APPENDIX D: Action Memorandum Format OSWER Directive 9360.0-16a Guidance for Conducting Federal-Lead Underground Storage Tank Corrective Actions July 25, 1988
The Region should prepare an action memorandum based on the State letter requesting Federal-lead UST corrective action (see Appendix C). The action memorandum should address all of the topics 1 in Appendix C, along with the additional items presented below. If the State request letter adequately follows the format suggested in Appendix C, then the Region's action memorandum may simply consist of the following sections with a copy of the State letter referenced and attached. If the State letter is deficient, the Region must ensure that the action memorandum addresses and corrects all of the deficiencies, including all of the information requested n Appendix C and in the additional sections described below. In any case, a copy of the State request letter should always be attached to the action memorandum for reference.
|SUBJECT:||Request for Federal-lead UST Corrective Action|
(Site, City, State)
|TO:||(see Appendix A)|
II. PROPOSED ACTIONS AND COSTS
OSCs should consider cost as one of many factors when proposing UST corrective actions. However, there are no statutory or regulatory requirements for cost-effectiveness. The purpose of this section is to provide guidelines for presenting information on proposed and alternative actions, estimated costs, and the project schedule.
A. Proposed Actions
- Describe the proposed actions.
Describe the specific tasks involved and the results sought by the corrective actions as they pertain to the threat (s) discussed in Appendix C. For example, "The primary objective of the proposed action is the mitigation of the threat to public health y provision of alternate of the threat to public health by provision of alternate potable water supplies to the affected homes."
Indicate whether any further information is needed before all response actions can be identified (e.g., sampling to address ground water or drinking water contamination).
State why the proposed actions are appropriate for this situation and explain the rationale for choosing the proposed option. Describe the technical feasibility and probable effectiveness of the proposed action. Address response time requirements, intermedia relationships, considerations, and environmental impacts.
Describe the procedures to be undertaken in the proposed actions. For example, "corrective action will include ventilation of affected structures and provision of bottled water to impacted residents." Describe any impediments to the proposed action (e.g., lack of public acceptance of problems with access).
- Describe the project schedule.
Give the time frame needed to stabilize or clean up the site and include how quickly response can begin. Give the estimated period of performance. Indicate whether postcorrective action site control (operation and maintenance) will be required, and how the State intends to perform it.
- State the estimated costs.
Estimate the total project ceiling with an itemized breakout of the following cost categories that comprise that ceiling: extramural costs, which include cleanup contractor costs, TAT costs, and a 15% contingency allowance; and EPA intramural costs, both direct and indirect. For example:
|Intramural (both HQ and Region)|
|Indirect (estimate based on provisional rates)||6,000|
|TOTAL PROJECT CEILING||$37,750|
B. Alternative Actions
Describe what other actions were considered (e.g., providing hookups to city water instead of providing bottled water). Briefly describe the technical feasibility and probable effectiveness of each option. Address response time requirements, intermedia relationships, temporary vs. long-term solutions, institutional considerations, environmental impacts, and estimated costs of each option. State any impediments to the options (e.g., public acceptance or access to the site). State why the selected alternative was chosen.
The purpose of this section is to briefly present the Region's recommendations, rationale, and projected costs for the action. For example, "Because conditions at [site name] meet the criteria for Federal-lead UST response, I recommend your approval of the proposed UST corrective action. The estimated total project costs are $37,750 of which $20,000 are for extramural cleanup contractor costs. This site meets the criteria for a cleanup contractor costs. This site meets the criteria for a major public health (and/or environmental) emergency, and no State, local, or other agency, owner or operator, or other partly can or will provide adequate and timely response."
Approve [Name and Title] ____________________ Date: ____________________
Disapprove [ Name and Title] _________________ Date: ____________________
Concur [Name and Title] _____________________ Date: ____________________