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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF
SOLID WASTE AND
EMERGENCY RESPONSE

Luu 1 9 2016	NOW THE

OFFICE OF LAND AND
EMERGENCY MANAGEMENT

MEMORANDUM

SUBJECT: Quick Tips: Superfund Site A ssessment Coordination at
Non-Federal Sites

FROM: James E. Woolford, Director

Office of Superfund Remediation and Technology Innovation

TO:	National Superfund Program Managers

The attached document. Quick Tips: Superfund Site Assessment Coordination at Non-Federal Sites,
summarizes effective coordination practices when conducting Superfund remedial assessments at non-
Federal sites. These practices are based on individual input of experienced site assessors from nine U.S.
Environmental Protection Agency (EPA) regions, 30 states and five tribes. The Office of Superfund
Remediation and Technology Innovation (OSRTI) worked with EPA, state and tribal site assessors to
gather and summarize these practices.

The document contains no requirements; however, a new section describing coordination points to
consider when assessing sites has been added to Chapter VI, "Remedial Site Assessment," of EPA's
Superfund Program Implementation Manual (https://semspub.epa.uov/work/l 10/190517.pd0. I
encourage regional Superfund site assessment managers and staff to periodically review the practices
described in this document and consider whether existing coordination practices can be improved.

In closing, I want to thank the following individuals who collaborated with my staff to develop this
document: Gabriele Hauer (IN), Dale Urban (UT), Tedd Yargeau (CA), Jason White (Cherokee Nation),
Cathy Moyik and James Desir (EPA Region 2), Lorie Baker (EPA Region 3), Ralph Howard (EPA
Region 4), David Brauner (EPA Region 5), LaDonna Turner (EPA Region 6), and Victor Ketellapper
(EPA Region 8).

If you have questions regarding this document, please contact Dana Stalcup, Director of the Assessment
and Remediation Division in OSRTI (703-603-9702, stalcup.dana@epa.go v). or have your staff contact
Randy Hippen (703-603-8829, hippcn. randy@epa. go v) or Melanie Keller at (703-603-8706,

kelleiMnelanie@eDa.uov).

Attachment

Internet Address (URL) • http://www.epa.gov	QPMQ Rnr |R 1*1 1 QfiRHR

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Flw^ReVySiedH'aper' '' ' ~ ' 3UOUU


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cc: Reggie Cheatham, OLEM/OEM
Barnes Johnson, OLEM/ORCR
David Lloyd. OLEM/OBLR
Cyndy Mackey, OECA/OSRE
John Michaud, OGC/SWERLO


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d EPA

Quick Tips: Superfund Site Assessment
Coordination at Non-Federal Sites

U.S. Environmental Protection Agency	EPA Publication Number 9200.2-162

Office of Land and Emergency Management	December 2016

Introduction

EPA, along with its state and tribal partners, conducts
site assessments to identify and evaluate releases of
hazardous substances. These assessments determine
whether cleanup may be warranted under a
Superfund-managed or -monitored program.

These tips promote stronger coordination throughout
the Superfund remedial site assessment process. This
document discusses practices and techniques EPA, state
and tribal site assessors use to coordinate the workload
of non-federal sites needing assessment. Site-
assessment program managers are encouraged to
review this tip list and consider how they can improve
workload coordination.

To develop this document, a workgroup of EPA, state
and tribal site assessors independently gathered
coordination experiences and opinions from
experienced site assessment colleagues. These
experiences and opinions informed the document's
content. We have also provided quotes from site
assessors in key places to illustrate the difference that
coordination has made in their work.

Coordination between EPA, states and tribes
throughout the Superfund site-assessment process is
essential. Effective coordination conserves resources,
accelerates assessment, and unifies goals and
expectations during all phases of the site-assessment
process.

This document does nof establish a regulation or policy
and does not create any new requirements.

Coordination is a fundamental component of the EPA,
state and tribal partnership. Opportunities for
coordination occur throughout the site-assessment
process from site notification through final site
disposition. This document organizes elements of

effective coordination into the following sections:

•	Coordination Basics;

•	Strategic Program Management;

•	Site Notification and Data Collection;

•	Report Writing and Decision Making;

•	Transitioning Agency Lead; and

•	Public Outreach.

Coordination Basics

The following elements help form the foundation of
effective coordination:

Communication Skills

Assessors cited the following communication skills as
being associated with highly effective coordination:

•	Willingness to engage in a timely, collaborative
manner;

•	Awareness of what information is important to
share, when to share it, and who to share it with;

•	Support for an open, straight and constant line
of communication; and

•	Willingness to actively participate in face-to-
face meetings.

Agreements

Agreements are a building block for a successful
working relationship between EPA and its state and
tribal partners. The agreement types are:

•	Site assessment cooperative agreement;

•	Superfund memorandum of agreement or
memorandum of understanding; and

•	State deferral agreement.

Elements of
Effective Coordination

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Several assessors feel existing non-funded agreements
could be brought up-to-date, offer more detail, and be
used more widely. Assessors felt coordination is more
effective when agreements are:

•	Communicated to staff to promote awareness of
them and how they can support a stronger, long-
lasting partnership;

•	Based on input provided by all parties;

•	Detailed enough to include:

o Clearly defined roles, responsibilities and
expectations;

o What each party will do and when (e.g.,
specific reporting requirements, defined
timelines for reviews and addressing
comments); and

o Specific terms and conditions;

•	Flexible enough to accommodate changing
priorities;

•	Regularly updated to incorporate new terms,
objectives and schedules, with changes
communicated to all program staff;

•	Evaluated for improvement by partners in an
open and cooperative fashion; and

•	Limited in terms of reporting requirements to only
essential elements.

Where funding agreements exist, EPA works with states
and tribes to provide funding for site assessments. Like
other phases of Superfund, funding for assessments is
constrained, and the program is under continual
pressure to find and implement efficiencies. Effectively
coordinating with partners on resource allocation
decisions can be especially challenging when both staff
and funding are limited.

Site assessors felt coordination on resource allocation
decisions is most effective when there is:

•	An open and timely discussion of funding needs;

•	A consistent and transparent funding process
discussion (this may help create solutions to
working with limited resources);

•	Use of allocation models (to avoid any
appearance of arbitrary funding);

•	Discussion with partners on leveraging resources
to use them efficiently and minimize downtime,
including:

o Mix of state, tribal and EPA contractor-led
work, including consideration of data
collection costs and program strengths;

o Resource sharing, including:

¦	Equipment (e.g., mobile analytical, drill
rigs);

¦	Labs; and

¦	EPA contractor resources (e.g., deep well
sampling by EPA contractor at a state-led
expanded site inspection);

•	Discussion of whether and how state capabilities
can be enhanced to offer more efficient options
for assessing sites; and

•	Discussion of complementary funding from other
federal, state or tribal programs (e.g., EPA
removal) to assess sites of common interest and
yield more comprehensive data.

"The option to conduct investigations through either
organisation allows us to adjust for fluctuations in contractor
and agency personnel workload to achieve the best fit at any
given time." — State site-assessment manager

"Close coordination helps identify best methods for analysis,
standard practices and timeframes for requesting site analysis
and lab assignments, sharing work plans and communication
on lab issues." — EPA site-assessment manager

'Additional training in field sampling techniques would help
to make the most of available resources." — State project

Collaboration Tools

Site assessors use a combination of methods to
communicate site information to partners. In general,

"MODs for cleanup sites are an effective [tool]for leveraging
funding resources for tribes." — Tribalproject coordinator

"The [state] CA [cooperative agreement] is very simple and
direct. There was quite a bit of discussion and agreement on
various tasks before the CA was drafted; thus there are clear
expectations and understanding of what will occur." — State

Resources

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site assessors reported that regularly scheduled in-
person meetings are beneficial in strengthening the
atmosphere of cooperation and teamwork among
stakeholders.

Site assessors named the following tools as essential
components of strong coordination:

•	Phone calls and emails (e.g., weekly or biweekly
discussions on site progress);

•	Meetings (as funding and schedules allow),
especially when attended:

o On a regularly scheduled basis;

o In person (this is beneficial in strengthening
the atmosphere of cooperation and
teamwork among stakeholders);

o By staff and management; and

o Both individually (e.g., EPA Region and
single state or tribe) and in a group setting
(e.g., EPA Region and all its states and
tribes);

•	SharePoint and FTP (File Transfer Protocol) for
transferring files;

•	Database access by partner(s) to view site
information; and

•	Site visits.

"Phone calls: best tool to stay up-to-date with EPA partner
on site status and strategy. In-person meetings are always
effective to discuss process and responsibilities." — State staff
person

"Emails are fine but in-person training or communication for
the more complex issues is better." — Tribal director

'Phone calls are effective but the most effective coordination
tool is conference trainings and meetings, there must be face-
to-face interaction..." — EPA site-assessment manager

Guidance Documents

Site assessor opinions varied significantly on this
subject. Some felt coordination rests with people, not
with guidance. Others felt guidance covering
coordination steps would be helpful and recommended
the following activities:

•	Address coordination as guidance is developed
or revised; and

•	Create a reference tool of coordination points
throughout the site-assessment process.

Strategic Program Management

EPA implements annual operating plans and a five-
year strategic plan. These plans establish goals for
completing site assessments and other activities. EPA
Regions commit to meeting a portion of each goal. They
are responsible for working through staff, federal
contractors and/or states and tribes to complete
assessments. States and tribes often administer their
own cleanup programs independent of EPA and that is
where most sites assessed under Superfund eventually
reside.

States and tribes have consistently performed about
50 percent of Superfund assessments each year, but
this percentage varies greatly across EPA Regions
(from 0 to 100 percent). A smaller portion of states and
most tribes do not receive funding from EPA to conduct
Superfund assessments. When funded, communication
of goals and priorities is essential to effectively
managing the Superfund site-assessment program.

Site assessors felt coordination on strategic
management issues is more effective when timely,
regular, open and collaborative discussions occur with
a focus on:

•	Each partner's goals and priorities to identify
optimal strategies to address EPA, state and
tribal priorities;

•	Emerging issues;

•	Expectations;

•	Efficient handling of workloads; and

•	Flexibility, should program or site priorities
change during the year.

"Our monthly update calls provide for communication of
changes that are not urgent. We typically exchange email and
have separate calls when neededfor other topics or when more
urgent issues arise." — State program coordinator

Current national site assessment guidance contains
limited discussion of specific coordination steps with
states and tribes.

"We negotiate our deliverables before the work year
begins... terms and conditions allow the work between the
state and Region to be renegotiated in the e vent of different
priorities.EPA staff person

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Site Notification and
Data Collection

Site-specific workload coordination can begin as soon
as one or more partners become aware of the need to
assess a site. Effective coordination ensures site
notification and data collection activities run smoothly,
and that the lead agency is determined and has the
latest available site information.

Site assessors felt the following practices support highly
effective coordination on site notification and data
collection:

'EPA informs

le state of new sites via monthly calls with

state environmental and health agencies.EPA site-
assessment manager

"The state typically verbally notifies the [EPA] SAM

[site-assessment

anager] andfollows itp with a preemptive

email before sendi

ng the discovery or referralpackage to the

EPA SAM."-

State site-assessment manager

"The ability to lei

wage contractor resources (drillers, labs,

etc.) from EPA

elps preserve limited cooperative agreement

finding and reduces the amount of time neededfor

procurement if the

state had to obtain those same services."

— State manager



•	Collaborating with partners to discuss and
implement site discovery projects;

•	Establishing and adhering to a joint notification
process that includes:

o Points of contact in each agency;

o Process for assigning the lead agency;

o Method and timeframe for informing
appropriate EPA, state and tribal partners;
and

o Opportunities to discuss site issues; and

•	Before data collection begins, discussing new
sites and site strategies with partners helps
identify the most efficient use of available
resources and clarifies:

o	Agency lead;

o	Initial site strategy;

o	Work plans;

o	Data collection methods;

o Applicable and current standards in place
for each agency;

o Field sampling data objectives;

o Use of data quality objectives;

o Standard practices and timeframes for
requesting site analysis and lab assignments;
and

o Expectations, including timeline, for
completing assessments.

Report Writing and
Decision Making

Report Writing

Site assessors developing assessment reports should
clearly understand applicable reporting requirements
for their respective EPA Region to avoid rework and
downtime. This includes:

•	Report formats (e.g., document structure, use of
specific software, etc.);

•	Required content; and

•	The submission and approval process.

Site assessors associated the following elements with
highly effective coordination when writing reports:

•	Frequent discussions and training on current
document preparation and the review and
approval process, including:

o Required content;

o Structure and format, including flexibility;

o Submission and approval (including
transmission method and feedback loop);

o Timelines; and

o Distribution;

•	Joint development of report templates that meet
the needs of both agencies;

•	Online collaboration tools such as SharePoint
that facilitate transmittal of draft and final
documents; and

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• Email and phone calls, which can significantly
speed up the editing process.

'Extensive discussion

of report contents andformat has

allowed our state to de

velop a template that works for

EPA's needs." — Sta

fe site-assessment manager

"We have agreed-upoi

workflowprocesses for the report

review and appro val cy

cle, as well as standardised report

formats." — State mat

'ager

Decision Making

Effective coordination and communication during the
cleanup decision-making process can facilitate faster
decisions and smoother transitions to these cleanup
programs. Cleanup program options should be clearly
understood, and opportunities for input should be
established as appropriate. Cleanup decisions should
be communicated in a timely and effective manner.

Site assessors associated the following elements with
highly effective coordination when making site
assessment decisions:

• Partner agencies have a clear and consistent
understanding of the criteria used to make
decisions, including:

o

Site data;

o

Site risks and cleanup needs;

o

Cleanup options;

o

State, tribal and federal concerns;

o

Political support; and

o

Expectations;

•	Timely notification of new site information;

•	Timely notification when decision-making is
impacted by changes to policies, procedures or
guidance;

•	Collaborative decision-making, including:

o Understanding each agency's needs;

o Early and frequent cooperative discussions
with a willingness to openly and directly
discuss issues and solutions;

o Good project management and
communication skills; and

o Timely notification of final decisions to
appropriate partner agencies.

"Pre-decisional meetings need to occur on sites which are
likely to need cleanup so that allparties are comfortable with
the array of potential outcomes... rather than wait until the
end of the assessment to have these conversations and address
concerns.EPA manager

"Both EPA and states allow us to review the remedial site
assessment work at certain Superfund sites. We can make
comments and suggestions as needed [and] feel comfortable
enough to voice our concerns if needed." — Tribal staff person

'EPA allows our state to review and comment on draft
reports before they are finalised, which allows the state to
requestfurther information or clarification of the contents to
obtain information that is useful to us.State site

Transitioning Agency Lead

Agency lead changes commonly occur in the site
assessment process. This happens when a site assessed
by EPA is referred to a state or tribal program based
on a No Further Remedial Action Planned (NFRAP)
decision or Other Cleanup Activity referral. It also
happens when a site assessed by a state or tribe is
referred to EPA for potential National Priorities List
(NPL) listing or further assessment.

When lead changes occur, timely transfer of the latest
relevant site information facilitates the transition and
enables the lead agency to continue activity at the site
with less downtime. Partner agencies should have a
consistent awareness of applicable documentation,
communication and coordination requirements at sites
transitioning from one lead to another.

Site assessors noted the following characteristics of
highly effective coordination during lead changes:

•	Constant, open communication on sites that may
need to be transitioned, including stakeholder
and site complexities;

•	An established referral process that is agreed to
by all parties and addresses:

o Roles and responsibilities;

o Clear expectations for transferred sites;

o Notification methods and associated
timeframes;

o Central points of contact;

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o Documentation (e.g., transition memo, site
reports, site history, sampling data, maps);
and

o Document transfer methods (e.g., SharePoint,
FTP).

•	Regular updates of site progress, including
access to lead-agency database or database
reports; and

•	Early notification of further lead changes.

"The state and EPA have developed an effective transfer and
referralprocess that assures a referralpackage with necessary
information to support the referral and site decision is
fonmrded. The centralpoint of contactfor both EPA and
the state is vital to assuring transfers are consistent and fast,
and the products are of acceptable quality.State site
assessment manager

"Transitions are highly effective due to use of 1) EPA
decision forms; 2) state site transfer memorandums to the
applicable programs to make sure sites do not linger orfall
through the cracks." — EPA manager

•	Jointly review products (e.g., flyers, brochures,
fact sheets, website content) and address issues
before finalizing;

•	Keep partners informed of and involved in
upcoming meetings as much as possible;

•	Coordinate responses to the public;

•	Defer unanticipated questions to the
appropriate agency or jointly respond;

•	Ensure community outreach with residents and
public officials is made a priority by agency
managers and project officers; and

•	Make sure EPA and states work closely and
effectively with individual tribes and the Inter-
Tribal Environmental Council.

' Prior to any public outreach meeting, we have conference calls
and/ or meetings to discuss talking points and share
presentation content. This is very important especially when
dealing with public health concerns and peaking as one
voice." — State staffperson

"State and local agencies better understand the needs of their
community and are more successful in targeting the correct
audience." — EPA manager

Public Outreach

Public outreach may be required at various points in
the site-assessment process depending on site
conditions, level of awareness, and interest. Community
involvement activities should be well coordinated and
communicated in a timely and effective manner.

More Information

For more information about the Superfund Site
Assessment process, visit:

https://www.epa.aov/superfund/superfund-site-
assessment-process.

"This is the most important aspect of workload coordination.
Working with the state, EPA and the community is critical
in the work we do for our Superfund program." — Tribal
staffperson

Site assessors indicated highly effective public outreach
coordination occurs when EPA, states and tribes apply
strong collaboration techniques. These techniques
include the following steps:

•	Clearly identify roles and responsibilities;

•	Identify lead agency and points of contact;

•	Collaborate early and regularly throughout the
process, from initial planning through final
follow-up;

•	Develop a unified, consistent message for the
public and Potentially Responsible Parties;

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