United States 

Environmental Protection 

Agency 

Superfund Response Actions: 

Temporary Relocations 

Implementation Guidance 
Superfund Response Actions: 

Temporary Relocations 

Implementation Guidance 

U.S. Environmental Protection Agency 

Office of Solid Waste and Emergency Response 

Washington, DC 20460 

OSWER Directive 9230.0-97 

April 2002 
TABLE OF CONTENTS


I. PURPOSE AND OBJECTIVES ................................ 1 


II.	 AUTHORITIES AND GUIDING PRINCIPLES ....................... 3 


A. Applicability to Potentially Responsible Party-Led Temporary Relocations ...... 3

B. Guiding Principles ................................................. 4

III.	 TAKING A TEAM APPROACH ................................ 6 


A. Getting Help From Other Sources ..................................... 7

A.1. USACE Support ............................................ 8

A.2. Contractor Support .......................................... 9

A.3. Public Affairs ............................................... 9

A.4. Congressional Relations ..................................... 10 


A.5. Additional Support Options and Funding Tools ................... 10 


IV.	 DEVELOPING A RELOCATION STRATEGY ...................... 11 


A. Making the Relocation Decision ..................................... 11 


B. Gathering and Analyzing Resident and Household Information ............. 11 


C. Site-Specific Relocation Plan ....................................... 14 


D. Temporary Relocation Notification to Residents ......................... 15 


V.	 PROMOTING A SUCCESSFUL TEMPORARY RELOCATION WITH THE


COMMUNITY .......................................... 17 


A. Communication is a Key to Success .................................. 17 


B. Dealing with Stress and Disruption ................................... 18 


C. Anticipate the Residents’ Needs ..................................... 21 


D. Documentation of the Primary Residence and Personal Property ........... 21 


E. Site Security ..................................................... 23 


VI.	 DETERMINING ELIGIBILITY FOR RELOCATION ASSISTANCE ......... 25 


VII.	 TYPES OF ASSISTANCE AVAILABLE .......................... 26 


A. Temporary Housing ............................................... 26 


A.1. Cost of Transient Accommodations ............................ 28 


A.2. Fair Market Rent for Houses or Apartments ...................... 29 


A.3. Lodging Provided by Friends or Family ......................... 29 


B. Furniture Rental/Moving Costs ...................................... 30 


B.1. Furniture Rental ........................................... 30 


B.2. Moving Costs ............................................. 31 


C. Utilities ......................................................... 32 


C.1. Primary Residence ......................................... 32 


C.2. Temporary Residence ...................................... 33 


D. Daily Allotments for Food, Incidentals, and Laundry ...................... 33 

E. Household Staples ................................................ 34 


F. Insurance Premiums for the Temporary and Primary Residences ........... 34 


G. Personal Transportation Costs ...................................... 34 


H. Damaged or Contaminated Personal Property .......................... 35 


I. Reimbursement for Non-Residential Relocations ........................ 35 


J. Other Expenses Directly Related to Relocation .......................... 36 


K. General Requirements for Reimbursement of Expenses .................. 36 


L. Public Housing Considerations ...................................... 37 


M. Tax Implications and Eligibility for Other Federal Programs ................ 37 


N. Temporary Relocation Assistance Records Management .................. 37 


VIII. TERMINATION OF ASSISTANCE AND RESOLUTION OF DISPUTES ...... 39 


A. Termination of Assistance .......................................... 39 


B. Disputes ........................................................ 40 


IX. PROVISION OF PERMANENT ALTERNATIVE HOUSING ............. 42 


A. Renters ........................................................ 42 


A.1. Renters Who Have Occupied Their Primary Residence


Less Than 90 Days ......................................... 42 


A.2. Renters Who Have Occupied Their Primary Residence


90 Days or Longer ......................................... 42 


A.3. Down Payment Assistance ................................... 44 


B. Homeowners .................................................... 44 


ATTACHMENTS ............................................. 46 

ATTACHMENTS


1. Temporary Relocation Check List ........................................ 47 


2. Decent, Safe, and Sanitary Standards .................................... 50 


3. Key Team Functions .................................................. 51 


4. Consent for Entry and Access to Property ................................. 54 


5. Statement of Work ................................................... 56 


6. Comparable Replacement Housing ...................................... 58 


7. Notification Letter .................................................... 59 


8. Essential Furniture Items .............................................. 61 


9. Personal Property Appraisal Record ...................................... 62 


10. U.S. EPA Temporary Relocation Agreement ............................... 63 


11. Information Needed to Apply for Relocation Assistance ....................... 67 


12. Application for Superfund Temporary Relocation Assistance—Needs Determination 68


13A. Meals and Incidentals Computation Sheet ................................. 74 


13B. Rental Assistance Computation Sheet .................................... 75 


14. Assignment of Insurance Claim ......................................... 76 


15. Sample Insurance Claim Letter to Insurance Company ....................... 78 


16. Example of Hotel Rules ............................................... 79 


17. General Packing Instructions ........................................... 81 


18. Check Receipt Acknowledgment Form .................................... 82 


19. Application for School Bus Transportation ................................. 83 


20. Public Housing 101—Section 8 Housing Choice Voucher Programs ............. 86 


21. Ending Temporary Relocation Assistance ................................. 88 


22. List of Related Documents ............................................. 89 


23. List of Acronyms ..................................................... 90 

DISCLAIMER


This document provides guidance to United States Environmental Protection Agency (EPA) 

Regions concerning how the Agency intends to exercise its discretion in implementing one 

aspect of Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 

response actions—the temporary relocation of residents. 

Some of the statutory provisions described in this document contain legally binding 

requirements. However, this document does not substitute for any statutory provisions or 

regulations, nor is it a regulation itself. Thus, it cannot impose legally binding requirements on 

EPA, states, or the regulated community, and may not apply to particular situations based upon 

the circumstances. Any decisions regarding a particular temporary or permanent relocation 

issue will be made based on statutory provisions or regulations, and EPA decision makers retain 

the discretion to adopt approaches on a case-by-case basis that differ from this guidance when 

appropriate. 

Interested parties are free to raise questions and objections about the substance of this 

guidance and the appropriateness of the application of this guidance to a particular situation. The 

Agency welcomes public input on this document at any time. EPA may change this guidance in 

the future. 
I. PURPOSE AND OBJECTIVES 

The purpose of this guidance is to provide On-Scene Coordinators (OSCs), Remedial Project 

Managers (RPMs), Community Involvement Coordinators (CICs), representatives from the 

Office of Regional Counsel (ORC) of the United States Environmental Protection Agency (EPA), 

and potentially responsible parties (PRPs) with policy and recommended procedures for 

temporarily relocating residents during response actions carried out under Sections 104(a) and 

106(a) of the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA). Limited information is also provided for temporarily relocating businesses, see 

Section VII, “Types of Assistance Available.” This guidance also is designed to help implement 

the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (URA), as 

amended, and the Uniform Relocation Assistance and Real Property Acquisition Regulations for 

federal and federally assisted programs contained in 49 CFR Part 24. 

The objectives of this guidance are to ensure the following: 

•	 Temporary relocations are carried out in a way that is sensitive to the needs of the


people being relocated.


•	 EPA is fair and consistent in the way temporary relocations are carried out. 

•	 All temporary relocations comply with relevant laws and regulations. 

In this guidance, all relevant terms are defined according to the laws and regulations from which 

they are derived. The forms and letters included in the attachments are examples, and should be 

modified to meet site-specific needs. A “Temporary Relocation Checklist” is included in 

Attachment 1. This checklist includes the tasks that may need to be performed; it is not intended 

to stand alone as guidance. 

Temporary relocations are carried out under removal and remedial authorities and can occur as 

part of an emergency response or an action that has a longer planning period. They can affect 

one person, a family, hundreds of people, businesses, farms, churches, and other 

organizations. Because of the range and scope of actions where temporary relocation may be 

contemplated, and because each resident’s life has unique circumstances, this document is 

unlikely to answer all questions. Relocation experts in the Office of Emergency and Remedial 

Response (OERR) and the Office of General Counsel (OGC) have experience working with 

temporary relocations conducted throughout the ten Regions and also have contacts at other 

federal agencies who can provide additional advice. Regions are encouraged to contact their 

OERR Regional Coordinator for assistance in identifying appropriate experts. 

This document supersedes “Guidance on Temporary Relocations During Superfund Removal 

Actions,” EPA Region 5, August 1996, and any previous guidance on temporary relocations 

performed by EPA under CERCLA authority. All temporary relocations conducted under 

CERCLA authority, whether funded by EPA or conducted by PRPs, should be undertaken 

consistent with this guidance. 

OSWER Directive 9230.0-97 1 
In general, EPA does not provide temporary relocation assistance to potentially responsible 

parties because of their role in creating or maintaining the situation that caused the relocation in 

the first place. However, in cases where a person’s contribution to the contamination of their 

own residence has been very minor (de minimis), the Region may make the determination that a 

resident who may be a PRP is eligible for temporary relocation assistance based on a review of 

the facts at the time. 

2 April 2002 
II. AUTHORITIES AND GUIDING PRINCIPLES 

In 1971, Congress enacted the Uniform Relocation Assistance and Real Property Acquisition 

Policies Act (URA), Public Law (PL) 91-646 at 42 U.S.C. Section 4601. This Act provides for 

uniform and equitable treatment of people whose homes or businesses are acquired by federal 

and federally assisted programs. Congress later amended this law and designated the 

Department of Transportation (DOT) as the lead agency for its implementation. Under its 

authority as lead agency, DOT issued uniform regulations. These regulations, published in 49 

CFR Part 24, provide specific rules for conducting permanent relocations and useful guidance 

for temporary relocations. EPA should be consistent with these regulations when implementing 

a temporary relocation. 

In 1981, Executive Order 12316 delegated the CERCLA Section 104(a) temporary and 

permanent relocation authority to the Director of the Federal Emergency Management Agency 

(FEMA). In July 1984, FEMA delegated to EPA the authority to determine the need for temporary 

relocation as part of removal actions, but retained the authority to actually conduct the 

relocations. FEMA promulgated regulations for implementing temporary relocations under 

CERCLA. In the fall of 1990, Executive Order 12580 redelegated to EPA the authorities originally 

delegated to FEMA to conduct temporary and permanent relocations. FEMA later withdrew its 

regulations. 

A CERCLA response action may require that EPA relocate people temporarily to ensure their 

health and safety or to allow EPA to conduct cleanup activities. Unlike permanent relocation, 

which generally involves the acquisition of real property by the federal government or PRPs, 

temporary relocation does not involve the acquisition of real property. Appendix A of the DOT 

Uniform Regulations distinguishes between displaced persons (owners or occupants of real 

property being acquired for federal or federally assisted projects) and owners/occupants of real 

property who are required to relocate temporarily in connection with such projects. 

Appendix A of the DOT Uniform Regulations urges agencies to ensure consistent treatment for 

people who are being temporarily relocated and to reimburse them “for all reasonable out-ofpocket expenses incurred in connection with the temporary relocation, including moving 

expenses and increased housing costs during the temporary relocation.” The URA and its 

implementing regulations provide the guiding principles for EPA and PRP staff when conducting 

temporary relocations. 

A. Applicability to Potentially Responsible Party-Led Temporary Relocations 

This guidance provides a framework for determining what financial or advisory assistance is 

provided to residents when they are temporarily relocated during a PRP-lead or Fund-lead 

(funded by EPA using Superfund) response action. The Agency is committed to ensuring that all 

temporarily relocated residents and businesses receive fair and equitable treatment and that 

assistance provided is consistent among Superfund response actions. 

Sometimes, PRPs will be asked to conduct temporary relocations of residents and businesses. 

While the URA and its regulations set the standard for federal and federally assisted projects, 

they do not discuss relocations performed by a non-governmental entity. To ensure that 

relocations conducted by PRPs meet the same or similar standards, the relevant URA 

OSWER Directive 9230.0-97 3 
requirements and this guidance should be incorporated into the Record of Decision (ROD) or 

Action Memorandum and other enforceable decision documents. 

As part of any response action, whether Fund- or PRP-lead, residents and business owners 

should be advised of the relocation procedures and assistance available very early in the 

process. Residents and business owners should be told that if they are not satisfied with a 

PRP’s decisions regarding assistance, they should contact EPA in writing and provide a detailed 

description of their claim. The EPA OSC or RPM should contact his/her colleague in ORC and, 

when appropriate, his/her OERR Regional Coordinator at Headquarters regarding the claim. 

EPA should work with the PRP to ensure that affected parties are treated fairly and consistently 

(see Section VIII, “Termination of Assistance and Resolution of Disputes,” for additional 

guidance). 

The remainder of this guidance addresses the policies and implementation of temporary 

relocation operations during CERCLA response actions, as well as the parameters and the 

administration of temporary relocation assistance. 

B. Guiding Principles 

The URA regulations, 49 CFR Section 24.2, Appendix A, provide requirements for temporary 

relocation. The following requirements serve as guiding principles to help OSCs and RPMs 

make decisions about appropriate temporary relocation assistance for residents: 

•	 The Agency should ensure fair and equitable treatment of people who are being


temporarily relocated.


•	 Residents should be compensated for actual, reasonable, and necessary out-of-pocket 

expenses. In most cases, residents must first incur expenses to be entitled to 

reimbursement. Residents are not entitled to compensation for expenses that are never 

incurred. 

•	 Residents are entitled to temporary housing that is, at a minimum, decent, safe and 

sanitary (see Attachment 2). 

In addition to these principles, the Agency emphasizes the following: 

•	 Regions should use a team approach to relocation planning and decision making to 

ensure clear communication and timely responses by the appropriate experts. The site 

team, led by an OSC or RPM, may be as small or large as needed given the complexity 

of the temporary relocation, and should include relocation support experts to ensure a 

successful relocation. The team approach is described in Section III of this document. 

•	 Generally, temporary relocations are considered voluntary. In situations where the health 

or safety of residents is threatened by the contamination, the local government may use 

its own authority (e.g., authority to condemn property) to force a temporary relocation of 

occupants. Contact your OERR Regional Coordinator for additional support if residents 

refuse to relocate temporarily. 

4 April 2002 
•	 Temporary relocation assistance is not intended to compensate individuals for expenses 

or losses associated with contamination at a Superfund site. 

•	 Efforts should be made to limit the disruption of the residents’ personal lives. 

•	 EPA and its relocation support experts should avoid suggesting that specific assistance 

will be provided until it is known that the individual resident qualifies for the assistance. 

OSWER Directive 9230.0-97 5 
III.TAKING A TEAM APPROACH 

Historically, temporary relocations have consumed more of the OSC’s/RPM’s time than 

anticipated. Most OSCs and RPMs with experience implementing relocations strongly 

recommend forming a Temporary Relocation Team (the Team) to efficiently manage the 

temporary relocation. This team approach brings together people with a mixture of technical, 

outreach, and legal expertise to effectively support the affected community, while allowing the 

OSC/RPM to focus on implementing the cleanup. However, it is very important for the 

OSC/RPM to remain actively involved as a key member of the Team even as he or she 

implements the cleanup. The OSC/RPM may have to make key decisions that affect residents’ 

lives and will need to know the community and each resident well. 

The Team should be organized early to help the OSC/RPM determine if temporary relocation is 

a viable option. The size and composition of this Team will depend on the scope and complexity 

of the temporary relocation being considered. Some Team members may never meet one-onone with the residents, while others may work closely with the community while serving as 

technical experts for the temporary relocation. 

It is important for each agency or organization to understand EPA’s leadership role and to have 

its own role clearly defined at the beginning of the project. The Team should immediately assign 

responsibility for its various functions. It is especially important for the Team to select one or two 

members to be the community’s primary contacts on temporary relocation issues to ensure 

consistent communication between the community and the Team. It is often best to have more 

than one Team member attend meetings with the residents and to document these meetings 

fully and accurately. If not already done, the OSC/RPM should notify his or her Headquarters 

OERR Regional Coordinator that a temporary relocation is planned. Headquarters can provide 

additional guidance on implementing temporary relocations. 

At first, Team members generally include: 

• 	An OSC or RPM. 

•	 A CIC. 

•	 An attorney from the ORC. 

•	 A relocation expert from another federal agency or an EPA contractor. 

If the temporary relocation being considered is large or complex, other Team members may be 

added to the Team to offer specific expertise. These members may include: 

•	 Representatives from the Region’s offices responsible for external affairs/media


relations.


•	 Representatives from the Region’s office responsible for environmental justice concerns. 

•	 Representatives from local government. 

6 April 2002 
•	 State or tribal government representatives. 

•	 Officials from local health and social service agencies. 

•	 Officials from the Agency for Toxic Substances and Disease Registry (ATSDR), the 

Department of Housing and Urban Development (HUD), and other federal agencies. 

The Team also may draw on the expertise of the OGC and OERR. It also helps to have a Team 

member with expertise on health and safety issues available to address residents’ concerns. A 

list of key Team functions is included in Attachment 3. 

For PRP-led temporary relocations, it is recommended that the PRP’s team include members 

with expertise similar to those who would be involved in a fund-led response. The OSC/RPM 

overseeing a PRP-led temporary relocation should work closely with the PRP’s team to ensure 

that people are treated fairly, consistently, equitably, and in accordance with this guidance, and 

to provide technical assistance where necessary. 

EPA staff and relocation support experts must be sensitive to the needs of all affected residents, 

including those who live near the site but are not temporarily relocated. Even a small relocation 

may require hundreds of decisions. Temporary relocation disrupts everyone’s lives, especially 

those residents with special needs, including: 

•	 The elderly and families with small children requiring community services or special 

housing arrangements. 

•	 People with pets needing special housing arrangements or kenneling. 

•	 Families with school-age children who have after-school activities and require special 

transportation arrangements. 

•	 People with complicated health problems who require special services. 

•	 Owners of small businesses and farms who find temporary relocation especially difficult 

and potentially financially devastating. 

•	 Community members who are opposed to the implementation or the scope of the


response action.


•	 People who need to live near public transportation to get to work, school, or day care 

providers during the temporary relocation. 

•	 People who find the temporary relocation particularly stressful and need extra support. 

A. Getting Help From Other Sources 

To support implementation of a temporary relocation, an OSC/RPM may request technical 

assistance from the United States Army Corps of Engineers (USACE), other federal agencies, 

and contractors. Technical assistance from relocation specialists is especially important for 

OSWER Directive 9230.0-97 7 
large or complex relocations and for relocations that are expected to last more than a few 

weeks. Relocation experts should be consulted at key milestones in the decision-making 

process, such as when the availability of adequate temporary housing is being determined. 

A.1. USACE Support 

EPA has a Memorandum of Understanding (MOU) with USACE, under which USACE has 

agreed to provide technical assistance to EPA. USACE relocation support is usually provided by 

USACE’s real estate experts. Such technical assistance may include relocation support 

services, such as: 

•	 Identifying available temporary housing. 

•	 Documenting each resident’s unique needs. 

•	 Determining relocation assistance payments. 

•	 Arranging for rental furniture. 

•	 Arranging for storage of personal property, if necessary. 

•	 Arranging transportation for residents who are temporarily relocated away from their 

work or school. 

•	 Arranging the moves to and from the temporary residence. 

•	 Maintaining temporary relocation files. 

•	 Obtaining temporary access agreements on real property affected by the response 

action (for an example of an access agreement, see Attachment 4, “Consent for Entry 

and Access to Property.”). 

•	 Answering resident’s questions about the temporary relocation. 

•	 Helping residents prepare their applications for assistance. 

•	 Reviewing disputes and making recommendations to EPA (additional information on 

resolving disputes is available in Section VIII.B. of this guidance). 

A Regional office may enter into a site-specific Interagency Agreement (IAG) with USACE to 

obtain technical support services. Regions also have access to an umbrella IAG that is 

managed in the Region or at Headquarters. These umbrella IAGs can be accessed quickly to 

obtain support for initial decision making and getting started with the temporary relocation. It may 

be necessary to put additional funds into the IAG before the USACE can fulfill all the 

requirements of the Statement of Work (SOW). 

The Team may contact its OERR Regional Coordinator to access the Headquarters umbrella 

IAG. The IAG process should be started as soon as there is an indication that temporary 

relocation support from USACE will be needed. Funding for relocation support services will 

come from extramural resources. Each IAG must contain a SOW that describes the type(s) of 

8 April 2002 
services to be performed (Attachment 5 contains a sample SOW for relocations). It is important 

that the SOW provides clear, well-defined expectations and that it emphasizes that this 

guidance is to be used for all fund-led temporary relocations. The OSC/RPM must stay closely 

involved in the effort by working directly with USACE and overseeing its work. 

A.2. Contractor Support 

Sometimes it is not possible to obtain on-site support from USACE relocation specialists at the 

earliest stages of a temporary relocation. In these cases, the OSC/RPM may use the 

Emergency and Rapid Response Services (ERRS) and Superfund Technical Assistance and 

Response Team (START) contractors, or the Superfund Analytical Technical Assistance 

Contractors (SATA) or their subsequent replacement contracts. However, there are limitations 

on the use of ERRS/START or SATA contractors: 

•	 The ERRS/START or SATA contractors generally should be used only in emergency 

situations (contact a Regional Contracting Officer for additional input). The OSC/RPM 

should discuss the extent of the ERRS/START or SATA contractors’ role in the 

temporary relocation with the appropriate Regional Contracting Officer. If the 

ERRS/START or SATA contractors are used for the duration of the temporary relocation, 

the OSC/RPM must be available to monitor its actions. For long-term (more than a few 

weeks) or complex temporary relocations, the OSC/RPM should arrange for the services 

of USACE or a contractor with relocation expertise as soon as possible. 

•	 Generally, contractor involvement should focus on performing initial relocation tasks, 

including identifying potential temporary housing, tracking costs, moving the residents to 

hotels, reimbursing residents for expenses, and handling routine procedures. 

•	 Generally, the ERRS/START or SATA contractors may provide administrative support 

during the temporary relocation (e.g., tracking costs and paying temporary relocation 

expenses). 

•	 The ERRS/START or SATA contractors never should be asked to do anything that will 

require making decisions regarding relocation assistance beyond what is clearly 

described in this guidance or involves EPA’s discretion. The OSC/RPM should provide 

the contractor with very clear instructions regarding EPA’s expectations. 

A.3. Public Affairs 

CERCLA actions involving temporary relocations are likely to generate considerable public 

interest, resulting in greater demand for public affairs and community involvement activities than 

is normally necessary for Superfund actions (see EPA Publication 9360.3-05, “Superfund 

Removal Procedures, Public Participation Guidance for On-Scene Coordinators: Community 

Relations and the Administrative Record”). It may be desirable to have an experienced CIC help 

the Team identify public information and community needs, and perform the appropriate 

outreach to the media and Congress. EPA should coordinate development of the appropriate 

public information materials—including statements to the press or interviews with the 

media—with USACE and other federal, state, and local officials. 

OSWER Directive 9230.0-97 9 
A.4. Congressional Relations 

A temporary relocation may attract congressional attention. In these cases, the Team should 

coordinate with the appropriate Regional and Headquarters representatives in all Congressional 

activities. This includes notifying the appropriate Congressional liaison in the Region before 

making any Congressional contacts concerning sites where relocation activity is involved. The 

timing of news releases and media events should be coordinated with the release of information 

to the Congressional delegation. 

A.5. Additional Support Options and Funding Tools 

Additional tools are available to OSCs and RPMs for getting temporary relocation support and for 

quickly acquiring necessary goods and services. Some of these tools are most appropriate for 

removal actions; others are useful for both removal and remedial actions. Procedures for using 

these tools are described in the “On-Scene Coordinator Toolbox Guide,” EPA Directive 9242.2-

12. For assistance, contact your Regional Contracting Officers. 

10 April 2002 
IV. DEVELOPING A RELOCATION STRATEGY 

A. Making the Relocation Decision 

There are three primary reasons why a Region may select temporary relocation as part of a 

response action: 

•	 Health threats—The contamination may pose an unacceptable threat to human health, or 

implementation of the response action may pose an unacceptable health risk to 

residents (e.g., there could be an increased chance of exposure during sampling, 

bulking, and excavation). 

•	 Safety of residents—The response action itself may pose an unacceptable risk to 

residents (e.g., use of heavy construction equipment too near a house could threaten the 

integrity of the structure or pose an attractive nuisance to children). 

•	 Efficiency of the response action—The response action can be implemented more 

quickly and at a lower cost if residents are not in the area (e.g., work hours can be 

extended to include early morning and late evening hours when residents would normally 

be at home). 

Temporary relocation should not be selected if health and safety risks or circumstances that 

pose an unreasonable inconvenience can be adequately addressed by other means without 

significantly increasing the overall cost or duration of the response action. However, on a caseby-case basis, in unusual situations, Regions may select temporary relocation when they think 

the response action creates too much of a disruption to residents (e.g., use of heavy, noisy 

equipment may keep them awake at night, they may not be able to easily access their homes 

during the response action, and they may have concerns over strong odors from the 

contaminated area). 

B. Gathering and Analyzing Resident and Household Information 

Before selecting temporary relocation, the Region should form a small Temporary Relocation 

Team to gather information necessary to implement a temporary relocation, and in cases where 

the Region has some flexibility in response options, to determine whether temporary relocation 

is viable given site specific circumstances. The Team will be led by the OSC/RPM. For 

emergency actions, the OSC may ask an EPA contractor to join the team to locate appropriate 

accommodations and provide other support as time permits. For response actions with more 

planning time, the OSC/RPM may ask USACE or an EPA contractor to join the team to 

determine if temporary housing is available. A CIC may also join the Team at this time. The 

OSCs/RPMs are encouraged to solicit support from others as early in the decision-making 

process as possible. 

The information the Team gathers should be analyzed carefully. This analysis should be done 

before an announcement is made to offer temporary relocation. Depending on site 

circumstances, this analysis can be done using information that is already available to the 

Team. However, the Team may find it necessary to gather additional information. Whenever 

OSWER Directive 9230.0-97 11 
possible, the Team member(s) who will perform the temporary relocation should be involved in 

gathering this information to begin establishing consistent relationships with the residents. 

In most instances, detailed discussions with residents about the possibility of temporary 

relocation should be avoided at this stage. If questions arise, it is better to be clear that the 

scope of the response action is still being considered. 

The analysis, which may be streamlined in emergency situations, may include the following 

information about the overall community: 

•	 An estimate of the number of households to be temporarily relocated, including 

information on owner/tenant status, family characteristics, and special considerations of 

the impacts on minorities, the elderly, large families, and residents with physical or 

mental disabilities, where applicable. 

•	 An estimate of the number of decent, safe, and sanitary temporary replacement


apartments, houses, or hotels/motels available in the area that are expected to be


available and can fulfill the needs of households being temporarily relocated.


•	 An estimate of the number, type, and size of any businesses, farms, or nonprofit 

organizations to be temporarily relocated and the approximate number of employees that 

may be affected. 

•	 The residents’ feelings and concerns about the temporary relocation and their willingness 

to allow EPA and its representatives access to their homes and property. 

From this and other information, the Team should answer the following questions: 

•	 Does the temporary relocation have a clear ending date, or would it be more appropriate 

to consider permanent relocation? 

•	 Are there alternatives to temporary relocation? 

•	 Is there enough temporary housing available (e.g., hotels, apartments, rental homes) at 

reasonable rental rates to support the housing demand? (USACE, a local real estate 

agent, or an appropriate contractor can help determine housing availability). 

•	 Are there residents with special needs (e.g., who require housing with wheelchair access 

or have a large number of pets) that cannot be accommodated by available temporary 

housing? 

•	 Will the temporary relocation cause undue stress to any residents, specifically persons 

with disabilities, the elderly, or school-age children? 

•	 How will relocated residents get to schools, work, and shopping? Is adequate public 

transportation available? 

•	 Is the community likely to resist temporary relocation? 

12 April 2002 
•	 Does the community have unique cultural needs that must be considered? 

•	 Are non-residential properties (e.g., businesses, farms, and schools) located within the 

relocation area? Temporarily relocating businesses may severely hinder their ability to 

remain economically viable. It is often impossible to relocate farms temporarily. The 

OSC/RPM may consult their OERR Regional Coordinator at Headquarters for advice. 

•	 Can any other authority, such as the state or local government, take the lead or play a 

significant role in implementing a temporary relocation? 

If the answers to any of these questions pose potential problems for a successful temporary 

relocation, and there is some flexibility in response options, the Region should carefully examine 

other options, such as a change in the planned removal or remedial action. Examples of such 

changes may include: 

•	 Altering the hours of site operations. 

•	 Limiting the use of noisy equipment at times when residents are home. 

•	 Arranging for children to attend day-time activities (e.g., day camp) to keep them away 

from heavy equipment being used at the site. 

•	 Organizing a demonstration of heavy equipment being used at the site for parents and 

creating a booklet that emphasizes the dangers associated with heavy equipment for 

children. 

•	 Increasing use of noise reduction, dust suppression, and odor control technology. 

•	 Providing air conditioners or other equipment so residents can keep windows closed. 

Once the Region makes the decision to offer temporary relocation to residents, this decision is 

documented in the Action Memorandum or ROD. In cases where the need for temporary 

relocation is not known at the time the decision document is signed, the relocation decision 

should be documented in an amendment to the action memorandum or a pollution report 

(polrep) in the case of a removal action. In the case of a remedial action, refer to “A Guide to 

Preparing Superfund Proposed Plans, Records of Decisions, and Other Remedy Selection 

Decision Documents,” EPA Directive 9200.1-23P for guidance on post ROD changes. 

OSWER Directive 9230.0-97 13 
The OSC/RPM also should notify the 

appropriate Regional Coordinator in 

OERR. OERR can provide 

assistance in determining relocation 

eligibility, as well as information on 

relocation experiences in other 

Regions. 

C. Site-Specific Relocation 

Plan 

Once a decision to offer temporary 

relocation is made, the Temporary 

Relocation Team may develop a 

site-specific temporary relocation 

plan, especially for large or complex 

projects. A relocation plan will speed 

up decision making during the 

implementation of the temporary 

relocation and clarify expectations of 

Team members’ roles and 

responsibilities. A well thought-out 

plan also will help Team members 

provide residents with accurate 

information. This plan may include 

the information gathered in the predecision analysis and can include 

the following information: 

•	 A description of how


information will be


communicated to the


residents.


•	 A description of community 

support activities, which may 

include relocation advisory 

services provided by EPA or 

other cooperating agencies 

(see Section V.A., 

“Communication is a Key to 

Success”). 

•	 The project budget, including 

estimated outlay schedules. 

•	 Time frames for completing 

tasks. 

i

i

i

l

i

i

i

i

l

i l

i i

i

resi

i

i

i i

i

i

i

ti i i

i

i

l

resi

i i

i

i l i

i i ing 

Sometimes Temporary Relocation is Not Possible 

A Superfund s te in a residential neighborhood in New Jersey 

was once the locat on of a wood treatment facility where 

railroad t es and telephone poles were sent through canals 

filled with creosote and soaked in creosote agoons. In the 

early 1960s, a developer bought the property, lightly covered 

the site with soil, and built 137 homes. In the m d-1990s, 

problems n the development came to EPA’s attention after a 

sump pump n the basement of one of the homes began pulling 

up creosote nto the basement. 

EPA acquired and demolished several of the homes that sat 

over the agoons or canals to facilitate the necessary 

excavat on work on the agoons and canals. Creosote has a 

strong smell, and EPA was concerned that odors released 

during the excavat on could be object onable to many of the 

nearby remaining residents. 

Although EPA planned to take act on to control odors, 

dents who lived next door to and across the street from the 

proposed excavat on area asked for temporary relocation 

because they were concerned about effects of the odors on 

their health. EPA and ATSDR tried to assure res dents that the 

odor would not pose a signif cant health threat, but res dents 

were not convinced. 

Before mak ng the decision to offer temporary relocation to the 

affected res dents, the Team conducted a real estate study. 

The study showed that private rentals n the area were almost 

non-existent and hotels wouldn't work because of the length of 

me needed for the relocat on. The extremely t ght housing 

market in that area had been made even t ghter by a hurricane, 

which had struck a year earlier. Even if a few rentals could have 

been found, it would have been almost imposs ble to find an 

equitable way to decide who would go and who would stay. 

The Agency decided it could not offer temporary ocation to any 

dents unless work being conducted on a property required 

shutt ng off utilities, which would make t temporarily 

uninhabitable. 

By evaluating the options before making the decision to offer 

temporary relocation, the Agency was able to determ ne that 

temporarily relocat ng a arge number of res dents from this site 

would not be successful. Prov ding res dents with conflict

information and ill thought-out plans was avoided. 

14 April 2002 
•	 Responsibilities assigned to the Temporary Relocation Team members, including state 

and local agency participants (see Attachment 3, “Key Team Functions). 

•	 Methods for notifying affected residents and receiving applications for assistance (see 

Attachment 7, “Notification Letter,” and Attachment 12, “Needs Determination”). 

•	 A method for determining fair market rental rates (FMR) for the area (see Section VII.A.2, 

“Fair Market Rent for Houses or Apartments). 

•	 The number of hotel/motel rooms needed and any special needs (e.g., adjoining rooms 

for families with children and refrigerators for baby milk and medications). If apartments 

and/or single family housing will be utilized, these requirements should be clearly 

described (see Section VII.A., “Temporary Housing”). 

•	 Kenneling, rental furniture, and special transportation arrangements. 

•	 Methods for documenting the condition of the primary residence (see Section V.D., 

“Documentation of the Primary Residence and Personal Property”). 

•	 Procedures for allowing residents access to their primary residences while in temporary 

housing. Where necessary, residents should be warned before they vacate their property 

that they may not return until the response action is completed. 

•	 Site security arrangements (see Section V.E., “Site Security”). 

•	 Procedures for contracting. 

•	 A description of how disputes will be addressed (see Section VIII.B., “Disputes”). 

•	 The expected date when residents will be able to return to their homes and a description 

of the condition of their home, yard, and neighborhood they should expect upon return 

(especially if the response work will continue after they return). Include a description of 

how residents will be notified of the termination of their assistance (see Section VIII.A., 

“Termination of Assistance”). 

Once the plan is finalized, each Team member should be given a copy for his or her reference. 

D. Temporary Relocation Notification to Residents 

Once a decision has been made to offer temporary relocation, EPA should immediately notify 

affected residents in writing where practicable. Where written notice is not practicable, EPA may 

notify residents verbally, as long as this notice is followed-up in writing with a notice letter. The 

notice letter should include the following information: 

•	 Rationale for the decision to offer temporary relocation assistance. 

•	 The government’s intention to meet with residents one-on-one to discuss their concerns 

and any unique or specific needs. 

OSWER Directive 9230.0-97 15 
•	 Start date and approximate length and end date of the temporary relocation. 

•	 Location of the suitable and decent, safe, and sanitary dwelling to be made available for 

the temporary period, if known. 

•	 Description of the relocation assistance for which residents may be eligible and the 

procedures for obtaining that assistance. 

•	 List of contacts and advisory services available to help residents file for temporary 

relocation assistance. 

•	 Notification that residents may or may not be able to gain access to their primary


residence during the temporary relocation.


•	 Reminders to residents to take important documents they may need while in temporary 

housing, such as tax and medical records, copies of leases and mortgage papers, 

school records, birth certificates, proof of a pet’s vaccinations and passports. 

•	 The terms and conditions under which residents may return to the primary residence or 

to another decent, safe, and sanitary location. 

All notifications recommended under this guidance should be personally served or sent by 

certified or registered first-class mail, return receipt requested, and documented in Agency files. 

Notices should be written in plain, understandable language and should include the name and 

telephone number of a Team member who can be contacted for further information or 

assistance. Appropriate translation and counseling should be provided to people who cannot 

read or understand the notification. The Team is encouraged to maintain a careful file system to 

keep track of various correspondences that are mailed to residents. Attachment 7 is an example 

of a notice letter. 

16 April 2002 
V. PROMOTING A SUCCESSFUL TEMPORARY RELOCATION WITH THE 

COMMUNITY 

A. Communication is a Key to Success 

Effective communication is the key to a successful temporary relocation. This communication 

can be done by the Team in two ways: through public meetings or one-on-one interviews. Public 

meetings are best for notifying residents of general plans; one-on-one interviews are best for 

discussing family-specific assistance and individual concerns. It is best if more than one, but not 

more than two or three, Team members attend both public meetings and the one-on-one 

interviews to assure that the discussions are recorded fully and accurately and to assure that 

consistent information is provided. These Team members should serve as the community’s 

primary contacts for relocation issues. 

During the first few public meetings and one-on-one interviews with residents, many Regions 

have found it best to spend more of the time listening to residents’ needs and concerns, rather 

than just presenting the types of assistance that EPA can provide. It is also important during 

these meetings for EPA to: 

•	 Inform residents about the role and responsibilities of key Team members. 

•	 Be cautious when answering questions about specific temporary relocation assistance 

without a complete understanding of each resident’s unique needs. 

• 

i i

• i i

i i

ignifi

l i ion. 

• i i

• i i

i ing. 

• i /

i indivi

Communication is a two-way street. EPA staff and community members need to get to know 

each other. To help make this happen, consider doing the following: 

Introduce key members of the Temporary Relocation Team—including contractors or other 

agencies’ relocat on specialists—at the f rst public meeting to help residents become familiar with 

them. 

In addit on to holding group meetings w th community members and attending community 

meetings, meet separately with each household that is a candidate for temporary relocation to 

identify specific relocat on needs and to explain the ass stance available and the procedures for 

obtaining it. Uncertainty about the availability of financial support can s cantly increase stress 

and can ead to unnecessary res stance to the relocat

Communicat on techniques that work well in one community may not be effective n others. Avoid 

a cookie cutter approach. 

Conduct public availability sess ons, especially at key milestones in the process, so res dents 

can ask quest ons in a one-on-one sett

Responsibility for the site rests w th the OSC RPM; therefore she or he is strongly encouraged to 

meet the affected res dents and be aware of their dual needs and concerns. 

OSWER Directive 9230.0-97 17 
•	 Avoid suggesting that specific assistance can be provided unless it is clear that the 

residents will qualify. 

Team members should never discuss residents’ personal circumstances during public 

meetings or with other residents. These discussions should be handled during one-on-one 

interviews. Residents may have someone from outside their household participate in these 

meetings. This may be especially important for senior citizens who feel more comfortable when 

a son or daughter is at their side. 

B. Dealing with Stress and Disruption 

Temporary relocation is a stressful experience and a major disruption to people’s lives for many 

reasons: 

•	 People have to leave their homes, gardens,


neighbors, and neighborhoods.


•	 Residents may have a different and possibly


longer commute to work.


•	 Children may need to be driven to school or


bus service may need to be provided.


•	 The stores people are used to shopping in


may no longer be convenient. This can be


particularly difficult for the elderly.


. 

ici i

i

i

Reaching residents living in a large 

geographic area can be very challenging

At a pest de-contaminated s te in Ohio, 

Region 5 rented a van and equipped it to serve 

as a mobile community resource center. The 

van carried all the necessary forms and 

guidance that res dents might need. 

This approach might be helpful at other s tes 

to increase community access to important 

information. 

•	 The temporary homes may not be able to accommodate pets. 

•	 Residents may harbor fears about potential exposure to the contamination. 

•	 Once the cleanup is over, people will have to move back and try to re-establish their old 

connections and routines. 

By the time a temporary relocation decision has been made, residents often have been dealing 

with a variety of site-related concerns for a considerable period of time, including their families’ 

health, loss of their property values, and possible responsibility for damages. These concerns 

may come on top of personal difficulties people may be facing: 

•	 Couples may be having marital difficulties. 

•	 Families may be trying to cope with a member’s drug or alcohol addiction. 

•	 A family member may be experiencing mental or physical health problems. 

•	 An elderly resident may be physically incapacitated. 

•	 Residents may be experiencing financial hardships. 

18 April 2002 
It is important to recognize that dealing with these 

difficulties may leave residents with relatively little 

capacity to deal with the additional stress of the 

relocation. Indeed, for some, the stress of the 

relocation may be the last straw. 

When people’s resources are stretched beyond their 

capacity, they may react unpredictably. EPA and 

other agency staff or contractors may become the 

target of residents’ reactions even though they may 

not be the cause of the problem. Residents may 

become hostile in meetings, have difficulty 

understanding the explanations offered, be unable to 

make decisions in a timely manner, and become 

very anxious or depressed. It is important for the 

Team to remember that these negative reactions 

may not be targeted directly at them. Patience and 

compassion are helpful tools in these situations. 

Holding regular group meetings or open houses 

where residents can vent their frustrations can help to relieve the tension. It may be helpful to 

develop a reference guide for each resident that includes a list of social service providers in the 

community. 

resi ing 

l

i

ti

i i

l

i

i

Helping Residents is More About Listening to 

Them Rather Than Telling Them What You 

Can Do 

Region 1 successfully addressed an elderly 

dent’s reluctance to be relocated by tak

the time to listen to her carefully. Baff ed by her 

reluctance, Team members met w th her several 

mes and eventually understood that she would 

feel more safe and comfortable stay ng w th her 

daughter in another state than in temporary 

housing. Once her feelings were c ear, a round 

trip airline ticket was purchased for her. 

Arranging for this resident to stay w th her 

daughter reduced her concerns over the 

temporary relocation and eliminated the need for 

EPA to f nd a temporary residence near the site. 

OSWER Directive 9230.0-97 19 
• i i

• 

i i

• i

i

i

• i

i

• if 

resi i l

• i

i

resi

• i i

j

• i i i

i l i

• i i

i i

i

• i

ion. 

• i i l i i

l

• 

• l l iviti

• i i i

i

It is important to be consistent when communicating with the public. To ensure this: 

Limit the number of people who are responsible for contact ng res dents; the greater the number of 

people, the more likely that inconsistencies will creep into messages. 

All members of the Team should have the same information as that provided to the community. For 

example, if res dents will not be perm tted to return to their homes during the temporary relocation, 

they should be told this before they move. 

Community support staff should be n place at the time of the notification and application procedures 

so they can ass st in obtaining information about each household and its housing needs. This will 

help EPA to match each household’s needs w th the appropriate temporary housing. 

Community support personnel should be available regularly to answer quest ons and provide support. 

Availability may be necessary during evenings and weekends when res dents are home from work or 

school. 

To ensure that language barriers do not cause misunderstandings, have translators available 

dents speak a different f rst anguage. Remember to provide translated written documents. 

Residents who are living n relocation housing should be given the names and phone numbers of 

EPA contacts, and staff should develop procedures for stay ng in contact with these relocated 

dents. 

Remember that communicat ons do not stop once the res dents are occupying temporary housing; 

they only ust begin. 

Here are some possible ways to explain the temporary relocation process and assistance 

available to residents: 

Prov de a site-specific relocat on booklet that explains the kinds of ass stance available and the 

logistics of the relocat on in an easy-to-understand sty e. A template for this booklet s available from 

your OERR Regional Coordinator. 

Hold a series of public availability sess ons that provide opportunit es for residents to get information 

about the cleanup, followed by one-on-one indiv dual meetings w th each household to allow time for 

personal quest ons. 

For large relocations, set up a toll-free number and/or a Web page w th information about the cleanup and relocat

Place a bullet n board n a central ocation and post nformat on on the status of the response action. 

Inc ude the names and phone numbers of key contacts. 

Give each household a binder for relocation documents and information. 

Be sure to explain c early the proposed c ean-up act es and how and when the decision will be 

made to return the residents to their homes. 

Clearly describe the s te condit ons res dents should expect to find when they return to their homes, 

especially if addit onal work on their property or in their neighborhood needs to be done. 

20 April 2002 
C. Anticipate the Residents’ Needs 

It is important to recognize that temporary relocation disrupts people’s lives. Therefore, the 

Team should make every effort to minimize these difficulties and inconveniences, especially if 

the relocation is going to last more than a couple of weeks. Besides resolving their relocation 

issues, other efforts that might ease residents concerns include: 

•	 Helping residents file “Change of Address” forms with their Post Office so their mail will 

be forwarded to their temporary address during the relocation. 

•	 Helping residents find acceptable accommodations for their pets. (Try to avoid temporary 

accommodations that require pets be kenneled for many weeks). 

•	 Working with local social service agencies to ensure that any relocation assistance 

provided to residents is exempt from income considerations for food stamp, Medicaid, 

and Head Start programs. 

•	 Helping residents connect with local organizations that can provide additional assistance, 

such as the American Red Cross, the Veterans’ Administration, local churches, United 

Way organizations, and other nonprofit organizations. 

The OSC/RPM or ORC also may work with landlords to minimize or prevent the increase of 

rents after the temporary relocation due to unavoidable improvements made to the rental 

property during the clean up (contact your Region’s OERR Regional Coordinator at 

Headquarters for additional information). 

Finally, it takes time to build a good working relationship with residents. Early and meaningful 

community involvement is one way to get off to a good start. This will set the tone for future 

relationships with residents and send a clear message to them that they have a role to play in 

decisions that affect them. Another way to build trust with residents is to avoid making promises 

that cannot be kept. Finally, remember that effective community involvement does not mean 

pleasing everyone all of the time. It may be necessary to “agree to disagree” with residents from 

time to time. 

D. Documentation of the Primary Residence and Personal Property 

While the primary goal of any response action is to mitigate the hazards at the site, it is also 

important to document the condition of personal and real property at the primary residence to 

prevent or settle disputes, protect everyone involved, and potentially increase residents’ 

satisfaction with the results. The documentation needed depends on the nature and complexity 

of the response action and the temporary relocation. 

Documenting the conditions of property at residential or commercial locations serves the 

following purposes: 

• Provides a record of any pre-existing damage. 

• Documents the existence and condition of items that will be disposed of or destroyed during 

the cleanup. 

OSWER Directive 9230.0-97 21 
• Allows for more efficient restoration. 

• Provides evidence in case of a dispute. 

• Provides a record of any valuables that residents elect to leave behind. 

Documentation of any pre-existing damage will allow EPA to determine any responsibility for the 

cost of repairs. It also can be used in discussions with property owners to settle damage claims. 

Videos and photographs can be very effective documentation, especially when they are 

accompanied by a survey of the land contours and drainage. 

The following features should be documented in videos or photographs: 

• Foundations of buildings • Wet or barren areas 

• Sidewalks and driveways • Furniture, appliances, and electronic 

• Trees, shrubs, gardens, and other equipment


landscaping features • Interior walls, wood work, carpets and


• Sprinkler systems and drainage pipes other flooring 

• Pots, ornaments, and other detached • Visible cracks in the walls, or inside or 

fixtures outside the structure 

• Patio furniture and playground • Window air conditioning units and


equipment central heating/cooling units


• Fences and gates • Dog houses 

• Lights • Any other significant conditions or


damage
 • Exposed piping and plumbing 

It also is advisable to check electrical outlets, water spigots, and natural gas connections to 

ensure that they are in working condition. This information also can be recorded with video and 

photographs. 

When videotaping, move the camera slowly to cover the entire area. As you film, talk into the 

camera’s microphone to provide a detailed description of what you are filming. Whenever 

possible, ask the residents to participate in the video/audio recording. Describe the location of 

the camera and the direction from which the picture is being taken. This information also can be 

recorded in a logbook, and a map showing the general layout of the yard and the location of the 

camera can be included. 

All appliances and electronic equipment in the homes should be checked to see if they are 

running properly during the documentation phase. Regions should consider videotaping the 

interiors of each home even if the cleanup may not require working inside the homes. This will 

help protect EPA and residents against future damage claims. The videotape footage of each 

residence should be accompanied by a catalog of the items videotaped, which could include the 

model numbers of electrical equipment, sales receipts, and other important information. Items 

22 April 2002 
can be grouped together when videotaping or photographing them, but all items to be appraised 

should be fully visible, and their condition should be apparent in the videotapes or photographs. 

When EPA assumes responsibility for reimbursing residents for items that will be disposed of or 

destroyed during the site cleanup, it is particularly important to gather sufficient documentation to 

allow for the proper appraisal of their value. Where interiors of buildings will be involved in the 

cleanup, appraisers may not be allowed to enter because of contamination. Thus, videos/photos 

of the interior and its contents can be useful tools for the appraiser. 

For unique items, it is important that a value be established by an independent appraiser. 

Historically, EPA has used the services of local appraisers, as well as appraisers made 

available by the USACE. The type of appraisal expertise necessary may depend on the cost and 

uniqueness of the item being appraised. Once an independent appraiser establishes an 

appraised value, the Region should not make adjustments to the value without cause. For 

example, a resident may disagree with the appraised value and provide substantive support for 

their position. The Region then could agree to adjust the appraised value. The Team also can 

provide for the full replacement value of certain essential items (see Attachment 8 for a list of 

essential furniture items). 

In addition to the videotape and photographs, documentation can include actual samples of the 

material that was removed. Small squares of carpet, wallpaper, cabinets, floor tile, and molding 

can be stored in sealed plastic bags to show their quality or color (videos and photographs do 

not always show the correct color or texture). Bags should be labeled to identify the sample, 

which residence it came from, and where in the residence it came from. These samples and the 

photo-documentation should be made available to the restoration contractor. It can be helpful to 

have a combination TV/VCR available at the residence so contractors can view the videos as 

the restoration progresses. 

View the entire videotape and have photographs developed to make sure the images are clear 

and captured the necessary details before work begins. A sample form that can be used for 

recording this information can be found in Attachment 9, “Personal Property Appraisal Record.” 

E. Site Security 

Some residents may be reluctant to move temporarily if they fear that their property (both real 

and personal) may be vulnerable to vandals, fire, or other damage. The Team should describe to 

residents the security that will be provided at the site, and remind residents whenever 

practicable to take valuables—including those of sentimental value—with them when they move. 

Residents also should be reminded that they are responsible for maintaining existing insurance 

at their primary residence. 

Providing site security can help residents build their confidence in EPA and ease their reluctance 

to move. OSCs and RPMs should make a site-specific decision regarding the type of security 

that will be provided and acknowledge that not all sites need the same level of security. 

OSC/RPMs should evaluate the following factors when making decisions about site security: 

OSWER Directive 9230.0-97 23 
•	 Insurance companies may cancel an existing policy or raise the policy rates if a building 

is expected to be unoccupied for a lengthy period of time. The amount of the increase in 

insurance rates may be a reimbursable out-of-pocket expense. 

•	 Residents may have particularly valuable or meaningful personal property that can be 

placed in a safety deposit box rather than being left behind at the primary residence or 

moved to the temporary residence. A reasonable fee for a safety deposit box may be 

considered a reimbursable out-of-pocket expense. 

•	 Media attention that mentions relocation may spark the interest of burglars, especially 

when large blocks of unoccupied homes are involved. 

•	 Residents may feel that their homes and personal property are irreplaceable. 

•	 Residents, especially tenants, may not have insurance. 

•	 Residents may want to return to their homes during the response action to check for 

problems if the area is not secured. In some cases, it may be difficult or impossible to 

allow residents to return to their homes. 

Site security may include: 

•	 Installing alarms in unoccupied homes. 

•	 Working with the local police to arrange for increased patrol in the area. 

•	 Arranging for a security guard or police officer to be on-site whenever there are no 

response personnel working at the site. 

24 April 2002 
VI. DETERMINING ELIGIBILITY FOR RELOCATION ASSISTANCE 

Eligibility for relocation assistance is limited to people who live in the affected residence on the 

date residents are notified that EPA will offer temporary relocation assistance. Because the 

amount of assistance is based on the number of people in each household who will live in the 

temporary housing, the Team should carefully document and verify the number of occupants in 

each residence. To do this, the Team can use information obtained through conversations with 

residents. Proof of residence can be shown by: 

•	 Driver’s licenses. 

•	 Current lease or rental agreements. 

•	 Deed of trust or sales contract for the home purchase. 

•	 The first page of tax returns. 

•	 Copies of the previous three months’ checks (front and back) or money order payment 

stubs to show payment of rent or mortgage. 

•	 Proof of public assistance. 

At a minimum, the Team should obtain a driver’s 

license or a social security number for all adult 

residents who will be receiving relocation assistance. 

The Team must be notified of any changes in the 

number of residents (e.g., the birth of a child) that 

may occur after the assistance determination has 

been made. This information must be included in the 

family’s file. Attachment 11 provides a list of 

additional information/documents that residents may 

need to provide the Team when applying for 

assistance. 

Residents may need to sign several forms to 

document their eligibility for assistance, their 

understanding of the scope of the assistance 

provided, the procedures for receiving assistance, 

and when assistance will be terminated. Attachment 

12, “Application for Superfund Temporary Relocation 

Assistance—Needs Determination” is a form that 

can be used to document this information. 

Attachment 13A, “Meals and Incidentals Computation Sheet” and Attachment 13B, “Rental 

Assistance Computation Sheet”, can be used to compute the amount of temporary relocation 

assistance needed. The Team’s ORC member should review the forms before giving them to 

residents. 

i

i

i

i i

i isi

i

i

isi

i

resi

i

l 

Early Documentation is Critical 

It is critical that the Team document the number 

of family members living n each house, as soon 

as the temporary relocation s announced. 

One Remedial Project Manager had f rst hand 

experience with the importance of documenting 

the number of res dents living n a house as 

soon as poss ble. On his first v t to a home, 

he found a single family w th three children 

living n a home with very sparse furnishings. 

On a subsequent v t, after EPA announced 

its ntention to temporarily relocate the 

dents and acquire their contaminated 

contents, he found that the residence was well 

furnished and occupied by two families, w th a 

tota of six children. 

OSWER Directive 9230.0-97 25 
VII. TYPES OF ASSISTANCE AVAILABLE 

People who are temporarily relocated as part of a CERCLA response action are eligible for 

reimbursement of reasonable out-of-pocket expenses incurred in connection with the 

temporary relocation. This includes the cost of moving to and from the temporary housing and 

the monthly rent and utility costs at the temporary housing. Applicants are eligible only for 

reimbursement when expenses are actually incurred. EPA should not reimburse residents for 

temporary relocation expenses incurred before the Agency initiates the temporary relocation or 

for expenses that were not initially approved by EPA. Some Regions have worked with residents 

to determine what relocation or damaged personal property costs can be covered by the 

resident’s homeowner’s or renter’s insurance. If insurance coverage is available, the Team may 

first ask the residents to seek reimbursement from their insurance company. In some cases, 

EPA may reimburse residents who agree to assign their insurance coverage to the Agency. 

(Attachment 14 an example of this kind of agreement, and Attachment 15 is a sample claim 

letter to an insurance company.) 

Residents are not eligible for temporary relocation payments if they receive a payment under 

federal, state, or local law that ORC/OGC determines is for the same purpose as payment 

provided under this guidance. EPA will not provide financial assistance to residents if they 

receive reimbursement for the same purpose from their insurance company or from a nonprofit 

organization. 

EPA will not be responsible for damages to personal property transported to a temporary 

residence by the resident, for damages or losses caused by theft from the temporary residence, 

or for damages at the temporary residence that are determined to be the resident’s 

responsibility. Residents should be encouraged to check their own homeowners’ or renters’ 

policies and arrange for any additional coverage that may be needed. 

Homeowners and renters are responsible for paying their mortgages, including taxes and 

insurance, or rent for their primary residences, even though they will not be living in them. This 

should be explained to residents, and they should be asked to sign a statement indicating that 

they have been informed that these payments remain their responsibility and that they 

understand that their temporary relocation assistance may be reduced or terminated if they fail 

to continue paying their mortgage or rent (Attachment 10 is an example of this kind of 

agreement). In addition, if a tenant terminates the lease on the residence from which he or she 

was relocated, or if a homeowner sells his/her primary residence, the relocation assistance 

should be terminated The rest of this section covers the various types of expenses covered 

under temporary relocation assistance. 

A. Temporary Housing 

Temporary housing can include transient accommodations (hotels or motels without cooking 

facilities), locally available private rentals (houses, apartments, or mobile homes), or 

accommodations provided by family or friends. Eligible expenses associated with temporary 

housing may include: 

• Rent. 

• Credit-check fees required by landlords of temporary housing. 

26 April 2002 
• Broker fees if a realtor is used to identify available housing. 

•	 Maintenance fees required by landlords of 

temporary housing. 

•	 Security deposits. 

•	 Kennel/pasturing fees and any vaccinations 

required by kennels. 

•	 Moving/storage fees. 

•	 Connection and disconnection fees for 

utilities, cable TV, and basic telephone 

service. 

i

i

i

Expect the Unexpected; Allow Time for 

Planning 

While conduct ng an emergency response to the 

threat posed by a stockpile of weapons, ncluding 

explosives and chemicals, Region 9 temporarily 

relocated a tenant and her 22 pets. The pets 

ranged from cats to horses and had many special 

care needs. Because no suitable housing was 

available that would accommodate all of the pets, 

some of them had to be boarded. Before the 

relocat on could be completed, the arrangements 

required extended planning and coordination. 

•	 Furniture rental. 

For short-term relocations lasting a few days to weeks, transient accommodations (hotels or 

motels without cooking facilities) may be most appropriate, but whenever possible, stays in 

transient accommodations should be limited to no more than a few weeks. For long-term 

relocations lasting more than a few weeks, private rentals may be more cost-effective and 

comfortable for residents. Depending on the circumstances, it may be necessary to place 

people temporarily in hotels or motels until more appropriate housing becomes available. 

ci i

i i

chil l l 

iviti

l l 

l

i

i i

Anticipate Problems, Find Creative Solutions 

Keeping small children occupied can be 

challenging for parents even under the best of 

rcumstances. Parents may f nd this even more 

diff cult while staying n hotels or motels for 

several weeks. One EPA Region arranged for 

dren who were re ocated for severa weeks to 

a motel to attend day camp and other day-time 

act es. These day-time activities kept the 

children active and reduced complaints from the 

mote management and other mote guests. The 

Region avoided damaging its relationship with the 

hotel management, which may have ed to the 

evict on of some of the residents. The cost of the 

day-time activities was less than the potential 

cost of mov ng the residents a second t me. 

To the extent possible—given time constraints and 

availability of temporary housing—the Team should 

try to find temporary housing that is: functionally 

equivalent to the resident’s primary residence; close 

to the resident’s work, schools, and shopping 

facilities; and accessible to public transportation, if 

needed [see 49 CFR Section 24.2(d)(2)]. At a 

minimum, the Team should be sensitive to the 

number, age, and sex of each family member when 

making sleeping room arrangements. For example, 

in hotels and motels, children under the age of 18 

should be in the same room or in connecting rooms 

with a responsible adult. Additionally, girls and boys 

may need to have separate sleeping rooms. Further 

difficulties may arise when hotels do not have the 

appropriate number of connecting rooms. 

For long-term temporary relocations, residents 

should be encouraged to help identify their own 

temporary relocation housing after being informed by the Team about the types of housing and 

the amount of rent that would be eligible for reimbursement. Local real estate sales offices are 

often good sources of information on available temporary housing and can help EPA and 

OSWER Directive 9230.0-97 27 
residents find housing in a limited market. While residents may help identify their own temporary 

housing, it is EPA’s responsibility to ensure that they are provided appropriate housing. 

Regardless of who identifies the temporary residence, the Agency or its designated agent should 

inspect the housing to determine that it is decent, safe, and sanitary before the move is 

scheduled. 

If it is necessary to enter into a lease for apartments or houses, the Team has two options: 1) 

the residents can sign the lease; or 2) EPA or its representative can sign the lease (see footnote 

below for further information).1 Whenever possible, the residents should sign the lease. This 

helps make it clear to the residents that they are liable for any damage made by themselves or 

their guests to the rental property. When residents sign leases, landlords should be notified that 

EPA or the PRP will reimburse the residents for the rent. In some cases, the Team may arrange 

with the landlord to bill EPA, USACE, or the PRP as appropriate. If that is not possible and the 

resident cannot wait for reimbursement of rent, or a landlord will not rent to a tenant with poor 

credit, or if the Team determines that it is more cost effective, the Team can arrange to issue 

the rent check in both the resident’s and landlord’s name. Generally, residents moved to hotels 

or motels should sign the agreement with the hotel or motel and agree to comply with their rules 

(see Attachment 16, Example of Hotel Rules). 

A.1. Cost of Transient Accommodations 

The government bases allowable costs for 

temporary housing in transient accommodations 

(hotels or motels without cooking facilities) on the 

federal per diem rates that are paid to 

government employees on official travel in the 

community. The government rate for lodging 

should be considered a maximum amount the 

Agency will reimburse for transient housing. In 

the rare case when the only available transient 

accommodations are priced higher than the 

government rate, the Region may approve an 

amount that is up to 150% of the maximum 

government rate for the area where the 

temporary relocation is taking place. The reason 

for such a decision should be well documented 

and should include information on the availability of similar temporary housing in the program or 

project area and the person’s circumstances (e.g., access to school transportation). If an 

OSC/RPM determines that there is little, if any, appropriate temporary housing available to 

affected residents within an entire project area and more expensive temporary housing is 

needed for the area as a whole, it may be appropriate to consider whether waiting for less 

expensive temporary housing to become available would justify a delay of the project. 

1 Since entering into a lease is a form of acquiring an interest in real property, the Regions do not have 

the authority to sign a lease. If a Region or its representative needs to sign a lease, the Region must contact an 

OERR Regional Coordinator to get Headquarter's approval. This includes getting concurrence from OGC and 

having the lease signed by the Director of the Facilities Management Services Division (FMSD). If the estimated 

amount of the lease is greater than $25,000, the Region also needs to get approval from the Assistant 

Administrator (AA) of OSWER or his/her delegated representative. 

April 2002 

i i

i

ivi

resi

i ivi

Residents Engaging in Illegal Activity 

Whenever poss ble, res dents should sign 

hotel/motel and rental agreements themselves. By 

doing so, they agree to comply w th the rules of the 

landlord. In one case, a hotel evicted a temporarily 

relocated resident due to allegations of drug act ty 

on hotel property. Since the hotel evicted the 

dent, EPA was not in the position of denying 

ass stance based on alleged criminal act ty. The 

evicted resident was responsible for finding a new 

hotel and paying his own moving costs. EPA 

continued to reimburse the resident for his lodging 

and daily allotment. 

28 
A.2. Fair Market Rent for Houses or Apartments 

When residents temporarily relocate to apartments or houses, the allowable cost for temporary 

housing is based on the rent charged for a similar apartment or house. In some communities, 

temporary housing may be limited. The Team should make sure the temporary housing offered 

is decent, safe, and sanitary as described in Attachment 2, and, at a minimum, has the 

necessary number of bedrooms to accommodate the residents. The rent should be reasonable 

for the size and type of residence in the local area. This may be determined by averaging the 

cost of available residences per bedroom size for each locality where temporary housing will be 

provided. A fair market rent (FMR) for an area will depend on supply, demand, and types of 

available housing resources. Determining the FMR is appropriate to ensure cost-effectiveness 

and to discourage inflation of rents in the affected area. Assistance in determining FMR may be 

available from local real estate agencies or USACE relocation support experts. 

While FMR guidelines reflect the desired maximum reimbursement, it also is likely that housing 

can be obtained at lower prices. The use of housing that is priced higher than provided in the 

FMR guidelines may be authorized for full reimbursement only when other existing resources 

are not available. When fewer than 10 families are being relocated, FMR guidelines may be 

established using a less time-consuming means. Acceptable methods include using an 

estimate provided by real estate agencies or conducting a sampling instead of a comprehensive 

survey. A copy of the established guidelines should be placed in each applicant’s file. 

A.3. Lodging Provided by Friends or Family 

Occasionally residents prefer to find temporary accommodations with friends or family. EPA 

cannot require that they do so and must offer these residents the same option as offered to 

other residents. Residents who choose to stay with friends or family should not receive 

reimbursement for lodging unless the host actually incurs additional costs in accommodating the 

resident. In such instances, the additional costs must be well documented and determined to be 

reasonable by EPA. Only additional costs may be compensated. Neither costs based on room 

rates for comparable conventional lodging in the area nor flat “token” amounts will be considered 

as reasonable (Regions should refer to the Federal Travel Regulations for additional advice). 

However, they may qualify to receive reimbursement for meals and incidentals depending on the 

type of temporary housing they were offered by EPA. 

Residents who are offered the option of temporarily relocating to hotels or motels without 

cooking facilities and elect to stay with friends or family are eligible to be reimbursed for meals 

and incidentals similar to government employees on official travel. Even though cooking facilities 

may be available at the home of their friend or family member, the resident should have the 

option of eating out as if they were if staying in a hotel or motel in order to reduce the impact on 

the family or friend. In this case, the cost to EPA for meals and incidentals would be the same, 

regardless of the choice the resident makes. 

Residents who are offered the option of relocating to an apartment or house with cooking 

facilities and elect to stay with family or friends should not be reimbursed for meals and 

incidentals unless clear documentation is provided to show the option to be more cost effective 

as compared to relocating to an apartment or house offered by EPA. 

OSWER Directive 9230.0-97 29 
Residents who elect to stay with family or friends, and find it necessary to move, should be given 

the option to move to the same type of temporary housing as originally offered by EPA if they find 

it necessary. 

B. Furniture Rental/Moving Costs 

B.1. Furniture Rental 

Whenever possible, residents should be encouraged to take with them any personal items they 

will need while away from their homes. In some cases, however, personal possessions may be 

contaminated and will have to be left behind. 

If residents are being placed in short-term transient housing, furniture will not be needed. For 

short-term temporary relocations to apartments or rental houses, it may be less expensive to 

rent furniture or to rent a furnished apartment, rather than to reimburse the costs associated with 

moving furniture from and back to the primary residence. For longer-term temporary relocations 

in apartments or rental houses, the Team should determine the most cost-effective and least 

burdensome way of providing furnishings. For longer-term temporary relocations, it may be 

more cost-effective to move residents’ furniture into their temporary housing. Sometimes, this 

will require the decontamination of the furniture (if possible) at the primary residence before it is 

moved. In some cases, furniture may be placed into storage while work is being done at the 

permanent residence. 

If the Team decides that rental furniture is the most cost-effective way of meeting residents’ 

needs, a furniture rental assistance payment or rental of a furnished apartment may be 

authorized. Rental furniture is provided on a loan basis for the duration of the temporary 

relocation. Keep in mind the following guidelines when considering the provision of rental 

furniture: 

•	 Rental furniture items are to be provided in accordance with family size and needs (See 

Attachment 8 for a list of essential furniture items for temporary housing). 

•	 Generally, residents should sign the rental agreement with the furniture store and receive 

reimbursement for the rental fees. In some circumstances, the Team may determine 

that it is more cost-effective or otherwise appropriate to pay the furniture rental store 

directly. 

•	 The furniture items provided should be of average construction and quality; EPA will not 

reimburse residents for luxury items. 

•	 Residents should be informed in writing (and asked to sign a receipt for this information) 

that they are responsible for any damages—other than normal wear and tear—done to 

the rental items. (See Attachment 10, “U.S. EPA Temporary Relocation Agreement”). 

•	 If possible, residents should be allowed to pick out their rental furniture based on a limited 

selection of essential furniture approved as eligible for reimbursement. This may make 

them more comfortable in their new living arrangement and help to reduce any additional 

stress caused by the relocation. 

•	 The Team should reimburse a reasonable rental fee for each item or approve a total fixed 

amount for all essential items. 

30 April 2002 
• The Team should make sure that the rental furniture is ordered and delivered before 

residents must move into their temporary housing. 

B.2. Moving Costs 

There are several options for moving personal items to and from temporary residences: 

•	 An EPA-arranged Move—Under this option, EPA’s contractors or the USACE (if USACE 

is providing relocation support) take responsibility for all aspects of moving the resident’s 

personal property to and from the temporary residence, including packing personal 

possessions. In this situation, residents incur no costs and receive no compensation. 

EPA’s contractors or USACE will obtain bids from several moving companies and select 

a company, taking costs, reliability, and other factors into consideration. It is important to 

be sure that the selected moving company is insured and, if necessary, bonded, 

especially when moving expensive or unusual items. Some moving companies have 

limited coverage for replacement of lost or damaged property. The Team should review 

the coverage carefully and be sure that the coverage is for the replacement value of the 

property. It also is important to note that most movers will not insure items they do not 

pack themselves. Thus, residents who choose to pack their own possessions may be 

responsible for any damage done as a result of the move and they should be informed of 

this in writing. 

•	 EPA and Resident Share Move—Residents may choose to pack their own property and 

have EPA move the property to and from the temporary address. EPA can provide the 

residents with packing materials and pre-printed packing labels at no cost to the 

residents, or the residents can purchase their own packing materials. If they purchase 

their own materials, they can be reimbursed for their expenses, as determined by EPA to 

be reasonable and necessary (49 CFR 24.301). In this case, EPA’s contractors or 

USACE (if USACE is providing relocation support) may be responsible only for damage 

that occurs during the actual transportation of the property, not for damage associated 

with inadequate packing. If residents decide to pack their own possessions, they should 

sign waivers acknowledging that they understand their responsibility if damage occurs. 

•	 Resident-arranged Move—Residents may choose to move their own property to or from 

the temporary residence or to hire a mover on their own. In this case, EPA will reimburse 

them for reasonable actual moving expenses. Residents should obtain three bids from 

legitimate (as determined by EPA) moving companies and select the best bidder based 

on consideration of cost and reliability. Under this option, EPA is not responsible for any 

damage suffered by the property or for any performance failures on the part of the 

moving company. Therefore, residents should be encouraged to ensure that their mover 

provides adequate insurance (e.g., replacement value of the property) to cover loss or 

damage to personal property. Residents should be made aware that insurance coverage 

varies among moving companies and may be an optional expense that would be 

reimbursed. 

•	 Fixed Payment for Moving Expenses—Residents may be offered a fixed payment rather 

than reimbursement for the actual moving expenses incurred when moving personal 

property to and from the temporary residence. A payment schedule, organized by state 

OSWER Directive 9230.0-97 31 
and number of rooms at the primary residence, is provided by the Federal Highway 

Administration (49 CFR Part 24.302) and provides guidance for determining an 

appropriate fixed rate. 

When time and resources permit, residents should be allowed to select the option that is best 

for them. If that is not possible, however, the Team should select the option that is the most 

cost-effective for the Agency and least burdensome for residents. Attachment 17 includes 

general packing instructions for residents. At the time this decision is made, it is important to 

document the condition of the residents’ personal property that will be moved and that will 

remain in the residence (see Section V.D., “Documentation of the Primary Residence and 

Personal Property”). 

Residents who request a transfer to another temporary residence solely for their own 

convenience or for reasons brought about by their behavior may be responsible for all expenses 

associated with the move, including any increase in rent. If, however, EPA initiates a second 

relocation or if the second relocation is necessary for reasons not the fault of the resident, all 

essential moving costs should be reimbursed, and the move should be accomplished with as 

little inconvenience to the residents as possible. 

C. Utilities 

Residents should be compensated for additional out-of-pocket expenses associated with 

utilities. The Team should consider several factors in determining which utilities EPA will pay. 

Those factors include the anticipated duration of the temporary relocation, the utilities EPA may 

actually use while implementing the response action, the rental agreement at the temporary 

address (some rental costs includes utilities) and other factors discussed below. In general, as 

with other expenses, residents should pay all utility expenses and seek reimbursement where 

appropriate. 

C.1. Primary Residence 

In general, residents are responsible for continuing to pay for the utilities at the primary 

residence. Generally, the major utilities (e.g., trash collection, water, electricity, gas) should be 

continued throughout the response action. If the relocation is for a short period of time (e.g., a 

few days to a few weeks), it also is cost-effective to leave telephones, cable television, and other 

utilities connected. If the relocation will last more than a few weeks, the Team may decide that it 

is more cost-effective for the government to pay for the disconnection and reconnection of some 

utilities, even if the utility companies will not waive these fees. EPA should be cautious, however, 

about disconnecting electricity, gas, and water utilities, because these may be necessary to 

protect the property. In some cases, heat may be necessary to keep pipes from freezing and 

dehumidifiers may be necessary to prevent damage from molds and mildew. If utilities are 

disconnected for any reason, residents should be reminded to move refrigerated/frozen foods to 

their temporary residence. If this is not possible, residents may be compensated for their losses. 

In some cases, the Team may need to use the utilities to implement the response action for a 

limited period of time. In this situation, EPA is responsible for paying the cost of the utilities and 

should carefully document the time period (meter readings) for which the utilities are used for the 

response action. The Team should consider meeting with each resident and discussing 

expectations regarding utilities. Documenting this in writing may help clarify expectations. 

32 April 2002 
C.2. Temporary Residence 

The Team may authorize reimbursement of costs for essential utilities at the temporary 

residence when they are not covered in the rent. Reimbursement for essential utilities can 

include gas, electricity, oil, water, and sewer. The Temporary Relocation Team also can 

approve reimbursing the resident for costs associated with the connection of cable TV if the 

residents had cable TV at their primary residence or if it is needed for television reception. 

There are three types of costs associated with telephone service: disconnection/reconnection 

fees, monthly local service fees, and long-distance service fees. EPA will reimburse the 

telephone disconnection/reconnection fees at both the primary and temporary residences, but 

only will reimburse for monthly local telephone service at the temporary residence if the service 

has not been disconnected at the primary residence (the cost for local telephone service at the 

temporary residence is considered an out-of-pocket expense associated with the relocation). 

The Team may negotiate with the hotel to waive these charges. The reimbursement is limited to 

the same type of service that the resident has at the primary residence. EPA generally will not 

reimburse for long-distance service or collect calls. Reimbursement of long distance or collect 

calls must be approved by the Team in advance of incurring the cost. These calls are eligible for 

reimbursement only if the expense can be clearly documented as an out-of-pocket expense. An 

example of an allowable reimbursable long-distance phone call would be a local call that was 

routinely made or received prior to the relocation that becomes a long-distance call since the 

relocation. Given the high charges hotels and motels impose for placing phone calls, it may be 

worthwhile to encourage people to purchase calling cards to make their long distance calls. 

Residents are responsible for any damages to the temporary housing or rental furniture caused 

by them or their guests. Residents should be informed of this and asked to sign an agreement 

indicating that they have been informed of their responsibilities, (see Attachment 10 for an 

example of this agreement). OSCs/RPMs have found it helpful to withhold a portion of residents’ 

final reimbursements until these types of outstanding debts are paid. 

D. Daily Allotments for Food, Incidentals, and Laundry 

Residents relocated to hotels or motels that do not have cooking facilities should be reimbursed 

for their reasonable out-of-pocket expenses just as government employees are when on official 

travel. Compensation for food and incidentals should be based on the appropriate government 

employee per diem rate for the geographic area. Adults and children should be covered at 

different rates. Residents who are 12 years and older should receive the full per diem rate and 

children under age 12 should receive half that amount. (See Section VII.A.3. for guidance on daily 

allotment for residents who choose to stay with family or friends). 

Residents who have a washer and dryer at their primary residence but not at their temporary 

residence may be reimbursed for their laundry expenses every fourth consecutive night they are 

temporarily relocated. Consistent with federal travel regulations, the daily allotment should be 

used for laundry needs when residents are relocated less than four days. Dry cleaning generally 

is not an out-of-pocket expense associated with the relocation and is not reimbursable. 

When families have limited resources, the Team may find it is necessary to provide them their 

daily allotment before their expenses are incurred. Relocated families may not be able to pay for 

restaurant meals and then wait for reimbursement. Special arrangements will have to be made 

with the real estate experts (ERRS or USACE) or with the financial experts in the Regional 

OSWER Directive 9230.0-97 33 
office. The advance payment for the daily allotments should not exceed two weeks. Attachment 

18 includes examples of forms that can be used to document receipt of advanced payments and 

other compensation. Additionally, many hotels/motels are located in areas that provide limited 

restaurant choices. Severely limiting resident’s restaurant options for an extended period of time 

is generally not practical, particularly if there are dietary needs/restrictions or cultural concerns. 

Some OSCs/RPMs have worked with local hotels to provide alternative restaurant 

arrangements, such as asking the hotel to provide shuttle bus service to nearby restaurants. 

E. Household Staples 

In some situations, residents may not be able to take any of their household staples—including 

cooking products like flour, spices, sugar, condiments, or cleaning products like bleach, laundry 

soap, brooms and mops—to their temporary apartment or house. Since these items are not 

purchased and consumed weekly, the cost of replacing all of them at once may be considered a 

reasonable out-of-pocket expense as residents set up housekeeping at their temporary 

residences. In these situations, the Team may decide to reimburse residents living in temporary 

housing for the reasonable replacement expense for routinely used household items. The actual 

amount should be based on the types of items that must be replaced (e.g., in some situations, 

food may need to be destroyed, but items such as cleaning and personal hygiene products may 

be taken to the temporary residence; in other situations, it may not be possible for the residents 

to remove any household staples from their homes). 

F. Insurance Premiums for the Temporary and Primary Residences 

Residents are responsible for maintaining 

insurance at their primary residence. 

Temporary increases in insurance costs 

resulting from the relocation should be treated 

as an eligible out-of-pocket expense (e.g., 

increased premiums for vacant dwelling and 

insurance at the temporary residence). In some 

situations, to limit insurance cost increases, the 

Team may contact the insurance company to 

advise them of the government’s 

responsibilities regarding provision of site 

security. Residents should be encouraged to 

obtain renters’ insurance at the temporary 

residence to protect their possessions. If 

renters’ insurance is an out-of-pocket expense, 

it is eligible for reimbursement. 

G. Personal Transportation Costs 

Personal transportation costs are not ordinarily 

considered expenses incurred as a result of 

relocation. However, the Team may 

recommend that certain expenses be considered reasonable out-of-pocket expenses directly 

related to relocation. For example, if the temporary housing is located far away from residents’ 

schools or work, the Team may authorize the payment of personal transportation costs or make 

i it is i i

i

ici

si i l ial 

i

i i

i

Finding Temporary Housing Near Schools 

Presents a Special Challenge 

Somet mes mposs ble to find temporary housing 

that is near the schools where temporarily relocated 

children are currently enrolled. However, these children 

must have transportat on to get to school. 

To address this problem at a pest de-contaminated 

te Ohio, Region 5 contracted w th a ocal soc

service organizat on to provide vans and drivers to 

transport the relocated children to their schools. This 

required monitoring by a Team member. In one 

instance, a driver dropped a child off at the wrong hotel 

after school. To allev ate such problems n the future, 

Region 5 developed an application for school bus 

transportat on. For an example of this application, see 

Attachment 19. 

34 April 2002 
arrangements for transportation to be provided. Regions should take great care to make sure 

standards are in place when selecting drivers and vans.2 

If the resident elected to move to a temporary residence that is farther from schools or work than 

a location EPA provided, EPA should not be responsible for any additional transportation costs 

beyond those associated with the temporary residence offered by EPA. 

H. Damaged or Contaminated Personal Property 

Costs associated with damaged or contaminated personal property are not a temporary 

relocation expense, but they often occur at sites where EPA is conducting a temporary 

relocation. In general, EPA has the discretion to compensate residents for personal property that 

is damaged in the course of the cleanup or that cannot be decontaminated. In most situations, 

EPA should provide replacement value for essential furniture items (see Attachment 8 for a list 

of essential furniture items) and depreciated value for non-essential personal property. 

Several methods can be used to reimburse residents. A third party draft can be used for 

reimbursement up to $5,000. Treasury checks can be issued for larger amounts. Issuing 

treasury checks may take time because there is a built in time delay in EPA’s procurement 

procedures. The Team should work with their financial management office to determine if 

treasury checks are feasible and if they can be issued in a timely manner. This guidance, 

however, is not intended to fully outline the assistance available to compensate residents for 

contaminated personal property. Contact the OERR Regional Coordinator for assistance. 

Additional guidance on funding options is available in the “On-Scene Coordinators Toolbox 

Guide,” EPA Directive 9242.2-12, EPA Publication 540-K-00-003. 

I. Reimbursement for Non-Residential Relocations 

Temporarily relocating farms, nonprofit organizations, businesses with special permits (such as 

bars and hotels), or large or specialized operations can have devastating effects on their 

success. Therefore, the OSC/RPM should explore every available option to avoid temporarily 

relocating them. However, if these types of businesses have to close down temporarily during a 

response action, they may be entitled to some assistance. ORC and the Region’s OERR 

Regional Coordinator should work with OGC to determine what assistance, if any, can be 

provided. 

Other types of businesses may be easier to temporarily relocate. For example, if a relocated 

resident had set aside part of his/her residence to operate a small business and had phone or 

fax lines, EPA may provide such arrangements at the temporary residence. Determinations for 

the types of relocation assistance EPA can provide are made on a case-by-case basis, and 

consider factors such as essential equipment needed to continue operation, special hook-ups, 

2 Bus driver qualifications and standards are established by state and federal regulations. All drivers 

must comply with federal regulations and any state regulations that exceed federal requirements. At a minimum, 

the Team should insist that school bus drivers pass a background investigation to uncover any criminal 

convictions or a history of mental illness. Drivers must not have been convicted of a felony involving the use of a 

motor vehicle; a crime involving drugs; or driving under the influence of drugs or alcohol. The Team may want to 

consult with the local school board for additional advice. Additional information is also available in the US 

Department of Labor's Occupational Outlook Handbook, http://www.bls.gov/oco/ocos242.htm#training. 

OSWER Directive 9230.0-97 35 
disconnections, and the potential for CERCLA liability of the business for the contamination. 

Costs associated with loss of goodwill, loss of profits, and loss of trained employees are not 

reimbursable. It is EPA’s policy to provide business owners the same opportunity for the 

resolution of disputes as provided to residents. See Section VIII, “Termination of Assistance and 

Resolution of Disputes.” 

Assistance for non-residential relocations is different from assistance for residential relocations. 

The URA includes caps on certain types of assistance. This guidance document is not intended 

to fully outline the assistance available for non-residential relocations. The Temporary Relocation 

Team should work with OGC/ORC, the Region’s OERR Regional Coordinator, and relocation 

specialists from the supporting agencies to determine the appropriate scope of relocation 

assistance for each non-residential operation requiring relocation. 

J. Other Expenses Directly Related to Relocation 

When appropriate, the Temporary Relocation Team may determine that other potential 

expenses directly related to the temporary relocation are eligible expenses. These expenses 

should be approved by the Team before costs have been incurred. In making determinations 

about other eligible expenses, the Team may consult ORC and/or their Headquarters Regional 

Coordinator for assistance. 

K. General Requirements for Reimbursement of Expenses 

During a temporary relocation, residents should incur expenses and seek reimbursement from 

EPA. Any claim for reimbursement made by residents during a temporary relocation should be 

supported with bills, receipts, certified prices, appraisals, or other documentation. EPA should 

provide reasonable assistance in the completion and filing of any required claims for 

reimbursement to persons temporarily relocated. It is important to keep the following 

requirements in mind when dealing with requests for reimbursement: 

•	 Timeliness of EPA reviews—EPA should review claims in an expeditious manner and 

promptly notify claimants if additional documentation is needed to support their claims. 

Payment for a claim should be made as soon as feasible after the supporting 

documentation has been received. 

•	 Timeliness of claim filing—It is EPA’s policy that all claims for relocation reimbursements 

should be filed with EPA/PRP within four months of the date that residents are allowed to 

return to their primary residence. This deadline can be extended; however, if residents 

can show the need. Residents should be notified of all deadlines in writing. 

•	 EPA disapproval of claims—If EPA disapproves all or part of a claim for reimbursement 

for any reason (e.g., the claim was not filed in a timely manner, residents requested 

reimbursement for ineligible goods or services), the Agency should promptly notify the 

claimant in writing of its decision, of the basis for its decision, and the procedures for 

additional review of the dispute by an EPA official not involved in the response action at 

the site (see Section VIII, “Termination of Assistance and Resolution of Disputes”). This 

written notice should be sent via certified mail. 

36 April 2002 
L. Public Housing Considerations 

Residents living in public housing should receive the same types of temporary relocation 

assistance as residents living in private homes and apartments. The Team should be aware that 

temporary relocation assistance should not count against the residents’ public assistance since 

it is not income. The Team should become knowledgeable about the requirements of various 

public housing programs before discussing temporary relocation assistance with public housing 

residents. 

In most cases where a response action affects public housing, the Region should have been 

coordinating with the appropriate public housing authority (PHA) before the relocation is 

announced. The PHA may be able to provide residents with temporary housing in other available 

public housing units or may wish to minimize the disruption in residents’ lives by providing 

permanent alternative housing to residents. It is important that the Team work closely with the 

PHA as arrangements are being planned. It also might be necessary to contact the appropriate 

public assistance agency if problems develop. Attachment 20 provides a brief description of the 

United States Housing and Urban Development (HUD) Section 8 Housing Choice Voucher 

Program. 

M. Tax Implications and Eligibility for Other Federal Programs 

Under 49 CFR 24.208, payment of relocation assistance is not considered income for the 

purpose of the Internal Revenue Code or for the purpose of determining eligibility for assistance 

under any other federal law, except for federal laws providing low-income housing assistance. 

EPA also should not withhold any part of a relocation payment from a relocated person to satisfy 

an obligation to any creditor other than the Agency. 

N. Temporary Relocation Assistance Records Management 

To support EPA cost recovery efforts, thorough documentation of assistance provided under 

CERCLA must be maintained. The OSC/RPM must ensure that relocation administrative 

personnel establish and maintain files for each applicant receiving temporary relocation 

assistance. At a minimum, these files should contain the following: 

•	 The completed “Application for Superfund Temporary Relocation Assistance—Needs 

Determination,” which can be found in Attachment 12. 

•	 Photocopies of all assistance checks issued to the applicant. 

•	 A copy of the applicant's eligibility determination. 

•	 Documentation of any change in the applicant’s eligibility status. 

•	 Photo and video documentation and appraisals of contaminated personal property that is 

being acquired and replaced as part of the response action. 

•	 Any additional documentation that the OSC/RPM thinks is needed. 

As stated in the “Application for Superfund Temporary Relocation Assistance—Needs 

Determination” (Attachment 12), the information requested on the application may be disclosed 

OSWER Directive 9230.0-97 37 
to federal, state, local, and private agencies for use in providing relocation assistance. The Team 

should be careful not to violate rules of privacy protection (regarding, for example, individual 

financial information or social security numbers). Applying for and accepting temporary 

relocation assistance is voluntary; however, if a resident is seeking this assistance, failure to 

provide any of the information requested can result in delay or rejection of the application. 

Records on temporarily relocated people should be retained for future claims and cost recovery 

purposes. These include any records relating to assistance provided, decisions about eligibility 

for assistance, documents indicating any unique circumstances, disputes, video documentation 

of property conditions, or any other materials that support EPA decisions. 

38 April 2002 
VIII. TERMINATION OF ASSISTANCE AND RESOLUTION OF DISPUTES 

A. Termination of Assistance 

The Team should be reasonably flexible with the residents when terminating temporary 

relocation assistance. Special circumstances that could affect the re-occupancy of the primary 

residence or business facility should be considered. This includes removing items or personal 

property from storage. 

EPA should provide each person reasonable notice before terminating their temporary relocation 

assistance. Generally, this is thirty days. In cases where the temporary relocation is very shortterm (a few days to a few weeks), the notice should be provided as soon as practical. 

At a minimum, the notice should include the date and time that residents can reoccupy their 

primary residences or business facilities, as well as the date and time when temporary 

relocation assistance will cease. The notice also should describe the expected conditions of the 

residence and the nearby neighborhood on the date that residents will return to their homes, 

especially if response work stills needs to be done. The notice also may include relevant 

sampling data to demonstrate that the residence is ready for re-occupancy. 

The notice of termination of assistance should be given in writing. Where written notice is not 

practicable, oral notice should be given, followed by a written notice. The notice should inform 

residents that they are responsible for any additional charges beyond the date and time of the 

termination of assistance if they do not vacate their temporary accommodations (See 

Attachment 21 for a sample termination letter). 

There are several scenarios that may call for ending some or all financial assistance: 

•	 The OSC/RPM determines that the primary residence from which the occupant was 

relocated is now ready for occupancy. 

•	 The Team determines that the temporary housing occupant has not complied with the 

terms of the lease or the reimbursement agreement. 

•	 The Team determines that the residents provided EPA with false information when 

applying for relocation assistance. 

•	 An offer is made to acquire the primary residence from which the person was relocated, 

and the person has permanently relocated as a result of this offer (Headquarters can 

provide additional information on implementing permanent relocations). 

•	 A tenant has found permanent replacement housing and wishes to move from the


temporary location.


•	 The homeowner has sold the primary residence and permanently relocated. 

OSWER Directive 9230.0-97 39 
•	 The landlord at the temporary residence determines that the resident has violated his or 

her rental agreement. 

•	 The resident has failed to take care of the temporary residence. 

•	 The resident has failed to pay for the mortgage/rent at the primary address, utilities, or 

other charges for which he or she is responsible. 

B. Disputes 

It is EPA's policy to provide all temporarily displaced persons the opportunity to have any 

decisions about their eligibility for, or the amount of, a temporary relocation assistance payment 

reviewed by an Agency official who is not directly involved in the relocation. Persons who 

disagree with any such determinations by EPA or a PRP may submit to EPA a written 

description of the dispute and a detailed justification to support their claim. This process applies 

to disputes regarding temporary relocation assistance only; it does not apply to disputes 

involving damage to personal property. Persons who will be temporarily displaced should be 

advised of the process for resolving disputes prior to being relocated. 

Requests for review must be submitted in writing to a member of the Temporary Relocation 

Team no later than 60 days from the date a claim is initially denied. Requests submitted after 

this date will be considered if the Agency determines that the person's failure to request a review 

in a timely manner was caused by circumstances beyond that person's control. The affected 

person should explain the circumstances that caused the delay in submitting the request for 

review. The affected person may be represented by legal counsel or another representative, but 

solely at the person's own expense. 

A Region may agree to participate in non-binding dispute resolution to reach agreement with a 

temporarily displaced person. If USACE is providing relocation support to a Region, EPA may 

ask USACE to make a recommendation regarding resolution of a dispute. The Region and the 

District should agree upon a detailed process for reviewing disputes in advance. EPA's 

expectations regarding the review process should be clearly set forth in the statement of work in 

the Interagency Agreement with USACE. The goal should be established for USACE to complete 

its review within 60 days. If USACE requires additional time to research a complicated dispute, a 

justification for the time extension should be provided to EPA. Whenever a disputed matter is 

referred to USACE for review, the Region should notify the appropriate OERR Regional 

Coordinator that a dispute is under review by the USACE. 

The process used by the Region and USACE should afford temporarily displaced persons an 

opportunity to provide evidence in support of their claim. USACE should prepare a document that 

provides the pertinent facts, legal and policy analysis, and a recommendation. This document 

should be prepared by someone at USACE who has not been involved with the relocation. 

USACE should provide the Region with status reports at key milestones during the review 

process. An example of a key milestone is the elevation of the dispute within the USACE 

command structure. If USACE recommends approval of the claim and the Region agrees, no 

additional review is needed. If, however, USACE recommends that the claim be denied and the 

Region agrees, or if USACE and the Region disagree as to the appropriate disposition of the 

claim, it should be forwarded to the Director of OERR at EPA Headquarters for a final decision. 

40	 April 2002 
At sites where USACE is not providing relocation support, the Region must have an internal 

process for handling disputes. The Regional process should allow the resident or business 

owner the same opportunity to provide evidence in support of the claim. Any final decision to 

deny a claim shall be made by the Director of OERR. 

In all cases, decisions on disputed matters should be communicated to the resident by EPA. All 

decisions should be sent to the affected person by certified mail 

Regions should contact the appropriate OERR Regional Coordinator for additional advice on 

resolving disputes. 

OSWER Directive 9230.0-97 41 
IX. PROVISION OF PERMANENT ALTERNATIVE HOUSING 

This section provides a brief outline of some issues and requirements that should be considered 

when the Team is considering providing alternative housing or permanent relocation. It is not 

intended to serve as complete guidance on either alternative housing or permanent relocation. 

Regions considering either option should contact the appropriate OERR Regional Coordinator at 

Headquarters for additional guidance. 

A. Renters 

It is sometimes appropriate to provide alternative housing or rental space for residential tenants 

or businesses (see EPA Directive 9355.0-71P, “Interim Policy on the Use of Permanent 

Relocation as Part of Superfund Remedial Actions”). The Temporary Relocation Team may 

consider arranging alternative housing for tenants who may be temporarily relocated for an 

extended period of time (six months or more). In making this decision, the Team should consider 

several factors, including the availability of desirable rental property, the cost of alternative 

housing compared with the cost of temporary relocation, and the desire of the residents to return 

to their primary residences. If the Team decides to offer permanent alternative housing to 

tenants, there are several options, which are outlined below. 

A.1. Renters Who Have Occupied Their Primary Residence Less Than 90 Days 

Renters who have lived at the rental property for less than 90 days before the announcement of 

the temporary relocation assistance offer may be eligible for the following assistance: 

•	 Moving costs to relocate to housing outside the contaminated area. 

•	 One month of rental assistance at the new housing if they are required to provide their 

landlord with 30 days notice of their intention to vacate. 

•	 The deposit needed for the new rental residence. 

A.2. Renters Who Have Occupied Their Primary Residence 90 Days or Longer 

Renters who have been at the rental property for at least 90 days are eligible for rental 

assistance payments or a down payment assistance payment, as provided in 49 CFR 24.402. 

Renters who are offered permanent alternative housing are entitled to rental assistance 

payments up to a maximum of $5,250 over 42 months if they: 

•	 Have actually and lawfully occupied the primary residence for at least 90 days


immediately before the offer of temporary relocation was announced.


•	 Have rented or purchased and occupied a decent, safe, and sanitary replacement 

residence within one year (unless the Agency extends this period for a good reason) after 

they moved from the primary residence. 

•	 Can certify that they are lawful residents of the United States, as required by a 1997 

amendment to the URA (Contact your OERR Regional Coordinator to get forms for 

residents to use to certify their legal residency in the United States). 

42 April 2002 
To determine the amount of the rental assistance, the average base monthly rental and utility 

costs (using twelve months of actual bills if available, and a minimum of three-months if fewer 

bills are available) are subtracted from the cost of the replacement residence and estimated 

average utility cost, and the result is multiplied by 42. It is important for the Team and the 

residents to understand that EPA’s relocation assistance is intended only to compensate 

residents for actual losses. Thus, if residents choose to relocate to less costly housing identified 

by the Team, the rental and utility costs for the actual housing to which they relocate are the 

costs used to calculate the amount of relocation assistance rather than the costs for the 

comparable dwelling. It also is important to ensure that any replacement housing for which 

residents will receive relocation assistance meet the “decent, safe, and sanitary” criteria. 

There are three ways to determine the base monthly rental cost: 

•	 Use the family’s actual monthly rent and utility costs using twelve months of actual bills if 

available, and a minimum of three-months if fewer bills are available. Be sure to use data 

from the same time of the year so that air conditioning or heating costs are included. For 

residents who pay little (i.e., significantly less than the FMR) or no rent for the primary 

residence, use the FMR as the base monthly rental unless this would cause hardship to 

the resident because of low income or other circumstances (see 49 CFR 24.402 for 

additional information). 

•	 Calculate 30% of the household’s combined average gross income. The assumption is 

that the average family should pay approximately 30% of their average household income 

for rent. If the resident refuses to provide appropriate evidence of income (e.g., tax 

returns) or is a dependent, the base monthly rental is established by using one of the 

methods described above. 

•	 For families receiving welfare assistance payments that designate amounts for shelter 

and utilities, take the total monthly amount designated for shelter and utilities. 

You must use the method that results in the lowest base monthly rent and utility cost. 

Once the base monthly rent for the primary residence has been identified, subtract this amount 

from the total monthly rent and an estimated average utility cost for a comparable temporary 

replacement residence.3 Then multiply this amount by 42 (the maximum number of months for 

which rental assistance can be provided): 

Comparable replacement dwelling costs of $1,100 minus $1,000 base monthly rental= 

$100 X 42 = $4,200 total rental assistance amount. 

When making these calculations, consider whether the amount calculated will cause hardship to 

the family because of their income level or for other reasons. If so, adjustments may be made 

3 If residents have chosen to relocate to less costly dwellings than the identified comparable dwellings, 

the rental and utility costs for that dwelling are used to calculate the amount of relocation assistance rather than 

the costs for the comparable dwelling. 

OSWER Directive 9230.0-97 43 
(See 49 CFR 24.402 for additional information). It is EPA’s policy to distribute rental assistance 

funds in installment payments rather than a lump sum when the rental assistance is greater than 

$!0,000, unless the resident elects to use the money as part of a down payment on a home (49 

CFR 403 (f) provides guidance on making payments after the death of the resident). 

If the Team decides to offer a tenant alternative housing and no comparable replacement 

housing is available at the fair market rent (FMR), the Region may provide a housing-of-lastresort payment (49 CFR 24.404). This payment should be based on the same calculation 

described above, but may exceed the $5,250 ceiling. The justification for exceeding that ceiling 

should be well-documented and based on a careful search for comparable homes. The housingof-last-resort payment should not exceed the anticipated cost of temporarily relocating the 

tenant. The Team should keep in mind that Section 24.404 describes this type of assistance, but 

is based on the assumption that the tenant cannot return to the home. 

In situations where temporary relocation is being offered, provision of permanent alternative 

housing is at the discretion of EPA. Offering permanent alternative housing might be more costeffective than offering temporary relocation. However, the Temporary Relocation Team might 

want to reconsider a temporary relocation assistance offer if a housing-of-last-resort payment is 

necessary. The inconvenience to the residents of a long-term temporary relocation, the tenants’ 

interest in permanent alternative housing, and other factors also should be considered. 

A.3. Down Payment Assistance 

Tenants who occupied their primary residence for at least 90 days before they were offered 

temporary relocation may be entitled to a down-payment assistance payment if they want to 

become homeowners. This payment is calculated the same way as the rental assistance 

payment, but can be increased to $5,250 at EPA’s discretion if it is applied specifically to the 

purchase price of the replacement home. If the Agency decides to increase the payment, it is 

important that all affected residents be treated the same way. The full amount of the down 

payment assistance must be applied to the purchase price of the replacement dwelling and 

related incidental expenses. 

If the Team offers a housing-of-last-resort payment, the down-payment assistance payment 

would be equal to, but never more than, the housing-of-last-resort payment and thus could 

exceed $5,250. This payment should be provided at the time the tenant closes on the sale of a 

house. The tenants must agree to vacate their primary residence when requested by EPA. The 

residents should not receive rental assistance while searching for a home to buy. The tenants 

may be entitled to a reimbursement of their moving expenses or other temporary relocation 

assistance. 

This document is not intended to provide complete guidance on calculating and documenting a 

decision to offer down payment assistance. The Temporary Relocation Team should contact the 

appropriate OERR Regional Coordinator for additional assistance. 

B. Homeowners 

When a temporary relocation at an NPL site continues for one year or longer (see EPA Directive 

9355.0-71P, “Interim Policy on the Use of Permanent Relocation as Part of Superfund Remedial 

Actions”), EPA has the discretion to convert the temporary relocation into a permanent 

44 April 2002 
relocation. Such decisions are made on a case-by-case basis, and should consider a number of 

other factors, including: 

•	 Project length. 

•	 Amount of time the Region thinks it would take to acquire the property and permanently 

relocate the residents. 

•	 Availability of suitable housing. 

•	 Comparative costs of a permanent relocation over a temporary relocation. 

•	 Disruption of resident’s lives. 

•	 The wishes of the residents. 

•	 Whether or not the state will accept title to the acquired property and provide a cost 

share. 

Guidance for making this decision can be found in “Interim Policy on the Use of Permanent 

Relocations as Part of Superfund Remedial Actions,” EPA Directive 9355.0-71P. The Team 

should note that the policy makes it clear that EPA prefers to address the risks posed by the 

contamination by using well-designed methods of cleanup so people can remain safely in their 

homes and businesses. Approval from the Assistant Administrator of the Office of Solid Waste 

and Emergency Response (OSWER) and concurrence from the Office of General Counsel 

(OGC) is required to acquire property. 

OSWER Directive 9230.0-97 45 
ATTACHMENTS


The following attachments provide additional information to assist the Temporary Relocation 

Team in implementing the temporary relocation. Many of these attachments are templates that 

can serve as useful forms for recording important information or for correspondence between 

EPA and the residents. The templates are designed with the expectation that they will be 

modified to meet site specific circumstances. 

46 April 2002 
ATTACHMENT 1


Temporary Relocation Check List


Activities To Do 

(Not necessarily in chronological order) 

Section/ 

Attachment # 

(if applicable) 

U

Q Assemble a small Temporary Relocation Team to determine 

if temporary relocation is feasible 

Include the following members on the Team: 

• OSC or RPM 

• ERRS/START or SATA contractors or USACE 

representatives...(see Attachment 5) 

• CIC 

III, 

Attachment 3, 

Attachment 5 

Q Answer the following questions: 

• Can you anticipate community support? 

• Is there enough available temporary housing? 

• Is there a clear start and end date? 

• Are there residents with unique health needs? 

• Is transportation to and from schools and workplaces 

available at temporary residences? 

• Are there any business, nonprofit organizations or farms 

that may need temporary relocation? 

IV.B. 

Q Expand the Temporary Relocation Team 

Once the decision is made to offer temporary relocation, the 

Team may need to add members, such as: 

• An attorney from ORC 

• Regional media relations and environmental justice experts 

• State/Local Government Officials 

III 

Q Coordinate as necessary with the following: 

• Local and State officials 

• Community leaders 

• Local social service agencies 

• ATSDR 

• Media 

• Headquarters Regional Coordinators 

III 

Q Document the decision IV.B. 

Q Notify residents verbally, document eligibility status as 

soon as possible, and determine unique family needs. 

IV.D., 

Attachment 12 

OSWER Directive 9230.0-97 47 
Activities To Do 

(Not necessarily in chronological order) 

Section/ 

Attachment # 

(if applicable) 

U

Q Send formal notification letter to residents. 

(For emergency removal actions, provide a verbal notice 

followed by a written notice.) 

IV.D., 

Attachment 7 

Q Explain relocation assistance to residents: 

• Provide general information at a meeting of all residents. 

• Meet with each family to discuss specific assistance if 

appropriate. 

• Develop site specific booklet or pamphlet for the residents 

that explains what will happen and when. 

V.A., 

Attachments 

12, 13A, & 13B 

Q Obtain a signed agreement from each household 

accepting the offer of temporary relocation and agreeing 

to comply with the expectations of the agreement. 

Attachment 10 

Q Arrange for the following as necessary: 

• Movers...(VI.B.) 

• Utilities disconnect/reconnect...(VI.C.) 

• Documentation of primary residences (IV.F. and 

Attachment 9) 

• Kennels/pasturing fees 

• Transportation for residents...(VI.G.) 

• Rental furniture selection and delivery ...(VI.B.1.) 

• Storage facility for resident’s personal property 

• Maintenance of residence’s primary residence 

• Payment of daily allotment when appropriate ...(VI.D.) 

• Establishment of a records keeping system including 

tracking of all relocation expenses for reimbursement ... 

(VI.O.) 

• Payment of resident’s expenses ... (III.A.5., VI.I., VI.J., and 

Attachment 5) 

• Site security ...(IV.G.) 

• A process for resolving disputes ...(VII.B.) 

• A system to encourage residents to have their mail 

forwarded 

Q Be available throughout the temporary relocation to 

residents for questions and problem solving 

V.A. 

Q Keep residents informed of the project’s status 

throughout the temporary relocation. 

V.A. 

48 April 2002 
Activities To Do 

(Not necessarily in chronological order) 

Section/ 

Attachment # 

(if applicable) 

U

Q Send written letter to residents announcing when they can 

return to their homes. As time permits, work with resident 

to find a move date that is convenient to them. 

VIII.A. 

Attachment 20 

Q Notify landlords of the termination of the temporary 

relocation assistance. 

VIII.A. 

Attachment 20 

Q Make arrangements for the residents’ return: 

• Return of stored personal property to the primary residence 

and/or movers to move personal property from the temporary 

to the primary residence. 

• Reconnection of utilities at the primary residence. 

• Airing out of the primary residence if needed. 

• Notify residents to have their mail delivery returned to their 

primary residence. 

VII.B., VII.C. 

OSWER Directive 9230.0-97 49 
ATTACHMENT 2 

Decent, Safe, and Sanitary Standards 

The term “decent, safe, and sanitary dwelling” means a dwelling that meets applicable housing 

and occupancy codes. Housing must meet all of the following standards, even if not required by 

the building codes, unless waived for good cause by the federal agency funding the project. 

The dwelling shall: 

1. Be structurally sound, weather tight, and in good repair. 

2. Contain a safe electrical wiring system that is adequate for lighting and other devices. 

3. Contain a heating system that is capable of maintaining a healthful temperature (of 

approximately 70 degrees Fahrenheit), except in those areas where local climatic 

conditions do not require such a system. 

4. Be adequate in size with respect to the number of rooms and area of living space needed 

to accommodate the relocated person or family. There shall be a separate, well-lighted 

and ventilated bathroom that provides privacy to the user and contains a sink, bathtub or 

shower stall, and a toilet, all in good working order and properly connected to the 

appropriate sources of water and to a sewage drainage system. In the case of a 

housekeeping dwelling, there shall be a kitchen area that contains a fully usable sink that 

is properly connected to potable hot and cold water and to a sewage drainage system, 

and adequate space and utility service connections for a stove and a refrigerator. 

5. Contain unobstructed egress to safe, open space at ground level. If the replacement 

dwelling unit is on the second story or above, with access directly from or through a 

common corridor, the common corridor must have at least two means of exit. 

6. For a relocated person who is disabled, be free of any barriers that would prevent 

reasonable entry, exit, or use of the dwelling. 

SOURCE: 49 CFR SECTION 24.2 OF THE UNIFORM REGULATIONS 

50 April 2002 
ATTACHMENT 3 

Key Team Functions 

Throughout the project, members of the Temporary Relocation Team will serve as the contact 

for the relocated residents and will arrange all aspects of the relocation. Below are some of the 

activities that may be necessary during a temporary relocation (this list is not in chronological 

order or in order of importance): 

•	 Identifying the type of relocation assistance needed from other federal agencies, and/or 

private contractors, including EPA contractors, and/or the PRP. 

•	 Developing a clear and detailed statement of work that documents EPA’s expectations. 

•	 Reviewing legal documents. 

•	 Conducting community interviews, including interviews with residents and businesses. 

•	 Keeping residents informed about moving dates and projected dates for re-occupancy of 

the primary residence. 

•	 Answering questions about the progress on decontamination of residents’ homes. 

•	 Conducting risk communication and providing information about the contaminant to 

residents. 

•	 Distributing termination of assistance notices and related information. 

•	 Developing replacement item agreements with owners/tenants when property is


damaged.


•	 Distributing leaflets to each household in neighborhoods before mobilization of the 

decontamination crew and equipment. 

•	 Drafting documents used to administer the relocation. 

•	 Developing a site-specific communications strategy. 

•	 Responding to public and media inquiries. 

•	 Arranging press conferences and media events. 

•	 Issuing press releases at milestones in the project. 

•	 Arranging neighborhood information sessions and public meetings. 

OSWER Directive 9230.0-97 51 
•	 Identifying community needs and coordinating with other government agencies. 

•	 Developing community information materials, including fact sheets, leaflets, postcards. 

•	 Developing the site-specific community involvement plan. 

•	 Establishing local information repositories at public libraries in the affected communities. 

•	 Scheduling speaking engagements throughout the community. 

•	 Trouble-shooting problems that occur during temporary relocations. 

•	 Obtaining access agreements and assisting residents in completing the Application for 

Superfund Temporary Relocation Assistance. 

•	 Finding suitable temporary housing for families being temporarily relocated. 

•	 Making hotel/motel reservations. 

•	 Making kennel arrangements for pets. 

•	 Making plans for moving and storage of personal property. 

•	 Providing moving assistance, including packing materials. 

•	 Coordinating activities on residents' moving day. 

•	 Arranging school transportation for children of temporarily relocated households. 

•	 Arranging site security. 

•	 Maintaining site relocation files and updating relocation database information. 

•	 Paying all lodging costs, including tax. 

•	 Arranging for payment of temporary relocation assistance and delivering relocation 

assistance checks where applicable. 

•	 Making arrangements for an independent appraiser to appraise furniture disposed of 

because of contamination. 

•	 Establishing and maintaining a system for cost documentation. 

•	 Documenting condition of real and personal property at the resident’s primary residence. 

•	 Helping residents adjust to temporary housing. 

52 April 2002 
•	 Identifying key contacts at local, state and other federal government agencies. 

• Identifying support from local social service agencies. 

The OSC/RPM is responsible for: 

•	 Ensuring the fair and equitable treatment of the residents, in accordance with URA and 

DOT regulations. 

•	 Ensuring that the Temporary Relocation Team is functioning effectively as a team. 

•	 Maintaining close contact with the relocation support experts and ensuring that they are 

complying with this guidance and are sensitive to community needs. 

•	 Coordinating and interfacing with county health departments and other local and support 

agencies. 

•	 Ensuring appropriate distribution of government relocation monies. 

•	 Ensuring appropriate financial management and documentation by contractors assisting 

with the relocation operation. 

•	 Ensuring effective communication and coordination with residents and business owners. 

•	 Reviewing and processing disputes of residents regarding relocation assistance


decisions.


OSWER Directive 9230.0-97 53 
ATTACHMENT 4 

SAMPLE 

Consent for Entry and Access to Property 

United States Environmental Protection Agency—Region XX 

Name:	 Residence No.: 

Address: 

Temporary Address: 

Phone:	 ( ) 

Address of property for which consent to access is granted (the “Property”): 

Relationship to Property: 

(e.g., owner, 5 year tenant, etc.) 

I grant consent to officers, employees, and authorized representatives of the United States 

Environmental Protection Agency (“EPA”) to enter and have continued access to my property at 

all reasonable times for the following purposes: 

(Examples. Alter to make site specific.) 

•	 Air and wipe sampling. 

•	 Communication with residents and other people on the property. 

•	 Inventory, sampling, decontamination, stabilization, and/or disposal of items of personal 

property contaminated by [specify the contamination]. 

54 April 2002 
•	 Decontamination, stabilization and disposal of structures and furnishings contaminated 

by [specify the contamination]. 

•	 Removal and disposal of carpets, baseboards, furnace filters, drapes, blinds, and other 

window dressings, in accordance with health department recommendations. 

•	 Removal and disposal of food products in accordance with health department


recommendations.


•	 Oversight and verification of privately conducted remedial activities. 

•	 Demolition and disposal of contaminated trailer homes. 

•	 Such other actions as EPA determines are necessary to protect human health or welfare 

or the environment. 

I realize that EPA is authorized to undertake these actions pursuant to the Comprehensive 

Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA), 42 

U.S.C. §9601 et seq. 

I realize that there may be loss of or damage to property during these actions. In addition, I 

realize EPA will be using utilities, including heat, water, and electricity, while taking the actions 

permitted in this document. 

I certify that I have the authority to permit the actions authorized in this document. This 

written permission is given by me voluntarily, without threats or promises of any kind, and I 

understand that I have a right to refuse. 

I have not intentionally applied the [specify the contamination] in order to obtain 

assistance related to a government response action. I have not requested or permitted anyone 

else to apply [specify the contamination] in order to obtain assistance related to a government 

response action. I understand that intentionally applying (or arranging for the application of) the 

[specify the contamination] in order to obtain assistance related to a government response 

action is a crime punishable by a fine and/or imprisonment. I understand that making any 

misrepresentation in order to obtain assistance related to a government response action is a 

crime punishable by a fine and/or imprisonment. 

All statements in this document are true and correct to the best of my knowledge. I 

understand that intentionally making false or fraudulent statements in this document is a criminal 

offense punishable by a fine and/or imprisonment. 

Date: ____________Signature:___________________________________________ 

OSWER Directive 9230.0-97 55 
ATTACHMENT 5 

SAMPLE 

Statement of Work 

The U.S. Army Corps of Engineers (USACE) will provide real estate services to EPA in support 

of actions performed by EPA under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA), as amended. Specifically, USACE will provide 

trained relocation services to people identified by EPA as needing relocation assistance because 

of a release, or the threat of a release, of hazardous substances or other pollutants or 

contaminants covered by CERCLA that may pose an imminent threat to public health and the 

environment. 

[Add a brief description of the project here.] 

Section I. Preliminary Relocation Tasks 

a.	 USACE will comply with EPA’s guidance, “Superfund Response Actions: Temporary 

Relocations Implementation Guidance” OSWER Directive 9230.0-97, when conducting 

fund-led temporary relocations for EPA under CERCLA authority. USACE will coordinate 

with EPA before making decisions about assistance that are outside the scope of this 

document. 

b.	 USACE will provide a schedule for the work described in this document. 

c.	 USACE will provide EPA with a cost estimate for the work described in this document. 

d.	 USACE will consult with EPA in choices of contractors, contract types and contract 

details. 

e.	 USACE will have a clause in their contracts that makes contractors liable for liquidated 

damages or for slow or unacceptable progress. 

f.	 As soon as practicable, USACE personnel responsible for providing real estate services 

will hold a meeting with all affected landowners/tenants. EPA will participate in the 

meeting to respond to technical questions concerning the scheduled work at the site. 

USACE, along with other Temporary Relocation Team members, will meet individually 

with each resident and business owner to discuss their unique needs, and will document 

the number of individuals living in each residence. 

g.	 Throughout the temporary relocation, USACE will coordinate with other Team members 

to provide residents and business owners with a detailed explanation of relocation 

assistance and services, as outlined in EPA’s guidance. 

h.	 USACE will provide EPA with progress reports on a monthly basis or on a schedule 

established by the EPA Project Officer. 

56 April 2002 
i.	 USACE will provide EPA a point of contact for all the items under this Statement of Work. 

Section II. Relocation Tasks/Assistance 

a.	 USACE will provide relocation services and assistance to affected occupants consistent 

with the requirements of the Uniform Relocation Assistance and Real Property 

Acquisition Policies Act of 1970 (URA) (PL 91-646), as amended, and the regulations 

promulgated thereunder, and EPA’s Directive 9230.0-97 “Superfund Response Actions: 

Temporary Relocations Implementation Guidance.” 

b.	 USACE will process and pay all appropriate relocation assistance claims deemed 

appropriate. 

c.	 All documents furnished by USACE to residents (including access agreements, letters, 

assignments of claims, releases, etc.) will be subject to EPA review. 

d.	 USACE will provide EPA with technical assistance related to real estate, temporary 

relocation assistance, and the requirements of the URA and “Guidance on Temporary 

Relocations During Superfund Response Actions.” Those activities may include: 

•	 Identifying available temporary housing. 

•	 Determining relocation assistance payments. 

•	 Arranging for rental furniture. 

•	 Arranging for storage of the resident’s personal property. 

•	 Arranging transportation for residents who are temporarily relocated away from 

their work or school. 

•	 Helping residents prepare their applications for assistance and other forms. 

•	 Reviewing disputes and making recommendations to EPA. 

e.	 USACE will maintain separate files for each resident and assure that all personal 

information will be kept confidential. 

f.	 USACE will make a temporary relocation expert available on site throughout the 

temporary relocation to address resident’s concerns. (Specify the Region’s expectation 

regarding the USACE’s availability, including evenings and weekends when residents are 

more likely to be home). 

g.	 USACE will notify the Temporary Relocation Team as soon as possible of any issues 

residents may have or potential relocation problems that may develop. 

h.	 In communications with individual residents, at public meetings, and in written 

communication, USACE will make clear that EPA is the lead agency for the response 

action, including the temporary relocation. 

[EPA should carefully document its expectation regarding the dispute process USACE will provide. 

That process should be consistent with the expectations described in “Superfund Response Actions: 

Temporary Relocations Implementation Guidance,” EPA Directive 9230.0-97]. 

OSWER Directive 9230.0-97 57 
ATTACHMENT 6 

Comparable Replacement Housing 

The term “comparable replacement housing” means a dwelling that is: 

1.	 Decent, safe, and sanitary. 

2.	 Functionally equivalent to the original dwelling. The term “functionally equivalent” means 

that it performs the same function, provides the same utility, and is capable of 

contributing to a comparable style of living. While a comparable replacement dwelling 

need not have every feature of the original dwelling, the principal features must be 

present. In determining whether a replacement dwelling is functionally equivalent to the 

original dwelling, the Agency may consider reasonable trade-offs for specific features 

when the replacement unit is “equal to or better than” the original dwelling. 

3.	 Adequate in size to accommodate the occupants. 

4.	 In an area not subject to unreasonable adverse environmental conditions. 

5.	 In a location that is not less desirable than the relocated person’s dwelling with respect to 

public utilities, commercial and public facilities, and access to place of employment. 

6.	 On a site that is typical in size for residential development with normal site 

improvements, including customary landscaping. The site need not include special 

improvements such as outbuildings, swimming pools, or greenhouses. 

7.	 Currently available to the relocated person on the private market; however, a comparable 

replacement dwelling for a person receiving government housing assistance before 

relocation may reflect similar government housing assistance. 

SOURCE: 49 CFR SECTION 24.2 OF THE UNIFORM REGULATIONS 

58 April 2002 
ATTACHMENT 7 

EXAMPLE 

Notification Letter 

(Modify for residents relocated to rental units) 

Date: 

Name/Address: 

Re: 

Dear: 

As you may know, the U.S. Environmental Protection Agency (EPA) is decontaminating your 

residence because it was contaminated with [specify the contamination]. You and your family 

will need to be temporarily relocated for about ___weeks during the cleanup. 

This letter is to inform you that your application for Superfund Temporary Relocation Assistance 

has been reviewed and approved by EPA. EPA will provide the following assistance to you and 

your family during your period of temporary relocation: 

1.	 A daily allotment for food and incidental expenses. The daily allotment is based on the 

federal per diem rate for _________, which will be calculated as follows: 

Adults and children age 12 years and older $_____ per day 

Children age 11 and younger $_____ per day 

*	 Please note that if similar or equivalent assistance is provided to you, EPA will not 

provide such assistance. For example, if you receive reimbursement from your 

insurance company for meals and/or temporary housing or if you receive free meals 

from some other source you will not be reimbursed by EPA. 

2.	 Cost of temporary housing (like apartments, hotels, and motels) arranged by EPA will be 

reimbursed by EPA. If you are making other arrangements, please contact us to obtain 

prior approval and a determination as to our allowance, if any. 

*	 Please note that in order to be eligible for EPA temporary housing assistance, you 

must continue your tenant or ownership status and pay your rent/mortgage at your 

primary residence. 

3.	 Costs for essential utilities (gas, water, and electricity) at your temporary residence during 

your temporary relocation. 

OSWER Directive 9230.0-97 59 
*	 Please note that in order to be eligible for EPA temporary housing assistance, you 

must continue your tenant or ownership status and pay your bills for essential utilities 

at your primary residence. 

4.	 Cost of the monthly basic telephone service will be paid. This does not include longdistance phone calls. 

5.	 A one-time moving-out-of-residence allowance of $_____ and a one-time moving back into 

residence allowance of $______ will also be provided. 

6.	 Cost for kennel fees. 

*	 Please note, you must keep all receipts for expenses incurred during your relocation 

for which you plan to seek reimbursement. EPA will assist you in completing the 

enclosed claim forms. All claims for payment must be submitted within four months of 

the date you are allowed to return to your primary residence. 

Temporary relocation assistance will begin on [date] and will terminate upon notice from U.S. 

EPA. 

Please be advised that if EPA determines at a later date that you received an inappropriate 

payment or that the information you provided to calculate these payments were based on 

incomplete, inadequate, or incorrect information, EPA may change its determination and could 

possibly seek a refund of money disbursed upon notice. 

If you have any questions concerning this temporary relocation assistance, please contact 

[Designated Team Member] at [telephone number, Temporary Relocation Office]. 

If you wish to dispute this determination or the amount of assistance received under this 

determination, you can submit a written description of your dispute to the following address 

within 60 days of receipt of this letter: 

U.S. Army Corps of Engineers Relocation Specialist 

c/o	 [Name of OSC for Relocation Operations]


[Address]


Sincerely, 

EPA On-Scene Coordinator 

Enclosures 

Note: When handed to residents instead of mailing in certified mail, the Team may add a 

signature line for indicating receipt. 

60 April 2002 
ATTACHMENT 8 

Essential Furniture Items 

# Needed Type of Furniture 

1 Sofa 

1 Living room chair 

1 Coffee table 

2 End tables 

2 Table lamps 

1 Dining table 

* Dining chairs 

1 Range 

1 Refrigerator 

* Beds (mattress, box springs, frame) 

* Crib w/mattress when required 

1 Night table (per bedroom) 

1 Table lamp (per bedroom) 

* Chest of drawers 

1 Television 

1 Alarm clock 

* One per person or as needed 

OSWER Directive 9230.0-97 61 
___________________________ 

_____________________ 

ATTACHMENT 9


EXAMPLE


PERSONAL PROPERTY APPRAISAL RECORD 

Residence # ___________ Page ____ of ____ 

Address: ___________________________ 

Contact ________________________ Phone # ______________________ 

[at temporary residence] [at this address] 

Item # Description Appraised Value Full Replacement 

Value (if requested) 

Subtotal (this page): 

Total: 

Appraised by: 

Printed Name Signature 

Of: Company Date 

62 April 2002 
ATTACHMENT 10 

(This temporary relocation agreement must be modified to site specific circumstances. 

All residents over the age of 18 should sign this form.) 

Applicant Number: EPA/USACE Interviewer(s): 

Environmental Protection Agency 

Temporary Relocation Agreement 

This is an agreement between the United States Environmental Protection Agency (EPA), the 

United States Army Corps of Engineers (USACE), an agent of EPA, and Mr. ___________ and 

Mrs./Ms. ____________ (“Residents”), as representatives for the household located 

at__________________________________________________________. 

(address of primary residence) 

EPA has determined that a response action is necessary to [describe response action to be 

taken that warrants temporary relocation]. During the time that the response action is underway, 

[list the names of all residents living in the household who will be offered temporary relocation] 

will be offered temporary relocation. 

Residents hereby accept temporary relocation from their primary residence to [name of hotel or 

address of apartment/house], and acknowledge that any related increase in their out-of-pocket 

expenses, as described below, will be reimbursed by EPA. 

Residents agree that all household members will leave their primary residence on [date]. 

Residents understand that EPA estimates the temporary relocation will be for [X] days/weeks. 

Residents understand that they are responsible for continuing to make their mortgage/rent 

payments while they are temporarily relocated by EPA. Residents are further aware that if they 

do not continue to make these payments, some or all of their temporary relocation assistance 

may be terminated. 

Residents understand that they are responsible for continuing to make payments on their 

homeowners insurance at their primary residence. 

Residents agree to make appropriate payments to the various utility companies providing 

service to their primary residence. 

Residents understand that EPA will provide them with a list of things they should do before 

leaving their primary residences, such as disposing of garbage, removing and safely storing 

OSWER Directive 9230.0-97 63 
valuables, taking items that will be needed during temporary relocation, and turning down the 

heat, without turning it off. 

Residents also agree to abide by the rules of the motel/hotel, or the apartment management at 

the temporary residence, and understand that failure to do so may result in their being asked to 

leave and may result in a reduction of their temporary relocation assistance. In the event that 

EPA seeks to terminate the temporary relocation assistance under this program, EPA will first 

provide written notice to the residents that explains the Agency’s decision. 

At check out from the hotel, residents agree to pay for any long distance phone calls, pay per 

view television, and any other charges not covered by the basic room rate being paid by EPA. 

Residents understand that if they fail to pay these hotel expenses, EPA may withhold part of their 

temporary relocation reimbursement. 

Residents understand that they are responsible to the landlord and rental company for any 

damage to the temporary residence and rental furniture done by themselves, their family, or their 

guests. Residents understand that EPA may withhold part of their temporary relocation 

reimbursement if they fail to compensate the landlord or rental company for damages. 

Residents understand that EPA will notify them when their temporary relocation assistance will 

end. If residents choose not to return to their primary residence after that date, they are 

responsible for any additional expenses they incur. 

Residents understand that if EPA becomes aware of any potentially illegal activity at their 

primary or temporary residence, EPA will contact the appropriate authorities. 

Residents understand that if EPA determines that they purposely contributed to the 

contamination of their residence, they may not be entitled to relocation assistance. 

Residents understand that if any information they provide EPA for determining eligibility for 

assistance is found to be false, temporary relocation assistance may be terminated. Also, if 

family circumstances change while they are temporarily relocated, (e.g., the birth of a child, the 

moving out of an adult child from the temporary residence), or if they choose to sell their primary 

residence or to terminate the lease at their primary residence, residents will notify EPA. 

Residents understand that changes in the family circumstances may result in increases or 

decreases in temporary relocation assistance. 

Residents understand that, for safety reasons, they will not be able to return to their primary 

residence while they are temporarily relocated, and they should take all necessary personal 

property and records to their temporary residence. 

Residents understand that EPA will reimburse them for the following expenses: 

1.	 Rent at the temporary residence $_________ (monthly) 

(including monthly maintenance/condo fees) 

64 April 2002 
2.	 Rental deposits $_________ (one time payment) 

(If a rental deposit is returned to a resident by the landlord at the end of the temporary 

relocation, residents agree to return this deposit to EPA.) 

3.	 Utilities at the temporary address 

electric 

gas 

cable TV Total of monthly bills 

trash pickup (generally, EPA will not reimburse for 

basic telephone service late fees) 

water $__________ 

4.	 Daily meals and incidentals $__________ (daily rate) 

(for transient accommodations) 

5.	 Kenneling fees $__________(daily rate) 

6.	 Household staples $__________ (one time payment) 

(for setting up apartments/houses) 

7.	 Moving expenses $__________(two payments) 

(to and from primary residence) 

8.	 Tenant insurance $___________(as required) 

9.	 Storage fees $___________(monthly) 

(Add other appropriate reimbursements) 

Residents understand that EPA may pay for other expenses associated with the temporary 

relocation only if the expenses are approved in advance by EPA/USACE and receipts and/or 

other evidence of the expenditure are presented, and the reasons for the expense are 

documented. 

Residents understand that EPA/USACE has offered to reimburse them for any expenses 

associated with renting a safety deposit box at a hotel or bank for storing small items of value 

such as jewelry, important papers, etc. and in secured storage facilities for larger items of value 

such as televisions, VCRs, other electronic items, etc. 

Residents understand that EPA/USACE will arrange for transportation of their children from the 

motel/hotel/apartment to and from schools and that they must fill out an application for school 

bus transportation. 

Residents agree to allow EPA and/or USACE to videotape their primary residence and personal 

property before they depart and again just before they return to the residence to verify what 

property is left behind and the condition of all real and personal property. Residents also agree 

OSWER Directive 9230.0-97 65 
to sign an inventory form detailing all items to be placed in storage by EPA. Residents 

understand that they will receive a copy of the video free of charge. 

Residents understand that it is EPA’s policy to provide them an opportunity to have their disputes 

reviewed by an EPA official not involved in the disputed issue, and that they must describe their 

dispute in writing to EPA. 

As representatives of my/our household, I/we have read this agreement and understand and 

accept the terms and conditions of this temporary relocation agreement. I/we request that the 

temporary relocation assistance checks be made payable to:___________________________. 

(resident or guardian) 

Signature(s) of agreement: 

Resident(s): Date: 

Date: 

Date: 

Date: 

EPA: Date: 

USACE: Date: 

66 April 2002 
ATTACHMENT 11 

Information Needed to Apply for Relocation Assistance 

Proof of Size of Household—information that clearly documents who lives at your primary 

residence. 

A.	 First page of your two most recent tax returns 

B.	 Proof that you are receiving public assistance 

C. Medicaid/Medicare card(s) 

D. Section 8 papers 

Proof of Residency—Bring the following that apply to you: 

A.	 Copy of current lease 

B.	 Rent receipt or copies of past three months rent checks (front and back), money order 

payment stubs, or mortgage bills 

C. Name, address, and phone number of landlord/mortgage company 

D. Mail addressed to you at primary residence 

E.	 Deed of trust or sales contract for home purchase 

Homeowners or Renters Insurance Information 

a.	 Name of company and policy number 

b.	 Copy of Policy 

c.	 Copy of Declarations Sheet or other correspondence with insurance company 

d.	 All applicants who have renters’ or homeowners’ insurance may execute notice of 

claim and assignment forms (see copies attached with this package) 

Note: For additional assistance, contact your EPA contact. 

OSWER Directive 9230.0-97 67 
ATTACHMENT 12 

Application for Determining 

Superfund Temporary Relocation Assistance 

Shaded area to be filled out by EPA Please provide all applicable information 

Applicant Number: Head(s) of Household (select one or two adults to 

represent the family. This is the name of the person(s) 

that reimbursement checks will be made out to): 

Primary Residence Address: 

Verified by: 9 Utility bills, 9 Drivers license, 9 Other __________________ 

Occupancy Basis at Primary Address: Owner Tenant Living with Friend or 

Family. No rent paid 

Type of Primary Residence House Apartment Mobile Home Other 

Name and Address of Landlord/Mortgage Holder at Primary Address: 

Phone Numbers of Residents 

At Primary Address: Adult at Work: Other Adult at Work: 

Occupants at Primary Address 

Name Age Sex Relationship to 

Head(s) of Household 

1. 

2. 

3. 

4. 

5. 

Verified by: 9 Tax returns, 9 Other_______________ 

68 April 2002 
Special Needs? (e.g., handicap accessible, special provisions for health concerns) 

Hotel Needs 

(Delete if not relevant) 

Smoking: 

No / Yes 

Number of Rooms: ______ 

Adjoining Rooms: “ No “ Yes 

Explain: 

Refrigerator: “ No “ Yes 

Explain: 

EPA will provide guidelines for when multiple 

rooms may be provided 

EPA will provide guidelines for when a 

refrigerator may be provided 

How many cars/trucks do you currently have that will require parking at the temporary 

address? 

Apartment Needs 

(Delete if not necessary) 

Number of bedrooms needed: Other Needs: 

How many cars/trucks do you currently have that will require parking at the temporary 

address? 

Staying With Friends or Family 

(Delete if not necessary) 

Address of friend or family: Phone number of friend or family: 

OSWER Directive 9230.0-97 69 
Pet Needs 

Do you have pets 

that will need to be 

temporarily 

relocated? 

“ No “ Yes 

How many pets and what type? Do your pets have all their 

appropriate shots? “ No “ Yes 

You may have to verify this if the pet is 

kenneled. Be sure to bring proof. 

Do any of your pets have unique needs? (e.g., horses that require boarding) “ No “ Yes 

If yes, explain: 

Transportation Needs 

How many children do you have who will require transportation to school? _________ 

What is the name of the school(s) your children attend: 

If so, have you completed a application for school bus transportation form? “ No “ Yes 

Do you have other transportation needs? “ No “ Yes 

If yes, explain: 

(EPA will provide guidelines on which out-of-pocket expenses are eligible for reimbursement.) 

Required Furniture or Other Household Items that Must be Rented 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

10. 

EPA will provide guidelines on what may be eligible for reimbursement. Include need for 

Internet access and cable TV if you had either or both at your primary address. 

70 April 2002 
Storage of Valuables 

Would you like the use of a safety deposit box for valuables that you do not want to take with 

you to your temporary residence? “ No “ Yes 

Do you have any large expensive items (e.g., electronic equipment including TVs, VCRs, and 

stereos) that you would like to put in storage while you are staying at your temporary 

residence? “ No “ Yes 

Describe: 

Additional Information 

Other information you believe would be helpful to assist EPA in identifying appropriate 

temporary housing: 

I certify that the above information is accurate. I understand that if any information on this form 

changes, I need to inform EPA. I also understand that if EPA determines that the information on 

this form is found to be inaccurate, some or all of my temporary relocation assistance may be 

denied or withdrawn. 

Name: __________________________________________________________ 

Date: ______________________________ 

Based on nformation provided by the resident and available resources, the follow i ing

assistance will be provided to this resident/family. (To be filled out by EPA.) 

OSWER Directive 9230.0-97 71 
Applicant Number: Applicant Name(s): Applicant phone number at 

the temporary address: 

Hotel/Motel where this resident/family will stay (include room number): 

Temporary Residence Address: 

Name of resident, EPA, or USACE who signed agreements with furniture rental companies 

Kennel where the family pets are staying (Name, Address, and Phone Number): 

Name and Address of company that provided rental furniture: 

Rental furniture provided: 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

72 April 2002 
Residents will be reimbursed for the following expenses: 

Rent/Hotel/Motel Charges 

Per diem 

Furniture 

Transportation 

Phone calls 

Renter’s insurance 

Utilities 

Cable TV service 

Kennel fees 

Other (_______________) 

$________ 

$________ 

$________ 

$________ 

$________ 

$________ 

$________ 

$________ 

$________ 

$________ 

Attach assistance computation sheet and any other expense justifications 

Residents received a one-time reimbursement for household staples? No 

Amount received: $_____________ 

/ Yes / NA 

Storage provided for the following: 

Storage provided by: (Company name and address) 

Safety box provided by: (Company name and address) 

OSWER Directive 9230.0-97 73 
ATTACHMENT 13 A 

EXAMPLE 

Meals and Incidentals Computation Sheet For 

Households Offered Relocation to Hotel or Motels 

Without Cooking Facilities 

Applicant No:___________


Applicant’s Name:__________________________________________________


No. of persons age 12 and older: ________ @ $ ________ /day = _________


No. of persons age 11 and below: ________ @ $ ________ /day = _________


Total Meals and Incidental per day = $ _________ 

Pets 

No. of pets requiring boarding: ________ @ $ ________ /day = _________ 

Total Relocation Assistance per day = $ _________ 

Renter’s or Homeowner’s Insurance at primary residence: Yes/No 

Insurance Company:______________________ Policy No.________________ 

Note:This computation sheet can be used for households that were offered temporary relocation 

to hotels or motels without cooking facilities, but that decided to live with friends or families 

instead. 

74 April 2002 
ATTACHMENT 13B 

EXAMPLE 

Rental Assistance Computation Sheet 

Applicant Number: Name:


Type of Residence Rented (check one): House “ Apartment “ Mobile Home “

Monthly Expenses 

Dwelling Rent: $ 

Furniture Rent: $ 

Utilities: 

(when out-of-pocket expenses) $ 

Pet Boarding: $ 

Other: 

(e.g., cable TV and Internet access if 

applicable) $ Total 

Total Monthly Expenses: $ $ 

One-Time Expenses 

Dwelling Security Deposit: $ 

(Note: The applicant is responsible for damages to temporary residence and furniture.


The security deposit will be returned to the Government when the applicant vacates the temporary residence.)


Telephone Transfer:


(Reconnect and disconnect fees) $


Shots for Pets: $ 

One-Time Household Staples 

Replacement Expense: $ 

Moving Expenses 

(to and from temporary residence) $ 

Credit Checks $ Total


Other One-Time Expenses:


(Explain) $ $


OSWER Directive 9230.0-97 75 
ATTACHMENT 14 

EXAMPLE 

Assignment of Insurance Claim 

This Assignment of Insurance Claim (“Assignment”) is made on the ______ day of 

_________________ month, ________ year, by _____________________ (“Insured”). 

WHEREAS: 

The U.S. Environmental Protection Agency (“EPA”) found that an imminent and substantial 

endangerment to the public health, welfare or the environment was posed by the presence 

of [specify the contamination] at Insured’s property; 

Under the authority of the Comprehensive Environmental Response, Compensation, and 

Liability Act “CERCLA”, 42 U.S.C. §9601 et seq.), EPA is providing for the cleanup and 

restoration of Insured’s property and for temporary relocation of the residential occupants 

of Insured’s property; 

Regulations relevant to the provision of relocation assistance during EPA’s cleanup action 

(44 CFR § 220.4) provide that any insured applicant for relocation assistance must agree 

to repay the cost of relocation assistance to the extent that any insurance proceeds are 

available for this purpose; and 

Insured has an insurance policy (the “Policy”) with__________________________ 

Insurance Company (Policy Number: ________________), including any declarations 

thereto, which may entitle Insured to coverage for the expenses of cleanup, restoration, 

and/or relocation; 

NOW, THEREFORE, in consideration of the cleanup, restoration, and temporary relocation of 

the residents of Insured’s property, Insured assigns the Policy to EPA, under the following terms 

and conditions: 

1.	 Insured assigns to EPA all rights Insured has under the Policy, including the right to make 

demand upon the Insurer and to pursue any remedies, legal and otherwise, to the extent 

of coverage available for cleanup and restoration of the Insured’s property and for 

temporary relocation of the residential occupants of the Insured’s property. 

2.	 This assignment must be limited to the amount spent by EPA for cleanup and restoration 

of Insured’s property and for relocation assistance to residential occupants of Insured’s 

property. 

3.	 Insured authorizes the above-named insurance company, and its successors and


assigns, to make payments due to EPA under the Policy.


76 April 2002 
______________________________________ 

______________________________________ 

______________________________________ 

4.	 Insured agrees to provide to EPA a copy of the Policy and copies of any other


correspondence with that insurance company relating to claims arising from the


presence of [specify the contamination] at Insured’s property.


5.	 Insured agrees to cooperate with EPA in EPA’s attempt to pursue any insurance claim 

assigned to EPA pursuant to this Assignment. This cooperation includes signing a letter 

prepared by EPA for the purpose of notifying the insurance company of a claim under the 

Policy, and also includes signing any other documents necessary or useful to 

accomplish this Assignment or collect any assistance in connection with it. 

AGREED: 

Signature (Insured) 

Print Name 

Date 

OSWER Directive 9230.0-97 77 
__________________________________ 

ATTACHMENT 15 

Sample Insurance Claim Letter to Insurance Company 

Insurance Company Address: 

Attn: Claims Department 

Re: Policy Number _____________________________ 

Dear Sir or Madam: 

This letter notifies you of a claim under my (homeowners) (renters) (company name) 

insurance policy based on the presence of [specify the contamination], at my property at 

[address]. The U. S. Environmental Protection Agency 

(EPA) has determined that the presence of contamination at my property poses an imminent 

and substantial endangerment to the public health, welfare or the environment. 

EPA is carrying out a response action at my property. EPA’s response action involves the 

cleanup and restoration of my property, and the provision of temporary relocation assistance to 

residential occupants of my property. Accordingly, I have assigned my rights under the abovereferenced policy to EPA to the extent of coverage available for cleanup and restoration of my 

property and for temporary relocation of the residential occupants of my property. Please direct 

copies of any correspondence concerning this claim to: 

United States Environmental Protection Agency 

Region XX 

Address 

Thank you. 

Sincerely, 

(Name) (Insured) 

78 April 2002 
ATTACHMENT 16 

Example of Hotel Rules 

If you are temporarily relocated to a hotel or motel, you should be aware of some typical hotel 

policies that will make your hotel stay more comfortable. The U.S. Environmental Protection 

Agency (EPA) appreciates your cooperation throughout your temporary relocation period. 

•	 Please be courteous to all other guests in the hotel. No loud music or noise is allowed in 

guest rooms or in public areas. 

•	 All children must be accompanied by an adult or guardian at all times. No running or 

playing is permitted in the hallways or public areas. 

•	 You will be responsible for paying the hotel for long-distance telephone calls, bar bills and 

room service. EPA will reimburse you for any hotel fees associated with outgoing local 

calls. Incoming phone calls are free. You may need to ask the hotel’s front desk to 

activate your telephone. 

•	 No pets or animals are allowed inside or outside of the hotel unless permission is given 

from the hotel management. 

•	 Cooking or food preparation is not allowed inside hotel rooms. Hot plates, microwave 

ovens, or other cooking devices are not permitted. Before outdoor barbecue grilling, 

please check with the hotel management to see if it is permitted. 

•	 No extra furniture is allowed in hotel rooms unless you have obtained permission from 

the hotel management. 

•	 Please observe all “No Smoking” signs in public areas, and do not smoke in non­


smoking rooms.


•	 Housekeeping service is provided in most hotels; however, you are still responsible for 

the general condition of your room. You must allow the housekeeping attendant to enter 

the room daily to clean and provide fresh linens. 

•	 Please leave wet towels and dirty bed linens in your hotel room. Do not place these items 

in the hallway. The housekeeping service will pick up these items daily during their 

rounds. 

•	 You are responsible for any damage that occurs in your room during your temporary 

relocation, such as broken furniture and staining of carpets or linens. If the hotel charges 

a replacement fee for these items, you will be responsible for paying it directly to the 

hotel. 

OSWER Directive 9230.0-97 79 
•	 Please put litter in appropriate trash containers. Trash cans are provided in the laundry 

rooms, and dumpsters are located outside the building. If you have excess trash in your 

room, leave it in the wastebasket in your room or take it to a dumpster. Do not leave it in 

the hallway. 

•	 Many hotels have swimming pools that may or may not have lifeguards in attendance. 

Please observe the hotel rules for use of the pool. Also check at the main desk of your 

hotel or motel to see if you need to pay a fee to use the pool or other recreational 

facilities. 

•	 There may be an additional charge for any persons staying with you in your room who 

were not members of your household on the date of your relocation. EPA will not pay this 

extra charge. 

•	 When your temporary relocation ends, you must check out of the hotel. On the day that 

you leave, go to the main desk and inform the clerk that you are checking out. Give the 

desk clerk the keys to all rooms used by you and your family. 

•	 Please keep in mind that you are required to pay for any additional charges to your hotel 

room (such as room service, video rentals, or pay-per-view television events). 

•	 EPA has hired a 24-hour security guard at some of the hotels. To reach the security 

guard, please call the front desk of the hotel. 

PLEASE NOTE: Any complaints that EPA receives from the hotel management about any 

resident could result in your eviction from the hotel. If you are asked to leave the hotel for any 

reason, EPA will not provide you with another hotel and your relocation assistance may be 

terminated. Anyone engaged in illegal activity may be removed from EPA’s temporary relocation 

program. 

I have read and agree to comply with this list of hotel rules, and any other rules imposed by the 

hotel at which I am staying during my temporary relocation. 

Resident Signature	 Date: 

Resident Signature	 Date: 

80 April 2002 
ATTACHMENT 17 

General Packing Instructions 

(Modify for relocations to transient housing) 

If U.S. Environmental Protection Agency (EPA) is temporarily relocating you to a furnished 

apartment, you will need to pack up your belongings in a special way. In addition, there are a 

number of personal items you will need to bring with you to use in the apartment. 

Pack the belongings you won’t need during the cleanup for storage. Clearly mark these boxes 

and bags with the word “STORAGE.” Remember, once you pack these items and the cleanup 

begins, you cannot get to them until the cleanup is finished. Once you close and seal your 

boxes, EPA and its workers will not open them. 

Pack everything you are going to need while you are in your temporary furnished apartment 

separately. Place the items that you will need to take to the temporary apartment (an example 

list is provided below) in boxes or bags and clearly mark them with the word “APARTMENT.” All 

boxes also should be numbered (e.g., 1 out of 8) and include your name. If EPA provides you 

with pre-printed labels to mark your boxes or bags, please use them. 

You will remain in the apartment until the cleanup and restoration of your residence is complete. 

During your stay in the furnished apartment, EPA will provide you with essential furniture. 

Items Provided to You in Your Furnished Apartment: 

EPA will ensure that the following items are provided for you in your furnished apartment: one 

sofa, one living room chair, one coffee table, two end tables, two table lamps, one dining table 

with dining chairs, one range, one refrigerator, one bed and chest of drawers per person as 

needed, one night table and table lamp in each bedroom, one television, and one alarm clock. 

Items You Might Want to Bring to the Apartment: 

•	 Bed linens (sheets, pillowcases, and comforters) 

•	 Towels and wash cloths (kitchen and bathroom) 

•	 Toiletries (shampoo, soaps, makeup, hair dryers), and personal items (hair and


toothbrushes)


•	 Non-perishable foods that you are sure are not contaminated (flour, sugar, and spices) 

•	 Clothing you will need for your stay 

•	 Microwave, can opener, or other small appliances 

•	 Electronic items (TV, clocks, computers, VCR, and stereo) 

•	 Cleaning items (vacuum and dish soap) 

•	 Important medical and/or legal documents, including birth certificates, passports, wills, 

school registration forms, proof of pet vaccinations, and information to file tax returns if 

the relocation will extend beyond April 15. 

•	 Laundry supplies (clothes basket, soap, and fabric softener) 

•	 Valuables, jewelry, and sentimental items 

•	 Plants 

•	 Cooking and eating utensils 

OSWER Directive 9230.0-97 81 
______________________________ ______________________________ 

ATTACHMENT 18 

EXAMPLE 

Check Receipt Acknowledgment Form 

U.S. Environmental Protection Agency 

Applicant No. __________	 Date: ___________ 

I agree to vacate the premises at ______________(address)____________________ 

beginning on _______(date)____________ until the end of the decontamination process on my 

home. 

I elect to stay at the __________________________________________________ 

in accommodations provided by EPA. Accordingly, I agree to receive a food allowance of 

$______________ per day (see EPA’s Temporary Relocation Agreement–Attachment 10) for 

me and my family. I understand that if my eligibility for certain assistance changes, those 

changes may increase or decrease my payments. Relocation assistance will end on the date on 

which I re-enter my home or for any other reason listed on the Grounds for Termination of 

Relocation Assistance document that I have signed. 

Total allowance for this period is $___________ (check # ________). This covers the period 

from _____________ through ___________________, which is a total of _________ days. 

Interviewer	 Applicant (Print) 

Date: _______________	 _______________________________ 

Applicant’s Signature 

82 April 2002 
ATTACHMENT 19 

EXAMPLE 

Application for School Bus Transportation 

The U.S. Environmental Protection Agency (EPA), through its contractors, provides school bus 

transportation for children who are relocated in homes and apartments while their homes are 

being cleaned and restored. There is no charge for this service. 

If you would like to provide your own school transportation for your children instead, you must get 

pre-approval from EPA. If approved, EPA will reimburse you for miles traveled at $___ per mile. 

Please contact [Temporary Relocation Team Contact] at [telephone] if you are interested in this 

option. 

To apply for EPA-provided bus service, please provide the following information by (Date). 

NOTE: For young children, EPA may require that a parent/legal guardian, or an alternate adult 

approved by the parent/legal guardian, deliver the child to the school bus and receive the child 

from the school bus each day. This person will be required to sign a sheet when the child boards 

the bus for school in the morning and when the child gets off the bus after school in the 

afternoon. Many states have laws that hold parents responsible for the supervision of their 

children. Check the state laws to determine at what age children can board and get off the school 

bus without adult supervision. 

Children Needing School Bus Transportation 

Child’s Name: Age: 

School Name: School Year: ____/____/____ thru ____/____/____ 

Time School Starts: Time School Ends: 

Special Instructions For This Child: 

Child’s Name: Age: 

School Name: School Year: ____/____/____ thru ____/____/____ 

Time School Starts: Time School Ends: 

Special Instructions For This Child: 

OSWER Directive 9230.0-97 83 
Child’s Name: Age: 

School Name: School Year: ____/____/____ thru ____/____/____ 

Time School Starts: Time School Ends: 

Special Instructions For This Child: 

Parents or Legal Guardian 

Name: Relationship to Child: 

Permanent Address: 

Temporary Address: 

Daytime Phone: Evening Phone: 

Name: Relationship to Child: 

Permanent Address: 

Temporary Address: 

Daytime Phone: Evening Phone: 

Alternate Adults Approved to 

Deliver Your Children to and Pick Up Your Children from the School Bus 

Name: Daytime Phone: 

Work Phone: 

Name: Daytime Phone: 

Work Phone: 

Name: Daytime Phone: 

Work 

The school transportation service provided includes a school bus or van, driver, and a security 

guard. 

84 April 2002 
I understand that the transportation provided is contingent upon good behavior by my 

child/children riding on the school bus and that my child/children must follow instructions from 

the school bus driver and/or security guard while using the transportation service. 

I further understand that if my child/children misbehaves, or if there are difficulties with receiving 

my child/children from a responsible adult or delivering my child/children to a responsible adult, 

this service will be terminated and I will be responsible for school transportation for such 

child/children. 

Name of Parent or Guardian:


(please print)


Signature of Parent or Guardian: 

Date: 

Witness Signature: 

(Regions should take great care to make sure standards are in place when selecting 

drivers and vans. Bus driver qualifications and standards are established by state and 

federal regulations. All drivers must comply with federal regulations and any state 

regulations that exceed federal requirements. At a minimum, the Team should insist 

that school bus drivers pass a background investigation to uncover any criminal 

convictions or history of mental illness. Drivers must not have been convicted of a felony 

involving the use of a motor vehicle; a crime involving drugs; or driving under the 

influence of drugs or alcohol. The Team may want to consult with the local school board 

for additional advice.) 

OSWER Directive 9230.0-97 85 
ATTACHMENT 20 

Public Housing 101—


Section 8 Housing Choice Voucher Program


The U.S. Department of Housing and Urban Development (HUD) implements a Section 8 

Housing Choice Voucher program, which is a housing assistance payment program that may 

affect EPA’s actions when relocating public housing residents because of a Superfund response 

action. The program assists very low-income families, the elderly, and the disabled to afford 

decent, safe, and sanitary housing in the private market. HUD used to implement a Rental 

Certificate Program as well, but this program is no longer offered by HUD. 

Housing choice vouchers are administered locally by public housing agencies (PHAs) using 

federal funds from HUD. A family that is issued a housing voucher is responsible for finding a 

suitable housing unit of their choice whose owner agrees to rent under the program. Under the 

Housing Choice Voucher program, housing choices are not limited to units located in subsidized 

housing projects, and can include privately owned single-family homes, townhouses, and 

apartments. The housing choice may include the family's present residence. Rental units must 

meet minimum standards of health and safety, as determined by the PHA.1 

Eligibility for a housing voucher is determined by the PHA based on the total annual gross 

income and family size and is limited to U.S. citizens and specified categories of non-citizens 

who have eligible immigration status. In general, the family's income may not exceed 50% of the 

median income for the county or metropolitan area in which the family chooses to live. By law, a 

PHA must provide 75 percent of its vouchers to applicants whose incomes do not exceed 30 

percent of the area median income. Median income levels are published by HUD and vary by 

location. The PHA serving your community can provide you with the income limits for your area 

and family size. 

The PHA determines a payment standard that is the amount generally needed to rent a 

moderately-priced dwelling unit in the local housing market and that is used to calculate the 

amount of housing assistance a family will receive. However the payment standard does not 

limit and does not affect the amount of rent a landlord may charge or the family may pay. A 

family that receives a housing voucher can select a unit with a rent that is below or above the 

payment standard. The housing voucher family must pay 30% of its monthly adjusted gross 

income for rent and utilities, and if the unit rent is greater than the payment standard the family is 

required to pay the additional amount. By law, whenever a family moves to a new unit where the 

rent exceeds the payment standard, the family may not pay more than 40 percent of its adjusted 

monthly income for rent. 

1 The Housing Authority is committed to ensuring that the homes built, managed, or rehabilitated under 

its programs provide suitable, safe, and secure places for families to live. To meet these objectives, the Housing 

Authority has adopted Housing Quality Standards that establish a minimum threshold for the condition of all 

housing under its programs. Standards include annual inspections of all units, including units under the Mutual 

Help, Low Rent, and Section 8 programs; annual re-certification of resident incomes; and provision of resident 

services and counseling. 

86 April 2002 
A housing subsidy is paid to the landlord directly by the PHA on behalf of the participating family. 

The family then pays the difference between the actual rent charged by the landlord and the 

amount subsidized by the program. The PHA calculates the maximum amount of housing 

assistance allowable. The maximum housing assistance is generally the lesser of the payment 

standard minus 30% of the family's monthly adjusted gross income or the rent for the unit minus 

30% of monthly adjusted income. 

For more information on HUD’s Section 8 Housing Choice Program, go to: 

http://www.hud.gov/offices/pih/programs/hcv/about/fact_sheet.cfm. 

OSWER Directive 9230.0-97 87 
ATTACHMENT 21 

EXAMPLE 

ENDING TEMPORARY RELOCATION ASSISTANCE 

[Date] 

[EPA Address] 

Dear [Occupant's Name]: 

This letter is to inform you that EPA has almost completed (decontamination/excavation/other 

response action) affecting your residence at [address of primary residence] and has determined that 

your home will be safe to reoccupy on [date] . Throughout the cleanup and restoration process, 

U.S. EPA has provided certain assistance to you and your family while you have been temporarily 

relocated. Since you will be able to re-occupy you home, the assistance provided to you as part of 

U.S. EPA’s response action will be stopped on [date] at [time] a.m./p.m. 

Because your temporary housing assistance will end on ______, you are expected to move out of 

the temporary housing unit located at ________________ on or before the above-mentioned date. 

If you decide to remain in the unit beyond that date, you will have to make arrangements with the 

owner/agent. EPA will not reimburse you for any rental charges incurred after the date mentioned 

above. A move-out inspection is required, at which time you should return the keys to the 

residence. An EPA representative will contact you in the near future to review procedures for 

returning possession of the unit to EPA and to schedule a move-out inspection. 

If you have been provided with furniture by EPA for your temporary housing, an EPA 

representative will contact you to discuss arrangements for the return of that furniture. If your own 

furniture has been in storage, or if you have your own furniture with you at your temporary 

residence, EPA will arrange to have it delivered to your primary residence before the date you reoccupy the residence. 

If you wish to dispute the end of this assistance, you have the right to present your dispute to EPA 

within XX (fill in a reasonable period of time that makes sense for the project deadlines) business days from 

the receipt of this letter. Your dispute must be a signed, written statement explaining why the 

assistance should not be ended. If EPA does not receive your dispute within XX business days, 

your assistance will be ended on the date provided above. Additional information is available on 

EPA’s dispute process. Please address your dispute to: 

Temporary Relocation Team Contact 

[Address] 

If you have any questions, please contact [name] at [telephone number] . 

Sincerely,


Temporary Relocation Coordinator


Enclosure 

88 April 2002 
ATTACHMENT 22 

List of Related Documents 

Comprehensive Environmental Response, Compensation, and Liability Act, 42 USC Chapter 

103. 

A Guide to Preparing Superfund Proposed Plans, Records of Decisions, and Other Remedy 

Selection Decision Documents, EPA 540-R-98-031, EPA Directive 9200.1-23P, July 1999. 

“Early and Meaningful Community Involvement” October 12, 2001, EPA Directive 9230.0-99


Interim Policy on Use of Permanent Relocations as Part of Superfund Remedial Actions, EPA


540-F-98-033, EPA Directive 9355.0-71P, June 1999.


National Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300.


Negotiation and Enforcement Strategies to Achieve Timely Settlement and Implementation of


Remedial Design/Remedial Action at Superfund Sites [memorandum], OECA, June 17, 1999.


On-Scene Coordinators Toolbox Guide, EPA 540-K-00-003, EPA Directive 9242.2-12.


Response Actions That Affect Residential or Commercial Structures, EPA 540-F-98-029, EPA


Directive 9360.3-20, May 1998.


Response Actions at Sites with Contamination Inside Buildings, EPA Directive 9360.3-12,


August 1993.


Risk Assessment Guidance for Superfund: Volume 1— Human Health Evaluation Manual, 

Supplement to Part A: Community Involvement in Superfund Risk Assessments, EPA 540-R98-042, EPA Directive 9285.7-01E-P, March 1999. 

Superfund Removal Procedures: Public Participation Guidance for On-Scene Coordinators: 

Community Relations and the Administrative Record, EPA Directive 9360.3-05, July 1992. 

Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, Public Law 

91-646. 

Uniform Relocation Assistance and Real Property Acquisition Policies for Federal and Federally 

Assisted Programs, 42 USC Chapter 61, 49 CFR Part 24. 

OSWER Directive 9230.0-97 89 
ATTACHMENT 23 

List of Acronyms 

AA Assistant Administrator 

ATSDR Agency for Toxic Substances and Disease Registry 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 

1980 (Public Law 96-510) 

CFR Code of Federal Regulations 

CIC Community Involvement Coordinator (EPA) 

DOT Department of Transportation 

ERRS Emergency and Rapid Response Services 

FEMA Federal Emergency Management Agency 

FMR Fair Market Rent 

IAG Interagency Agreement 

MOU Memorandum of Understanding 

OECA Office of Enforcement and Compliance Assurance 

OERR Office of Emergency and Remedial Response (EPA Headquarters) 

OGC Office of General Counsel 

ORC Office of Regional Counsel 

OSC On-Scene Coordinator (EPA) 

OSWER Office of Solid Waste and Emergency Response 

PRP Potentially Responsible Party 

RPM EPA Remedial Project Manager 

SATA Superfund Analytical Technical Assistance (contractor) 

SOW Statement of Work 

START Superfund Technical Assistance and Response Team 

URA Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 

(Public Law 91-646) 

USACE United States Army Corps of Engineers 

U.S. EPA United States Environmental Protection Agency 

90 April 2002