an additional review to confirm that sites remain
protective.
The EPA's CPRM interim guidance does not require states to track the status and
type of reuse of remediated sites after they are determined to be RAU. The
interim CPRM guidance lists benefits for tracking reuses of cleaned-up sites, but
most of the listed benefits involve identifying trends in uses and prioritizing sites,
not on ensuring whether sites remain protective for human health. Further,
investors could rely on potentially inaccurate information to make business
decisions about a site based on outdated or incorrect information in the EPA's
publicly available databases. Tracking and monitoring revitalized sites that are
reused as intended by the cleanup and remediation plan would help better ensure
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that the reused sites are used properly as intended. We found the following for the
three programs reviewed.
Brownfields Program
For Brownfields sites, there is minimal contact between the state and EPA after
the cleanup has been accomplished, and changes in site conditions or site use may
go undetected by the EPA. The Brownfields program maintains that under the
Brownfields amendment to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), it does not have the authority to
conduct long-term oversight at Brownfields sites. EPA Office of Brownfields and
Land Revitalization officials maintain that the Brownfields program is a grants
management program that provides seed money for funding site assessments and
cleanups that the states perform, not the EPA. Those EPA officials added that
when the grant period ends, they cannot require grantees to report changes in site
conditions or reuse to the EPA.
We do not agree with the EPA position. Although the cleanup is managed by the
states and the EPA does not participate in cleanups, the OIG found that under
CERCLA, the EPA has the authority to add reporting requirements to the grant
agreement as deemed necessary and should do so to meet the intent of CERCLA.
For the length of the grant agreement, the EPA requires the grantee to add and
update information in the agency's database when appropriate. Since site use can
change, the EPA should either build in controls to better assure that site
conditions remain safe, or publicly disclose that the CPRM determinations may
not remain accurate over time.
We found that for all states in our review, Brownfields database information
included past uses of each site but only a few sites had information in the database
regarding the reuse of properties, whether it was planned or actual reuse. Region 4
managers said that their knowledge of site reuse of developed Brownfields sites is
"hit or miss." They added that they would like to track reuse but there were
resource issues. Some grantees submit Return on Investment Reports, but regional
managers said that this is more of the exception and not the rule.
Brownfields officials acknowledged that the reuse of cleaned-up sites could
change from the intended uses, and one Brownfields official said "hopefully states
are monitoring the uses, especially when there are uses that should not occur."
RCRA CA Program
Many RCRA CA sites have ongoing operations and, therefore, there is some
opportunity for the EPA to track changes because of periodic interaction between
the state and EPA. However, the communications between states and the EPA do
not encompass effective controls for reporting changes at RCRA CA sites.
RCRA CA headquarters managers said that once the RAU designation is made
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there is no requirement for states and regions to periodically reevaluate the reuse
determination to verify its continued validity.
The EPA relies on the state project managers to update the Ready for Anticipated
Use Determination form and send it to the EPA region if changes occur, at which
point the region should enter the information into RCRAInfo. A RCRA CA
headquarters manager said the form is a one-time submittal and there is no
requirement for the state to periodically verify that the reuse designation remains
valid. However, these forms are not normally checked by the regional EPA staff
after a site is RAU. Further, when the states do not submit the determination form
or do not inform the region of a change in site status, EPA Region 4 can only
identify the site changes through RCRAInfo. Without the form, EPA has no
information on how the site use or site conditions have changed and their impact,
which could result in EPA reporting erroneous site information to the public.
Also, the site may no longer be protective of human health and the environment.
State oversight of RCRA CA sites extends beyond the time a site is initially
designated RAU. Therefore, the EPA and the states should track changes in site
conditions and use. Most sites receive RCRA CA permits to ensure the site is
being operated properly. The EPA incorporates corrective action into a facility's
permit. According to a Region 6 RCRA CA manager, the permits are not used to
verify the accuracy of sites' long-term RAU status. The EPA should include
conditions in the permit that require the state to revise the determination form to
show that changes in site use or conditions have occurred and whether the RAU
designation should be removed. The permit should further stipulate that these
revised determination forms be submitted to the EPA. EPA review of submitted
forms would help it and the states better ensure that sites remain protective of
human health and the environment.
Region 4 RCRA CA staff stated they are not aware of the CPRM voluntary
indicators (status and type of reuse) and believed site reuse information is relevant
information the EPA needs to know. Receiving this information will provide the
controls needed for the EPA to continue to verify that site conditions and site use
remain PFP and RAU.
UST Program
EPA headquarters and regional managers informed us that there are no controls in
the UST program to ensure sites continue to be protective of human health long
term. EPA headquarters managers also said that after a site has been cleaned up,
the state generates a "No Further Action" letter for each site and maintains site-
specific information but does not submit that information to the EPA. States
report cumulative site cleanup numbers to EPA regions, which then provide these
totals to the OSWER Office of Underground Storage Tanks. However, states do
not provide the names of the RAU sites or the documentation that supports the
reuse designations. OSWER also noted in its 2010 CPRM report that it is unable
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to identify whether any institutional controls, if needed, are in place at UST reuse
sites, and acknowledges that this limitation is an inconsistency with the RAU
definition. A similar qualification exists in the 2013 Accomplishments report.
Having institutional controls in place is one of the requirements for a site to meet
the criteria for reuse. Because the majority of RAU sites are UST, not knowing
the status of institutional controls calls into question the validity of the reuse
designation for most of OSWER's RAU sites.
The EPA's regional UST managers and staff said they were unfamiliar with the
CPRM performance measures. They said they report the total number of
cleaned-up sites to EPA headquarters, and headquarters then reports the sites as
achieving reuse status. States are not required to report when site use or
conditions change. As a result, the EPA may be unaware when such changes
occur. If the use of a site changes, or the conditions change, the site may no
longer be protective of human health and the environment.
EPA Can Improve Controls by Finalizing CPRM Interim Guidance
The EPA issued its CPRM interim guidance in 2006,2 but the guidance is still not
final. The agency stated in the 2007 Guidance for Documenting and Reporting
Performance in Achieving Land Revitalization that the CPRM interim guidance
established the overarching framework for these measures, but directed each of
the individual OSWER programs to develop companion guidance outlining
program-specific implementation. The Superfund/Federal Facilities cleanup
program and the RCRA CA program did develop specific guidance for its
respective programs, while the Brownfields and UST programs did not.
During our review of the CPRM, we learned that some of the Brownfields and
UST program regional staff are not aware of the CPRM measure or how states'
hazardous waste cleanup information is used by EPA headquarters to report
CPRM performance measure accomplishments. EPA regional cleanup program
staff are not reviewing the state cleanup reports to verify whether the data input
by Brownfields, RCRA CA and UST grantees is correct. Reviewing state reports
for accuracy in the programs' databases is important, as the cleanups are reported
by OSWER as RAU and PFP in public reports and websites. Further, some
Brownfields and UST program staff do not know the relationship between their
respective state site cleanups and the CPRM. Region 6 Brownfields staff informed
us that ready for anticipated use "is not a Brownfields assessment grant term and
therefore does not apply to a Brownfields assessment grant award commitments
or accomplishments." The EPA has the opportunity to finalize its interim CPRM
guidance and address the issues described above.
2 Interim Guidance for OSWER Cross-Program Revitalization Measures, October 2006.
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Conclusions
The EPA has limited controls for verifying or testing the accuracy of information
that states and grantees are providing to show sites are PFP and RAU. Through its
accomplishment reports, EPA has reported to the public that over 400,000 sites
nationwide that were once contaminated or believed to be contaminated are now
RAU. However, the EPA is relying on states and grantees to voluntarily submit
accurate site information, and has minimal controls to be sure sites are RAU and
will remain that way. The results of our review demonstrate the usefulness of
reviewing supporting documentation for PFP and RAU designations, and the need
for the EPA to require states to routinely submit this support. The EPA should
revise the interim CPRM guidance to include the controls needed for ensuring
sites are accurately designated PFP and RAU.
The EPA's reporting of site reuse accomplishments is inaccurate because the
agency does not report limitations on the validity of the reuse designations and the
agency does not have controls to verify the accuracy of the initial or continued
validity of those designations. As a result, the EPA may be inaccurately
representing the benefits of its measures. This greatly diminishes the value and
meaning of the EPA's RAU performance measure. Further, in 2010, 2012 and
2013 the EPA reported the total and cumulative number of reuse sites for the
Brownfields, RCRA CA, UST and Superfund programs since 2008 without
qualifying that the designations were at a "point in time." Without specifying that
the number of reuse sites are at a "point-in-time," the reporting of these sites
suggests that the reuse determination continues to be valid over time when this
may not be the case. Therefore, the agency should reconsider whether it should
use the CPRM measures or it should qualify the information as appropriate.
Recommendations
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response:
1. Improve controls of the CPRM measures by revising the CPRM guidance
to require:
a.	Grantees to track and report the status and type of reuse at RAU
sites, instead of voluntary reporting.
b.	Brownfields and RCRA CA staff to obtain and review grantees'
supporting documentation for sites designated PFP and RAU and
verify that the grantees provide information in the appropriate
OSWER databases.
c.	UST staff to obtain and review grantees' supporting documentation
for a selected sample of sites designated PFP and RAU and verify
that the grantees provided information in the appropriate OSWER
databases.
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2.	After CPRM interim guidance is revised, provide training to regional
OSWER staff responsible for verifying states' PFP and RAU designations
to ensure staff are informed of the guidance and what is required.
3.	Stipulate the following in the grant agreements for each program:
a.	For Brownfields, require grantees to track the status and type of
reuse of remediated sites and report that information to OSWER.
b.	For RCRA CA, whenever there is a change in site conditions or
site use, require states to revise the RCRA CA determination form
to reflect the changes and have states re-submit the form to
OSWER.
c.	For UST, require states to submit to OSWER and make publicly
available site-specific information, including site name.
4.	Correct designations for sites identified as not PFP or RAU.
5.	Appropriately qualify the validity, uses and reliability of the CPRM data
reporting in OSWER's publicly available information systems.
Summary of Agency Response to Draft Report and OIG Evaluation
We received comments on the draft report from the Assistant Administrator for
OSWER on August 25, 2014. We held an exit meeting with OSWER staff on
September 24, 2014.
The agency disagreed with Recommendations 1, 2 and 3 and resolution efforts are
in progress. We continue to believe these recommendations are valid and their
implementation would improve the integrity and value of the RAU measures.
The agency agreed with Recommendations 4 and that recommendation is open
with agreed-to actions pending. The agency also agreed with Recommendation 5
and, as a result of the agency subsequently providing us with a milestone date,
that recommendation is also open with agreed-to actions pending.
The agency also suggested changes to the report and we made changes where
appropriate.
Appendix A contains the agency's complete response and well as OIG comments
on that response.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec. Page
No. No.
Subject
Status1
Action Official
Planned
Completion
Date
POTENTIAL
MONETARY
BENEFITS (in $000s)
Agreed-
Claimed To
Amount Amount
14	Improve controls of the CPRM measures by
revising the CPRM guidance to require:
a.	Grantees to track and report the status and
type of reuse at RAU sites, instead of
voluntary reporting.
b.	Brownfields and RCRA CA staff to obtain
and review grantees' supporting
documentation for sites designated PFP
and RAU and verify that the grantees
provide information in the appropriate
OSWER databases.
c.	UST staff to obtain and review grantees'
supporting documentation for a selected
sample of sites designated PFP and RAU
and verify that the grantees provided
information in the appropriate OSWER
databases.
15	After CPRM interim guidance is revised, provide
training to regional OSWER staff responsible for
verifying states' PFP and RAU designations to
ensure staff are informed of the guidance and
what is required.
15 Stipulate the following in the grant agreements for
each program:
a.	For Brownfields, require grantees to track
the status and type of reuse of remediated
sites and report that information to
OSWER.
b.	For RCRA CA, whenever there is a change
in site conditions or site use, require states
to revise the RCRA CA determination form
to reflect the changes and have states
re-submit the form to OSWER.
c.	For UST, require states to submit to
OSWER and make publicly available site-
specific information, including site name.
15 Correct designations for sites identified as not
PFP or RAU.
15 Appropriately qualify the validity, uses and
reliability of the CPRM data reporting in
OSWER's publicly available information systems.
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
10/12/14
03/31/15
1 0 = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
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Appendix A
Agency Response to Draft Report
and OIG Evaluation
August 25, 2014
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report EPA Needs to Improve Its
Process for Accurately Designating Land as Clean and Protective for Reuse Project
No. OPE-FY12-0016
FROM: Mathy Stanislaus
Assistant Administrator
TO:	Arthur A. Elkins, Jr.
Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. Following is a summary of the agency's overall position, along with its position on each
of the report recommendations. For those report recommendations with which the agency agrees,
we have provided high-level intended corrective actions and estimated completion dates to the
extent we can. For those report recommendations with which the agency does not agree, we have
explained our position, and proposed alternatives to the recommendations. We would appreciate
the opportunity to meet with you if you do not plan to accept these changes.
AGENCY'S OVERALL POSITION
The Agency works collaboratively with states, tribes, local government, and other stakeholders
to achieve its mission of assessing, cleaning up and restoring contaminated sites to set the stage
for redevelopment or facilitate the continued use of the facility. For the Superfund Program, EPA
directly oversees the cleanup activities. Other EPA programs were designed by Congress to be
delegated or authorized to states (e.g., RCRA Corrective Action, Underground Storage Tanks) or
established as a grant program (Brownfields). In fact, the majority of site-specific cleanup
decisions are made by the state-run or state-delegated programs, including decisions about
protectiveness. These roles and oversight are inaccurately portrayed in various parts of the draft
OIG report.
OKi Response I: The OIG has made re\isions where appropriate
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For example, there are no Brownfield specific regulatory authorities governing the cleanup of
brownfields delegated to the states. The EPA does not have statutory authority to require state
oversight of Brownfields cleanups.
The various roles, responsibilities, and relationships between EPA, states, tribes, and grantees
must be taken into consideration when designing and establishing an effective performance
reporting system. When a program is delegated or authorized to a state or is implemented
through a grant program, EPA relies on that entity to document and report results. These entities
are best placed to address site-specific problems as they arise on a day-to- day basis. EPA works
to strengthen and assist them and has established requirements for data reporting. Any data
reported for the performance measures should adhere to EPA's quality information policies.
OIG Response 2: We agree that any data reported for the performance measures should
adhere to EPA's quality information policies. As cited in EPA's Executive Order CIO 2105.0,
Policy and Program Requirements for the Mandatory Agency-Wide Quality System, Section 6
(a) (8), assessment of existing data, when used to support agency decisions or other secondary
purposes, must verify that the data is of sufficient quantity and adequate quality for their
intended use. As we have demonstrated in our report, OSWER does not have sufficient
controls and procedures to ensure that the CPRM data meets the quality standards cited in the
Executive Order.
In that way, the data used to report performance data are reliable and as complete as possible
given the structure of these programs.
The Cross-Program Revitalization Measures (CPRM), including the Ready for Anticipated Use
(RAU) measure, are a few of the numerous performance measures EPA uses to help manage the
program and gauge progress of sites along the cleanup continuum. The OIG inaccurately refers
to these measures as a "CPRM program".
OIG Response 3: As cited in Office of Management and Budget Circular A-l 1, the
Government Accountability Office defines a program as an organized set of activities directed
toward a common purpose or goal that an agency undertakes or proposes to carry out its
responsibilities. Therefore, the CPRM is a program. However, the term is not needed to make
our point and has been removed from the report.	
Four EPA cleanup programs report the RAU measure which allows us to better manage and
communicate at an OSWER level our collective cleanup and reuse related activities and
accomplishments3. The four cleanup programs are facilitated to work together to identify lessons
learned, potential efficiencies, and opportunities to advance site cleanup. EPA is then able to
look at this information collectively across programs and Regions, and gauge overall progress
cleaning up contaminated sites.
The RAU is not a reporting of site-specific risk. The RAU determination by the appropriate
entity is based on information at the time that the determination is made. It may change if the
3 The RAU is actually made up of specific performance measures from the Superfund, RCRA Corrective Action,
Brownfields, and Underground Storage Tank Programs.
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site's conditions change or if new or additional information is discovered regarding the
contamination or conditions at the site. Thus, the Agency publicly reports the RAU information
at a program level for the state-run or grant programs, not at a site- specific level with the names
of sites; therefore, it is not available to be used to make decisions on site reuse. The one
exception is the Brownfields program, at this time. The Brownfields program is removing the
RAU information from the public information system.
OIG Response 4: We do not agree that site-specific RAU information is only available to the
public for Brownfields sites. As can be found at
http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0301376. site-specific RAU
information is also available for the Superfund program. Instead of removing the site-specific
RAU information, EPA could qualify this data as recommended in OIG Recommendation 5.
Parties interested in finding out what uses would be protective for a particular property will rely
on site-specific cleanup documents and site-specific institutional controls and contact the
appropriate regulatory agency for more information.4
We plan to improve our communication materials to better explain the use of CPRM, the
conditions under which a RAU determination is made, and that the measures represent a point in
time. We have already begun to do this and will continue to explore ways to better explain the
measures to the public.
4 We recognize that the lack of data on institutional controls (ICs) for the underground storage tanks program is not
consistent with the definition of the RAU performance measure and we are working with the states to develop a
baseline of current practices related to long-term protectiveness and whether the IC data can be made available.
Nonetheless, we believe the LUST measure is a good indicator of sites ready for anticipate use, given the states'
determination that no further action is currently necessary to protect human health and the enviromnent.
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AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
AGKKKMKNTSs
No
Recommendation
I liuh-l ,e\ el Intended CoiTccli\e Action!s)
l-slimaled Completion
In Quarter and IV
4
Correct designations for
sites identified as not PFP
or RAU
Once the IG provides EPA with the list of 10 brownfields sites that it
believes have been mistakenly identified as either PFP or RAU then EPA
will review the information in the ACRES database to determine if the
IG's findings are correct and make any necessary changes to the PFP
and/or RAU status of the sites.
(In addition, all our programs will continue to work with regions and states
to correct any inaccuracies as they are identified.).
Within 30 days of
receiving the list of
sites from the IG.
5
Appropriately qualify the
validity, uses, and
reliability of the CPRM
data reporting in OSWER's
publicly available
information systems.
EPA will remove the RAU indicator for Brownfields sites from the
Cleanup In My Community database. The CPRM is not intended to be
used as a site-specific indicator for brownfields properties, rather it is
intended to be a measure of progress across the universe of brownfield
sites receiving EPA funding.
Furthermore, we are exploring ways to better explain RAU to the public.
As appropriate, EPA will include in its public communication materials
that the PFP and RAU measures represents a point in time and will include
information about conditions under which a RAU is made to explain
potential ICs and ECs may be required.
1st qtr FY 15
On-going. EPA is
adding clarifying
language to reports
and other
communication
materials about the
CPRM.
disa(;ui:i:mi:ms
No
Recommendation
Agency l-xplanation Response
Proposed Alteinati\e
1
Improve Controls of the CPRM measures by finalizing the interim guidance to require la, lb, and lc.
(Please note, the use of the term "interim" in the OSWER CPRM guidance did not mean draft. It met an interim step. The final
step was for program offices to develop their own program specific guidances. The draft CPRM guidance was sent for comment in
April 2006 and finalized October 2006. )
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la
States to track
and report the
status and type of
reuse at RAU
sites, instead of
voluntary
reporting.
See responses to 3a, 3b, 3c.

lb
Brownfields and
RCRA CA staff
to obtain and
review grantees'
supporting
documentation
for sites
designated PFP
and RAU
and verify that
the grantees
provide
information in the
appropriate
OSWER
databases
The RCRA Corrective Action program will remind Regions that these forms need to
be filled out for PFP and RAU and they should work with their states to verify that
these forms are filled out for future RAU and PFP determinations entered into RCRA
Info (EPA's RCRA corrective action national database.)
The Brownfields Program's existing Assessment, Cleanup, and Redevelopment
Exchange System (ACRES) system is designed and structured to collect brownfield
grantee reported information. Under the grant terms and conditions of the
Assessment, Cleanup, Revolving Loan Fund, and State and Tribal Response Program
grants, grant recipients are required to complete an OMB approved Property Profile
Form in ACRES for each property where grant funding is expended. As Brownfields
grants awarded prior to 2003 do not have a requirement to complete the Property
Profile Form under their grant conditions, they are not included in the reporting of
CPRM measures. The Ready for Anticipated Use (RAU) performance measure for
properties where federal brownfields funding has been expended is based on
information entered by the grantee on the Property Profile Form. An RAU
designation depends on documenting that a property meets the three criteria in the
RAU definition. As part of grant oversight and monitoring activities, EPA Regional
staff assist grantees, providing guidance on the completion of forms, ensuring timely
submission of forms, and completing quality assurance reviews of Property Profile
Form data. EPA collects property information via ACRES throughout the grant
period of performance, however, EPA cannot require grantees to enter information
about site activities after the close-out of the Brownfields grant or beyond that
approved by our existing information collection request approved under the
Paperwork Reduction Act by OMB.
Brownfields and
RCRA CA should
work with states to
improve
communication about
the CPRM and to
verify that the
appropriate forms are
completed.
(1st qtr FY15)
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lc
UST staff to
obtain and review
grantees'
supporting
documentation
for a selected
sample of sites
designated PFP
and RAU and
verify that the
grantees provided
information in the
appropriate
OSWER
databases.
Congress has designed and funded the UST program for state implementation
primarily. States make site-specific cleanup decisions, including determining when a
site is clean enough to be closed. EPA works with state partners to provide
regulations, guidance, policy, and funding resources to support the infrastructure of
state UST program so that the private and state resources can directly finance the
fieldwork necessary to clean up releases from federally regulated tanks releases.
UST staff should work
with states to properly
submit data into
OSWER's data system
and perform
appropriate QA/QC
checks.
(1st qtr FY15)
2.
After CPRM
interim guidance
is finalized,
provide training
to regional
OSWER staff
responsible for
verifying states'
PFP and RAU
designations to
ensure staff are
informed of the
guidance and
what is required
As noted earlier, the draft's authors may have misunderstood the context for the
"interim" nature of the CPRM guidance. Nonetheless, OSWER will improve
communications with the EPA regions on the CPRM tracking and reporting of
contaminated sites by issuing a memo from the Assistant Administrator to the regions
providing additional information on the measures, how they are used, and
expectations for reporting.
OSWER AA should
issue a memo to the
regions to ensure staff
are informed of the
CPRM guidance, how
the measures are used,
and what is required.
(1st qtr FY15)
3.
Stipulate the following in the grant agreements for each program:
3a
For Brownfields,
require states to
track the status
The Federal Brownfields program, in accordance with the Brownfield amendments to
CERCLA, is a national competitive grant program. It is not a regulatory or state-
delegated program. In keeping with this grant authority, Brownfields property
OBLR should expand
ACRES training to
place greater emphasis
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and type of reuse
of remediated
sites and report
that information
to OSWER.
cleanups are managed by the grant recipient and assessment and cleanup activities are
reported at a point in time to document grant funded activities. Moreover, while EPA
brownfield grants fund assessment or cleanup, but not redevelopment, property
specific reuse information often is not available at grant closure to report. Finally,
the internal CPRM measures are a snapshot in time and are not meant to track the
changing conditions at a site. As mentioned earlier, EPA cannot require grantees to
enter information about site activities after the close-out of a Brownfields
grant. Specific details about the scope of state VCP programs can be found in the
State Brownfields and Voluntary Response Program report, available online at
httD://www.eDa.gov/brownfields/state tribal/Dubs.htm.
on grantee reporting
and enrollment of
property cleanups in
State and Tribal VCP
programs, where
feasible.
(1st qtr FY15 -
ongoing)
3b
For RCRA CA,
whenever there is
a change in site
conditions or site
use, require states
to revise the
RCRA CA
determination
form to reflect the
changes and have
states re-submit
the form to
OSWER.
For the delegated CA states, cleanup decisions are made by states, EPA's recognition
of such cleanup decisions are based on these state decisions, and that the RAU is
simple a cumulative sum of these state cleanup decisions.
ORCR should
continue to
recommend that when
Regions or States
become aware of a
change in site
conditions or site use
that impacts the status
of PFP or RAU, they
should revise the PFP
and RAU
determination and
revise the forms.
3c
For UST, require
states to submit to
OSWER and
make publicly
available site-
specific
information,
including site
name.
States are the primary implementing agencies and make site-specific cleanup
decisions, including determining when a site is clean enough to be closed. EPA
works with state partners to provide regulations, guidance, policy, and funding
resources to support the infrastructure of state UST program so that the private and
state resources can directly finance the fieldwork necessary to clean up releases from
federally regulated tanks releases.
This recommendation
does not match the
nature of the UST
program and should be
deleted.
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CONTACT INFORMATION
If you have any questions regarding this response, please contact Brigid Lowery, Director,
OSWER Center for Program Analysis on 202-566-0198.
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Deputy Assistant Administrator for Solid Waste and Emergency Response
Director, Center for Program Analysis, Office of Solid Waste and Emergency Response
Audit Follow-Up Coordinator, Office of Solid Waste and Emergency Response
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