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Round 3-16: PRP Oversight Administration



Reform Description
As the Superfund program has matured, potentially responsible parties (PRPs) have developed considerable experience in conducting response activities at Superfund sites. In addition to performing high quality work, some PRPs have cooperated with EPA throughout the cleanup and enforcement processes. To recognize and promote further cooperation, EPA issued a July 1996 directive on reducing Federal oversight and a November 1996 memorandum on reducing oversight at Federal facilities (see Documents below).

During FY97, EPA requested that the Regions inform capable and cooperative PRPs of EPA's efforts to control or reduce oversight at their sites.

Overall, this reform aims to:

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Reform Status
check mark Implementation of this reform is complete.

EPA will continue to organize meetings between Regions and PRPs to discuss oversight issues and conduct site-specific evaluations to assess the impact of the reform.

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Results
In FY96, EPA tentatively identified 100 sites as eligible for the reform. In July 1996, EPA issued a national directive on reducing oversight, and later initiated a national workgroup to implement the directive. The Agency also issued a memorandum on streamlining oversight at Federal facilities in November 1996 (see Documents below).

In May 1997, the national workgroup hosted a meeting with industry representatives to discuss opportunities to control costs; EPA Regions 1, 2, 3, and 5 have hosted similar meetings. Throughout FY97, the Regions wrote PRPs to inform them of Agency efforts to control or reduce oversight costs.

In FY98, the Agency: During FY99, over 200 sites were potentially eligible for this reform. EPA revised the process for reducing oversight of cooperative PRPs by extending coverage to PRPs working under enforcement agreements. A new measure requires Regions to offer a meeting to discuss oversight expectations and to issue an oversight bill, as appropriate.

In FY01, EPA targeted 275 sites as eligible for this reform. Of these sites, 243 were accomplished (88%).
Final FY 2001 EOY PRP Oversight Administration Targets
RegionTargetAccomplishedPercentage
1272489%
2583662%
32222100%
42323100%
5161488%
666100%
74848100%
81919100%
91010100%
10464189%
National27524388%

Nationally, in FY 2002, this reform was targeted for 230 sites and it was accomplished at 227 of those sites. Thus, in FY 2002, the EPA Regions had a 99% success rate in the meeting the Office of Site Remediation Enforcement's (OSRE's) SPIM target of sending an annual bill for recovery of oversight costs and making an offer to meet with PRPs to discuss oversight expectations for the upcoming fiscal year.

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Stakeholder Comments
Rachel Deming, Remediation Counsel for Ciba Specialty Chemicals Corporation, commented that:

"We [industry] like the idea of meeting and discussing oversight expectations with EPA. Receiving cost information and getting bills on time also helps us plan and budget our oversight expenses. We'd like to get a sense of the baseline value of oversight costs against which to compare oversight costs at our own sites."

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Success Stories
Cleve Reber Site, Sorrento, LA

At the Cleve Reber site, EPA Region 6 achieved a cost savings of $500,000 in 1996 by switching to the U.S. Army Corps of Engineers for oversight instead of using a private contractor. [FY97 Success]

Pristine Inc. Site, Reading, OH

At the Pristine Inc. site, EPA Region 5 has saved roughly $250,000 a year since 1996 through the reduction of contractor support for oversight. [FY97 Success]

Ruston/North Tacoma Site, WA

By reducing the number of split samples taken, frequency of site visits, and comparative data analyses, EPA Region 10 saved nearly $700,000 in oversight costs between 1994 and 1996 at the Ruston/North Tacoma Study Area of the Commencement Bay-Nearshore Tideflats site. [FY97 Success]

Schuylkill Metals Corporation Site, Plant City, FL

By limiting field oversight, EPA Region 4 has incurred less than half of the oversight costs originally anticipated in 1993 at the Schuylkill Metals site, for a savings of over $80,000. [FY97 Success]

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Documents
Title: Memorandum: Interim Guidance on Implementing the Superfund Administrative Reform on PRP Oversight
Date: May 17, 2000
Document #: OSWER 9200.0-32P
Synopsis: This memorandum directs the Regions to promote effective and efficient PRP oversight by promoting open communication with PRPs that have settlements with EPA. The directive provides examples of oversight management and potentially cost-saving practices for RPMs to consider when planning or conducting PRP-lead response actions. Title: Memorandum: Federal Facilities Streamlined Oversight Directive
Date: November 29, 1996
Document #: OSWER 9230.0-75
Synopsis: This memorandum focuses on streamlining the regulatory oversight processes at Federal facilities in a systematic, planned manner based on site-specific factors and general streamlining techniques. The memorandum details the proposal and implementation of the directive. Title: Reducing Federal Oversight at Superfund Sites with Cooperative and Capable Parties
Date: July 31, 1996
Document #: OSWER 9200.4-15, NTIS PB96-963231
Synopsis: This directive presents factors for the Regions to consider when determining a PRP's eligibility for reduced oversight. The directive provides examples of oversight reduction, but recognizes some situations where additional reductions may be unwarranted (e.g., highly complex sites or cleanups with substantial community involvement).

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Contacts
Patricia Kennedy, U.S. EPA OECA
Mail Code: 5204G
U.S. EPA Headquarters
Ariel Rios
1200 Pennsylvania Avenue, N.W., 2273A
Washington, DC 20460

Phone: (202) 564-6061
E-mail: kennedy.patricia@epa.gov

Alan Youkeles, U.S. EPA OSRTI
Mail Code: 5204G
U.S. EPA Headquarters
Ariel Rios
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Phone: (703) 603-8784
E-mail: youkeles.alan@epa.gov

Chad Littleton, U.S. EPA OSRE
Mail Code: 2273A
U.S. EPA Headquarters
Ariel Rios
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Phone: (202) 564-6064
E-mail: littleton.chad@epa.gov

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