NOAA Policy 97-02
As a result of NOAA's environmental survey program, the facility manager at the Weather Forecast Office at Remote, Nebraska, realized on August 5, 1997, that his underground storage tank (UST) needed to be replaced with an above ground storage tank (AST). Since this discovery occurred within the last 60 days of the fiscal year, the facility manager met with his servicing Regional Environmental Compliance Officer (RECO) to determine if the UST removal and replacement would result in a financial environmental liability for NOAA. Since a UST removal constitutes a financial environmental liability, the RECO prepared a rough cost estimate to determine if the liability would approach or exceed the NOAA threshold for accrual of the liability. This project fell well short of that threshold, so its preparation was continued as a routine project. Had the project exceeded the NOAA threshold for accrual, its process for entry onto NOAA's master project list database would have been expedited to insure recognition and proper reporting by the end of the fiscal year.
With the help of his RECO, the facility manager drafted a description of the project on the Environmental Project Prospectus form and submitted it to the RECO on August 29, 1997. He noted that the National Weather Service did not have funds available to perform this project, and that he was inexperienced at estimating this type of cost.
Upon receipt of the prospectus, the servicing RECO validated the need for the project and the accuracy of the project description. She determined that the UST cost was a financial environmental liability, but that the AST cost was not. Furthermore, the likelihood of the UST liability was probable. Using the CostPro estimating software, she prepared a cost estimate for the UST removal at $6,000 and the cost of the replacement AST at $4,000. On September 16, 1997, the RECO submitted the data necessary to support NOAA's master protect list to NOAA's headquarters staff and recommended inclusion of the project on the list.
At headquarters, the project was reviewed and the information and conclusions validated. On October 6, 1997, the project was assigned a project number and added to the master list. It was noted to include a probable financial environmental liability project. The cost estimate was listed as $10,000, with the liability estimate listed as only $6,000. In the notes, an entry was made noting that the cost of the replacement AST was not a financial liability, although included in the total project cost estimate.
On November 4, 1997, as part of the NOAA Quarterly Review process, the RECO contacted the facility manager and verified that the UST removal and AST replacement remained a valid project and had not yet been accomplished. This validation process was repeated on January 29, 1998. On February 4, 1998, the RECO reviewed the cost estimate for the project and found it to be unchanged.
On February 9, 1998, funding was approved for the UST/AST project at Remote, Nebraska. The master list was updated to indicate that the project was funded for $10,000. A contract was placed with the Nebraska Muck and Truck Company, a qualified tank removal and replacement firm, on April 6, 1998. Work began on the Remote UST and the tank was out of the ground on April 14. Sampling revealed that there was contamination of the surrounding soil. Although the discovery of this condition was well before the end of the fiscal year and did not require expedited processing for that reason, the potential threat to the environment caused the project description and estimation process described earlier for the initial UST removal and AST replacement to be repeated on an expedited schedule such that a recommendation for inclusion of a probable financial environmental liability estimated at $30,000 for testing and removal of contaminated soil was received at headquarters on April 24, 1998. Headquarters verified the project information and conclusions and entered the data on the master list as a probable financial environmental liability project on May 4, 1998. Both the cost estimate and the liability estimate were entered as $30,000.
In the interim, headquarters approved funding for removal of the contaminated soil and a new contract was awarded. (At this point, headquarters updated the master list to indicate that the funded amount for the contaminated soil removal at Remote, Nebraska, was $30,000.) On May 13, 1998, the contaminated soil had all been removed and the state approved the process. At this point, the RECO certified that all contracted services associated with the contaminated soil removal had been performed satisfactorily and that payment should be made. The RECO notified headquarters that NOAA no longer had a contaminated soil liability at Remote, that the project was complete, and that receipt of services had been certified to the appropriate finance division. On May 28, 1998, headquarters updated the master list to show that the project was done and made the notation "completed" in the notes column. The actual cost of the contaminated soil removal was $28,000 and this figure was appropriately entered on the master list. Although NOAA no longer had a financial liability for contaminated soil, the project was retained as completed on the master list until the end of the fiscal year.
On June 9, 1998, Nebraska Muck and Truck completed installation of the AST at Remote, completing their contract. The RECO verified with the facility manager satisfactory project completion and certified for the appropriate finance division that contract payment should be made. NOAA headquarters was informed of project completion and receipt certification. On June 26, 1998, the master list was updated to reflect a completed project with an actual cost of $11,000. Again the project was retained on the master list until the end of the fiscal year.
On October 6, 1998, as part of the headquarters annual review and purging of the NOAA master list, all completed projects and those projects considered no longer necessary were removed from the master list. The master list effective on September 30, 1998, was retained as a separate file for historic and reference purposes, and a new file containing only active and future projects was carried into the new fiscal year.
Page last updated: August 23, 2010