EPA/540/P-91/013
Publication 9246.0-05
August 1991
Guidance On Site Assessment
Cooperative Agreements
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
Printed on Recycled Paper
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To obtain additional copies of this document contact:
National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4600
NOTICE
The policies and procedures set forth here are intended as guidance to Agency and other
government employees. They do not constitute rulemaking by the Agency, and may not
be relied on to create a substantive or procedural right enforceable by any other person.
The government may take action that is at variance with the policies and procedures in
this manual.
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CONTENTS
PAGE
1.0 INTRODUCTION . 1
1.1 Generic SMOA Language Pertaining to Site
Assessment Activities . . 1
2.0 GENERIC QUARTERLY REPORT FORMAT 3
2.1 Cover Letter 3
2.2 Summary of Quarterly Progress 3
2.3 Summary of Cumulative Effort . . 3
2.4 Summary of Remaining Effort 3
2.5 Sites Added or Deleted 3
2.6 Anticipated Activity 3
3.0 GENERIC SITE ASSESSMENT COOPERATIVE
AGREEMENT APPLICATION PACKAGE 4
3.1 Cover Letter 4
3.2 Table of Contents 4
3.3 Intergovernmental Review 4
3.4 Substantive Provisions 4
3.5 Health and Safety Plan 8
3.6 Quality Assurance Plan . . 8
APPENDICES
Appendix A: Supplementary Material for Generic Language
Pertaining to Site Assessment Activities 9
in
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CONTENTS
(Continued)
PAGE
Appendix B: Supplementary Material for Generic Site
Assessment Cooperative Agreement Application 10
Package
Sample Letter for Initiation of Intergovernmental Review 10
Sample "Application for Federal Assistance" (SF 424) 12
Sample Budget Sheets (SF 424A) 13
Sample Background Discussion 15
Sample Schedule of Deliverables 16
Sample Preliminary Assessment Description 17
Sample Average Preliminary Assessment Costs Per Site by
Object Class Category 19
Sample Total Preliminary Assessment Costs by
Object Class Category 20
Sample Budget Summary for All Site Assessment Activities by
Object Class Category . . . • 21
Sample Overall Budget Summary by Site Assessment Activity 22
Sample Preliminary Assessment Work Plan 23
Sample Screening Site Inspection Work Plan 24
Sample Form 5700-49 .' 26
Sample Form 5700-48 27
iv
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CONTENTS
(Continued)
PAGE
Sample Provisions Required for Site Assessment
Cooperative Agreements 28
Sample General Provisions and Assurances 29
Sample Special Conditions . . . •. 32
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1.0 INTRODUCTION
The guidance on site assessment cooperative
agreement presents generic SMOA language
pertaining to Site Assessment activities, a generic
quarterly report format, and generic site assessment
cooperative agreement application package. In
addition, the appendices provide additional sample
schedules, forms, and letters for developing a site
assessment cooperative agreement.
1.1 Generic SMOA Language Pertaining to Site
Assessment Activities
The [state department or agency] will conduct
site assessment activities that will include [list the
specific site assessment activities that the state will
perform]. The [state department or agency] will be
the lead agency for these activities, except where
agreed otherwise for specific sites.
At the annual planning meeting, the [state
department or agency] and EPA will determine and
mutually agree upon the number of site assessment
activities that will be completed utilizing state
resources. The determination of these numbers
should occur prior to the Regional Office's receipt of
final Superfund Comprehensive Accomplishments
Plan (SCAP) targets from EPA Headquarters. In
addition, funding for site assessment activities will be
provided by EPA to the [state department or agency]
through a Site Assessment Cooperative Agreement
(SACA). In order for the [state department or
agency] to receive this funding, the [state department
or agency] must prepare a SACA application package
and have it reviewed and approved by EPA.
The [state department or agency] will complete
site assessment activities at sites identified in the
SACA and will submit the appropriate reports (e.g.,
a Preliminary Assessment (PA) report, a Screening
Site Inspection (SSI) report, etc.) to EPA for review
and approval. A list of EPA review times for these
reports is presented below in Table 1.
Site assessment activities will be performed in
accordance with the Scope of Work (SOW) contained
in the SACA. The identification of new sites or
changes to the list of sites designated for site
assessment activities that is included in the original
SACA must be approved by EPA.
The [state department or agency] will submit
quarterly reports to EPA in accordance with the
provisions contained in the SACA and EPA's PA/SI
State Cooperative Agreement Guidance. These
quarterly reports should include a summary of
activities performed and expenses incurred during the
reporting period and an estimate of the time and funds
needed to complete the work required. See Table 1
for timeframes for EPA review.
The [state department or agency] and EPA agree
to work together to ensure that sites requiring site
assessment activities are addressed as expeditiously as
possible. If the [state department or agency] falls
behind in its accomplishments as established under
the SACA, EPA, in consultation with the state, may
initiate site assessment activities at state-lead sites to
assist the [state department or agency] in
accomplishing the site assessment activities.
The [state department or agency] will be provided
an opportunity to supply written comments on all
completed EPA-lead Sis and Hazard Ranking System
(HRS) scoring packages. While EPA will determine
whether to list or delete a site from the National
Priorities List (NPL), the Agency will consult with
the [state department or agency] prior to the
nomination of sites for the NPL and the [state
department or agency] must concur on each deletion
from the NPL.
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Table 1
Documents Provided by State
Documents Provided by State
PA Reports
Draft SSI & ESI Workplans
SSI/ESI Reports
HRS Scoring Packages
Type of EPA Review
Review/Comment
Review/Comment
Review/Comment
Review/Consultation
Timeframe (Working Days)
10 Days
20 Days
30 Days
20 Days
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2.0 GENERIC QUARTERLY REPORT
FORMAT
2.1 Cover Letter
The cover letter should include a brief summary
of the tasks and activities performed during the
current reporting period. A general discussiori
concerning an estimate of the time and funds needed
to complete the work required in the CA should also
be provided. If this is greater than the amount of
time and funds remaining, there must be a
justification for any increase.
2.2 Summary of Quarterly Progress
This section should provide a narrative describing
the progress made during the current reporting period.
This discussion should include a description of the
work accomplished during the reporting period, an
explanation of delays or other problems, if any, and
a description of the corrective measures, that are
planned. This section should also include a list of
site-specific products completed during the reporting
period, with an estimate of the technical hours
required to complete each product. A sample format
for the presentation of this site-specific product
information is presented in Appendix A. Appendix A
includes information for Preliminary Assessments and
Site Inspections; if additional site assessment activities
were conducted, information on these activities should
also be provided. (Required by 40 CFR Part 35 -
Subpart O, §35.6650(b)(l»
2.3 Summary of Cumulative Effort
This section should include information that
provides a comparison of the percentage of the project
completed to the project schedule contained in the
CA. An explanation of any significant discrepancies
should be provided. This section should also provide
a comparison of the estimated funds spent to date to
the planned expenditures for these activities. Again,
an explanation of any significant discrepancies should
be included. (Required by 40 CFR Part 35 -
Subpart O, §35.6650(b)(2), (3))
2.4 Summary of Remaining Effort
In this section, the state should provide an
estimate of the time and funds needed to complete the
remaining site assessment activities required by the
CA. This estimate should be compared to an estimate
of the time and funds remaining, and a justification
for any necessary increases should be provided.
(Required by 40 CFR Part 35 - Subpart O,
§35.6650(b)(4))
2.5 Sites Added or Deleted
This section should list any sites that may have
been added to or deleted from the list of sites
contained in the CA during the current reporting
period, and should explain the reasons for their
addition or deletion in a footnote at the bottom of the
page.
2.6 Anticipated Activity
This final narrative section should provide
projected activity and report completion dates for
pending site assessment activities during the next two
quarters, if these dates have changed from those
indicated in the CA.
See Appendix A for supplementary materials to
this section.
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3.0 GENERIC SITE ASSESSMENT
COOPERATIVE AGREEMENT
APPLICATION PACKAGE
The following documents, forms, and information
should be included as part of the Cooperative
Agreement (CA) application package for site
assessment activities under the Comprehensive
Environmental Response, Compensation, and Liability
Act (CERCLA). All site assessment CA application
packages submitted by states and Indian Tribes must
comply with the applicable requirements of 40 CFR
Part .31 ("Uniform Administrative Requirements for
Grants and Cooperative Agreements to State and
Local Governments"), 40 CFR Part 35 -Subpart O
("Cooperative Agreements and Superfund State
Contracts for Superfund Response Actions"), Office
of Management and Budget (OMB) Circular A-102,
and any other applicable federal regulation or
requirements.
3.1 Cover Letter
The cover letter for the CA package should
provide the name of the state, the date upon which
the application was submitted, and the name,
telephone number, and address of the contact
person(s) for the state. The cover letter should also
indicate whether the application is for the approval of
a new CA, the renewal of an existing CA, or the
revision of an existing CA. The cover letter for the
CA package should be directed to the appropriate
Regional Administrator.
'3.2 Table of Contents
The table of contents should provide, in outline
format, the subject and page number for the various
provisions and other documents that comprise the CA
application package.
3.3 Intergovernmental Review
A state shall seek approval for site assessment
work before completing an "Application for Federal
Assistance" (Standard Form (SF) 424) by using the
intergovernmental review procedure. This procedure,
conducted between the designated state agency and
local governments, serves to ensure both the
responsiveness of federal, state, and local government
agencies to one another and to facilitate site
asspssment work once a CA has been approved. On
April 8, 1985, EPA published a notice in the Federal
Register (50 FR 13873) announcing the revised
intergovernmental review procedure for site
assessment activities ("Procedures for Implementing
Intergovernmental Review"). The state should notify
the state intergovernmental review point of contact by
letter to explain the nature of the proposed site
assessment activities and the scope of the program.
The state should notify the state intergovernmental
review point of contact at least one quarter prior to
the anticipated initiation of the planned site
assessment activities. A copy of this communication
and any other corresponding intergovernmental review
comments should be included in the subsequent CA
application package. Indian Tribes are exempt from
having to meet these intergovernmental review
requirements. Appendix B provides a sample letter
for a state to initiate intergovernmental review.
3.4 Substantive Provisions
3.4.1. Application for Federal Assistance
The state must include an "Application for
Federal Assistance" (SF 424) for non-construction
programs in the CA application package. This form
requires information such as the legal name and
address of the applicant, the estimated funding
requirements for the activities proposed by the
applicant, and other administrative information.
General instructions for completing the SF 424 are
included with the application. See Appendix B for a
sample "Application for Federal Assistance."
(Required by 40 CFR Part 35 - Subpart O,
§35.605S(a))
3.4.2. Budget Sheets
A standardized budget summary, entitled "Budget
Information-Non-Construction Programs" (SF424A),
should immediately follow SF 424 in the CA
application package. SF 424A requires information
on the state's plans for allocating the authorized funds
among the various site assessment activities. These
site assessment activities may include Preliminary
Assessments (PAs), Screening Site Inspections (SSIs),
Expanded Site Inspections (ESIs), preparation of
Hazard Ranking System (HRS) scoring packages,
training, and management assistance review of
contractor documents (i.e., state review of contractor
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documents). This budget information should be
broken down by site assessment activity and object
class category (e.g., personnel, fringe benefits, travel,
equipment). A sample SF 424A is included in
Appendix B. (Required by 40 CFR Part 35 -
Subpart O, §35.6055(a)(l))
3.4.3. Project Narrative Statement
The project narrative statement is the core of the
CA application package, and should include a
background section, a schedule of deliverables, a list
of sites at which site assessment activities are
planned, and a Statement of Work (SOW), which
includes detailed budget information. (Required by
40 CFR Part 35 -Subpart O, §35.6055(a)(2))
a) Background
The state should briefly discuss the status and
structure of its site assessment program. This
discussion should include the number of PAs,
SSIs, ESIs, and other site assessment activities
completed by the state. The discussion should
also include an estimate of the total number of
sites within the state that are listed on the
CERCLA Information System (CERCLIS) and"
still need to be assessed or inspected. A sample
background discussion is provided in Appendix
B.
b) Schedule of Deliverables
A schedule designating the number of PAs, SSIs,
ESIs, and other site assessment activities that will
be submitted to the EPA Regional Office during
each quarter of the fiscal year should be included
by the state. Site assessment activities that are
carried over from a previous fiscal year should be
clearly noted. Quarterly reports will provide the
state an opportunity to confirm the number of
submissions to the Region and to request changes
to the schedule if necessary. A sample schedule
of deliverables is presented in Appendix B.
(Required by 40 CFR Part 35 - Subpart O,
§35.6055(a)(2)(iii))
c) List of Sites
A list of the names of sites at which site
assessment activities are planned should be
included in the project narrative statement. If the
state proposes to revise the list, the state may not
incur costs at a new site until the EPA Regional
Project Officer has approved the site. The list of
sites should be categorized by the type of site
assessment activity to be undertaken at a site and
should indicate the estimated quarter of the fiscal
year in which the activity at a site will be
completed. In the event mat all sites are not
identified at the time an application is submitted,
the state should provide the number of
unidentified sites and should make a commitment
to submit the names of these sites as they are
identified. (Required by 40 CFR Part 35 -
Subpart O, §35.6055(a)(2)(ii))
d) Statement of Work
The SOW for proposed site assessment activities
should include the following: (Required by 40
CFR Part 35 - Subpart O, §35.6055(a)(2)(ii))
(i) A detailed description of each of the site
assessment activities to be conducted
under the CA, including lists of the
information to be provided by each site
assessment activity, lists of tasks
necessary for the completion of each
activity, lists of what final site
assessment activity reports will include,
and other documentation, as the state
deems necessary. Exhibit 6 provides a
sample activity description for a PA;
similar activity descriptions should be
provided for other site assessment
activities to be performed. The
guidance materials listed below should
assist states in preparing these site
assessment activity descriptions for each
of the site assessment activities to be
performed.
e) Guidance Materials
Guidance materials for performing PAs, Sis, and
HRS scoring packages are currently being
developed. These guidance materials will be
listed here as they are finalized and distributed.
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(i) Detailed budget and cost information
presented in several different ways in a
series of tables. The budget information
that is required by the first two tables
(see Appendix B) can be used to
generate the summary information
required by the following two tables
(see Appendix B). This budget
information should include the
following:
(A) A budget for each of the site
assessment activities to be
performed, itemized by object class
category. This information should
be presented first by average cost
per site and second by total costs
across all sites. A sample of this
itemized budget information for
PAs is provided in Appendix B;
similar cost information must be
provided for all other proposed site
assessment activities.
(B) A summary budget table that lists
the total costs associated with each
object class category for all site
assessment activities to be
performed across all sites. A
sample of this budget information is
included in Appendix B.
Attachments should be included in
cases where the state deems it
necessary to justify in writing
certain expenses (e.g., the purchase
of equipment or certain expenses in
the "contractual" category). Such
attachments should explain how the
particular expense will be useful in
the attainment of site assessment
program goals.
(C) A summary budget table included
as a means of summarizing the
overall cost information. This
budget table should list the planned
site assessment activities, the
number of sites planned for each
activity, the approximate hours
required for the completion of each
activity per site, the approximate
cost per site, and the total costs per
site assessment activity. Appendix
B provides a sample of this budget
summary table.
(D) A statement concerning indirect
cost rate negotiation agreements.
This statement should include a
copy of any indirect cost rate
agreement negotiated between the
state and the federal government for
use under grants and contracts with
the federal government.
(ii) A work plan for each of the various
types of site assessment activities to be
performed under the CA. The work
plan should provide a breakdown of the
process necessary to perform a
particular site assessment activity,
itemizing each task and listing the
estimated hours associated with the
completion of each task. One of the
primary purposes of a work plan is to
allow the state to efficiently schedule
such resources as manpower, equipment,
and laboratory services in advance of an
activity. Sample work plans for a PA
and an SSI are included in Appendix B.
Work plans should be provided by the
state for all site assessment activities
that are to be undertaken.
3.4.4. Drug-Free Workplace Certification
The state must certify (40 CFR Part 32 - Subpart
F) that it is in compliance with the Drug-Free
Workplace Act of 1988 (Pub. L. 100-690, title V,
subtitle D), which requires applicants for CAs to
certify in writing that they will provide a drug-free
workplace. The state must follow the requirements
contained in the OMB notice entitled "Government-
Wide Implementation of the Drug-Free Workplace
Act of 1988" (54 FR 4946, January 31, 1989).
(Required by 40 CFR Part 35 • Subpart O,
§35.6055(a)(3))
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3.4.5. Certification Regarding Debarment,
Suspension, and Other Responsibility Matters
The appropriate state official must sign the
"Certification Regarding Debarment, Suspension, and
Other Responsibility Matters" (EPA Form 5700-49)
and certify that the state is in compliance with
Executive Order 12549 and 40 CFR Part 32. A
sample form 5700-49 is provided in Appendix B.
(Required by 40 CFR Part 35 - Subpart O,
§35.6055(a)(4))
3.4.6. Procurement Certification
The state must evaluate its own procurement
system to determine if the system meets the
requirements of 40 CFR Parts 31 and 35. After
evaluating its procurement system, the state must
certify that its procurement system meets these
requirements and submit this certification with the CA
application package. Citations should be provided for
those sections of state regulations that are relevant to
procurement. It is recommended that states provide
this procurement certification by completing the
"Procurement System Certification" (EPA Form 5700-
48). A sample form 5700-48 is provided in Appendix
B. If the state's procurement system does not meet
these requirements and, consequently, a procurement
certification is not provided, the state must instead
comply with the procurement requirements of 40 CFR
Part 35 - Subpart O. (Required by 40 CFR Part 35
- Subpart O, §35.6055(a)(5))
3.4.7. Anti-Lobbying Certification
The state must certify (40 CFR Part 34, Appendix
A) that no appropriated funds will be expended to pay
any person for influencing or attempting to influence
an officer or employee of any agency, a member of
Congress, an officer or employee of Congress, or an
employee of a member of Congress, in connection
with any federal award in excess of $100,000, in
accordance with section 319 of Pub. L. 101-121. The
state must follow the requirements in the Interim
Final Rule entitled, "New Restrictions on Lobbying"
(55 FR 6736, February 26, 1990). (Required by 40
CFR Part 35 - Subpart O, §35.6055(a)(6))
3.4.8. Provisions
Conditions
and Assurances/Special
CAs awarded under CERCLA are subject to a
number of terms and conditions. These terms and
conditions must be defined in the CA either as
provisions and assurances, if developed and
incorporated into the application package by the state,
or as special conditions, if developed and incorporated
by EPA. The state should attempt to ensure that
these terms and conditions are addressed in the CA
application package as provisions and assurances.
Requirements not adequately covered in the state's
application package will be included as special
conditions in EPA's offer of award for the CA. The
EPA Regional Office and the state may also negotiate
provisions specific to a particular situation or need at
the time the application package is prepared.
Some provisions are specific to the EPA site
assessment program and must be included in a CA for
site assessment activities by either the state or EPA as
a provision or condition of the award. Provisions
specific to CAs for site assessment activities are:
1) sample splits and analyses; 2) sampling plans;
3) addition of new sites; 4) joint PA/SI efforts;
5) quarterly reports; and 6) release of HRS scoring
information. Failure to comply with these provisions
is sufficient cause for EPA to terminate a CA. Sample
language for the six required provisions discussed
above is included in Appendix B. Sample language
for other provisions and assurances that may apply to
a site assessment CA can also be found in Appendix
B. It should be noted that these sample provisions
and assurances are not exhaustive and that individual
states should consider whether additional provisions
are necessary to address the unique situations
surrounding their proposed site assessment activities.
As discussed above, requirements concerning site
assessment activities that are not adequately covered
in a state's CA application package will be included
as special conditions in EPA's offer of award. These
special conditions would include issues of special
concern to the EPA Regional Office and requirements
that would apply to the unique conditions of sites
within the Region. Some examples of special
conditions that may be included in offers of CA
awards by EPA are presented in Appendix B.
7
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The following plans do not have to be developed
and included as part of the site assessment CA
application package. However, these plans must be
developed and in place before field work may be
commenced by the state.
3.5 Health and Safety Plan
The state, as recipient of a CA award, must
prepare a health and safety plan providing for the
protection of on-site personnel and area residents.
This plan must be made available to EPA upon
request. This health and safety plan must comply
with Occupational Safety and Health Administration
(OSHA) regulations 29 CFR 1910.120, "Hazardous
Waste Operations and Emergency Response," unless
the recipient of the CA award is an Indian Tribe,
which are exempt from OSHA requirements.
(Required by 40 CFR Part 35 - Subpart O,
§35.6055(b)(l))
3.6 Quality Assurance Plan
The state, as a recipient of a CA award, must
abide by the quality assurance requirements described
in 40 CFR 31.45 and develop a non-site-specific
quality assurance plan. The recipient must submit
this plan to EPA in adequate time (generally 45 days)
for approval to be granted before beginning field
work. These plans must comply with the
requirements regarding split sampling described in
section 104(e)(4)(B) of CERCLA. (Required by 40
CFR Part 35 - Subpart O, §35.6055(b)(2))
8
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Appendix A:
Supplementary Materials for Generic
SMOA Language Pertaining to Site
Assessment Activities
SAMPLE FORMAT FOR SUMMARY OF QUARTERLY PROGRESS
QUARTERLY REPORT - FOURTH QUARTER
July 1 - September 30, 1990
"^ Site Name
(including)
Project Officer)
TOTAL
AVERAGE HOURS
PERSITE2/
Direct Personnel^
Hours Per Site
PA
SSI
ESI
HRS
Scoring .
Packages
Total
Site
Disposition^
Date of
Submission
of Report
J7 "Personnel" refers to only those staff persons who were directly involved in performing the site assessment activity.
2f The following codes may be used to indicate the disposition of a site: '
NFA - No further action SSI - Screening Site Inspection recommended
ESI - Expanded Site Inspection recommended ER - Emergency Removal recommended
REF - Site referred to another program/ HRS/NPL - Site recommended for HRS
agency for response scoring/NPL listing
OTHER - Other recommendations (explain briefly)
3/ Average hours per site should be calculated only for complete deliverables.
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Appendix B:
Supplementary Materials for Generic Site
Assessment Cooperative Agreement
Application Package
Sample Letter for Initiation of Intergovernmental Review
This letter may be revised, as necessary, for use when notifying directly affected governmental
entities where a state intergovernmental review process does not cover the activity under consideration.
Revision is also necessary in cases where other site assessment activities are to be performed under the
Cooperative Agreement.
Dear [Designated Single Point of Contact for State Process]:
This letter notifies you of on-going and anticipated Superfund activities to be funded by the U.S. Environmental
Protection Agency. These activides are subject to the State intergovernmental review process. The 60-day comment
period on these proposed actions will begin five days after the date this letter is sent. Please address any comments
on the proposed actions to [ ]. The activities are described below.
1.
Description of Proposed Acdvities: [EPA or name of state department or agency] will conduct Preliminary
Assessments (PAs) on [number of] sites and site inspections on [number of] sites.1
The PA/SI program will be conducted in accordance with the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) (40 CER Part 300) and all other applicable EPA directives.
A PA is a review of available information about a site with the purpose of determining whether further
action, such as an SI, or no further action is needed. The PA should involve an off-site survey but does
, not include on-site work. A PA includes the gathering of data on the magnitude of the hazard, routes of
exposure, nature of the materials present, possible targets, and the existence of easily identifiable, potentially
responsible parties.
The SI builds upon the information gathered during the PA and includes collecting and developing data from
the field. Unlike the PA, the SI always involves an on-site visit. It routinely includes sampling and can
include more sophisticated tasks such as monitoring, remote sensing, and other data gathering techniques.
The purpose of an SI is to determine whether further action is needed and, if so, to gather data sufficient
to score the site for consideration for the National Priorities List, which is the list of sites that are eligible
to receive funds to clean up the site.
2.
Estimated Cost: S[
based on $ /PA. and $_
J, to be 100 percent funded by the U.S. EPA. (Give a range of costs
'SI or other, better estimates.)
If the exact number of PAs and Sis is not known, a range may be given; i.e., "will conduct PAs on
between Row estimate] and [high estimate] sites.
10
,
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Sample Letter for Initiation of Intergovernmental Review (continued)
^
3. List of Sites: [attached]
4. Projected Start Dates: f ]
5. State Project Officer: [name, address, telephone number]
6. EPA Regional Project Officer: Fname. address, telephone number]
As I have indicated above, you will have 60 days after receipt of this letter to submit your comments. However,
I would very much appreciate hearing from you at the earliest possible time so that we can proceed with the program
without any delays. If you have any questions on this project or if you need further information, please contact
[name, telephone number] of .my staff who is available to assist you in any way during your review.
Sincerely yours,
11
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Sampl« "Application for Federal Assistance-" (SF 424)
APPLICATION FOR
FEDERAL ASSISTANCE
2 SATE SUBMITTED
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A 00 >ci Don
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5 AP»UCANT'NFCHMATICN
Organuasonjj unit
Main* igrv* .,iy. county, iuia>. ana zie eooai
Htrrm «no tawonon* numear o« trw e«rsen 10 o« eenuet»a an m«nm
nvo
7 rvpg OF APPLICANT (Kiwr lopreena* wt»r m eeit
« TYPf OF APPLICATION
Q New
Conmuaoon
tr«»f aeproonaH MOMtst in MUM):
A inercaM Award
0 Daaaaa* Ouraaon
Q Havnwn
DD
C. ineraao* Ouraoen
A SUM
8 County
C Munetoal
0
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F
Q. So*oai OiWKt
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i SUM COTOofed in*o«j»on ol
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Sample Budg«t ShMts (SF 424 A)
OMC AAMTOVA! M*. CMI-AMA
BUDGET INFORMATION — Non-Construction Programs
Grant Program
function
or Activity
(•)
1.
2.
3.
4.
S TOTALS
SECTION A - lUDGET SUMMARY
Otdogoffecter*!
OcwMMkAiihtMKe
Mumbti
(b)
Eitimtttd UfMibligatid Funds
Federal
(c)
$
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<<0
$
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Niw or Newhed Budget
Federal
(e)
S
S
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(0
$
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Total
(9)
S
S
SECTION •-•UOGETCATCGOftlES
t Object Oasi Categories
i. tereeRRsi
b. Fringe Benefits
c Travel
4. IvilfMnMt
•. iinf>Ii«t
I. Contitctu*!
g. CombiKtkM
h. Other
1. Tout Direct OwrfM (Him at 6»- 6h)
J. Indirect Oxtget
b. TOTALS (mm of Ci and C|)
(HUNT MKKUUMl FUNCTION 00 ACTIVITY
0)
S
1
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S
S
(3)
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Sample Budget Sheets (SF 424A) (continued)
•.
SECTION C-NON^EOEKAL RESOURCES
t.
ir
11.
12. TOTALS (turn oi (HIM • Midi!)
U. MMl
U. NmMmi
IS. TOTAl (sum olliiwiliMtd 14)
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SECTION D - FORECASTED CASH NEEDS
TMdtM tllVMt
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SECTION E-IUDGET ESTIMATES OF Fl
(I) Onm Pragma
U.
17.
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l».
1*. TOTALS (turn ollinct 1C -H)
lildiartM
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s
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•DERAL FUNDS NEEDED FOR BALANCE OF THE PROJECT
lUTUtlfUMMWNHXXrrunJ
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SECTION F - OTHER BUDGET INFORMATION
(Attach «dditK>iul ShctU if Nccetury)
21. DiiMtauigii:
In. ln«itctCluif«f:
Authorized loc Local R«oroducUon
Sf 424A H-M) P*g* 2
PlMuibM by OU6 bed* A-102
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Sample Background Discussion
The [state department's or agency's] Preliminary Assessment (PA) and Site Inspection (SI) Program is
administered by the . In the past years, the [state
department or agency] has conducted _ PAs and Sis under EPA grants (RCRA 3012 and CERCLA 104(c) and
(d)). During this same time period EPA conducted approximately PAs and Sis within the State. The [state
department or agency] is currently conducting PAs and Sis under an existing Cooperative Agreement (CA)
with EPA.
The Site Investigation and Response (SIR) Section consists of six full-time persons responsible for conducting
PAs, Sis, and other assessment activities, and administrative activities. Secretarial and clerical support is available
within the Division. The [state department or agency] has recently been awarded a Core Program Cooperative
Agreement to provide services, training, personnel, and funds to help support CERCLA implementation activities.
In addition to these resources, the SIR Section has access to the resources of the Division of Wastes Management
and the Department of Natural Resources.
It is anticipated that by [date], CERCLIS will contain at least sites in [state] for which PAs need to be
performed. Approximately sites in the state require Sis. It is anticipated that as many as sites will be added
to CERCLIS during the calendar year via routine site discovery procedures.
The [state department or agency] proposes to conduct PAs and Sis. All work will be approved by EPA
prior to initiation of site work by the state. In addition, __ weeks of Superfund training is proposed here for each
staff member and personnel hours for management assistance activities are required. The grant period would
extend from [date] through [date]. '
15
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Sample Schedule of Deliverables
Activity
Preliminary Assessment
Screening Site Inspection
Expanded Site Inspection
Management Assistant Review of
Contractor Documents
HRS Scoring Packages
Quarterly Reports
October-
December
January-
March
April-
June
July-
September
Total
16
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Sample Preliminary Assessment Description
Preliminary Assessments (PA)
A PA will consist of those activities that are necessary to characterize, in a preliminary fashion, the hazardous
substances present, potential pollutant dispersal pathways, the population and resources that might be affected, and
facility management practices.
A Preliminary Assessment is conducted to determine whether a site listed in CERCLIS should be considered
for further study. A PA will be conducted according to the guidance issued by U.S. EPA in the Preliminary
Assessment and Site Inspection State Cooperative Agreement Guidance, on September 28, 1984 and Preliminary
Assessment Guidance Fiscal Year 1988 OSWER Directive 9345.0-01. PAs at federal facilities will be conducted
by the appropriate federal agency. The state will provide management assistance in reviewing PAs, as requested,
and charge such assistance as a fundable task against this Cooperative Agreement.
An assessment provides the following information:
1. Site identification;
2. Name, location, and ownership of the site;
3. Brief site description, including size and operations;
4. Type(s) of hazardous substances present and type of containers;
5. Characteristics of the relevant hydrogeological and meteorological factors;
6. Population density of surrounding area;
7. Location of other environmentally sensitive receptors (e.g., water supplies, wildlife habitat);
, 8. Conclusions and recommendations; and
9. CERCLIS Input
corrections to current data
alias names
Some of the activities that may be necessary for the completion of the PA are:
interviews with federal, state, and local government personnel and private citizens;
reviews of federal, state, and local government files, reports, and archival documents;
limited title searches to determine property ownership;
review of U.S. Geological Survey, Soil Conservation Service, and hydrogeological and topographic
data;
17
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Sample Preliminary Assessment Description (continued)
review of appropriate private and public well logs;
review of appropriate meteorological data;
review of appropriate land use data;
review of available aerial imagery;
off-site reconnaissance of site (windshield survey) as required to complete the site report and PA
forms; and
other off-site and on-site activities as appropriate to complete PA forms.
A total of PAs will be completed by [state]. It is assumed that the completion and quality assurance
review of each PA will require approximately hours. This will include the completion of Site Identification and
Preliminary Assessment Tasks, and the review of these tasks on forms currently used by EPA for these purposes.
This will also include a conceptual sampling plan recommendation.
A PA will be considered complete when the site information and the appropriate forms are approved and
accepted by the EPA Regional Project Officer (RPO). Deliverables must be submitted to the Regional Office with
sufficient time to allow for a week review period by the RPO, and a week response period for the state. (The
quality of the deliverables will be judged upon adherence to the specific performance criteria negotiated with the
state.)
18
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Sample Average Preliminary Assessment Costs Per Site
by Object Class Category
CATEGORY
Personnel
ESIII
( hrslPAx$ Ihr)
SEC/I
( hrslPAx$ Ihr)
Fringe __ % of personnel cost
Personnel Subtotal
Travel - Off-site reconnaissance
Assumes:
sites require off-site reconnaissance
and off-site reconnaissance conducted per
trip ( persons/trip x $ per diem x
day 1 trip x )
($ /mile x average miles/trip x )
Travel Subtotal
Equipment
Supplies
Contractual
Other
TOTAL DIRECT CHARGES PER SITE
INDIRECT CHARGE @ _ % OF DIRECT CHARGES
TOTAL
COST
-
-- .
19
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Sample Total Preliminary Assessment Costs
by Object Class Category*
CATEGORY
Personnel
Personnel cost
($ /site x sites)
Training ( days)
( hrslperson x persons x$ Ihr -
ES/II)
Fringe % of personnel cost
Personnel Subtotal
Travel
Training
($ per diem x days x persons)
($ /flight x persons)
Travel Subtotal
Equipment
Supplies ($ /site x sites)
Contractual
OTHER TOTAL DIRECT CHARGES
INDIRECT CHARGE _ % OF DIRECT CHARGES
TOTAL
COST
*Budget for one year. (Includes additional non-site-specific costs associated with training.)
20
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Sample Budget Summary for Ail Site Assessment Activities
by Object Class Category
CATEGORY
Personnel
Program Manager I
Environmental Scientist HI
Environmental Scientist I
Secretary
Seasonal Environmental Engineer
Fringes ( % of personnel cost)
Personnel Subtotal
Travel
EPA Seminars and Training
Travel Subtotal
Equipment
Supplies
Contractual
Medical Monitoring
Training Courses (Training for new staff)
Information and Education Services
(Public affairs for program activities)
Geophysical Tasks
Audit Costs
Federal Express (Sample shipment if necessary)
Contractual Subtotal
TOTAL DIRECT COSTS
INDIRECT CHARGE _ % OF DIRECT CHARGES
TOTAL
COST
21
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Sample Overall Budget Summary by Site Assessment Activity
FEDERAL SUPERFUND PROGRAM
(October 1, 1989 - September 30, 1990)
Site Assessment Activity
Preliminary Assessment
Screening Site Inspection
Expanded Site Inspection
HRS Scoring Package
Management Assistance of
Contractor Documents
Training (In House)
TOTAL
Total Number
of Sites
Estimated
Duration
Hrs/Site .
Approximate
Cost/Site
-
Total
•4,
22
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Sample Preliminary Assessment Work Plan
TASK
1. Gather site information
Natural/quantity of hazardous materials
Possibility of exposure
Possible affected target populations and
environments
2. Review and evaluate data
3. Draft PA report
Document findings
Recommend disposition of site and provide
justification for disposition
4. Type, copy, and file
5. Program Manager review and concurrence
TOTAL PER SITE
TIME REQUIRED
PER SITE
(person-hours)
120 hrs
Tasks 1-3 account for hows and will be conducted by:
Environmental Scientist/Level II (ES/II) - $_fyr ($ Ihr)
Task 4 accounts for hours and will be conducted by:
Secretary/Level I (SEC/I) - $_lyr ($ Ihr)
Task 5 accounts for hours and will be conducted by:
Supervisory Environmental Engineer I Level III (SEE/HI) —
$_lyr ($_/hr)
23
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Sample Screening Site Inspection Work Plan
TASK
1. Perform background search
PA file review
Literature/reference search on chemicals and wastes
review USGS, meteorological, land use records, etc.
research/evaluate potential community interest
2. Prepare sampling plan and safety plan
perform site recon
3. Coordinate site visit
obtain site access
prepare equipment, obtain field supplies,
coordinate other logistics
schedule sample analysis
notify appropriate community contacts
4. Conduct field work
perform field audit (1 of every 4 sites)
site mobilization
interview employeeslowners
assess geology/topography
identify potential receptors
document site layout/site activities
collect package, ship samples
5. Perform sample analysis
6. Review analytical data (QA)
7. Compile, evaluate data, write report, prepare
pre-projected HRS score
8. Perform lexicological review
TIME REQUIRED
PER SITE
(person-hours)
24
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Sample Screening Site Inspection Work Plan (continued)
TASK
9. Type, copy, and file
10. Review of SSI by Program Manager, Concurrence,
Recommendations, Cover Letter
TOTAL PER SITE
TIME REQUIRED
PER SITE
(person-hours)
500 hrs
Tasks 1-3 account for hours and will be conducted by: Environmental Analyst II or Engineering Technician
II - $_lyr. ($_lhr)
Task 4 accounts for hours and will be conducted by: Environmental Analyst HI, Environmental Analyst II,
Engineering Technician II, Water Resources Inspector — $ lyr. ($ Ihr)
Task 5 will be performed by EPA for DNR
Task 6 accounts for hours and will be performed by: Chemist II or III — $ 'lyr. ($ Ihr)
Task 7 accounts for hours and will be conducted by: Environmental Analyst II, Engineering Technician II,
Environmental Analyst III — $ lyr. ($ Ihr)
Task 8 accounts for hours and will be conducted by: Secretary I — $ lyr. ($ Ihr)
Task 9 accounts for hours and will be conducted by Environmental
Analyst III - $_Jyr. ($_lhr)
25
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Sample Form 5700-49
EPA
s?A
Coniroi
Unrtto Statas Environmental Pretaction Agtncy
Wiunmgton. DC 20460
Certification Regarding
Determent, Suspension, and Cihw Responsibility Matters
(
orasoaoiva oanteoara carufiaa to tna oast of its knowtaoga and Baiiaf that it and its pnnepaia:
(a) Ar« not orasamry dabanad. susoandad. propoaad for dabarmant. daoaraa ineligible, or votuntanly excluded from
cavarad transacaona by any Federal daparunant or aganey;
(b) Have riot wflttin a tfuweyeeroenc4 preceding thiapreoeaal been cc^^
agamst warn tar eemmtaaien of fraud or a cnrmnal off enaa in connection wtti ebtamng, aaampung te obtain, or
performing a pubie
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Sample Form 5700-48
EPA
•JNfTED STATES ENVinONhCIMTAi. PROTECTION AGENCY
WASHINGTON. OC 204CO
PROCUREMENT SYSTEM CERTIFICATION
10.31-47
APPLICANTS NAME
ASSISTANCE APPLICATION NUM8EH~
APPLICANTS ADDRESS
SECTION I - INSTRUCTIONS
The applicant must complete and suomit a copy of this form with each application for EPA Assistance. If the applicant
has certified its procurement system to EPA within the past 2 years and the system has not been suostantialty revteed.
complete part A in Section II. then sign and date the form. If the system lias-not been certified within the past 2 years!
complete Part B. then sign and date the form.
SECTION II - CERTIFICATION
A. I affirm that the applicant has within the past 2 years c«nif ieo IP EPA that its procurement system
complies won 40 CFR Pan 33 and that the system meets the requirements in 4O CFR Pan 33.
The date of the applicant's latest certification is:
MONTH/YEAR
B. Based upon my evaluation of the applicant's procurement system. I. as authorized representative of the applicant:
(Cheek one of the foUowiog:) «
Q 1 .CEflTTFYthat the) applicant's procurement system will meet ail of the requirements of 40 CFR Pan 33 before
undertaking any procurement aeoon with EPA assistance
Please furnish citations to applicable procurement ordinances and regulations
Q 2.50 NOT CERTIFY THE APPLICANTS PROCUREMENT SYSTEM. The aooiicant agrees to follow tne
requirements of 4O CFR Part 33. including the procedures in Appendix A, and allow EPA preawara review
of proposed procurement actions mat will use EPA assistance.
TYPED NAME AND TITLE
SIGNATURE
DATE
27
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Sample Provisions Required for Site Assessment Cooperative Agreements
1. Sample Splits and Analyses
In accordance with CERCLA section 104(e), state employees, officers, or representatives will provide the
owner, operator, or individual in charge of a site the opportunity to promptly receive a split of each sample collected
at the site, a receipt describing the samples collected, and a copy of analytical results.
2. Sampling Plans
Prior to commencing sampling activities under a Screening Site Inspection (SSI) or Expanded Site Inspection
(ESI) at a site, a sampling plan will be submitted by the [state department or agency] to the Region for review and
approval. The sampling plan shall be submitted to the EPA Regional Office at least two weeks prior to the
commencement of sampling activities to allow sufficient time for review and comment.
3. Addition of New Sites
The [state department or agency] will notify the Region in writing of any changes to the list of sites, submitted
in the CA application package, designated for site assessment activities. Written approval of these changes must be
received by the state before site assessment work may begin at these sites. (In practice, the state may notify the
Region by telephone first, and use the Region's written approval as a follow-up to this notification.)
4. Joint PA/SI Efforts
The [state department or agency] and EPA agree to work together to ensure that sites requiring PAs and Sis
are addressed as expeditiously as possible. If the [state department or agency] falls behind in its accomplishments
as established under this CA, EPA, in consultation with the state, may initiate PAs and Sis at state-lead sites to assist
the state in meeting its site assessment goals, and this Agreement may be modified accordingly.
5. Quarterly Reports
The [state department or agency] will submit progress reports to the Regional Project Manager within thirty
days of the end of each federal fiscal quarter. Such quarterly reports shall include: a description of the work
'accomplished during the reporting period, an explanation of delays or other problems, if any, and a description of
the corrective measures that are planned; a list of site-specific products completed during the reporting period, with
an estimate of the technical hours required to complete each product; a comparison of the percentage of the project
completed to the project schedule, and an explanation of discrepancies; a comparison of the estimated funds spent
to date to planned expenditures and an explanation of significant discrepancies; and an estimate of the time and funds
needed to complete the work required in the CA, a comparison of that estimate to the time and funds remaining, and
a justification of any increase. (Required by 40 CFR Part 35 - Subpart O, §35.6650)
6. Release of HRS Scoring Information
The [state department or agency] will not release HRS scoring information to the public without the approval
of EPA.
28
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Sample General Provisions and Assurances
General Provisions
A. Authority
EPA awards this Cooperative Agreement in accordance with the Federal Grant and Cooperative Agreement
Act of 1977. This Agreement is subject to all applicable EPA assistance regulations.
B. Procurement Standards
This Cooperative Agreement is subject to the procurement standards of 40 CFR Part 35 Subpart O.
C. Prompt Payment Act Provisions
In accordance with Section 2(d) of the Prompt Payment Act, federal funds may not be used by the recipient
for the payment of interest penalties to contractors when bills are paid late, nor may interest penalties be used
to satisfy cost sharing requirements. Obligations to pay such interest penalties will not be obligations of the
United States.
Special Conditions
1.
2.
3.
4.
5.
The Cooperative Agreement recipient will adhere to all accounting standards and guidelines outlined in
40 CFR Subpart O.
Payment for activities contained in this Cooperative Agreement shall be on an actual cost basis, not the
fixed prices included in the assistance application for budget purposes. The application and supporting
documentation or subsequent amendments are for planning purposes.
No portion of this award may be used for lobbying or propaganda purposes as prohibited by 18 U.S.C.
Section 1913 Section 607(a) of Public Law 96-74.
All activities conducted under this Cooperative Agreement shall be consistent with the revised National
Contingency Plan (NCP), 40 CFR Part 300, dated March 8, 1990, (55 FR 8666).
The [state department or agency] agrees to satisfy all federal, state, and local requirements, including
permits and approvals, necessary for implementing activities addressed in this Cooperative Agreement.
To the extent allowable under state law, the [state department or agency] will provide access to the sites,
as well as all rights-of-way and easements necessary to complete the response actions. The [state
department or agency] will provide access to EPA employees and contractors at all reasonable times to
the extent allowable under state law.
29
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Sample General Provisions and Assurances (continued)
6. The [state department or agency] shall prepare its own site safety plan for its own employees or
representatives for any on-site activities performed pursuant to this Cooperative Agreement in which the
[state department or agency] does not accompany the Field Investigation Team (FIT) contractor. The
[state department or agency] employees and representatives will comply with the EPA/FIT site safety
plan applicable to each site. The [state department or agency] reserves the right to act in a more
restrictive manner than the FIT plan requires.
7. The [state department or agency] will allow public access to its records in accordance with applicable
state law. EPA will allow public access to its records in accordance with the procedures established
under the Freedom of Information Act, regulations promulgated pursuant thereto, and agency guidance.
To the extent allowable under state and federal law, parties agree to protect each other's claims for
confidentiality, particularly with regard to documents related to pending or ongoing enforcement actions,
generated by either the state or EPA.
8. Nothing contained in this Agreement shall be construed to create, either expressly or by implication, the
relationship of agency between EPA and the [state department or agency]. Any standards or procedures
prescribed in this Agreement to be followed by the [state department or agency] during the performance
of its obligations under this Agreement do not constitute a right to control the actions of the [state
department or agency]. EPA (including its employees and contractors) is not authorized to represent or
act on behalf of the [state department or agency] in any matter relating to the subject matter of this
Agreement, and the [state department or agency] (including its employees and contractors) is not
authorized to represent or act on behalf of EPA in any matter related to the subject matter of this
Agreement Neither EPA nor the [state department or agency] shall be liable for the contract acts, errors,
or omissions of the agents, employees, or contractors of the other party entered into, committed to, or
performed with respect to this Agreement.
9. The [state department or agency] will assist EPA by making available its records and employees, if EPA
litigates against responsible parties associated with a site where work is performed under the Cooperative
Agreement, to the extent allowable by state law.
10. All Preliminary Assessment and Site Inspection reports, as well as Screening Site Inspection and
Expanded Site Inspection work plans, are subject to review and approval by the EPA Project Officer to
ensure their completeness and consistency with EPA criteria. Deliverables must be submitted to the
Regional Office with sufficient time to allow for a week review period by the Regional Project
Officer, and a week response period for the state. (The quality of the deliverables will be judged
upon adherence to the specific performance criteria negotiated with the state.)
30
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Sample General Provisions and Assurances (continued)
11. The [state department or agency] proposes to accompany EPA's contractor on EPA-Lead Screening Site
Inspections and Expanded Site Inspections based on the following understanding:
a. Once the Site Inspection plan has been finalized, the [state department or agency] and the EPA
contractor shall provide the other party with no less than two weeks notice prior to
commencement of any on-site activities unless the parties mutually agree otherwise. The [state.
department or agency] shall be provided such notice via a schedule of the EPA contractor
activities (location and time) for each site where the EPA contractor is involved in Site
Inspection activities. Inability of the [state department or agency] to provide representation
at a site shall not be cause for the EPA contractor to deviate from the activity schedule.
b. The EPA contractor is accountable to EPA only. The [state department or agency] functions
in an advisory capacity. EPA issues all contractor work assignments and amendments, and
is responsible for directing and evaluating the work of contractors.
c. The [state department or agency] is solely responsible for ensuring that its employees and
representatives are properly outfitted with the appropriate protective clothing and/or equipment.
d. [state department or agency] employees and representatives will comply with the EPA
contractor's site safety plan applicable to each site. The [State Department or Agency] may
act in a more restrictive manner than the EPA contractor's plan.
e. The extent to which [state department or agency] employees perform site tasks will depend
upon the capacity of [state department or agency] employees to perform work safely and
correctly and will be agreed upon between EPA and the [state department or agency] prior to
the actual site work. During the site activity, the [state department or agency], EPA, or EPA
contractor may suspend this Agreement if an employee acts in a manner that may threaten the
safety of him/herself or other site personnel.
12. Projected HRS score sheets shall accompany all PAs, SSIs, and ESI work plans submitted to EPA. The
score sheets are necessary to substantiate the recommended course of action.
13. EPA will provide instructional courses on the proper completion of Preliminary Assessments, Site
Inspections, and HRS scoring. EPA expects that [state department or agency] personnel involved in
completing Preliminary Assessments, Site Inspections, or HRS scoring will attend the courses, [state
department or agency] personnel costs incurred while the course is being given plus necessary travel
expense for the appropriate individuals is allowable for funding under this Cooperative Agreement.
14. EPA and the [state department or agency] are responsible for periodically reviewing the role functions
described in this Agreement for their applicability and effectiveness and negotiate the necessary revisions.
31
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Sample Special Conditions
The following special conditions apply only to that part of the [state department's or agency's] site assessment
program for which EPA will reimburse the state. This grant shall not inhibit the [state department or agency] from
performing additional work at sites at which the [state department or agency] believes it is appropriate, using the
state's own funding sources.
1. All Preliminary Assessment and Site Inspection reports, as well as Screening Site Inspection and Expanded
Site Inspection work plans, are subject to review and approval by the EPA Project Officer to ensure their
completeness and consistency with EPA criteria. Deliverables must be submitted to the Regional Office with
sufficient time to allow for a week review period by the Regional Project Officer, and a week response
period for the state. (The quality of the deliverables will be judged upon adherence to the specific performance
criteria negotiated with the state.)
2. EPA comments on state-generated reports shall be incorporated or rebutted in writing. If a dispute arises
concerning the validity/technical accuracy of the comments, an attempt will be made to mutually resolve all
issues before a final decision is made regarding the comments.
3. The [state department or agency] agrees to submit a copy of the sampling plan for any SSI or ESI to EPA for
review and comment at least two weeks prior to the commencement of sampling activities.
4. Well drilling and geo-physical techniques shall not be used routinely during a screening site inspection. Only
in justified special cases will EPA approve these activities during a screening site inspection.
32
•&U.S. GOVERNMENT PRINTING OFFICE: I99Z - 648-003/40679
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