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ABACKGROUND SUMMARY The Comprehensive Environmental Response Compensation and Liability Act 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 Environmental Protection Agency EPA is required to recover its response costs from responsible parties after participating in the investigation cleanup oversight enforcement and other required administrative provisions State agencies which spend CERCLA funds must account for and document all response costs to permit recovery of these costs from responsible parties by EPA and the State Funds may also be provided to the State by EPA under a grant system to undertake Superfund related response activities State agencies which spend CERCLA grant funds must account for and document all State costs This manual outlines procedures involved with the expenditure of funds by the Maryland Department of the Environment MDE for CERCLA activities It sets forth financial management and recordkeeping requirements for Superfund sites and for CERCLA related activities covered 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 future cost recovery actions This manual will 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 Part 31 Part 33 and Part 35 Subpart O - State Superfund Financial Management and Recordkeeping Guidance 1987 EPA - OMB Circular No A-87 Cost 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 Section D include - Documentation of all expenses involved
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