CERCLA Cleanup and Federal Agency Role Sample Clauses

CERCLA Cleanup and Federal Agency Role. Executive Order 12580 delegates the authority to conduct certain cleanups and removal actions under CERCLA to Federal agencies. CERCLA § 120 states that a federal agency must comply with the substantive and procedural requirements of cleanups to the same extent as private entities must. EPA provides advice and consent on the federal agency’s response actions for the Site’s cleanup to ensure that CERCLA and National Contingency Plan (NCP) requirements are met and that a Remedial Investigation/Feasibility Study (RI/FS), to determine the nature and extent of contamination, is begun within 6 months of listing. Immediately after listing confirmation occurred, VA began efforts to hire a CERCLA Program Manager and contract with an environmental remediation firm to develop an investigational strategy and plan for the field work efforts. After the remedial investigation and feasibility study (RI/FS) is completed, the federal lead agency is required to enter into an inter-agency Federal Facilities Agreement (FFA). The FFA is a legal agreement which defines the requirements for performance of Site response activities and how cleanup will proceed, as well as, penalties for non-compliance. The parties’ signatory to the FFA includes VA, EPA Region 8, and UDEQ. The FFA between these parties was finalized in F e b r u a r y , 2016 and is awaiting final signatures of UDEQ and EPA. The FFA requires that a Site Management Plan (SMP) be developed for the Site and be accepted by EPA and UDEQ. This SMP will be an appendix of the FFA under CERCLA Section 120 (Docket Number No. EPA-HQ-SFUND-2012-0647) and describes the work and process VA intends to use to address the Site’s contamination and a schedule for the work. The SMP is amended annually to update any changes in the proposed schedule. Milestone changes agreed to by the Remedial Project Managers (RPMs) are included in the next annual amendment to the SMP. Near-term milestones, deadlines, are enforceable to the extent allowed under CERCLA and the FFA.
Sample 1
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