Removal Actions: Oil and Hazardous Substances

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PROCEDURES FOR ACCESSING THE FUNDS

I. Oil Overview: These procedures apply to FOSCs (either Coast Guard or EPA) who are 

performing oil removal operations under the National Contingency Plan and require 

funding support from the OSLTF.

a. The FOSC accesses CANAPS via the Internet and requests issuance of an FPN

and a corresponding ceiling amount. NPFC then works with FINCEN to establish 

and fund an accounting line.

b. CANAPS will confirm via email and issue all necessary notifications by priority

message. CANAPS generates the message format and sends it via CGMS.

c. Authorized users of CANAPS can act as surrogates to request a ceiling on behalf

of other authorized users when their access to CANAPS is disrupted. District

OPCENs have this authority/capability for units within their AOR, including EPA 

Federal On-Scene Coordinators (FOSCs)/Regions. EPA Regions are also able to

act as surrogates for their FOSCs when available. The NPFC has the ability to act

as a surrogate for any authorized CG or EPA field user of CANAPS. NPFC can 

also issue numbers manually in the event CANAPS is completely unavailable.

d. All ceiling messages, POLREPS, or other messages related to incidents accessing

the OSLTF shall include the following info addees in addition to current reporting 

requirements: FOSC, NPFC, CG FINCEN, the SILC contracting branch, and the 

appropriate District (drm/dmf).

e. If no funding was expended against an FPN for the removal, the FOSC can 

request cancellation of the FPN via CANAPS.

f. The FOSC ensures that obligations from the OSLTF remain within the authorized

ceiling, and if necessary, promptly obtains additional ceiling via CANAPS.

g. FPN Construction.

i. For Coast Guard cases CANAPS uses a smart numbering scheme,

ensuring the ability of the user to identify the CG district, fiscal year, and 

sequential number of the case. To avoid overlapping of current cases, the

FPN is an alphanumeric value where the first character is a letter

delineating the CG district, the second and third characters are the fiscal 

year, and characters four through six are the sequential number of each

district’s cases, which can be alphanumeric if necessary.

ii. All EPA FPN’s start with the letter “E” followed by the two-digit fiscal

year. The fourth character indicates the number of the EPA region with a

“0” indicating EPA region 10. The last two characters are sequential 

based on the number of FPN’s issued to that region in that fiscal year.

II. Hazardous substances/CERCLA Overview: These procedures apply only to CG FOSCs 

who are performing hazardous substance response operations under the National

Contingency Plan and require funding support from SUPERFUND, also known as the 

CERCLA Fund.
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a. The CG FOSC accesses CANAPS via the internet and request issuance of a 

CERCLA Project Number (CPN) and a corresponding ceiling amount. CANAPS 

prepares all record message traffic via CGMS and delivers it to the appropriate

units. NPFC then works with FINCEN to establish and fund an accounting line.

b. Initial CERCLA ceiling requests will not exceed $250,000. NPFC receives 

limited CERCLA funding authority from EPA each year to fund all ceilings. An 

Action Memorandum prepared by the FOSC must support funding requests that 

are equal to or greater than $250,000. See Sub tab “Action Memo Guidance” for

guidance on CERCLA Action Memorandums. If the nature of the emergency 

requires a higher initial ceiling, the NFPC will coordinate such requests with the 

CG FOSC, CG District, COMDT (CG-533), and the EPA on a case-by-case basis.

c. All messages, POLREPS, or other messages related to the incident where

CERCLA/ SUPERFUND has been accessed shall include the FOSC, NPFC, CG

FINCEN, cognizant Coast Guard District (drm/dmf), and cognizant SILC

contracting branch as INFO addees, in addition to current reporting requirements.

d. The FOSC ensures that obligations from CERCLA remain within the authorized

ceiling, and if necessary, promptly requests increased ceiling authorizations via 

CANAPS. The FOSC shall request the increase sufficiently in advance to avoid

exceeding the ceiling at any point during response activities

e. Special FOSC Requirements for CERCLA Incidents. The CG/EPA Memorandum

of Understanding and its resulting funding agreement place special requirements 

on the FOSC. 

i. If a response requires less than $250,000 in funding, the FOSC must 

document a finding of imminent and substantial endangerment. This

finding may be included in the situation description section of POLREP 

One, and at a minimum must include the following items.

1. The hazardous substance(s), pollutant(s), or contaminant(s)

involved;

2. description of what is affected or threatened (people, animals, 

crops, drinking water, etc.; 

3. a statement indicating that the situation presents an imminent and

substantial threat to public health, welfare, or the environment; and

4. description of the response action necessary to neutralize the threat.
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ii. If a response requires $250,000 or more, or will last more than two years, 

the FOSC must prepare an Action Memorandum in accordance with EPA 

guidance. 

1. The response can begin, but the Action Memorandum is required 

before reaching the $250,000 limit. See Sub tab “Action Memo 

Guidance” for guidance on CERCLA Action Memorandums. 

2. If the nature of the emergency requires a higher initial ceiling, the

NFPC will coordinate such requests with the CG FOSC, CG 

District, COMDT (CG-533), and the EPA on a case-by-case basis.

III. Strike Team support of EPA under CERCLA Overview: these procedures apply when 

CG Strike Team assets support the EPA on an EPA case. The CG efforts are funded 

from annual IAGs with the EPA that are managed within NPFC.

a. The NPFC establishes an annual accounting string construct with each of the three 

CG Strike Teams that includes project number assignments.

b. EPA requests CG Strike team services through the issuance of a Work 

Authorization Form (WAF) to a Strike Team. The Strike team shall forward the 

specific case information to the NPFC via CGMS. The information needed 

includes the following data.

i. EPA Site Name including County and State,

ii. Next CERCLA Project Number from the list provided by NPFC at the

beginning of the fiscal year,

iii. EPA Region requesting the support, and

iv. Ceiling limit.

c. NPFC then works with FINCEN to establish and fund an accounting line.

d. The NPFC will facilitate any ceiling adjustments between the EPA and Strike 

Team.

IV. Disaster Pollution Funding Overview: these procedures apply when CG assets conduct a 

pollution response under ESF-10 (Emergency Response Function -10) resulting from 

a Presidential Disaster Declaration under the National Response Plan.

a. FEMA controls Disaster funding for pollution response. Funding normally 

becomes available after a Presidential Disaster Declaration. The FEMA vehicle 

for disaster funding is a Mission Assignment (MA). An MA is both operational 

tasking and a funding document. An MA can come to the Coast Guard directly 

from FEMA or from the EPA (who receives the MA directly from FEMA).

b. Disaster response funding is not distributed via CANAPS. If the field initiates a 

CANAPS FPN/CPN funding request prompted by a disaster NPFC will determine 

if FEMA has issued or will be issuing an ESF-10 MA. If an MA is forthcoming 

NPFC will initiate direct coordination with the District (drm) to establish DPN 

funding.
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c. NPFC will confirm that the District/Area has accepted the MA. The preferred 

confirmation approach is for the District/Sector to fax the MA to 202-493-6898, email or telephone confirmation is also acceptable.

d. NPFC will accept the funding on behalf of the Coast Guard and issue a message to 

the appropriate field units. The message will include the following details.

i. The appropriate accounting line with unique disaster project number 

(DPN),

ii. A direct reference to the applicable FEMA Mission Assignment Number,

iii. Guidance on actions appropriately funded by the DPN.

e. NPFC then works with FINCEN to establish and fund an accounting line.

f. Units should contact NPFC if assistance is needed accumulating cost 

documentation.