Advanced Computer Legal Education.

Practical Aspects of Cost Recovery in Hazardous Waste Clean-Up.

N/A

03/00/90

Advanced Computer Legal Education, Inc.

Cost Recovery Library, Book 8

This binder includes information distributed at a seminar held March 27, 1990 in Washington, D.C. The seminar covered the following issues surrounding cost recovery in hazardous waste history; the Environmental Protection Agency (EPA) regulations, enforcement, and policies; private vs. governmental cost recovery actions; potentially responsible party liability issues; case management and automation alternatives; challenging government cost claims; use of consultants and experts, and defense of CERCLA actions.

Arthur Young.

Evaluation of Indirect Cost Rate Development Policies and Procedures.

N/A

04/11/88

Arthur Young.

Cost Recovery Library, Book 4

This report was written to provide results of the Superfund indirect cost rate development policies and procedures evaluation and to present recommendations for modifications and changes which appear appropriate in light of the evolution of the Superfund program. Arthur Young and Company recommend a transition to a General and Administrative (G&A) allocation basis using total site costs (instead of the use of a labor hour allocation basis). They suggest that this would permit the Environmental Protection Agency (EPA) to take a full cost recovery position. This document is marked "Draft." EPA indicates that a final report was never issued.

Belthoff, Richard C., Jr.

Private Cost Recovery Actions Under Section 107 of CERCLA.

Columbia Journal of Environmental Law, Vol. 11, pp. 141 - 192.

12/00/86

N/A

Cost Recovery Library, Book 10

This article provides the reader with a general description of the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensations, and Liability Act (CERCLA) and discusses who is liable under these laws. It explicitly looks at sections of CERCLA which have affected the implementation of private cleanups and cost recovery actions. This article cites a number of cost recovery cases between private parties and describes the issues and results of each case. The article concludes that although private cleanups and recovery actions are effective tools to address the hazardous waste problem, the impact of these cleanups and cost recovery actions are limited by the vagueness in the statutory scheme and the inconsistent judicial decisions.

Booz, Allen & Hamilton

Superfund Site-Specific Invoice Processing Procedures for RTP/FMO.

N/A

11/27/85

N/A

Cost Recovery Library, Book 54

Beginning October 1, 1985, the Environmental Protection Agency (EPA) required certain contractors to the Superfund program to report their charges on a site-specific basis. This document serves as both a description of RTP's site-specific invoice handling procedures and as a reference for solving problems encountered during the processing cycle. The text of this manual assumes that the reader is generally familiar with the RTP organization, its two invoice payment systems (REMARC and VSS), and Financial Management System (FMS).

Brennan, Douglas F.

Joint and Several Liability for Generators Under Superfund: A Federal Formula for Cost Recovery.

UCLA Journal of Environmental Law and Policy, Vol. 5, No. 2, pp. 101 - 135.

12/00/86

N/A

Cost Recovery Library, Book 7

This article examines the question of Joint and Several Liability and how such liability should be allocated according to CERCLA. Furthermore, this article discusses the different interpretations and applications of joint and several liability by the courts. The author suggests that in order to remedy inconsistencies in the law under CERCLA, the courts should rely on the Federal Water Pollution Control Act (FWPCA) and the traditional and evolving principles of common law. Finally, the author proposes an indivisible harm rule that facilitates the determination of joint and several liability, yet provides for equitable contribution and releases.

Buse, Jennifer.

CERCLA Cost Recovery Suits: A Suit Against an Insured for Damages Under a Comprehensive General Liability Policy.

William Mitchell Law Review, Vol. 14, pp. 829 - 858.

09/00/88

N/A

Cost Recovery Library, Book 1

This article discusses the authority granted the Environmental Protection Agency (EPA) under CERCLA to recover cleanup costs and the nature of the cleanup costs. In this article the author explores the implications and problems between insureds, who have extended the defense of an EPA cost recovery action under CERCLA 104, 106, and 107 to their Comprehensive General Liability (CGL) carriers, and the insurers, who claim that this insurance does not cover CERCLA liability because it does not constitute "damages" within the meaning of a CGL policy. Finally, the author suggests that if the artificial distinction between restitution and compensatory damages were dropped, the polluters, EPA and the insurance carrier could cooperate early in the response plan to facilitate a prompt and cost efficient cleanup.

Carter, Kristin M.

Superfund Amendments and Reauthorization Act of 1986: Limiting Judicial Review to the Administrative Record in Cost Recovery Actions by the EPA.

Cornell Law Review, V. 74, No. 6, pp. 1152 - 1178.

00/00/89

N/A

Cost Recovery Library, Book 13

This Note defines the parameters of an administrative record and discusses the appropriate scope of judicial review under Superfund Amendments and Reauthorization Act of 1986 (SARA). This article emphasizes four criticisms of procedure and judicial review under SARA. The author concludes that one way to grant PRPs due process, and to place a check on agency behavior, is to provide PRPs with the right to cross-examine the Environmental Protection Agency's (EPA's) personnel involved in the remedial selection process at the trial level.

Cooke, William

Declaration of William Cooke

N/A

07/13/93

N/A

Cost Recovery Library, Book 71

This is a declaration of William Cooke, EPA's Fact Witness on indirect costs in cost recovery matters. This declaration was taken for the case of U.S. v. Gordon Stafford, Inc. et. al. The deposed describes the system used by the EPA to calculate indirect costs. The documents referenced by Mr. Cooke which support EPA's system of calculating indirect costs are part of the Cost Recovery Library Collection.

Ernst & Whinney

N/A

N/A

08/26/83

N/A

Cost Recovery Library, Book 22

This package contains four documents developed by Ernst & Whinney Evaluation of Existing E.P.A. Cost Accounting Principles and Procedures and Recommendations for a Cost Allocation Process and Methodology for Superfund Sites; Procedures for Developing Indirect Cost Rates for Superfund Sites; User Requirements, EPA Cost Allocation for Superfund Sites; and Feasibility Study for Automation of the Superfund Site Cost Allocation Process.

Ernst & Whinney

Changes in Bases of Allocation for EPA's Indirect Cost Allocation Plan for FY 1983.

N/A

04/29/85

N/A

Cost Recovery Library, Book 23

This document includes a cover letter from Ernst & Whinney which approves the Environmental Protection Agency's (EPA's) proposed changes to the bases of allocation of the Indirect Cost Allocation Plan. The changes were necessitated by organizational changes and accounting restructurings within EPA occurring between FY 1982, the year for which Ernst and Whinney's developed the Plan, and FY 1983.

Fuhrman, Robert H. and David B. Hird

EPA Proposed Rule on Superfund Cost Recovery: Streamlining or Steamrolling.

Toxics Law Reporter.

09/09/92

N/A

Cost Recovery Library, Book 47

This article is considered to be a part of the Public Comments Section in the Superfund Program Recovery of Costs for CERCLA Response Actions, Proposed Rule Public Docket 115CR (refer to Book 44). This article critiques the Environmental Protection Agency's (EPA's) proposed cost rule, alleging that it is bad public policy because it greatly restricts any effective means for PRPs to challenge EPA response costs, thereby substantially increasing the costs PRPs would pay.

Hanson, Kent E., and Adam Babich.

Local Governments and Hazardous Substances: Cleanup, Cost Recovery and Damages Under CERCLA.

The Florida Bar Journal, Vol. 62, No. 11, pp. 65 - 68.

12/00/88

N/A

Cost Recovery Library, Book 19

This article was written to help local governments recognize and take advantage of opportunities available under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). CERCLA gives local governments an independent authority to recover damages for injuries to natural resources; obtain cleanup orders; and recover investigation, litigation and other expenses.

Hanson, Kent E., and Adam Babich.

Municipalities and Hazardous Substances: Cleanup, Cost Recovery and Damages Under CERCLA.

The Municipal Attorney, Vol. 29, No. 4, pp. 1-6.

07/00/88 - 08/00/88

N/A

Cost Recovery Library, Book 20

This article discusses the effect CERCLA has on municipalities' power to address problems created by toxic and hazardous chemicals. The authors suggest that if statutory remedies are used effectively, cleanup and environmental enforcement will proceed at the expense of the responsible parties instead of local governments and their taxpayers.

Heiring, Paul W.

Private Cost Recovery Actions Under CERCLA.

Minnesota Law Review, Vol. 69, No. 5, pp. 1135 - 1160.

05/00/85

N/A

Cost Recovery Library, Book 9

This Note discusses four major areas of disagreement among the courts concerning Private Cost Recovery Actions under CERCLA and suggests resolutions consistent with the policies of CERCLA. The four areas of disagreement discussed in this article are the procedures necessary for a private cleanup to be consistent with the National Contingency Plan, the types of expenditures that rise to the level of "necessary costs of response," the point in a cleanup when response costs are "incurred" and thus become recoverable, and the notice requirements that apply in private cost recovery actions.

Helmstetter, Carl H., and David C. Linder.

The Rapidly Changing World of RCRA and CERCLA Response Cost Update.

N/A

12/13/90

N/A

Cost Recovery Library, Book 15

The authors of this article present their estimation of chances of success with respect to various government response cost claims. This article gives an outline of recent CERCLA decisions addressing the government's right to recover response costs under section 107(a)(4)(A). This paper was prepared for American Bar Association Committee on Solid and Hazardous Waste, Section of Natural Resources, Energy and Environmental Law, Seminar held December 13, 1990 in Washington, D.C.

Howard, Robert M.

Government Cost Recovery After the Cleanup: Do the Superfund Amendments Give the EPA a License to Squander?

Baylor Law Review, Vol. 42, pp. 53 - 96.

00/00/90

N/A

Cost Recovery Library, Book 5

This article analyzes the inclusion in the Superfund Amendments and Reauthorization Act of 1986 (SARA) of a deferential standard of judicial review concerning Superfund cleanup operations. According to the author, this standard gives the Environmental Protection Agency (EPA) a "license to squander" and reduces government cost recovery trials to nonadversarial pro forma enforcement proceedings.

Lee, Martin R., John Blodgett, and Eugene Buck

Environmental Issues: From the 101st to the 102nd Congress, CRS Report 91-11 ENR.

N/A

01/04/91

Library of Congress, Congressional Research Service, Environment and Natural Resources Policy Division

Cost Recovery Library, Book 51

This report discusses environmental programs from the 101st to the 102nd Congress. This reports deals with environmental issues which continue to be unresolved, newly emerging ideas, as well as the scheduled expiration of appropriations' authorization for several major environmental statutes during 1991 and 1992. This article discusses many of the environmental measures enacted by Congress which deal with air and water quality, oil pollution, Superfund, enforcement of environmental laws, and pollution prevention.

Lee, Martin R., John Blodgett, and Claudia Copeland

Summaries of Environmental Laws Administered by the Environmental Protection Agency, CRS 91-251 ENR.

N/A

03/14/91

Library of Congress, Congressional Research Service, Environment and Natural Resources Division

Cost Recovery Library, Book 52

This report supplements Environmental Issues: From the 101st to the 102nd Congress (See Book 51) by providing a concise summary of the Environmental Protection Agency's (EPA's) present authorities and responsibilities.

Library of Congress, Congressional Research Service, Environment and Natural Resources Policy Division, Environmental Protection Section.

Environmental Protection: An Historical Review of Legislation and Programs of the Environmental Protection Agency, CRS Report 83-34 ENR.

N/A

03/01/83

Library of Congress, Congressional Research Service, Environment and Natural Resources Policy Division

Cost Recovery Library, Book 50

This report describes the creation of the Environmental Protection Agency (EPA), and the evolution of the major environmental statutes. It provides the reader with an historical review of the major legislation and programs of the EPA. Also included in this report is a description of EPA's budget for FY 1971 - 1984. the 102nd Congress) and Book 52 (Summaries of Environmental Laws Administered by the Environmental Protection Agency) for incremental updates of EPA's program responsibilities. Together these three reports provide the reader with background on EPA's program responsibilities.

Malter, Barry L., and Jerome C. Muys.

Private Cost Recovery and Contribution Actions Under CERCLA.

ALI-ABA Course Materials Journal, Vol. 10, No. 1, pp. 27 - 48.

00/00/85

N/A

Cost Recovery Library, Book 11

This article addresses specific sections of CERCLA (Sections 9605, 9606, 9607, 9611, 9612, 9613) which deal with private party cost recovery rights of action. In order to identify issues regarding private cost recovery actions under CERCLA, the authors cite a number of cases which deal with these issues.

Marchetta, Joanne.

Introduction to Cost Recovery: What Do You Need to Know to Prepare a Cost Recovery Case?

N/A

03/28/90

N/A

Cost Recovery Library, Book 6

This document addresses the cost documentation process and gives the reader information on how to compile sufficient evidence and information in order to link an accurate statement of the monies spent to the work performed at Superfund sites. This document support costs, use of a cost summary, the purpose of various types of documentation and how and where to find documentation. This paper was prepared for presentation at an Environmental Enforcement Section staff meeting.

McGeehin, Patrick A.

Recovering Superfund Costs.

N/A

12/00/91

Rubino & McGeehin, Chartered

Cost Recovery Library, Book 18

This is the outline of a paper presented in a training session for staff of Aspen Systems, Inc. on December 11, 1991. This presentation provided an overview of the cost recovery process, Department of Justice (DOJ) litigation strategy concerns, use of expert witnesses in cost recovery, accounting and documentation issues, and issues raised by potentially responsible parties. This paper identifies issues Rubino & McGeehin have found to be of importance when dealing with cost recovery matters. Samples of cost documents are included as attachments.

N/A

Documentary Proof Schematic for EPA CERCLA Costs (DRAFT)

N/A

07/14/92

N/A

Cost Recovery Library, Book 70

This document is an outline of the evidence available by fact and cost type for cost recovery cases. Although this document is a "Draft" document and may not be complete, it can be used as a guide to available evidence for cost recovery.

Seng, Beverly S.

The Quasi-Contractual Nature of Cost-Recovery Actions Under CERCLA.

Virginia Journal of Natural Resources Law, Vol. 5, No. 1, pp. 85 - 177.

09/00/85

N/A

Cost Recovery Library, Book 14

The thesis of this article is that CERCLA's cost recovery mechanism is derived from the common law quasi-contractual action that affords quantum meruit recovery. The author concludes that analyzing Section 107 from this viewpoint will help courts to rule coherently on cost recovery issues and may also help the Environmental Protection Agency (EPA) and the Justice Department to implement CERCLA.

Tichenor & Eiche

U.S. Environmental Protection Agency, Region 3, Philadelphia, Under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 for the Fiscal Year Ended September 30, 1984.

N/A

09/18/87

N/A

Cost Recovery Library, Book 36

This Report is a follow-up of the Tichenor and Eiche Superfund Indirect Cost Rates audits for the fiscal years ended September 30, 1984 and 1983, in which the CPA firm did not express an opinion on the Superfund Indirect Cost Rate for Region 3 due to questioned and set-aside Personnel Compensation and Benefits (PC&B) costs for Region 3 for fiscal year 1984. Region 3 personnel subsequently conducted a review of PC&B costs for fiscal 1984 and made adjustments to the previously reported amounts. This is the audit report for the adjusted PC&B figures.

Tichenor & Eiche

U.S. Environmental Protection Agency, Region 4, Atlanta, Georgia: Report of Audit of Superfund Indirect Cost Rate Under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 for the Fiscal Year Ended September 30, 1983.

N/A

02/17/88

N/A

Cost Recovery Library, Book 24

This Report is a follow-up of the Tichenor and Eiche audit of the Superfund Indirect Cost Rates for the Fiscal Years ended September 30, 1984 and 1983, in which the CPA firm did not express an opinion on Region 4's Superfund Indirect Cost Rate for fiscal year 1983. Region 4 personnel reviewed all set-aside and questioned Personnel Compensation and Benefits costs and adjusted the amounts originally reported. This is the audit report of the adjusted costs.

Tichenor & Eiche

U.S. Environmental Protection Agency: Report of Audit of Indirect Cost Rates under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, for Fiscal Years Ended September 30, 1984 and 1983.

N/A

09/15/86

N/A

Cost Recovery Library, Book 25

This Report includes the following sections: Scope and Objectives, Background, Auditors' Report on Superfund Indirect Cost Rates, Report on Compliance, Schedules of Indirect Cost Rates for FY 1984 and FY 1983.

Tichenor & Eiche

U.S. Environmental Protection Agency Report of Audit of Indirect Cost Rates Under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 for Fiscal Years Ended September 30, 1986 and 1985.

N/A

09/18/87

Tichenor & Eiche

Cost Recovery Library, Book 26

This audit report includes the following sections: Scope and Objectives, Background, Auditors' Report on Superfund Indirect Cost Rates, Auditors' Report on Compliance, Schedules of Indirect Cost Rates for FY 1986 and for FY 1985.

U.S. Comptroller General.

Government Auditing Standards.

N/A

00/00/88

U.S. General Accounting Office

Cost Recovery Library, Book 40

This publication supersedes the 1981 revision of Government Auditing Standards and became effective for audits on January 1, 1989. It explains standards for audits of governmental organizations, programs, activities and functions. Auditing has become an integral element of government accountability, and the reliance on auditors has enhanced the need for standards to guide auditors and allow others to rely on auditors' work. This 1988 revision of Government Auditing Standards is also know as "the Yellowbook".

U.S. Congress. Office of Technology Assessment.

Assessing Contractor Use in Superfund - A Background Paper of OTA's Assessment on Superfund Implementation.

N/A

01/00/89

U.S. Government Printing Office.

Cost Recovery Library, Book 21

This background paper explores the following five key issues which what extent is Superfund dependent on contractors, (2) why depend on contracting to such a great extent, (3) is the extent of Superfund's dependence on contracting appropriate, (4) does the extent of Superfund's dependence on contracting reduce environmental effectiveness, and (5) is Superfund's heavy dependence on contracting cost effective. This assessment presents some preliminary findings and then goes on to present some thoughts about the use of Superfund contractors in the future.

U.S. Congress.

Inspector General Act of 1978 and the Legislative History. Public Law 95-452 and the Legislative History for Public Law 95-452.

U.S. Code; Congressional and Administrative News. 95th Congress - Second Session, Volume 1 and Volume 4.

01/19/78

West Publishing Company.

Cost Recovery Library, Book 41

The Inspector General Act of 1978 was written in order to legislate the reorganization of the executive branch of the Government and increase its economy and efficiency by establishing Offices of Inspector and Auditor General in seven executive departments and six executive agencies, to consolidate existing auditing and investigative resources to more effectively combat fraud, abuse, waste and mismanagement in the programs and operations of those departments and agencies.

U.S. Department of Justice and U.S. Environmental Protection Agency.

A Well Documented Case.

N/A

02/00/93

U.S. Department of Justice

Cost Recovery Library, Book 55

"A Well Documented Case" was produced by the U.S. Department of Justice (DOJ) Audiovisual Unit and is the result of a project done with members of the DOJ Litigation Support Section, attorneys from the DOJ Environmental Enforcement Section and members of the Environmental Protection Agency (EPA) staff. This video was designed to explain vital cost documents necessary to support the litigation of Superfund cases, including state documents, EPA documents and other federal agency documents. This video is designed as a training tool for both EPA and DOJ personnel. The video script was written by Mark Trachtman and the runtime is 21 minutes and 47 seconds. This is a VHS tape. (4 Copies)

U.S. District Court for the District of Rhode Island.

U.S. of America vs. American Cyanamid Company (Picillo Pig Farm) and Rohm & Haas Company; Memorandum and Order.

N/A

03/17/92

N/A

Cost Recovery Library, Book 53

In this important CERCLA cost issues decision, Judge Pettine rejected all of the National Contingency Plan (NCP) challenges in issue and reversed the Special Master's recommendation that some costs should be disallowed as "duplicative". The Court held that costs will only be rejected as inconsistent with the NCP if the defendants prove a response action was arbitrary and capricious when measured against a specific provision of the NCP, and that excess costs resulted from the inconsistency.

U.S. Environmental Protection Agency.

GOVCOST Reports, FY83 and FY84.

N/A

00/00/85

N/A

Cost Recovery Library, Book 38A - 38D

These computer printouts contain indirect cost allocation information prepared using GOVCOST, an Ernst & Whinney software package designed to solve indirect cost allocation problems. GOVCOST was used by the Environmental Protection Agency (EPA) in allocated costs by EPA organization unit, list of allocation statistics by organizational unit, and summary of allocated costs. Included with these reports is a copy of the GOVCOST User's Guide prepared by Ernst & Whinney.

U.S. Environmental Protection Agency.

Headquarters Telephone Directory.

N/A

08/00/91, 06/00/93

U.S. Environmental Protection Agency.

Cost Recovery Library, Book 3

This directory contains a complete telephone listing of the Environmental Protection Agency's (EPA's) offices as well as individuals located at EPA's Headquarter offices.

U.S. Environmental Protection Agency.

A Management Review of the Superfund Program.

N/A

06/00/89

N/A

Cost Recovery Library, Book 46

This review, commissioned by the Administrator of the Environmental Protection Agency (EPA), William K. Reilly, appears in the reference materials section of the Superfund Program Recovery of Costs for CERCLA Response Actions, Proposed Rule Public Docket 115CR (Refer to Book 44). The report discusses a strategy for Superfund, strengthening enforcement and maximizing responsible party work at Superfund sites, accelerating and improving remedial action, using innovative technologies at Superfund sites, involving the community, managing and administering Superfund, and communicating progress to the public.

U.S. Environmental Protection Agency.

Recovery of Costs for CERCLA Response Actions; Proposed Rule.

N/A

00/00/92

U.S. Environmental Protection Agency.

Cost Recovery Library, Book 39

This is the proposed rule submitted for public comment which amends 40 CFR Part 300 and establishes a new 40 CFR Part 308, CERCLA Cost Recovery. The issues addressed by the proposed rule indirect costs and interest; documenting response actions and costs; CERCLA statute of limitations; and public comment. Refer to Book 44 for the Superfund Program Recovery of Costs for CERCLA Response Actions, Proposed Rule Public Docket 115CCR.

U.S. Environmental Protection Agency.

Resources Management Directives, Financial Management of the Superfund Program, General Superfund Information; excerpt re. Superfund Account Numbers.

N/A

07/25/88

U.S. Environmental Protection Agency.

Cost Recovery Library, Book 34

This excerpt includes pages 2-5 - 2-9, along with exhibits, which describe the components of Superfund account numbers. Topics covered include appropriation year, program element, allowance holder, regional identifier/responsibility center, activity code, and site/spill identifier. Tables are also included which show program element titles and codes, Superfund allowance holders codes, and Superfund activity codes by category and fiscal year.

U.S. Environmental Protection Agency.

Superfund Program Recovery of Costs for CERCLA Response Actions, Proposed Rule Public Docket 115CR.

N/A

08/06/92

N/A

Cost Recovery Library, Book 44

This collection is approximately 2000 pages in length and it contains the documents which are relevant to this rulemaking. The proposed regulation is intended to clarify certain aspects of the cost recovery process and thereby avoid unnecessary costs and delays involved in that process whether they occur during settlement negotiations or administrative or judicial proceedings. The Proposed Rule Public Docket 115CR contains the following Notices, Public Comments, Response to Comments (Support Document), Communications/Correspondence, Public Information Materials, Reference Materials, and Support Materials Available to the Public from Other Sources. (See Book 39 for a copy of the Proposed Rule as submitted by EPA for public comment).

U.S. Environmental Protection Agency.

Who's Who and What's What in PCMD.

N/A

02/00/90

U.S. Environmental Protection Agency.

Cost Recovery Library, Book 17

This handbook provides the reader with information about the Environmental Protection Agency's (EPA's) Procurement and Contracts Management Division (PCMD) and was written to assist employees in EPA Regions and in Headquarters. This reference book describes the important elements of the contracting process, points of contact within the Procurement and Contracts Management Division as well as information on all the regulations and procedures followed in PCMD. An organizational chart which delineates the Branches and Sections within PCMD is included.

U.S. Environmental Protection Agency.

40 CFR Part 2, Disclosure of Confidential Data; Interim Rule.

Federal Register, Volume 58, No. 2 pp. 458 - 465.

01/05/93

United States Government Printing Office

Cost Recovery Library, Book 61

This rule updates statutory references to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) pursuant to changes made by the Superfund Amendments and Reauthorization Act of 1986 (SARA), corrects erroneous citations to CERCLA and the Clean Air Act (CAA) in these regulations, authorizes disclosure of confidential data submitted by contractors, pursuant to CERCLA section 104, to authorized representatives of the United States and to potentially responsible parties (PRPs) in actions under CERCLA section 107 for recovery of EPA's response costs, and authorizes disclosure of confidential data to contractors of other Federal Agencies.

U.S. Environmental Protection Agency, Financial Management Division, Superfund Accounting Branch.

Annual Allocation Reporting Process, EPA Guidance Document.

N/A

07/23/92

U.S. Environmental Protection Agency

Cost Recovery Library, Book 58

This guidance is intended to be the primary source of guidance for the Environmental Protection Agency's (EPA's) preparation in the Annual Allocation Reporting Process. This document discusses the Annual Allocation Reporting Process, defines the roles and responsibilities of EPA participants in the Annual Allocation Reporting Process, provides guidance for the performance of activities required prior to a contractor's report preparation, and discusses additional sources of information.

U.S. Environmental Protection Agency. Financial Management Division. Superfund Accounting Branch.

Fiscal Year 1988 Indirect Costs.

N/A

09/04/91

N/A

Cost Recovery Library, Book 69

This binder includes calculations for EPA's indirect costs for fiscal year 1988. These calculations are used to allocate EPA's indirect costs for fiscal year 1988. Notes regarding the indirect cost computations include indirect cost methodology; allocation statistics; identification of costs; cost exclusions in regards to IAGs, contracts, and grants; realignment of amounts in regard to layoffs; review of the calculations, and supporting detail are included as part of this package.

U.S. Environmental Protection Agency. Financial Management Division. Superfund Accounting Branch.

Summary of the Indirect Cost Pools, Fiscal Year 1987 Indirect Costs.

N/A

N/A

N/A

Cost Recovery Library, Book 68

This binder contains EPA's indirect cost pool calculations for fiscal year 1987. These calculations are used to allocate EPA's indirect costs for fiscal year 1987. Notes regarding the indirect cost methodology, indirect cost exclusions, indirect costs expended, indirect cost computer files, indirect cost computations, other adjustments to indirect costs, indirect costs HQ Press Releases are included as part of this package.

U.S. Environmental Protection Agency, Financial Management Division, Superfund Accounting Branch.

Transmittal of Revised Annual Allocation Clause and Instruction Document for Superfund Contracts.

N/A

09/13/91

U.S. Environmental Protection Agency

Cost Recovery Library, Book 59

The purpose of this memorandum is to transmit a revised Annual Allocation contract clause for all active Superfund contracts. This transmittal includes a brief contract clause Attachment A, Annual Allocation of Non-Site Costs and Attachment B, Instructions for Performing the Annual Allocation of Non-Site-Specific Costs. Both the clause and the instruction document incorporate comments and suggestions from PCMD staff, regional contracting officers, and the Contracts Operation Review and Assessment Staff of OSWER.

U.S. Environmental Protection Agency. Office of Communications and Public Affairs.

Glossary of Environmental Terms and Acronym List.

N/A

12/00/89

U.S. Environmental Protection Agency.

Cost Recovery Library, Book 2

This glossary of environmental terms and acronyms is designed to give the user an explanation of the more commonly used environmental terms and acronyms appearing in EPA publications, news releases and other Agency documents. Please refer to Book 2A for an updated version of this publication.

U.S. Environmental Protection Agency. Office of Communications and Public Affairs.

Terms of Environment, Glossary, Abbreviations and Acronyms.

N/A

09/00/92

U.S. Environmental Protection Agency.

Cost Recovery Library, Book 2A

This glossary of environmental terms, abbreviations, and acronyms is the most recent Environmental Protection Agency (EPA) publication which defines the more commonly used environmental terms appearing in EPA publications, news releases, and other Agency documents. This glossary combines terms and acronyms from previously published lists, internal glossaries produced by various programs and specific suggestions made by personnel in many Agency offices.

U.S. Environmental Protection Agency. Office of the Comptroller. Financial Management Division. Superfund Accounting Branch.

Financial Management Procedures for Documenting Superfund Costs.

N/A

09/00/86

U.S. Environmental Protection Agency

Cost Recovery Library, Book 43

This handbook establishes Agency-wide procedures to ensure that documentation of the Environmental Protection Agency's (EPA's) costs of cleaning up Superfund sites is complete and accurate and can be provided to attorneys for litigation in a timely manner. Financial Management Procedures for Documenting Superfund Costs was written primarily for EPA's Financial Management Offices (FMOs), which are responsible for documenting Superfund costs and providing copies of the cost documentation to EPA counsel. This document is often referred to as "the Bluebook".

U.S. Environmental Protection Agency. Office of the Comptroller. Financial Management Division.

Financial Management of the Superfund Program.

N/A

07/25/88

U.S. Environmental Protection Agency

Cost Recovery Library, Book 42

This document, designated as Directive 2550-D of the Resources Management Directives Systems, provides financial management and accounting policies and procedures guidance for the Superfund Program.

U.S. Environmental Protection Agency. Office of the Comptroller. Financial Management Division. Superfund Accounting Branch.

Pilot Project Design and procedures: Transfer of Cost Documentation Package Responsibilities to Region VII.

N/A

03/23/89

N/A

Cost Recovery Library, Book 32

This Report describes the Pilot Study, using the Environmental Protection Agency's (EPA's) Region VII, to test and confirm the feasibility of transferring cost documentation package preparation responsibilities to the Regions. The Report contains four chapters, including a description of the Pilot Study, procedures for the initial and on-going transfer of site files to Region VII, and procedures for monitoring the timeliness and quality of cost documentation package preparation.

U.S. Environmental Protection Agency. Office of the Comptroller. Financial Management Division. Superfund Accounting Branch.

State Superfund Financial Management and Recordkeeping Guidance.

N/A

11/00/87

U.S. Environmental Protection Agency

Cost Recovery Library, Book 35

This handbook provides Superfund financial management and recordkeeping guidance to help state agencies receiving Superfund monies to understand and meet their site-specific financial management and recordkeeping responsibilities.

U.S. Environmental Protection Agency. Office of the Comptroller. Financial Management Division. Superfund Accounting Branch.

Superfund Indirect Cost Manual for Fiscal Years 1985 and 1986.

N/A

07/00/91

U.S. Environmental Protection Agency

Cost Recovery Library, Book 33

This Manual provides a detailed description of the computation of the Environmental Protection Agency's (EPA's) indirect cost rates and should be used in conjunction with the Superfund Indirect Cost Manual for Cost Recovery Purposes, FY 1983 through FY 1986, issued in March 1986 (see Book 27). This Manual has three sections. Section one provides a brief description of the theory of indirect costs. The second section is a detailed description of the steps taken in computing the Agency's indirect cost rates. The third section describes the changes in the indirect cost methodology from FY 1983-84 and FY 1985-86. The FY 1985 and FY 1986 computations are included as an appendix.

U.S. Environmental Protection Agency. Office of the Comptroller. Office of Administration and Resources Management.

Superfund Final Indirect Cost Rates for Fiscal Years 1987 and 1988.

N/A

04/02/93

U.S. Environmental Protection Agency

Cost Recovery Library, Book 57

This memo transmits final indirect cost rates for fiscal years 1987 and 1988. These rates are applied to payroll hours worked in selected Responsibility Centers as described in the "Superfund Indirect Cost Manual Fiscal Years 1985 and 1986" dated July 1991 (Book 33). The 1987 and 1988 rates were computed based on the indirect cost methodology recommended in a study by Ernst & Whinney dated August 1983 (Book 22) and have been audited by the Office of Inspector General (Book 23). Attachment A, Final Indirect Cost Rates for Superfund Cost Recovery Fiscal Years 1987 and 1988, and Attachment B, Final and Provisional Indirect Cost Rates for Superfund Cost Recovery Fiscal Years 1983 through 1993 are included.

U.S. Environmental Protection Agency. Office of the Comptroller. Office of Administration and Resources Management.

Superfund Indirect Cost Manual for Cost Recovery Purposes, FY 1983 through FY 1986.

N/A

03/00/86

U.S. Environmental Protection Agency

Cost Recovery Library, Book 27

This Manual was prepared to describe the fundamentals of the indirect cost allocation methodology in an understandable way. The Manual also explains how the FY 1983 and FY 1984 indirect cost rates were developed.

U.S. Environmental Protection Agency. Office of the Comptroller. Office of Administration and Resources Management.

Superfund Indirect Cost Rates for Fiscal Years 1985 and 1986.

N/A

12/17/87

U.S. Environmental Protection Agency

Cost Recovery Library, Book 28

This Memo transmits final indirect cost rates for FY 1985 and FY 1986. The rates have been audited by the Office of Inspector General. The indirect cost rate calculations for FY 1985 and 1986 are included as an attachment to this memo.

U.S. Environmental Protection Agency. Office of the Comptroller. Office of Administration and Resources Management.

Superfund Indirect Cost Rates for Fiscal Year 1987.

N/A

09/28/89

U.S. Environmental Protection Agency

Cost Recovery Library, Book 29

This memo transmits the FY 1987 Superfund indirect cost rates for cost recovery actions. These rates are considered provisional and subject to change based on an audit by the Environmental Protection Agency's (EPA's) Office of Inspector General and promulgation of EPA's Regulation on CERCLA Cost Recovery. The FY 1987 provisional indirect cost rates are included as an attachment to this memo.

U.S. Environmental Protection Agency. Office of the Comptroller. Office of Administration and Resources Management.

Superfund Indirect Cost Update.

N/A

01/05/87

U.S. Environmental Protection Agency

Cost Recovery Library, Book 30

This memo updates the information contained in the Superfund Indirect Cost Manual, FY 1983 through FY 1986, which provided indirect cost rates to be used in Superfund cost recovery actions. This memo provides new rates for FY 1983 - FY 1986 and a provisional rate for FY 1987, clarifies the distinctions between provisional rates and final rates, and apprises the reader of the Environmental Protection Agency's (EPA's) plans regarding indirect costs during FY 1987.

U.S. Environmental Protection Agency. Office of the Comptroller. Office of Administration and Resources Management.

Transmittal of FY 1983 Indirect Cost Rates for Use in CERCLA Section 107 Actions.

N/A

07/08/85

U.S. Environmental Protection Agency

Cost Recovery Library, Book 31

This transmittal includes as Attachment 1 the FY 1983 indirect cost rates for each region and specific instructions for indirect cost rate calculation. These rates are used in calculating Agency indirect costs to be claimed for reimbursement from responsible parties in CERCLA cost recovery actions. The transmittal also includes an Attachment 2, "U.S. Environmental Protection Agency Stand-Alone Document for Allocating FY 1983 Indirect Costs to Superfund Sites", which gives an explanation of the allocation methodology used to develop the indirect cost rates for each region.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.

Superfund: Getting into the Act; Contracting and Subcontracting Opportunities in the Superfund Program.

N/A

04/00/89

U.S. Environmental Protection Agency.

Cost Recovery Library, Book 16

This publication was intended to assist those interested in providing contractual services to the Superfund program. This publication discusses procurement opportunities under Superfund. It also describes the following five basic types of Superfund services, (4) technical support services, and (5) policy program management, and administrative Services. Contact points, addresses, and telephone numbers for firms with Superfund contracts are provided in this publication.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.

User's Guide to the Contract Laboratory Program.

9240.0-01D

01/00/91

U.S. Environmental Protection Agency.

Cost Recovery Library, Book 72

This Guide was prepared by the Contract Laboratory Program (CLP) Sample Management Office (SMO) to provide guidance and direction to the programs clients. This CLP User's Guide discusses the objective and structure of the CLP, the procedures for CLP analysis and acts as a reference for the Regions and laboratory contractors to promote consistency in procedures and to ensure proper adherence to CLP requirements. A directory of contacts in the National Program Office, the Sample Management Office, and each of the EPA's ten Regions is included in this Guide.

U.S. Environmental Protection Agency. Hazardous Site Evaluation Division.

FIT Zone Contracts Management Guide.

N/A

01/00/90

N/A

Cost Recovery Library, Book 75

This Manual discusses the FIT (Field Investigation Team) contracts as well as the roles and responsibilities of the Environmental Protection Agency. The FIT contracts constitute the primary capability of the Federal government for assessing, inspecting, and ranking hazardous waste sites. This Guide discusses how the contractor's performance is tracked (i.e. TDDs (Technical Directive Document) and Progress Reports). Both TDDs and Progress Reports are known as work performed documents.

U.S. Environmental Protection Agency. Office of the Inspector General.

Annual Superfund Report to the Congress for Fiscal 1987.

N/A

09/00/88

N/A

Cost Recovery Library, Book 66

This report is provided pursuant to section 111(k) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended. The Superfund Amendments and Reauthorization Act (SARA) of 1986 amended that section of CERCLA to add several annual requirements for the Inspector General of each Federal agency carrying out CERCLA authorities. These requirements include four audit areas (Trust Fund, Claims, Cooperative Agreements, and Remedial Investigations/Feasibility Studies (RI/FS)) and an annual report to Congress regarding the required audit work. This report covers fiscal 1987 audits of Superfund activities. In addition to fulfilling the statutory requirements the objectives of this report include providing Congress with significant results of all Superfund audit work and a better understanding of how the Office of Inspector General is carrying out its purposes with respect to the Superfund program.

U.S. Environmental Protection Agency. Office of the Inspector General.

Audit Report No. E5E26-05-0101-61508; Report of Audit; EPA's Planning, Negotiation, Awarding and Administering of Emergency Response Cleanup Services Contracts (ERCS).

N/A

09/23/86

N/A

Cost Recovery Library, Book 63

This is an audit of the Emergency Response Cleanup Services Contracts (ERCS). The objective of this audit was to evaluate the efficiency, effectiveness, and economy of the ERCS contracts.

U.S. Environmental Protection Agency. Office of the Inspector General.

Audit Report No. E1SFF9-03-0144-0100222. Report of Audit, Report of Audit on Superfund Cost-Plus-Award-Fee Contracts.

N/A

03/28/90

N/A

Cost Recovery Library, Book 64

This is an audit of Superfund Cost-Plus-Award-Fee Contracts. The purpose of this audit was to determine if awards fees effectively motivated contractors to excellence, award fee plans and procedures were consistent between Superfund programs, the award fee process adhered to Federal Acquisition Regulations, award fee plans developed by the Agency, and Superfund program user manuals, and award fee process was completed in a timely manner.

U.S. Environmental Protection Agency. Office of the Inspector General.

Audit Report No. E1SGE2-03-0145-2100209; Final Report on Audit on Superfund Alternative Remedial Contract Strategy (ARCS) Contracts in Region 1, 3, and 5.

N/A

02/03/92

N/A

Cost Recovery Library, Book 65

The objective of this audit was to evaluate whether ARCS (Alternative Remedial Contract Strategy) contracts accelerated site remediation by expediting site studies, generated improvement in contractor performance, and increased efficiency and accountability. This report contains important findings and recommendations regarding ARCS contracts. Recommendations are made to both the Assistant Administrator for Solid Waste and Emergency Response and the Acting Assistant Administrator for Administration and Resources Management.

U.S. Environmental Protection Agency. Office of the Inspector General.

A Decade of Auditing Superfund Obligations and Disbursements: Fiscal Years 1981 Through 1990, Audit Report P1SFF1-11-0027- 3100058.

N/A

12/29/92

N/A

Cost Recovery Library, Book 60

This audit report summarizes the results of audits performed by the Office of the Inspector General of Superfund obligations and disbursements for the 10 year period ending September 30, 1990.

U.S. Environmental Protection Agency. Office of the Inspector General.

Final Audit Report No. P1SFF0-11-0041-3100114 Financial Audit of Superfund Indirect Cost Rates for Fiscal Years 1988 and 1987.

N/A

02/22/93

N/A

Cost Recovery Library, Book 56

This memo transmits EPA's (Environmental Protection Agency's) final audit report on the results of the financial audit of the Schedules of Indirect Cost Rates for the Hazardous Substance Superfund for the Fiscal Years Ended September 30, 1988 and September 30, 1987. The attached report (Dated January 27, 1993) was prepared by Leonard G. Birnbaum and Company, Certified Public Accountants, and is based on field work they performed from September 4, 1991, to July 14, 1992. The rates were calculated from EPA's indirect costs in operating the Superfund program. The indirect cost rates are used in cost recovery actions against responsible parties.

U.S. Environmental Protection Agency. Office of the Inspector General.

The OIG Manual; Chapter 103 - Review of Internal Controls, Chapter 104 - The Survey Phase of Audits, Chapter 105 - Reviews of Operation, Chapter 107 - Audit Guides and Assignment Programs, Chapter 108 - Audit Evidence and Working Papers, Chapter 109 - Nature and Presentation of Audit Findings and Recommendations, Chapter 110 Audit Report Content and Format, Chapter 111 - Review and Issuance of Audit Reports, Chapter 112 - Distribution of Audit Reports, Chapter 117 - Management of Multidivisional Audits, Chapter 122 - Compliance with Laws and Regulations, and Chapter 150 - Reports of Review.

N/A

03/26/84 - 09/02/92

N/A

Cost Recovery Library, Book 62

These OIG (Office of Inspector General) Manual Chapters cover the OIG audit process. These procedures include conducting the survey (chapter 104); developing audit guides and programs (the guide and program details how the audit will be accomplished, what the auditor will do to accomplish the audit objectives (chapter 107)); the audit work (chapter 108); the audit report phase (chapters 109, 110, 111, 112) and special reviews (chapter 150). In addition to these procedures, the OIG audit staff is required to comply with the General Accounting Office (GAO) Government Auditing Standards and other generally accepted audit standards (Please refer to Book 40).

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response.

Enforcement Project Management Handbook.

Directive 9837.2B

05/00/93

N/A

Cost Recovery Library, Book 67

The overall goal of the Superfund program is to protect human health and the environment through timely and effective site remediation. Enforcement plays a major role in this process. This handbook describes the roles and responsibilities of the Regional Project Manager (RPM) in identifying and communicating with Potentially Responsible Parties (PRPs), coordinating with the community, States, and natural resource trustees; negotiating for site cleanup; initiating administrative and judicial enforcement actions; selecting site remedies; recovering EPA's cleanup costs; and overseeing PRP-lead response actions.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.

National Cost Recovery Staff Directory.

N/A

07/00/92

U.S. Environmental Protection Agency

Cost Recovery Library, Book 37

This directory lists the staff involved in cost recovery in the Environmental Protection Agency (EPA) Headquarters Office of Waste Programs Enforcement, Office of Enforcement, and Financial Management Division; in the Regional Waste Management Divisions, Regional Financial Management Office, and Offices of Regional Council; and the Department of Justice (DOJ). The directory lists staff name, position, areas of specialization, and phone number/mail code.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.

Technical Assistance Team (TAT) Contracts User's Manual.

OSWER Directive 9242.4-01A

09/00/87

U.S. Environmental Protection Agency.

Cost Recovery Library, Book 73

This manual presents information and guidance on the management and implementation of the Environmental Protection Agency's (EPA's) "Technical Assistance Teams (TAT)" contracts. EPA's successful implementation of emergency response action responsibilities requires multidisciplinary Technical Assistance Teams (TATs) for each EPA Region. EPA has procured the services of two TAT contractors under the "Technical Assistance Teams for Emergency Response, Removal and Prevention" contracts to assist in implementing Superfund Emergency response activities. This manual defines the roles and responsibilities of EPA and contractor personnel in managing and executing the TAT contracts. Additionally, this manual discusses the work performed documents pertaining to the TAT contracts.

U.S. Environmental Protection Agency. Office of Waste Programs Enforcement, CERCLA Enforcement Division, Contracts and Planning Branch, Contracts Management Section.

TES V+ User's Manual.

N/A

04/00/92

N/A

Cost Recovery Library, Book 74

This Manual describes the Technical Enforcement Support V+ contracts by giving an overview including the background and structure of the TES contracts, contractor requirements in executing statement of work activities, and the role contract management has in regards to the TES contracts. This Guide also discusses TES work assignment management (WAM).

U.S. General Accounting Office.

Superfund: A More Vigorous and Better Managed Enforcement Program is Needed.

N/A

12/00/89

N/A

Cost Recovery Library, Book 45

This report discusses the Environmental Protection Agency's (EPA's) Superfund enforcement program. The report covers EPA's process for identifying liable and financially viable parties to hold responsible for cleaning up Superfund sites; EPA's use of its funding and de minimis settlements; EPA's recovery of its costs in cleaning up Superfund sites; and EPA's management of the enforcement program. This report also appears in Book 44, Superfund Program Recovery of Costs for CERCLA Response Actions, Proposed Rule Public Docket 115CR.

U.S. General Accounting Office.

GAO's Policy and Procedures Manual for Guidance of Federal Agencies, Title 7 - Fiscal Guidance.

N/A

02/12/90

N/A

Cost Recovery Library, Book 49

The General Accounting Office has revised Title 7 of its Policy and Procedures Manual for Guidance of Federal Agencies. This revision has been made to simplify and modernize GAO's guidance on legal and accounting requirements for fiscal procedures. It supplements Title 2 of this Manual. The Manual appears in the reference materials section of the Superfund Program Recovery of Costs for CERCLA Response Actions, Proposed Rule Public Docket 115CR (Refer to Book 44).

U.S. General Accounting Office. Office of Policy.

Title 2, GAO Policy and Procedures Manual for Guidance of Federal Agencies.

N/A

05/18/88

N/A

Cost Recovery Library, Book 48

This is a reprint of Title 2 which combines transmittals 2-24, 2-25, and 2-26. This Manual discusses accounting principles and standards, internal control standards, and accounting systems. This reprint of Title 2 appears in the reference materials Section of the Superfund Program Recovery of Costs for CERCLA Response Actions, Proposed Rule Public Docket 115CR (Refer to Book 44).

White, Mark J.

Private Response - Cost Recovery Actions Under CERCLA.

University of Kansas Law Review, Vol. 34, No. 1, pp. 109 - 147.

09/00/85

N/A

Cost Recovery Library, Book 12

This article addresses the actions a private individual can take in response to the dangers posed by a hazardous waste site, and what, if any, costs incurred in responding to these dangers the individual may recover. This article discusses the courts' decisions regarding private response cost recovery actions and concludes that the disparity in these decisions arises from both the uncertain basis for private actions and the limited statutory guidance available in CERCLA. Lastly, the author suggests that these issues can only be resolved when Congress clarifies its intent regarding the availability for private response-cost actions.