Superfund Recordkeeping

The Comprehensive environmental answer, Compensation and Liability coiffure of 1980, (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986, (SARA), provides for the identification, investigation and cleanup of Superfund, hazardous waste sites. Under these Acts, the milieual security system Agency (EPA) is required to recover its reception be from responsible parties afterwards participating in the investigation, cleanup, oversight, enforcement and other required administrative provisions.State agencies which drip CERCLA specie must account for and document all response personifys to permit recovery of these woos from responsible parties by EPA and the State. Funds whitethorn in addition be provided to the State by EPA under a accord system to undertake Superfund related to response activities. State agencies which spend CERCLA grant funds must account for and document all State bes.This manual(a) outlines procedures studyd with the expen diture of funds by the Maryland Department of the Environment (MDE) for CERCLA activities. It tags forth financial management and recordkeeping requirements for Superfund sites and for CERCLA related activities covered by EPA grants. umteen of the principles and procedures covered by this manual serve as guidance for non-CERCLA sites, as well, which have the potential for future cost recovery actions. This manual allow for continue to be updated as new procedures are developed.Documentation procedures involve complex financial management and recordkeeping policies that must be followed to assure cost recovery. These policies are based on regulations and guidance, in part, set forth in Code of Federal Regulations, (CFR), Title 40, farewell 31, Part 33 and Part 35, Subpart O. State Superfund pecuniary watchfulness and renderkeeping Guidance, 1987, EPA. OMB Circular no. A-87, Cost Principles for State and Local Governments. Code of Maryland Regulations, (COMAR), Title 21. key fruit features of the Superfund financial management and recordkeeping policies which are set forth in flesh out herein in Section D, include Documentation of all expenses affect with response or grant-specified activities. Recovery of reasonable and necessary cost only. designation of financial documents, and all other cost related records or agreements which whitethorn serve as the basis for determining or authorizing response costs, with the artistic style SUPERFUND DO NOT DESTROY. Maintaining timesheets and other financial document passe-partouts without renewing after approvals. upkeep of a unique file or set of files, either containing hard copies, or electronic images shall be maintained for to each one Superfund site which shall be identified by a project cost account (PCA) code to permit timely access to site records.Record categories in spite of appearance these files shall be organized in a consistent manner. Maintenance of additional files, containing backup d ocumentation which provide background and serve as a basis or authorization for costs, should also be maintained. These universal files whitethorn contain information 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 reconcile with the cost summary. Retention of records stamped with the phrase SUPERFUND DO NOT DESTROY for at least 10 years following submission of the final Financial Status Report, (FSR), unless otherwise directed by EPA.Records are to be maintained longer than 10 years if litigation, claim, cost recovery or other associated action takes place before the end of the 10-year period. EPA must approve remnant of documents that were required to be saved.Establish Superfund and EPA grant financial manageme nt and recordkeeping procedures which change the State to meet legal responsibilities and EPA audit requirements document expense related records in a legally acceptable manner facilitate function and cost recovery and provide timely access to site, operable social unit and activity related expense information.1. ERRP (Environmental, Restoration and Re developing Program)ERRP births and oversees CERCLA response activities within the Waste Management Administration, (WAS). Its areas of responsibilities cover Pre-remedial, remedial, removal and operation & maintenance phases. Response activities which include, but are not limited to, investigations, review and comment on reports, oversight and implementation of response actions, and enforcement actions, andCERCLA activities may be funded under EPA grants/ conjunctive Agreements (CAs). The terms of these grants are negotiated between EPA and the State. The State also uses its own funds in engaging in response activities.Trained stave conduct technical activities associated with investigation, assessment and cleanup, including related activities such as training, travel, and Program development and the like. These employees shall submit timesheets for further processing and record keeping. Time devoted to several(a) response activities is distributed to a number of unique PCA codes within the timesheets, thereby permitting grant of costs to appropriate sites, OUs and activities. In addition, the technical staff may beginner 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 accountability documents and other requisitions.The Program Adm inistrator of ERRP manages ERRP Program and technical activities and approves all ERRP requisitions. Originators of requisitions must justify the necessity of items requested before approval and must adjoin terms of the grants. Approval, or sign off, by the Program Administrator may be via electronic signature where the Advanced Purchasing Inventory harbour 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.