Enforceable regulatory compliance milestones are requirements in the cleanup process with mandatory due dates, subject to the availability of appropriated funds, documented in applicable site agreements, decrees, or other legal arrangements. Enforceable regulatory compliance milestones include cleanup work like building demolition, important cleanup decisions like Superfund Records of Decision, and submission of recurring status updates like environmental monitoring reports. There are hundreds of enforceable regulatory compliance milestones within EM cleanup agreements across the complex.
While the Office of Environmental Management (EM) meets the majority of its milestone dates, fulfillment of these regulatory commitments can be challenging due to several factors. Some examples include unforeseen changes to cleanup conditions, year-by-year variations in appropriated funds, adjustments to cleanup priorities, and the need to design and implement first-of-a-kind technologies.
If EM anticipates that fulfillment of a milestone commitment will be delayed, EM site officials will notify and meet with regulators to identify a feasible alternative milestone date. Depending on the signatories of the site legal agreement, EPA and/or state regulators must approve any milestone changes EM proposes.