UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
O
January 23, 2009
OSWER Directive #9200.1-93
MEMORANDUM
SUBJECT: Revised Guidance on Reclassification of Superfund Special Accounts
FROM: James E. Woolford, Director /s/
Office of Superfund Remediation & Technology Innovation
Office of Solid Waste and Emergency Response
Marcia E. Mulkey, Director /s/
Office of Site Remediation Enforcement
Office of Enforcement and Compliance Assurance
Lorna M. McAllister, Director /s/
Office of Financial Management
Office of the Chief Financial Officer
Carol Terris, Acting Director /s/
Office of Budget
Office of the Chief Financial Officer
Raffael Stein, Acting Director /s/
Office of Financial Services
Office of the Chief Financial Officer
TO: Regional Counsel, Regions I-X
Superfund National Program Managers, Regions I-X
Regional Comptrollers, Regions I-X
I. INTRODUCTION
The purpose of this memorandum is to provide revised guidance on reclassification of
special accounts. This guidance supersedes portions of prior Agency documents related to the
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reclassification of special accounts.1
Attached to this memorandum are four documents. Attachment 1 is a step-by-step table of
the reclassification process. Attachment 2 is a model document for Regions to use to advise
Headquarters of their plan to reclassify funds. Attachment 3 is a sample spreadsheet Regions
may use for developing reimbursable authority requests and KV transactions to record the
reclassification. Attachment 4 is a model Regions may use when entering reprogramming
information into the Agency's financial system for recertifying Superfund appropriation
resources made available as a result of the reclassification process.
II. BACKGROUND
Section 122(b)(3) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), 42 U.S.C. §9622(b)(3), authorizes EPA to retain and use funds
received through an agreement to fund response actions contemplated in the agreement. EPA
retains these funds in site-specific accounts, called "special accounts." EPA will only establish a
special account if there is future work at a site.2
The use of a special account to fund response actions is determined by the settlement
language under which the funds were received. Most settlements provide that funds in a special
account will be used to conduct or finance response actions at or in connection with the site.3
EPA's general hierarchy4 for use of special account funds is as follows:
a. retain the funds as a future settlement incentive with potentially responsible
parties (PRPs);
b. fund any response actions, including the oversight of PRP-lead response
actions;
c. estimate and retain funds to address future site costs/risks, then apply remainder
to previous site expenditures5 (reclassification); and
d. transfer any remaining balances to the general part of the Trust Fund.
In situations where the settlement indicates that the funds are earmarked for a specific activity
(e.g., disbursed to a PRP or to fund a specific operable unit), the activities identified in the
settlement take precedence over the above hierarchy.
1 Reclassification of special accounts has been discussed in several Agency guidances, including: "Special
Accounts: Guidance on Key Decision Points in Using Special Account Funds" (September 28, 2001)(Timing and
Use Guidance); "Consolidated Guidance on Establishment, Management and Use of CERCLA Special
Accounts"(October 4, 2002)(Consolidated Guidance); Attachment 4 to the "Superfund Special Account Guidance"
(July 16, 2002); and "Additional Guidance on Prepayment of Oversight Costs and Special Accounts" (December 22,
2006)(Prepayment Guidance).
2 See Consolidated Guidance on page 7.
3 See "Placement of Proceeds from CERCLA Settlements in Special Accounts"(January 27, 2000).
4 These are clarifying restatements of the hierarchy for use language in the Timing and Use Guidance, on page 3.
5 For purposes of this guidance, an "expenditure" is equivalent to a "disbursement."
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EPA has also recently undertaken an effort to better manage Superfund special accounts.
As part of that effort, each Region monitors the status and uses of special accounts throughout
the life cycle of a Superfund site. This includes conducting periodic reviews of special accounts
and updating data fields in the Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS), as necessary.
III. RECLASSIFICATION
Reclassification of special account funds is a process under which the Agency uses the
funds in a special account to finance response actions previously funded through Superfund
appropriation resources at that site. The use of special account funds for reclassification puts
EPA in the same position it would have been in if the PRP settlement proceeds had been
received prior to the expenditure of Superfund appropriation resources at that site. Use of PRP
settlement dollars in this manner is consistent with the terms of the settlement under which EPA
received the dollars (i.e., funds are being used to finance response actions at the site).
A. KEY TERMS
Expenditures eligible for reclassification - Previous expenditures of Superfund
appropriation resources such as current year budget authority, carryover, and recertified
Superfund appropriation resources.
General Ledger - The major record in the Agency's accounting system wherein all
transactions are summarized. It contains the principal accounts from which the trial
balance and related financial statements are prepared and constitutes the control point of
the accounting system.
KV transaction - A financial transaction that allows EPA to make adjustments in the
Agency's financial management system to establish and document a reclassification.
Special account reclassifications may only be executed by recording the KV transaction.
Recertification - The process by which prior year Superfund appropriation resources that
were replaced by the special account funds are made available for future obligation.
Reclassification - The process by which EPA uses funds in a special account to reimburse
previous EPA expenditures of Superfund appropriation resources for response actions at
the site.
Special accounts - Site-specific accounts established by EPA pursuant to Section
122(b)(3) of CERCLA, and are used by EPA as contemplated by the agreement under
which the Agency received the funds. Special accounts are sub-accounts within the
Hazardous Substance Superfund (Superfund Trust Fund). These funds are identified in
the Agency's financial management system by the fund codes "TR2," "TR2A," or
"TR2B."
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Superfund appropriation resources - Resources appropriated to EPA by Congress from
the Superfund Trust Fund. These resources include current year budget authority as well
as prior year appropriated resources such as carryover and recertified funds. These funds
are generically referred to as "T" funds.6
B. WHEN TO CONSIDER RECLAS SIFICATION
Each reclassification decision is based on site-specific circumstances. Generally, the
Region should consider the reclassification of special account funds (principal and interest) when
a Region determines that there are more than sufficient funds in the special account to fund
remaining response actions at that site. This determination will often, but not necessarily, occur
after response action(s) to implement cleanup are substantially complete (e.g., construction
complete) and better estimates can be developed to indicate the funds necessary to retain for
post-construction completion work (e.g., long-term response action, operation and maintenance,
and five-year reviews).
In some cases it may be appropriate to defer consideration of reclassification until after the
Region has performed at least one five-year review to determine the ongoing effectiveness of the
remedy. This may be particularly true for ground water sites and for sites with large or complex
remedies. Conversely, there may be situations where it may be appropriate to consider
reclassification earlier in the response process. This may occur when a PRP is performing all
remaining response actions under a settlement, there is adequate financial assurance (e.g., a
secured financial instrument), and future EPA incurrence of response costs is anticipated to be
minimal. Another situation could be when a settlement provides funding for a specific activity
but EPA expends Superfund appropriation resources for that activity before the payment is
received to fund that activity. In all situations, decisions regarding the use of special account
funds should be made throughout the life cycle of a site and be reflected in CERCLIS. As site
conditions change, so may the priority for the use of special account funds, including the timing
for reclassification.
When considering whether to commence reclassification, the Region should also allow
sufficient time to complete the entire reclassification process, including recertification and
obligation of the appropriated funds made available as a result of the reclassification prior to the
end of the fiscal year.
C. HOW TO ACCOMPLISH RECLASSIFICATION
The reclassification process has several sequential steps. Attachment 1 is a step-by-step
chart of the activities needed to accomplish reclassification.
Step 1. Reclassification Justification Memorandum
6 Prior to FY 1996, Superfund appropriated funds were recorded with a numeric character representing the fiscal
year in front of the "T" (e.g., 2T (1992), 3T (1993), 4T (1994), etc.).
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Once a Region decides to commence the reclassification process, the Regional Program
Office (RPO), after consulting with the Office of Regional Counsel,7 should prepare and send a
draft reclassification justification memorandum in the form shown in Attachment 2 to the Office
of Site Remediation Enforcement (OSRE) and Office of Superfund Remediation and Technology
Innovation (OSRTI) Headquarters staff (contacts are identified at the end of this memorandum)
for review and comment.8 The draft reclassification justification memorandum should contain
the following information:
a. site background;
b. the current status of the cleanup;
c. the entity (e.g., EPA, State, Federal facility, PRP, or other parties) that is
performing the work;
d. the settlement language that describes the use of the funds in the special account
that will be reclassified;
e. description of future actions and estimate of costs still to be incurred;
f. rationale (including cost and risk assumptions) for costs still to be incurred;
g. the amount of funds to be reclassified;
h. identification of the categories (e.g., remedial, removal, enforcement) of
previous activities against which the special account funds will be applied and the
dollar amounts for each category; and
i. the planned use of the reclassified dollars to ensure that Superfund appropriation
resources made available through reclassification will be used consistent with the
current fiscal year Deobligation Recertification Guidance memorandum.
As part of the development of the reclassification memo, the Region should prepare
documentation of the site-specific "T" expenditures that will be reclassified. Expenditures
eligible for reclassification should include only site-specific costs that are identified in the
Agency's financial system.9 Attachment 3 provides a sample spreadsheet that contains the site-
specific information the Regional Program Office, the Regional Budget Office (RBO), and the
Regional Finance Office (RFO) or Servicing Finance Office (SFO)10 may use to determine the
appropriate coding for the Region's request for reimbursable authority (Step 2) and to process
the KV transactions (Step 3). The Region should also ensure that data in CERCLIS for planned
reclassifications in the special account is consistent with the justification memo.
The Region should also consider the potential implications of reclassifying resources that
were previously used to fund remedial action at the site where a state has previously paid a state
cost share for that action. If the settlement under which EPA received the special account funds
(which are now being reclassified) did not address allocation of settlement proceeds between
7 The Office of Regional Counsel's role is to ensure that the use of the funds is consistent with the settlement under
which the funds were received and that the funds are actually available for reclassification (e.g., have not previously
been promised to a PRP or are being retained as a future settlement incentive).
8 If a Region is unsure whether the timing for reclassification is appropriate, it may first contact OSRE and OSRTI
staff before drafting a reclassification memorandum.
9 By definition, site-specific costs captured in the Agency's financial system do not include annual allocation and
indirect costs that may be assigned site-specifically in the Superfund Cost Recovery Package Imaging and On-line
System (SCORPIOS) for cost recovery purposes.
10 The term SFO includes both Regional Finance Offices and National Service Centers.
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EPA and that state, the Region should explain in the justification memorandum how they will
address the reduction of Superfund appropriation resources and the state cost share.
After receiving the draft reclassification justification memorandum, the OSRE and
OSRTI Headquarters contacts will coordinate with other affected Headquarters offices, and
provide written comments to the Region within 15 days. If, after receiving and addressing
Headquarters comments, the Region wants to move forward with reclassification, the Region
will then finalize the reclassification justification memo (signed at the RPO Division Director
level). The final memorandum should be sent to the Office Directors of OSRE and OSRTI, with
a copy to the Office Director of the Office of Budget (OB).
Step 2. Request for Reimbursable Authority for the Special Account
Consistent with the information provided in the final reclassification justification
memorandum, the Region may then proceed with reclassification. The RBO will enter into the
Agency's financial system a reprogramming request for reimbursable spending authority for
special account resources that will be used in the reclassification process to replace previous "T"
disbursements at the site. The Region should follow the general procedures outlined in the
current fiscal year Reimbursable Authority Guidance issued by OB when requesting
reimbursable authority. The purpose statement in the reprogramming request should identify the
date of the final justification memorandum.
The total amount of reimbursable authority requested for the special account must equal
the amount of "T" disbursements being reclassified,11 and the Program Results Code (PRC) for
the special account funds should be the current analogue of the PRC or Program Element (PE)
code originally used for the "T" disbursements. Once OB approves the reprogramming,
reimbursable authority will be moved into the appropriate regional allowance to allow the
obligation and expenditure of special account funds. The request for reimbursable authority can
be done in advance or just prior to the subsequent KV transaction (explained below).
Step 3. The KV Transaction
After reimbursable authority to use special account resources has been issued to the
Region, the RFO or SFO should use the data prepared to support the reclassification justification
memorandum to enter a KV01 transaction in the financial system. The KV01 transaction
generally does the following:
a. decreases site-specific expenditures recorded under the "T" fund code, which in
effect deobligates the "T" funds; and
b. increases site-specific expenditures in "TR2," "TR2A," or "TR2B," as
appropriate, using the current Budget Fiscal Year and the appropriate current year
PRC and Site/Project field codes that correspond with the PRC (or PE) and
Site/Project field codes of the funds being decreased.
11 In situations where reimbursable authority already exists from prior reimbursable authority requests, the Region
should only request the additional amount needed for the reclassification.
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Recording the KV transaction replaces Superfund appropriation resources expended at
the site with special account resources, which then makes prior year Superfund appropriation
resources available for recertification. The KV01 transactions and General Ledger impact,
including a description of the special account fund codes, are in Attachments 1 and 4 of the
Superfund Special Account Guidance issued by the Office of the Chief Financial Officer
(OCFO).12 If Superfund appropriation resources have been obligated but not yet expended, and
the Region then decides to use special account resources to fund that activity, the resulting
financial vehicle modifications or amendments are not recognized as reclassifications.
KV transactions are recorded in the General Ledger and not at the level of detail of the
financial vehicle associated with the original expenditure(s). The RPO or RFO may collect
financial vehicle information for internal record keeping; however, financial vehicle expenditure
data should not be used as the basis for reclassification amount eligibility because records at this
level of detail will not identify reclassifications that may have already taken place.
Step 4. The Recertification Request
The KV transaction records the exchange of Superfund appropriation resources at the site
with special account funds, effectively making Superfund appropriation resources available for
recertification for new purposes. At this point, the Region should proceed with a recertification
request to allocate the reclassified Superfund appropriation resources in accordance with the
current fiscal year Deobligation Recertification Guidance.
The recertification request should follow the same procedures as used for the
recertification of normal deobligations, but should refer to the date of the final reclassification
justification memorandum and the KV01 transactions rather than obligating document numbers.
Funds made available as a result of the KV01 transaction will be reprogrammed using the
Superfund deobligation recertification fund code ("TCD"). Attachment 4 provides a model for
the reprogramming request for the recertification.
D. REMAINING SPECIAL ACCOUNTS FUNDS AFTER RECLASSIFICATION
If there is no future work and special account funds remain after the reclassification
process, the Region should consider closeout of the special account. The process of transferring
remaining special account balances to the general portion of the Trust Fund requires
communication between the SFO and RPO, who will jointly advise the Cincinnati Finance
Center (CFC) of the amount of special account funds to be transferred to the general portion of
the Trust Fund.13
IV. CONCLUSION
Reclassification is a valuable tool to ensure that special account funds are used to pay for
the costs of cleanup at their designated sites. The process allows EPA to properly consider costs
12 See "Superfund Special Account Guidance" (July 16, 2002).
13 For more detail on special account closeout procedures, see "Superfund Special Account Closeout Procedures"
(September 28, 2005).
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to be incurred in the future at a site as well as those costs previously incurred by EPA. By
effectively using special accounts, EPA is able to direct Superfund appropriation resources
toward sites that do not have special account proceeds or PRPs to conduct response work. Please
direct reclassification proposals or questions about this guidance to the following lead contacts,
as appropriate.
• For reclassification justification memorandum and guidance questions, contact:
o Tracey Stewart, OSRTI, at (703) 603-8791 (OSRTI will coordinate with other
OSWER offices as necessary)
o Gary Worthman, OSRE, at (202) 564-4296
• For additional questions regarding reclassification procedures, including reprogramming
requests, KV transactions, and recertification/deobligation policy, contact:
o Diane Kelty, OB, at (202) 564-7688
o Kevin Brittingham, OFM, at (202) 564-4941
o Connie Ely, OFS, at (513) 487-2075
o Greg Luebbering, OFS, at (513) 487-2074
cc: Regional Budget Officers, Regions I-X
OSWER Senior Budget Officer
OECA Senior Budget Officer
Director, Office of Emergency Management (OSWER)
Director, Federal Facilities Restoration and Reuse Office (OSWER)
Director, Office of Program Management (OSWER)
Director, Assessment and Remediation Division (OSWER/OSRTI)
Director, Resource Management Division (OSWER/OSRTI)
Superfund Regional Branch Chiefs, Regions I-X
Superfund Information Management Coordinators, Regions I-X
Superfund Budget Coordinators, Regions I-X
Attachments
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Attachment 1
Process for Special Account Reclassification
Steps
Who1
What
Why
1. Reclassification
Justification
Memorandum and
Supporting
Documentation
Regional
Program
Office
Headquarters
Contacts
Prepare and send draft
reclassification justification
memorandum to Headquarters
for review/comment.
Coordinate with other
Headquarters offices and
consults with the Region on
the proposal.
Draft reclassification justification
memorandum advises Headquarters of
Region's plan to reclassify balances.
Consultation ensures national consistency
and proper management consideration is
given to the proposal.
Regional
Program
Office
Prepares final reclassification
justification memorandum
after consultation with
Headquarters.
Final reclassification justification
memorandum advises Headquarters of
Region's decision to move forward with
reclassification.
Regional
Program
Office
Prepares documentation to
support reimbursable authority
request and KV transactions.
Documentation ensures decision can be
executed in the Agency's financial system,
amounts are consistent, and basis for
recertification to appropriate PRCs is
documented.
2. Request for
Reimbursable
Authority
Regional
Budget Office
Submit reprogramming
request in Agency's financial
management system.
Request enables OCFO to issue
reimbursable authority for expenditure of
special account funds ("TR2," "TR2A,"
"TR2B") to replace Superfund
appropriation resources.
3. KV01
Transactions
Servicing
Finance Office
Adjust "T" expenditures
in financial system at General
Ledger level, moving them
from "T" to "TR2", "TR2A",
or "TR2B."
Action replaces Superfund appropriation
resources with special account resources in
the Agency's financial system; essentially
deobligates the "T" funds and makes them
available for recertification.
4. Request
Recertification of
"T" Funds Made
Available by
Reclassification
Regional
Budget Office
Submit recertification
reprogramming request (see
Attachment 4 for example) in
Agency's financial system
consistent with current fiscal
year Deobligation
Recertification Guidance.
Recertification request informs
Headquarters of request for allocation of
funds made available as a result of special
account reclassification; KV document
number is needed on the reprogramming
request to allow Control Team to verify KV
adjustment.
5. Recertification of
"T" Funds Made
Available by
Reclassification
Office of
Budget
Recertifies the prior year "T"
funds by putting them in the
"TCD" fund code for the
current budget fiscal year.
Action makes deobligated "T" funds
available in current FY in "TCD."
1 Particular Regional office responsibilities may vary depending on how a Region is organized and operates.
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Attachment 2
MEMORANDUM
SUBJECT: Reclassification of Special Account Funds for the [Site Name] Site
FROM: [NAME], Director
Superfund Division, Region XX
TO: [NAME], Director
Office of Site Remediation Enforcement
Office of Enforcement and Compliance Assurance
[NAME], Director
Office of Superfund Remediation and Technology Innovation
Office of Solid Waste and Emergency Response
The purpose of this memorandum is to serve as notification of the Region's intent to
reclassify funds in the [Site Name] special account [Special Account Number], The total amount
to be reclassified in this action is [insert amount]. As discussed below, the Region is reserving
sufficient funds to address remaining future needs so that the amounts identified can be
reclassified. The Region plans to request recertification in accordance with the current fiscal
year Deobligation Recertification Guidance.
Site Background
[Include basic information, e.g., status of site in the pipeline, parties responsible for
conducting the work, residual risks at the site, number of parties, types of decision documents,
enforcement actions at the site, costs incurred, and specific discussion of the amount of EPA's
past costs.]
Settlement and Special Account
[Include information about the settlement(s) under which EPA received the funds
deposited into the special account. This should include the current balance, any limitations on
use of the funds, and the amount of interest accrued on the account. There should be an
affirmative statement that the terms of the settlement document(s) have been reviewed with
current financial records and there is no impediment to this reclassification transaction.]
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Discussion of Future Work and Rationale for Reclassification
[The Region should discuss future work remaining at the site and timeframes, remaining
costs to EPA, and long-term planning assumptions, including various parties' future
implementation responsibilities, contingency or future remedy issues, and plans for future site
use.]
[Based on future planning assumptions, the Region should provide its rationale to
reclassify the special account funds in this section. For example, did work at the site cost less
than anticipated, or is a PRP now performing the work under a settlement? What is the Region's
estimate for the level of uncertainty regarding future actions at the site?]
[This section should also include the total amount requested for reclassification, the
categories (e.g., the remedial, removal, enforcement PRCs) of previous activities against which
the special account funds will be applied, and the dollar amounts for each category.]
Discussion of Planned Use for the Recertified Funds
[The Region should discuss the planned use of the recertified funds. The planned use
information should be detailed enough (e.g., site, activity, amount needed) to demonstrate how
the Region plans to use the recertified funds consistent with the current fiscal year Deobligation
Recertification Guidance.]
Please call [program contact], [site attorney], or [finance contact] if you have any
questions or concerns about this action.
cc: Legal, Program, Finance and Budget Headquarters Contacts
Regional Comptroller
Regional Budget Officer
Director, Office of Budget (OCFO)
Connie Ely, Office of Financial Services (OCFO)
Director, Program Costing Staff (OCFO/OFM)
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Attachment 3
Sample Spreadsheet for Use in Development
of Request for Reimbursable Authority and KV Transactions
Below is a sample spreadsheet that the Regional Program Office may use to identify for
the Regional Finance Office (RFO) or Servicing Finance Office (SFO) the correct accounting
line items in the Agency's financial management system to record KV decrease and increase
transactions as well as to prepare a request for reimbursable authority. This spreadsheet is not
required as part of the reclassification and recertification process, but is meant as a tool to assist a
Region in assuring consistency between the amounts identified for reclassification in a
reclassification justification memorandum and the actual reclassification.
Data sufficient to prepare a KV transaction are readily available from the "Budget Detail
Query" of the Financial Data Warehouse table of contents and may be downloaded to an Excel
spreadsheet. KV transactions are recorded in the General Ledger and not at the level of detail of
the financial vehicle associated with the original expenditure(s). The RPO or RFO may collect
financial vehicle information for internal record keeping; however, financial vehicle expenditure
data should not be used as the basis for reclassification amount eligibility because records at this
level of detail will not identify reclassifications that may have already taken place.
The first section of the spreadsheet includes accounting information for expenditures
eligible for reclassification presently in the Agency's financial system that will be subject to a
KV decrease transaction, which effectively deobligates prior year Superfund appropriation
resources. The second section of the spreadsheet identifies the new, current year, accounting
codes to be used to record the KV increase transaction, which effectively funds the previous
financial transactions using the special account resources. These data may also be used to
develop the request for reimbursable authority that must be requested before KV transactions are
recorded.
Original Line Item Data for KV Decrease
New Line Item Data for KV Increase
FY
Fund
Org
Prog
Job
No
Cost
Org
BOC
Paid Amt
FY
Fund
Org
Prog
Job No
Cost
Org
BOC
Paid Amt
1990
0T
6ALL
TFA
06B1L
2535
$632,060.71
2008
TR2B
06S
302DD2C
06B1CO01
C001
2505
$632,060.71
1991
1T
6ALL
TFA
06B1L
2535
$105,000.00
2008
TR2B
06S
302DD2C
06B1CO01
C001
2505
$105,000.00
1992
2T
6ALL
TFA
06B1L
2535
$170,569.83
2008
TR2B
06S
302DD2C
06B1CO01
C001
2505
$170,569.83
1993
3T
6ASN
TFA
06B1N
2535
$400,000.00
2008
TR2B
06S
302DD2C
06B1RD01
C001
2505
$400,000.00
1994
4T
6ASN
TFA
06B1N
2505
$51,427.56
2008
TR2B
06S
302DD2C
06B1RD01
C001
2505
$51,427.56
1995
5T
6ASJ
TFA
06B1N
2505
$193,058.31
2008
TR2A
06S
302DD2C
06B1RD01
C001
2505
$93,058.31
2008
TR2B
06S
302DD2C
06B1RD01
C001
2505
$100,000.00
Total
$1,552,116.41
Total
$1,552,116.41
Note: In the sample table, the last original line item is split into two new line items because multiple fund codes are
used.
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Attachment 4
Sample Special Account Reclassification Recertification Reprogramming in
Agency's Financial System
Document Trans Date BFY Fund
RP XXXXXXXXXX XX/XX/XX XXXX TCD
SPECIAL ACCOUNT RECLASSIFICATION RECERTIFICATION
(SARR)1
Example: Region XX requests recertification of $XX deobligated pursuant
to a reclassification from special account (XXXX) for XX Superfund site.
Final reclassification memorandum dated XX/XX/XXXX. KV
XXXXXXXXXX entered in the Agency's financial system on
XX/XX/XXXX. XX% of the reclassified "T" funds were from XX PRC
and will be recertified to XX PRC. $XX are being recertified to the National
Remedial (or Removal) Program.2
CONTACT: John Doe, XXX-XXX-XXXX.
Line From/To RPIO ORG PE BOC QTR Amount Bud Level Res Type
001 FROM XX XX XXX XX X XX XX X
002 TO XX XX XXX XX X ? XX XX X
1 To distinguish between recertification of resources made available due to Superfund special account
reclassifications and other reprogrammings in the Agency's financial system, please include this title or abbreviation
at the beginning of the reprogramming description request.
2 This sentence only applies to Superfund Remedial and Superfund Emergency Response and Removal
recertification requests.
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