MEMORANDUM OF UNDERSTANDING

BETWEEN THE

NATIONAL POLLUTION FUNDS CENTER

UNITED STATES COAST GUARD

AND THE

OFFICE OF RESPONSE AND RESTORATION

NATIONAL OCEAN SERVICE

NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION

U.S. DEPARTMENT OF COMMERCE

FOR FUNDING AND REIMBURSEMENT IN SUPPORT OF

FEDERAL ON-SCENE COORDINATORS

FOR OIL AND/OR HAZARDOUS SUBSTANCE REMOVAL AND

FEDERAL TRUSTEES TO INITIATE ASSESSMENT OF NATURAL

RESOURCE DAMAGES

NOS Agreement Code: MOA-2020-103/12022

USCG Agreement Code: 
I. PARTIES AND PURPOSE

A. This multi-year Memorandum of Understanding is between the National Pollution Funds Center 

(NPFC), U.S. Coast Guard (USCG), and through the Office of Response and Restoration (OR&R), 

National Ocean Service (NOS), National Oceanic and Atmospheric Administration (NOAA), U.S. 

Department of Commerce (DOC). This MOU supersedes the MOU executed on September 27, 

2013.

B. The USCG is responsible for ensuring removal of oil discharges and/or hazardous substance 

releases in the coastal zones. Upon request by the USCG Federal On-Scene Coordinator (FOSC), 

the NOAA Scientific Support Coordinator (SSC) provides support services related to scientific 

issues affecting the removal. NOAA may also provide other services to the FOSC during a removal 

as a member of the Regional Response Team (RRT). This Agreement identifies the cost 

reimbursement protocols for those activities under the National Contingency Plan for which NPFC 

provides funding using the OSLTF (oil) or using amounts provided to USCG via Superfund

(hazardous substances).

C. NOAA is responsible for assessing natural resource damages to resources under their trusteeship 

resulting from oil pollution incidents and developing and implementing plans for the restoration, 

rehabilitation, replacement, or acquisition of the equivalent, of those damaged resources. This 

Agreement also addresses the procedures for NOAA to request funding from the OSLTF 

Emergency Fund to initiate Natural Resource Damage Assessment activities in respect to Oil 

Pollution Act (OPA) incidents.

II. BACKGROUND

The USCG and NOAA have developed an effective partnership for responding to discharges of oil, 

releases of hazardous substances, and other emergency incidents in navigable waters of the United 

States. Under the National Contingency Plan (NCP), the USCG generally has lead federal responsibility 

to direct removal efforts and coordinate all other efforts at the scene of a discharge or threat of discharge 

of oil or a hazardous substance in the coastal zone. NOAA has responsibility under the NCP to provide 

scientific support to the USCG in the discharge of its responsibilities, playing a critical role in providing 

key data, analysis, and predictions for oil and hazardous substances removal. For example, NOAA 

provides data on the sensitivity of resources at risk, analysis of potential removal alternatives, and 

predictions of the fate and trajectory of released substances.

III. AUTHORITIES

A. The authorities for NOAA to enter into this Agreement are:

1. Public Law 102-567 authorizes the types of allowable costs to be reimbursed to NOAA 

for spill response. The allowable costs include incremental and base salaries, ships, 

aircraft, and associated indirect costs. Allowable costs do not include base salaries and 

benefits of NOAA SSCs.
2. NOAA also has authority as a designated natural resource trustee to act pursuant to 

section 1006 of the Oil Pollution Act (OPA), 33 U.S.C. 2701 et seq., when there is injury 

to, destruction of, loss of, or threat to natural resources, including their supporting 

ecosystems, as a result of a discharge of oil.

B. The authorities for the USCG to enter into this Agreement are:

1. 40 CFR §300.145 provides for the FOSC to request and utilize a NOAA SSC as the 

principal advisor for scientific issues, communication with the scientific community, and 

coordination of requests for assistance from state and Federal agencies regarding 

scientific studies in the coastal zone. Where the FOSC requests assistance from OR&R 

under this paragraph or other provisions of this Agreement, the Parties will execute a 

Pollution Removal Funding Authorization (PRFA) (NPFC Technical Operating 

Procedures, Ch. 3) to govern reimbursement. 

2. Under 40 CFR §300.322(c)(3), the USCG or RRT shall dispatch appropriate personnel 

to the scene of the discharge to assist the FOSC upon request. This assistance may include 

technical support in the agency's areas of expertise and disseminating information to the 

public. Where the FOSC requests assistance from OR&R under this paragraph or other 

provisions of this Agreement, the Parties will execute a Pollution Removal Funding 

Authorization (PRFA) (NPFC Technical Operating Procedures, Ch. 3) to govern 

reimbursement.

3. USCG is the fiduciary for the Oil Spill Liability Trust Fund (OSLTF) established under 

Title 26 USC §9509. OPA and Presidential delegation have assigned management of 

certain uses of the OSLTF to the USCG NPFC, including use of amounts made available 

pursuant to 33 USC §2752(b) to carry out 33 USC 1321(c) and to initiate the assessment 

of natural resource damages.

4. Section 104 of the Comprehensive Environmental Response, Compensation and 

Liability Act of 1980 (CERCLA) authorizes the President to act ". . . whenever (a) any 

hazardous substance is released or there is a substantial threat of such a release into the 

environment, or (b) there is a release or substantial threat of release into the environment 

of any pollutant or contaminant which may present an imminent and substantial danger 

to the public health or welfare... "Superfund is the source of funds for CERCLA removal 

costs incurred by the USCG. Such costs are reimbursed by the EPA via interagency 

agreements between the EPA and USCG. The agreement and applicable instrument of 

redelegation covers costs incurred by the USCG in carrying out functions related to 

immediate removal actions at facilities and responses to releases or threats of releases 

from vessels. Costs incurred by OR&R under CERCLA in support of the USCG are 

covered through this Agreement; OR&R’s costs are reimbursed by the USCG via 

reimbursable agreement.

5. The Robert T. Stafford Disaster Relief and Emergency Assistance Act: 44 CFR § 206.2 

(18). An ESF-10 work order issued to the Coast Guard by the FEMA Regional 

Administrator, FEMA Assistant Administrator for the Disaster Operations Directorate, 
or FEMA Administrator, directing completion by that agency of a specified task and 

citing funding, other managerial controls, and guidance.

6. Chapter 2 (Removal Actions-Oil & HAZMAT) of the National Pollution Funds Center 

User Reference Guide provides guidance on the use of the OSLTF and Superfund, along 

with applicable regulations and background information. The NPFC User Reference 

Guide (eURG) can be found at https://www.uscg.mil/Mariners/National-PollutionFunds-Center/URG/.

IV. TERMS AND CONDITIONS

A. Removal Activities

Reimbursements for Removal Activities will be handled via PRFAs. “See Section V. Pollution 

Removal Funding Authorization.”

OR&R may provide the following support, consistent with the NCP, to an oil or hazardous 

substances spill when requested by the FOSC:

1. Scientific Support Team (SST) Support

Depending upon the magnitude of the spill, OR&R Emergency Response Division (ERD)

SSCs can be supported by a Scientific Support Team (SST). The expertise of the SST 

includes oil spill tracking; pollutant transport modeling; biological assessments; evaluation 

of environmental tradeoffs resulting from specific countermeasures and cleanup

techniques; assessment of natural resources at risk; environmental chemistry; chemical 

hazard assessment; weather conditions and predictions, health and safety; and information 

management. The team may also be augmented by other Federal, state, or academic experts 

and is tailored to the specific scientific requirements of the incident and the local expertise 

available. During the removal the SSC and members of the SST work closely with the 

FOSC staff, USCG or EPA personnel, and other removal personnel to provide scientific 

advice and other technical guidance. The SSC and specific members of the OR&R SST 

can serve in many of the standard Incident Command System positions as referenced in the 

USCG's Incident Management Handbook (COMDTPUB P3120.17B series). The SSC will 

recommend the number of team members for each level and type of removal.

2. Other Support Services From OR&R

NOAA data and resources to support a removal may be requested by the FOSC from the 

Department of Commerce (DOC) RRT representative through the SSC or through the RRT 

Co-chairs. This support might include tide and circulation information; nautical charts; 

satellite imagery; meteorological, hydrologic, ice, and oceanographic data for marine, 

coastal, and certain inland waters; navigation response teams, information and field support 

regarding marine fisheries, marine mammals, seafood safety and certain endangered 

species from NOAA's National Marine Fisheries Service; personnel and technical support 

from NOAA's National Marine Sanctuaries; use of the NOAA ResponseLink and/or 

ERMA (Emergency Response Management Application) information system and National 

Weather Service communications networks; special-purpose aircraft and/or ships; and 

other staffing and expertise within NOAA.
B. Initiating Natural Resource Damage Assessment Activities under OPA

Reimbursements for Natural Resource Damage Assessment (NRDA) activities will be 

handled via Inter-Agency Agreements (IAA). 

Pursuant to OPA and other applicable laws and regulations, NOAA and NPFC will enter

into IAAs that provide obligations and subsequent reimbursement of costs incurred by 

NOAA to conduct NRDA initiate activities, from available amounts managed by NPFC. 

These costs associated with NRDA activities must be incident specific and agreed to in 

advance through the signed IAA. The specific conditions and requirements for 

reimbursement and changing the obligated amounts are outlined in the IAA. For additional 

information please see Section VI. 

C. USCG agrees to provide funding to cover the costs associated with the above. The following fiscal 

and accounting data applies. 

USCG NOAA

DUNS No.: 806754677 DUNS No.: 78-4769085

Employer ID: 54-6010204 Employer ID: 52-0821608 

OMB MAX Code: 024-60-8349 OMB MAX Code: 006-48

Agency Location Code: 70-06000 Agency Location Code: 13-14-0001

Appropriation Code (for billing): 70x8349 Appropriation Code (for collection): 13x1450

BETC Code: DISB BETC Code: COLL

V. POLLUTION REMOVAL FUNDING AUTHORIZATION (PRFA)

The PRFA is a tool available to FOSCs for quickly obtaining needed removal services and 

assistance from other government agencies in oil spill and/or hazardous materials removal actions. 

Appendix A includes detailed procedures for processing PRFAs. Using a PRFA, the FOSC 

authorizes reimbursement to NOAA for services, equipment, and other support that were requested 

and approved by the FOSC. The OR&R SSC or DOC RRT member will ensure the requested 

services and other support are specified in the Scope of Work attachment to an FOSC approved 

PRFA prior to providing such services and other support. PRFA general terms follow: 

A. Non-Reimbursable Costs 

1. OR&R will not seek reimbursement for costs associated with team members who 

do not serve FOSC approved removal functions. Information about the specifics 

of an incident is often sketchy during the first hours of a removal. In these 

situations, OR&R sometimes assembles and dispatches a team before the exact 

nature of the removal is known. This is the best way to ensure that the FOSC has 

timely support during major spills. However, when team members are sent who do 

not fit the removal needs (not approved or requested by the FOSC), OR&R will 

immediately demobilize those SST members.

2. OR&R will not seek reimbursement for the associated costs to send personnel to 

participate in the removal who are in a training status.
3. OR&R will not seek reimbursement for SSC regular salary costs.

4. OR&R will not seek reimbursement for other support services from OR&R or 

participation by the DOC RRT Member that were not FOSC requested or FOSC 

approved.

B. Reimbursable Costs

Costs of FOSC approved support services to be reimbursed include, but are not limited 

to:

1. Personnel salary costs (excluding the SSC regular salary), including regular salary, 

overtime, compensatory time, and, if applicable, holiday pay and hazardous duty 

pay;

2. OR&R overhead costs for labor (distribution rates including divisional overheads) 

as determined annually by the NOAA Comptroller and NOAA accountants;

3. Travel and per diem expenses;

4. Established charges for using NOAA-owned aircraft, ships, and associated indirect 

costs;

5. Actual costs of NOAA contractors performing activities approved by the FOSC.

6. Costs of NOAA Business Services Group (BSG) to track costs and prepare NOAA 

cost documentation for submittal to NPFC.

7. Actual expenses certified by the FOSC and payment authorized by NPFC as 

removal costs.

C. Incident Cost Documentation File

1. NOAA's Business Services Group (BSG) will maintain each incident's cost 

documentation file in accordance with Appendix C. BSG is responsible for all 

budget and fiscal matters related to NOAA RRT members, SSCs, SSTs and other 

NOAA components supporting a removal.

2. The cost documentation file will include both reimbursable and non-reimbursable 

costs. Reimbursable costs include costs for personnel who are not normally 

available for oil spill removal, premium pay (overtime, hazardous duty pay, etc.) 

for all personnel working at an incident, travel vouchers, contractor invoices, and 

other charges related to an incident. The cost documentation will also include costs 

that are recoverable from a responsible party, but not reimbursable to OR&R, such 

as regular salary costs associated with SSCs.

3. BSG will provide a status report of OR&R costs by incident to NPFC for all 

incidents for the current fiscal year upon request.
D. Equipment

1. NOAA personnel should only purchase property with OSLTF funds when 

operational necessity directly related to the removal dictates or when it is clearly 

more beneficial to the Government than leasing. When making decisions to buy 

versus lease property, and operational conditions permit, personnel should factor 

in the costs necessary to acquire, maintain, and dispose of the property, not just the 

purchase price versus the costs of leasing. Many of these considerations are 

appropriately addressed through the planning process before a spill occurs. 

Documentation of the factors considered in purchasing property during a spill is 

critical in cost recovery and litigation efforts and shall be documented to the 

greatest extent possible.

2. NOAA personnel should be aware that property purchased for removal activities 

will be billed to the Responsible Party (RP) at 100% of the cost. Accordingly, 

whenever feasible, the FOSC and NOAA should provide the RP the opportunity 

to purchase or otherwise directly supply the property needed for removal activities. 

Upon case completion, any property purchased and provided by the responsible 

party shall be returned to the responsible party. Property purchased with the 

OSLTF, however, shall be disposed of in accordance with the procedures outlined 

below and with NPFC Removal Technical Operating Procedures.

3. NOAA may request reimbursement for repair or replacement of equipment that is 

damaged or lost during an incident. The request should describe the cause of the 

loss, and any efforts to avoid or minimize damage. The request will be submitted 

to NPFC via the FOSC. The FOSC will comment on the request and forward it to 

the NPFC. The NPFC will consider the merits of reimbursement for repairing or 

replacing the damaged or lost equipment on a case-by-case basis. Reimbursement 

will not be allowed for equipment that is damaged as a result of normal wear-andtear, neglect, alteration, or improper use, including failure to follow instructions 

for operation, maintenance, and use under specific environmental conditions 

prescribed in the equipment manuals. NOAA will not seek reimbursement for use 

of an item or equipment when the equipment's replacement is also reimbursed.

4. Consumable equipment remaining at the completion of removal action should be 

disposed of in a cost-effective manner. Multiple items of consumable equipment 

in lots having a cost per lot of over $2,500 shall be treated as non-consumables. 

NOAA shall forward to NPFC documentation such as Form DD-1348 or other 

evidence of disposal/disposition action taken for all non-consumable equipment 

and consumables in lots worth more than $2,500. Non-consumable equipment 

includes items costing over $2,500 and items of lower cost but high interest (e.g., 

radios, cellular phones, computers; copiers, photographic equipment, protective 

clothing, test equipment). Costs, including shipping and transportation costs, for 

disposal/disposition, are reimbursable via the PRFA.
E. Cost Documentation

A copy of-the cost documentation to support the charges will be provided to the 

Incident NPFC Case Officer, when requested (See Appendix C).

F. Billing

To obtain reimbursement for eligible costs, OR&R will present a bill to the FOSC with 

a copy to the NPFC (See Appendix A for procedures).

VI. Inter-Agency Agreements to Initiate Funding for Natural Resources Damage 

Assessment

Section 6002(b) of OPA provides that the OSLTF Emergency Fund is available "to initiate the 

assessment of natural resource damages" following OPA incidents. Per Executive Order 12777, 

this funding is available only to federal trustees; state and tribal Trustees seeking IAA funding must 

work through the Federal Lead Administrative Trustee (FLAT). This Executive Order also 

introduced the "FLAT" concept to provide a focal point for addressing natural resource issues 

associated with a specific incident.

Federal trustees include the Departments of the Interior, Commerce, Agriculture, Defense, and 

Energy. 

When NOAA is serving as the FLAT, NPFC will provide initiate funding through an IAA that 

obligates funds for specific assessment activities (e.g., Trustees Labor, Contractor Costs, Data 

Collection, etc.). Upon completion of the activities, NOAA will provide the NPFC with 

documentation of costs incurred by activity and category (e.g., agency labor, travel, contracts, 

purchases, and government equipment). The NPFC will then reimburse those costs that are 

documented appropriately and found to be compensable under OPA.

A. Non-Reimbursable Costs

Costs that are outside the scope of the IAA, or otherwise not associated with NRDAs, including 

costs of activities in support of the FOSC removal actions, litigation, negotiations with the 

responsible party, training, or any activities that are not necessary to complete the NRDA will not 

be recoverable under the IAA.

B. Reimbursable Costs

Categories of costs for IAA activities to be reimbursed include, but are not limited to:

1. Personnel salary costs, including regular salary, overtime, compensatory time, and, 

if applicable, holiday pay and hazardous duty pay;

2. OR&R overhead costs for labor (distribution rates including divisional overheads) 

as determined annually by the NOAA Comptroller and NOAA accountants;
3. Travel and per diem expenses;

4. Established charges for using NOAA-owned aircraft, ships, and associated indirect 

costs;

5. Actual costs of NOAA contractors performing activities in the IAA; and

6. Costs of NOAA Business Services Group (BSG) to track costs and prepare NOAA 

cost documentation for submittal to NPFC.

C. Reporting

NOAA will provide the NPFC with periodic reports on status of the IAA activities 

pursuant to the terms of the IAA. Documentation submitted with these reports will be 

reviewed to determine reimbursement of eligible costs.

D. Cost Documentation

NOAA will provide documentation to support NPFC payment of eligible costs as 

follows:

1. Labor: Compensable labor is any labor that is directly related to development of a 

plan. This may include field activities, administrative tasks, technical review of 

reports, etc. Labor associated with removal actions, litigation, negotiations, or any 

work done outside the scope of the IAA is not compensable. 

2. Documentation for labor should include: Name of each employee, title/function of 

each employee who charged labor, work accomplished by each employee (should 

include enough information so the NPFC can determine whether the work is within 

the scope of the signed IAA), dates the employee worked, number of hours 

worked, hourly wage, a full accounting and description of all indirect and overhead 

charges applied to base labor, and the methodology used to apply indirect overhead 

charges, and justification of any claimed overtime. The NPFC needs the ability to 

replicate all costs. 

3. Trustee Travel: Travel directly related to a study/project included in the signed 

IAA is compensable. Examples of compensable travel include trustee meetings, 

public meetings to inform the public about NRDA activities, fieldwork, and site 

visits. Travel for training, conferences, or for any reason not directly related to 

study/project included in the signed IAA are not compensable. A travel voucher 

with supervisor and member signatures, travel dates, purpose for traveling, costs 

incurred (e.g. hotel, airfare, per diem) and an itemization of amounts paid to the 

employee is required. To document travel, the NPFC requires the trustees to 

provide a signed travel voucher or equivalent.

4. Contract Costs: Contract costs pursuant to the signed IAA are compensable. 

Contractors are subject to the same restrictions as the trustees (e.g., labor for claim 

preparation, litigation, and negotiations and travel for any reason outside of the 

scope of the signed IAA is also not compensable).Work plans, contractor invoices, 
proof of payment, and a description of work accomplished by the contractor are 

required to document contract costs. 

5. Grants: Grant costs are compensable under the signed IAA. The work performed 

must be directly related to a study/project included in the signed IAA. Grant 

recipients are subject to the same restrictions as the trustees (e.g. labor for claim 

preparation, litigation, negotiations, etc. is not compensable and travel for any 

reason outside of the scope of the signed IAA is also not compensable). To 

document grant costs, the trustees need to provide the NPFC with grant proposals, 

proof of grant disbursement for the NRDA-associated work, and a description of 

work accomplished by the grant recipient. 

6. Purchases: Equipment or property necessary to carry out the signed IAA should be 

leased, if possible. If practicable, the RP should be allowed to provide the 

necessary equipment or property. In all instances in which the trustees purchase 

equipment or property using OSLTF funds, as opposed to leasing, the trustees 

should document the decision making process for the purchase explaining how the 

equipment or property will be used for the NRDA as well as documenting the 

actual use and disposal of the equipment/property. All non-consumable items, 

which include any items or systems having a cost in excess of $2,500, or items of 

high interest (e.g., radios, fax machines, cellular phones, computers, pagers, 

copiers, photographic equipment, protective clothing, meters, and similar items) 

regardless of cost, require evidence of disposal action. Equipment or property 

purchased with OSLTF funds cannot to be retained by the agency after completion 

of the NRDA. This does not preclude replacement in kind for agency equipment 

damaged or expended. Documentation of purchases must include justification that 

purchasing was more cost effective than leasing, receipt(s) for purchase(s), and 

proof of disposal, if necessary. For upfront claims and IAAs where the Trustees 

plan on purchasing high value items (see above) the trustees should first contact 

the NPFC prior to making the purchase and receive authorization in writing.

7. Trustee Use of Government Equipment: The NPFC can reimburse the actual cost 

of using government equipment, such as government vehicles or boats. 

Additionally, the NPFC would pay boat costs/ expenses/ repairs in lieu of a 

standard rate; up to the applicable and appropriate cost of the standard rate. To 

document these costs, the trustees must provide the NPFC with a usage log, the 

cost associated with using government equipment, and purpose and duration of 

use. If requesting reimbursement for costs of associated maintenance and repairs 

in lieu of standard rates, the trustees must provide the NPFC with a usage log, the 

cost associated with using government equipment, and purpose and duration of use 

to compare the standard rate costs to the maintenance and/ or repair costs.

VII. CONTACTS

The contacts for coordinating activities under this MOU are:

NOAA USCG

John A. Tarpley William R. Grawe

Acting Chief, Emergency Response Director

Division Office of Response and National Pollution Funds Center
Restoration United States Coast Guard

National Ocean Service STOP 7605

National Oceanic and Atmospheric 2703 Martin Luther King Jr. Ave

Administration Washington, DC 20593-7605

1305 East West Highway Phone: 202-795-6001

SSMC4, Station 10148 Fax: 202-372-8402

Silver Spring MD 20910 Email: William.R.Grawe@uscg.mil 

Phone: (206) 526-6338

Email: John.Tarpley@noaa.gov

The Parties agree that if there is a change regarding the information in this section, the Party making 

the change will notify the other Party in writing of such change.

VIII. DURATION OF THE MOU, AMENDMENTS, AND TERMINATION

A. This MOU will become effective after being signed by all Parties. This MOU will 

remain in effect through September 30, 2027.

B. This MOU may be amended within the scope of this MOU through the written mutual 

consent of the Parties. Adding or changing appendices does not constitute an 

amendment of the overall MOU. Such additions and/or changes may be made by mutual 

written consent of the officials responsible for the specific subject area(s) in the NPFC 

and OR&R. The officials making such change shall immediately bring the change to 

the attention of the persons signing this MOU, or their successors, and then shall 

disseminate the change to all users of the MOU.

C. The Parties will review this MOU at least once every three years to determine whether 

it should be amended or terminated.

D. This MOU may be terminated by (1) mutual written consent; (2) 30 days advance 

written notice by either Party, or (3) completion of the operation/terms of this MOU. 

Termination of this MOU does not terminate incident-specific PRFAs or Inter-Agency 

Agreements. In the event a PRFA or Inter-Agency Agreement is terminated, 

reimbursement for outstanding costs will be governed by the terms of the PRFA or InterAgency Agreement.

IX. RESOLUTION OF DISAGREEMENTS

A. Nothing herein is intended to conflict with current NOAA or USCG directives. If the terms of 

this MOU are inconsistent with existing directives of either of the agencies entering into this 

MOU, then those portions of this MOU, which are determined to be inconsistent, shall be 

invalid, but the remaining terms and conditions not affected by the inconsistency shall remain 

in full force and effect. At the first opportunity for review of the MOU, all necessary changes 

will be accomplished either by an amendment to this MOU or by entering into a new agreement, 

whichever is deemed expedient to the interest of both Parties.

B. If a dispute related to funding remains unresolved for more than 30 calendar days after the 

parties have engaged in an escalation of the dispute, disputes will be resolved in accordance 

with instructions provided in the Treasury Financial Manual (TFM) Volume I, Part 2, Chapter 

4700, Appendix 10, available at http://www.fms.treas.gov/tfm/index.html.
APPROVALS

This Agreement is entered into and made effective as of the date later in time indicated below.

ACCEPTED AND APPROVED FOR THE

U.S. DEPARTMENT OF COMMERCE 

NATIONAL OCEANIC AND 

ATMOSPHERIC ADMINISTRATION 

NATIONAL OCEAN SERVICE

ACCEPTED AND APPROVED FOR THE 

U.S. DEPARTMENT OF HOMELAND 

SECURITY

U.S. COAST GUARD

NATIONAL POLLUTION FUNDS 

CENTER

BY: ____________________________ BY:______________________________

Scott Lundgren William R. Grawe

National Ocean Service Director

National Oceanic and Atmospheric National Pollution Funds Center

Administration United States Coast Guard

1305 East West Highway STOP 7605

SSMC4 Station 10148 2703 Martin Luther King Jr. Ave

Silver Spring MD 20910

DATE:__________________________ 

Washington, DC 20593-7605

DATE:____________________________ 

9/10/2020
Appendix A

PROCEDURES FOR "COST REIMBURSEMENT" UNDER THE POLLUTION 

REMOVAL FUNDING AUTHORIZATION (PRFA)

The following are cost reimbursement protocols for those services provided by NOAA as part of 

an oil or hazardous substances removal.

1. Execution Phase

A. Following a request for OR&R support services, the SSC or SSC representative will 

notify and provide OR&R's Business Services Group (BSG) with information 

pertaining to resource utilization and the associated FPN (Federal Project Number for 

oil incidents), CPN (CERCLA Projects Number for hazardous substance incidents), or 

DPN (Disaster Project Number – ESF-10), FOSC (or representative), and telephone 

number.

B. BSG will prepare a 2 week cost estimate (unless otherwise noted by the FOSC) of 

actual costs for resources used and pre-approved by the FOSC. The estimate is sent to 

the FOSC (or representative) and the NPFC case officer.

C. The FOSC (or representative) will provide BSG with a Pollution Removal Funding 

Authorization (PRFA). The PRFA documents the pollution incident name, 

identification number (FPN, CPN, or DPN), funding limit, a Statement of Work to be 

performed (i.e., task orders) points of contact, and FOSC billing address.

D. BSG confers with the SSC when costs incurred begin to reach the PRFA funding limit. 

Updates to NOAA's estimated costs are provided to the FOSC through the SSC and to 

the NPFC as needed but no more than twice during a seven-day period.

E. BSG provides the FOSC and NPFC with the updated cost estimate from which the 

FOSC develops a PRFA amendment. Depending on the length of the removal, the 

PRFA may be amended several times.

2. Reimbursement of Expenses

A. BSG collects all cost documentation associated with an incident as costs are incurred.

B. BSG reviews the incident file with NOAA's financial management information system 

to determine if chargeable costs are accurate and makes any corrections.

C. Once all incident costs are accurately recorded in NOAA's financial management 

system or 120 days after removal activities are complete (whichever comes first),BSG 

prepares a cost spreadsheet billing for submission to the NPFC via the incident FOSC. 

The FOSC will verify that the actual costs on the spreadsheet are for resources that 

were used as approved during the specific incident. The spreadsheet will cite: 1) the 
pollution incident name, 2) FPN, CPN, or DPN identification number and 3) an 

incident-specific breakdown of charges.

D. Concurrently, BSG notifies the Office of Response and Restoration (OR&R), ERD's 

parent organization, to initiate a request to the NOAA Comptroller's office to prepare 

an SF-1081 that is sent to the FOSC, copy to NPFC, within 120 days after removal 

activities are complete. The SF-1081 includes the agency's address, agency location 

code, fiscal year, Treasury symbol, and task code associated with the billing costs. The 

address of the NPFC is:

Director

National Pollution Funds Center (Cm)

2703 Martin Luther King Ave SE

Washington DC, 20593-7605

US Coast Guard STOP 7605

Re: FPN/CPN/DPN

E. The Coast Guard's FOSC and NPFC will review NOAA's SF-1081 to authorize it for 

payment, and forward it to the USCG Finance Center within 30 days of receipt, unless 

there are problems with the SF-1081 package. Reimbursement is accomplished 

through the Intra-governmental Payment and Collection (IPAC) System.

F. In the event of a lengthy or large incident, OR&R will submit an interim billing as 

agreed upon between the NPFC case officer and BSG. The interim billing process uses 

the same procedures as outlined in A through E above.
APPENDIX B

PROCEDURES FOR "COST REIMBURSEMENT" UNDER AN INTERAGENCY 

AGREEMENT FOR INITIATION OF NATURAL RESOURCE DAMAGE ASSESSMENT

The NPFC will pay the trustees for all documented costs determined to be reasonable, appropriate, and in 

accordance with OPA and an Inter-Agency Agreements (IAA). The following are IAAs and cost

reimbursement protocols.

1. IAA Execution

A. Federal Lead Administrative Trustees (FLAT) should contact a NPFC NRD claims 

manager to request funding via the Division Chief (202-795-6054, Monday - Friday, 8 

a.m. to 4:30 p.m.) or NPFC Command Duty Officer (202-494-9118, after normal 

business hours).

B. The claims manager will discuss the request with the FLAT and, where appropriate, 

provide a standard IAA template and further instructions.

C. The FLAT should submit draft IAA with the appropriate information to the claims 

manager.

D. Upon approval of the draft IAA, the claims manager will request that the FLAT provide 

a signed copy to the NPFC. The NPFC will then sign the IAA and provide a copy to 

the FLAT.

2. Reimbursement of Expenses

A. The FLAT will submit documentation of costs incurred to the claims manager.

B. The claims manager will review cost documentation submitted by the FLAT and pay 

those determined to be appropriately documented and in accordance OPA and the 

Inter-Agency Agreement. As part of this review, the Cn Claims Manager coordinates 

with the NPFC Case Manager to ensure submitted costs are separate and distinct from 

payments under any Pollution Removal Funding Authorizations (PRFAs).

C. The NPFC will pay the FLAT through the Intra-governmental Payment and Collection 

(IPAC) System. Separate payments may be made directly to individual trustees, if 

requested. In that case, each participating trustee receiving a direct reimbursement will 

provide the NPFC with an SF-1080 or SF-1081 (or equivalent), along with a 

participating trustee ALC and corresponding ALC address (if federal) or SAM number.

D. The SF-1081 includes the agency's address, agency location code, fiscal year, Treasury 

symbol, and task code associated with the billing costs.

E. Payments made against the Inter-Agency Agreement will be deducted from the 

available balance of the obligation.
APPENDIX C

COST DOCUMENTATION

NOAA will produce a comprehensive written record supporting all expenditures and costs incurred during 

each removal activity. This documentation will support reimbursement of OR&R costs and NPFC's cost 

recovery on behalf of the OSLTF. NOAA will use an alternate method of record keeping for cost 

documentation rather than the standard resource documentation procedures outlined in NPFC’s User 

Reference Guide. Time sheets, payroll reports, travel orders, etc., will be redacted to remove data protected 

by the Privacy Act such as social security numbers.

1. NOAA Personnel Costs: Documentation will show each employee's name, grade, hours, function, 

appropriate subtotals, and an overall total. In addition, NOAA will indicate whether the employee 

is Off Site or On Scene. OR&R will include copies of the Civilian Time and Attendance Daily 

Reports, CD-440PC, indicating incident-specific hours. NOAA Corps Officers are not required to 

maintain a CD440PC, but will record incident-specific hours on a Timekeeping Record Worksheet.

2. NOAA Travel Costs: Incident-specific travel documentation will include copies of each Travel 

Order, CD-29, or NOAA Form 56-1 for Corps Officers; Travel Voucher, CD-370, with supporting 

receipts as required by the applicable federal travel regulations; and/or Claim for Reimbursement 

for Expenditures on Official Business, SF-1164, with appropriate subtotals and an overall total.

3. Contractor Costs: Documentation will include copies of the contract incident specific tasking orders 

(technical directions), modifications (where applicable), statements of work, and invoices 

associated with incident-specific costs. Contractor costs will have appropriate subtotals and an 

overall total.

4. Other NOAA Costs: Documentation for transportation, rents/leases, and supplies/equipment will 

be included when applicable.
APPENDIX D

DEFINITIONS

1. Federal On-Scene Coordinator (FOSC)

The FOSC is the Federal official pre-designated by the USCG or EPA to coordinate and direct 

removals under subpart D or E of the National Oil and Hazardous Substances Pollution 

Contingency Plan (NCP) (40 CFR §300.5). When FOSC is used in this document, it also means 

EPA OSC.

2. NOAA Scientific Support Coordinator (SSC)

When designated by the FOSC, the NOAA SSC is the principal advisor for scientific issues, 

communication with the scientific community, and coordination of requests for assistance from 

state and Federal agencies regarding scientific studies. The SSC may serve on the FOSC's staff 

supporting the Unified Command or within the Planning or Operations Section of the Incident 

Command System and may, at the FOSC's request, lead a scientific team(s) to provide scientific 

support for making operational decisions.

3. Regional Response Team (RRT)

The National Response System (NRS) is the mechanism for coordinating response actions by all 

levels of government in support of the FOSC. The NRS organization is divided into national, 

regional, and area levels. National planning and coordination is accomplished through the National 

Response Team (NRT). The NRT consists of representatives from 16 Federal agencies. Regional 

planning and coordination of preparedness and response actions is the responsibility of the RRT. 

The RRT agency membership parallels that of the NRT, but also includes state, and sometimes, 

local representation. RRT members provide FOSCs with assistance from their respective Federal 

agencies commensurate with agency responsibilities, resources, and capabilities within that region.

4. Remove or Removal

"Remove" or "removal" is defined in 33 USC 1321 (a) to mean "containment and removal of the 

oil or hazardous substances from the water and shorelines or the taking of such other actions as 

may be necessary to minimize or mitigate damage to the public health or welfare, including, but 

not limited to, fish, shellfish, wildlife, and public and private property, shorelines, and beaches."

5. Removal Cost

"Removal costs" is defined in 33 USC 2701 (31) as "the costs of removal that are incurred after a 

discharge of oil has occurred or, in any case in which there is a substantial threat of a discharge of 

oil, the costs to prevent, minimize, or mitigate oil pollution from such an incident." Note that the 

terms "response" and "remediation" are not used in the Oil Pollution Act (OPA).

6. NOAA Emergency Response Division (ERD)

ERD, a division within NOAA OR&R, provides critical advice on science and other natural 

resource issues to the FOSCs during the Federal government's response to coastal oil and hazardous 

substance spills or substantial threat of release. SSCs lead the scientific support team at spills, 

drawing on ERD's spill trajectory estimates, chemical hazards analyses, assessments of the 

sensitivity of biological and human-use resources, and other types of expertise to help the FOSC 
make timely and appropriate operational decisions. NOAA spill response personnel work closely 

with the FOSC to respond to about 120 accidental releases each year. ERL) also typically provides 

Department of Commerce representation on the RRT during planning and removal phases.

7. Federal Lead Administrative Trustee (FLAT)

Provides a focal point for addressing natural resource issues associated with a specific incident. 

The NPFC will only accept requests for initiation from the FLAT. State and Tribal Trustees must 

work through a FLAT. Those State and Tribal Trustees acting in the event of a spill may join with 

the designated Federal Trustees to name a FLAT.

8. Natural Resource Damage Assessment (NRDA)

Natural resource Trustees determine whether injury to public trust resources has occurred. Their 

work includes collecting time-sensitive data and reviewing scientific literature about the released 

substance and its impact on trust resources to determine the extent and severity of injury. During 

the next step, trustees quantify injuries and identify possible restoration projects. Economic and 

scientific studies asses the injuries to natural resources and loss of services. The final step is to 

implement restoration and monitor its effectiveness. NRDA process ensures an objective and cost 

effective assessment of injuries.