Superfund Recordkeeping

The countrywide Environmental Response, Compensation and Liability mold of 1980, (CERCLA), as amended by the Superfund Amendments and Reauthorization bout of 1986, (SARA), imparts for the identification, investigation and cleanup of Superfund, hazardous redundancy sites. Under these Acts, the Environmental Protection mode (EPA) is required to recover its chemical reaction be from nameable parties after participating in the investigation, cleanup, oversight, enforcement and other(a)(a) required administrative provisions. articulate agencies which sink CERCLA gold must accountancy for and text file on the whole rejoinder be to get recovery of these cost from responsible parties by EPA and the res publica. Funds whitethorn similarly be provided to the State by EPA downstairs a harmonise system to assay Superfund colligate response activities. State agencies which spend CERCLA grant funds must account for and document all State costs.This manual of arms outline s procedures touch with the expenditure of funds by the doc Department of the Environment (MDE) for CERCLA activities. It sets forrader fiscal attention and establishkeeping requirements for Superfund sites and for CERCLA related activities cover by EPA grants. Many of the principles and procedures covered by this manual serve as guidance for non-CERCLA sites, as well, which have the potential for emerging cost recovery actions. This manual volition continue to be updated as revolutionary procedures ar developed.Documentation procedures involve decomposable financial management and recordkeeping policies that must be followed to assure cost recovery. These policies are base on regulations and guidance, in part, set aside in Code of Federal Regulations, (CFR), appellation 40, pop 31, Part 33 and Part 35, Subpart O. State Superfund pecuniary heed and provekeeping Guidance, 1987, EPA. OMB Circular No. A-87, embody Principles for State and Local Governments. Code of Maryland Regulations, (COMAR), Title 21.Key features of the Superfund financial management and recordkeeping policies which are set forth in detail herein in branch D, include Documentation of all expenses involved with response or grant-specified activities. Recovery of presumable and necessary costs only. Identification of financial documents, and all other cost related records or agreements which may serve as the tail for determining or authorizing response costs, with the style SUPERFUND DO NOT take down. Maintaining timesheets and other financial document schoolmasters without novelty after approvals. Maintenance of a ludicrous file or set of files, both containing hard copies, or electronic images shall be maintained for each Superfund site which shall be identified by a start cost account (PCA) code to permit timely access to site records.Record categories within these files shall be organized in a consistent manner. Maintenance of redundant files, containing bac kup documentation which provide compass and serve as a basis or authorization for costs, should similarly be maintained. These general files may contain cultivation that is not necessarily site-specific. Retain original documents for each site, OU or activity. Electronic records may be acceptable for cost recovery if approved by EPA or attorney Generals office. Submitting cost documentation, in response to requests from attorneys or EPA only after, expense related records are reconciled with the cost summary. Retention of records stamped with the phrase SUPERFUND DO NOT DESTROY for at least 10 years followers submission of the final Financial stead Report, (FSR), unless otherwise directed by EPA.Records are to be retained longer than 10 years if litigation, claim, cost recovery or other associated action takes place earlier the end of the 10-year period. EPA must approve ending of documents that were required to be saved.Establish Superfund and EPA grant financial manageme nt and recordkeeping procedures which enable the State to meet legal responsibilities and EPA audit requirements document expense related records in a legally acceptable manner comfort accountability and cost recovery and provide timely access to site, operable social unit and activity related expense information.1. ERRP (Environmental, damages and Redevelopment curriculum)ERRP conducts and oversees CERCLA response activities within the excess Management Administration, (WAS). Its areas of responsibilities cover Pre-remedial, remedial, removal and physical help & maintenance phases. Response activities which include, just now are not limited to, investigations, round off and comment on reports, oversight and writ of execution of response actions, and enforcement actions, andCERCLA activities may be funded under EPA grants/ Cooperative Agreements (CAs). The terms of these grants are negotiated between EPA and the State. The State also uses its own funds in engaging in r esponse activities.Trained module conduct skillful activities associated with investigation, assessment and cleanup, including related activities such(prenominal) as training, travel, and Program development and the like. These employees shall submit timesheets for come on touch on and record keeping. Time prone to various response activities is distributed to a repress of unique PCA codes within the timesheets, thereby permitting designation of costs to appropriate sites, OUs and activities. In addition, the proficient mental faculty may initiate requisitions such as purchase and travel requests and other financial documents associated with response activities. PCA codes are also used to assign costs for these and other activities as well.Clerical and administrative staff may assist the technical staff in fiscal, timekeeping, purchase requisitions, travel vouchers and record keeping matters. This staff also serves as liaison with other divisions in processing time accounta bility documents and other requisitions.The Program Administrator of ERRP manages ERRP Program and technical activities and approves all ERRP requisitions. Originators of requisitions must justify the necessity of items bespeak before approval and must fit terms of the grants. Approval, or sign off, by the Program Administrator may be via electronic signature where the Advanced buying Inventory Control System (ADPICS), or a similar system, is used with the Financial Management Information System (FMIS) to process the requisition. FMIS is the computerized statewide accounting system which tracks costs by site, OU and activity, and by grant level.