Superfund Recordkeeping

The Comprehensive Environmental Response, Compensation and Liability Act of 1980, (CERCLA), as adapted by the Superfund Amendments and Reauthorization Act of 1986, (SARA), provides for the identification, analysis and cleanup of Superfund, chancy decay sites. Beneath these Acts, the Environmental Protection Agency (EPA) is adapted to balance its acknowledgment costs from amenable parties afterwards accommodating in the investigation, cleanup, oversight, administration and alternative adapted authoritative provisions. State agencies which absorb CERCLA funds charge annual for and certificate all acknowledgment costs to admittance accretion of these costs from amenable parties by EPA and the State. Funds may additionally be provided to the State by EPA beneath a admission arrangement to undertake Superfund accompanying acknowledgment activities. State agencies which absorb CERCLA admission funds charge annual for and certificate all State costs. This chiral outlines procedures circuitous with the amount of funds by the Maryland Department of the Environment (MDE) for CERCLA activities. It sets alternating banking administration and recordkeeping requirements for Superfund sites and for CERCLA accompanying activities covered by EPA grants. Many of the attempt and procedures covered by this chiral serve as advice for non-CERCLA sites, as well, which accept the abeyant for approaching amount accretion actions. This chiral will abide to be adapted as new procedures are developed. Documentation procedures absorb circuitous banking administration and recordkeeping behavior that charge be followed to assure amount recovery. These behavior are based on regulations and guidance, in part, set alternating in: - Cipher of Federal Regulations, (CFR), Title 40, Allotment 31, Allotment 33 and Allotment 35, Subpart "O". - "State Superfund Banking Administration and Recordkeeping Guidance", 1987, EPA. - OMB Circular No. A-87, " Amount Attempt for State and Local Governments". - Cipher of Maryland Regulations, (COMAR), Title 21. Key appearance of the Superfund banking administration and recordkeeping behavior which are set alternating in detail herein in Section D, include: - Affidavit of all costs circuitous with acknowledgment or grant-specified activities. - Accretion of "reasonable and necessary" costs only. - Identification of banking documents, and all alternative amount accompanying annal or agreements which may serve as the base for free or acceding acknowledgment costs, with the byword - "SUPERFUND – DO NOT DESTROY". - Maintaining timesheets and alternative banking certificate originals afterwards about-face afterwards approvals. - Aliment of a different book or set of files, either absolute adamantine copies, or cyberbanking images shall be maintained for anniversary Superfund armpit which shall be articular by a action amount annual (PCA) cipher to admittance adapted admission to armpit records. Record categories aural these files shall be organized in a constant manner. - Aliment of added files, absolute advancement affidavit which accommodate accomplishments and serve as a base or allotment for costs, should additionally be maintained. These accepted files may accommodate advice that is not necessarily site-specific. - Retain aboriginal abstracts for anniversary site, OU or activity. - Cyberbanking annal may be adequate for amount accretion if accustomed by EPA or Attorney General's office. - Submitting amount documentation, in acknowledgment to requests from attorneys or EPA alone after, amount accompanying annal are accommodated with the amount summary. - Retention of annal formed with the byword - "SUPERFUND – DO NOT DESTROY" for at atomic 10 years afterward acquiescence of the final Banking Status Report, (FSR), unless contrarily directed by EPA. Records are to be retained best than 10 years if litigation, claim, amount accretion or alternative associated action takes abode afore the end of the 10-year period. - EPA charge accept abolition of abstracts that were adapted to be saved. Establish Superfund and EPA admission banking administration and recordkeeping procedures which: - accredit the State to accommodated acknowledged responsibilities and EPA analysis requirements; - certificate amount accompanying annal in a accurately adequate manner; - facilitate accountability and amount recovery; and - accommodate adapted admission to site, applicable assemblage and action accompanying amount information. 1. ERRP - (Environmental, Restoration and Redevelopment Program) ERRP conducts and oversees CERCLA acknowledgment activities aural the Decay Administration Administration, (WAS). Its areas of responsibilities cover: - Pre-remedial, remedial, abatement and operation & aliment phases. - Acknowledgment activities which include, but are not bound to, investigations, analysis and animadversion on reports, blank and accomplishing of acknowledgment actions, and administration actions, and CERCLA activities may be adjourned beneath EPA grants/ Cooperative Agreements (CAs). The agreement of these grants are adjourned amid EPA and the State. The State additionally uses its own funds in agreeable in acknowledgment activities. Trained agents conduct abstruse activities associated with investigation, appraisal and cleanup, including accompanying activities such as training, travel, and Program development and the like. These advisers shall abide timesheets for added processing and almanac keeping. Time adherent to assorted acknowledgment activities is broadcast to a cardinal of different PCA codes aural the timesheets, thereby allowing appointment of costs to adapted sites, OUs and activities. In addition, the abstruse agents may admit requisitions such as acquirement and biking requests and alternative banking abstracts associated with acknowledgment activities. PCA codes are additionally acclimated to accredit costs for these and alternative activities as well. Clerical and authoritative agents may abetment the abstruse agents in fiscal, timekeeping, acquirement requisitions, biking vouchers and almanac befitting matters. This agents additionally serves as communication with alternative capacity in processing time accountability abstracts and alternative requisitions. The Program Administrator of ERRP manages ERRP Program and abstruse activities and approves all ERRP requisitions. Originators of requisitions charge absolve the call of items requested afore approval and charge amuse agreement of the grants. Approval, or assurance off, by the Program Administrator may be via cyberbanking signature area the Advanced Purchasing Inventory Control Arrangement (ADPICS), or a agnate system, is acclimated with the Banking Administration Advice Arrangement (FMIS) to action the requisition. FMIS is the computerized statewide accounting arrangement which advance costs by site, OU and activity, and by admission level.

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