United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington, DC 20460
93S5.0-04B
PB95-963307
EPA 540/R-95/059
June 1995
vvEPA
Remedial Design/Remedial
Action Handbook
Printed on Recycled Paper
-------
-------
9355.0-04B
United States Office of Emergency and PB95-963307
Environmental Protection Remedial Response EPA 540/R-95/059
Agency Washington, DC 20460 June 1995
Remedial Design/Remedial
Action Handbook
Printed on Recycled Paper
-------
RD/RA Handbook
Disclaimer
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.
Additional Copies
Additional copies of this report may be obtained from the following source:
National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650
-------
Acknowledgements
This handbook is the product of the U.S. Environmental Protection Agency's (EPA's) Office of Emergency
and Remedial Response (OERR). The EPA Work Assignment Manager was Richard Jeng of the Hazardous
Site Control Division (HSCD), Design and Construction Management Branch (DCMB). Lieutenant Com-
mander Jo Ann Griffith, U.S. Public Health Service, was the original author.
Special recognition is extended to the following co-authors for their ongoing support, essential technical
expertise, and invaluable recommendations and insight:
Kenneth J. Erickson, P.E., USEPA, Region IX
Jo Ann Cola, USEPA, Region IX
Frances Costanzi, USEPA, Region III
Gene Wingert, USEPA, Region UI
William J. Bolen, USEPA, Region V
Kenneth Skahn, P.E., USEPA, HQ HSCD/DCMB
Robert Curnyn, P.E., U.S. Army Corps of Engineers
The authors express their appreciation to the following persons for their contributions to the depth of infor-
mation embodied in the handbook: Tracy Hopkins, P.E., USEPA, HQ HSCD/DCMB, and Gary L. Johnson,
USEPA, QAD/RTP-NC.
in
-------
-------
Table of Contents
Chapter 1 Introduction
1.1 Purpose of the Handbook 1
1.2 Overview of the Handbook 1
Chapter 2 Project Management
2.1 Introduction 3
2.2 Definition of Project Management 3
2.2.1 Scope of Work 3
2.2.2 Project Budget, Funding, and Costs 3
2.2.3 RD/RA Schedule 3
2.2.4 Project Team 3
2.3 Skills of a Successful Project Manager 4
2.3.1 Knowledge of Project Management Principles 4
2.3.2 Competency as a Manager in a Project Environment 4
2.3.3 Leadership 4
2.3.4 Technical Competence 4
2.4 Project Management 4
2.4.1 Monitoring the RD/RA 4
2.4.2 Managing the RD/RA 5
2.5 General RPM Responsibilities During RD/RA 6
2.5.1 Responsibilities During RD/RA Planning 7
2.5.2 Responsibilities During RD/RA Execution 8
2.5.3 Responsibilities During RD/RA Closeout 8
2.5.4 Limits of Authority 8
2.5.5 Potential RPM Liability •• 9
Chapters RD/RA Project Planning
3.1 Introduction. • 11
3.2 Developing the Project Management Plan..... 11
3.3 Establishing the RD/RA Lead for Federal-Lead Projects : 12
3.4 Assembling a Technical Review Team 12
3.5 Developing a Communications Strategy 14
-------
RD/RA Handbook
3.6 Collecting Predesign Information 14
3.7 Analyzing Project Constraints 15
3.7.1 Genera! Constraints 16
3.7.2 Property Access Issues 18
3.7.3 Record of Decision Changes 19
3.8 Scheduling the RD/RA 20
3.8.1 Gantt Chart Method 20
3.8.2 Critical Path Method 21
3.9 Developing the RD/RA Budget 21
3.10 Developing a Contracting Strategy for the RD and RA 22
3.10.1 Schedule Acceleration 23
3.10.2 RD/RA Design Approach 24
3.10.3 RA Contracts 25
3.10.4 RA Procurement Strategies 26
3.11 Coordinating with the State 27
3.11.1 State Support Role in Federal-Lead RD/RA 27
3.11.2 Developing the Superfund State Contract 27
3.12 Maximizing Community Relations 28
Chapter 4 Federal-Lead Remedial Design
4.1 Introduction 31
4.2 Deciding to Task the RD to an EPA Contractor or USAGE 31
4.3 Developing the Statement Of Work 31
4.3.1 Preparing the Remedial Design Statement of Work 33
4.3.2 Developing a Preliminary Remedial Design Schedule 35
4.3.3 Developing the Remedial Design Independent Government Cost Estimate 36
4.4 Tasking the Remedial Design 36
4.4.1 Tasking the Remedial Design to an EPA Contractor 37
4.4.2 Tasking the Remedial Design to USAGE 38
4.4.3 Managing the Progress of the Remedial Design 40
4.5 Procuring a USAGE Designer 42
4.6 Reviewing and Approving the Work Plan (ARCS/RACs) 43
4.6.1 Reviewing the Work Plan.... 43
4.6,2 Negotiating with the Contractor 44
4.6.3 Approving the Work Plan 45
VI
-------
4.7 Overseeing the Design Development 45
4.7.1 Design Review Procedures 45
4.7.2 Predesign Phase Submittals 46
4.7.3 Treatabiiity Studies 50
4.7.4 Preliminary Design Phase.... 51
4.7.5 Intermediate Design Phase 55
4.7.6 Prefinal/Final Design 58
4.8 Value Engineering During Remedial Design 61
4.8.1 VE Screen 61
4.8.2 VE Study Team 61
4.8.3 VE Study 62
4.9 Post-Design Activities 63
Chapter 5 Federal-Lead Remedial Action
5.1 Introduction 65
5.1.1 Preparation for the Remedial Action 65
5.1.2 Responsibilities of Key Participants Involved In the Remedial Action 65
5.2 Remedial Action Planning Activities 67
5.2.1 Revising the Project Management Plan 68
5.2.2 Assembling the Technical Review Team.... 68
5.2.3 Finalizing the Superfund State Contract and Defining State Involvement During the Remedial Action.... 68
5.2.4 Developing the Remedial Action Statement of Work 69
5.2.5 Developing the IGCE 70
5.2.6 Developing the Remedial Action Schedule 71
5.2.7 Issuing the RA Work Assignment or Executing the Interagency Agreement 71
5.3 Managing the Remedial Action 71
5.3.1 Managing the RA Work Assignment or Terms of the Interagency Agreement 71
5.3.2 Community Relations During the Remedial Action 72
5.3.3 Reviewing the EPA Contractor's Remedial Action Work Plan 72
5.4 The Remedial Action Procurement Process 73
5.4.1 Sealed Bidding 73
5.4.2 Negotiated Procurement 74
5.4.3 Two-Step Sealed Bidding. 74
5.4.4 Non-Competitive (Sole-Source) Procurement 75
5.4.5 The Remedial Project Manager's Role in the Procurement Process 75
VII
-------
RD/RA Handbook
5.4.6 Approving the EPA Contractor's Selected Constructor 75
5.4.7 Construction Contract Award Controversies 75
5.5 Preconstruction Activities 76
5.5.1 Issuing the Notice to Proceed 76
5.5.2 Conducting the Preconstruction Conference 76
5.5.3 Delivering the Preconstruction Submittals 77
5.5.4 Providing Site Security 77
5.5.5 Mobilizing the Constructor 77
5.5.6 Posting EPA Signs at the Site 77
5.6 Construction Implementation 77
5.6.1 Inspection and Testing 78
5.6.2 Monitoring Construction Progress 78
5.6.3 Reviewing Record Drawings 80
5.6.4 Changes to the Construction Contract 80
5.6.5 Managing Claims 81
5.6.6 Value Engineering During Construction 81
5.7 Contractor Completion Activities 82
5.7.1 Achieving an Operational and Functional Remedy 82
5.7.2 Prefinal Construction Conference 82
5.7.3 Prefinal and Final Inspections 82
5.7.4 Contractual Acceptance of the Project and Warranty 83
5,7.5 Remedial Action Report 84
5.8 State Operation and Maintenance 84
5.9 Site Closeout Process 85
5.9.1 Construction Completion Activities 85
5.9.2 Site Completion Activities 87
5.9.3 Site Deletion Activities 89
Appendix A Glossary A-1
Appendix B Transmittal Forms B-1
Appendix C Design Review Checklists C-1
Appendix D Model RD, RA, and Technical Assistance lAGs D-1
viii
-------
Appendix E Model RD, RD Oversight, RA, and RA Oversight SOWs E-1
Appendix F RD/RA Fact Sheets and Other Guidance F-1
Appendix G State-Lead G-1
Appendix H Enforcement-Lead H-1
Appendix I Operations and Maintenance 1-1
List of Figures
Figure 2-1. Skills of a Successful Project Manager 4
Figure 2-2. Remedial Project Management Responsibilities , 7
Figure 3-1. Project Management Plan 11
Figure 3-2. Potential Technical Review Team Members 13
Figure 3-3. Example of a Communications Matrix 15
Figure 3-4. Typical Collection of Predesign Information 15
Figure 3-5. Examples of ROD Changes 19
Figure 3-6. Gantt Chart 21
Figure 3-7. Gantt Chart with Critical Path Identified 22
Figure 3-8. Construction Bond Requirements 26
Figure 4-1. RPM Responsibilities During Remedial Design 32
Figure 4-2. EPA Contractor RD Standard Tasks (RACs) 33
Figure 4-3. USAGE Standard Design Specifications 34
Figure 4-4. Principal Remediation Categories for RD Schedules 36
Figure 4-5. Components of a Work Plan 43
Figure 4-6. Components of the HASP 47
Figure 4-7. Field Sampling Plan Contents 48
Figure 4-8. Suggested Format for the QAPP 49
Figure 4-9. Suggested Format for a Pilot-Scale Treatability Study 50
Figure 4-10. Preliminary Design Phase Submittal Components 52
Figure 4-11. Intermediate Design Phase Submittal Components 55
Figure 4-12. Prefinal/Final Design Phase Submittal Components 58
Figure 4-13. Value Engineering Screening 62
Figure 5-1. Preremedial Action Checklist 65
IX
-------
RD/RA Handbook
Figure 5-2. Remedial Action Process 66
Figure 5-3. Contractual Relationships in the Remedial Action Process 67
Figure 5-4. Roles and Responsibilities of the Resident Engineer 68
Figure 5-5. RAG and ARCS Contract RA Standard Tasks 69
Figure 5-6. Preconstruction Conference Activities 77
Figure 5-7. EPA Contractor Progress Reports 79
Rgure 5-8. Site Completion and Deletion Processes 86
Figure 5-9. Contents of the Preliminary Closeout Report 87
Rgure 5-10. Final Closeout Report Summary 88
Rgure 5-11. Contents of the Notice of Intent to Delete 90
-------
Acronyms and Abbreviations
Acronyms and Abbreviations
EL
A/E
ARARs
ARCS
BAFO
CA
CBD
CCE
CD
CERCLA
CERCLIS
CFR
CM
CO
CPAF
CPM
CQAP
CRC
CRP
CSI
CWE
D&CA
D&F
DBA
DQO
Architect/Engineer
Applicable or Relevant and Appropriate Requirements
Alternative Remedial Contracting Strategy
Best and Final Offer
Cooperative Agreement
Commerce Business Daily
Construction Cost Estimate
Consent Decree
Comprehensive Environmental Response, Compensation,
and Liability Act
CERCLA Information System
Code of Federal Regulations
Construction Manager
Contracting Officer
Cost-Plus-Award-Fee
Critical Path Method
Construction Quality Assurance Plan
Community Relations Coordinator
Community Relations Plan
Construction Specification Institute
Current Working Estimate
Design and Construction Advisor
Determination and Finding
Davis-Bacon Act
Data Quality Objective
xi
-------
RD/RA Handbook
EL
EPCRA
ERP
BSD
Expenditure Limit
Emergency Planning and Community Right-to-Know Act
Emergency Response Plan
Explanation of Significant Differences
FAR
FCOR
FR
FRP
FS
FSP
FY
Federal Acquisition Regulation
Final Closeout Report
Federal Register
Federal Response Plan
Feasibility Study
Field Sampling Plan
Fiscal Year
GAO
HASP
HTRW
General Accounting Office
Health and Safety Plan
Harzardous, Toxic, and Radioactive Waste
IAG
IDT
IFB
IGCE
Interagency Agreement
Indefinite Delivery
Invitation for Bids
Independent Government Cost Estimate
LAN
LEPC
LOE
Local Area Network
Local Emergency Planning Committee
Level-of-Effort
xii
-------
Acronyms and Abbreviations
CL
EL
H_
LTCS
LTRA
MOU
MSW
NCP
NOID
NPL
NRC
NTCRA
O&M
OERR
OGC
OIG
OMB
ORC
ORD
OSC
OSHA
OSWER
OU
p&ro
PCOR
PFD
Long-Term Contracting Strategy
Long-Term Response Action
Memorandum of Understanding
Municipal Solid Waste
National Contingency Plan
Notice of Intent to Delete
National Priorities List
National Response Center
Non-Time-Critical Removal Action
Operations and Maintenance
Office of Emergency and Remedial Response
Office of General Counsel
Office of Inspector General
Office of Management and Budget
Office of Regional Counsel
Office of Research and Development
On-Scene Coordinator
Occupational Safety and Health Administration
Office of Solid Waste and Emergency Response
Operable Unit
Piping and Instrumentation Diagram
Preliminary Closeout Report
Process How Diagram
-------
RD/RA Handbook
PPE Personal Protective Equipment
PO Project Officer
PR Procurement Request
PRP Potentially Responsible Party
QA
QAPP
QC
Quality Assurance
Quality Assurance Project Plan
Quality Control
RA
RAC
RACS
RCRA
RD
RE
REPR
RFP
RI
ROC
ROD
RPM
Remedial Action
Response Action Contract
Response Action Contracting Strategy
Resource Conservation and Recovery Act
Remedial Design
Resident Engineer
Real Estate Planning Report
Request for Proposal
I
Remedial Investigation
Regional Off-Site Contract
Record of Decision
Remedial Project Manager
S/RPOD
SACM
SAP
SARA
SAVE
SCA
SF
SMOA
Superfund/RCRA Procurement Operations Division
Superfund Accelerated Clean-Up Model
Sampling and Analysis Plan
Superfund Amendments and Reauthorization Act
Society of American Value Engineers
Service Contract Act
Standard Form
State Memorandum of Agreement
XlV
-------
Acronyms and Abbreviations
SMP Site Management Plan
SOP Standard Operating Procedure
SOW Statement of Work
SSC Superfund State Contract
DL
EL
W,X,Y,Z
TA
TAG
TO
TERC
TQM
TRT
UAO
USAGE
VE
VECP
VEP
WA
WACN
WACR
WAF
WAM
WAP
WBS
WP
Technical Assistance
Technical Assistance Grant
Technical Direction
Total Environmental Restoration Contract
Total Quality Management
Technical Review Team
Unilateral Administrative Order
United States Army Corps of Engineers
Value Engineering
Value Engineering Change Proposal
Value Engineering Proposal
Work Assignment
Work Assignment Closeout Notification
Work Assignment Completion Report
Work Assignment Form
Work Assignment Manager
Work Assignment Package
Work Breakdown Structure
Work Plan
xv
-------
-------
Chapter 1« Introduction
Chapter 1 Introduction
1.1 Purpose of the Handbook
The purpose of this handbook is to provide Reme-
dial Project Managers (RPMs) with an overview of
the remedial design (RD) and remedial action (RA)
processes. The handbook may be used by the entire
range of RPMs—from those who have had little ex-
perience with RD or RA projects to those who have
managed several. It should be most useful for Fed-
eral-lead sites where the Superfund is used to finance
the RD or RA. The management principles outlined
herein, however, apply generally to all lead sites.
The RD/RA Handbook focuses on how an RPM can
use project management principles to implement ef-
fectively a selected remedy in accordance with the
Record of Decision (ROD). It is not a conventional
engineering manual, but rather a general reference
document for issues that arise during the RD/RA
process. Where additional EPA guidance exists on
a topic, it is referenced at the end of the applicable
section.
1.2 Overview of the Handbook
Chapter 2, "Project Management," and Chapter 3,
"RD/RA Project Planning," introduce an RPM to
basic engineering project management principles.
Chapter 4, "Federal-Lead Remedial Design," and
Chapter 5, "Federal-Lead Remedial Action," pro-
vide an overview of the RD and RA processes re-
spectively, as they should occur in Federal-lead,
Fund-financed sites. Chapters 4 and 5 also docu-
ment procedures and suggest RPM actions for Fed-
eral-lead, Fund-financed sites. The appendices, an
integral part of the RD/RA Handbook, contain addi-
tional reference material in support of the chapters.
Every effort has been made to make the RD/RA
Handbook a user-friendly reference guide. The
handbook is in notebook format with tabbed divid-
ers so that revisions or updates to the chapters or
appendices may be added or pages may be removed
where appropriate. Tabbed dividers for state- and
enforcement-lead and operations and maintenance
guidance are included so that those documents may
be added as developed.
The RD/RA Handbook will assist the RPM in nego-
tiating and managing the challenges that arise dur-
ing an RD or RA. It contains detailed information
about the activities that RPMs perform and the tools
that are available to make their job easier. One of
the most important functions that any RPM must
perform, however, is managing the complex profes-
sional relationships that are part of all RD/RA
projects. A typical RPM works with EPA Regional
staff, EPA Headquarters staff, United States Army
Corps of Engineers (USAGE) staff, Alternative Re-
medial Contracting Strategy (ARCS) or Response
Action Contract (RAC) contractor staff, local com-
munity members, and representatives from the states.
Although the RD/RA Handbook defines these rela-
tionships and provides guidance on encouraging
communication among those who will influence the
outcome of an RD/RA project, the RPM ultimately
must decide how to manage the multiple individual
and organizational relationships involved.
-------
-------
Chapter 2 • Project Management
Chapter 2 Project Management
2.1 Introduction
Managing a remedial design (RD) or a remedial
action (RA) presents a number of challenges to the
Remedial Project Manager (RPM). While RD/RA
projects are similar to other design and construction
projects in many respects, there are unique
challenges that RPMs face due to the sensitized
regulatory environment under which these projects
are conducted. For example, managing an RD/RA
project under the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA), as amended by the Superfund
Amendments and Reauthorization Act (SARA),
requires that the RPM balance the sometimes
conflicting objectives and needs of individuals and
organizations whose cooperation is required for
successful project completion. This chapter provides
the RPM with the definition of project management
and covers the skills required of and the activities
performed by a successful project manager, quality
principles to be applied to projects, and other general
responsibilities. The RPM should be familiar with
the project management concepts presented in this
chapter and should periodically evaluate his or her
management approach for effectively directing an
RD or an RA.
2.2 Definition of Project Management
Project management is the process of creating,
monitoring, and controlling the scope of work,
schedule, and budget of an RD/RA project. The
project manager creates and manages the project
team, which is composed of all project participants.
The RPM as project manager acts as the focal point
of communications and coordinates project team
efforts, ensuring that project participants work
together to accomplish the RD/RA project. The
project manager maintains a clear vision of the final
objective—successful completion of the RD/RA
project on time and within the budget—while
coordinating the individuals, organizations,
technology, money, equipment, time, and other
resources to bring it about.
2.2.1 Scope of Work
The RD/RA scope of work must be based on the
Record of Decision (ROD), which defines the
selected remedy to be applied at the site. The
elements of the ROD are contained within the
following documents:
• Work assignments (WAs) issued to the EPA
contractor for Federal/EPA-managed sites
• Interagency agreements (LAGs) for Federal/
United States Army Corps of Engineers
(USACE)-managed sites
• Cooperative agreements (CAs) for State-lead
sites
• Consent decrees (CDs) or unilateral
administrative orders (UAOs) for
enforcement-lead sites
As the focus of the RDIRA Handbook is Federal-
lead sites, CAs, CDs, and UAOs are not discussed
in detail.
2.2.2 Project Budget, Funding, and Costs
Project budget, funding, and costs for Federal- and
state-lead sites are maintained and tracked in the
Comprehensive Environmental Response,
Compensation, and Liability Information System
(CERCLIS). One of the RPM's most important
functions is updating RD/RA budget information hi
CERCLIS as the project progresses.
2.2.3 RD/RA Schedule
The project schedule, developed and managed by
the RPM, is also tracked hi CERCLIS. It is specified
in the WA, IAG, CA, CD, or UAO, depending on
the site-lead status. Scheduling is necessary to
anticipate when project resources or participation
by others will be needed. The RPM updates the
schedule as the RD/RA project progresses.
2.2.4 Project Team
Creating and managing an RD/RA project team from
all the participants in an RD/RA project is a
challenge. The RPM must rely on his or her ability
to communicate among, direct, and coordinate
-------
RD/RA Handbook
project participants. TheRPM should use the project
management plan, the Technical Review Team
(TRT), a communications strategy, and other tools
at his or her disposal to accomplish this task (see
sections 3.2, 3.4, and 3.5).
2.3 Skills of a Successful Project Manager
Successfully managing an RD/RA project requires
the RPM to blend a number of skills. Four of the
most important, as listed in Figure 2-1, are
knowledge of project management principles,
competency as a manager in a project environment,
leadership, and technical competence.
Figure 2-1
Skills of a Successful Project Manager
• Knowledge of project management principles
• Competency as a manager in a project environment
• Leadership
• Technical competence
51-043-19A
2.3.1 Knowledge of Project Management Principles
Each RPM should understand basic project
management principles and the application of these
principles for the successful completion of an RD/
RA project. Technical competence alone is
insufficient because a large portion of the RPM's
job is comprised of non-technical components. The
project manager must perform his or her
management functions with a foundation of basic
project management principles, supplemented by a
common-sense approach based on experience and
effective use of scheduling and budgeting systems.
2.3.2 Competency as a Manager in a Project
Environment
A successful RPM exhibits certain characteristics,
such as having a concern about quality and
performance, leadership ability, anticipating possible
project constraints, staffing the project with quality
people, communicating frequently and effectively,
having effective work systems, documenting the
project decision-making process, delegating
authority when possible, being enthusiastic, and being
sensitive to interpersonal and interorganizational
relationships.
2.3.3 Leadership
The RPM must lead, motivate, and inspire project
personnel to give their best efforts to the project.
Completing an RD or RA brings people together who
do not routinely work together. The RPM must
develop a project team to perform satisfactorily; an
RPM's personal attributes are as important as project
management systems and procedures for this skill.
Leadership includes setting a project's direction,
establishing a vision, and developing and
implementing strategies to achieve the project goals.
2.3.4 Technical Competence
Ideally, the RPM should be competent in a discipline
suitable to the project. This allows the RPM to feel
comfortable with, and contribute to, the highly
technical aspects of the RD/RA and enhance his or
her ability to communicate effectively with technical
participants in the project. An RPM familiar with
the technical aspects of a project is better equipped
to make decisions regarding the project scope,
schedule, and budget issues, thus reinforcing his or
her leadership position and gaining respect from
project team members. RPMs lacking the applicable
technical abilities for their projects should select
others with these skills to assist in RD/RA activities.
One of the best training methods for an inexperienced
RPM is to seek an apprentice relationship with an
experienced RPM, particularly before assuming first-
time responsibility for an RD/RA.
2.4 Project Management
This section presents approaches to routine activities
for monitoring and managing RD/RA projects.
These methods are extremely important in producing
a successful project and have their roots in traditional
project management.
Effective management at the onset of and throughout
a project minimizes the obstacles that develop as
the project progresses. During initial project stages,
it is easier to effect change and to take corrective
action. Changes during later project stages usually
take significantly more effort to achieve, cost more,
and extend the schedule.
2.4.1 Monitoring the RD/RA
The RPM monitors actual site progress, adherence
to the project schedule, and budget and work
-------
Chapter 2 • Project Management
performance throughout the project, using a number
of techniques at his or her disposal.
Site Progress
The primary method for gauging site progress is to
compare actual events with the schedule and budget
developed in the planning phase; this is
accomplished by holding review meetings in
conjunction with obtaining regular status reports.
Both USAGE and EPA contractors should produce
monthly progress reports for RPM use. More
frequent reports may be needed during RA
construction (i.e., the RA statement of work [SOW]
could be written to require weekly reports). The
Alternative Remedial Contracting Strategy (ARCS)/
Response Action Contract (RAC) contractors are
required by contract to provide specific types of
progress reports that the RPM uses to compare the
actual schedule and budget with the planned targets.
To facilitate this comparison, the regular progress
reports must:
• Determine the status and progress of each task
towards its objective
• Report progress for the current period and
estimate progress for the succeeding period
• Report expenditures for the current period and
estimate expenditures for the succeeding
period
• Review total expenditures
• Review the overall schedule and budget status
• Identify issues affecting work progress,
especially ones that may cause delay or
necessitate additional funding
Schedule and Budget
Monitoring and reporting of project schedules are
conducted using the techniques discussed in section
3.8. The RPM uses this information in the short-
term to ensure that critical milestones such as design
reviews are met. These techniques also are used for
long-term project management decisions to avoid
delays that could affect the schedule and budget.
Budget reports are monitored by the RPM to ensure
that a particular activity is being accomplished
according to its overall schedule and within the
budget ceiling, to ascertain that funding is spent
appropriately, and to obtain cost information for
invoice approval. The RPM also reviews budget
reports to assess the underutilization or
overutilization of funds and labor hours (burn rate)
as compared to the expected burn rate.
Work Performance
In addition to routine monitoring of the schedule and
budget, the RPM evaluates work performance.
Where deficiencies are noted, the RPM must be
proactive and correct the deficiencies as soon as
possible. Early corrections allow a project to get
back on course without additional expenditures and
schedule delays.
An RPM may receive a seemingly overwhelming
number of submittals (deliverables) because of his
or her monitoring function. A register, like the one
in Appendix B, can be used by the RPM as a valuable
tool to track submittals, due dates, and required EPA
action. The RPM should decide which submittals
he or she will review and which submittals the
Technical Review Team (see section 3.4) will review.
Implementation of effective quality assurance and
quality control (QA/QC) activities to support RD/
RA work is critical to work performance. The RPM
is responsible for planning, implementing, and
assessing the effectiveness of required and
appropriate QA/QC activities that support all phases
of the RD/RA process. Part C of the ANSI/ASQC
guidelines should be used as the basis for QA/QC
for RD/RA projects.
ANSI/ASQC E4-1994, "Specifications and
Guidelines for Quality Systems for
Environmental Data Collection and
Environmental Technology Programs," Part C,
provides the minimum quality systems
requirements for the design, construction, and
operation of technology usedforRDIRAs.
2.4.2 Managing the RD/RA
Although a project manager is held accountable for
all aspects of a project, a Superfund RPM seldom
has the authority or the control of all external factors
to ensure that a project proceeds according to plan.
Thus, the RPM must develop a proactive approach
to project management.
-------
RD/RA Handbook
For example, routine progress meetings help the
RPM identify potential deviations from the project
strategy. RPM response to a particular project
management issue varies depending on the problem
and its immediacy—some deviations will be long-
term trends rather than immediate events. Deviations
from project strategy are avoided or controlled by
initiating preventive or corrective actions. The
proactive approach emphasizes anticipating potential
problems and developing pre-emptive solutions,
devising work-around strategies when problems do
arise, and modifying the project with minimum
disruptions to handle surprise situations that
inevitably arise.
Anticipatory Actions
Anticipatory actions are preventive strategies for
avoiding potential schedule disruptions. Possible
actions include:
• Requesting USAGE assistance in EPA
contractor oversight
• Maintaining strict submittal schedules
• Increasing direct observation of office or field
activities
• Maintaining awareness of upcoming project
milestones and associated EPA reviews
• Identification and resolution of property
access issues
• Early and continued interaction with the
community
• Early state involvement
Work-Around Strategies
Work-around strategies respond to negative
deviations (usually in schedule, budget, or personnel
resources) to accommodate changes and minimize
the effects on overall completion of the project.
Examples include:
• Streamlining requirements for work products
to avoid repetition of data in multiple
deliverables
• Conducting in-progress reviews to eliminate
interim deliverable requirements
Modifications to Project Strategy
Modifications are used to accommodate deviations
only as a last resort. Modifications alter the project
budget, schedule, or scope and may require:
• Additional funding (if available)
• ROD changes
• Superfund state contract (SSC) changes
2.5 General RPM Responsibilities During
RD/RA
This section provides an overview of the RPM's
responsibilities during the performance of the RD/
RA. As a professional project manager responsible
for the successful completion of a technically
complex, multi-million dollar design and
construction project, the RPM has an instrumental
role in the planning, execution, control, and closeout
of the RD/RA. As such, the RPM is a guardian of
the taxpayer's money, imbued with upholding the
public trust in executing a ROD as promised.
To carry out his or her responsibilities, the RPM must
oversee the successful completion of the RD/RA,
regardless of lead, and ensure that the completed
remedy meets all goals and objectives described in
the ROD. The RPM's involvement in ensuring that
the objectives and goals are achieved varies
depending on the designated lead agency or party.
In attempting to achieve the end results of the RA,
the RPM should manage the big picture and not
micro-manage all aspects of the project. Micro-
management can result in the RPM becoming
overwhelmed as the project progresses. The RPM
must use appropriate team members to help manage
the RD/RA and delegate responsibility to those
individuals or organizations so that he or she can
effectively manage the entire project.
Specific details on RPM responsibilities are
presented throughout Chapters 3, 4, and 5.
Figure 2-2 lists the RPM's general responsibilities
during each of the RD/RA phases. RPM
responsibilities can be divided into the following
categories, each described below, which provide a
-------
Chapter 2 • Project Management
Figure 2-2
Overall
RD/RA Planning
RD/RA Execution
RD/RA Closeout
Remedial Project Management Responsibilities
• Ensures completed remedy meets all goals and objectives in the ROD
• Focuses on the overall management ("big picture") versus micro-management of RD/RA
• Develops project management plan
• Organizes Technical Review Team
• Establishes communications strategy
• Understands requirements and procedures of EPA support contracts
• Prepares SOW, schedule, budget/independent government cost estimate
• Revises budget and schedule based on review of the contractor's/USACE's work plan
and subsequent negotiations
• Coordinates with the state/potentially responsible parties (PRPs) regarding site access
• Ensures public awareness of RD/RA activities
• Ensures all applicable or relevant and appropriate requirements (ARARs) are identified
for the site
• Plans necessary QA/QC activities
• Monitors, controls, and revises schedule on regular basis
• Monitors, controls, and revises budget on regular basis
• Audits project execution
• Reviews key deliverables and ensures quality products
• Manages WAs, lAGs, CAs, CDs, and other agreements
• Facilitates communications between parties
• Updates CERCLIS/WasteLAN Systems
• Maintains administrative record/site files
• Conducts final inspection
• Reviews RA reports
• Prepares WA closeout report or formal cioseout request for the IAG, reviews and approves
invoices, and deobligates any remaining funds in WA, IAG, or CA
framework for understanding the general and varied
nature of the position:
• Responsibilities during RD/RA planning
• Responsibilities during RD/RA execution
• Responsibilities during RD/RA closeout
• Limits of authority
• Potential liability
2.5.1 Responsibilities During RD/RA Planning
The RPM is the key to successful project planning
and should devote considerable time and energy to
the planning and startup phases of the project. The
majority of funds in the Superfund program are spent
on RDs and RAs; consequently, it is important that
each RD/RA project be successful. Although even
the most carefully planned and administered project
can develop serious implementation problems, the
chances of this occurring are greatly reduced by
adequately scoping the project and developing a
strategy for project implementation. When planning
the RD/RA, the RPM must be aware of his or her
role, responsibilities, and level of authority to ensure
that the best plan for accomplishing the objectives
is produced.
-------
RD/RA Handbook
Initially, the RPM should develop a project
management plan (section 3.1) to serve as a
framework for defining the RPM's approach to
project execution. This enables the RPM to visualize
the specifics of the project, make key decisions
regarding execution, consider constraints, and plan
accordingly. The project management plan is an
evolving document that is updated periodically as
more information is gathered and circumstances
change. The purpose of the project management plan
is to develop a strategy to complete the RD/RA
successfully. It is a particularly useful tool for the
less experienced RPM who has not yet managed an
RD/RA project. Less experienced RPMs should
obtain assistance in preparing a project management
plan from a more experienced manager. Experienced
RPMs may find that they already perform a similar
planning exercise when scoping the project.
OSWER Directive 9355.0-43, "Guidance for
Scoping the Remedial Design," (Publication No.
PB95-963306), March 1995, provides more
information on scoping an RD project.
2,5.2 Responsibilities During RD/RA Execution
After the initial planning is completed and the RD/
RA begins, the RPM is responsible for ensuring that
the project progresses on schedule and within budget.
To do so, the RPM manages the EPA contractor,
USAGE, state, or potentially responsible parties
(PRPs) by:
• Initiating and maintaining frequent
communications with project participants via
conference calls
• Conducting regular meetings to discuss RD/
RA progress, identify problems, and take
corrective actions as necessary
• Developing complete documentation of all
meetings and conference calls
• Ensuring timely review of key deliverables by
the TRT (section 3.4)
2.5.3 Responsibilities During RD/RA Closeout
Upon completion of the RD/RA, the RPM must
ensure that the appropriate procedures are followed
for closing out the EPA contractor WA, the USAGE
LAG, the state CA, or the PRP-lead activities. The
RPM also ensures that the proper transfer of sites to
parties responsible for operation and maintenance
(O&M) of the remedy takes place. For Federal-lead,
Fund-financed sites, the state generally is responsible
for O&M and its responsibilities are outlined in the
SSC. Chapter 5 and section 3.11 contain additional
information on these responsibilities.
2.5.4 Limits of Authority
During project execution, EPA enters into
agreements with a state, USAGE, a contractor, or
PRPs to accomplish all or part of the remedial
activities at the site. Even though the successful
completion of the RD/RA is the RPM's
responsibility, he or she often does not have the
authority or ability to control all external influences
that can impede the project's successful completion.
For Federal-lead/EPA-managed RDs and RAs, the
RPM must know the contracting structure of the
project; the RPM cannot direct or assign work not
specified in contract documents (e.g., the SOW or a
WA) or enforcement documents. The Contracting
Officer (CO) is the only government official who
can authorize work beyond the original scope of the
WA. To prevent this from happening, the RPM must
develop a thorough SOW for the WA while being
familiar with the terms and organization of all
agreements with all the parties involved. For
Superfund sites, the RPM usually functions as a
Work Assignment Manager (WAM). When
functioning as a WAM, the RPM should be aware of
his or her limits of authority in directing and
authorizing work. As the CO is the only government
official authorized to commit government funds in
a WA, the RPM must not direct a contractor to initiate
work before receiving authorization from the CO.
When USAGE is the contracting party and manages
the RD or RA, personnel from USAGE authorize
the work. The RPM should understand his or her
role and limits of authority and work within the limits
of the particular contractual agreement (the IAG).
In addition to knowing his or her limit of authority
under each type of agreement, the RPM must
administer the necessary paperwork for the
agreement. For all types of agreements into which
-------
Chapter 2 • Project Management
EPA enters with third parties to implement
Superfund remedial activities, the RPM usually
initiates, monitors, revises (as necessary), and closes
out the agreements.
2.5.5 Potential RPM Liability
The RPM should understand his or her own liability
and the liability of others during the performance of
theRD/RA.
Remedial Design
Although the RPM approves the design and
deliverables before they are implemented, EPA's
review and approval does not imply an assumption
of responsibility for design deficiencies, errors, or
omissions. Whenever the RPM submits review
comments or approves a design, the correspondence
should include a clause that emphasizes that the
responsibility for the effectiveness of the design rests
with the designer and that RPM "approval"
constitutes only an authorization to proceed.
Likewise, the RPM does not approve, although he
or she may appear to do so, other design-related
.deliverables such as the health and safety plan
(HASP) and the quality assurance project plan.
The RPM also must guard against directing the
design contractor toward an unsound design. If the
RPM does so and the implemented design fails, and
the contractor was not negligent in implementing
the design, then the design contractor's liability is
reduced or eliminated, regardless of whether the RD/
RA is a Federal-, state-, or enforcement-lead project.
However, the RPM, as a federal employee, would
not be personally liable for government damages
resulting from directing the design contractor
because government employees are protected from
personal liability incurred from performance of their
job duties under the Federal Torts Claims Act. An
RPM could incur personal liability for damages,
however, if the damages are the result of an action
the RPM knowingly performed outside the scope of
his or her job duties or area of competence.
To avoid those situations, the RPM should assemble
a complete and competent TRT to review thoroughly
the design (see section 3.4). The RPM also should
verify that the design contractor is complying with
its own design QA/QC plan.
Remedial Action
The RPM must respect the privity of contract
between the contracting party and the constructor.
Unless EPA has a contract directly with a constructor,
EPA must not direct the work of the constructor.
Only the party contracting directly with the
constructor has the authority to do so. For example,
during remediation activities, the RPM must be
cautious to ensure conformance with the
specifications without assuming responsibility for
the direction of the work of the constructor. To
accomplish that, the RPM works with the EPA
contractor or USAGE, which then directs the work
of the constructor.
As with RD deliverables, EPA review and approval
of RA deliverables such as the HASP does not
constitute legal "approval." For more specific
information on legal liability, consult the Office of
General Counsel or Regional Counsel.
If an RA contract modification is required because
of an error or deficiency in the design, the party that
contracted for the design should examine the
designer's possible liability. If sufficient liability
appears to exist, the designer may be held liable.
-------
-------
Chapter 3 • RWRA Project Planning
Chapter 3 RD/RA Project Planning
3.1 Introduction
Any successful project begins with thorough and
sound project planning. This chapter and the
remainder of the RD/RA Handbook focuses
specifically on Federal-lead, Fund-financed sites.
Tabbed dividers have been provided so that
individual documents on state- and enforcement-lead
sites may be added.
The Remedial Project Manager (RPM), acting on
EPA's behalf, is responsible for the quality of the
remedial design (RD) or remedial action (RA)
project. To implement a successful RD/RA project,
the RPM must devote substantial time and effort to
the planning process. The RPM who does so will
face fewer unanticipated management demands as
the project progresses. Although RD/RA project
planning may appear to start after remedy selection
and the signing of the Record of Decision (ROD), it
should commence before the ROD is signed
whenever possible. The earlier the planning begins,
the greater the RPM's ability to direct the RD/RA to
its successful completion.
3.2 Developing the Project Management
Plan
After the RPM is familiar with remedy details and
pertinent site information and history, he or she can
begin making key planning decisions. To facilitate
the planning and eventual implementation of the RD/
RA, the RPM should develop a project management
plan that documents project management goals and
operational procedures. The project management
plan is the RPM's tool to devise and document a
strategy for successfully completing the project on
time and within budget. The project management
plan is a "living" document that is updated when
new information becomes available as the design
proceeds or as site circumstances change.
The RPM is responsible for the quality of the project,
establishing project requirements and
communicating these requirements to the other
project participants, including the designer and the
constructor. To summarize the requirements of the
project fully, the RPM should consider carefully all
aspects of the RD/RA project. A project management
plan enables the RPM to do this effectively.
Figure 3-1 outlines the major managerial decisions
addressed in project management plan development.
Figure 3-1
Project Management Plan
1. Definition of project objectives
2. Organizational structure
• Identifying the lead
• Assembling a Technical Review Team (TRT)
3. Communications structure
• Developing the communications strategy
4. Project constraints
• Analyzing effect on schedule/scope/budget
5. RD/RA contracting strategy
• Identifying opportunities to accelerate the schedule
- Phasing
- Fast-tracking
- Use of preplaced and prequalified contracts
• Selecting the design approach
- Detailed design specifications and drawings
- Performance-based specifications and drawings
• Identifying the RA contract type
- Fixed price
- Cost-plus-reimbursement
- Time and materials
- Indefinite delivery orders
- Service or construction contracts
• Choosing an RA procurement strategy
- Competitive procurement
- Non-competitive procurement
6. Schedule development
7. Budget preparation
• Independent government cost estimates (IGCEs)
8. Superfund state contract (SSC) timing
9. Property access issues
10. Community relations
11
-------
RD/RA Handbook
Plan content will depend on the complexity of the
RD or RA; fewer requirements need to be addressed
for simple projects. The RPM determines plan
contents and the level of detail. Some questions
cannot be addressed until the design is underway;
thus, the project management plan must be
periodically revisited and updated. An inexperienced
RPM should seek technical assistance from
experienced Regional staff or the U.S. Army Corps
of Engineers (USAGE) when developing the plan.
Specific elements of the project management plan
are discussed in the following sections and in
Chapters 4 and 5.
3,3 Establishing the RD/RA Lead for
Federal-Lead Projects
Before an RD/RA project commences, the lead is
established. For Federal-lead sites, the RPM must
select the appropriate means of performing the RD
and the RA. RD responsibilities may be assigned to
an EPA contractor or USAGE, at the Region's
discretion, regardless of cost An Office of Solid
Waste and Emergency Response (OSWER)
Dkective mandated a maximum RA ceiling of $15
million for issuing RA assignments to an EPA
contractor. RAs estimated to exceed $15 million
should be assigned to USAGE for construction
management.
If an EPA contractor will be selected for the RD or
RA or for both, the RPM, with assistance from the
Project Officer (PO), should evaluate the contractor's
success on other projects. Although it may appear
to be desirable to maintain continuity from the
remedial investigation/feasibility study (RI/FS)
through the RA by using the same contractor for the
RD and the RA, the RPM must consider carefully
all options in light of project requirements and
available contract capacity. In some instances, an
EPA contractor will be selected to design the remedy
and USAGE to manage the construction. In these
situations, it is strongly recommended that USAGE
serve as a technical advisor during the RD and be
permitted to participate fully in the review of
drawings and specifications.
OSWER Directive 9242.3-03, December 10,
1991, mandated a maximum RA ceiling of $15
million for issuing RA assignments to an EPA
contractor.
3.4 Assembling a Technical Review Team
The complexity of a typical RD or RA project
requires in-depth knowledge of a variety of
engineering and geological fields, including
chemical, civil, mechanical, and electrical
engineering, and hydrogeology. Since a single RPM
rarely possesses such a broad knowledge base, the
RPM should assemble and coordinate a project team
of career professionals with knowledge in the
applicable fields. Before initiating an RD, the RPM
should review the nature of the project and select
the appropriate technical assistance. The project team
approach, which requires the creation of a Technical
Review Team (TRT) comprised of representatives
from many disciplines, is used by federal agencies
engaged in design and construction management,
including USAGE, and results in higher technical
quality and improved project efficiency.
The TRT may include Superfund technical support
staff, other experienced RPMs, representatives from
USAGE, the state, the Office of Research and
Development (ORD), other EPA programs such as
the Offices of Air, Water, and Solid Waste, or
Technical Assistance Grant (TAG) technical
representative. The RPM should also involve the
state or other agencies with the expertise to assist in
regulatory interpretation for compliance with permit
or substantive requirements.
USAGE uses the project team approach when
managing an RD or RA and taps its own in-house
resources to create a TRT. When issuing work
assignments (WAs) to Alternative Remedial
Contracting Strategy (ARCS) contractors and
Response Action Contract (RAG) contractors, the
RPM must identify additional resources, both
internal and external, that could be used as part of
the TRT to ensure success. For example, the RPM
should consider using USAGE in a technical
assistance capacity. Other agencies have excellent
technical resources and may provide a wide variety
of engineering and project management services
unavailable within EPA. These services can be
obtained by preparing a technical assistance
interagency agreement (IAG) that will explain and
authorize the services needed. An IAG is an
agreement between governmental agencies that
outlines the responsibilities of each agency in a
cooperative project. An RPM will encounter three
12
-------
Chapter 3 • RWRA Project Planning
types of lAGs with USAGE on RD/RA projects: RD
lAGs; RAIAGs; and technical assistance LAGs.The
titles of the lAGs reflect their purposes; technical
assistance lAGs typically are used to facilitate
USAGE provision of technical assistance on a
project. See section 4.4.2 and Appendix D for
additional information.
Once the TRT is formed, team members assist the
RPM in scoping the work and reviewing the work
plan and other crucial deliverables. Document review
Figure 3-2
is a very common bottleneck in project management.
Some EPA Regional offices have adopted an intra-
agency approach involving the creation of peer
review groups from EPA staff to assist RPMs. Peer
review groups tend to be most useful on simple or
small-scale projects or as a component of the TRT.
Figure 3-2 lists potential representative members
of the TRT.
Large, diverse TRTs, with members from EPA and
other organizations located in different areas, present
Potential Technical Review Team Members
EPA Regional Personnel
Technical Suppport Team
Groundwater Technical Support Unit
Other experienced RPMs
ORD personnel
Office of Water
Office of Solid Waste
Office of Air
RCRA representative
Health and Safety Officer
Community Relations Coordinator
Environmental Services Division
Regional IGCE Coordinator
Contracting Officer/Project Officer
Staff attorney
Quality Assurance Manager/Coordinator
State Personnel
State Environmental Departments
State Natural Resources Trustees
Federal Agencies
U.S. Army Corps of Engineers
U.S. Bureau of Reclamation
U.S. Department of Interior
U.S. Geological Survey
Occupational Safety and Health Administration
National Oceanic and Atmospheric Administration
EPA Contractors
ARCS/RACs
Local Government Agencies
Building inspectors
Community members (TAG representatives)
Experience Added to Project Team
Specialized technical services
Specialized technical services
RD/RA management experience
Technology experts
Media experts
Media experts
Media experts
Applicable or relevant and appropriate requirements
(ARARs), regulatory specialists
Health and safety specialists
Experience in communicating with the public
Quality assurance/sampling experts
Costing specialist
Contract/WA administration
Legal expertise
Quality assurance/quality control experts
State ARARs, procedures, concerns
Environmental impact/management
Design, construction, & management experience
Management and oversight experience
Management and oversight experience
Management and oversight experience
Safety and health expertise
Media and weather expertise
Engineering and scientific expertise; RD and construction
management
• Design review plan-checks for compliance with building codes
• Technical expertise
51-043-36C
13
-------
RD/RA Handbook
the RPM with a resource management challenge.
When creating the TRT, the RPM should delegate
responsibilities up front to team members and clearly
establish project and individual requirements for
each team member.
3.5 Developing a Communications Strategy
Once a TRT is formed, the RPM must develop an
effective communications strategy. The strategy
should provide a framework for communication
among a diverse team of individuals, usually
working within different organizational boundaries,
and facilitates efficient exchange of technical,
financial, schedule, and procedural information. As
a general rule, the more information a project
manager passes along to TRT members, the more
likely that they will generate good ideas for the
project and communicate them to the project
manager.
Since the RPM acts as the conduit for RD/RA project
information, he or she should ensure that appropriate
information is communicated to the appropriate
people at the right time. The project management
plan should document a strategy, in written or
graphical form, that:
• Sets up communication procedures
• Outlines frequency of communication patterns
• Provides clear channels for communication
• Establishes controls to identify
communication breakdowns
The RPM should strike a balance between the
frequency of communication among the various
parties and the appropriate level of communications.
The opportunity for miscommunication and
misunderstanding increases with the number of
people involved and the complexity of the project.
The following communications mechanisms should
be included in the project management plan:
• Kickoff meeting involving all team players
• Formal meetings to review progress (e.g.,
design reviews)
• Conference calls
• Periodic status reports
• Informal meetings/interpersonal
communication
An RPM can structure a communications strategy
in many different ways. One suggested method
involves preparing a communications matrix
identifying key team members and how information
(including submittals, memoranda, documents, and
approvals) is distributed among the members. The
RPM should use whichever matrix format(s) best
serves his or her purposes. A generic example of a
matrix format is illustrated in Figure 3-3.
The communications matrix should reflect the
agreement of the entire team and be designed so that
everyone clearly understands his or her role in the
flow of communication before the RD commences.
The roles in the communications matrix should
provide open channels of communication without
inundating team members with too much
information, thereby discouraging a value-added
review. An important aspect of effective
communications is providing TRT members with
advance notice regarding submittals for their review.
3.6 Collecting Predesign Information
During the planning process and before the RD
begins, the RPM must be as thorough as possible in
providing all relevant information (sampling reports,
etc.) to the designer. Predesign information collection
is an essential step in facilitating the smooth
transition from the ROD to the RD and ensuring that
the designer has a clear understanding of the
technical objectives of the ROD. The RPM must be
as thorough as possible in providing relevant
information, but the designer is responsible for
ensuring the completeness of the information
provided. This collection of information, along with
the project management plan, serves as the initial
building block for the RPM to develop the RD
statement of work (SOW) (see section 4.3).
Primary information sources for predesign
information collection include the RI/FS, the ROD,
and other available documents. In addition, much
of the information for Federal-lead RDs may be
obtained through a predesign discussion session,
which should be held soon after the ROD is signed,
involving the RPM, the RI/FS contractor, in-house
14
-------
Chapter 3 • RDJRA Project Planning
Figure 3-3 ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H
Example of a Communications Matrix
Invoice/
Monthly
Reports
Internal
Memoranda
RD
Submittals
(List)
RA
Submittals
(List)
RPM
PO
CO
State
ARCS/RAC
Contractor
TRT
51-043-37A
technical experts, and other Regional personnel
experienced in RD/RA project work.
Representatives from the designer, theTRT, the state,
and other federal agencies also may attend.
A listing of collected information serves as a current
inventory of information pertinent to the RD and
should be attached as an appendix to the RD SOW
so that both the RPM and designer may identify
design information needs. Figure 3-4 lists
information to be collected.
OSWER Directive 9355.0-43, "Guidance for
Scoping the Remedial Design," March 1995,
provides more information on predesign
information collection.
3.7 Analyzing Project Constraints
Although the RPM faces several project constraints
that can jeopardize timely project completion, they
can be minimized through effective planning. This
section describes a list of issues an RPM generally
encounters that can affect the project schedule and
costs. By recognizing potential constraints, the RPM
can develop the most effective RD/RA contracting
strategy to avoid late changes to the budget and
schedule.
Figure 3-4
Typical Collection of Predesign Information
• Initial site conditions (e.g., characteristics, availability
of utilities, restrictions on road use)
• Availability of site access (any known restrictions or
issues)
• Technology/design approach
« Performance standards, ARARs, permits
• Summary of all available technical information (listing
of the source and description of the data)
• Volume of materials to be treated and the accuracy
of the data
• Unresolved issues (including undecided or unknown
performance standards)
• Health and safety concerns
• Operation and maintenance (O&M) issues
• Historical property boundary and ownership information
51-043-388
15
-------
RD/RA Handbook
3.7.1 General Constraints
The following major types of constraints should be
considered for most RD/RA projects:
• Funding
• Schedule
• Health and safety
• Equipment
« Weather
• Change in RPM
• Community relations
• Permits
• Off-site disposal
Funding
All funding constraints must be identified so that
the project may be scoped adequately. The RPM
should know the availability of funds for the RD,
RA, technical assistance, and O&M costs. The RPM
also should be aware of the state cost share.
Incomplete RA funding for the project (only partial
funding available) may result in the need to phase
certain portions of the RA (see section 3.10.1). A
phased RA would alter the design approach.
Additionally, a state's inability to fund expensive
RAs or O&M activities may affect design decisions
(see section 3.11).
Schedule
The RPM, with help from theTRT, prepares a master
project schedule containing major milestones
throughout the RD/RA process. The RPM must
identify any schedule commitments to factor them
into the contracting decision-making process. The
schedule must be updated as the project develops.
Health and Safety
The RPM should be aware of worker and public
health and safety issues because they might affect
project completion. For example, the use of levels
A or B personal protective equipment (PPE) for
workers may affect productivity and, subsequently,
the budget and schedule. There also may be periods
when construction is halted at a site to protect the
public against safety threats such as a potential
increase in air emissions.
Equipment
Although the RPM is not responsible for procuring
equipment, he or she should know if the ROD
specifies a process or remedy that requires special
or proprietary (unique) equipment. Equipment that
needs to be procured under a separate contract or
has a delayed delivery schedule may affect the RD/
RA schedule.
Weather
Geographic location and seasonal weather variances
should be evaluated for the project site. Extreme
temperatures, excessive rainfall, or high winds may
delay RA execution; winter construction shutdowns
are common in the northern United States. Weather
patterns affect design decisions such as whether to
use fast tracking. It may not make sense to fast-track
an RD/RA only to be shut down during the winter.
Change in RPM
An RPM may not be the project manager for the
entire process due to the length of time required for
project completion. To minimize project disruption,
records should be organized and current so that the
replacement RPM can trace the history of the project
and the rationale for earlier decisions.
Community Relations
The RA schedule should accommodate community
concerns. Responding to the community takes much
more of the RPM's time while a site is being
remediated because of the increase in construction
activity (e.g., the community may be affected by
truck traffic or noise levels). The community may
propose a desired hauling route, work hours, etc.
These constraints must be identified to allow the
designer an opportunity to address them.
Permits
Permitting requirements may delay an RD/RA if not
addressed in a timely fashion. Section 121(e)(l) of
the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)
exempts EPA from having to obtain permits (local,
state, or federal) for any RA conducted entirely on
site; however, the "substantive requirements" of such
permits must still be met. This applies to all permits,
including environmental and building permits. The
formal permitting process must be completed for any
16
-------
Chapter 3 • RD/RA Project Planning
off-site activities, because off-site activities are not
exempt from having to obtain permits.
The designer is responsible for applying for all off-
site permits and identifying substantive
requirements, but the RPM must ensure that
permitting requirements for the project are met. As
part of the basis of design report, the designer must
submit a permits plan that lists the permits required
and the strategy for complying with permit
requirements, including how to address the
substantive requirements for the on-site RA. In
addition, the permits plan should include a schedule
for obtaining all required permits before the RA
begins. To prevent RA delays, this process must be
started as early in the design effort as possible.
The expertise to evaluate the substantive
requirements often resides with the appropriate
permitting agency. The RPM must identify the
agencies responsible for setting permit requirements
so that agency personnel may provide assistance with
interpreting the regulations and setting permit
conditions. Arrangements should be made with the
permitting authorities for assistance in reviewing
submittals for compliance both for on-site work
where permits are not required and for off-site work
where permits are required.
The same approach should be used to work with local
authorities to ensure that all national and local
building codes are met. If necessary, an RPM may
request assistance from local permitting authorities
to review pertinent design specifications to ensure
substantive requirements are met. Local authorities,
however, may lack the health and safety training to
be allowed access to certain areas of the site.
OSWER Directive 9355.7-03, "Permits and
Permit Equivalency Processes for CERCLA On-
Site Remedial Actions," February 1992, provides
guidance on permits for CERCLA.
Off-Site Disposal
Section 121(d)(3) of CERCLA requires EPA to
dispose of hazardous waste only at those facilities
operating in compliance with the Solid Waste
Disposal Act. The RPM plays a critical role in
ensuring effective implementation of the off-site
rule. The RPM must determine if the facility permit
or interim status authorizes receipt of waste,
pretreated as required, from the RA site.
The RPM is responsible for contacting the Regional
Off-Site Contact (ROC) in the Region where the
wastes will be shipped. The ROC reports on whether
the facility can currently receive the waste. Often,
determining whether a facility can accept waste is
specific to particular units within a facility, rather
than to the entire facility. Because of the dynamic
nature of compliance conditions at these units or
facilities, status should be verified before each waste
shipment.
A facility that has received a notice of
unacceptability (issued by the ROC) has a 60-day
period during which it may continue to receive
CERCLA wastes while it addresses the violation
cited. The ROC and RPM should communicate
throughout the 60-day period. On the 60th day after
issuance of the unacceptability notice, the RPM must
stop waste transfer to the facility if the facility has
not corrected the problem.
Because the off-site disposal rule can result in
lengthy RA schedule delays, the RPM should be
prepared with an alternative disposal site or other
contingency in place such as requiring the designer/
RA constructor to designate backup facilities.
For example, the disposal contract between the
constructor and the company chosen to manage the
disposal of CERCLA waste off site should specify
the primary and alternate facilities that will receive
the waste for ultimate treatment, storage, or disposal.
The RPM should coordinate with the ROC regarding
the facility permit status of all facilities to receive
waste before a disposal contract is signed. The
contracting party should require the constructor to
provide copies of written agreements between the
facilities and the constructor to document facility
availability.
OSWER Directive 9834.11 and.Ha, "Revised
Procedures for Planning and Implementing Off-
Site Response Actions," September 1993, and
OSWER Directive 9834.11FS, "Overview of the
Off-Site Rule for OSCs andRPMs," September
1993, provide guidance for EPA's off-site
disposal policy.
17
-------
RD/RA Handbook
3.7.2 Property Access Issues
Property access is a potential constraint for both RDs
and RAs and obtaining site access for both will
involve much more effort than an RPM may
anticipate. Early planning is crucial because failure
to obtain access in a timely manner results in
schedule delays and increased costs.
Access for RD Data Collection Activities
The RPM, with assistance from the Office of
Regional Counsel (ORC), should determine if
existing RFFS access agreements, obtained using
the authority provided by CERCLA, allow EPA
access to the site. If new access agreements are
needed, they must be obtained before the designer
goes onto the property. Generally, property access
is not problematic during the design effort because
of existing property access agreements or because
the designer does not need to access the property.
On a few occasions where sampling must occur off-
site (e.g., the ground water in off-site areas must be
sampled) and RI/FS agreements do not cover the
access, property access must be established. At this
stage, the RPM also should begin to explore
obtaining access to utility connections. The RPM
should work with USACE or the EPA contractor to
establish responsibilities for doing so.
Access for RA Implementation
During RD development, the designer should
identify all property access necessary to implement
the RA and submit the information to the RPM as a
design submittal. The RPM, with assistance from
ORC, develops an approach to obtain site access to
the property. The process by which property is
acquired depends upon the parties involved in
remedy implementation and the state where the site
is located.
There are two ways to obtain access to a property to
implement the RA:
• Access agreements
• Property acquisition
Access Agreements
Section 104(e) of CERCLA provides EPA with the
authority to obtain access to property that is
contaminated or threatened with contamination for
implementing response actions. Any existing access
agreements from previous site activities must be re-
examined to ensure that the agreements are valid
during construction. Because of the intrusive nature
of construction, the access agreement should
describe the activities that will occur and the planned
restoration of the property upon completion. This
approach may not be effective for ground water
actions where the extraction well networks extend
across adjacent properties and there is a requirement
for guaranteed long-term access. Access agreements
are valid only for the current landowner whose
signature is on the agreement and do not transfer to
future property owners. Access agreements usually
are not tied to the property deed.
Property Acquisition
Section 104(j) of CERCLA allows EPA to acquire
by purchase, lease, donation, condemnation, or
otherwise any property necessary (generally EPA
will only acquire property that is not contaminated)
to conduct an RA. However, EPA may acquire
property under CERCLA 104(j) only if the state
where the property is located assures EPA before
the property is acquired, through a contract or
cooperative agreement or otherwise, that the state
will accept transfer of the interest after RA
completion. Property acquisition (includes purchase,
easements, leases, etc.) allows EPA to record its
interest onto the property deed. Property acquisition
differs from property access agreements, which are
subject to future access issues should property
ownership change. Acquisition ensures long-term
access for off-site actions. CERCLA 104(j) also
allows EPA to acquire property for off-site staging
areas, creation of new wetlands for ARARs
compliance, or permanently relocating residents.
In addition, other types of property issues may arise
during the RA that should be considered during the
RD:
• Temporary relocations during construction—
Residents may need to be relocated during
construction activities. USACE has a
relocation staff to carry out this effort. ARCS/
RAC contractors must not perform this
function for EPA.
• Replacing damaged property—It may be
necessary for EPA to excavate in residential
areas such as yards, driveways, or sidewalks.
EPA can offer replacements (e.g., replacing
18
-------
Chapter 3 • RD/RA Project Planning
fencing and restoring landscaping). The RPM
should consult with ORC in these instances.
Site access issues must be resolved before
advertising the RA contract. Failure to obtain access
may result in contractor delay claims.
USAGE develops a Real Estate Planning Report
(REPR) for all RDs that it manages. The REPR
describes the property needs for the project based
on information from the designer and associated
costs should EPA choose to acquire property or
interests in property. The RPM should consider
requesting a similar report from an EPA contractor
for EPA-managed RDs. The strategy for obtaining
the property through the access provisions of 104(e)
or acquisition through 104(j), however, is developed
by the RPM and ORC.
Regardless of the RD lead, if property acquisition is
necessary, USAGE must perform that function.
USAGE acquires property (including acquisition of
temporary construction easements) on EPA's behalf
because EPA lacks the appropriate staff to carry out
an acquisition program. EPA contractors can be
tasked to provide real estate support but cannot
determine any purchase price, make any offers, or
negotiate with property owners.
The RPM enters into an IAG with USAGE (if one
does not already exist) for real estate assistance.
When acquiring property, USAGE follows Public
Law 91-646, the Uniform Relocation and Real
Property Assistance Act, which governs the means
by which citizens are compensated and the
procedures the government must follow when
purchasing property. Although the law concerns
permanent property acquisition, the procedures are
used by USAGE for all property acquisitions.
OSWER Directive 9355.5-01/FS, "Real Estate
Acquisition Procedures for USAGE Projects,"
February 1990, outlines USACE's role in real
estate acquisition under CERCLA.
3.7.3 Record of Decision Changes
The RPM must ensure that the RD is consistent with
the ROD. After a ROD is signed, information may
be received or generated during the RD/RA process
that could affect how EPA believes the selected
remedy should be implemented. These changes may
include a change in the remedy scope or performance
standards or an increase in costs or treatment
quantities. In case of a deviation from the ROD, the
designer should immediately notify the RPM. The
RPM then makes a determination whether the design
results in one of the three categories of ROD changes
described below. Figure 3-5 illustrates examples of
each type of ROD change.
Figurb3-5
Examples of ROD Changes
Minor- Testing during RD shows that soil volume
requiring treatment is 75,000 cubic yards, not the 60,000
estimated in the ROD. the remedy cost, however, will
increase only by five percent because of economies of
scale.
Significant- Residuals from a treatment operation were
unexpectedly hazardous and must be disposed of in a
Subtitle C landfill, rather than a Subtitle D landfill.
Fundamental- The in-situ soil washing remedy selected
in the ROD proves to be infeasible to implement after
testing during the RD. A decision is made to excavate
and thermally treat the waste instead.
51-043-39
Minor Changes
Minor changes have little or no effect on the overall
scope, performance, or cost and should be recorded
in a memorandum in the post-decision document file.
Significant Changes
Significant changes have a profound effect on the
scope, performance, or cost of the remedy and are
documented in an Explanation of Significant
Differences (BSD) as required by CERCLA
Section 117(c). Depending on the significance of the
change, a public comment period may be warranted.
While the BSD is developed, EPA may continue with
the design or construction activities.
Fundamental Changes
Fundamental changes occur when fundamental new
information results in a change of the selected
remedy and must be documented by a ROD
amendment. The amendment must be prepared in
accordance with procedures outlined in iheNational
Contingency Plan (NCP),.4Q Code of Federal
Regulations (CFR) Section 300.435(c)(2). If a ROD
19
-------
RD/RA Handbook
amendment is necessary, affected site activities
should be stopped until an amendment is issued.
Work unaffected by the change may continue.
Documenting both minor and significant ROD
differences is an NCP requirement that must be
performed in a timely manner. Preparing the
documentation for ROD changes cannot wait until
site deletion. No site will be eligible for the NCP's
Construction Completion category with outstanding
memoranda on minor changes or outstanding ESDs
on significant changes.
Significant or fundamental ROD changes must be
reflected in the SSC. The RPM must ensure that the
state is aware of the ROD changes and that they are
incorporated into the SSC.
OSWER Directive 9355.3-02IFS, "Guide to
Addressing Pre-ROD andPost-ROD Changes,"
April 1991, outlines how to address and
document ROD changes.
3.8 Scheduling the RD/RA
In the project management plan, the RPM, with the
assistance of theTRT, develops a baseline schedule
from start to completion of the RD and RA. The
RPM creates an initial RD/RA schedule during the
planning stage that builds upon the schedule
information in the Comprehensive Environmental
Response, Compensation, and Liability Information
System (CERCLIS). An inexperienced RPM should
communicate with experienced RPMs who have
successfully managed an RD or RA to identify
obstacles and factors that will affect the overall
schedule (see section 3.7).
Project scheduling flows from the work breakdown
structure (WBS), a standardized system for
numbering each work element (see the statement of
work [SOW] for a RAC). The schedule assigns dates,
durations, and interconnections to the tasks and
subtasks identified in the WBS. Start and end dates
for each task and subtask in the WBS are based on
the RPM's experience and knowledge of site
conditions, on the advice of the TRT and more
experienced RPMs, existing guidance for scheduling
RDs and RAs, and the RPM's ability to balance
priorities. Although some tasks are conducted
concurrently, some depend on the successful
completion of others. The interrelationships among
tasks need to be identified and reflected in the
scheduling technique used by the RPM.
The RPM should evaluate the appropriateness of
accelerating the schedule. For example, the RPM
may want to consider acceleration options (e.g.,
phasing and fast-tracking) for RDs. Generally, more
opportunities exist for schedule acceleration during
the RD than the RA (see section 3.10.1).
The baseline project schedule is the basis for
negotiations with the EPA contractor and is used to
develop agreed-upon timeframes for USACE-
managed projects. When the EPA contractor
provides the RPM with a detailed RA or RA schedule
(as part of the work plan submittals), it should be
incorporated into the RPM's overall baseline project
schedule. For USACE-managed projects, the
schedule is maintained by USAGE with a copy
provided to the RPM. The approved project schedule
must be established early in the RD or RA and must
incorporate any scope changes as they occur to
remain a valid benchmark for evaluating schedule
performance. The RPM should review the schedule
on a monthly or more frequent basis. Because the
schedule is a tool for evaluating contractor or
USAGE performance, it may be changed only upon
prior EPA approval. The RPM also should update
schedule changes in CERCLIS and inform EPA
management as necessary. Two scheduling
techniques are suggested: the Gantt chart method
and the critical path method (CPM). EPA
predominately uses the former.
3.8.1 Gantt Chart Method
The Gantt chart is a bar chart presenting a list of
tasks or activities required to meet an objective with
estimates of time required to complete each task.
Time is usually displayed as a horizontal bar with a
dateline placed at the top. Tasks or activities are
scaled to show expected durations—the length of
each line represents the number of planned labor
hours/days for a particular activity. For example, in
Figure 3-6, Task A is scheduled for three days and a
horizontal bar extends between day one and day four.
Also, Tasks C and D are scheduled for six and two
days, respectively, and each includes two floating
days (note boxes spanning days 11 and 12 for Task
C and days 13 and 14 for Task D). Depending on the
RD/RA project, the time scale should be weekly or
20
-------
Chapter 3 • RD/RA Project Planning
Figure 3-6 ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H
Task
A
B
C
D
E
Gantt Chart
Days
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
.egend
i Planned Activity I i Float
51-043-6
monthly, covering as many years as is necessary for
project completion. The Gantt chart is easy to read,
the time scale is readily comprehensible, and it
clearly identifies where resources are required. Its
main disadvantage is that schedule logic (i.e., tasks
critical to timely completion) is not always evident.
3.8.2 Critical Path Method
Crucial project elements are called critical tasks and
are determined by a process called the critical path
method (CPM.) The critical path is determined by
considering each activity's duration, sequence, and
constraints and may be identified by making the bars
solid. For example, in Figure 3-7, Tasks A, B, and E
are critical tasks; therefore, they are represented by
solid horizontal bars. Noncritical tasks are displayed
differently.
CPM uses precedence diagrams for a graphic display
of tasks and subtasks. CPM should be used to
determine the project length and to identify activities
critical to project completion. The critical path of a
project is the series of interdependent activities of a
project that must occur in a specific sequence. The
CPM illustrates schedule logic. Disadvantages of
using the CPM are that the time scale is difficult to
understand, since time is usually denoted above or
below each task, and it is difficult to assess resource
use, because resources are not depicted on the
diagram.
3.9 Developing the RD/RA Budget
The RPM is responsible for controlling RD/RA cost
when Superfund monies are used for cleanup
activities. The RPM controls RD/RA costs by
establishing a preliminary budget and periodically
updating it. After the ROD is signed, the RD/RA
budget and schedule developed during the RI/FS
should be reviewed for accuracy and corrected, if
necessary. The RPM consults with the IGCE
coordinator, the information management
coordinator, or other experienced staff within the
Region to ensure consistency with available
historical cost and schedule data.
The RPM incorporates budget information into
CERCLIS to ensure funding availability upon
21
-------
RD/RA Handbook
Figure 3-7 ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H
Task
A
B
C
D
E
Gantt Chart with Critical Path Identified
Days
1
2
.
3
.
4
•
5
6
7
8
9
m
10
11
12
13
14
15
-
16
-
17
-
18
-
19
-
20
Legend
F=q Planned Activity ••• Critical Task cm Float
commencement of the design process and to
facilitate other planning and project management
activities. The estimated costs and dates serve as
benchmarks; however, they should be refined and
updated in CERCLIS periodically as they become
more detailed and accurate. Failure to update
CERCLIS hinders efforts to fund and schedule the
project properly, potentially resulting in work
stoppages, scheduling delays, cost overruns, and a
general reduction in project quality.
3.10 Developing a Contracting Strategy for
the RD and RA
When planning the RD/RA project, the RPM should
develop a contracting strategy. The contracting
strategy for RD/RA execution includes several
interrelated decisions including choices for the
following:
• Accelerated or traditional scheduling
• Design approach
• Designer
• RA contract types
• RA procurement strategy
Each decision affects other parts of the strategy. For
example, an accelerated approach to start or
complete a project more quickly affects all other
contracting strategy decisions, which subsequently
affect remediation costs. Project constraints (see
section 3.7) also affect the contracting strategy.
Examples of this include:
• Schedule requirements—Starting or
completing a project quickly could require an
accelerated strategy, which would affect all
other contracting strategy decisions, including
choice of designer, type of RA contract, RA
procurement strategy, and cost.
• Project complexity and size—Project
complexities range from simple earthwork
projects to more complex projects to
innovative technologies. Technical complexity
also affects the type of design approach
needed.
22
-------
Chapter 3 • RDIRA Project Planning
• Level of confidence—The degree of
confidence in the site characterization data
primarily will affect the contract type (e.g., a
fixed-price contract may be inappropriate for a
site where contaminant concentration or
distribution is not well defined).
The following four sections of the chapter describe
the major elements to consider when developing an
RD/RA contracting strategy.
3.10.1 Schedule Acceleration
EPA is committed to expediting cleanups at
Superfund sites. Therefore, the RPM must evaluate
every project for opportunities to accelerate the
schedule. Methods of developing an optimum
schedule for an accelerated RA include phasing, fast-
tracking, and using preplaced or prequalified
contracts. The RPM should be aware, however, that
ill-considered shortcuts or schedule acceleration
during the RD process may result in problems during
RA construction that require more financial
resources to address at that stage of the RD/RA
process.
Phasing
Phasing is the division of a project into smaller work
elements that can be implemented on different
schedules, thereby accelerating the RD and RA. It
allows certain project elements to be started ahead
of others to reduce the hazards present at the site or
to complete simple prerequisite work elements ahead
of more complex and hazardous ones. All elements
may be in progress simultaneously, but each one has
its own schedule and rate of progress. Phasing is
advantageous because the initial RA start date can
be accelerated. The following criteria can be used
for grouping RD/RA activities into discrete work
elements:
• Existing information
• Type of waste
• Funding availability
Existing Information
When sufficient information is available to design
some RA components, these elements may be
phased. Typically, these activities include road or
fence construction, utilities installation, building
demolition, tank removal, and site preparation. These
activities can be completed and RA contracts
procured while data on other aspects of the design
are gathered.
Type Of Waste
Segregation of nonhazardous and hazardous work
elements can be a simple criterion for project
phasing. The engineering required for the
nonhazardous components of a project is frequently
more conventional and may lend itself readily to an
accelerated schedule. Activities generally suitable
for this approach include constructing roads and
fences and installing utilities. Whenever possible,
construction activities should be designated as
nonhazardous to allow for more open competition,
thereby resulting in lower government costs (29 CFR
1910.120 may not apply).
Funding Availability
As stated in section 3.7, funding constraints may
create the need to phase an RA. For example, an
incinerator project could be phased by mobilizing
and constructing the incinerator as phase one and
operating the incinerator as phase two.
Fast-Tracking
Fast-tracking is a procedure that is complementary
to phasing. Whereas phasing is the process by which
large complex projects are partitioned into smaller,
more manageable work elements, fast-tracking
accelerates the implementation of individual work
elements. Fast-tracking techniques manipulate the
internal steps required to complete each phased
element, thereby optimizing the overall schedule.
There are several ways in which the RD/RA process
can be fast-tracked:
• Expediting the RD
• Optimizing the RD
• Fast-tracking the RA
Expediting the RD
In this method, steps in the RD process are
eliminated or shortened. However, short-cutting
involves the assumption of risks. The level of detail
in an RD can be reduced, particularly for simple
engineering efforts, such as soil excavation or tank
dismantling. Several Regions also are developing
standardized design specifications that can be used
to shorten the design time. The designer would begin
23
-------
RD/RA Handbook
with the standard specifications and modify them
for the specific site. USAGE, with funding assistance
from EPA, developed a series of standard design
specifications for certain types of remediation
activities that are available to any designer involved
in federal remediation (see section 4.3.1 and Figure
4-3 or USAGE'S Huntsville Construction Division
should be contacted for additional information).
Optimizing the RD
Optimization is the rearrangement of the sequence
in which RD elements are performed to enhance the
overall schedule. Examples include:
• Completing the site preparation portion of a
design (and other simple construction
activities) and initiating construction while the
rest of the design effort continues
• Scheduling all design reviews in parallel with
ongoing design work so they are not on the
critical path
Fast'Tracklng the RA
Some projects can be divided into separate stages
for construction by awarding contracts for each stage
of construction work as soon as the design is
completed (e.g., site preparation, procurement of
long-lead equipment, utilities installation).
OSWER Directive 9355.5-2, "Guidance on
Expediting RD and RA," contains additional
information on phasing and fast-tracking.
Use of Preplaced or Prequalified Contracts
The use of preplaced or prequalified contracts is
another means of expediting construction initiation.
These contracting methods require approximately
30 to 60 days to initiate construction activities by
eliminating the solicitation and audit requirements
of site-specific contracts. Additionally, lengthy
delays due to bid protests or bonding difficulties are
eliminated. These contracts reduce competition,
however, and may increase the cost of the project.
Furthermore, because preplaced contracts are cost-
reimbursement contracts, they require more
extensive government oversight than fixed-price
contracts. USAGE has developed methods to
expedite RA initiation through the implementation
of the following two innovative contracting
strategies:
• Preplaced RA and Rapid Response Contracts
• Total Environmental Response Contracts
(TERCs)
There are restrictions on these types of contracts,
but they may provide an excellent means to
accelerate the RA.The RPM is encouraged to consult
with the appropriate USAGE contact to discuss the
possibility of using them.
OSWER Directive 9355.5-05IFS, "Procedure for
Use of USAGE Preplaced Contracts to Expedite
Superfund Cleanups," April 1994, contains more
information on preplaced and rapid response
contracts.
3.10.2 RD/RA Design Approach
The design approach for an RD/RA is an important
part of the contracting strategy. Specifications, a
generic term that includes drawings, are developed
by the remedial designer and included in the RD
package. Specifications contain a description of the
technical requirements the constructor must meet to
implement the RA and the criteria for determining
whether these requirements are met. Two types of
design specifications typically used in Superfund are
detailed design and performance-based
specifications. The type of specification package,
developed in response to specific site characteristics
and the selected remedy, influences both the design
and the RA procurement schedule. Although the
RPM cannot mandate which type of design
specifications the remedial designer should develop,
if the RPM can accurately describe EPA's
requirements for the site in the RD SOW, the designer
should choose design specifications to meet EPA's
requirements. Therefore, the RPM should know the
different types of design specifications and their
effect on the RA procurement strategy when
planning how to manage the RD/RA.
Detailed Design Specifications
Detailed design specifications and drawings are used
in solicitations when the government's technical
requirements are definite and can be clearly
communicated to bidders (e.g., an entire treatment
plant designed down to the bolt level). Under this
type of specification, the contracting party (in some
cases, EPA) or the designer may be responsible for
design and related omissions, errors, and deficiencies
24
-------
Chapter 3 • RDJRA Project Planning
in the specifications and drawings. If the constructor
follows the design and the remedy fails, the
constructor may not be liable. The government must
assume the cost of correcting the problem (and
pursue designer liability, if any, separately). RAs
lending themselves to detailed design specifications
include landfill covers and traditional ground water
treatment systems.
Detailed design specifications permit RA contract
award solely on price and may result in a lower cost
to the government (see section 5.4 for additional
information). Competition for contract award is also
expanded because construction firms without design
capabilities may bid on projects. Although detailed
designs save time during the RA procurement phase
of a project (by alleviating the need for a technical
proposal review), some time is usually lost during
the intensive design effort. The RPM, in consultation
with the TRT, should decide whether the overall
schedule and budget can be reduced using this
approach.
Performance-Based Specifications
Performance-based specifications in the RD package
advise the constructor what the final product must
achieve and explicitly describe how performance
will be measured. The RA constructor proposes the
method to achieve the requirements established in
the specifications. If the RA constructor has
undertaken an impossible task, meets technological
problems, or cannot complete performance due to a
lack of experience, the constructor assumes the risk
of financial loss. This potential risk of financial loss,
however, translates into a higher project cost for the
government (in the form of higher bids).
Performance-based specifications are suitable for
more complex treatment technologies and are
commercially available through a number of
vendors. A performance-based specification package
is generally more easily prepared and can result in a
shortened RD schedule. Time savings, however, are
offset by the additional procurement time needed to
conduct technical evaluations of the submitted
proposals, since each bidder may propose different
means to achieve the prescribed requkements.
3.10.3 RA Contracts
The enormous scale and complexity of procurement
has necessitated the development of a wide variety
of contract types. The appropriate contract to
implement the RA is a project-specific determination
made by the party contracting for the RA. USAGE
and the ARCS/RAC contractor, respectively, will
decide the RA contract type for USACE-managed
and EPA contractor-managed RAs. Although the
RPM does not choose the contract type for the RA
procurement, he or she must be aware of the different
contract types.
RA Contract Type
The three types of contracts generally used for RAs
are fixed-price, cost-reimbursement, and time and
materials contracts.
Fixed-Price Contracts
Fixed-price contracts provide a firm price for the
RA at contract award. The contract amount is
adjusted only when work must be added to or deleted
from the contract, such as upon the occurrence of an
unanticipated event or contingency. Most Superfund
RAs, in which the work is well-defined, are awarded
as fixed-price contracts.
Cost-Reimbursement Contracts
Cost-reimbursement contracts provide for payment
to the contractor of all allocable, eligible, and
reasonable costs expended by the contractor in
contract performance. In addition to the costs, most
cost-reimbursement contracts provide for the
payment of a fee (profit) to the contractor. Cost-
reimbursement contracts contain an estimate of total
cost and a cost ceiling so funds may be obligated.
These contracts should be used only when the
performance cost cannot be estimated at the time of
contract award with the accuracy necessary for a
fixed-price contract. Because cost-reimbursement
contracts require the government to pay for all costs
incurred by the RA constructor, the government
assumes a financial risk. To minimize the
government's potential financial risk, more intensive
contract management is required by EPA.
Time and Materials Contracts
A time and materials contract provides for the
acquisition of supplies, services, equipment, and
construction on the basis of direct labor hours at
specified hourly rates and materials at cost. These
contracts are used only where it is not possible (at
25
-------
RD/RA Handbook
the time of contract placement) to estimate
accurately the scope (extent or duration) of work
required. The contract provides for direct labor hours
at an hourly rate and the provision of materials at a
designated cost. Time and materials contracts require
the use of time and cost standards applicable to the
particular work item.
RA Contract Requirements
After the RA contract type is established, bonding
and wage rate requirements must be met by the
constructor. Bonding and wage rates are the
responsibility of the RA contracting party, but the
CO works with the contracting party to ensure all
requirements are met. The RPM, however, should
be aware of the status of such requirements.
Construction and Service Contract Wage Rates
The contracting party soliciting the RA contract must
differentiate between construction and service
portions of the contract. Whether an RA or portions
of it are determined to be construction (alteration or
repair, including dredging, excavating, and painting)
or service (operating a treatment unit, refuse
removal, etc.) will determine the labor wage rates
and the bonds necessary for the project. The plans
and specifications should differentiate between the
two types of activities so that appropriate labor wage
rates (Davis-Bacon Act rates for construction and
Service Contract Act rates for service) can be used.
For construction work funded in whole or hi part
under Section 104(g)(l) of CERCLA, the law
requires that all laborers and mechanics employed
by contractors be paid wages at rates not less than
those prevailing on projects of a similar character
within the same locality as determined by the
Secretary of Labor in accordance with the Davis-
Bacon Act. Service Contract Act wage rates must be
applied when appropriate for government contractors
providing services.
OERR, "Davis-Bacon Act/Service Contract Act
and Related Bonding," contains more
information on wage rates and bonding
requirements.
Bonding Requirements for RA Contracts
Historically, bonding companies have been reluctant
to issue bonds where the construction cleanup costs
are high. By separating the project into two portions,
construction and service, the overall construction
costs are lower, thereby increasing the opportunities
for contractors to obtain bonds. Performance and
payment bonds are required on all federal
construction jobs over $25,000. Figure 3-8 describes
construction bond requirements. When RA costs
increase, bonds may need to be re-evaluated and
additional bonds obtained by the constructor.
Figure 3-8
Construction Bond Requirements
The Miller Act (40 U.S.C. 270a-270f) requires performance
and payment bonds for any construction contract
exceeding $25,000. h payment bond is required should
the RA contractor fail to pay its subcontractors. The
amount of the payment bond shall equal:
1. 50 percent of the contract price if the contract price
is not more than $1 million;
2. 40 percent of the contract price if the contract price
is more than $1 million but less than $5 million; or
3. $21/2 million if the contract price is more than $5
million.
A performance bond guarantees that the cost of the
construction can be recovered should the RA contractor
default on its obligation. Performance bonds generally
cover 100 percent of the contract price and can be
increased if the cost of the RA changes. The performance
bond requirement may be waived or reduced by the CO,
provided the government's financial interest is adequately
protected.
51-043-40A
3.10.4 RA Procurement Strategies
The selected procurement method should correlate
to the type of work being performed and will depend
on the type of design specifications developed. Since
EPA usually does not directly procure the RA, the
RPM probably will not choose the RA procurement
method. The RPM should, however, be familiar with
the different types of procurement methods. In
general, there are four basic forms of procurement
within federal construction contracting:
• Sealed bidding
• Negotiated procurement
• Two-step sealed bidding
• Non-competitive (sole-source) procurement
26
-------
Chapter 3 • RDIRA Project Planning
For detailed information on these types of RA
procurement, see section 5.4.
3.11 Coordinating with the State
The state is an integral part of the Superfund program
and as such must be afforded the opportunity to
participate in a meaningful way in RD/RA
implementation. As a first step in defining state
involvement for a site, the RPM should determine
whether a State Memorandum of Agreement
(SMOA) exists between EPA and the state (40 CFR
300.500). The SMOA usually establishes the general
roles and responsibilities of EPA and the state during
Federal-lead and state-lead response actions. Having
a SMOA will save tune hi negotiating site-specific
agreements (i.e., Superfund state contracts and
cooperative agreements) and other Superfund-
related issues with the state. For states that have not
signed a SMOA with EPA, the RPM has a greater
role in establishing the terms of the EPA-state
relationship.
Secondly, the RPM and his or her state counterpart
should meet before the RD starts to discuss fully the
roles and responsibilities of both parties. During
this initial meeting, the RPM should question the
state about potential state concerns related to its
CERCLA obligations. State constraints on funding
or property transfer may have a significant effect on
the implementation of the project and must be
identified prior to issuing a design assignment. This
meeting serves as a kick-off to an ongoing exchange
that must continue to take place between EPA and
the state.
Once EPA and state roles are defined by a SMOA or
discussions, the RPM should develop a site-specific
agreement outlining state and EPA responsibilities
for that site. Superfund state contracts (SSCs) or
cooperative agreements (CAs) specify EPA and state
roles for RDs and RAs. In a Federal-lead, Fund-
financed response, EPA is the lead agency and the
state is the support agency (40 CFR 300.500). When
EPA is the lead agency, an SSC is created between
EPA and the state (see section 3.11.2); when the state
is the lead agency, a state enters into a CA with EPA.
SSCs also allow the transfer of necessary resources
that the state may request as part of its support agency
function.
3.11.1 State Support Role in Federal-Lead RD/RAs
For a Federal-lead response, the RPM should
encourage the state to be an actively involved
member of EPA's project team. Under Section 104
of CERCLA, the state is required to:
« Provide a 10 percent cost share of the
remedial response (could be 50 percent or
more for state-operated facilities)
• Conduct and fund all O&M activities
• Accept transfer of all property acquired by
EPA to conduct the RA
In addition to the statutory requirements, Sections
300.515(g) and (h) of the NCP require that the
following be done for RDs and RAs:
• The extent and nature of state involvement
during the RD and RA be specified in site
specific SCCs or CAs
• A joint inspection be conducted at the
conclusion of RA construction
• The lead agency allow the support agency the
opportunity to review documents (i.e., for
Federal-lead RDs, the state is allowed a
minimum of ten working days and a
maximum of 15 working days to review RDs)
Without the state's assurance of its willingness to
fulfill these requirements, the RA cannot be
implemented. An experienced RPM understands that
gaining the state's support takes much more than
meeting minimum requirements. Therefore, early
and full participation by the state is crucial to project
success.
3.11.2 Developing the Superfund State Contract
The SSC is a joint, legally binding site-specific
agreement between EPA and a state to obtain the
necessary state assurances before an RA can begin
at a site. The process of developing an SSC may
take a year or longer. Creating a draft SSC early in
the RD and meeting with the state on a regular basis
as discussed above to resolve common issues should
prevent the SSC from delaying the RA
implementation. Surprising the state with higher
projected RA costs or labor intensive O&M
requirements near the end of the RD is poor project
management. This may cause the state to object to
27
-------
RD/RA Handbook
meeting unanticipated obligations, which may result
in project disruption. Taking a proactive approach
by regularly meeting with the state and creating an
environment where the state is a valuable team
participant should prevent incidents like this from
occurring.
In addition to addressing the state's required
CERCLA obligations, the RPM should also work
with the state to ensure the following issues are dealt
with in the SSC:
• Providing a complete RA cost estimate with
an appropriate contingency amount to
minimize state reluctance to increase its cost-
share during the RA. RA construction change
orders may result in costs exceeding the SSC
amount. To minimize state disagreement over
financial terms as the project progresses,
careful analysis of the RA cost estimate and
the associated contingency must be performed
and included with the SSC.
• Defining if and to what extent the state will be
involved hi RA construction management
(change order and claims review, value
engineering proposals, and USAGE
construction contractor selection technical
evaluation panels).
• Determining at what point the remedy can be
declared "operational and functional" (see
section 5.7.1). Once the remedy is determined
to be operational and functional, the state is
required to assume O&M activities (40 CFR
300.510). The SSC should clearly list the
tests, performance requirements, or other
functional requirements to be used to make
this determination.
• Identifying O&M requirements and projected
costs. In this section, the RPM and the state
should address facility transfer, operator
training, site access for O&M activities, and
the O&M manual contents.
OSWER Directive 9355.0-57FS, "Cost-Risk
Analysis for Remedial Actions," (DRAFT) 1995,
provides guidance on estimating contingency
amounts for RAs,
3.12 Maximizing Community Relations
Community relations is a useful and vital aspect of
the RD/RA process. Community relations activities
serve to keep communities informed of the activities
at the site and help EPA anticipate and respond to
community concerns. EPA, as the lead agency in a
Federal-lead RD/RA, must do the following,
according to 40 CFR Section 300.435:
• Review the community relations plan and
update it as necessary
• Issue a fact sheet and hold a public meeting at
RD completion, as appropriate (public meet-
ings can also be held throughout the RD/RA
process, if appropriate)
A community relations plan is developed for a site
when the RI/FS commences. The community
relations plan should be reviewed and updated to
reflect the anticipated community relations activities
that will occur during the RD/RA. Many RPMs may
recall difficulties in implementing the RA because
of the lack of initial coordination with the community
over construction concerns. The key to effective
community relations is taking a proactive role. The
RPM must seriously discuss the effect of the
construction and ways to mitigate its effect on the
community. The RPM should not wait until the final
design to initiate a discussion of the effects of the
proposed RA with the community because it often
will be too late to accommodate community concerns
by making modifications.
The RPM may be assisted by USAGE (if it has the
RD and/or RA lead) or an EPA contractor in revising
the community relations plan. The Regional
Community Relations Coordinator may also be
consulted. However, the RPM must retain the
primary responsibility for plan implementation.
For ARCS/RAG contracts, all anticipated
community relations support should be described in
detail in the RD and RA SOWs. EPA contractors
may only serve in a supporting capacity; they may
not represent EPA during meetings with the
community.
During the RD, the RPM should meet with local
citizens groups early and often to discuss the effect
28
-------
Chapter 3 • RDJRA Project Planning
of the RA on their community. These effects may
include:
• Air emissions—The potential for fugitive
emissions, types of monitoring, plan for
suppression, warning systems for the
community (Le., to address concerns about
playgrounds, school areas, etc.), and
evacuation procedures are very real
community concerns. Some RPMs have
arranged to have ah" monitoring data read out
to a local point within the community,
installed video cameras to record site activities
for local cable access channels, and worked
with the community to develop a warning
system to notify the community of an
emergency situation.
• Traffic—The RA generally will involve a
substantial increase in vehicular (particularly
truck) traffic around the site. The designer will
suggest truck hauling routes (based on road
weight restrictions, ease of transport, etc.) but
citizens who know the area may have then-
own suggestions. The RPM should consider
the alternatives, which may include rerouting
or restricting the time of day that trucks may
operate.
• Noise levels—The RA may result in an
increase in noise levels in the surrounding
community. The designer is responsible for
evaluating the local restrictions on noise levels
and ensuring that the design incorporates these
standards. Even if the design complies with
the local noise standards, the RPM may need
to consider additional sound suppression
systems to accommodate the community.
• Relocation—The RA may result in temporary
or permanent relocation of community
structures or residents, which the RPM should
address.
• Economic effects—Citizens will question the
economic effect that the RA will have on the
community. As a show of good faith, the RPM
may request that the contract be structured in
such a way as to allow more local business
participation. The contract can be phased (e.g.,
site preparation work, site security) and
separated into nonhazardous and hazardous
components that would allow smaller local
firms to compete.
Overall, the RPM must remember that the
community can also serve as an ally during the RD/
RA effort. For example, community members may
notice suspicious activities and report them to EPA,
thus reducing Superfund site vandalism. By
establishing a rapport with the community, the RPM
will find that the community should be more
responsive which in turn will make everyone's job
easier.
The RPM should also discuss all of the above issues
with local citizens groups before and during the RA.
Section 5.3.2 provides more information on
community relations efforts during the remedial
construction project phase.
OSWER Directive 9230.0-04, "Community
Relations Guidance for Evaluating Citizen
Concerns at Superfund Sites," and EPAI540IG-
881002, "Community Relations in Superfund—A
Handbook (Interim Guidance)," contain
additional information on community relations.
29
-------
-------
Chapter 4 • Federal-Lead Remedial Design
Chapter 4 Federal-Lead Remedial Design
4.1 Introduction
The remedial design (RD) is a series of engineering
reports, documents, specifications, and drawings that
detail the steps to be taken during the remedial action
(RA) to meet the goals established in the Record of
Decision (ROD) and remove the site from the
National Priorities List. This chapter describes the
responsibilities of the Remedial Project Manager
(RPM) in overseeing the development of Federal-
lead RDs.
The RPM ultimately is responsible for overseeing
the successful completion and implementation of the
RD. The RPM's role in the RD process, however,
differs depending on whether the RD is an EPA- or
United States Army Corps of Engineers (US ACE)-
managed RD. For EPA-managed RDs, the RPM
oversees the work of EPA contractors developing
the RD and has more direct control over the RD
effort. For USACE-managed RDs, the RPM
facilitates USAGE development of the RD and acts
in an advisory capacity while remaining responsible
for overseeing the project and ensuring that the RD
meets EPA goals and objectives. The term
contracting party is used in this chapter to refer to
either EPA or USAGE, since both EPA and USAGE
may be contracting with a remedial designer. In some
instances, USAGE will perform the RD in-house and
will not use contractor services.
An overview of the RD process highlighting the
RPM's responsibilities for EPA- and USACE-
managed RDs is presented in Figure 4-1.
Office of Solid Waste and Emergency Response
(OSWER) Directive 9355.1-1, "Super/and
Federal-Lead Remedial Project Management
Handbook"; and EPA 5401R-94/022 and 103,
"Response Action Contract Users' Guide,
Volumes 1 and 2," provide additional
information on project management.
4.2 Deciding to Task the RD to an EPA
Contractor or USAGE
The RPM must determine whether to task the RD to
an Alternative Remedial Contracting Strategy/
Response Action Contract (ARCS/RAC) contractor
or to USAGE. The RPM should consult with the
Technical Review Team (TRT) and consider the
following factors when making this determination:
• Need for on-site federal presence
• The RPM's workload and availability to
manage government contractors
• Technical expertise needed for the design
• USAGE and ARCS/RAC contractor
experience and history
• ARCS/RAC contractors' contract capacities
• Conflict of interest (COI) screening
• Continuity with future RA activities
Tasking the RD to an ARCS/RAC contractor or to
USAGE will affect the RPM's workload and
responsibilities. The interagency agreement (TAG)
between EPA and USAGE creates a different type
of contractual relationship than the relationship
between EPA and its contractors. Regardless of
whether EPA or USAGE manages the RD, however,
the RPM remains ultimately responsible for the
success of the RD.
OSWER Directive 9242.3-08, "Revision of Policy
Regarding Superfund Project Assignment
Between Alternative Remedial Contracting
Strategy Contractors and USAGE," December
1991, provides information on using EPA
contractors and USAGE.
4.3 Developing the Statement of Work
The RPM must prepare a statement of work (SOW)
for the RD. Many RD requirements are developed
during the remedial investigation (RI) and feasibility
study (FS) and are detailed in the ROD and the
31
-------
RD/RA Handbook
Figure 4-1
EPA-Managed
viaARCS/HAC
Prepares RD SOW,
schedule, and IGCE with
TRT assistance
Tasks RD to ARCS/RAG
contractor via WA; with
TRT assistance, prepares
WA package and
coordinates work plan
review and appoval
RPM and TRT review and
approve contractor
submittals including:
• Predesign submittals
•Treatability studies
• Preliminary designs
• Intermediate designs
• Prefinal/final designs
RPM oversees VE study,
if necessary
RPM completes post-
design activities and
prepares for RA
RPM Responsibilities During Remedial Design
Assembles TRT and determines
whether RD will be EPA- or
USACE-managed
Informs community of RD
progress throughout
design project
IJSACE-Managed
: vialAG
Prepares IAG SOW,
schedule, and preliminary
RD cost estimate with
TRT assistance
Tasks RD to USAGE via
IAG; coordinates with
USAGE regarding
designer procurement
RPM, with TRT
assistance, participates
in USAGE review of:
• Predesign Subrnittals
• Treatability Studies
• Preliminary Designs
• Intermediate Designs
• Prefinal/Final Designs
Participates in USAGE
oversight and review of
VE study, if necessary
RPM ensures post-design
activities are complete
and prepares for RA
51-043-4D
32
-------
Chapter 4 • Federal-Lead Remedial Design
RPM's project management plan (see Chapter 3).
The RPM should consult the information collected
to complete the RI/FS, ROD, and project
management plan when preparing the RD SOW. The
RPM, with TRT assistance, prepares the SOW
detailing EPA's requirements for EPA-managed RDs.
For USACE-managed RDs, the RPM prepares an
IAG SOW for the RD, which outlines EPA RD
requirements. USAGE develops the RD SOW with
RPM assistance using the RD IAG SOW as a
framework.
4.3.1 Preparing the Remedial Design Statement of
Work
The RPM is required to prepare RD SOWs for EPA-
managed designs that are contracted out through
ARCS contracts or RACs. The SOW for EPA-
managed designs must be very detailed because the
SOW becomes a legally binding component of the
ARCS/RAC contract. An RPM must prepare an
SOW for USACE-managed designs as part of the
IAG between EPA and USAGE. The LAG SOW for
USACE-managed designs, prepared with assistance
from USAGE, facilitates communication between
EPA and USAGE regarding design requirements.
The IAG is discussed in section 4.4.2.
SOW for EPA-managed RDs
The RD SOW is the most important document that
an RPM prepares during the RD/RA process because
it establishes the framework to implement the
remedy. An inadequate, incomplete, or inaccurate
definition of the work to be completed by the
remedial designer will affect adversely the time, cost,
and effectiveness of the site remediation. The SOW
must describe clearly the RD requirements to prevent
the designer from incorporating unnecessary or
insufficient components into the design. The RPM
must understand EPA's site remediation goals and
what is required to achieve them before preparing
the SOW.
Work is allocated to ARCS/RAC contractors by is-
suing a work assignment (WA). Each WA includes
a detailed SOW that describes the work to be com-
pleted as part of the WA. Each ARCS/RAC contract
contains standard tasks outlining the work to be per-
formed under the contract and includes standard
tasks for RD WAs. When developing an SOW for
an RD WA, the RPM should use the standard tasks
listed in the contract as a basic SOW framework and
expand the framework to incorporate site-specific
requirements.
Standard tasks, in addition to simplifying SOW
development, provide EPA with a consistent method
Figure 4-2
EPA Contractor RD Standard Tasks (RACs)
Task 1 Project planning and support
Task 2 Community relations
Task3 Data acquisition
Task 4 Sample analysis
Task 5 Analytical support and data validation
Task 6 Data evaluation
Task 7 Treatability study/pilot testing
Task 8 Preliminary design
Task 9 Equipment/services/utilities
Task 10 Intermediate design
Task 11 Prefinal/final design
Task 12 Post remedial design support
Task 13 Work assignment closeout
51-043-7C
of tracking WA costs. In RACs, WA tasks and
subtasks compose the work breakdown structure
(WBS).TheWBS simplifies the tracking of monthly
WA costs because the contractor must report costs
in the WBS format. The RD standard tasks for RACs
are listed in Figure 4-2.
The benefits of using a WBS include:
• Establishing a common framework for
activities within each EPA Region
• Facilitating SOW template development
• Simplifying the monthly tracking of WA costs
• Enabling RPMs to use EPA historic cost
databases to prepare independent government
cost estimates (IGCEs)
An OSWER Directive, Guidance for Scoping the
Remedial Design, details the items and concerns to
incorporate when developing the RD SOW.
Appendix E contains a model RD SOW that may
be used to develop a site-specific SOW. The directive
recommends that RPMs use the following
guidelines:
33
-------
RD/RA Handbook
List all possible SOW tasks in the order
indicated in Figure 4-2, but only provide task
information relevant to the design. Do not
delete or change the order or numbering of the
standard tasks. For example, if it appears that
data acquisition will not be required as part of
the RD, the SOW should state, "Task 3: Not
required." The RD SOW can be amended
later to include Task 3 requirements if
necessary.
Specify all deliverables and their due dates
and include the methods for evaluating them.
Instruct the contractor to use existing RI/FS
site-specific plans whenever possible. For
example, the health and safety plans (HASPs),
sampling and analysis plans (SAPs), and
emergency response plans (ERPs) prepared
for the RI/FS can be reused during the RD
with minor modifications or addenda.
Require justification prior to any resampling
effort. Additional sampling consumes time
and resources and should be avoided if
possible. The RPM also must re-examine the
RI/FS data quality objectives (DQOs) to
ensure that they are appropriate for the RD.
Incorporate standard design specifications by
reference for the designer to use wherever
possible. Many portions of an RD are not site-
specific and can be adapted from previously
prepared specifications. USAGE has
developed treatment-specific design
specifications that can benefit EPA-managed
projects. A listing of these standard design
specifications appears in Figure 4-3. The
design specifications may be obtained from
USAGE'S Huntsville Construction Division.
Specify that design submittals conform to the
Construction Specification Institute (CSI)
format or a locally supported format. If
USAGE is expected to manage the RA, the
submittals must conform to USAGE'S
specification format contained in ETL 1006,
Technical Requirement for Pre-design and
Design Submittals.
In situations where ARCS/RAG contractors
design the remedy and USAGE procures RA
services, the ARCS/RAG contractor must be
Figure 4-3
USAGE Standard Design Specifications
USAGE has developed the following treatment-specific
design specifications:
• Air Stripping
• Asbestos Abatement
• Blower, Off-Gas: Treatment Systems
• Chemical Feed Systems
• Clearing and Grubbing
• Contractor Chemical Data Quality Control
• Filtration Systems
• Geomembrane Barriers for Landfill Covers
• Geonet
• Geosynthetic Clay Liner
• Low Permeability Clay Liner
• Monitoring Well Installation
• Piping, Off-Gas: Treatment Systems
• Plate and Frame Filter Press
• Remediation of Contaminated Soils and Sludge by
Incineration
• Removal of Underground Storage Tanks
• Safety, Health, and Emergency Response (reviewed
by the EPA/Labor Task Force)
• Separation/Filtration Geotextile
• Soil/Bentonite Slurry Cutoff Walls
• Solidification/Stabilization of Contaminated Materials
51-043-8A
available for consultation during the RA. The
RA SOW should include the coordination
between the RD contractor and USAGE as a
separate task or subtask (see section 5.2.4 for
more information on RA SOWs). Significant
RPM coordination with USAGE personnel,
Including the USAGE resident engineer, is
required to ensure that the RA WA is in place
when the RD WA is completed. This will help
ease the transition from one remedial phase to
the next.
Design Contractor's Responsibility for Quality Control
The RPM must require as part of the SOW that the
contractor perform internal design reviews. Internal
design reviews are a cornerstone of the contractor's
quality control (QC) program and are carried out by
members of the design team to ensure delivery of a
quality product to EPA. The RPM will review
34
-------
Chapter 4 • Federal-Lead Remedial Design
contractor QC methodologies as part of the work
plan review.
The most important QC activities generally
performed by a design contractor are: plan-in-hand
reviews and correlating drawings and specifications.
Plan-in-hand reviews are performed by the design
contractor at the end of the design by visiting the
site and comparing the current site conditions with
the design drawings and making any appropriate
corrections.
Correlating drawings and specifications is a
structured process to coordinate the drawings and
specifications among the various engineering
disciplines using the process flow diagrams (PFDs)
and the piping and instrumentation diagrams
(P&IDs) as the templates to cross-check the design
and ensure that errors or omissions are discovered
and corrected. For example, this review may find
that mechanical drawings indicate equipment with
different horsepower ratings than those shown on
electrical drawings. This review will be performed
before submission of the prefinal design to the
contracting party (see section 4.7.6).
SOW for USACE-Managed RDs
The relationship between EPA and USAGE during
USACE-managed RDs is outlined in the IAG.
Although the RPM prepares the IAG SOW, USAGE
prepare the designer's RD SOW. It is strongly
recommended, however, that the RPM prepare an
effective IAG SOW and work with USAGE to
prepare a design SOW. Clear lines of communication
between the two agencies will increase project
quality and reduce unnecessary delays.
The IAG SOW does not need to contain the same
level of detail as an RD SOW prepared for an EPA
contractor because USAGE functions as an extension
of EPA and is free to develop its own RD
specifications. The IAG SOW prepared by the RPM
could define only the major project requirements,
schedule, all known constraints, funding issues, and
roles and responsibilities, but also should contain
any communications requirements between USAGE
and EPA, an oversight cost estimate, and any special
reports to be generated for the RPM.
All predesign information also must be made
available as part of the SOW provided with the IAG.
When developing the IAG SOW, the RPM, in
conjunction with the TRT, is encouraged to meet
regularly with USAGE representatives to discuss the
project requirements and EPA's expectations.
Ideally, USAGE should be involved in the RI/FS as
part of the RPM's TRT as soon as it is expected to
be a USACE-managed RD. Early involvement is
invaluable in establishing a good working
relationship between the agencies and minimizes
schedule delays when changing from EPA's RI/FS
contractor to USACE. The RPM also must firmly
establish early in the relationship that he or she will
be involved in the USACE design contract SOW
preparation. Cooperation between the agencies
during RD SOW preparation prevents the need to
modify the designer's contract or delivery order, a
process that takes additional time. Negotiating
changes after contract award historically has taken
several months to complete and has resulted in
prolonged interruptions in design work.
Most difficulties incurred by an RPM when working
with another agency are caused by lack of
communication between both parties. Failure to use
the expertise of TRT members, particularly when
the RPM is not intimately familiar with engineering
and construction, can compound the communication
difficulties. Early and frequent interaction may
prevent these types of problems from occurring and
will help define each agency's roles and
responsibilities.
OSWER Directive 9355.0-43, "Guidance for
Scoping the Remedial Design," March 1995;
ETL1006, "Technical Requirement for
Predesign and Design Submittals"; and EPA
540IR-94I022 and 103, "Response Action
Contract Users' Guide, Volumes 1 and 2,"
provide additional information to assist the RPM
in preparing the RD SOW.
4.3.2 Developing a Preliminary Remedial Design
Schedule
The RPM prepares a baseline RD schedule as part
of the SOW development process. During the work
plan approval process, a highly detailed RD schedule
(developed by the contractor) will be negotiated
between the parties. The RPM should ensure
adherence to the detailed RD schedule to
35
-------
RD/RA Handbook
successfully manage an RD (see section 3.9). For
EPA-managed RDs, EPA has developed remedy-
specific RD schedules for each of the nine categories
that encompass the range of technologies being used
to remediate NPL sites. These categories are listed
in Figure 4-4. The generic schedules are based on
historical data from previous EPA contracts. The
OSWER Directive, Guidance for Scoping the
Remedial Design, contains remedy-specific RD
schedules divided into EPA contractor standard tasks.
An RPM can adapt these schedules to formulate a
preliminary or baseline RD schedule based on the
standard tasks in the site-specific RD SOW.
Figure 4-4
Principal Remediation Categories for RD Schedules
• Groundwater Treatment-Complex
• Groundwater Treatment-Simple
• Groundwater Treatment - Simple (Expedited)
• Treatment of Soils/Sludge - Complex
• Treatment of Soils/Sludge - Simple
• Civil Engineering - Complex
• Civil Engineering - Simple
• Civil Engineering - Simple (Expedited)
51-043-9A
During USACE-managed RDs, USAGE personnel
develop the RD schedule with RPM input and
cooperation. The schedule cannot be modified by
the designer without prior approval from the
contracting party. The RPM must be available as
needed to resolve issues that affect the schedule.
Once the schedule has been developed and approved,
the RPM should enter the information into the Compre-
hensive Environmental Response, Compensation, and
Liability Information System (CERCLIS). The RPM
continually must update the CERCLIS information as
the RD and RA progress. CERCLIS, however, is not
to be used to supplement the RPM's own scheduling
efforts. The RPM's master schedule should be the
primary document; CERCLIS is merely an
administrative tracking device and is not suitable or
intended to be used as a project management tool.
4.3.3 Developing the Remedial Design Independent
Government Cost Estimate
An IGCE is an estimate of the cost required to
complete a project. Federal Acquisition Regulation
(FAR) Part 36.605 requires that an IGCE be prepared
for each contract or contract modification (such as a
WA) expected to exceed $25,000. The accuracy of
the IGCE depends on the detail provided in the SOW.
After the RD SOW is completed, the RPM must
complete an IGCE for EPA-managed RDs and is
strongly encouraged to complete a similar cost
estimate for USACE-managed RDs. The RPM is
responsible for updating CERCLIS with the cost
estimate information and confirming that RD funds
are available before the actual design work begins.
IGCEs for EPA-Managed RDs
If EPA is the contracting party, the RPM, as the Work
Assignment Manager (WAM) for the RD, is required
to prepare an IGCE before issuing the WA. OSWER
Directive 9355.0-43, Guidance for Scoping the
Remedial Design, provides basic information to
estimate the level of effort (LOE) for each of the
standard tasks using the principal remediation
categories hi Figure 4-4. These LOE estimates are
derived from data collected from previous EPA
contracts. The RPM should consider the use of these
estimates only as a starting point in developing a
more site-specific cost estimate. Before preparing
an IGCE, the RPM should contact the Regional
IGCE coordinator who is available to assist the RPM
with the format, content, and review of the estimate.
IGCEs for USACE-Managed RDs
An RPM is not required to prepare an IGCE as part
of the IAG with USAGE. USAGE prepares the IGCE
when developing a site-specific contract for design
services or an indefinite delivery work order under
their preplaced/indefinite delivery contracts.
Although not required to prepare an IGCE, the RPM
should develop a rough estimate before entering into
RD scoping discussions with USAGE. Comparing
independent RD cost estimates is an effective means
of determining whether both parties fully
comprehend the scope of the design activity. It also
helps resolve potentially difficult issues such as
USAGE travel costs, the number of staff involved,
36
-------
Chapter 4 • Federal-Lead Remedial Design
and the duration of the design process.
4.4 Tasking the Remedial Design
The RD is tasked to ARCS/RAC contractors by
issuing an RD WA and to USAGE through an IAG.
The RPM's responsibilities for tasking the RD to an
EPA contractor or to USAGE and for managing the
progress of the RD are discussed below.
4.4.1 Tasking the Remedial Design to an EPA
Contractor
EPA orders work from ARCS/RAC contractors by
issuing a written WA to the contractor. The WA is a
legally binding part of the EPA contract with the
contractor and generally contains the project
background, scope of work, project schedule, a list
of deliverables, approved LOE, documentation
requirements, and restrictions on contractor travel,
printing, or other activities. This section does not
describe the entire WA management process but
provides a brief overview of basic WA procedures.
This section describes:
• Preparing and issuing the RD WA package
• Issuing RD WA amendments and
modifications
• Closing out the RD WA
The WA process is described in greater detail in other
references listed at the end of this section.
Preparing and Issuing the RD WA Package
The RPM prepares a WA package to initiate a new
WA. The WA package is reviewed by the Project
Officer (PO) and reviewed and approved by the
Contracting Officer (CO) before being issued to the
contractor. The WA package must include the
following:
• Work assignment form (WAF)—The WAF is a
one-page form used to track the various
actions required to initiate, approve, amend,
and complete a WA. The WAF also includes
the approved expenditure limit that provides
the RPM with the means to control the funds
available to the contractor and allows the
RPM to manage the phasing and execution of
the WA.
• SOW—The SOW is a clear description of the
work required of the contractor. The SOW
includes a detailed breakdown of work, all
required deliverables, work quality
requirements, and delivery schedule (see
section 4.3).
• IGCE—An IGCE is the RPM's cost estimate
for the cost of performing the work detailed in
the SOW. The IGCE is used by the CO to
negotiate WA costs with the contractor and
must never be disclosed in any fashion to the
contractor (see section 4.3.3).
• Nomination and appointment of Contracting
Officer's representative (COR) form, EPA
Form 1900-65a—Form 1900-65a is used to
designate the WAM for the new WA. The
RPM usually will function as the WAM for
RD WAs.
• Procurement request (PR), EPA Form
1900-8—The PR is used to commit funds to
individually funded WAs. If a WA is bulk
funded, as most RAC WAs are, funds are
committed by indicating the expenditure limit
on the WAF.
• Work assignment allocation matrix—The
work assignment allocation matrix is used to
identify which ARCS/RAC contractor will
receive the WA. (This form is added to the
WA package by the PO.)
After the PO reviews the WA package for accuracy
and completeness, it is submitted to the CO for final
review and approval. The CO signs the WAF, issues
the WA to the contractor, and returns copies of the
approved WA to the RPM and PO.
Once the ARCS/RAC contractor has received the
WA, the contractor attends a scoping meeting with
the RPM, TRT, and PO and, possibly, the CO to
discuss the WA. The contractor prepares and submits
a work plan that describes the contractor's proposed
approach for completing the WA tasks. Any required
changes to the work plan will be negotiated with the
contractor by the CO with assistance from the PO
and RPM. A revised work plan will be submitted by
the contractor if significant changes are required.
The RPM and PO oversee the approval of the
contractor work plan or revised work plan.
37
-------
RD/RA Handbook
issuing RD WA Amendments and Technical Direction
The unforeseen complications inherent with RD
work require a certain degree of EPA and contractor
flexibility. Site conditions may exist that were not
considered when the WA SOW and contractor work
plan were prepared. The necessary response to the
new site conditions may affect the approved scope,
LOE, or dollar values and require revisions to the
WA. There are two methods for clarifying the WA:
issuing technical direction or amending the WA.
Issuing Technical Direction
The RPM may issue technical direction to assist the
contractor in completing the WA. Technical direction
should be issued in the form of a technical direction
memorandum and may be issued in response to a
contractor question, to clarify provisions in the SOW
or EPA-approved work plan, hi response to project
or site activities, or to comment on or document
approval of contractor deliverables. Technical
direction, however, cannot be used to change the
scope or budget of the WA.
Amending the WA
A WA amendment is required for changes to the WA
scope when funds or LOE above the approved work
plan budget are needed or when funds or LOE levels
need adjustment. If the WA amendment will increase
the WA cost by more than $25,000, the RPM must
prepare an IGCE for the amendment. The CO issues
final approval for all WA amendments. The
contractor is required to submit a revised work plan
to incorporate WA amendment changes. The revised
work plan is approved using the same procedures
used to approve the original work plan.
The RPM can increase or decrease WA funding for
bulk-funded WAs by preparing aWAF and increasing
or decreasing the expenditure limit. The RPM
submits the WAF to the PO for review and the PO
presents it to the CO for final review and approval.
For individually-funded WAs, the RPM must prepare
a PR and an amended WAF and forward them to the
CO for processing. The RPM must consult with the
Region's Information Management Coordinator to
ensure, prior to increasing WA funding, that
additional RD funds are available.
The RPM must also remain aware of theARCS/RAC
WA period of performance and extend the period as
necessary. The RPM extends the period of
performance by updating the WAF and submitting
it for PO review and CO review and approval. The
RPM must update CERCLIS with all WA changes
that affect the WA budget or schedule.
Closing Out the RDWA
The final task in each WA is WA closeout. WA
closeout involves:
• RPM, PO, CO, and contractor evaluations of
contractor performance
• Organizing and retiring WA files
• Site demobilization, if necessary
• Verifying and processing final WA costs
The WA is considered complete upon approval of
the final deliverable and receipt of the final invoice.
After the WA is complete, the RPM evaluates the
contractor using the WA completion report (WACR)
form. The PO, CO, and contractor also complete
WACRs.
The RPM is responsible for organizing and retiring
WA files and ensuring that contractor files are
properly organized and retired. The RPM also must
coordinate the return of all government property in
the contractor's possession that will not be used by
the contractor during the RA.
OSWER Directive 9242.6-01, "ARCS Work
Assignment Management—Field Guide,"
January 1989; EPA/540IG-89I008, "ARCS
Contracts Users'Manual"; and EPA 540IR-94I
022 and 103, "Response Action Contract Users'
Guide, Volumes 1 and 2," provide additional
information on the WA process.
4.4.2 Tasking the Remedial Design to USAGE
The RD is tasked to USAGE with an LAG. An LAG
is a written agreement negotiated between agencies
that allows an agency to purchase goods and services
from another agency. All Superfund LAGs are similar
in that they contain special conditions for records
retention, reporting, and cost recovery. For RD/RA
projects, there are three types of lAGs between EPA
and USAGE: RD LAGs, RA LAGs, and technical
assistance lAGs. Appendix D contains model RD
and RAIAGs. This section refers to RD LAGs. Each
38
-------
Chapter 4 • Federal-Lead Remedial Design
type of IAG may be executed in one of three ways—
as a generic IAG, as an incrementally funded IAG,
or as a two-phase LAG.
A Region and USAGE may have a long-standing
generic IAG between them with sufficient funding
for EPA to task USAGE with the preliminary RD/
RA planning and cost estimate. Some Regions prefer
using one generic IAG with USAGE to initiate RD
projects. After the initial planning and preparation
is complete, the RPM prepares an RD IAG for the
actual design.
Incrementally funded lAGs are used for specific
projects with USAGE. EPA prepares an IAG with
limited funding. The limited funding allows USAGE
officials to procure a design firm and meet with the
RPM and define and shape the RD SOW (including
schedule and budget). EPA approves the start of the
actual design work by amending the LAG to increase
the available funding. Additional funds can be added
to the IAG when needed as the remedial work
progresses. This approach requires more paperwork
than using one generic LAG.
A two-phase LAG is an older form of LAG that is
similar to incrementally funded lAGs. Like the
incrementally funded IAG, the two-phase IAG
begins with limited funds to allow initial
consultations between EPA and USAGE. The second
phase, however, requires the preparation of an
additional IAG to increase the scope of work and
increase the available funding and, therefore,
requires additional time and paperwork to complete.
Many Regions have adopted the incrementally
funded IAG approach and no longer use the two-
phase approach.
This section provides a brief overview of basic IAG
procedures. These procedures include:
• Preparing and executing the LAG
• Preparing IAG amendments and increasing
funding
• Closing out the LAG
Preparing and Executing the IAG
The RPM prepares the IAG package for PO and CO
approval. The LAG review and approval procedures
vary by Region. The RPM, therefore, should follow
Regional guidance concerning specific IAG
procedures. The LAG package contains the following
documents and may contain additional Region-
specific documents:
• EPA Form 1610-1—the EPA standard LAG
form that includes the RD SOW and schedule
• Attachment A, "Special Conditions for Design
LAGs"—a summary of special conditions
developed for Superfund to deal specifically
with cost documentation requirements
(Attachment A contains requirement lists for
design lAGs)
• Decision Memorandum—memorandum from
the Program Administrator requesting the
Regional Administrator's signature approving
the LAG
• Commitment Notice—the format and content
are Region-specific
While the LAG should be as detailed as possible, the
Office of General Counsel (OGC) has determined
that EPA may not unilaterally impose its QA/QC
requirements in lAGs. The specific QA/QC
requirements must be negotiated into the LAG on a
case-by-case basis.
Once the IAG is signed by the designated EPA
Regional official, it is forwarded to USAGE for
signature by the responsible authority. It is then
returned to the EPA Region so funds can be
transferred by the Regional budget staff.
Separate lAGs are necessary for RDs and RAs due
to the different funding authorization and tracking
codes assigned to each activity.
Preparing IAG Amendments and Increasing Funding
Changing site conditions may require the IAG to be
amended. Amendments also may be necessary if the
scope of the activity changes or additional funds are
needed to complete the design. The same process
for executing the original IAG must be followed to
amend an LAG. The RPM also must be aware of the
time required to complete the design and be prepared
to extend the period of performance as necessary.
Closing out the IAG
LAGs must be closed out upon completion and all
remaining funds deobligated for recertification and
use at other Superfund sites. The RPM initiates
39
-------
RD/RA Handbook
closeout activities when at least one of the following
conditions exists:
• No further activities will take place
• All expenditure commitments have been met
The RPM prepares a written closeout request that
states there will be no further activity under the IAG,
that EPA has received the services stated in the
agreement, and that all invoices have been paid. The
RPM prepares a letter for the designated EPA
Regional official's signature requesting USAGE to
begin IAG closeout activities. The closeout activities
are designed to certify completion of the design effort
and resolve any outstanding costs. The RPM should
consult Region-specific guidance for additional IAG
closeout activity information.
4.4.3 Managing the Progress of the Remedial
Design
The RPM is responsible for managing RD progress.
There are several methods that an RPM can use to
manage the design effort and ensure compliance with
the requirements established in the RD SOW. The
level of oversight required to manage the RD
successfully depends on whether USAGE or an
ARCS/RAC contractor is responsible for the design.
When USAGE develops the RD in-house or oversees
the RD contract, the design document will be in
accordance with ih&FederalAcquisition Regulation
(FAR); therefore, any design effort managed or
performed by USAGE does not require as much
scrutiny as an EPA contractor design effort.
The methods available to the RPM for overseeing
EPA- and US ACE-managed designs require effective
use of TRT members' experience and expertise. The
specific methods are discussed below.
Managing ARCS/RAC RDs
EPA-managed RDs are tasked to ARCS/RAC
contractors with an RD WA. EPA contracts are cost-
reimbursement contracts and, therefore, require close
governmental control. The RPM must proactively
manage ARCS/RAC contractor performance to
ensure that work is satisfactorily completed and the
government is receiving goods and services
commensurate with costs billed.
The RPM cannot assume that the design effort will
be performed exactly as required. He or she, with
the assistance of the TRT, must actively oversee and
manage contractor performance with the objective
of assuring that contractor activities meet the
requirements of the RD SOW. There are a number
of effective ways that an RPM can manage RD WA
progress, including:
• Inspecting work—Unannounced inspections
may reveal that design work is not being
performed as expected. If a contractor
concentrates all work effort into a short time
period before an EPA submittal delivery date,
the design quality may suffer. If Regional
travel budgets do not allow the RPM to visit
the contractor, the progress reports can
function as the primary inspection tool. Work
inspections and progress reports also allow a
preview of the final RD submittal so that
revisions may be incorporated before the final
design is prepared. Inspections also allow the
RPM and TRT to determine if the contractor is
staffing the project to the levels and with the
individuals promised.
• Telephone communications—Frequent RPM
communication with the contractor is
important to establish EPA's expectations for
a quality contractor work effort. The
contractor is more likely to report any
difficulties or issues encountered if the RPM
is readily available to offer quick solutions. A
scheduled time and day for weekly contact
should be maintained throughout the duration
oftheWA.
• Meetings with contractor personnel—The
RPM should schedule regular meetings with
contractor personnel. Meetings typically occur
after major deliverables have been submitted
and reviewed by EPA. Additional progress
meetings may be appropriate, particularly for
complex sites, and should include the
appropriate TRT members.
• Comparing progress with work plan
schedule—The RPM must determine if the
contractor is performing according to the work
plan schedule. A transmittal register such as
the one provided in Appendix B is a useful
tool for tracking deliverable due dates,
submittal dates, and EPA responses.
40
-------
Chapter 4 • Federal-Lead Remedial Design
• Reviewing progress and financial
management reports—The ARCS/RAC
contracts require specific reporting
requirements and additional reporting
requirements may be specified in the WA. The
progress reports allow the RPM, with TRT
assistance, to evaluate contractor performance
and progress. The financial reports provide
information detailing how government funds
are spent and give the RPM the opportunity to
question contractor expenses and ensure that
sufficient funds remain in the WA budget to
complete the design effort. ARCS/RAC
contractors are required to notify EPA when
75 percent of the approved funds have been
expended. The RPM should seek any
clarification on the monthly progress or
financial reports review procedures from the
PO.
• Reviewing deliverables—The RPM must
review all contractor deliverables to ensure
that they meet the RD SOW requirements. It is
strongly recommended that the RPM use the
TRT to review design deliverables. The RPM
is responsible for ensuring that the reviews are
completed within the allotted time frames to
prevent delaying the contractor.
The RPM, as part of the RD WA management
process, also must examine the contractor staffing
mix and provide constant feedback to the contractor
regarding overall WA performance. These RPM
activities are described below.
Monitoring Contractor Personnel
The quality of contractor output depends on
contractor personnel competence. The RPM must
ensure, with TRT assistance, that the design project
personnel are qualified to perform the work
according to the SOW standards. The RPM should
clearly define personnel experience and
qualifications needed in the RD SOW and ensure
that the contractor work plan complies with SOW's
personnel requirements. The RPM should continue
to oversee the contractor personnel mix throughout
the life of the RD.
The RPM should be familiar with and discourage
several problematic contractor practices. Frequently
the contractor staff that prepare the work plan are
not the same individuals assigned to work on the
design. Some contractors also are plagued by rapid
personnel turnover that negatively affects design
quality. Finally, the RPM should verify that the
professional levels and contractor personnel are
being used as described in the approved work plan.
To determine if such difficulties are occurring, the
RPM should thoroughly review the monthly progress
reports. If inadequacies with the labor mix or
personnel involved with the design are suspected,
the RPM may request all contractor personnel
information, including resumes and position
descriptions, to evaluate personnel qualifications.
The RPM, with assistance from the PO, should
immediately inform the contractor of any problems
related to contractor personnel and take necessary
steps to resolve the difficulties.
Providing EPA Feedback to the Contractor
The RPM should be in regular contact with the
ARCS/RAC contractor throughout the RD WA. The
RPM establishes the tone for the project and by his
or her actions conveys this tone to others involved
with the project. The RPM must provide the
contractor with regular feedback regarding
contractor performance so the contractor understands
EPA expectations and delivers a product consistent
with or exceeding those expectations. The RPM must
inform the contractor immediately of any
inadequacies because the longer a difficulty remains
undiscussed, the more difficult it is to resolve.
There are several guidelines for the RPM to consider
when providing EPA feedback to the contractor:
• Avoid delay—Give feedback immediately
when reviewing a contractor submittal or
when a problem is discovered.
• Be specific—Indicate specific problems and
provide examples.
• Keep records—Record when and what
feedback was given. A memorandum should
be prepared and sent to the contractor
documenting the problem, discussion, and
resolution. A copy of the memorandum should
be placed in the WA file. (The RPM should
seek PO input and assistance when resolving
contractor problems.)
41
-------
RD/RA Handbook
• Reinforce positive performance—Give
positive, as well as negative, feedback where
appropriate.
• Remain consistent with the WA scope of
work—Changes to the scope of work require
concurrence by the CO.
Under term-form WAs, available under ARCS and
RACs, the contractor is only required to give its "best
effort" in performing the work. For this reason,
diligent monitoring and frequent discussions with
the contractor are necessary to prevent the
government from paying for poor performance that
will be claimed later as best effort. Information on
the use of term- and completion-form WAs is
available in the RAC Users' Guide.
Managing USAGE RDs
Roles and responsibilities governing EPA and
USAGE actions have been established in a national
memorandum of understanding (MOU). The MOU,
however, does not relieve the RPM of the
responsibility for managing RD progress, ensuring
that ROD requirements are met, and ensuring that
the RD is completed on schedule and within the
budget agreed to by both parties.
After executing the TAG, USAGE personnel, with
the RPM's assistance, establish the RD completion
schedule. The RPM must work with USAGE to
identify the deliverables that EPA will review and
EPA's review schedules. The RPM may use
USAGE'S computerized schedule management
system that feeds into the Regional WasteLAN
database to monitor RD progress.
The RPM receives monthly progress reports and a
copy of Standard Form-1080 (for requesting
payment) from USAGE. Although EPA has adopted
the direct cite payment process for US ACE-managed
projects, the RPM should still receive and review
monthly vouchers. The direct cite payment process
allows USAGE rather than the RPM to certify the
invoice for payment. All monthly reports contain a
description of both USAGE in-house and contractor
activities. The national MOU does not preclude the
RPM from questioning USAGE expenditures and
requesting additional documentation, including
project time sheets, to review vouchers submitted
by USAGE. If the RPM believes that there are
inaccurate charges, he or she should notify the PO
for further direction. EPA can request reimbursement
from USAGE for disputed fund transfers.
A communication strategy should be included in the
IAG. As part of this strategy, the RPM should
schedule routine meetings and conference calls with
USAGE to oversee the RD effort. It is imperative
that the RPM maintains contact with USAGE during
the design phase because the RPM is ultimately
responsible for the design effort.
OSWER Directive: 9355,5-14 FS, "EPA/USACE
PAYMENT PROCESS Direct Cite/Revised
Reimbursement Methods," May 1990, provides
additional information on the EPA/USACE IAG
payment procedures. EPA540IR-94I022 and 103,
"Response Action Contract (RAC) Users' Guide,
Volumes 1 and 2," provide additional
information on term- and completion-form WAs.
4.5 Procuring a USAGE Designer
After an IAG is executed between EPA and USAGE,
the USAGE design districts have several design
procurement options available. These options
include:
• In-house (USAGE) design
• Use of indefinite delivery (IDT) architecture/
engineer (A/E) contracts
• Total environmental restoration contracts
(TERCs)
• Site-specific A/E contracts
In general, procurement of a site-specific contract
takes six months and initiation of work by an IDT
contractor typically takes 60 days. Initiation of work
by a TERC contractor varies depending on the
requirements.
USAGE may need to procure a contractor to prepare
the design if in-house services are not available and
preplaced contracts are not being used. USAGE
begins the designer procurement process by
preparing a USAGE version of the EPA project
management plan (see Chapter 3). The USAGE
project management plan details the procedures for
42
-------
Chapter 4 • Federal-Lead Remedial Design
contracting and managing the project. The RPM
should request a copy of the plan from the USAGE
project manager and review it to ensure EPA
requirements are met.
USAGE must undertake certain contractor
procurement activities after completing its project
management plan, including:
• Summarizing the project requirements in the
Commerce Business Daily (CBD), a
government solicitation publication used to
announce available federal contracts
• Developing the design contractor preselection
list
• Contacting designers on the preselection list to
determine interest in the project
« Developing a designer selection list containing
at least three interested firms
• Making a tentative designer selection
The USAGE project manager will work with the
RPM to meet EPA requirements for contract action
at a site.
OSWER Directive 9355.5-05, "Procedure for Use
of USAGE Preplaced Contracts to Expedite
Superfund Cleanup Tasks," April 1994, provides
additional information on USAGE preplaced
contracts.
4.6 Reviewing and Approving the Work Plan
(ARCS/RACs)
The ARCS/RAG contractor describes its proposed
technical approach for completing the requirements
of the RD SOW in the work plan. Figure 4-5 outlines
the general contents of a contractor work plan.
Additional predesign phase submittals may be
included as part of the work plan or may be submitted
shortly thereafter. These submittals are discussed in
section 4.7.2.
After receiving the work plan, EPA must complete
the following tasks:
• Review the work plan to ensure that the
contractor understands and incorporates all
EPA requirements
F gure 4-5
Components of a Work Plan
• Statement of project goals
• Description of each task/deliverable
• Project schedule identifying task and deliverable
completion dates
• Proposed RA contracting strategy
• Proposed personnel
• Areas requiring clarification or anticipated problems
• Proposed use of subcontractors with discussion of how
the effort will be managed by the prime contractor
• Detailed cost proposal broken down by task and subtask,
including subcontractor cost breakdown (using WBS)
• COI statement
• Drawing register listing all drawings and specifications
that will be prepared
51-043-10C
• Negotiate with the contractor to modify or
clarify the work plan
• Approve the work plan
4.6.1 Reviewing the Work Plan
The RPM performs a comprehensive technical
review and cost analysis immediately upon receipt
of the work plan. The purpose of the review is to
ensure that the ARCS/RAG contractor fully
understands the scope of the project and that the
proposed technical approach, schedule, and staffing
are complete, reasonable, and comply with the RD
WA requirements.
The technical review includes a work plan evaluation
by professionals familiar with the RD process who
have the knowledge, skills, and experience necessary
to evaluate the technical aspects of the work plan.
The RPM's TRT should receive a copy of the work
plan as soon as it is available and should be consulted
as part of the RPM's technical evaluation of the work
plan. The RPM also must conduct a cost analysis
that includes reviewing the individual cost elements
of the work plan and comparing them with the IGCE.
The RPM should provide explanations for variances
between EPA and contractor cost estimates to the
CO and suggest methods for resolving the differences
through negotiations.
When reviewing the work plan, the RPM must ensure
that the following questions are answered
43
-------
RD/RA Handbook
adequately:
* Is the proposed work reasonable, appropriate,
and complete?
• Does the work plan respond to the RD SOW
and do the proposed tasks fit the RD SOW or
does the work plan unnecessarily exceed SOW
work requirements?
• Are the skill mix and number.of LOE hours
appropriate for the tasks? Is the level of
subcontracting necessary and appropriate for
the design effort?
• Are the schedules and milestones reasonable
and acceptable?
• Are travel and other direct costs necessary,
reasonable, and appropriate?
• Are the contractor personnel qualifications
appropriate for the work?
• Has the contractor defined problems that
require EPA resolution?
• Are there any issues that require CO or PO
attention?
The ARCS/RAC contractor must provide its
recommended RA contracting strategy as part of the
work plan (see section 5.4). This strategy must
include the proposed procurement methods, the type
of design specification (performance versus
detailed), and phasing/fast-tracking alternatives. The
RA contracting strategy influences the overall design
effort in terms of schedule and budget and must be
agreed upon before the contractor expends design
resources.
The RPM summarizes his or her review of the work
plan in a memorandum to the PO and CO. The PO
and CO review the RPM's report and
recommendations and may request additional
information from the RPM before CO approval.
4.6.2 Negotiating with the Contractor
The RPM, PO, and CO work plan reviews may reveal
that the proposed contractor work plan does not meet
EPA technical requirements, cost estimates, or both.
The RPM, PO, and CO should meet and discuss the
need for work plan negotiations with the contractor.
The CO, with assistance from the PO and RPM,
develops the negotiating position. The CO represents
EPA hi all negotiations with the contractor and must
ensure that negotiation records adequately document
negotiation results.
The RPM and PO assist the CO in preparing the EPA
negotiating strategy by reviewing the earlier RPM
work plan recommendation memorandum to ensure
that it adequately:
• Details variances between the RD SOW and
contractor work plan.
• Examines the work plan from the contractor
point of view and indicates contractor strategy
or possible motivation.
• Determines instances where contractor
variance with the SOW is due to contractor
knowledge of the site or previous RD
experience and where contractor variance
appears to indicate a misunderstanding
regarding EPA objectives. These
determinations are especially important when
the contractor has made substantive or
material changes from the SOW.
• Lists all recommended changes to the work
plan.
• Provides a list of issues and proposed changes
for the PO and CO to consider.
The CO shall maintain written documentation of the
significant differences between the government and
contractor negotiation positions. Additionally,
documentation for the government's negotiating
position, why changes were made, and the results of
the actual negotiations must be created and retained.
After successful negotiations and after the contractor
submits the revised work plan, the RPM reviews it
to ensure that all negotiated changes are incorporated
and that the work plan does not contain additional
modifications not agreed upon during negotiations.
The RPM may require the contractor to note or
highlight all deletions, additions, and revisions to
the work plan. The work plan areas that are not
marked do not need to be as thoroughly reviewed
by the RPM. After completing his or her review, the
RPM prepares another work plan review
memorandum recommending work plan approval or
outlining items for further negotiation and submits
it to the PO and CO for their review.
44
-------
Chapter 4 • Federal-Lead Remedial Design
4.6.3 Approving the Work Plan
If the CO determines that the work plan adequately
addresses all EPA requirements, the CO approves it
and informs the contractor. The RPM may need to
adjust the WA expenditure limit following work plan
approval to make available funding sufficient to
begin the RD. Adjustments to the expenditure limit
are indicated on the WAF and approved by the CO.
OSWER Directive 9202.1-12, "Guidance on
Roles and Responsibilites for Preparing
Independent Government Cost Estimates
(IGCEs) for Remedial and Enforcement Work
Assignments," July 27,1993, and EPA 540IR-94I
022 and 103, "Response Action Contract (RAC)
Users' Guide, volumes 1 and2,"provide
additional information on approving the work
plan, including information on conducting and
documenting work plan negotiations.
4.7 Overseeing the Design Development
The design development phase includes all activities
relating to the review and approval of all design
efforts, including preliminary, intermediate, prefinal,
and final design phase submittals. The government
must review all deliverables to ensure that it is
receiving goods and services commensurate with the
costs billed. The contracting party (EPA or US ACE),
therefore, must review all design submittals.
This section provides descriptions of many of the
design deliverables and details EPA review
procedures associated with each of the submittals.
The RPM is responsible for ensuring that all
submittals are delivered and reviewed in a timely
manner to prevent delays in the project schedule.
The RPM also is expected to manage his or her
design oversight activities and balance federal, state,
and community relationships.
This section describes:
• Design review procedures
• Predesign phase submittals
• Treatability screening submittals
• Preliminary design phase submittals
• Intermediate design phase submittals
• Prefinal/final design phase submittals
4.7.1 Design Review Procedures
The RPM review procedures may be conducted in
parallel or in series with other ongoing design
activities. Parallel reviews are conducted while other
design work continues and eliminate inefficiencies
and delays caused by work interruptions. Parallel
reviews, however, are not appropriate in all
circumstances because the work performed may
have to be repeated if the review results indicate that
the design effort is not proceeding in the desired
direction. In a serial review, subsequent design
activities do not begin until the review is completed,
all comments are resolved, and approval to proceed
is granted.
The RPM is responsible for coordinating the review
of all contractor deliverables when EPA is the
contracting party. The RPM must review submittals
that are within his or her breadth of knowledge and
experience and distribute all other submittals to the
TRT. A copy of the submittals must be submitted to
the designated state officials for their review. The
RPM also may provide copies of the submittals to
the potentially responsible parties or technical
assistance grant contractors hired by the community.
The RPM collects TRT comments and any additional
relevant suggestions, resolves conflicting comments,
consolidates the comments into a single report, and
provides the results of the review to the contractor.
The RPM, during EPA-lead designs, is involved with
scheduling a post-submittal meeting that includes
all involved parties, including the TRT and state
officials, after every major design submittal. The
purpose of the meeting is to reach consensus on
remaining design submittal issues. The RPM must
designate someone to take meeting notes and
document resolution of the issues.
The contractor must respond to all EPA comments
and indicate whether the comment was incorporated
or provide an explanation for excluding it. The
contractor has a professional responsibility to inform
the RPM of any unintended or adverse effects that
result from incorporation of EPA comments into the
design. The RPM should ensure that the contractor
response to EPA comments is provided according
to the schedule in the work plan.
The RPM also may coordinate the review of
contractor deliverables as part of the IAG with
45
-------
RD/RA Handbook
USAGE. If USAGE is the contracting party and the
RPM is facilitating the EPA review, the RPM must
follow USAGE review procedures. If the RPM is
not coordinating the review of contractor
deliverables, the RPM should participate in the
review as a member of USAGE'S review team. These
procedures should have been resolved as part of the
IAG SOW.
The duration of review activities for any particular
project is a function of the site characteristics, the
complexity of the design, and EPA or USAGE
administrative requirements. The specific review and
approval milestones should be identified clearly in
the project schedule. All involved parties should be
aware of the consequences resulting from
unnecessary delays.
There are a number of concerns that must be
incorporated into a thorough RD review. Information
on biddability, operability, constructability, claims
prevention, and environmental reviews and a design
review checklist are included in Appendix C. These
reviews provide a more systematic approach to the
design review process and, although experienced
reviewers include many of these features as part of
their review, the RPM should consult the specific
review information to ensure a thorough review.
4.7.2 Predesign Phase Submittals
Several plans must be submitted by the design
contractor before any on-site field activities are
initiated. The design contractor must submit an RD
work plan to describe its proposed approach to
completing each project task (see section 4.6). The
following additional plans may be submitted either
with the contractor's work plan or shortly thereafter:
• Site management plan
• Health and Safety Plan (HASP)
• Sampling and Analysis Plan (SAP)
• Contingency plan
Site Management Plan
The site management plan details the security
provisions to be taken during the RD. Security
provisions include:
• Methods for limiting access to the site
• Secure waste disposal practices
• Management responsibilities
Site security is a concern particularly when
equipment is left on-site during RD field activities.
The RPM should ensure that the contractor is tasked
with periodic site security inspections and that there
exists a means of maintaining (or enhancing, if
necessary) existing security features. Site security
becomes more important during the RA for two
reasons: additional equipment could increase the
likelihood of site vandalism; and there is a potential
for danger to trespassers as a result of the
construction activities.
Health and Safety Plan
The Occupational Safety and HealthAdministration
(OSHA) regulations require that a single written
occupational, safety, and health program that
includes a HASP be in place for remedial activities
at all Superfund sites. There should be one HASP
per site, not one HASP per contractor, and every
site employee should be provided with a copy. The
objective of the plan is to protect workers through
the identification, evaluation, and control of health
and safety hazards and to provide for emergency
response contingency planning. While EPA uses the
acronym HASP, OSHA uses the term safety and
health program or plan, and USAGE uses site safety
and health plan. The required contents of the plans
are similar.
The contents of a HASP must include (but are not
limited to) the requirements of 29 Code of Federal
Regulations (CFR) 1910.120 for hazardous waste
operations. The standards outlined in 29 CFR
1910.120, referred to as Hazardous Waste Operations
and Emergency Response (HAZWOPER) standards,
contain specific requirements to minimize the health
and safety hazards associated with actions at
uncontrolled hazardous waste sites. In addition, the
HASP also may include other OSHA safety
standards for traditional construction activities.
Figure 4-6 outlines the general contents of the HASP,
incorporating only the HAZWOPER standards. To
create the HASP, the HASP developed for the RI/FS
may be reused or updated.
Only the hazardous portions of site cleanups fall
under HAZWOPER standards. Designating areas as
nonhazardous, and therefore not subject to
HAZWOPER, results in a more cost-effective
46
-------
Chapter 4 • Federal-Lead Remedy Design
Figure 4-6
Components of the HASP
Key personnel and hazard communications plan
Health and safety risk analyses
Site control measures
Employee training assignments
Medical surveillance
Personal protective equipment
Air and personnel monitoring
Spill containment program
Confined space entry procedures
Decontamination procedures
Emergency response plan
51-043-11
cleanup and enables more firms to compete for those
portions of the construction work. OSHA standards,
not cleanup levels, determine hazardous exposure
levels. The designation of nonhazardous areas must
be made by professionals competent in worker health
and safety.
Emergency Response Plan
The emergency response plan (ERP) is a required
element of the HASP and includes a description of
how to handle potential site emergencies and how
to minimize the risks associated with a response.
The ERP must be developed and implementedbefore
commencing operations at a site. The required
elements of the ERP are codified in 29 CFR
The ERP must include information on site
topography, layout, prevailing weather conditions,
and procedures for reporting incidents to local, state,
and federal agencies. The ERP must be included in
overall site operation training programs and must
be reviewed and rehearsed regularly. The plan also
must remain available on-site for employee, OSHA,
and other government agency review.
The ERP should incorporate the capabilities and
limitations of the local emergency response
community and the local community's contingency
plan, which should be developed by the Local
Emergency Planning Committee (LEPC). The
Superfund Amendments and Reauthorization Act
Title in, or the Emergency Planning and Community
Right-to-Know Act, requires local governments to
create LEPCs. LEPCs should have in place local
contingency plans for coordinating police, fire,
utility, and medical services.
The local emergency responders should be involved
early on in efforts to develop the ERP so they are
familiar with their roles in a site emergency. Once it
is completed, copies must be provided to the local
emergency response facilities.
RPM's HASP Responsibilities
The RPM must review the HASP when an EPA
contractor is tasked with the RD or RA. To conduct
this review, the RPM should consult a health and
safety contractor or USAGE to have the HASP
reviewed by a certified industrial hygienist. For
USACE-managed RDs and RAs, USAGE is
responsible for reviewing and approving the HASP.
It is the contractor's responsibility to comply with
all OSHArequirements, including the HASP. OSHA
personnel ensure contractor compliance by
performing periodic safety inspections. It is the
RPM's responsibility to ensure that the contractor
implements the HASP. To effectively carry out this
responsibility, an RPM may use the following
techniques:
• Inquire about health and safety activities at
every progress meeting. Let it be known that
health and safety is an important criterion
when rating contractor performance.
• Review the site files for HASP revisions.
HASPs are evolving documents that must be
revisited continually and modified as
necessary. If the cover is dusty, chances are
that the HASP is not being followed.
• The RPM can contact the TRT or EPA's
Emergency Response Team (ERT) in Edison,
New Jersey, for advice if there is a question on
whether the HASP is being implemented
properly. The ERT is the national Superfund
lead on all health and safety issues related to
site cleanup. The RPM also has the option of
contacting OSHA for a compliance inspection.
The RPM, as EPA's representative, must maintain
effective community relations, according to the
National Contingency Plan. During the predesign
phase, the RPM should contact the LEPC to
coordinate the community's local contingency plan
47
-------
RDIRA Handbook
with the ERR The RPM should obtain a preliminary
agreement with the community to provide
emergency response services as part of the ERR
The RPM also should facilitate the incorporation of
the community's concerns during the development
of the ERR The RPM must ensure that the local
response community is equipped to handle their
respective roles. All emergency responders must
have a level of training comparable to the job they
will be performing. This requirement generally
translates into a minimum of 24 hours of training.
Failure to initiate discussions with the community
early in the RD process may affect the overall project
schedule and lead to a breakdown in community
relations. Although the RPM should establish initial
contact regarding the use of local emergency
response units, the final agreement is the contractor's
responsibility and is the constructor's responsibility
during the RA because the ERP is part of the HASP
and the HASP is the contractor's responsibility.
Publication 9285.1-03, "Standard Operating
Safety Guides," June 1992; EPAI540IG-89I010,
"Health and Safety Audit Guidelines";
Publication 9285.1-02, "Health and Safety Roles
and Responsibilities at Remedial Sites," July
1991; and Publication 9285.6-08FS, "Emergency
Responder Agreements for Fund Lead RAs,"
March 1994, provide additional information on
health and safety requirements at Superfund
sites.
Sampling and Analysis Plan
The SAP is a report that details the methods and
procedures concerning analytical methods employed
during site-related sampling and data evaluation. The
SAP incorporates the information from two separate
but related reports: the field sampling plan (FSP)
and the quality assurance project plan (QAPP). These
two reports may be submitted separately, but
generally are submitted together as the SAP.
The purpose of data collection during the RD is not
to recharacterize the site but to obtain physical data
to support the design effort. The RPM must ensure
that the SAP is adequately reviewed by personnel
with the appropriate experience and qualifications
who are familiar with the RD information
requirements and who can identify unnecessary
procedures.
Field Sampling Plan
The FSP details the sampling and analytical
procedures and methodologies the contractor or
designated subcontractor will use and should be
written so that a field sampling team unfamiliar with
the site is able to collect the required samples and
field information. The FSP specifies how many
samples will be taken, how and where they will be
collected, what technical means will be employed
to collect them, what technical methodologies and
procedures will be used to analyze the samples, and
how the investigation-derived waste will be
disposed. The FSP also should contain an analysis
of the specific data gaps that the plan is designed to
eliminate. Figure 4-7 lists the contents of the FSP.
Figure 4-7
Field Sampling Plan Contents
• Site background
• Sampling objectives
• Sample location and frequency
• Sample designation
• Sampling equipment and procedures
• Sample handling and analysis
• Investigation-derived waste disposal procedures
51-043-12A
There is a tendency for contractors to mistrust data
collected by others, regardless of its quality.
Resampling often is not necessary and only increases
the time and cost of the RD. It should be avoided
unless serious inadequacies in the existing data can
be demonstrated. SAP reviewers should be instructed
to note any unnecessary sampling or analyses.
Quality Assurance Project Plan
The quality assurance project plan (QAPP) provides
a blueprint for the QA/QC activities during the
sampling and analysis phases of the project that are
needed to produce environmental data of the type
and quality required for the project. The QAPP
augments the FSP by incorporating the design of
the sampling and analysis events based on a
systematic plan developed using the data quality
objectives (DQOs) process. The DQO process
enables the designers and the users to create a
sampling design that, when implemented, will yield
a dataset of values within acceptable limits of error
48
-------
Chapter 4 • Federal-Lead Remedial Design
specified by the user. DQOs are qualitative and
quantitative statements derived from the DQO
process that clarify study technical and quality
objectives, define the appropriate type of data, and
specify tolerable levels of the potential decision
errors that will be used as the basis for establishing
the quality and quantity of data needed to support
decisions. The DQO process is a systematic strategic
planning tool based on the scientific method that
identifies and defines the type, quality, and quantity
of data needed to satisfy a specified use. The key
elements of the process include:
• Concisely defining the problem
• Identifying the decision to be made
• Identifying the key inputs to that decision
• Defining the boundaries of the study
• Developing the decision rule
• Specifying tolerable limits on potential
decision errors
• Selecting the most resource efficient data
collection design
The QAPP should address, as a minimum, the
elements listed in Figure 4-8. If a particular element
is not required, the QAPP should record why. Since
some of the information required for the RD QAPP
may be contained in previous site-specific QAPPs,
it will be necessary only to reference those earlier
approved QAPPs. Duplicate information does not
need to be repeated.
EPA QAIR-5, "EPA Requirements for Quality
Assurance Project Plans for Environmental Data
Operations," and OSWER Directive 9355.3-01,
"Guidance for Conducting Remedial Investi-
gations and Feasibility Studies under CERCLA,"
provide additional information on preparing
QAPPs andFSPs. CERCLA-specific guidance
on applying the DQO process to remedial acti-
vities may be found in EPA540-R-93-071, "The
Data Quality Objectives Process for Superfund:
Interim Final Guidance," September 1993.
Contingency Plan
The contingency plan is written to protect the local
affected community in the event of an accident or
Figure 4-8
Suggested Format for the QAPP
Title and Approval Sheet
Table of Contents
Distribution List
Project/Task Organization
Problem Definition/Background
Project/Task Description
Quality Objectives and Criteria for Measurement of Data
Special Training Requirements or Certifications
Required Documentation and Records
Sampling Process Design (Experimental Design)
Sampling Methods Requirements
Sample Handling and Custody Requirements
Analytical Methods Requirements
Quality Control Requirements
Instrument/Equipment Testing, Inspection, and Maintenance
Requirements
Instrumentation Calibration and Frequency Requirements
Inspection/Acceptance Requirements for Supplies and
Consumables
Data Acquisition Requirements (Non-Direct Measurements)
Data Management Requirements
Required Assessments and Response Actions
Required Reports to Management
Data Review, Validation, and Verification Requirements
Validation and Verification Methods
Reconciliation with User Requirements
51-043-130
emergency. It may incorporate an air monitoring
plan and a spill control and countermeasures plan,
if applicable, for the site. The following is a
preliminary list of items that could be included in a
contingency plan:
» Name of person responsible for responding in
the event of an emergency incident.
• Plan and date for meeting with the local
community, including local, state and federal
agencies involved in the cleanup, as well as
local emergency squads and hospitals.
• First aid and medical information including
names of personnel trained in first aid; map
with the locations of medical facilities clearly
marked; all necessary emergency phone
numbers; fire, rescue, local hazardous material
49
-------
RD/RA Handbook
teams; and National Emergency Response
Team.
• Air monitoring plan—Air monitoring will be
necessary at any site when the site-specific
risk assessment specifies a risk via the
inhalation/air transport pathway. This section
details the minimum requirements for air
monitoring both onsite and at the perimeter of
the site. The chemical constituents identified
at the site as part of the risk assessment should
be the basis for pollutant sampling and
measurement of atmospheric pollutants. Air
monitoring may include personnel monitoring,
on-site or off-site area monitoring, and
perimeter monitoring. Trigger concentrations
to implement the contingency plan should be
specified.
• Spill control and countermeasures plan—This
plan will provide contingency measures for
potential spills and discharges from materials
handling or transportation. It describes
methods, means, and facilities required to
prevent contamination of soil, water,
atmosphere, uncontaminated structures,
equipment or material from the discharge of
waste due to spills; provides for equipment
and personnel to perform emergency measures
required to contain a spill and to remove and
properly dispose of any media that become
contaminated due to spillage; and provides for
equipment and personnel to perform
decontamination measures that may be
required to remove spillage from previously
uncontaminated structures, equipment, or
material.
4.7.3 Treatability Studies
A treatability study is a laboratory or field test
designed to provide critical data needed to evaluate
and support the design of one or more treatment
technologies. Treatability studies usually should be
conducted during the remedy evaluation phase of
the RI/FS and include a three-tiered approach: (1)
laboratory screening; (2) bench-scale testing; and
(3) pilot-scale testing.
The only function of a treatability study during the
RD is to provide the quantitative design and cost
data required to optimize critical design parameters.
The earlier laboratory screening and bench-scale
testing procedures performed during the RI/FS are
used to determine if a remedy will work and most
likely will be adequate to allow an RD treatability
study to begin with the pilot-scale test. Pilot-scale
testing provides an evaluation of the following types
of information:
• Full-scale performance
• Treatment train performance
• Materials handling characteristics
• Process upsets and recovery
• Sidestream and residuals generation
• Energy and reagent usage
• Site-specific considerations such as heavy
equipment access, waste-feed staging space,
and local availability of equipment and
qualified personnel
Figure 4-9 provides a suggested pilot-scale
treatability study work plan format
Figure 4-9
Suggested Contents for a Pilot-Scale Treatabilty
Study Work Plan
• Project description
• Cost estimates/schedule
• Test objectives
• Treatability study work plan
• Pilot plant installation and setup
• Pilot plant operation and maintenance procedures
• Parameters to be measured
• Sampling plan
- Analytical methods
- Data management
- Data analysis and interpretation
• Subcontractor's HASP
• Residuals management plan
• Subcontractor's contract management
51-043-140
Pilot-scale testing is expensive (averaging $225,000
to $1 million per site) and often can be avoided by
relying on alternative means for collecting
performance data. Contractors bidding on the RA
contracts and technology vendors marketing waste
treatment systems frequently include detailed
50
-------
Chapter 4 • Federal-Lead Remedial Design
performance-based specifications in their bids.
Potential RA contractors include detailed
information about their processes. Vendors may be
allowed to remove small amounts of site waste to
test the application of their technologies. The data
available from these sources may satisfy the
designer's data needs and avoid the additional time
and expense of conducting a pilot study.
Overseeing Treatability Study Progress
For EPA-managed RDs, the RPM must monitor
contractor oversight of the treatability study
subcontractor. The RPM, however, must not contact
the subcontractor directly to discuss EPA concerns.
All contact with the subcontractor must be
coordinated through the contractor.
For USACE-managed RDs, USAGE ensures the
treatability study is completed, if necessary, and will
report the study progress to the RPM. USAGE must
notify the RPM if the results of the treatability study
affect the ROD, RD cost, or RD schedule.
The RPM will oversee the ARCS/RAG contractor
or USAGE performance of the following activities:
• Procuring the treatability study subcontractor,
test facility, equipment, and materials
• Procuring outside laboratory services, if
necessary for performance analysis
• Establishing an on-site field laboratory to
facilitate analysis of test samples
• Obtaining samples as specified in the work
plan
• Testing equipment to ensure proper operation
• Analyzing test samples
• Evaluating test results and preparing results
report
Reviewing the Treatability Study Evaluation Report
The RD contractor submits a treatability study
evaluation report at the conclusion of the treatability
study. The report provides detailed information
regarding the effectiveness of the treatment
technology when compared with the performance
standards established for the site by the ROD. The
report evaluates the effectiveness, implementability,
cost, and actual results and compares them with the
predicted results. The report also evaluates full-scale
application of the technology, including a sensitivity
analysis identifying the key parameters affecting
full-scale operation (i.e., how the unit will be scaled
from pilot-scale to full-scale and how unknown
factors may affect the design). The report describes
the usefulness of the treatability study results as
optimum design parameters.
The RPM reviews the evaluation report using the
same methods used to review any contractor
deliverable, including using theTRT. The RPM also
should consider the benefits of a project review
meeting with the contractor to allow the contractor
to present the results of the treatability study and to
summarize the current status of the RD.
Maintaining Effective Community Relations During the
Treatability Study
The RPM must maintain effective community
relations during an on-site treatability study. The
RPM should augment the community relations plan
(see section 3.12) to address any unique issues related
to the proposed testing. These issues may include
the potential for off-site air emissions, transportation
of hazardous materials, noise levels, increased
traffic, and other issues that affect the community.
The RPM, after consultation with the Community
Relations Coordinator, may consider including
additional public availability sessions, visitor's days,
or other outreach methods to explain the proposed
testing. A fact sheet describing the activity with a
section that specifically addresses any potential
community concerns or a briefing with the local
public officials also may be useful.
OSWER Directive 9380.3-10, "Guide for
Conducting Treatability Studies Under
CERCLA," December 1989, provides additional
information on performing treatability studies.
4.7.4 Preliminary Design Phase
The preliminary design phase is considered complete
when approximately 30 percent of the design work
has been completed. The preliminary design phase
is an active phase and requires close RPM
supervision. For EPA-managed RDs, the RPM
should schedule a meeting with the RD contractor
to begin the preliminary design phase. Due to the
logical progression of the engineering design
process, certain preliminary design phase submittals
51
-------
RD/RA Handbook
are conceptual documents that must be completed
and approved before successive preliminary design
phase documents are begun.
The contracting party (EPA or USAGE) is required
to review and approve numerous preliminary
drawings and specifications that build upon the
design foundation established by the predesign phase
submittals (see section 4.7.2). The preliminary
design phase submittals include:
• Design criteria report
• Basis of design report
• Preliminary drawings and specifications
• Results of value engineering (VE) screen
• Preliminary RA schedule
• Preliminary RA and operation and
maintenance (O&M) cost estimates
This section describes the preliminary design phase
submittals and procedures for reviewing and
approving them. Figure 4-10 outlines preliminary
design phase submittal components.
Figure 4-10
Preliminary Design Phase Submittal Components
• Design criteria report
- Project description
- Design requirements and provisions
- Preliminary PFDs
- O&M provisions
• Basis of design report
- Design assumptions
- RA contracting strategy
- Permits plan
- Preliminary easement/access requirements
- Preliminary P&IDs
• Preliminary drawings and specifications
- Outline of general specifications
- Drawings and schematics, including final
P&IDs
- O&M requirements
- Chemical and geotechnical data
• Results of VE screen
• Preliminary RA schedule
• Preliminary RA and O&M cost estimates
EPA and USAGE use different procedures and
identify designer submittals by different names. The
submittal names also may vary among Regions. The
RPM, therefore, should know the functions of the
submittals rather than the submittal titles. At times,
the design criteria report and the basis of design
report may be submitted as a single report.
Design Criteria Report
The design criteria report describes the technical
parameters upon which the design will be based. The
design contractor must submit and await contracting
party approval of the design criteria report before
expending additional design effort. This allows the
contracting party to determine if the contractor is
correctly interpreting and translating ROD
performance standards, applicable or relevant and
appropriate requirements (ARARs), and engineering
standards and codes into site-specific engineering
parameters.
The design criteria report may contain the following
elements:
• Project description
• Design requirements and provisions
- Waste characterizations
- Technical design standards that the
completed project is expected to meet
- Complete description of how ARARs,
pertinent codes, and standards will be
translated into engineering parameters
- Technical factors of importance to the
design and construction, including
currently accepted environmental control
measures, constructability, and the use of
currently acceptable construction
practices and techniques
• Preliminary process flow diagrams (PFDs) for
the treatment processes under design that
identify all process significant components
within the treatment train(s), the stream
properties, and additional information as
needed, including an integral chart showing
stream properties and heat and material
balances. The PFDs should include:
- Pretreatment requirements
- Volume and types of media requiring
treatment
51-043-15A
52
-------
Chapter 4»Federal-Lead Remedial Design
- Treatment schemes (includes all media
and by-products)
- Input/output rates of flow streams
- Influent/effluent qualities of flow streams
(temperatures, pH, concentrations, etc.)
• O&M provisions that will have a significant
influence on design approach (e.g., unattended
operation, remote output of instrumentation
signals, process data logging requirements,
etc.)
Basis of Design Report/Design Analysis Report (USAGE)
The basis of design report is a detailed description
of the analyses conducted to select the design
approach. The basis of design report, referred to as
the design analysis report by USAGE, may include
the following elements:
• Summary and detailed justification of design
assumptions
• RA contracting strategy
• Permits plan
• Identification of easement and access
requirements
• Preliminary piping and instrumentation
diagrams (P&IDs)
Summary and Detailed Justification of Design
Assumptions
The basis for making the necessary design
assumptions must be clarified for future reference.
The necessary clarification requires that the designer
provide:
• Calculations supporting the assumptions (e.g.
unit sizing, feed rates, etc.) and references to
any software programs used to model data
• Material and energy (or heat) balance
• Evaluation of how ARARs will be met
• Plan for minimizing negative effects on the
environment and community during the
construction and O&M phases
RA Contracting Strategy
The designer submits an RA contracting strategy
detailing the qualifications that will be expected of
the RA contractor. The strategy plan provides the
information necessary to procure an RA contractor
with any unusual experience, skills, or equipment
that may be incorporated into the design.
Permits Plan
The permits plan details how requirements for all
permits needed to implement the RA will be obtained
and satisfied. The plan identifies required off-site
disposal and discharge permits, the time required to
process the permit applications, and a schedule for
submitting permit applications. Where permits are
not required for on-site activities due to federal
exemptions, the substantive requirements of the
permit(s) that would otherwise be required must be
detailed (see section 3.7.1).
Identification of Easement and Access Requirements
The property surrounding a site that is needed for
site access, RA staging areas, or other remediation
purposes must be identified early in the design
process. Failure to secure the necessary property
through acquisition or access agreements may
prevent the lead agency from procuring the RA
constructor and will delay the commencement of RA
activities (see section 3.7.1).
Preliminary P&IDs
The preliminary P&IDs expand upon the PFDs that
were submitted with the design criteria report and
later revised. The P&IDs become the foundation for
the remainder of the design.
Preliminary Drawings and Specifications
The contracting party also must review all
preliminary drawings and specifications. These
include:
• An outline of general specifications
• Drawings and schematics, including final
P&IDs
• A description of the planned O&M
requirements
• All chemical and geotechnical data
Outline of General Specifications
The outline details the specifications that will be
prepared and submitted as part of future RD
submittals. The specifications must conform to the
CSI format when designs are conducted under EPA
contracts. USAGE has developed its own format,
53
-------
RD/RA Handbook
outlined in ETL 1006, Technical Requirement for
Pre-design and Design Submittals, as well as the
standardized design specifications listed in Figure
4-3, which are available from USACE's Huntsville
Construction Division.
Drawings and Schematics
The type and number of drawings depend on the
remedy selected. At this stage in the design, only
the PFDs and P&IDs will be submitted in final form.
These submittals shall include but are not limited
to:
• A complete list (drawing register) of all
drawings and specifications that will be
produced through the end of the design
• Facility representations, including final PFDs
and P&IDs and preliminary site and utilities
layouts
• The site layout, existing site plan, utilities
layouts, and demolition plans
Planned O&M Requirements
The anticipated O&M requirements following the
completion of the RA must be described so that the
RPM and state have access to the information and
understand their expected future role in site
remediation.
Chemical and Geotechnlcal Data
All data used to develop the design or be included
in the RA contract documents shall be presented in
a tabulated format. The sources of the data also must
be identified.
Results of Value Engineering Screen
The VE screening includes an evaluation of the
relationship between cost and function in the RD,
with an emphasis on high cost areas. VE screening
results are presented as a recommendation
supporting or rejecting the need for a full-scale VE
study. The VE screen should be performed as soon
as possible during the preliminary design to avoid
the time and expense of significant redesign resulting
from the VE study. The VE study is discussed further
in section 4.8.
Preliminary RA Schedule
The preliminary RA schedule must be appropriate
to the size and scope of the anticipated activities and
must include an evaluation of a phased approach to
expedite the RA. The preliminary RA schedule
should be one of the final preliminary design phase
submittals, with the exception of the preliminary RA
cost estimate, to allow the appropriate design
personnel sufficient time to evaluate the design and
prepare a reasonably accurate RA schedule.
Preliminary RA and O&M Cost Estimates
The preliminary RA cost estimate must include all
costs necessary to arrive at a current working
estimate (CWE). The CWE is a detailed bottom-up
cost estimate developed from design documents and
serves as the basis for all future (intermediate or
prefinal/final) stage estimates and the RA IGCE.
The CWE must include the estimated contract cost
(including contractor direct labor, equipment, and
material costs, overhead, profit, and bond),
allowance for applicable contingencies (during both
design and construction), escalation to midpoint of
construction, appropriate escalation of operating
costs, allowances for construction management,
engineering during construction, as-builts, and other
pertinent allowances.
The estimate should be prepared with as much detail
as design documents allow. At the preliminary
project stage, however, the design is only about 30
percent complete. Thus, design contingencies (i.e.,
construction contingencies during design) normally
will be higher at this stage than for intermediate or
prefinal/final design project stages. Cost allowances
also must be made for construction features yet to
be included in the design. New WAs issued under
RACs will require the contractor to develop RA cost
estimates using the USACE's work breakdown
structure and MCASES-Gold software. This
requirement is written into the RA Model SOW
provided in Appendix E.
The preliminary RA cost estimate should be as
accurate as the available information allows. The
final cost for simple projects may be as much as 40
percent higher or 20 percent lower than the
preliminary cost estimate and as much as 50 percent
higher or 30 percent lower for complex projects. This
estimate should be more refined than the ROD
estimate. USAGE has developed specific hazardous,
toxic, and radioactive waste (HTRW) cost
engineering guidance, which outlines in detail
procedures for preparing HTRW cost estimates. This
54
-------
Chapter 4 • Federal-Lead Remedial Design
information is provided in the reference materials
listed below.
The O&M cost estimate will generally include
operating labor (wages, salaries, training, overhead,
and fringe benefits associated with post-construction
operations); maintenance material and labor (labor,
parts, and materials required to perform routine
maintenance of facilities and equipment); auxiliary
materials and energy (chemicals, fuel, electricity,
water, sewer, etc. needed for plant operations);
purchased services (sampling costs, laboratory fees,
and other professional services); administrative
costs; insurance; taxes; and licenses (property taxes,
permit renewals, reporting).
The preliminary RA and O&M cost estimates
generally will be the final preliminary design phase
submittals, which allows the designer's cost
estimator time to evaluate the RD, schedule, and
O&M requirements and prepare reasonably accurate
cost estimates.
Reviewing the Preliminary Design Phase Submittals
The lead agency is responsible for reviewing
preliminary design phase submittals. In-depth
reviews should be conducted by professionals
experienced in the disciplines covered by the design.
The submittals are the basis for all remaining design
activities and, therefore, must be reviewed
thoroughly by the contracting party to avoid costly
and time-consuming redesigns later in the RD. The
technical review must focus on the design criteria
analysis and basis of design reports first. These
reports provide an overview of the design and
establish the tone for the remaining design effort.
At a minimum, the review should focus on the
following:
• Assuring that the engineering design
parameters correctly incorporate the ARARs
and other ROD requirements
• Verifying that unit processes are being
employed by the treatment train
• Confirming that the standards for efficient
removal or treatment are reasonable for both
the process and for waste volumes and
concentrations
• Checking that process waste streams are
adequately identified and addressed and that
flow rates are appropriate
• Verifying that proposed siting of the process is
appropriate and that any site abnormalities
have been addressed
• Checking design calculations thoroughly
enough to assess professional quality of
design activity
• Completing a preliminary design biddability,
constructability, and operability and an
environmental and claims prevention
screening (see Appendix C).
For EPA-managed RDs, the RPM must collect all
TRT comments and forward them to the contractor.
As specified in the SOW, the contractor shall review
and formally respond to each comment. USACE-
managed site-specific contracts also require the
contractor to respond to all review comments.
The RPM must update CERCLIS as the RA cost
estimate and schedule is refined. Updating and
maintaining the information hi CERCLIS facilitates
effective communication between the RPM, PO, and
CO and helps ensure that RA funds will be available
as needed.
USAGE Engineering Regulation 1110-3-1301,
"Cost Engineering Policy and General
Requirements for Hazardous, Toxic, and
Radioactive Waste (HTRW) Remedial Action
Cost Estimates," and Technical Manual 5-800-2,
"Construction Cost Estimates," provide
information on preparing RA cost estimates.
4.7.5 Intermediate Design Phase
The RD enters the intermediate design phase
following the completion of the preliminary design.
Approximately 60 percent of the design effort is
completed before the intermediate design phase
ends. All data collection and analysis should be
completed and approved by the contracting party
before the intermediate phase of the RD process
begins. During the intermediate design period, the
drawings and specifications submitted at the
preliminary stage are completed and new, more
detailed or later-phase documents are begun. Many
of the deliverables, therefore, are refined preliminary
55
-------
RD/RA Handbook
Figure 4-11
Intermediate Design Phase Submittal Components
• Revised design criteria report, if necessary
• Revised basis of design report, if necessary
• Intermediate drawings and specifications
- Preliminary specifications
- Drawings and schematics
- O&M requirements
- Unit price lists for the RA
- Chemical and geotechnical data
• VE study results
• RA schedule
• Intermediate RAand O&M cost estimates
51-043-16
design deliverables, while some are submitted for
the first time. Figure 4-11 outlines the major
components of the intermediate design phase.
Less complex projects may not require a formal
intermediate design phase or the associated
submittals. In these cases, the RPM may consider
substituting an in-progress review for the
intermediate design phase submittals. This should
be done only when it is apparent intermediate design
phase submittals are unnecessary.
Revised Design Criteria Report
The design criteria report is updated and modified
only if necessary and should not be modified
extensively during the intermediate design phase.
Major modifications should be addressed during the
preliminary design phase and, for all practical
purposes, should be complete at the preliminary
submittal stage. VE study results, however, may
affect the design if proposed VE changes are
incorporated. Design changes will affect the contents
of the design criteria report.
Revised Basis of Design Report
The basis of design report also is updated and
modified where appropriate. Like the design criteria
report, the basis of design report should not be
modified extensively during the intermediate design
phase with thepossible exception of the permits plan
and the easement/access requirement components
of the report. These components must be updated
throughout the design process because they are
subject to change as the design progresses. As with
the design criteria report, proposed VE changes
would affect the basis of design report.
Intermediate Drawings and Specifications
During the intermediate design phase the preliminary
drawings and specifications are further refined and
additional information and reports are completed.
The intermediate drawings and specifications
include:
• Draft specifications
• Drawings and schematics
• Revised O&M description and cost estimate
• Unit price lists for the RA
• Chemical and geotechnical data
Draft Specifications
The contractor is required to submit draft
specifications for construction, installation, site
preparation, and field work standards, including an
equipment startup and operator training plan. All
specifications shall conform to CSI format (US ACE-
managed RDs will follow the USAGE ETL 1006,
Technical Requirement for Pre-design and Design
Submittals specifications). The contractor should
prepare new specifications only where guidance does
not exist in EPA/USACE guide specifications or
from previous RDs.
The technical specifications governing major
process-significant or complex components of the
proposed treatment systems should include
requirements for the technology vendor to provide
visits by experienced factory representatives to
supervise the installation, adjustment, startup, and
operation of the treatment systems.
Drawings and Schematics
The intermediate design package will build on the
work presented during the preliminary design. The
type and number of drawings and specifications
depend on the remedy. The drawings may include
but are not limited to:
• A current drawing register that lists every
drawing and specification that will be
produced during the project and the current
status (revision number and date) of each
document
56
-------
Chapter 4 • Federal-Lead Remedial Design
• A revised PFD, if necessary (the PFD should
be finalized during the preliminary design
phase)
• Revised P&ID(s), if necessary (the P&IDs
should be finalized during the preliminary
. - design phase)
• Facility drawings (grading and paving,
foundation plan and sections, piping plan and
sections, structural plan and elevations,
electrical schematics and plans, conduit
routings, instrumentation and cable plan
details, piping isometrics, etc.)
• A process-control logic table describing how
all of the individual components of the process
system are interrelated
• All utilities drawings depicting electrical,
sewage, waste, gas, telephone, water lines, etc.
• Site layouts, existing site plan, contour maps,
and physical features of the site
• Site work zones (for establishing worker
protection zones) and date for verifying the
location of clean zones
• Plans for flood protection, excavation,
demolition, site clearing and grubbing, and
work limits
Revised O&M Description
As the design is refined, the actual O&M
requirements become more established. The RPM
should present O&M requirements to the state as
the information is made available.
Unit Price Lists for the RA
The contractor must provide the unit price or lump
sum pricing lists for each bid item.
Chemical and Geotechnical Data
All data used to develop the design should be
included in the RA contract documents, presented
in a tabular form. The sources for all data and any
uncertainties also must be identified.
Results of VE Study
The RPM should be aware of VE study results. After
the VE study report is produced, any proposed
changes that are incorporated will affect intermediate
design phase submittals. The EPA CO must approve
any proposed VE design changes for ARCS/RAC
contractor RDs. USAGE should inform the RPM of
any incorporated VE design changes that affect the
cost, schedule, or ROD requirements. Section 4.8.1
contains additional information on the VE study
process.
Updated RA Schedule
The revised RA schedule should identify the
timetable for initiating and completing all critical
path tasks and major milestones. The schedule also
should provide an accurate estimate of the RA
completion date.
Intermediate RA and O&M Cost Estimates
As with the preliminary RA cost estimate, the
intermediate RA cost estimate must include all costs
necessary to arrive at a CWE. The estimate should
be prepared with as much detail as the design
documents allow. At the intermediate project stage,
designs should be about 60 percent complete and
design contingencies should be higher at this stage
than for prefinal/final design project stages, but lower
than for the preliminary design stage.
The intermediate RA cost estimate should be refined
using flow sheets, layouts, and equipment details,
and is expected to be accurate within plus 30 percent
and minus 15 percent for simple projects and plus
40 percent and minus 20 percent for complex
projects. The basis for unit prices should be provided
with the estimate and should reflect current costs
for labor, equipment, and materials. Vendor
quotations should be included in the estimate when
used.
As the design is refined, the actual O&M cost
estimate also becomes more established. Anticipated
O&M costs must be presented to the state as the
information is made available.
Technical Review of the Intermediate Design
The intermediate design phase submittals must be
reviewed for technical content and consistency with
the ROD. The contracting party (EPA or USAGE) is
responsible for assuring that the intermediate design
is reviewed for:
• Biddability, constructability, operability,
claims prevention, and environmental
screening (see Appendix C)
57
-------
RD/RA Handbook
• Use of the most currently accepted pollution
control measures and technology
• Use of currently accepted construction
practices
• Spot-checking revised or newly submitted
calculations to assess design quality
For EPA-managed RDs, the RPM collects all TRT
comments and forwards them to the contractor. As
specified in the SOW, the contractor reviews and
formally responds to each comment. USAGE site-
specific contracts also require the contractor to
respond to all review comments.
The RPM also must update CERCLIS as the RA
cost estimate and schedule are refined. Updating and
maintaining the information in CERCLIS facilitates
effective communication between the RPM, PO, and
CO and helps ensure that RA funds will be available
as needed.
4.7.6 Prefinal/Final Design
The prefinal design is a draft version of the complete
RD, including all drawings, specifications, reports,
and attachments. All contracting party comments
generated during the intermediate design review
should be incorporated, all design work completed,
and the RA contract documents finalized.
The contracting party must review and approve all
prefinal design documents before requesting the final
design from the contractor. After the contracting
party has reviewed the prefinal design and the
contractor has incorporated any additional
comments, the contractor will submit the final Final
design. The final design should be stamped and
signed by licensed professional engineers involved
in preparing and certifying the final engineering
package. The certifications may include civil,
mechanical, structural, electrical, and chemical
engineering and registered geologist certifications.
Figure 4-12 outlines the major components of the
prefinal/final design deliverable.
Final Design Criteria Analysis Report
The final design criteria analysis report generally
should duplicate the contents of the intermediate
design criteria analysis report incorporating revisions
based on review comments. The USAGE version of
this report will be written in the past tense to indicate
Figure 4-12
Prefinal/Final Design Phase Submittal Components
• Design criteria report
• Basis of design report
• Prefinal/final drawings and specifications
- Complete specifications
- Complete drawings and schematics
- Construction QAPP
- Draft O&M manual
- Appendices
• RA solicitation package
• RA schedule
• Prefinal/final RA cost estimate
51-043-17B
that the criteria were considered before design
completion.
Final Basis of Design Report
The final basis of design report generally should
duplicate the contents of the intermediate basis of
design report incorporating revisions based on
review comments. Copies of all permit applications
also must be included as part of the permits plan
section of the report and access requirements
finalized to incorporate changes since the
intermediate report. The USAGE version of the basis
of design report, like the design criteria analysis
report, will be written in the past tense.
Prefinal/Final Drawings and Specifications
The major generic components of the prefinal/fmal
drawings and specifications listed in Figure 4-12 are
described below.
Complete Specifications
The prefinal/final specifications should finalize the
intermediate specifications and include final
construction, installation, site preparation, and
fieldwork standards, including an equipment startup
and operator training plan. The complete
specifications also must include a submittal register
to identify all plans, documents, and construction
submittal items that will be submitted by the
constructor during the RA. All specifications shall
conform to CSI format (USACE-managed RDs will
follow the USAGE ETL 1006, Technical
Requirement for Pre-design and Design Submittals
specifications).
58
-------
Chapter 4 • Federal-Lead Remedial Design
Complete Drawings and Schematics
All drawings and schematics must be presented in
final form. The types and number of drawings vary
depending on the nature of the remedy. The drawings
may include, but are not limited to:
• A drawing register listing each drawing and
specification produced during the course of
the project with current status indicated
• Facility representations, PFDs, and floor plans
• P&IDs
• A process control table
• Utilities drawings
• Grading and drainage controls
• A landscape plan
• A seeding and sodding plan and wetlands and
revegetation plan
• A vicinity map
• Site characterizations, contour maps, and
physical features
• Site work zones, designated safety zones, and
site clearing activities
• Excavation plans
• Site layouts and demolition plans
• A flood control plan
Construction Quality Assurance Plan
A construction quality assurance plan (CQAP) must
be prepared by the designer in accordance with the
Construction Quality Assurance Plan for Hazardous
Waste Land Disposal Facilities and submitted as part
of the prefinal/fmal report. The CQAP is the plan
that describes the QA tests necessary to ensure that
the final product meets the design specifications. The
tests are used to provide quantitative criteria with
which to accept the final product. Construction QA
is the responsibility of the contracting party and takes
place throughout the construction process.
The CQAP, at a minimum, should contain the
following elements:
• Lines of authority and responsibilities of all
key personnel involved in the RA
• Construction QA personnel qualification
requirements
• List of inspection activities, including the
summary, scope, and frequency of the tests
and observations used to monitor the RA and
verify compliance with environmental
requirements and customary construction
practices, OSHA, building and safety codes,
etc.
• List of sampling requirements
• All documentation requirements for reporting
construction QA activities, including daily
summary reports and inspection data sheets
Draft O&M1 Manual
The responsibilities for completing the O&M manual
are shared between the designer and the constructor.
The designer must prepare and submit a draft of the
O&M manual during design. The designer completes
its portion of the manual and provides a copy with
the specifications. The RA constructor completes the
manual during the RA phase of the project. The draft
manual may contain the following (with the party
responsible for completing each section indicated
in parenthesis):
• Description of how the designer intends the
facility to operate (designer)
• Description of normal O&M, including startup
procedures, prescribed treatment or operation
conditions, and schedule (constructor)
* Description of potential operating problems,
including common or anticipated remedies
and a useful life analysis of significant
components that includes replacement costs
(designer and constructor)
• QA plan for O&M, including a description of
routine monitoring tasks, a description of
required laboratory tests, required data
collection reporting requirements (to EPA,
USAGE, the state, etc.), and the location and
rationale of monitoring points (designer)
• Description of alternative procedures to
prevent releases or threatened releases which
may endanger health or prevent cleanup
standards from being attained (designer)
59
-------
RD/RA Handbook
• Description of the corrective action to be
taken in the event of a release (designer)
• Safety plan, including a description of
precautions, personal protective equipment
(PPE) requirements, and the tasks required in
the event of a safety systems failure (designer
and constructor)
* Description of all installed equipment,
including identification numbers, vendor data
and submittals, monitoring components, site
equipment, spare parts, and component
maintenance and replacement schedules
(constructor)
• Description of all record and reporting
mechanisms required, including daily
operating logs, laboratory records, for
operating costs, mechanisms for reporting
emergencies, maintenance records, and
reporting requirements to the appropriate
parties (designer)
• Final O&M cost estimate projected annually
along with supporting documentation
(designer and constructor)
Appendices
All pertinent data used in developing the design will
be included as appendices. The list includes, but is
not limited to:
• Calculations
• Chemical data
• Geotechnical data
• Applicable references
Complete RA Solicitation Package
The prefinal/final report must include the following
RA contract documents:
• Solicitation/contract form
• Supplies or services and prices
• RA SOW
• Terms and conditions of the contract,
including payments, delivery schedule, point
of delivery, and acceptance criteria
• Method of procurement, including evaluation,
basis, and method of awarding the RA
contract
• Prevailing wage rates determination, in
accordance with the Davis-Bacon Act or the
Service Contract Act, and the wage rate
expiration date
• Deadline and location for submitting bids/
offers
• All appropriate contract clauses
RA Schedule
The final RA schedule should detail the specific RA
milestones and outline the estimated completion
dates. The schedule also must include the estimated
labor, equipment, and oversight resources required
to complete each milestone as well as additional site-
specific or contracting party schedule requirements.
Prefinal/Final RA and O&M Cost Estimates
As with earlier stage RA cost estimates, the prefinal/
final RA cost estimate must include all costs
necessary to arrive at a current working estimate.
The estimate should be prepared with as much detail
as the design documents allow. Since the design is
more complete at this stage, design contingencies
normally will be lower at this stage than for
preliminary and intermediate design project stages.
Cost allowances also should be significantly reduced
at this stage. The prefinal/final RA cost estimate is
expected to be accurate within plus 15 percent and
minus 5 percent. The basis for all unit prices should
be provided with the estimate, and should reflect
current costs for labor, materials, and equipment.
Vendor quotations should be included in the estimate
when used. Cost risk analysis should be used for
assignment of contingencies to accommodate any
potential cost growth.
The RA cost estimate cannot be substituted for the
IGCE when preparing the RA solicitation package
because the IGCE is used for comparing and
negotiating costs with the RA contractor. A
contractor-prepared cost estimate cannot be used for
this purpose (see section 5.2.5).
The final O&M cost estimate information is included
as part of the materials submitted with the prefinal/
final draft O&M manual.
Reviewing the Prefinal Design
The contracting party's TRT reviews the prefinal
design phase submittal to ensure:
60
-------
Chapter 4 • Federal-Lead Remedial Design
• Contractor completion of the plan-in-hand
reviews and correlating drawings and
specifications as detailed in the SOW (see
section 4.3.1)
• Final biddability, constructability, operability,
claims prevention, and environmental reviews
(see Appendix C)
• Accuracy of the RA cost estimate, quantities
of materials, etc.
• Use of currently accepted construction
practices
• Use of the most currently accepted pollution
control measures and technology
• Adequacy of the O&M plan and the CQAP
• Adequacy of site security and the RA health
and safety specifications
• Compliance with local/national building and
safety codes
4.8 Value Engineering During Remedial
Design
VE is required for RDs because MR Part 48 requires
that federal contracts, with few exceptions, must
include a clause providing for VE services. In
addition to the FAR requirement, the Office of
Management and Budget Circular No. A-131
requires the use of VE, when appropriate, in all
federal departments and agencies to reduce
nonessential procurement and program costs.
VE is an organized effort directed at analyzing the
functions of systems, equipment, facilities, services,
and supplies for the purpose of achieving the
essential functions at the lowest life-cycle cost
consistent with required performance, reliability,
quality, and safety. VE during an RD is similar to
classical design reviews but focuses on functionality
and reducing the investment necessary to achieve
the design function. VE can be applied during any
phase of the project, but application during early
phases of the RD produces the maximum benefit.
The VE process involves a VE screen, the use of a
VE study team, and, possibly, a VE study. These
procedures are discussed below.
4.8.1 VE Screen
The first step in VE for an RD is the VE screen. The
contracting party must ensure that the schedule and
budget for the RD allow for VE and should include
VE redesign in the cost and budget contingencies.
For USACE-managed RDs, USAGE is responsible
for VE activities, including the VE screen. For
designs developed by an ARCS/RAC contractor, the
RPM includes the VE screen in the WA SOW to
ensure that it is conducted.
In the VE screen, the designer reviews the proposed
process and identifies the potential high cost design
elements or subsystems that may become candidates
for a formal VE study. Figure 4-13 highlights typical
questions the designer should ask when conducting
a VE screen. This task should be completed as early
as possible, with the results of the VE screen
presented in a formal report to the contracting party
with or before submittal of preliminary design phase
drawings and specifications.
The contracting party reviews the VE screen rec-
ommendations and determines if a VE study is nec-
essary. When USAGE is the contracting party, it
should notify the RPM if a VE study will be per-
formed and the effects that a study will have on the
ROD, budget, and schedule. When EPA is the con-
tracting party, the RPM should consult with theTRT
to ensure that potential high costs or problem areas
have been explored in the VE screen before autho-
rizing a VE study.
4.8.2 VE Study Team
The VE team selected to conduct the VE study must
be independent from the actual design team so that
no VE study team member has a financial interest
in the outcome. Studies may be conducted by a VE
team from another federal agency, a VE consultant,
EPA in-house personnel or, in certain situations, by
the EPA contractor (ARCS/RAC). If the EPA
contractor that is developing the design conducts the
VE study, the CO must ensure that the contractor
has an independent VE group within its organization
and demonstrate that the contractor has made the
decision to develop a quality product regardless of
the effects on profit.
If the Regional EPA office has a VE program in
place, this team may perform the study. Lacking an
61
-------
RD/RA Handbook
Figure 4-13
Value Engineering Screening
The Society of American Value Engineers (SAVE) developed the following questions to Identify design elements
as candidates for a VE study.
• Is the item expensive?
• Is the Kern complex?
• Is it a high-volume item? Can a simple change in one item produce large savings in the total project?
• Does the item use critical materials?
• Is it difficult to construct?
• Does it have high O&M costs?
• Does it require specialized skills to construct or operate?
• Does it use obsolete materials and methods?
• Was the design rushed?
• Does it use traditional design?
• Is the competition producing the item at a lower cost?
In addition, several other questions should be asked:
i
• Does the design advocate using proprietary technology? (Royalties, which must be paid for proprietary technology,
could be avoided by considering other options.)
• Will it require highly trained personnel to operate?
• Is the design treating everything using a single piece of equipment, when several pieces of equipment would be more
cost-effective and efficient?
• Is the design using technology already proven in industry in similar (not necessarily in the hazardous waste field)
commercial applications? (Look to chemical processing, oil refining, field production, etc.)
• Has the design used predesigned skids or equipment packages effectively?
in-house team, the RPM should consult with the
USAGE VE study team chief engineer located in
the Savannah, Georgia division office. If the RPM
requests the USAGE specialized VE team in
advance, it may be able to conduct a timely review
without adversely affecting the schedule.
All technical disciplines involved hi the design must
be represented on the team. Team members should
have received the 40-hour VE training sponsored
by the Society of American Value Engineers (SAVE)
and the team leader should be certified by that
organization. Adjunct members also may participate.
EPA should not, however, pay for contractor
personnel VE training. A representative from the
designer should also be available.
4.8.3 VE Study
A VE study during an RD uses a prescribed
methodology to address technical problems
51-043-18D
creatively and attempt to lower project capital or
O&M costs. The typical VE study consists of six
phases:
• Information—The VE team identifies and
analyzes the function of each design element
to be studied.
• Speculation—The creative phase of the
process in which efforts are made to find a
better way of performing a specified function.
• Analysis—Each idea is analyzed for function
and potential cost benefit.
• Development—The ideas are developed in
detail and the VE proposal is written.
Development is limited to concept and
potential cost savings. Potential cost savings
account for the cost of redesign. No detailed
design work is performed by the VE team
during this phase.
62
-------
Chapter 4 • Federal-Lead Remedial Design
• Presentation—An oral presentation based
upon the written proposal is made. Team
recommendations are presented to the
decision-making body.
• Implementation—Incorporation of VE
proposals in the design.
The first three phases of the VE study often occur
during a week-long team meeting. The development
phase may take an additional two to three weeks.
The VE study team leader will provide the
contracting party with redesign options and study
recommendations.
The decision to incorporate the results of the VE
study is made by the contracting party. Where
USAGE is the contracting party for the RD, USAGE
should consult with the RPM before making a
decision to incorporate VE study results, especially
when proposed design changes may affect the
schedule or design costs. Where EPA is the
contracting party, the EPA CO consults with the RPM
and TRT and makes the decision to incorporate VE
study results.
Office of Management and Budget (OMB)
Circular A-131, May 21,1993, requires federal
departments and agencies to use VE where
appropriate.
4.9 Post-Design Activities
Post-design activities include the preparation of the
RA solicitation package (final drawings and
specifications), advertising the solicitation in the
CBD, holding a preproposal conference for all
potential constructors, and issuing amendments to
the solicitation package as necessary. The
procurement process is addressed in more detail in
section 5.4.
Prior to the initiation of the solicitation process by
the contracting party, the RPM is responsible for
completing the following activities:
• Obtaining the Superfund state contract (this
must be signed by the state before EPA
Headquarters releases RA funds for the site)
• Obtaining all site access/property for the RA
• Ensuring that the designer will be available
during the RA to provide technical support
• Preparing the RA SOW and the IGCE
• Preparing the IAG or WA
• Revising the RA communications matrix
• Ensuring TRT availability
• Issuing an RD fact sheet (40 CFR 300.435)
• Making information available to the public, as
appropriate, in a public availability session
before RA initiation (40 CFR 300.435)
63
-------
-------
Chapter 5 • Federal-Lead Remedial Action
Chapter 5 Federal-Lead Remedial Action
5.1 Introduction
The primary purpose of this chapter is to provide a
Remedial Project Manager (RPM) with an overview
of the remedial action (RA) process and his or her
responsibilities regarding the RA. The RA is the
process by which the remedy, as selected in the
Record of Decision (ROD) and defined by the
remedial design (RD), is implemented. The chapter
highlights the RPM's planning activities for the RA
(generally initiated before design completion) and
provides the RPM with an overview of the traditional
construction process, focusing primarily on the role
of the contracting party. The RPM's role in the site
closeout process is also defined and explained.
5.1.1 Preparation for the Remedial Action
There are a number of steps to be taken before the
actual RA commences (most of these should have
occurred during the RD). Figure 5-1 is a checklist
of pre-RA issues that need resolving.
Figure 5-1
Preremedial Action Checklist
• Is the Superfund state contract (SSC) complete?
• Has the RD fact sheet been completed and community
issues resolved?
• Has the Emergency Responder Preliminary Agreement
for local emergency response been obtained?
• Has property access been obtained for the RA?
• Are all permit applications submitted?
• Is the designer available during the RA?
• Is the Technical Review Team (TRT) available?
• Are the RA funds available?
• Is the independent government cost estimate (IGCE)
complete?
• Is the interagency agreement (IAG)/work assignment
(WA) completed, including the IGCE (for the WA)?
• Has the project management plan been revised?
51-043-21B
5.1.2 Responsibilities of Key Participants Involved
In the Remedial Action
The RA process, as illustrated in Figure 5-2, includes
the following phases:
• RA planning activities
• Procurement of the RA constructor
• Preconstruction activities/RA submittals
• Construction of the designed remedy
• Site-completion activities
Descriptions of the roles and responsibilities of the
various parties represented in an RA follow. Figure
5-3 illustrates the parties involved in the RA process.
Contracting Party
The use of the term contracting party in this chapter
differs slightly from its use in Chapter 4. The
contracting party advertises, awards, and manages
the RA contract. In the case of a Federal-lead RA,
this role is usually filled by an EPA contractor or the
United States Army Corps of Engineers (USAGE).
The EPA contractor is an Alternative Remedial
Contracting Strategy (ARCS) or Response Action
Contract (RAC) contractor. In rare situations, EPA
may serve as the contracting party (i.e., when
utilizing EPA prequalified contracts).
Technical Review Team
The TRT is a team of people whose primary
responsibility is to assist the RPM in reviewing
deliverables. The complex nature of a typical RD/
RA requires in-depth knowledge of a variety of
engineering and other scientific disciplines, so it is
important that the RPM assemble a team of
individuals with the appropriate backgrounds. The
TRT is assembled as early as possible in the RD/RA
process by the RPM to assist in reviewing submittals,
attending project meetings, and conducting site visits
(see section 3.4).
65
-------
RD/RA Handbook
Figure 5-2
Remedial Action Process
ROD/RD
IAG/WA development
RA Planning Phase
• Project management plan revisions
RA Procurement
• Solicitation of offers
• Evaluation of offers
• Selection
• Award
Construction
Notice to proceed
Submittals
- Schedule (RA)
- Health and safety plan (HASP)
- Quality assurance project plan
- Other technical submittals
Preconstruction conference
Mobilization
Performance of construction
Inspection and testing
Progress payments
Record drawings
Final inspection and acceptance
1
RA Report
Operations and Maintenance (O&M)
Site Closeout Activities
• Preliminary closeout report
• Final closeout report
• Notice of intent to delete
Construction Manager (CM)
The construction manager (CM) represents the RA
contracting party and is assigned to the site to
administer and oversee the construction contract. For
a US ACE-managed RA, this terminology is not used.
In such cases, the Resident Engineer (RE) fulfills
those obligations.
Resident Engineer
During traditional construction projects, an RE
serves as the designer's representative during the
construction, installation, and start-up phases of the
RA. The RE is responsible for ensuring that the
j 51-043-1E
constructor implements the RD in accordance with
design documents. Common RE services are shown
in Figure 5-4.
For projects where USAGE managed the design and
is managing the construction, USAGE performs the
resident engineering functions during the RA. To
assist USAGE in this effort, USAGE retains the
services of the designer (Title II services under the
designer's contract with USAGE). In situations
where a RAG or ARCS contractor developed the RD
and USAGE manages the construction, the RPM
retains the services of the ARCS/RAG design team
to respond to questions that may arise concerning
the design.
-------
Chapter 5 • Federal-Lead Remedial Action
Figure 5-3
Contractual Relationships in the Remedial Action Process
through an
interagency
agreement
USAGE
Resident Engineer
(USAGE on-site
representative)
through a
prequalified contract
through a
work assignment
Construction
Contractor
(constructor)
• Construction
Superintendent
(constructor's on-site
representative)
ARCS/RAC
Contractor
Construction
Manager
(ARCS/RAC
representative)
Resident Engineer
(on-site
representative)
RA Contractor or
Subcontractor
(constructor)
Construction Superintendent
(constructor's on-site
representative)
RA Subcontractor
(constructor)
Construction Superintendent
(constructor's on-site
representative)
51-043-aC
For ARCS/RAC-managed RDs and RAs, a member
of the actual design team fulfills the resident
engineering responsibilities. This individual may be
assigned to the site full-time, depending on the
complexity of the project.
Constructor
The constructor holds the contract for the RA and
does the remediation work. The constructor reports
directly to the contracting party. The RPM must
honor the privity of contract between the constructor
and the contracting party. The RPM cannot direct
or give the appearance of directing the constructor.
By interfering with the constructor, the RPM may
create a situation that could lead to a dispute claim
by the contracting party.
Construction Superintendent
The construction superintendent is the constructor's
official representative. The superintendent manages
the equipment and materials, oversees the labor,
coordinates the subcontracting work, controls health
and safety at the site, and communicates with the
contracting party.
5.2 Remedial Action Planning Activities
The RA planning activities are similar in scope to
those activities undertaken by the RPM when
initiating the RD assignment and include:
• Revising the project management plan
• Assembling the TRT
67
-------
RD/RA Handbook
Figure 5-4
Roles and Responsibilities of the
Resident Engineer
• Witnesses acceptance/confirms documentation of
goods, materials, and equipment
• Monitors the work performed by the constructor
• Interprets drawings and specifications
• Attends job meetings with the constructor
• Maintains project file, reviews submittal schedules,
and confirms progress reports
• Conducts inspection of completed work
• Reviews value engineering proposals
• Reviews change order requests
• Maintains an independent set of drawing markups
for comparison with those maintained by the
constructor
• Reviews constructor quality control files and identifies
issues of concern
51-043-24
• Finalizing the Superfund state contract (SSC)
(funds cannot be obligated without a signed
SSC)
• Drafting the RA statement of work (SOW) for
the ARCS/RAC contractor or (suggested for)
USAGE
• Developing the IGCE for ARCS/RAC-
managed RAs or assisting USAGE in
developing IGCE for USACE-managed RAs
• Conflict of interest screen
• Developing the RA schedule for the ARCS/
RAC contractor or assisting USAGE in
developing a schedule for USACE-managed
RAs
• Issuing the WA or executing the interagency
agreement (IAG)
5.2,1 Revising the Project Management Plan
As discussed in section 3.2, the RPM is encouraged
to develop a project management plan to serve as
the overall strategy for delivering the project on
schedule and within budget. The plan should be
updated to reflect decisions made during the RD.
As part of the initial RA planning activities, the RPM
should review the project management plan and
make necessary changes. This exercise ensures that
a complete record of major decisions charting the
course of the RA is adequately documented and that
the RPM is prepared to undertake RA project
management responsibilities.
5.2.2 Assembling the Technical Review Team
The RPM enlists the services of career professionals
to provide appropriate technical assistance in
reviewing submittals, serve as consultants during the
RA, and participate in site visits. As the project
develops, the RPM may change team members or
find that team members are no longer available. For
an RA where an ARCS/RAc contractor serves as
the contracting party, the RPM should obtain the
services of a USAGE construction advisor to help
the RPM review ARCS/RAC contractor claims and
change orders. USAGE brings its own TRT to the
project when it is the contracting party. In those cases,
the RPM should identify any other appropriate EPA
or state representatives to add to USACE's TRT. (See
section 3.4 for additional information on the
formation and composition of the TRT.)
5.2.3 Finalizing the Superfund State Contract and
Defining State Involvement During the
Remedial Action
Section 104 of the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA) requires the state to provide 10 percent
of the RA cost (the state's share of the RA cost is 50
percent or more if the state operated the facility at
the time of disposal of hazardous substances) and
conduct all O&M activities through an SSC. Thus,
the state plays a strong supporting role during the .
RA. The RPM must understand the state's role and
adequately plan for it to prevent schedule delays.
Before obtaining RA funds for the project, EPA and
the state must sign the SSC. The SSC is critical to
the RA schedule, since RA procurement cannot
proceed without it. The RPM must ensure that the
SSC is drafted early during the RD and completed
as soon as the final RA cost estimates (including the
cost of construction management services) are
available. The final RA cost estimate should include
a cost-risk analysis that should be performed by
USAGE to estimate potential cost escalation during
the RA project. USAGE should perform this analysis
because USAGE is experienced in developing
accurate contingency percentages for construction
projects. This potential cost escalation must be
factored into the state's cost-share estimates to
68
-------
Chapter 5 • Federal-Lead Remedial Action
minimize the likelihood of SSC cost overruns during
the RA (see section 3.11 for additional information
on SSCs).
. The SSC is important because cost sharing in the
RA may bring about increased state involvement in
routine site management decisions. By defining the
roles and responsibilities of the state and other parties
in a Federal-lead RA before the RA commences and
providing detailed cost estimates with an appropriate
contingency built into the estimate, an RPM may
avoid situations that result in project delays.
The RPM and the state should meet regularly during
the RA to discuss site progress and any issues that
may affect the SSC. If the state does not participate
in the RA, it may raise issues at the end of the project
that cannot easily be addressed and may delay RA
completion. Ideally, the RPM should encourage the
state to be a member of theTRT and attend regularly
scheduled site progress meetings between the RPM
and USAGE personnel or theARCS/RAC contractor,
participate in site visits, and attend public meetings
with the RPM. This degree of state involvement is
also needed to prevent the state from being
"surprised" by an EPA request to amend the SSC
cost-share terms and ease the transition to the O&M
phase. Finally, the state and EPA, in accordance with
40 Code of Federal Regulations (CFR) Part
300.515(g), must conduct a joint inspection upon
RA completion.
5.2.4 Developing the Remedial Action Statement of
Work
The RA SOW is prepared during the RD and lists
all RA activities and requirements. The SOW must
contain clear, concise project requirements and
, provide key project milestones and target dates
establishing the project's schedule. The technical
requirements for both ARCS/RAC- and USACE-
managed RAs are discussed in greater detail below.
RA SOW for ARCS/RAC WAs
The RA SOW for ARCS/RAC WAs is developed
using the standard tasks for RA services identified
in Figure 5-5. TheARCS/RAC contractor manages
the actual construction activities performed by
subcontractors and the RA SOW reflects this
management role. In the SOW, field construction is
performed by a subcontractor under a single task. It
is important to differentiate between ARCS/RAC
Figilire 5-5
RAC and ARCS Contract RA Standard Tasks
RACs
Task 1 Project planning
Task 2 Develop and update site-specific plans
Task 3 Subcontract procurement
Task 4 Management support
Task 5 Detailed resident inspection
Task 6 Cleanup validation
Task 7 Community relations
Task 8 RA implementation (subpooi activity)
Task 9 Project performance
Task 10 Project completion/closeout
ARCS Contract
Task 1 Procurement support
Task 2 Construction management
Task 3 Technical engineering services
51-043-25B
contractor submittals and subcontractor submittals.
A register such as the one presented in Appendix B
is an essential tool the RPM uses to track the ARCS/
RAC contractor's work at the site and record the
contractor's transmittal of submittals. The RPM
(assisted by the TRT) performs these tasks when
developing the RA SOW:
• Identifies ARCS/RAC contractor submittal
due dates, the methods to evaluate whether the
contractor has delivered the quality of work
required, and EPA's procedures (i.e., time
frames, number of copies needed, location of
meetings, etc.) for reviewing the submittals, as
they affect the contractor.
• Identifies all subcontractor submittals that
EPA elects to review. ARCS/RAC contractor
personnel receive numerous submittals in
accordance with the RA subcontract and EPA
must identify those it wishes to review.
• Outlines minimum communication
requirements, including the frequency of
routine meetings. Meetings must be held at
least once per week to manage the RA. There
are cases, however, when daily contact is
necessary to ensure project success.
-------
RD/RA Handbook
• Specifies when and under what circumstances
the federal government will accept transfer of
all constructed facilities. A definite date for
government acceptance of transfer is
necessary because the government pays for
liability insurance through the ARCS contract
and RAC invoices as long as the subcontractor
is responsible for the facility. Consults the
Project Officer (PO) and Contracting Officer
(CO) for further instruction related to
subcontractor insurance requirements for
ARCS/RAC-managed RAs.
• Details expected requirements for O&M
transition.
A model RA SOW, incorporating the RAC standard
tasks, is included as Appendix E.
RA SOW for USAGE lAGs
An IAG SOW is required as part of an RA IAG and
serves to communicate EPA's needs to USAGE. A
lack of clearly defined roles and responsibilities
ultimately may lead to a breakdown in
communication and a reduction in project quality.
Successful US ACE-managed RAs are facilitated by
open and regular communication between EPA and
USAGE.
The IAG SOW for an RA is not the same as a
contractor SOW because USAGE is functioning as
an extension of EPA. Ideally, the RPM should
coordinate with USAGE to develop an IAG SOW.
The RPM should also work with USAGE to develop
accurate construction cost estimates. The IAG SOW
should define EPA's requirements, the expected
schedule and known constraints, and discuss
participants' roles and responsibilities. The IAG
SOW should include the following:
• Roles and responsibilities
• Communication requirements between
USAGE and EPA
• Special reports that may be generated for the
RPM
• Special community relations requirements
(i.e., site tours, media events, responding to
the press)
• Estimate of dollar amount of oversight costs
• Description of the relationship between the
parties for ARCS/RAC designs and US ACE-
managed construction
5.2.5 Developing the IGCE
An IGCE is a detailed estimate of the cost to the
government for services and supplies to be acquired
by the contracting party. An RA IGCE is a detailed,
formally approved estimate of cost to the
government to support contract award. The RA IGCE
for contract award purposes includes only those costs
associated with the contract itself. Other government
costs such as construction management, engineering
during construction, construction contingencies, etc.
should not be included in the IGCE used for RA
procurement. The IGCE should include only contract
direct costs of labor, equipment, and material;
contractor markups, including overhead, profit, and
bond; and escalation to the midpoint of construction.
Design contingencies can also be included for special
items in those projects for which the design has not
been completed, such as for performance
specification technologies.
IGCE for ARCS/RAC-Managed RAs
An IGCE must be completed before issuing an
ARCS/RAC WA. Initially, the designer prepares a
detailed cost estimate for the RA construction. This
is not the IGCE and should not be substituted for it.
The designer's construction cost estimate must be
independently confirmed with the signature(s) of
government personnel with relevant experience, such
as the Regional IGCE coordinator or USAGE staff
tasked to do the IGCE through a technical assistance
IAG. Both the ARCS/RAC contractor construction
management costs and the actual construction costs
must be estimated and included in the IGCE.
Construction contingencies, construction
management costs, and other government costs are
added to the IGCE after contract award to form a
current working estimate for programming purposes.
The contingency is essentially an emergency fund
obligated by EPA for use when processing change
orders and claims. The contingency is generally 10
to 25 percent of the construction cost estimate and
can be used only by the ARCS/RAC contractor when
authorized by the CO. Contingencies should be
developed from a cost-risk analysis.
70
-------
Chapter 5 • Federal-Lead Remedial Action
IGCE for USACE-Managed RAs
When USAGE manages the RA, it undertakes an
exercise similar to performing an IGCE before RA
solicitation activities. USAGE has a team of
experienced construction cost estimators who are
brought into a project before the final design is
completed to do the cost estimation. The RPM should
have USAGE perform a cost-risk analysis to
determine the actual level of cost uncertainty in the
project. This provides a more realistic cost estimate
which benefits the RPM when negotiating with the
state.
5.2.6 Developing the Remedial Action Schedule
A proposed RA construction schedule is developed
by the designer during the RD effort. For ARCS/
RAC WAs, the RPM must add the ARCS/RAG
contractor construction management responsibilities
to the construction schedule. The RA WA schedule
must include key delivery dates and EPA's required
time frames for deliverable review. Once the
schedule is in place, it cannot be changed (other than
with a contract modification) and all parties must
adhere to it. If the RPM does not abide by the
schedule, it may affect the constructor's schedule.
The constructor might then make a construction
delay claim, which EPA may be required to pay.
The same information is pertinent to USACE-
managed construction contracts. The RPM must
clearly identify which submittals he or she will
review and their associated review time frames. This
information can then be incorporated into the
schedule. USAGE should develop the full RA
schedule in consultation with the RPM.
5.2.7 Issuing the RA Work Assignment or Executing
the interagency Agreement
The type of WA used to initiate the RA depends on
the party that manages the construction and serves
as the construction contracting party. Information
on issuing ARCS/RAG WAs and executing USAGE
lAGs is provided in section 4.4. Although the
information presented in that section is specific to
RD WAs and lAGs, the processes are essentially the
same for RA WAs and lAGs.
5.3 Managing the Remedial Action
The RPM is responsible for managing the RA to
ensure that the project is delivered on time and within
the projected budget. At the same time, the RPM is
responsible for communicating with the EPA
contractor or USAGE, the TRT, state, and
community.
5.3.1 Managing the RA Work Assignment or Terms
of the Interagency Agreement
The RPM is responsible for managing the scope,
budget, and schedule of the RA. The level of
oversight required to successfully manage the RA
depends on whether USAGE or an ARCS/RAG
contractor serves as the contracting party. USAGE
serves as the agent of the federal government and
oversees the RA construction contract in accordance
with the Federal Acquisition Regulation (FAR).
Therefore, US AGE-managed RAs do not require the
same amount of RPM scrutiny as ARCS/RAC-
managed RAs.
EPA is held ultimately responsible for RA
development and execution, regardless of which
contracting party performs the RA. As EPA's
representative, the RPM must keep the project
on track by effectively managing the WA or IAG
in a manner that protects EPA's interests. Although
ultimately responsible for the RA, the RPM is
removed from the actual implementation of physical
work at the site because the constructor reports
directly to the ARCS/RAG contractor or USAGE
personnel. To successfully manage the RA WA or
terms of the RA IAG, the RPM does the following:
• Reviews all invoices, requesting backup
documentation as necessary. Under the IAG,
USAGE accepts responsibility for certification
of contractor invoices, thereby alleviating the
RPM of this major responsibility.
• Establishes and maintains thorough and
regular communications with the contracting
party.
• Processes IAG/WA amendments immediately
to increase funding or modify the scope of
work. Any delays in processing paperwork can
result in project delays leading to increased
RA costs.
• Enforces the schedule; requests a notice of
planned corrective actions to prevent schedule
delays; and demands immediate reporting of
any potential schedule delays by the
constructor.
71
-------
RD/RA Handbook
• Schedules routine site visits and attends daily
job meetings between the contracting party
and the constructor as part of any routine site
visit. These meetings can reveal RA issues
that may not be reported to the RPM. Weekly
visits and progress meetings are strongly
recommended. Additional visits should be
included to coincide with significant
construction events at the site.
• Provides timely responses to issues raised by
the contracting party. During construction,
quick decisions are necessary to prevent
paying constructor delay claims.
• Ensures that the RPM is involved in any
change orders that affect the scope,
performance, or cost of the remedy and that
would result in ROD modification.
• Emphasizes health and safety compliance. The
RPM must take the initiative to place health
and safety on the agenda during progress
meetings and site visits.
• Ensures compliance with all applicable QA/
QC requirements and policies.
Additional information on managing WAs and the
terms of lAGs can be found in sections 4.4.1 and
4.4.2, respectively.
5.3.2 Community Relations During the Remedial
Action
As discussed in section 3.12, the RPM implements
a community relations plan. He or she identifies,
based on personal contact with the community, how
often and by what means the community is informed
of the remediation activities. The RPM and Regional
Community Relations Coordinator should update the
community relations plan throughout the RA.
The amount of effort expended on community
relations activities depends greatly on the nature of
the RA and location of the site in relation to
residential areas. Failure to prepare the community
adequately for the upcoming RA may lead to serious
difficulties during implementation. Before and
during RA implementation, an RPM should:
• Inform the community about the RA
procurement process and constructor
selection.
• Notify the community immediately before the
constructor mobilizes and before other major
RA milestones that might affect the
community.
• Provide routine updates about site progress
through fact sheets and public meetings.
• Offer tours of the site (when safe to do so),
particularly at the end of the remediation.
• Discuss remediation activities, including
contingency plans, with those who live closest
to the site and those along the travel route for
off-site waste disposal.
'i
• Prohibit construction workers from discussing
remediation activities directly with the
community and the media (this requirement
can be written into the RA contract).
I
5.3.3 Reviewing the EPA Contractor's Remedial
Action Work Plan
Reviewing and approving the EPA contractor's RA
work plan is similar to the process described in
section 4.6. The work plan is a detailed response to
the RA SOW, containing a task-by-task description
of the contractor's approach to meeting EPA's project
requirements. The RPM, assisted by the TRT,
reviews the work plan to ensure that the EPA
contractor understands the RArequirements. The RA
work plan must contain the following essential
elements:
I
• Description of the roles and responsibilities of
the construction management team, RE, and
other key personnel; lines of authority; and
lines of communication in the management of
construction activities.
• Resumes of key contractor personnel assigned
to the project.
• Description of the proposed procurement
process.
• RA schedule and those procedures requiring
EPA approval to update it.
• Preconstruction conference schedule,
including a list of critical items to be covered.
• Method for implementing the construction
quality assurance plan (CQAP) (see section
4.7.6).
72
-------
Chapter 5 • Federal-Lead Remedial Action
HASP for field construction activities (see
section 4.7.2) which must be incorporated into
the overall site HASP.
Formal procedures for transmitting submittals
and shop drawings from the constructor to the
EPA contractor for review and approval.
Formal procedures should be in place to
identify which parties are responsible for
reviewing each document. Large projects with
a broad range of technical submittals should
include a flow chart of the procedures as well
as a narrative description.
Description of the organization and
maintenance of the RA contract files at all
stages of the project, including disposition of
files at the end of construction or at the end of
O&M.
Description of the required inspection and
testing procedures for determining constructor
compliance.
Process by which the constructor is required to
submit record drawings (these are design
drawings, also called as-builts, showing the
original design as modified by actual changes
during construction). The marked-up record
drawings will be kept on-site and should be
available for review. A final set of record
drawings is submitted after construction is
completed.
Description of the process by which the
constructor submits invoices for completed
work and verifies that the work is satisfactory;
retention provisions; turn-around time for
payment; required reports; and provision for
final payment and release of retained funds.
Description of internal procedures that the
EPA contractor uses to manage change orders,
identifying key personnel, lines of authority,
procedures for developing estimates, and the
schedule and budget adjustment negotiations.
Description of the procedures by which the
EPA contractor will resolve and process
constructor claims.
Procedures describing the process wherein the
construction work is accepted and final
payment is made to the constructor; the
conditions that must be met by the constructor
to obtain acceptance during the prefinal and
final inspections; the shift in responsibility for
the site between the constructor and the
government; and the warranty of the work in
accordance with the contract.
• For projects that produce facilities requiring
postclosure operation, the EPA contractor
provides the procedures for startup, operation,
trouble-shooting, training, and evaluations
until transfer to the state under the SSC (see
40 CFR 300.435) takes place.
• Identification major equipment needs for WA
performance and how the contractor will
obtain the equipment.
• Identification the system-testing criteria and
acceptable limits, ranges, and timeframes that
will be used to establish that the system is
operational and functional (see section 5.7.1).
5.4 The Remedial Action Procurement
Process
Procurement is a complex process in which the
contracting party solicits bids (or offers) and
evaluates them, selects a constructor, and awards the
contract. There are four basic forms of procurement
within federal construction contracting:
• Sealed bidding
• Negotiated procurement
• Two-step sealed bidding
• Non-competitive (sole-source) procurement
5.4.1 Sealed Bidding
Sealed bidding provides an opportunity for all
qualified contractors to compete for the work on a
price basis. The work must be described in detail so
that bidders fully understand what is required and
bid on an equal basis. The selected bid becomes the
basis for a fixed-price contract. Therefore, sealed
bidding is used for sites where detailed design
specifications have been developed. Four steps are
involved in sealed bidding.
• Presolicitation (i.e., the RD)—Drawings and
specifications are developed in this step.
73
-------
RD/RA Handbook
• Solicitation and receipt of bids—An invitation
for bids (IFB) is advertised in the Commerce
Business Daily (CBD). Bids are submitted in
sealed envelopes according to IFB
instructions. It is suggested that the IFB be
placed in local newspapers as well.
• Bid evaluation—The bids are evaluated to
determine if they are "responsive and
responsible." Responsive bids are completely
filled in, have all necessary attachments and
signatures, and are not qualified or
conditioned by the bidders in any way.
Responsible bids are made by organizations
that possess sufficient capital and resources
and past work histories to indicate a high
probability for successfully accomplishing the
work. Sufficient work history is determined
through consultation with the TRT.
• Award of contract—The lowest bid that is
deemed responsive and responsible is
announced and the contract awarded. This
type of procurement typically results in lower
costs to the government and a shorter bid time
period since no technical evaluations are
necessary.
When a majority of the sealed bids submitted in
response to an IFB are significantly higher in cost
than anticipated or are non-responsive, the RPM
should be involved in any RA procurement decisions
made. For example, depending on the reason for non-
responsive bids, the IFB may need to be altered and
re-issued or the procurement cancelled.
5.4.2 Negotiated Procurement
Negotiated procurement proposals are evaluated on
the basis of technical merit and cost rather than cost
alone. Six steps are involved in the negotiated
procurement process.
• Presolicitation—Performance-based
specifications are developed during the
design, stating project requirements (i.e.,
standards of quality and services to be
provided). Offerers develop their own
approaches to meeting the performance
standards established for the site.
• Solicitation and receipt of proposals—A
request for proposals (RFP) is advertised in
the CBD. The RFP contains project
performance specifications and a description
of the evaluation criteria. The scoring criteria
and the basis for award also are provided. It is
suggested that the RFP also be placed in local
newspapers.
• Discussions—Offerers are made aware of any
deficiencies hi their proposals in order to
bring as many as possible into the acceptable
range.
• Evaluation of proposals—The cost and
technical acceptability of the proposal and the
offerer's firm's ability to accomplish the work
are evaluated. The cost and technical
evaluations are done separately and combined
at the end for a total score. Proposals are
usually categorized as technically acceptable,
potentially acceptable, or unacceptable. If the
RPM is required to make any technical
judgments, input from the TRT is
recommended. The government then issues
interrogatories and all offerers have the
opportunity to clarify or improve then-
proposals (e.g., make potentially acceptable
proposals technically acceptable).
i
• Best and final offers (BAFOs)—The
contracting party is required to solicit BAFOs
from all technically acceptable proposals.
BAFOs are evaluated and scored in terms of
cost and technical merit to determine a final
score.
• Source selection and award—The BAFO with
the highest final score is selected and a
contract awarded.
5.4.3 Two-Step Sealed Bidding
In this procurement method, offerers first submit
proposals without cost information in response to
an RFP and submit sealed bjds if their proposals are
found acceptable. The proposals are judged on their
compliance with established criteria. They are
categorized as being either acceptable, potentially
acceptable, or unacceptable. Although this method
is conducted as a sealed bidding procurement, there
are two differences: (1) bidding is limited to those
who have successfully completed the first stage and
(2) bidders must comply with the RFP and meet any
additional IFB requirements. The government then
selects the lowest bid.
74
-------
Chapter 5 • Federal-Lead Remedial Action
5.4.4 Non-Competitive (Sole-Source) Procurement
Non-competitive, or sole-source, procurement is the
least-favored method of procuring an item or service
and can be used only in the rarest of circumstances.
FAR Part 6.3 states that one of the following
circumstances must apply in order to employ this
type of procurement:
• Only one responsible source is available and
no other supplies or services satisfy EPA's
requirements
• Unusual or compelling urgency exists (poor
planning does not satisfy this criterion)
• An emergency situation exists involving
industrial mobilization or engineering,
development, or research capability
• International agreement (where a foreign
government reimburses EPA)
• Authorized by a statute
• National security is an issue
• In the public interest not to proceed with full
and open competition *
Additional planning must be undertaken at the outset
because of potential controversy surrounding the use
of non-competitive procurement. If USAGE is the
contracting party, it ensures that the procurement is
performed in accordance with all federal regulations.
In those cases, the RPM should defer to USAGE
personnel judgement. When an EPA contractor is
the contracting party, the CO must consent to a
subcontract procured by this method.
5.4.5 The Remedial Project Manager's Role in the
Procurement Process
The RPM's role is limited in the constructor
procurement process, because EPA does not have a
direct line of communication with the constructor
(unless EPA is managing the contract directly
through a prequalified contract). The RPM, however,
is responsible for monitoring the process to ensure
the procurement proceeds without delay. Even the
best solicitation packages may need to be amended
at some point during the solicitation process. This
need usually arises in a bidders' conference where
the potential bidders request clarification of the
solicitation package.
The RPM should attend the bidders' conference
which may include a "job walk" through the site. A
job walk is a tour of the site to obtain a site overview
and help the bidders/offerers decide how to approach
the RA project. When USAGE is the contracting
party, the RPM is encouraged to participate in the
technical review process as either a voting or
nonvoting member. (Being a voting member,
however, requires a substantial time commitment
because the panel's voting members are sequestered
several times during the selection process.) Although
the RPM may participate in the technical review
process for proposals in USACE-managed RAs, he
or she may not participate in the evaluation of
subcontractor proposals with an ARCS/RAG
contractor-managed RA.
5.4.6 Approving the EPA Contractor's Selected
Constructor
Before the contract is awarded, the EPA contractor
sends a notice of intent to award to the RPM. The
RPM then prepares an evaluation memorandum and
submits it to the EPA CO for concurrence. The CO
reviews the memorandum and consults with the
RPM, PO, and TRT to determine if the constructor
can perform satisfactorily. The CO acknowledges
constructor acceptance by issuing a letter authorizing
the subcontract or issuing a contract modification.
Once the EPA contractor selects the constructor, a
notice of award is sent to the constructor and a copy
to the RPM. This notice requires the constructor to
submit all required bonds (payment, bid, and
performance) and sign a contract within the period
of time specified in the notice. If the selected
constructor does not qualify (e.g., due to the inability
to obtain bonds or meet other contractual
requirements) or refuses to enter into a contract, the
bid bond is forfeited. Due to the potential for award
delay, the solicitation usually states that the bids and
bid bonds may be held as long as 60 days after
opening.
5.4.7 Construction Contract Award Controversies
An award controversy in a Federal-lead RA has the
potential to create delay in the construction process.
The method of managing contract award
controversies, or bid protests, differs depending on
the contracting party. Protests can be filed at any
time in the procurement process but generally occur
75
-------
RO/RA Handbook
immediately following the notice of award. For more
specific information than is provided below, refer to
the Office of Regional Counsel or the Office of
General Counsel.
Construction Contracts with the ARCS/RAC Contractor
Construction contracts with an EPA contractor are
subcontracts. Subcontractors to EPA contractors do
not have a direct contractual relationship with EPA;
therefore, subcontractors do not have access to
federal administrative procedures for hearing
protests. All award controversies regarding the
contract between the EPA contractor and its
subcontractor must be resolved between those two
parties without government involvement. The parties
may resort to state courts, which could lead to
injunctions or other delays. In contrast, an EPA
contractor that directly contracts with EPA would
be able to access the federal administrative
procedures described in FAR Part 33 to protest
contract award.
Construction Contracts with USACE
FAR Part 33 details the requirements for filing and
processing bid protests. An unsuccessful offeror
(assuming the offeror would be a prime contractor
with USACE) can file a protest with USACE or
directly with the GeneralAccounting Office (GAO).
Protests submitted to USACE for resolution are
governed by USAGE regulations (USACE uses the
Department of Defense Board of Contract Appeals).
Normally, protests filed with a USACE CO before
award of the contract prevent award until the protest
is resolved.
Protests filed with GAO prevent award, if filed
before award, or prohibit performance on the
contract, if filed within ten days of award of the
contract or five days after a requested debriefing to
an unsuccessful offeror. The CO may award a
contract in the interim if it is deemed to be in the
best interest of the government or urgent and
compelling circumstances that significantly affect
the interests of the United States will not permit
awaiting GAO's decision. Only in rare circumstances
is this avenue taken. The normal course of action is
to await decision by GAO.
Protests filed with GAO have greater potential for
delaying projects because of GAO's review and
decision-rendering timeframes. Once a protest is
filed with GAO, it has 125 calendar days (mandated
by tin&FederalAcquisition Streamlining Act of 1994,
P.L. 103-355) to render a decision. For protests filed
with GAO more than ten calendar days after contract
award, the CO does not have to suspend contract
performance or terminate the awarded contract
unless it appears likely that the award may be
invalidated.
5.5 Preconstruction Activities
During actual construction, the ARCS/RAC
contractor assigns a CM to the site to supervise all
construction activities, whereas USACE personnel
assign an RE or a team of REs to RA projects. The
following six activities occur immediately after
contract award:
• Issuing the notice to proceed
• Conducting the preconstruction conference
• Delivering the preconstruction submittals
• Providing site security
• Mobilizing the constructor
• Posting EPA signs at the site
5.5.1 Issuing the Notice to Proceed
A notice to proceed initiates construction activity.
The ARCS/RAC contractor or USACE issues the
notice sufficiently hi advance of the required date to
provide the constructor adequate lead time. The RPM
should request and receive a copy of the notice. The
date on the notice marks the formal beginning of
the construction project. Progress within the
construction schedule will be measured by that date.
Before the notice is issued, the constructor should
have submitted a detailed construction schedule
against which progress can be measured.
5.5.2 Conducting the Preconstruction Conference
There must be a preconstruction conference before
work begins attended by all parties involved in the
RA project, including the RPM, state, and local
authorities (i.e., municipal public works department,
municipal or county highway department, local
emergency response personnel, etc.). This is the first
meeting attended by everyone involved in the
project. The purpose is to establish relationships,
define roles and responsibilities, and answer any
76
-------
Chapter 5 • Federal-Lead Remedial Action
questions concerning contract implementation.
Figure 5-6 lists activities covered in a typical
preconstruction conference.
Figure 5-6
Preconstruction Conference Activities
• Introducing team members
• Discussing EPA's expectations
• Reviewing general project scope
• Reviewing the final CQAP and quality control plan
• Reviewing the project schedule
• Establishing scheduled meetings and briefings
• Reviewing roles and responsibilities
• Reviewing document control procedures
• Discussing key issues, concerns, and project goals
• Discussing procedures to resolve disputes and
misunderstandings
• Reviewing the HASP and emergency response plan
• Reviewing procedures for project completion
51-043-26
5.5.3 Delivering the Preconstruction Submittals
Refer to the RA SOW in Appendix E for a sample
listing of preconstruction submittals. These
submittals require approval before the constructor
can be mobilized.
5.5.4 Providing Site Security
The constructor must provide a site security plan
before mobilizing at the site to prevent the public
from having access to potential site safety hazards
and to prevent the theft of or damage to facilities.
The contracting party and the RPM should review
site security on a regular basis to ensure compliance
with the accepted plan.
Many sites have security cameras with 24-hour
surveillance. Routine checks must be conducted to
ensure that the cameras are operational. At a
minimum, all sites under construction should have
a guard posted during working hours. It may be
necessary to post guards 24 hours per day, depending
on the specific problems encountered. The RPM
must be forceful in reviewing the security measures
and require all security lapses to be investigated
immediately. Any corresponding corrective actions
should be taken to prevent the lapse(s) from
reoccurring.
5.5.5 Mobilizing the Constructor
Mobilization begins after the constructor completes
preconstruction submittals. Mobilization is the
transfer of operations to the project site. At this point,
any delays caused by the government or the
contracting party can result in constructor claims for
delay. Conversely, if the constructor fails to progress
in accordance with the schedule, the constructor may
be subject to liquidated damages at the end of the
project (but only if such provisions exist in the
constructor's contract).
5.5.6 Posting EPA Signs at the Site
All Superfund sites should have signs posted at their
front gates to inform the public about the current
remedial activities. They should be posted when the
constructor mobilizes at the site and must contain
the following information:
• EPA logo (available from EPA Headquarters
printing office: Room MG 100D,
Environmental Protection Agency,
Washington, DC 20460 (202)260-2125)
• State logo
• USAGE logo (if it is the contracting party)
• Site name (with "Superfund" in the title)
• Contract award amount
• A point of contact and telephone number for
those who wish to obtain further information
or report suspicious activities
Office of Solid Waste and Emergency Response
(OSWER) Directive 9375.5-10IFS, "Public
Awareness Signs at Superfund Sites," October
1990, provides additional information on
Superfund signs.
5.6 Construction Implementation
Construction performance is the sole responsibility
of the constructor. The constructor determines the
methods and sequence for the work not previously
specified in contract documents. Before mobilizing,
the constructor must submit for approval a detailed
work schedule that is used to measure the
constructor's progress. The construction
77
-------
RD/RA Handbook
superintendent supervises the construction activities
and administers and coordinates the arrival of
materials, equipment, and labor in a manner that
proceeds without interruption. He or she supervises
the individuals responsible for different categories
of work and administers all subcontracts.
5.6.1 Inspection and Testing
In accordance with the quality assurance project plan
(QAPP), the constructor is required to maintain an
inspection system to substantiate that the work
conforms with contract requirements before the work
can be accepted by the contracting party. The terms
of the contract describe the required tests and
procedures. The constructor must provide the
resources necessary for the accomplishment of these
tests at the appropriate times.
In ARCS contracts and RACs, the CM, on behalf of
EPA and the RD designer's RE, will observe all of
the constructor's inspection activities and conduct
additional inspections as necessary in accordance
with the work plan to ensure the quality and quantity
of the work. Under USAGE contracts, the USAGE
RE conducts these inspections at his or her discretion
(although if an ARCS/RAC contractor performs the
RD there is also an RE representing the ARCS/RAC
contracting firm). Inspection should be carried out
hi such a manner that the work is not delayed. The
CM (or RE) shall maintain suitable records of the
inspection activities reflecting the number of
observations made, the number and types of defects
found, the corrective actions taken, and the resolution
of any written instructions. The following project
aspects should be inspected:
• Progress
• Materials (quality and quantity)
• Quality of work
» Adherence to design
• Health and safety
The quality assurance (QA) inspectors, hired by the
constructor, shall review all daily reports and
construction activities to verify that the work
conforms with the contract. This includes sampling
data collected by the constructor. All data confirming
the achievement of final cleanup levels must also
be verified. Additionally, the inspector should verify
compliance with all environmental requirements of
the contract. These inspections shall include, but not
be limited to, air quality and emissions monitoring
records, waste disposal records, and compliance with
the HASP. There also should be a plan for regular
materials testing specifying what tests will be
performed, on which materials, and testing
schedules. All inspection reports and certificates
must be filed on-site with the contracting party. The
CM or RE reviews and initials each report prepared
by the constructor. Any comments should be noted
in the CM or RE's daily log.
The RPM's Role in Inspections
Construction inspection records must be available
for the RPM to review on-site with assistance from
the TRT during RAs in which an ARCS/RAC
contractor is the contracting party. In addition, the
RPM should conduct spot checks of inspection
activities. The RPM should schedule site visits to
ensure that the contracting party and constructor are
fulfilling their respective responsibilities. The
frequency of these inspections is determined by the
size and complexity of the project, the rate of
progress being achieved, and the nature of problems
or issues arising during construction. At certain
critical phases, daily inspections may be necessary.
These inspections typically focus on recordkeeping,
contract administration, claims and change order
management, labor standards, construction progress,
and construction quality.
The RPM also conducts a joint inspection with the
state at the end of a Fund-financed RA to fulfill EPA's
requirements under the National Contingency Plan
(NCP), 40 CFR Section 300.515(g). The purpose of
the joint inspection is to determine that the remedy
has been constructed in accordance with the ROD
and the RD. This joint inspection should not be
confused with the prefinal or final inspections that
take place between the contracting party and the
constructor (see section 5.7.3).
!
5.6.2 Monitoring Construction Progress
The constructor should keep the project on schedule
while maintaining the specified quality and cost of
the work. As a practical matter, performance
according to the construction schedule should be
reinforced through frequent communication between
the parties. If the constructor is in danger of
defaulting on its contractual obligations, the
contracting party must meet with the RPM to discuss
78
-------
Chapter 5 • Federal-Lead Remedial Action
all potential options. The RPM monitors construction
progress through management of lAGs for USACE-
managed RAs and through WAs for ARCS/RAC-
managed RAs. When working with USAGE or an
ARCS/RAC contractor, the RPM can monitor
construction progress with the following:
« On-site construction activities
• Progress reports
• Progress payments
On-Site Construction Activities
The RPM should review the daily logs and the CM's
(or RE's, in USAGE projects) field diaries.
Photographs, including those of deficient work,
should be used to supplement the RE's or CM's daily
reports and establish job progress. At some sites, the
RPM or CM (or RE, in USAGE projects) may watch
footage taken of constructor activities by video
cameras at the site. He or she can thus observe project
progress without wearing protective gear. The
cameras also serve to document field activities
should claims arise later.
The RPM should attend weekly meetings between
the contracting party and the constructor at the site
whenever possible. While the RPM is on his or her
site visits, he or she should take advantage of the
opportunity to attend daily meetings between the
contracting party and the constructor. The RPM also
should conduct periodic spot checks of the site to
observe and document RA progress.
Progress Reports
Detailed progress reports from the ARCS/RAC
contractor and USAGE are required by the contract
on a monthly basis throughout the duration of the
project and are usually submitted with the monthly
invoices. The RPM uses the reports as a supplement
to site visits to monitor construction activities. These
reports must develop a chronological record of
remediation activities and should contain the
information outlined in Figure 5-7.
Progress Payments
In most fixed-price construction projects, progress
payments are made based on the percentage of work
completed. The payment formula is decided before
work begins and a system is developed that the
constructor uses to demonstrate, through field
measurements and inspections, that the work has
Figbre 5-7
EPA Contractor Progress Reports
• Documentation of the percentage of work completed
and total project cost to date
• Summaries of the following items for the reporting
period:
- Work performed on site
- Community relations activities
- Change orders to and claims made on the contract
- Problems or potential problems encountered,
inspection failures, reworked items, etc.
- Reports of accidents, injuries, etc.
• Status of contingency fund to date
• Estimate of work for the next reporting period
• Copies of daily reports, change orders, manifests for
off-site disposal, and all laboratory/monitoring data
51-043-27A
been completed. Verifying the quantity and quality
of work completed is part of the contracting party's
overall construction inspection duties.
Progress payments do not constitute final acceptance
by the government of the work performed to date. It
is customary to retain some portion of the initial
progress payments—usually five to ten percent—
until the constructor demonstrates that satisfactory
progress is being made. Full progress payments are
usually made when 50 percent of the work is
complete and continue until project closeout.
At the end of the project, sufficient funds must be
retained as a means of ensuring that punch list (a
written list of items needing correction or completion
in order to complete the contract terms) items are
performed and the final inspection is completed.
Final acceptance usually occurs after performance
of punch list items and completion of the final
inspection and sometime during or after the process
of achieving operational and functional status (see
section 5.7.1).
The RPM must review and certify for payment the
ARCS/RAG contractor's invoice by verifying that
the work has been completed as stated on the invoice
and accompanying progress report. The invoice must
include the constructor's costs as well. The ARCS/
RAC contractor retains the funds payable to the
constructor as noted above. The RPM should request
backup documentation as necessary.
79
-------
RD/RA Handbook
For a USACE-managed site, the RPM receives and
reviews Standard Form 1080 for final payment.
Although the RE certifies the invoice for payment,
the RPM must still review the invoice and may
request backup documentation as necessary. If there
are errors, corrections will be reflected on future
invoices.
5.6.3 Reviewing Record Drawings
As the construction progresses, the constructor and
CM or RE document each segment of completed
work. As part of this documentation, markups will
be made on a set of drawings. On simple projects,
such as a water main installation, the record drawings
can be markups of the original RD drawings. The
markups illustrate how the installed facilities differ
from the original design. For the installation of a
treatment facility, markups may be made on the
drawings indicating the actual components installed.
At the completion of the project, these markups will
be used to produce a clean set of record drawings
that accurately describe the installed facilities.
The RPM should review the development and ensure
the accuracy of the markup drawings as the work
progresses and that they are provided to EPA and
the state for O&M. The requirements for modifying
original drawings (i.e., production of record
drawings) in accordance with the markups should
be included in the RA SOW with the requirement
for RE services from the designer.
5.6.4 Changes to the Construction Contract
Construction contracts for both ARCS/RAC
contractors and USAGE contain a changes clause
and other related clauses. The changes clause
provides the needed flexibility to change the work
described in the contract to adjust to actual field
conditions and new interpretations of the drawings
and specifications as the work progresses. The
changes clause also can be used to order additional
work within the scope of the contract to meet the
government's need to implement the remedy.
The constructor is obligated to accomplish the work
ordered by the CM or RE who exercises the changes
clause, and in return is guaranteed an equitable
adjustment to both the price and the project schedule.
Additionally, the constructor may process claims
under the changes clause for equitable adjustments
for construction change costs. Construction changes
occur when the constructor performs work without
a formal change order due to the direction of the
CM, RE, or other authorized contracting party
employee.
Whenever the work is changed, both parties must
negotiate acceptable terms. When negotiations are
successful, the work changes are accomplished under
a supplemental agreement to the contract. If the
parties are not able to reach agreement, the
constructor will be ordered to proceed with work
under a change order for a price that the CM or RE
considers to be reasonable. If the constructor is
unsatisfied with the price, the constructor may file a
claim against the contracting party to resolve the
issue.
The RPM will be closely involved with ARCS/RAC-
managed RA change orders as part of his or her WA
management duties. For ARCS/RAC contractor-
managed RAs, there are two distinct spheres of
authority regarding changes in EPA contracts. The
constructor is a subcontractor under the EPA prime
contractor, so the government is not a party to the
actual construction contract. The EPA contractor,
therefore, is the only party with authority to negotiate
or order changes to the construction contract. The
second sphere of authority is in the contractual
relationship between the EPA contractor and EPA.
The contractor must obtain EPA review and approval
of the changed work within the context of the WA.
The EPA CO is the only individual who can commit
the government to pay these costs. Changes are paid
through the contingency fund (see section 5.2.5). The
CO requests that the CO's Technical Representative
review and make recommendations to support the
payment.
For USACE-managed RAs, USACE has its own
change order and construction change procedures
but the RPM and USACE personnel need to
communicate regarding significant change orders,
especially if a change order will result in a need for
more funds than authorized under the IAG or if the
change order affects the ROD.
Office of Solid Waste and Emergency Response
(OSWER) Directive 93S5.5-01/FS, "ARCS
Construction Contract Modification
Procedures," September 1989, provides
additional information on processing change
orders.
80
-------
Chapter 5 • Federal-Lead Remedial Action
5.6.5 Managing Claims
Constructor claims are generally made for the
purpose of requesting more financial remuneration
or to deviate from the schedule. In the claim, the
constructor alleges that the contracting party's action,
inaction, or misrepresentation in the contract
documents has caused an involuntary change in the
cost or time of performing the contract. The
contracting party can use the following techniques
to minimize the occurrence and effects of claims:
• Before advertising for bids or offers, ensure
that the drawings and specifications are
biddable, all conflicting language has been
removed, and ambiguities have been clarified.
• Make a complete investigation of the
subsurface conditions before soliciting bids
for and starting the RA and include the results
in the bidding documents.
• Closely monitor the construction to anticipate
problems and be prepared to resolve them as
soon as possible.
Because EPA does not have privity of contract with
the constructor for either USAGE- or ARCS/RAC-
managed RAs, EPA will become involved in
constructor claims only under certain circumstances
such as when the ARCS/RAC contractor pursues the
claim in the name of the constructor (see FAR Part
33 and the Contract Disputes Act of 1978). If the
ARCS/RAC contractor pursues a claim, it must be
submitted to an EPA CO. Usually, however, the CM
attempts to address any claim issues before the claim
goes to the CO. If the CO denies the claim, it may
be appealed in the Department of the Interior Board
of Contract Appeals or in U.S. District Court.
For USACE-managed RAs, the constructor that
directly contracts with USAGE will submit a claim
to USAGE for consideration. USAGE and the RPM
should communicate so that the RPM is aware of
any constructor claim that might affect the schedule
or achievement of the remedy. If the USAGE CO
rejects the claim, it may be appealed in the
Department of Defense Board of Contract Appeals
or in U.S. District Court.
If a claim is filed, the CM or RE should address the
issues raised and control future claim costs by having
the technical and legal staff analyze each issue.
5.6.6 Value Engineering During Construction
Value engineering (VE) is to be included in federal
construction contracts worth $100,000 or more with
few exceptions (see FAR 52.248-1). The VE clause
for construction is an incentive clause that provides
the opportunity to the constructor to use the latter's
unique knowledge and construction experience as a
basis for submitting a value engineering change
proposal (VECP) (see FAR 52.248-3). Developed
with its own resources (i.e., non-reimbursable), the
VECP is the constructor's proposal to make changes
to the RA project that, if incorporated, will save
money without compromising quality or
performance. The savings resulting from the
incorporation of a VECP are normally shared (45-
55 percent split for fixed-price contracts and a 75-
25 percent split for cost-reimbursement contracts)
between the federal government and the contractor
that submits the VECP. However, this arrangement
may vary according to contract type with the sharing
arrangement being determined by the type of VE
and the source of savings (see FAR 52.248-1 [f]).
Payment of any share due the constructor for use of
a VECP shall be authorized by a modification to the
construction contract.
After EPA receives a VECP from the contracting
party, it must notify the contracting party as to the
status of the VECP within 45 days or, if additional
time is needed, explain the delay and provide an
expected date for its decision. The RPM/Work
Assignment Manager prepares a letter on the status
of the VECP review for the CO's signature. VECPs
should be processed expeditiously; however, EPA
is not liable for any delay in acting upon a VECP.
If a VECP is not accepted, the CO notifies the
contracting party in writing, which in turn notifies
the constructor, explaining the reasons for rejection.
Any VECP may be accepted, in whole or in part, by
the CO's approval of a modification to the
construction contract. The CO may accept the VECP,
even though an agreement on price reduction has
not been reached, by issuing a notice to proceed with
the change. Until such a notice is issued or the CO
approves a contract modification, the constructor
must perform according to the existing contract.
For USACE-managed RAs, USAGE follows its own
VE procedures, but should notify the RPM of any
81
-------
RD/RA Handbook
accepted VECPs that wouldaffect ROD requirements
or the RA schedule or budget.
OSWER Directive 9355.5-03/FS, "Value
Engineering," May 1990, provides additional
information on VE during construction.
5.7 Contractor Completion Activities
As a project nears completion, all parties must
understand their roles and responsibilities to ensure
proper project completion and closeout. Final
inspection and closeout activities are discussed
below.
5.7.1 Achieving an Operational and Functional
Remedy
Immediately following construction of the remedy,
the remedy enters a "shakedown" phase referred to
as the operational and functional period. This
shakedown enables the constructor to make minor
modifications as necessary to ensure the remedy is
operating as designed.
Under 40 CFR Section 300.435, a remedy becomes
operational and functional either one year after
construction is complete or when the remedy is
determined concurrently by EPA and the state to be
functioning properly and is performing as designed,
whichever occurs first.
The operational and functional determination by both
EPA and the state is a critical milestone because it
marks the start of the O&M phase of a project.
Subsequently, disagreements may arise as to whether
the remedy is operational and functional. To
minimize disruption to the project, the RPM should
do the following:
• Ensure the designer incorporates into the
design documents (CQAP) the tests that are
necessary to demonstrate that the remedy is
operational and functional. This requirement
should be included in the RD SOW.
• Obtain agreement with the state through the
SSC on which tests will be used by both
parties to demonstrate that the remedy is
operational and functional.
5.7.2 Prefinal Construction Conference
A prefinal construction conference is required just
before completing the construction work. The
conference will be scheduled by the contracting party
and attended by the RPM, state, and constructor. The
objective of the conference is to discuss procedures
and requirements for project completion and
closeout. Suggested conference topics include:
• Final O&M plan submission
• Construction cleanup responsibilities
• Demobilization activities
• Security requirements for project transfer
• Prefinal inspection schedule
• EPA/state joint inspection schedule (NCP
requirement)
• Facility startup and training
• Operator training
5.7.3 Prefinal and Final Inspections
The prefinal and final inspections are standard
construction practices for closing out a contract. The
purpose of these inspections is to determine whether
the construction was completed in accordance with
the contract. They are generally held between the
contracting party and the constructor. These
inspections are often confused with the mandatory
EPA/state joint inspection requirement under the
NCP, 40 CFR Section 300.515(g). The EPA/state
joint inspection is a separate inspection held at the
completion of physical construction to obtain
agreement between EPA and the state that the
operational and functional period is ready to
commence. The contracting party and the
constructor, however, may agree to invite both the
RPM and the state to the prefinal or final
inspection(s) to avoid having to schedule separate
inspections.
Prefinal Inspection
The ARCS/RAC contractor's CM or USACE's RE
and the constructor's construction superintendent
will inspect the site and look at each element of work
to see if it is complete and ready to be accepted. In
some instances, the prefinal inspections can be
performed as each major element of the job is
completed instead of at the end of the project.
82
-------
Chapter 5 • Federal-Lead Remedial Action
Generally, there will be a few elements of work still
in progress at this time and some minor defects that
will come to light as the inspection proceeds. A
prefinal inspection report must be prepared that
includes the punch list developed by the CM,
completion dates for outstanding items, and a date
for a final inspection (if one is to be held). A copy of
this report should be sent to the RPM.
Final Inspection
Work is considered complete when the remedy is
operational and functional, all punch list tasks have
been performed, and terms of the contract have been
met. Thus, completion of construction activities does
not mean that theWAis complete. All parties should
attend the final inspection. The CM or RE determines
the level of work completeness. There may be a few
minor work elements not yet complete, but they may
not affect acceptance of the work. A portion of the
constructor's final payment is retained until these
outstanding elements are completed.
The RPM must focus EPA's portion of the inspection
on determining whether the remedy has been
implemented hi full compliance with the ROD. In
addition, where anARCS/RAC contractor serves as
the contracting party, the RPM needs to determine
if the work has been completed as described in the
ARCS/RACs work plan. The RPM should perform
a thorough work plan review so he or she will be
fully prepared to participate in the inspection. The
RPM should have his or her TRT assist in this
inspection.
Demobilization
Site demobilization occurs after the majority of
construction work is completed. This phase of the
remediation is generally comprised of the following
tasks:
• Removing all equipment, machinery, or
materials that are no longer necessary to
complete site activities
• Removing temporary buildings and structures
• Completing all necessary restoration or
replacement of public or private property
affected by the remediation activities
• Removing site debris, disconnecting
temporary utilities, and cleaning roadways or
other public access or service areas
• Transferring all finalized documentation
associated with the construction (e.g., log
books, records, etc.)
Items removed from the site during demobilization
may require decontamination before removal. Final
inventories of remaining materials and utilities
should also be completed. Any additional or site-
specific requirements contained in contract
requirements and specifications prepared during the
RD should be addressed.
5.7.4 Contractual Acceptance of the Project and
Warranty
Accepting the work is an important juncture in the
project because it alters the rights and responsibilities
of the parties involved in the construction project.
The government takes over full possession of the
facilities from the constructor upon acceptance of
the work. Final acceptance occurs after final
inspection and correction of the punch list items.The
risk of loss due to damage or theft shifts from the
constructor to the government. By accepting the
work, the government limits its rights to require the
constructor to make adjustments to or correct defects
in the work.
The government's acceptance does not relieve the
constructor from assuming responsibility for the
quality of work performed. If any of the three
exceptions to the finality of acceptance—latent
defects, fraud, or gross mistakes—are found to exist,
the constructor generally must correct the work.
In conditions not described above, awarranty clause
must be in the original contract to ensure that the
constructor corrects any defects. The warranty period
is usually one year against defects in equipment and
materials or quality of work and design.
Final Payment
Final payment to the constructor cannot occur until
the following items are completed:
• All final drawings, log books, records, and
other documentation are received by the
contracting party.
• The contracting party receives a letter from
the constructor stating that all work has been
performed in accordance with the contract and
is complete in every respect.
83
-------
RD/RA Handbook
• The contracting party receives a letter from
the constructor stating that all wages, debts,
and payments incurred by the constructor
during work performance have been settled or
paid in full.
• The contracting party receives a letter from
the bonding company stating that it has
reviewed the constructor's final request for
payment and agrees that payment will release
the constructor from any and all claims that
the constructor may have against the
regulatory agency(ies) in performance of this
contract.
• The contracting party receives satisfactory
evidence of the release of any outstanding
liens.
5,7.5 Remedial Action Report
Within 60 days after the final inspection, the
contracting party prepares and submits an RA report
to the RPM for each construction project. The report,
the official record of RA activities, is a required
submittal. This is not to be confused with the EPA
contractor or USAGE contractual obligations with
the constructor. This is an EPA administrative
requirement only and does not have to be done to
fulfill contractual agreements. The RA report
contains the following information:
• Introduction
• Chronology of events
• Performance standards and cleanup goals met
• Description of the QA/quality control (QC)
procedures followed
• Description of construction activities
• Final inspection documentation
• Certification that the remedy is operational
and functional
• Discussion of O&M requirements
• Summary of project costs
Review of the RA Report
The RPM reviews the RA report to ensure that the
remedy has been completed and meets EPA's goals
as established in the ROD. After reviewing and
accepting the report, the RPM prepares a letter to be
signed by an EPA branch chief, notifying the
contracting party of the acceptance.
OSWER Directive 9355.0-39FS, "Remedial
Action Report—Documentation for Operable
Unit Completion," June 1992, provides more
information on RA reports.
5.8 State Operation and Maintenance
This section provides a brief overview of O&M
activities. State-performed O&M activities are
necessary to protect the integrity of the remedy.
(Additional guidance that EPA Headquarters is
developing on O&M should be inserted into the
handbook when available.)
O&M commences on the date that EPA and the state
agree that the remedy is operational and functional.
The exception is active ground water restoration,
where EPA will operate a pump and treat system for
up to ten years, after which time the system is
declared operational and functional.
The SSC establishes the rules for transferring the
site and its facilities from EPA to state control. Once
the facility is transferred, it becomes state property.
The RPM must ensure that the O&M package
(drafted by the designer) has been completed by the
constructor and includes all record drawings and
manufacturer equipment manuals. The state and its
contractors should conduct a tour of the site and
obtain any special training necessary to carry out
O&M before the transfer.
The RPM should be aware that site access is often
overlooked as part of the transfer process. The RPM
and state should determine what, if any, state site
access is needed to implement O&M. These issues
must be worked out before the state assumes control.
O&M commences on the date in the RA report that
certifies the project is complete and the remedy is
operational and functional (with the exception of
ground water restoration).
The SSC is also the mechanism through which EPA
establishes the state's reporting requirements for
O&M, including the frequency for report
submission. The RPM must continue to review these
reports and ensure that they are submitted on
schedule after the state assumes responsibility for
the site.
84
-------
Chapter 5 • Federal-Lead Remedial Action
5.9 Site Closeout Process
The site closeout process consists of documenting
that all Superfund response action is complete and
the site can be deleted from the National Priorities
List (NPL). Site completion requirements provide a
definitive endpoint to Superfund cleanup activities
and satisfy the NCP requirements for site deletion.
Figure 5-8 illustrates the site closeout process,
highlighting the following three phases:
• Construction completion activities
• Site completion activities
• Site deletion activities
OERRIHSCD "Closeout Procedures for National
Priorities List Sites," (Draft), April 1995,
provides information on the site closeout process.
5.9.1 Construction Completion Activities
In 1991, the EPA Administrator established national
targets for the number of sites to be deleted from the
NPL through the year 2000. The concept of
construction completion, EPA's primary measure of
accomplishment toward that goal, was created to
simplify the system of site categorization and to
better communicate the successful completion of site
cleanup activities. Construction completion means
that physical construction of the remedy is complete
or that no substantial physical construction is
necessary to implement the remedy. It marks
completion of a phase in the Superfund remedial
process but does not affect the separate milestones
of site completion or deletion. Characteristics of sites
satisfying construction completion criteria include:
• Sites where all necessary physical
construction is complete, whether or not final
cleanup levels or other requirements have
been achieved
• Sites where EPA has determined that the
response action should be limited to measures
not involving construction (e.g., institutional
controls)
• Sites that qualify for deletion from the NPL
Preliminary Closeout Report (PCOR)
The PCOR forms the basis for the final closeout
report (FCOR) and focuses on site construction and
completion. The PCOR includes information on the
release of contaminants at the site, site conditions,
response action, steps remaining for site completion,
and a schedule for their completion. The PCOR
should contain the information shown in Figure 5-9.
The RPM often prepares the PCOR before the RA
report for the final operable unit (OU) because the
RA report can be submitted up to 60 days after
determining that the remedy is operational and
functional. The PCOR generally should be three to
five pages long. A draft of the PCOR must be sent to
EPA Headquarters for review. The purpose of the
review is to ensure national consistency in reporting
completions. Construction completion is considered
final when the Regional Division Director approves
and signs the PCOR.
WPL Sites Involving Construction
Completion of physical construction means that the
final remedy, as determined by the ROD, has been
constructed at the site and a prefinal inspection has
identified only minor unfinished activities on the
punch list. When determining eligibility for
construction completion, the RPM must anticipate
likely site progress as well as consider current site
status. A site with a significant number of
outstanding work elements to be completed should
not be categorized as achieving construction
completion. Achieving construction completion does
not imply final acceptance by EPA.
After a site achieves construction completion status,
some minor tasks will remain before a site can move
towards site completion status (i.e., completing
remaining punch list items, conducting the final
inspection, achieving operational and functional
status, and signing the final RA report). In most
cases, the RPM should prepare a PCOR to document
construction completion. However, sometimes the
need for a PCOR is eliminated because remedial
activities at the site have progressed to the point
where construction and site-completion
determinations occur simultaneously. In these cases,
the RPM can rely on the FCOR to satisfy the
documentation requirements for both events.
Additional information on preparing an FCOR is
presented later in this section.
85
-------
RD/RA Handbook
Site Completion and Deletion Process
Does RA
at final operable
unit require
construction?
Complete construction
at final operable unit
, i ! /
Previous EPA-lead
RA at site?
Conduct prefmal
inspection
Site
construction
criteria met?
Draft no (further)
action ROD, including
FCOR certification
Draft no-action ROD
including FCOR
certification
Obtain state concurrence
Prepare notice of intend to delete (NOID); obtain EPA HQ comments
and Regional Administrator approval; compile deletion docket material
Place deletion docket in Regional public docket and local repository
Publish NOID in Federal Register (FR); publish local NOID in paper(s) of
general distribution
1.
Provide 30-day public comment period; prepare responsiveness
man/, if necessary, and place in Regional docket and local reposi
summary.
repository
Determination of remedy as
operational and functional
Obtain EPA HQ and state
comments: obtain Region
and state peer comments
Incorporate comments
into FCOR
Prepare notice of deletion; publish in FR
Obtain Regional
Administrator's signature
and send
FCOR to EPA HQ
., M VMtt >*» V,
NOTE: Shaded portion identifies the steps associated with achieving construction
and site completion.
-------
Chapter 5 • Federal-Lead Remedial Action
Figure 5-9
Contents of the Preliminary Closeout Report
• Background of site conditions
• Remedial construction activities
• Discussion of QA/QC from cleanup activities
• Final inspection
• RA report and EPA approval
• EPA/state joint inspection (may coincide with the
final inspection)
• Operational and functional periods
• O&M period
• Discussion of five-year reviews
51-043-29
NPL Sites Not Involving Construction
At some NPL sites, EPA determines through the
remedial investigation/feasibility study (RI/FS) that
no remedial construction is necessary to protect
human health and the environment. If certain criteria
are met, construction and site completion can be
documented by completing one of the following:
• no-action ROD
• no-further-action ROD
• limited-action ROD requiring no physical
construction (i.e., a ROD with only
institutional controls)
A site with a ROD that does not require construction
is considered to be a construction and site completion
site when the Regional Administrator approves and
signs the ROD. If the site is a no-action site where
EPA has never implemented an RA, the RPM does
not prepare a PCOR (or FCOR) and should instead
place the following certification in the declaration
section of the no-action ROD:
"EPA has determined that its response at this site is
completed and no action/no further action is
necessary at this site. Therefore, the site now
qualifies for inclusion on the construction
completion list."
For sites with no-further-action RODs where EPA
has previously conducted RAs (triggering statutory
documentation requirements), the RPM may choose
either to prepare an FCOR or to document
compliance with statutory requirements in the RODs,
incorporating information normally included in the
FCOR and the certification mentioned above.
Sites with limited-action RODs not requiring
physical construction may achieve construction
completion when the Regional Administrator
approves and signs the ROD. The RPM does not
prepare a PCOR, but should instead place the
following certification in the declaration section of
the limited-action ROD:
"EPA has determined that its future response at this
site does not require physical construction.
Therefore, the site now qualifies for inclusion on
the construction completion list."
The RPM may not declare site completion at this
time since the site will include some future activities
such as implementing the institutional control
requirements. An FCOR will thus be required (see
section 5.9.2).
5.9.2 Site Completion Activities
Site completion marks the end of remedial activity
at a site. A site must meet all four criteria below to
be eligible for site completion status:
• Cleanup levels specified in all RODs are met
and cleanup actions and other measures
identified in all RODs are successfully
implemented.
• The constructed remedy is operational,
functional, and performing according to
engineering design specifications.
• The site protects human health and the
environment.
• The only remaining site activity to be
completed, if any, is O&M.
A site may meet the site completion criteria
following any one of a number of activities at a site.
For example, a site is eligible for site completion
following completion of the final OU of the RA, a
no-action ROD, or completion of a long-term
response action. In order to satisfy these
requirements, an FCOR generally will be prepared.
However, in certain cases a final OU limited-action
ROD for a site that does not require remedial
construction may be sufficient documentation to
satisfy site completion requirements (see section
5.9.1).
87
-------
RD/RA Handbook
TheFCOR
The FCOR is a detailed summary of site history,
emphasizing the RD and RA. In general, the RPM
prepares the FCOR but also may allow other parties
to prepare it The FCOR is usually 12 to 15 pages
long and should summarize the information
necessary to describe the activities performed and
the results achieved. Figure 5-10 lists the types of
information in an FCOR.
The information needed to prepare the FCOR should
be readily available from previous documentation
of site activities such as the RA report, RI/FS, and
ROD.
Since it is the final record of site remedial activities,
the FCOR must be complete and able to stand alone.
The FCOR provides the overall technical
justification for site completion, and so must clearly
demonstrate how the remedial activities conducted
satisfy site completion requirements. After the FCOR
is prepared, the RPM submits a draft to EPA for
review. The state also must be given the opportunity
to review the FCOR and provide comment. However,
the state does not formally offer a signed concurrence
on the report itself. Site completion is considered
final when the RegionalAdministrator approves and
signs the FCOR.
Figure 5-10
Chapter
I. Introduction
II. Summary of Site
Conditions
111. QA/QC of Cleanup
Activity
IV. Monitoring Results
V. Summary of O&M
Activity
VI. Protectiveness
VII. Five-Year Review
VIII. Bibliography
Final Closeout Report Summary
Contents
- General statement indicating successful execution of RA
- Site background
- Early actions performed
- RI/FS results
- ROD findings
- Design criteria
- Cleanup activities performed
- Community involvement activities performed
- QA/QC protocol followed
- Sampling and analysis protocol followed
- Results of on-site inspections
- Sufficient data available to demonstrate cleanup levels specified in the ROD or action
memoranda have been achieved and implemented and remedies are performing to design
specifications
- Brief documentation of monitoring required at no-action sites after the ROD is signed
(should also be included in the administrative record)
- Assurance that O&M plans are in place and sufficient to maintain integrity of remedy
- Assurance that all necessary institutional controls are in place
- Assurance that O&M activities specified for the site will be performed by the state or PRP(s)
- Assurance that the implemented remedy (or no-action decision) achieves the degree of
cleanup or protection specified in the ROD(s) for all pathways of exposure and that no further
Superfund response is needed to protect human health and the environment
- Assurance that all areas of concern described in the NPL listing have been adequately
addressed
- Statement explaining whether a five-year review is appropriate, and if so, the type of review
(statutory or policy) and review schedule
- Brief description of the results of any five-year reviews performed
- Assurance that the remedy is protective
- Complete citations of all relevant reports
88
-------
Chapter 5 • Federal-Lead Remedial Action
5.9.3 Site Deletion Activities
The site is eligible for deletion from the NPL when
all of the site completion activities discussed in
section 5.9.2 are complete. At this point, issues
surrounding placement of the site on the NPL have
been addressed, the threat to human health and the
environment has been addressed, and the Superfund
process has completed its course. Site deletion
requirements ensure that documentation and
verification of activities and decision-making at the
site are complete and the public has an opportunity
to comment before the site is formally deleted from
the NPL.
Section 300.425(e) of theAO* states that a site may
be deleted from or recategorized on the NPL when
no response/no further response is appropriate. The
RPM consults with the state in making this
determination. To delete a site from the NPL, EPA
must determine, and the state must concur, that one
of the following criteria has been met:
• Potentially responsible parties (PRPs) or other
persons have implemented all required
response actions.
• All appropriate Fund-financed response under
CERCLA has been implemented, and no
further response action by PRPs is
appropriate.
• The RI has shown that the release poses no
significant threat to public health or the
environment, and therefore, taking of remedial
measures is not appropriate.
Deletion of a site from the NPL does not preclude
eligibility for subsequent Fund-financed or PRP
actions. If future actions warrant, the NCP provides
that Fund-financed RAs may be performed at sites
deleted from the NPL. When there is a significant
release at a site deleted from the NPL, the site may
be restored to the NPL after rescoring the site on the
Hazard Ranking System. Additionally, enforcement
actions also may be taken, depending on liability
releases in the consent decree or administrative order.
The RPM should initiate the deletion process by
consulting with the state and requesting its
concurrence with EPA's intent to delete the site from
the NPL. No site may be deleted from the NPL
without state concurrence. Once state concurrence
is obtained, the RPM prepares a deletion docket
containing all pertinent information supporting the
deletion recommendation. The RPM works with the
Superfund community involvement staff to ensure
that complete copies of the docket are placed in the
appropriate Regional and local repositories.
Notice of Intent to Delete (NOID)
The NOID informs the public of EPA's intention to
delete a site from the NPL. The deletion docket must
be complete before the Region publishes the NOID
in the Federal Register (FR) or local newspaper(s).
Site-specific information needed to prepare the
NOID should be available from the FCOR. Figure
5-11 lists the contents of a NOID.
The public has the opportunity to comment on the
intended NPL deletion during the 30-day comment
period that follows publication of the NOID. The
RPM is responsible for preparing a responsiveness
summary for all local and national comments
received. The responsiveness summary should
present all comments received during the public
comment period, paired with detailed responses to
the comments. The RPM must include a copy of the
responsiveness summary, approved by the Regional
Administrator, in the Regional docket and local
repository.
Notice of Deletion
The RPM then publishes the notice of deletion in
the FR. This notice states that all appropriate Fund-
financed responses under CERCLA have been
implemented and that no further response is
appropriate. The notice of deletion includes an
effective date, a Regional contact, and supplemental
site information. All NPL rulemakings subsequent
to the publication of this notice will reflect this
deletion.
89
-------
RD/RA Handbook
Figure 5-11
Chapter
I. Summary
II. Dates
111. Addresses
IV. Regional Contact
Information
V. Supplementary
Information
Contents of the Notice of Intent to Delete
Contents
Announcement of intent to delete
Dates of a 30-day period for submission of public comments
Name, address, and phone number of a Regional contact to whom comments should be sent;
address of Regional docket and local repository
Name, address, and phone number of a Regional contact for further information or questions
Information: identification of site(s) to be deleted and a summary of information in the NOID
NPL Deletion Criteria: List of the applicable NCP criteria and statement indicating that EPA
retains the ability to use Superfund authority at a deleted site if future conditions warrant such
action (40 CFR §300.425(e)(3))
Deletion Procedures: brief description of procedures followed to delete sites from the NPL
Bases for Intended Site Deletion(s): brief descriptions of the following items:
- Site history (location, former use, type of contaminants, FR citations of proposed and final
NPL listing, and site conditions resulting in listing)
- All response actions taken, including scope of Rl (if applicable), general results, and
conclusions regarding future performance of these actions
- Specific cleanup standards and criteria and results of all confirmatory sampling
- O&M procedures and site monitoring program
•
- Reasons for needing five-year reviews, when appropriate, and plans for their execution, in
accordance with EPA's plans for their execution, in accordance with EPA's requirements for
protectiveness at the time of each future review
- Major community involvement activities
- How site meets deletion criteria
- Evidence of state concurrence with decision to delete site
51-043-31B
90
-------
AppendkA
Glossary
-------
-------
Appendix A • Glossary
Portions of this glossary have been reprinted from The Government Contracts Reference Book
(©1992) by Ralph C. Nash, Jr., and Steven L. Schooner, with permission from the Government
Contracts Program of George Washington University.
Access Agreements
Alternative Remedial
Contracting Strategy
Applicable or Relevant and
Appropriate Requirements
As-Builts
Under CERCLA Section 104(e), EPA may obtain access to a
property to implement a remedial action. EPA obtains
access through access agreements which must specify the
work to be performed and how the property will be restored
upon completion. Access agreements do not extend beyond
the owner that signs the agreement and are not necessarily
tied to the property deed.
EPA's approach to obtaining project management and
technical services to support remedial response activities at
National Priorities List sites. ARCS contracts are designed
to optimize quality, timeliness, and cost efficiency by: (1)
promoting continuity in site project management and
execution from remedial planning through construction; (2)
decentralizing contract management responsibilities by
placing authority and responsibility for management deci-
sions within Regional offices; and (3) implementing perfor-
mance incentives to the maximum extent possible by
awarding multiple contracts in each Region or zone and
using triennial ratings of contractor performance to deter-
mine the amount of work assigned to each contractor.
Federal, state, or local laws that apply to Superfund activi-
ties at NPL sites. Both emergency and long-term actions must
comply with these laws or provide sound reasons for allow-
ing a waiver. Applicable or relevant and appropriate require-
ments must be identified for each site relative to the charac-
teristics of the site, the substances found at the site, or the
cleanup alternatives being considered for the site.
See Record Drawings.
Baseline Schedule
A rudimentary schedule that is established early as a frame-
wo'rk for the entire RD/RA process. Baseline schedule
information is entered into CERCLIS and updated as the
RD/RA process progresses.
A-1
-------
RD/RA Handbook
Basis of Design Report
Biddability Review
Best and Final Offer
Bid Bond
Bidder
Bulk Funding
Bulk-Funding Categories
The basis of design report is a detailed description of the
analyses conducted to select the RD. It is submitted during
the preliminary RD phase and is modified if necessary as the
design progresses. The basis of design report may contain a
summary and justification of design assumptions, the RA
contracting strategy, permits plan, easement and access require-
ments, and preliminary piping and instrumentation diagrams.
The USAGE term for the report is the design analysis report.
!
Biddability is generally defined as the degree to which the
design documents can be understood, bid on (or offered),
administered, and enforced. The purpose of the biddability
review is to ensure that the construction package is free of
significant design errors, omissions, and ambiguities so that
prospective bidders can respond in a reasonable manner at a
reasonable cost.
i
An offer submitted to the government in a competitive
negotiated procurement after written or oral discussions
have been conducted. The CO issues a request for BAFOs
to all offerers within the competitive range. Following
evaluation of the BAFOs, the CO selects the offer most
advantageous to the government, considering price and other
factors included in the solicitation. (The Government Con-
tracts Reference Book)
A bond used frequently in public construction projects to
guarantee a bid. A bid bond assumes that the bidder will not
withdraw a bid within the period specified for acceptance
and will execute a written contract and furnish required
bonds within the time specified in the bid. (The Government
Contracts Reference Book)
\
One who submits a bid. While this term technically refers
only to an offerer on a sealed bid procurement, it is fre-
quently used to refer to any offerer on a government pro-
curement—whether sealed bid, competitive negotiation, or
otherwise. (The Government Contracts Reference Book)
A system for COs to receive clearance from a fiscal and
accounting officer to obligate funds on purchase documents
against a specified lump sum of funds reserved for the
purpose for a specific period of time. FAR 13.101. (The
Government Contracts Reference Book)
Four bulk-funding categories are used hi RACs: (1) other
response/program support; (2) site characterization; (3)
removal; and (4) enforcement. Money is obligated separately
to these bulk-funding categories.
A-2
-------
Appendix A • Glossary
E_
Changes Clause
Change Order
Change Order Management
Strategy
Claims Management Strategy
Closeout
Commerce Business Daily
A mandatory clause that allows the government to change
contract terms unilaterally in certain situations. Under the
changes clause, work described in the contract may be
changed to adjust to actual conditions at the site.
A written order from the CO directing the contractor to
make a change without the contractor's consent, as autho-
rized under the contract's clause. FAR 43.101. Contractors
must continue performance of the contract as changed
except that in cost-reimbursement or incremental funded
contracts the contractor is not obligated to continue perfor-
mance or incur costs beyond the established funding limits.
FAR 43.201 and 52.243-1 through -6. (The Government
Contracts Reference Book)
The internal procedures that the contractor uses to manage
change orders. The strategy identifies key personnel, lines
of authority, process for developing estimates, and negotia-
tion of adjustments to the schedule and budget. The internal
procedures of different contractors may vary, but each
system should interface appropriately with EPA's change
orders procedures that are used to access the change order
reserve funds for the work assignment.
The procedures used to process contractor claims. Because
there usually is no privity of contract between EPA and the
constructor, the constructor usually does not pursue a claim
with EPA, unless the prime contractor allows the constructor
to do so in the name of the prime contractor.
For government contracts, the process of settling all out-
standing contractual issues, ensuring that each party has met
all of its obligations, and documenting the contract file
accordingly. The primary objectives of contract closeout
are: (1) to identify and resolve any outstanding obligations
or pending liabilities on the part of either the government or
the contractor; and (2) to ensure that contract-related deci-
sions and actions have been properly documented. (The
Government Contracts Reference Book)
A daily publication of the Department of Commerce that
lists U.S. government solicitations, contract awards, subcon-
tracting leads, sales of surplus property, and foreign business
opportunities.
A-3
-------
RD/RA Handbook
Communications Matrix
Community Relations
Consent Decree
Contracting Party
Constructability Review
Construction Completion
Construction Manager
A method the RPM can use to structure the communications
strategy. The matrix identifies key team members and
documents how information will be distributed among the
members.
I
Efforts to establish two-way communication between the
public and EPA to create a better understanding of EPA
programs and related actions. These efforts, made early and
throughout Agency actions, ensure public input from af-
fected communities about issues concerning them. Specific
community relations activities are required for Superfund
remedial actions.
A legal document, approved by a judge, that formalizes an
agreement reached between litigants. In Superfund cases,
consent decrees establish the terms by which PRPs will
conduct all or part of a cleanup action of a Superfund site, cease
or correct actions or processes that are polluting the environ-
ment, or otherwise comply with regulations where PRP
failure to comply caused EPA to initiate regulatory enforce-
ment actions.
The party that advertises, awards, and manages a contract.
Depending on the circumstances, EPA, an ARCS/RAC
contractor, or USAGE may be the contracting party.
A constructability review is performed to enhance the
"buildability" of the design. It allows for the evaluation of
the design for accuracy and completeness. In addition the
review provides an opportunity to eliminate impractical and
inefficient remedial action requirements as well as deficien-
cies hi contract documents.
The completion of all physical construction of the
remedy(ies) or the emplacement of the substantial physical
construction necessary to implement the selected remedy.
This is typically documented in a preliminary closeout report
after a prefinal inspection is performed and only minor
punch list items remain or when only nonconstruction
aspects of the remedy, such as institutional controls, need to
be implemented (see OSWER Directive 9320.2-3C and 58
Federal Register 12142).
I
I
Representative of the contracting party assigned to the site to
administer and oversee the construction contract. The con-
struction manager performs the following roles: mediates
conflicts at the site, reviews and evaluates schedule deviations,
reviews and approves invoices, and administers the construc-
tion contract. The RPM communicates directly with the
construction manager (see resident engineer).
A-4
-------
Appendix A • Glossary
Construction Superintendent
Constructor
Contract Modification
Cooperative Agreement
Cost-Reimbursement Contracts
Critical Path Method
EL
The official representative of the RA constructor. For a
remedial action, the construction superintendent manages
the equipment and materials, oversees the labor, coordinates
the subcontracting work, controls health and safety at the
site, and responds to communications from the contracting
party.
A contractor, usually a subcontractor, that performs the
construction work in a remedial action.
A written change in the terms of a contract. FAR 43.101. A
unilateral or bilateral written change in the specifications,
delivery point, rate of delivery, contract period, price,
quantity, or other provision of an existing contract in accor-
dance with the contract clause. Examples include change
orders, notices of termination, supplemental agreements, and
exercises of contract options. (The Government Contracts
Reference Book)
A legal instrument used to transfer money, property, or
services to a state or local government or to another recipient
in order to accomplish a public purpose where substantial
involvement is expected between the government and the
recipient. 31 United States Code 6305. A cooperative
agreement is not subject to the FAR. (The Government
Contracts Reference Book)
Cost-reimbursement contracts provide for payment to the
contractor of all allocable, eligible, and reasonable costs
expended by the contractor in contract performance. In
addition to the costs, most cost-reimbursement contracts
provide for the payment of a fee (profit) to the contractor.
A scheduling technique used by contractors to plan, coordi-
nate, and control work activities to complete contract work
as quickly and economically as possible. The critical path
represents the longest chain of interrelated activities in the
project schedule diagram. A delay in completing an item on
this critical path usually delays the entire project. (The
Government Contracts Reference Book)
Data Quality Objectives
DQOs are used to formulate sampling plans for the RD/RA
field data collection effort. DQOs are qualitative and
quantitative statements used to ensure that data of known
and appropriate quality is obtained during data gathering
activities. DQOs for RD and RA are detailed in the quality
assurance project plan for each activity and will vary de-
pending on the intended use of the data.
A-5
-------
RD/RA Handbook
Davis-Bacon Act
Demobilization
Design Analysis Report
Design Criteria Analysis
Design Drawings
Detailed Design Specifications
The Davis-Bacon Act, 40 United States Code 276a, requires
payment of not less than prevailing wage rates to workers on
federal or federally-funded construction projects costing
more than $2,000. FAR 22.403-1. (The Government Con-
tracts Reference Book)
i
Period of time at the end of a contract or remedial action
when most closeout actions are completed, final invoices are
submitted, and government property is returned.
See basis of design report.
The analysis used to describe the technical parameters on
which the design will be based. The analysis must be
submitted and approved prior to expending additional design
effort to confirm that the contractor is correctly interpreting
and translating ROD performance standards, applicable or
relevant and appropriate requirements, and engineering
standards and codes into site-specific engineering parameters.
Drawings showing the original design plan for a remedial
activity.
i
Specifications that set forth precise measurements, tolerances,
materials, in-process and finished-product tests, quality
control measures, inspection requirements, and other spe-
cific information. Design specifications increase the
government's liability for claims that arise during contract
performance regarding design defects since the government
generally assumes responsibility for the correctness and
adequacy of design specifications. Consequently, FAR
10.002 requires that functional and performance specifica-
tions be used instead of design specifications whenever
possible.
Emergency Response Plan
Expenditure Limit
A required element in the overall site-specific health and
safety plan (HASP) that must be in place before commence-
ment of on-site operations. The emergency response plan
includes arrangements for local fire departments, hospitals,
and police departments to provide coordinated and inte-
grated services throughout the project in the event of an
emergency.
The amount of dollars available to the contractor to expend
in performance of a particular work assignment. The
contract prohibits the contractor from exceeding the expen-
A-6
-------
Appendix A • Glossary
diture limit (EL) without CO approval. The government sets
the EL when a work assignment is issued and adjusts it as
needed during the course of the work assignment to manage
the phasing and execution of the work.
Fast-Track Construction
Feasibility Study
Federal Tort Claims Act
Field Sampling Plan
Fixed-Price Contract
Fundamental Changes
Method of construction contracting under which the con-
structor begins building as soon as the foundation plans are
ready and a foundation permit has been issued, regardless of
whether the designer has finished designing the project.
Throughout work performance, the designer must keep
ahead of the constructor's progress in order to supply the
necessary plans and drawings before each stage of the construc-
tion is reached. (The Government Contracts Reference Book)
The analysis of the potential cleanup alternatives for a site. The
feasibility study usually starts as soon as the remedial investi-
gation is underway.
An act, 28 United States Code 1346(b), 2401-2402, 2671-
2672, 2674-2680, permitting persons injured by negligent
conduct of the government to sue for damages in U.S.
district courts. Before filing suit in court, the injured party
must file for administrative relief with the agency involved.
(The Government Contracts Reference Book)
The field sampling plan provides guidance for all fieldwork
by defining in detail the sampling and data collection
methods to be used during the project. The FSP includes
sampling objectives, locations and frequency, equipment and
procedures, and sample handling and analysis and contains
an analysis of specific data gaps and ways in which the
sampling is designed to fill in the data gaps. The field
sampling plan and the quality assurance project plan are
routinely submitted as a single document, referred to as the
sampling and analysis plan.
A type of contract providing for a firm pricing arrangement
established by the parties at the time of contracting. The
contract amount usually is adjusted only when work must be
added or deleted from the contract. Superfund RA construc-
tion contracts may be issued as fixed-price contracts.
A fundamental change is a major change in the selected
remedy that affects the ROD. When a fundamental change
is made, a ROD amendment must be prepared in accordance
with the procedures specified in the National Contingency
Plan, 40 CFR section 300.435(c)(2).
A-7
-------
RD/RA Handbook
Gantt Chart Method
The Gantt chart is a bar chart that represents work activities
through a time-scaled bar line. The time scale is weekly or
monthly for as many years as the RD/RA project is sched-
uled to last.
Hazard Ranking System
Health and Safety Plan
HRS is the principal screening tool used by EPA to evaluate
relative risks to public health and the environment associated
with abandoned or uncontrolled hazardous waste sites. HRS
calculates a score based on the potential of hazardous
substances spreading from the site through the air, surface
water, or ground water and on other factors such as nearby
population. The HRS score is the primary factor used to
decide if the site should be on the
A plan outlining the implementation of all federal, state, and
local requirements regarding human health and safety. Each
remedial contractor must submit a corporate health and
safety plan (HASP) and any site-specific HASP required by
an individual work assignment issued under the contract.
Indefinite-Delivery Contract
Indefinite Quantity
Independent Government Cost
Estimate
II
A contract in which the time of delivery is unspecified in the
original contract but established by the contracting officer
during performance, (see FAR Subpart 16.5 ). (The Govern-
ment Contracts Reference Book)
A type of contract used when it is impossible to determine in
advance the precise quantities of supplies or services that
will be needed during a contract performance period. The
method of ordering work must be stated in the contract as
well as the minimum/maximum orders allowable during
each period.
A detailed estimate of the cost to the government for ser-
vices or supplies to be acquired from a contractor. Cost
estimates are performed by the government and not by
contractors. (EPA Independent Government Cost Estimating
Guide)
A-8
-------
Appendix A'Glossary
Interagency Agreement
Intermediate Design Phase
A written agreement between federal agencies to provide
support, services, or management setting forth the roles and
responsibilities of each agency for performing and oversee-
ing the activities or other services. Interagency agreements
are commonly used to procure services of other federal
agencies.
The intermediate design phase commences at the completion
of the preliminary design phase and ends with the comple-
tion of approximately 60 percent of the design effort.
Level-of-Effort
Local Emergency Planning
Committee
A quantification of work in terms of the amount of effort
expended, usually measured in labor-hours or labor-years.
(The Government Contracts Reference Book)
Superfund Amendments and Reauthorization Act, Title III,
also known as the Emergency Planning and Community
Right-To-Know Act, requires local governments to create a
local emergency planning committee for Superfund sites.
The committee should have in place a local contingency
plan for coordinating police, fire, utility, and medical
services in the event of an emergency.
Miller Act
Minor Changes
EL
The Miller Act requires the execution of separate perfor-
mance and payment bonds as a prerequisite to award of
construction contracts exceeding $25,000. FAR 28.102.
(The Government Contracts Reference Book)
Minor changes have little or no consequence on the overall
scope, performance, or cost of a remedial project, and do not
affect the selected remedy outlined in the ROD. Minor
changes are recorded in the post-decision document file.
Negotiated Procurement
A procurement in which the basis of the proposal evaluation
is a combination of technical merit and cost, rather than just
cost.
A-9
-------
RD/RA Handbook
Non-Competitive (Sole-Source)
Procurement
Notice of Deletion
Notice of Intent to Delete
Notice to Proceed
A contract for the purchase of supplies or services that is
entered into, or proposed to be entered into, by an agency
after soliciting and negotiating with only one source. As the
least favored method of procuring an item or service, non-
competitive procurement may be employed only in limited
circumstances, outlined in FAR part 6.3.
j
A notice of deletion is a Federal Register notice that states
that all appropriate Fund-financed responses under CERCLA
have been implemented and that no further response is
appropriate. The notice also includes an effective date of the
deletion, a Regional contact, and supplemental site informa-
tion. All NPL rulemakings subsequent to the publication of
this notice will reflect the deletion.
A notice of intent to delete is a Federal Register notice
informing the public of EPA's intention to delete a site from
the NPL. The deletion docket must be complete before the -
Region publishes the notice in the Federal Register or local
newspaper(s). Site-specific information needed to prepare
the notice should be available from the site closeout report.
A notice to proceed initiates construction activity and the
date on the notice to proceed marks the formal beginning of
the construction project. The contracting party will issue a
notice to proceed sufficiently in advance of the required date
to provide the constructor adequate lead time.
Offer
Offerer
Operability Review
A response to a solicitation that, if accepted, would bind the
offerpr to perform the resultant contract. FAR 2.101. Re-
sponses to an invitation for bids, in sealed bidding, are offers
that are called bids or sealed bids. Responses to a request
for proposals, in negotiation, are offers that are called
proposals. An offer may also take the form of an unsolicited
proposal.
i
The party that makes an offer and looks for acceptance from
the offeree. In government contracting, the offerer is the
generic term for prospective contractors that submit bids,
proposals, or quotations.
|
The objective of this review is to determine whether the
particular system or remedial facility will function in an
optimal manner, as required by the design documents, and
whether it can be maintained for its intended use. The
operability review is a specialized review where only
operations and maintenance issues are examined.
A-10
-------
Appendix A • Glossary
Operation and Maintenance
EL
Operation and maintenance (O&M) activities are performed
to protect the integrity of the remedy for a site. The state
performs O&M after the site is transferred from the federal
government to the state upon state and federal agreement
that the remedy is operational and functional. An exception
to this is active ground water restoration where EPA operates
a pump-and-treat system for up to 10 years after the system
has been declared operational and functional.
Payment Bond
Performance Specifications
Performance Bond
Permits Plan
Phasing
A bond required by the Miller Act for all federal construc-
tion contracts exceeding $25,000, that covers payment for
labor and materials if a constructor is unable or refuses to
perform its construction contract. A payment bond assures
payments, as required by law, to all persons supplying labor
or materials in. the prosecution of work provided for in the
contract. (FAR 28.001)
Specifications that set forth operational characteristics for
the desired result. The specifications are used to determine
final product performance. When the contract contains
performance specifications, the contractor accepts general
responsibility for product design and engineering and for
achievement of the stated performance requirements.
A contract bond required by the Miller Act for all federal
construction contracts exceeding $25,000, that protects
against loss due to the inability or refusal of a contractor to
perform its construction contract. A performance bond
secures performance and fulfillment of the contractor's
obligation under the contract. (FAR 28.001)
A plan listing the permits required and the strategy for
complying with permit requirements. The plan addresses
substantive requirements and building and safety require-
ments for an on-site RA as well as off-site permits. The plan
should present a schedule for obtaining all required permits
before the RA begins.
The division of a project into smaller work elements that can
be implemented on different schedules, resulting in accelera-
tion of the RD and RA. Phasing allows certain elements of a
project to be started ahead of others to reduce the hazards
present at the site or to complete simple prerequisite work
elements ahead of more complex and hazardous work ele-
ments. All elements are addressed at the same time, but each
individual element has its own schedule and moves at its
own rate through the process.
A-11
-------
RD/RA Handbook
Potentially Responsible Party
Prefinal and Final Inspections
Prefinal Construction Conference
Prequalified Contracts
Procurement Process
Progress Payment
Progress Report
Project Management Plan
Entity that may be liable for the release of hazardous sub-
stances at a site. The government conducts a potentially
responsible party search as an early step in its enforcement
process, seeking to identify the generators, transporters,
owners, or operators of a site.
The prefinal and final inspections are standard construction
practices for closing out a contract. They are generally
conducted by the contracting party and constructor. These
inspections are often confused with the EPA/state joint
inspection requirement under the National Contingency
Plan. The contracting party and the constructor may agree to
invite both the RPM and the state to one of these inspec-
tions, however, to avoid the need to schedule a separate
EPA/state joint inspection.
|
A prefinal conference, scheduled by the contracting party,
which should occur just before the construction work is
completed and is attended by EPA, the state, and the construc-
tor. The objective of the conference is to discuss procedures
and requirements for project completion and closeout.
I
A contracting method that expedites the RD/RA process by
eliminating the solicitation and audit requirements for site-
specific contracts. Prequalified contracts require approxi-
mately 30 to 60 days to initiate activities and delays due to
bid protests or bonding difficulties are eliminated. However,
this type of contract may reduce competition and may
increase the cost of the project. EPA is the contracting party
for prequalified contracts.
The process by which the contracting party solicits bids (or
offers), evaluates the bids, selects a contractor, and awards
the contract. The nature of the procurement process depends
on whether sealed bidding, negotiated procurement, two-step
sealed bidding, or non-competitive (sole-source) procure-
ment is used.
I
A payment made as costs are incurred by the contractor
under a contract or on the basis of percentage of completion
or achievement of a particular stage of work.
I
Detailed progress reports from the contractor are required on
a monthly basis throughout the duration of the project. The
progress reports are used by the RPM to monitor the contractor
activities and are usually submitted with the monthly invoices.
A strategy developed by the RPM for successfully delivering
a RD/RA project on time and within budget. The plan
documents the project management goals and operational
procedures and is updated periodically.
A-12
-------
Appendix A • Glossary
Prompt Payment Act
Punch List
Passed in 1982, 31 United States Code 3901 et seq., requires
solicitations and contracts to specify payment procedures,
payment due dates, and interest penalties for late invoice
payments. The act is implemented by FAR Subpart 32.9 and
OMB Circular No. A-125, Prompt Payment, August 19,
1982. The government must make invoice payments and
contract financing payments as close as possible to, but not
later than, the due dates specified in the contract (generally
30 days after receipt of a proper invoice, 14 days for con-
struction contract progress payments). Agencies pay an
interest penalty for late invoice payments or improperly
taken discounts for prompt payment.
A list of work that must be corrected or completed to satisfy
contract requirements for a construction project.
Quality Assurance
Quality Assurance Project Plan
Quality Control
E_
Real Estate Planning Report
Tasks performed to monitor or improve an organization's
quality and quantity of output. QA may include a planned,
systematic pattern of actions taken to provide adequate confi-
dence that sufficient technical requirements are established,
that products and services conforms to those requirements,
and that satisfactory performance is achieved. FAR 246.101.
The QAPP describes the policy, organization, functional
activities, and quality assurance/quality control protocols
necessary to achieve data quality objectives.
Tasks performed by individuals inside an organization to
improve the quality of the organization's output. Govern-
ment contracts may call for the contractor to provide a QC
system that ensures that the work meets contract require-
ments. QC generally includes: (1) setting cost, performance,
safety, and reliability standards; (2) comparing the offered
product or service with house standards; (3) taking correc-
tive action when necessary; and (4) planning for improve-
ments. (The Government Contracts Reference Book)
A report describing property needs for the RD/RA project,
based on information received from the designer. The report
includes analysis of costs should EPA choose to acquire a
property or an interest in property. USAGE automatically
develops a real estate planning report for all remedial
designs it performs or manages.
A-13
-------
RD/RA Handbook
Record of Decision
Record Drawings
Remedial Action
Remedial Action Constructor
Remedial Design
Remedial Investigation
Remedial Project Manager
Request for Proposal
Resident Engineer
Response Action Contracting
Strategy
A public document that explains which cleanup
alternative(s) will be used to clean up sites listed on the
NPL. It is based on information generated during the RI/FS
and consideration of public comments and community
concerns.
i
Design drawings also called "as-builts," which show how
the original design has been modified by actual changes
during construction.
The actual construction or implementation phase of a
Superfund site cleanup following RD.
|
i
The contractor that performs RA construction.
i
A phase of site cleanup where engineers design the technical
specifications for cleanup remedies and technologies, as
specified in the ROD.
i
An in-depth study designed to gather the data necessary to
determine the nature and extent of contamination at a
Superfund site, establish the criteria for cleaning up the site,
identify the preliminary alternatives for cleanup actions, and
support the technical and cost analyses of the alternatives.
The remedial investigation is usually done with the feasibil-
ity study.
The EPA official responsible for overseeing cleanup actions
at a site. (NPL Glossary)
A solicitation for proposal containing performance require-
ments, a description of the evaluation criteria, and the basis
of award. Requests for proposals are advertised in the
Commerce Business Daily.
,\
A design firm employee that serves as the designer's repre-
sentative during construction, installation, and start-up
phases of activity. The resident engineer, as a continuous
presence at the site, acts directly on behalf of the designer
and reports to the designer's contracting party. When
USAGE is managing the RA, resident engineer is also the
term used for staff that perform construction manager
functions (see construction manager).
i
EPA's strategy designed to balance program needs and
strategy objectives. The strategy includes: (1) an integrated
"one program" approach to enforcement and site cleanup;
and (2) greater flexibility, improved oversight, and cost
management through decentralization of contract manage-
ment responsibilities to the Regions.
A-14
-------
Appendix A • Glossary
Scope of Work
Sealed Bidding
Service Contract
Significant Changes
Site Closeout Process
Site Management Plan
The scope of work is based on the ROD and delineates the
work to be performed at the site.
A procurement in which the contract is awarded to the
lowest responsive and responsible bidder. The work is
described in detail so the bidders understand fully what is
required of them for the price of the bids since the bids
become the basis for a fixed-price contract. Sealed bidding
typically results in lower costs for the government and a
shorter bid review time period since no technical evaluations
are necessary. (The Government Contracts Reference Book)
A contract that directly engages a contractor's tune and
effort to perform an identifiable task rather than to furnish an
end product. FAR 37.101. A service contract may be either
a personal services contract or a nonpersonal services
contract and can cover services performed by either profes-
sional or nonprofessional personnel on either an individual
or an organizational basis. Service contracts include those
for: (1) maintenance, overhaul, repair, servicing, rehabilita-
tion, salvage, modernization, or modification of supplies,
systems, or equipment; (2) routine recurring maintenance of
real property; (3) housekeeping and base services; (4)
advisory and assistance services; (5) operation of govern-
ment-owned equipment, facilities, and systems; (6) commu-
nications services; (7) architect-engineer services; and (8)
transportation and related services. (The Government
Contracts Reference Book)
Significant changes have a significant effect on the scope,
performance, or cost of the remedy contained in the ROD
and are documented in an "Explanation of Significant
Differences", as required by CERCLA Section 117 (c).
Depending on the nature of the change, a public comment
period may be warranted.
The site closeout process consists of the activities that are
required to document that all Superfund response action is
complete and the site can be deleted from the NPL. Site
completion requirements were developed to provide a
definable endpoint to Superfund cleanup activities as well as
to satisfy the National Contingency Plan requirements for
site deletion.
The site management plan describes how access issues,
security, contingency procedures for accidents, management
responsibilities, and waste disposal are to be handled.
A-15
-------
RD/RA Handbook
Site Security Plan
Source Selection Award
State Memorandum of Agreement
Superfund State Contract
Statement of Work
Submittal
Submittal Procedures
Submittal Register
The site security plan is required before mobilization at the
site to prevent the public from having access to potential site
safety hazards and to prevent the theft of or damage to the
facilities.
i
A solicitation process in which a contract is awarded to the
proposal with greatest value score regarding cost and
technical merit.
The state memorandum of agreement, as described in 40
CFR Part 300.505 of the NCP, details state and EPA roles
and responsibilities for response actions.
The Superfund state contract is signed by EPA and a state
and contains any terms that the parties agree to and the terms
for implementing the CERCLA Section 104 requirement that
the state 1) provide a cost-share in the cost of the remedial
action, and 2) conduct all operation and maintenance activi-
ties at the site.
Describes the actual work to be done by the contractor by
means of specifications or other minimum requirements,
quantities, performance dates, time and place of perfor-
mance of services, and quality requirements. The SOW is
the basis for a contractor's response to a solicitation, and
provides a baseline against which progress and subsequent
contractual changes are measured during contract perfor-
mance. (The Government Contracts Reference Book)
}
Also referred to as a deliverable, a submittal is a product or
service that is prepared for and submitted to the government
under terms of a contract, delivery order, or work assignment.
Formal procedures for the transmission of submittals and
shop drawings from the constructor to the contracting party
for review and approval.
|
A register that may be used by the RPlvI as a tool when
tracking submittals.
D
Technical Direction
Technical direction is guidance given by the government to the
contractor on how to perform task(s) within the scope of work
of the contract or work assignment. Technical direction is
usually issued to an EPA contractor to assist the contractor in
accomplishing the work assignment statement of work or to
comment on and approve deliverables.
A-16
-------
Appendix A • Glossary
Technical Review Team
Time-and-Materials Contract
Total Quality Management
Treatability Study
Two-Step Sealed Bidding
EL
A team whose primary responsibility is to assist the RPM in
reviewing technical deliverables. The complex nature of a
typical RD/RA requires in-depth knowledge of a variety of
engineering and other scientific disciplines, so the RPM
assembles and coordinates a team of individuals with the
appropriate backgrounds. Members of the technical review
team may be from EPA, other federal agencies, state agen-
cies, local government agencies, or EPA contractors.
A cost-reimbursement contract used when it is not possible
to estimate accurately the scope (extent or duration) of work
required at the time of contract preparation. The contract
calls for provision of direct labor hours at an hourly rate and
the provision of materials at a designated cost.
A management philosophy intended to provide the founda-
tion for a continuously improving organization by encourag-
ing employees to focus their attention on means of improving
efficiency and effectiveness.
Testing a treatment method on contaminated ground water,
soil, etc., to determine its effectiveness.
A procurement method that combines competitive proce-
dures to obtain the benefits of sealed bidding when adequate
specifications are not available. FAR 14.501. Technical
proposals are submitted in the first step, and offerers that
submitted acceptable proposals submit sealed bids in the
second step. This method is especially useful in the request
for submission, evaluation, and discussion of technical
proposals. No pricing is involved in this bidding technique.
(The Government Contracts Reference Book)
Unilateral Administrative Order
Unit Price List
A legally binding document issued by EPA, directing PRPs
to perform site cleanups or studies (EPA generally does not
issue unilateral orders for site studies). This type of order is
not signed by the PRPs and does not require approval by a
judge.
The unit price and lump sum pricing lists for each bid item.
A-17
-------
RDIRA Handbook
Value Engineering
Value Engineering Change Proposal
Value Engineering Screen
A formal technique by which contractors may (1) voluntarily
suggest methods for performing an RD/RA more economi-
cally and may share in any resulting savings, or (2) be
required to establish a program or identify and submit to the
government methods for performing more economically.
EAR 48.101(a). The object of value engineering is to reduce
costs in the design or construction of a project without
compromising its quality or functionality. (The Government
Contracts Reference Book)
|
A constructor's proposal to make changes to the RA con-
struction that, if implemented, will save money without
compromising quality or performance. Constructors de-
velop and submit value engineering change proposals
(VECPs) on a voluntary basis. As an incentive to submit
VECPs, the constructor shares with the government any cost
savings realized from accepted VECPs.
j .
An evaluation of cost and function relationships in an RD/
RA project, concentrating on high cost areas. The product of
the screening is a recommendation for or against a full-scale
value engineering study. If approved, the screening should
be performed as soon as practicable during the preliminary
design phase, and the results should be submitted to EPA.
W,X,Y,Z
Work Assignment
Work Assignment Form
Work Assignment Package
A written order for work issued by the government to a
contractor under a work assignment (WA)-type contract. A
WA designates the government WAM and generally con-
tains: background for the requirement, scope of work, time
schedule, deliverables, period of performance, reference to
the applicable section of the contract statement of work,
level-of-effort, documentation requirements, and any
restriction on travel, printing, or other activity.
A one-page form used to initiate and track a work assign-
ment.
To initiate a new work assignment (WA), the WAM must
prepare a WA package, which includes the following items:
(1) WAform, (2) statement of work, (3) independent govern-
ment cost estimate, (4) WAM designation form 1900-65, (5)
procurement request (EPA Form 1900-8), and (6) contractor
selection notice.
A-18
-------
Appendix A • Glossary
Work Breakdown Structure A display of a contractual statement of work or an organiza-
tional chart depicting the necessary hardware, software, and
services required in contract performance. The structure
divides the work required under a contract into logical
segments to help track progress and performance cost. (The
Government Contracts Reference Book)
Work Plan The work plan is the contractor's response to a government-
issued work assignment (WA). The work plan describes the
project goals, technical approach to be used by the contractor,
tasks and deliverables, delivery schedule, and proposed
personnel (including resumes), equipment, subcontracting,
and other special requkements of the WA. It also includes a
detailed cost estimate outlining in detail what the contractor
believes will be the WA performance costs.
A-19
-------
-------
Appendk B
Transmitted Forms
-------
-------
EPA Contractor Transmittal Register*
Project Title and Location
Subtask No.
Deliverable
No. of Copies
Due Date
Contract No.
Transmittal No.
Date Comments
Sent To
Contractor
Work Assignment No.
EPA
Acceptance
Date
Remarks
3
a.
00
*For use by the RPM/WAM to record and track deliverables submitted by the contractor.
51-043-32B0)
-------
Transmittal of Documents for Acceptance by EPA*
To:
Subtask No.
Date:
From:
Deliverable
No. of Copies
Transmittal No.
Q New Transmittal
Q Resubmittal of
Transmittal No
Remarks
Acceptance Action
Documents Found Acceptable (list by subtask no.)
Name/Title/Signature of Reviewer
Date
*For use by the contractor when submitting a deliverable to the RPM/WAM.
51-04W2B(2)
-------
Appendk C
Design Review Checklists
-------
-------
Appendix C • Design Review Checklists
Biddability Review __
Definition
Biddability is generally defined as the degree to which the design documents can be understood, bid on,
administered, and enforced. The purpose of the biddability review is to ensure that the construction package
is free of significant design errors, omissions, and ambiguities so that prospective bidders can respond in a
reasonable manner and at a reasonable cost. In this review, the actual design is analyzed for consistency
with the bid documents. The bid and design documents should be clear, comprehensive and manageable.
The review also should assure that the bid documents provide a firm basis against which any claims may be
evaluated.
Review Team
The contracting party is responsible for having the appropriate design reviews conducted. In-house reviews
may be conducted if the requisite expertise is available or reviews may be sent to another agency or contrac-
tor. The designer should be awarded the review task if independent and objective reviews can be conducted.
The biddability review focuses on the bid documents that accompany the drawings and specifications. The
review is conducted by a review team of members fully experienced in contracting procedures and procure-
ment regulations and policies. It is unnecessary to solicit review input from each of the engineering disci-
plines having design responsibility on the project
Timing of the Review
The initial screening may occur at the completion of the intermediate design, but contract documents gen-
erally are not prepared until later. An earlier review may hamper the designer by disrupting the design effort
and forcing premature contract package development. The detailed review should coincide with the prefinal
design submittal to the contracting party. The review, when combined with other types of reviews (oper-
ability, constructability, claims prevention, and environmental), should take an average of five to ten work-
ing days.
Scope of the Review
The drawings and specifications serve three basic functions in project construction. First, they describe the
proposed work so that bids can be compiled. Second, they establish the rules and guidelines for procuring
materials and performing the construction. Third, they act as contractual documents in case of litigation.
A review of drawings and specifications during a biddability review is not done to determine their technical
accuracy. Rather, this review focuses on the completeness and clarity of information. The drawings and
specifications should provide adequate information of existing site conditions to enable the constructor to
anticipate any problem areas. All data available to the designer should be available, at least by reference, to
prospective bidders. Availability of utilities, adequacy of space for work areas, and disposal of excess
material are all considerations that must be addressed in the drawings and specifications. Technical respon-
sibilities of the constructor and contracting party for quality control, and requirements for submittal and re-
view of deliverables must be clearly defined for each phase of work.
Unlike drawings, specifications typically include language from contract administration and non-technical
provisions such as those found in the form of General and Special Conditions. These specification sections
should be checked carefully, particularly regrading constructor submittal requirements, changed conditions,
progress payments, and schedules. A sample checklist of remedial action (RA) bid documents is included
C-1
-------
RD/RA Handbook
I
in this appendix as Attachment I. Contract development or legal counsel are the most qualified reviewers
for these portions of the reviews.
The proposed RA schedule should include milestone dates and logic ties, particularly when multiple con-
structors must interface with each other. Experienced engineers with construction backgrounds can aid hi
evaluating the feasibility of performing the work within reasonable time-frames, and can assist in develop-
ing more logical and more biddable schedules. ;
The bid forms themselves should be examined for items such as logical organization (e.g., all earthwork bid
items should be grouped together), proper units for bid item quantities, adequate definition of scope of each
bid item, and appropriateness of estimated quantities and adequacy of the bid period. The reviewers must
examine the contract documents from a constructor's viewpoint. The contract should fairly allocate risks
between the constructor and the contracting party, to minimize the contingency included in the bid amounts.
The designer's interpretation of geologic data and the conditions expected to be encountered during con-
struction should be provided in the specifications. Any interpretations made by the designer in assessing
data along with the significance and associated implications for construction must be included. The speci-
fications should also define those areas where uncertainties exist that may require changes during construc-
tion.
The use of "as directed" statements and disclaimers should be avoided whenever possible. "As directed"
provisions allow for work under the contract that cannot be fully specified until the work is under way.
Excessive use of these statements can infer greater unknowns and constructor risk than appropriate, result-
ing in higher bids.
1
General Overview
!
The purpose of the review is to check the final design for the following:
• Clarity and simplicity of the bid schedule
* Appropriateness of contract sequencing, relationship to other work, and contract performance
period
• Real and possible conflicts among the drawings, specifications, bid forms, including terms and
conditions
• Completeness and clarity of the bidding instructions
• Clear guidance for measurement and payment
* Established criteria for RA contract award
• Clear guidance for contract completion requirements, including penalties, rewards and incentives
• Clear guidance for change order administration
ii
• Clear guidance for disputes resolution
. i
• Appropriateness and consistency of material quantity units
i • • ' I
A checklist is attached to provide additional detail to assist in a biddability review.
C-2
-------
Appendix C • Design Review Checklists
Attachment I
Checklist of Remedial Action Bid Documents
Q Index of Bid Documents
Q Advertisement for Bids
Q Instructions to Bidders
Q Bid Form
O Addenda Acknowledgement
Q Bid Bond
Q Certificate of Surety
Q Acknowledgment of Principal Form
Q Non-Collusion Affidavit
Q Certification of Nondiscrimination in Employment
Q Certification of Nonsegregated Facilities
Q Authority to Execute Agreement
Q Form of Agreement
Q Performance Bond Form
Q Payment Bond Form
Q Certificate of Ability to Obtain Insurance
Q General Conditions
Q Supplemented General Conditions
Q Federal Requirement and Agreement Provisions
Q Davis-Bacon Wage Rate Determinations
Q General Agreement Requirements (Special Conditions)
Q Scope of Work
Q Control of Materials
Q Utility Coordination Requirements
Q Project Supervision Requirements
Q On-Site Inspection Procedures
Q Safety Requirements, Responsibilities
Q Emergency Procedures
Q Progress Schedule
Q Payment Procedures (Measurement, Payment)
Q Change Order Procedures
Q Correspondence Distribution
Q Submittal, Processing Procedures ;-
Q Technical Specifications
Q Drawings and Plans (certified by a Professional Engineer)
Q Supplemental Data (e.g. geologic data, hydrologic data)
51-04342
C-3
-------
RD/RA Handbook
^EPA Design Review Checklist
Project Title & Location:
Design Phase:
Q Preliminary
Q Intermediate
Q Pre-Final/Final
Document Reviewed
(Section/Paragraph)
Item No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Reviewer:
Name
Organization
Telephone Date
Component to be evaluated for completeness, clarity and
appropriateness (provide comments on separate sheet)
BIDDABILITY
Are specification divisions appropriate and per CSI format?
Are substitutions allowed as an "engineer (or owner) approved
equal" to allow flexibility during construction?
Have the appropriate material and equipment standards been
specified?
Does the review confirm that no sole source or brand name material
or equipment has been specified?
Are terminologies and notations consistent among drawings,
specifications, bid items?
Have appropriate construction techniques been specified?
Are cross references of drawings to specifications complete and
accurate?
Has a description of materials and/or facilities provided by owner
been included?
Has a description of items of work provided by each contractor for
multiple contracts been provided?
Have the quality control responsibilities of contractor and quality
assurance by owner been adequately addressed?
Have all submittal requirements (content, schedule) been identified,
and are they appropriate?
Has owner review period for each submittal been identified, and is
it reasonable?
Is the construction schedule feasible and clearly defined with
schedule interface points identified?
Have completion times for distinct phases been specified?
Are the drawings complete (i.e., sufficiently detailed, clearly define
the work)?
Are specifications complete?
Acceptability
Yes
No
N/A
C-4
-------
Appendix C * Design Review Checklists
Design Review
Project Title & Location:
Document Reviewed
(Section/Paragraph)
Item No.
17
18
19
20
21
22
23
24
25
26
27
28
29
Component to be evaluated for completeness, clarity and
appropriateness (provide comments on separate sheet)
Should supplemental data be referenced on drawings or
specifications? If so, has it been provided?
Have the cost/schedule monitoring requirements (i.e., progress
reports) by contractor been clearly identified?
If off-site disposal of material by the contractor is required, have the
contractor's responsibilities been clearly identified?
Has the division of work been clearly identified at contractor interfaces,
where more than one contractor will be working at the site?
Does the bid package include all of the appropriate bid documents
(see biddability review in this attachment)?
Is the structure of the bid form appropriate (i.e., are bid sections
coordinated, defined, unambiguous)?
Do all bid items have appropriate units for measure and payment
and are they consistent with the specifications?
Is the scope of work for each bid item clearly defined?
Has the accuracy of bid quantities for the work defined been verified?
Are the bid expiration periods stated and reasonable?
Have the criteria to be used as the basis for awarding the contract
been clearly specified?
Has a review to ensure all the appropriate standard construction
contract clauses been conducted?
Do the contract documents specify when ownership of contractor
built or installed facilities transfers to the government or to the state?
Acceptability
Yes
No
N/A
51-043-41A(2)
C-5
-------
RD/RA Handbook
Operability Review
Definition
The objective of this review is to determine whether the particular system or remedial facility will function
in an optimal manner, as required by the design documents, and whether it can be maintained for its in-
tended use. The operability review is a specialized review where only operations and maintenance issues
are examined.
Review Team
The contracting party is responsible for having the operability review conducted. This review may be
conducted by the contracting party, using in-house resources, an outside agency, or the designer, if an inde-
pendent and objective review can occur. This review focuses heavily on process engineering, so the con-
tracting party should ensure that the appropriate team is available.
'• , i
Timing of the Review
i! • , i|
The review should be on a continuous basis from the start of the design phase. Under ideal circumstances,
the reyiew should be an ongoing review performed at key points - preliminary, intermediate, and prefinal
design phases. By using this approach, the focus of the review can change as the design develops. An
example would be the review of the process or facility layouts in the Design Criteria Analysis. Adjustments
could be suggested early in the process without causing major redesign cost.
: J '' • I
Scope of the Review
An operability review assures that the completed project will conform to applicable performance and opera-
tions requirements by asking:
« Does the operation and maintenance manual conform with the drawings and specifications?
• Are the requirements stated for equipment, installation, adjustment, etc.?
'! il
• Are the specifications complete for pre-startup, checkout, and post-startup optimization?
» Have the warranties, guarantees, or other contractual requirements applicable to operation and
maintenance of the project been reviewed?
Components of the design that should be evaluated to address the questions noted above are:
1. Process and Instrumentation Diagrams
II
2. Facilities and Process Equipment Layouts
3. Specifications review, to include General and Supplemental Conditions Review and Equipment
Specification, Mechanical Specification, and Electrical Specification reviews
A checklist is attached to provide additional detail to assist in an operability review.
C-6
-------
Appendix C • Design Review Checklists
Design Review
Project Title & Location:
Document Reviewed
(Section/Paragraph)
Item No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Component to be evaluated for completeness, clarity and
appropriateness (provide comments on separate sheet)
OPERABILITY
Process and Instrumentation Diagrams
Are the various components in the overall process train compatible?
Is the process reliable? If not, have back-up systems been provided?
Have the critical sampling points for process monitoring been
identified?
Does it appear that the proposed treatment system can be operated
efficiently without the need for highly specialized training?
Are the operating requirements compatible with the intended levels
for the proposed process?
Have control panels been centralized at one location? If not, is
staffing adequate to man several posts?
Have alarm systems or comparable warning systems been provided
in case of mechanical breakdown or system upset?
Does the selected equipment meet special needs (i.e., long term
operation, acidic waste, low feed rates, etc.)?
Are there provisions for expansion if additional treatment capacity
is required?
Is sufficient data collection and monitoring planned?
Facilities and Process Equipment Layouts
Are the process equipment and local control panels placed so the
operator has easy access?
Have special materials, handling problems, (debris, dust, tree
roots, wet soils, clay, etc.) been identified and addressed?
Are the items requiring routine maintenance accessible?
Are sampling valves and equipment accessible for operation checks
and for preventive and demand maintenance? (If the equipment
is hard to reach, it may not be maintained in a proper manner)
Have washdown and housekeeping requirements been specified?
Acceptability
Yes
No
N/A
51-043-41A(3)
C-7
-------
RD/RA Handbook
Design Review
Project Title & Location:
Document Reviewed
(Section/Paragraph)
Item No.
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
Component to be evaluated for completeness, clarity and
appropriateness (provide comments on separate sheet)
Specifications Review
Have the performance testing requirements for process equipment
been specified?
Are equipment manufacturers' and constructors' warranties and
guarantees required, and are they of reasonable duration?
Have the specific procedures for handling latent defects in process
equipment been specified?
Do specifications address compliance with equipment safety codes?
General Requirements
Do the design documents specify submittal requirements for the
equipment supplier O&M datasheets and for test results from factory
tests?
Do the specifications include a requirement for completion of the
O&M manual and a description of the type of equipment manufacturer
services that will be required during the training start-up phase?
Do the specifications include the responsibilities of the constructor
during the start-up phase?
Do the specifications include the necessary requirements for training
maintenance personnel?
Equipment Specifications
Have factory testing requirements been specified?
Have installation requirements, alignments, adjustments, and
lubrication requirements been addressed?
Have functional field testing requirements been specified?
Are there requirements for equipment labeling?
Has a list of manufacturer's recommended spare parts and special
tools been specified?
Have requirements for manufacturers' certification or proper
installation and performance been specified?
Have detailed manufacturer service requirements, including number
of days spent on site and number of trips, been specified?
Have types of sampling equipment and their applications been
included?
Is any of the equipment or are any of the materials more elaborate
than needed (i.e., can other standard or off-the-shelf items be
specified)?
Acceptability
Yes
No
N/A
51-043-41A(4)
C-8
-------
Appendix C • Design Review Checklists
Design Review
Project Title & Location:
Document Reviewed
(Section/Paragraph)
Item No.
33
34
35
36
37
38
39
40
41
42
Component to be evaluated for completeness, clarity and
appropriateness (provide comments on separate sheet)
Mechanical Specifications
Do mechanical specifications comply with state and local codes?
Have test pressures been specified for piping?
Does the valve and specialty list include pressure ratings?
Is equipment soundproofing needed and specified?
Electrical Specifications
Have a sufficient number of 100 and 220/440 outlets (provided for
maintenance purposes) been specified?
Is the system properly grounded?
Has cathodic protection been provided for equipment?
Is lighting adequate for O&M functions?
Has conformance with state and local electrical codes been specified?
Has power surge protection for equipment been specified?
Acceptability
Yes
No
N/A
S1-043-41A(S)
C-9
-------
RD/RA Handbook
Constructability Review
Definition
A constructability review is performed to enhance the "buildability" of the design. It allows for the evalu-
ation of the design for accuracy and completeness. In addition, the review provides an opportunity to
eliminate impractical and inefficient remedial action (RA) requirements as well as deficiencies in contract
documents. The review must be thorough enough to ensure that drawings, technical specifications, and bid
forms are unambiguous and compatible with each other. Projects designed with constructability in mind
will result in the lowest possible contract price with a minimum risk to all parties. Attention to constructability
also allows timely completion of the project with a minimum of contractor claims.
Review Team
i
The review should be conducted by individuals and organizations knowledgeable in construction tech-
niques, materials, equipment application, and design requirements. This review could be performed using
EPA in-house resources, another agency, or a contractor, as long as the review is impartial. The review team
should devote approximately five to ten working days reviewing and discussing the design documents. A
formal report is prepared to document review results.
Timing of the Review
The constructability review should be considered an interactive process, one that first occurs in the early
design phases in order to be of optimum value. At the preliminary design phase, the constructability screen-
ing might consist of an initial brainstorming session to discuss various aspects of the proposed concepts,
such as general accessibility, procurement policies, as well as a cursory review of sketches or preliminary
drawings. At the intermediate design phase, the screening can be enhanced to include more detailed review
of the drawings and specifications, including more specific information regarding construction methods
and installation details. The most comprehensive review occurs upon submission of the prefinal design to
the contracting party. However, as constructability is the focus of the earlier design efforts, this last review
should proceed without surprises.
!
Scope of the Review
The design documents critiqued during a constructability review fall into the two major categories: draw-
ings (civil, electrical, mechanical) and specifications (construction activities). Drawings are the primary
source of guidance in the field for the RA, portraying the physical aspects of the facility or structure and
showing the arrangement, dimensions, details, materials, and other information necessary for building the
project. Reviewers must rely on their own experience hi then- disciplines to evaluate the drawings for
clarity, completeness, compatibility with specifications, and ability to be understood by field personnel.
Spot checks of drawings should be done for sensitivity of the design to construction.
!
In evaluating the specifications, reviewers determine that the specifications are sufficient to effectively
communicate engineering information, quality control, performance periods, submittal requirements, and
the relationship to other work.
When the review is complete, the review team should be prepared to answer the following:
C-10
-------
Appendix C • Design Review Checklists
• Are there any potential construction constraints imposed by the site or unusual site conditions
which could affect the RA?
• What is the availability of local materials and possibility of procurement/schedule difficulties
caused by long-lead items?
• What are the seasonal constraints and how will they affect the RA?
• Is there an accurate depiction of design structures and existing site conditions such as access,
storage and utilities?
• Is there a lack of prescribed procedures for critical work or excessive detailing on drawings?
• Evaluation of accuracy of any estimated quantities?
A checklist is attached to provide additional assistance when performing the constructability review.
C-11
-------
RD/RA Handbook
Design Review
Project Title & Location:
.1
Document Reviewed
(Section/Paragraph)
Item No.
1
2
3
4
5
Component to be evaluated for completeness, clarity and
appropriateness (provide comments on separate sheet)
CONSTRUCTABILITY
Are there any potential construction constraints imposed by the site
or unusual site conditions which could affect the RA?
Are the seasonal constraints that will affect the RA identified?
Is there an accurate depiction of design structures and existing site
conditions such as access, storage and utilities?
Is there a lack of prescribed procedures for critical work, excessive
detailing on drawings?
Have existing utility locations been identified (water, sewer, electrical,
telephone)?
Acceptability
Yes
No
N/A
C-12
51-043-41 A(6)
-------
Appendix C»Design Review Checklists
Claims Prevention Review _^
Definition
A claims prevention review eliminates conflicts, inconsistences, ambiguities, errors, omissions, or other
identifiable problems in the drawings and specifications and contract documents that are subject to contract
modifications and constructor claims. A construction claim is a written demand or assertion to the contract-
ing party by the constructor seeking, as a matter of right, additional money, a time adjustment, or other
change in contract requirements. For purposes of claims prevention, the complexities can be reduced to
basic claim types and a prevention program designed around those basis claim types. The purpose of the
review is to identify causes or events which could lead to claims.
Review Team
The contracting party is responsible for having the appropriate design reviews conducted. The review can
be conducted by the contracting party, other federal agencies, or the designer (if independent and objective
reviews can be performed). The claims prevention review should be performed by those with experience in
construction contracts management, usually resident field engineers and contracting officers.
Timing of the Review
The claims prevention review is a one-time review conducted before contract solicitation. The review
should occur upon the submission of the prefinal design to the contracting party. The review is performed
in conjunction with other specialized design reviews (biddability, operability, constructability reviews).
Scope of the Review
The scope of the review is limited to an administrative review. The following questions should be evaluated
when reviewing the drawings and specifications and the contract documents:
• Is the contract clear, complete, and enforceable?
• Does the contract language use the common and normal meaning of words?
• Have contract documents been reviewed to ensure that conflicts do not exist among sections?
• Have the architectural and engineering disciplines taken sufficient precautions to ensure the design
is reasonably free of errors?
• Do the contract documents adequately support the terms of payment selected (i.e., fixed-price or
cost reimbursement)?
• Does the contract adequately explain the contract and consequences it contains for the contracting
party and constructor?
• Are criteria for constructor selection clear and fair?
• Are performance standards complete, adequate, and unambiguous?
• Is there a remedy and procedure for changes?
• Are the estimated quantities reasonable?
• Is the site (and soils investigation) and disclosure of technical information adequate?
A checklist is attached to assist in conducting a claims prevention review.
C-13
-------
RD/RA Handbook
Design Review
Project Title & Location:
Document Reviewed
(Section/Paragraph)
Item No.
1
2
3
4
5
6
7
8
9
10
11
Component to be evaluated for completeness, clarity and
appropriateness (provide comments on separate sheet)
CLAIMS PREVENTION
Is the contract clear, complete, and enforceable?
Does the contract language use the common and normal meaning
of words?
Have the contract documents been reviewed to ensure that conflicts
do not exist among various sections?
Have the architectural and engineering disciplines taken sufficient
precautions to ensure the design is reasonably free of errors?
Do the contract documents adequately support the terms of payment
selected (i.e., fixed price or cost reimbursement)?
Does the contract adequately explain the contract and consequences
it contains for the contracting party and constructor?
Are the criteria for constructor selection clear and fair?
Are the performance standards complete, adequate, and
unambiguous?
Is there a remedy and procedure for changes?
Are the estimated quantities reasonable?
Is the site (and soils investigation) and disclosure of technical
information adequate?
Acceptability
Yes
No
N/A
51-043-41 A(7)
C-14
-------
Appendix C • Design Review Checklists
Environmental Review
Definition
The environmental review ensures that the design will meet the technical requirements of the Record of
Decision (ROD) and that there is consistency between the implementation plans and current regulatory and
policy requirements. The review also determines the adequacy of documents that address potential environ-
mental releases during construction and contingency plans. The review does not re-evaluate potentially
applicable or relevant and appropriate requirements (ARARs) but determines if the design incorporates
adequate technical and administrative steps to meet the ARARs identified in the ROD.
Review Team
The contracting party is responsible for having the appropriate design reviews conducted. The review can
be conducted by the contracting party, other federal agencies, or by the designer if an independent and
objective review can be performed. The RPM (with appropriate representation from other EPA offices) and
the state, however, are the most qualified to undertake this review. Regardless of who performs the review,
the designer is not absolved of professional liability as the result of this review. If the design proves to be
deficient, the designer may be held liable for errors or omissions in the design.
Timing of the Review
The environmental review should occur late enough in the design process so that technical details sufficient
to judge process effectiveness or achievement of standards can be reasonably determined. The performance
standards for the design should be included by the designer in the design criteria analysis. The ARARs
should be determined as early as possible in the design effort to prevent redesign effort.
Scope of the Review
An environmental review seeks to address the following:
• Is there compliance with all applicable or relevant and appropriate environmental and public health
requirements identified in the ROD?
• Are currently accepted environmental control measures and technology utilized?
• Are all substantive permit requirements clearly identified in the design along with the means of
demonstrating compliance?
• Have all required off-site permits been applied for by the designer?
• Does the design require the constructor to comply with the off-site disposal rule (Section 121(d)(3)
of CERCLA)? Are back-up facilities required in the event that the primary disposal facility goes
out of compliance with the Resource Compensation and Recovery Act?
A checklist is attached to assist in conducting an environmental review.
C-15
-------
RD/RA Handbook
Design Review
Project Title & Location:
Document Reviewed
(Section/Paragraph)
Item No.
1
2
3
4
5
6
7
8
Component to be evaluated for completeness, clarity and
appropriateness (provide comments on separate sheet)
ENVIRONMENTAL
Is there compliance with all applicable or relevant and appropriate
environmental and public health requirements identified in the Record
of Decision?
Are currently accepted environmental control measures and
technology utilized?
Are all substantive permit requirements clearly identified in the
design with a description of the means of demonstrating compliance?
Have all required off-site permits been applied for by the designer?
Does the design require the constructor to comply with the off-site
disposal rule (Section 121(d)(3) of CERCLA)? Are back-up facilities
required in the event that the primary disposal facility goes out of
compliance with the Resource Compensation and Recovery Act?
Are all performance standards clearly identified?
Has perimeter air monitoring been specified?
Are dust and noise control measures specified?
Acceptability
Yes
No
N/A
51-043-41 A(8)
C-16
-------
Appendix D
Model RD, RA, and Technical Assistance
lAGs
-------
-------
Appendix D • Model RD, RA, and Technical Assistance lAGs
Model for USAGE Remedial Design IAG
United States Environmental Protection Agency
Washington, DC 20460
&EPA Intei
Part
'agency Agreement/
Amendment
1 - General Information
6. Name and Address of EPA Organization
[Regional Address]
1. EPA IAG Identification Number
DW96
4. Funding Location by
Region
2. Other Agency IAG ID Number (if known) [As appropriate]
3. Type of Action
New Agreement
5. Program Office
Abbreviation
[As appropriate]
7. Name and Address of Other Agency
U.S. Army Corps of Engineers (USAGE)
Engineering Division, Missouri River
Omaha, Nebraska 681 44-3869
8. Project Title
Design of Superfund Remedial Action at [site name, city, and state]
9. EPA Project Officer (Name, Address, Telephone Number)
[Regional Project Officer]
U.S. Environmental Protection Agency
[Regional Address]
[Telephone Number]
11. Project Period
10. Other Agency Project Officer (Name, Address, Telephone Number)
U.S. Army Engineer, Missouri River Division
ATTN: Lucy Harris
1 2565 West Center Road
Omaha, NE 68144-3869 (402)697-2422
12. Budget Period [same as ^.^ perfod]
13. Scope of Work (Attach additional sheets, as needed)
This interagency agreement will allow the USAGE and U.S. Environmental Protection Agency to utilize
the Direct Fund Cite/Revised Reimbursable methods for costs incurred during this action. The funds
are divided as follows:
Revised Reimbursable $
Direct Fund Cite
Total
$
$
Contracts financed under the Direct Fund Cite Procedure will cite the following accounting classification:
68/20X81 45, (Account Number)
1 4. Statutory Authority for Both Transfer of Funds and Project Activities 1 5. Other Agency Type
CERCLA as amended (42 USCA 9601 et seq.) Executive Order 12580 and Economy F , ,
Act of 1 932 as amended (31 USC 1 535)
Funds
16. EPAAmount
17. EPA In-Kind Amount
18. Other Agency Amount
19. Other Agency In-Kind Amount
20. Total Project Cost
21. Fiscal Information
Previous Amount
Amount This Action
Program Element FY Appropriation Doc. Control No.
FAY9A 94 68/20X8145
Amended Total
Account Number Object Obligation/DeobligationAmt.
Class
25.76
EPA Form 1610-1 (Rev. 10-88) Previous editions are obsolete.
51-043-33(1 )A
D-1
-------
RD/RA Handbook
Model for USAGE Remedial Design IAG (cont.)
Part II - Approved Budget
EPA IAG Identification Number
DW
22. Budget Categories
Itemization of
This Action
Itemization of Total Project
Estimated Cost to Date
(n) Personnel
(bjBlnga Benefits
(c) Travel
(d) Equipment
{•) Supples
(0 Procummsnt/Ass'stance
!q) USAGE DIVISKKI Cosls
(I) TotM Direct Charges
jj) irtdirocl Cosl
Rale:
(k)To!a!
(EPA Share 100%)
(Other Agency Share 0%)
23. Is equipment authorized to be furnished by EPA or leased, purchased, or rented with EPA funds?
(Identify all equipment costing $1,000 or more)
USAGE equipment needs ara unknown at this time. USAGE shall report equipment acquisition in accordance
with paragraph 3 of Attachment B - Special Provisions.
Yes
D
No
24, Ara any of these funds being used on extramural agreements? (See item 22f)
Typa of Extramural Agreement
Grant
D
Cooperative Agreement
Procurement (Includes Small Purchase Order)
Contractot/Recipienl Name (if known)
Unknown
Total Extramural Amount Under This Project
[estimate]
Percent Funded by EPA (if known)
100
Part ill - Funding Methods and Billing Instructions
25.
Funds-Out Agreement
Disbursement Agreement
I X I Repayment
(Note: EPA Agency Location Code (ALC) - 68010727)
Request for repayment of actual costs must be itemized on SF 1081 or SF 1080 and submitted to the
Financial Management Center, EPA, Cincinnati, OH 45268:
Monthly
D
Quarterly
n
Upon Completion of Work
. . Only available for use by Federal Agencies on working capital fund or with appropriate justification of
I I Advance need for this type of payment method. Unexpended funds at completion of work will be returned to
I 1 EPA. Quarterly cost reports will be forwarded to the Financial Management Center, EPA, Cincinnati,
OH 45268.
Used to transfer obligational authority or transfer of function between Federal agencies. Must receive
Allocation prior approval by the Office of the Comptroller, Budget Division, Budget Formulation and Control Branch,
Transfer-Out EPA Headquarters. Forward appropriate reports to the Financial Reports and Analysis Branch, Financial
Management Division, PM-226F, EPA, Washington D.C. 20460.
26.
I I Funds-ln Agreement
I I Reimbursement Agreement
Repayment
Advance
Allocation Transfer-In
OthorAgoncy's IAG Identification Number
EPA Program Office Allowance Holder/Responsibility Center Number
72E
Other Agency's Billing Address (Include Agency Location Code
or Station Symbol Number)
Other Agency's Billing Instructions and Frequency
EFAForm 1610-1 (Rev. 10-88)
51-043-33(2)A
D-2
-------
Appendix D • Model RD, RA, and Technical Assistance (AGs
Model for USAGE Remedial Design IAG (cont.)
Part IV - Acceptance Conditions
EPA IAG Identification Number
DW96
27. General Conditions
The other agency covenants and agrees that it will expeditiously initiate and complete the project for which funds
have been awarded under this agreement.
28. Special Conditions (Attach additional sheets if needed)
(See Attachment B)
Part V - Offer and Acceptance
Note: 1)For Funds-out actions, the agreement/amendment must be signed by the other agency official in duplicate and one
original returned to the Grants Administration Division for Headquarters agreements or to the appropriate EPA Regional
IAG administration office within 3 calendar weeks after receipt or within any extension of time as may be granted by EPA.
The agreement/amendment must be forwarded to the address cited in Item 29 after acceptance signature.
Receipt of written refusal or failure to return the properly executed document within the prescribed time may result in the
withdrawal of the offer by EPA. Any change to the agreement by the other agency subsequent to the document being
signed by the EPA Action Official, which the Action Official determines to materially alter the agreement/amendment,
shall void the agreement/amendment.
2) For Funds-in actions, the other agency will initiate the action and forward two original agreements/amendments to the
appropriate EPA program office for signature. The agreements/amendments will then be forwarded to the appropriate
EPA IAG administration office for acceptance signature on behalf of the EPA. One original copy will be returned to the
other agency after acceptance.
EPA IAG Administration Office (for administrative assistance)
EPA Program Office (for technical assistance)
29. Organization/Address
[EPA IAG Administration Office]
[Organization/Address]
30. Organization/Address
[EPA Program Office]
[Organ ization/Address]
Certification
All signers certify that the statements made on this form and all attachments thereto are true, accurate, and complete. Signers
acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or both under
applicable law.
Decision Official on Behalf of the Environmental Protection Agency Program Offica
31 . Signature
Typed Name and Title
Action Official on Behalf of the Environmental Protection Agency
32. Signature
Typed Name and Title
Date
Date
Authorizing Official on Behalf of the Other Agency
33. Signature
Typed Name and Title
Date
EPA Form 1610-1 (Rev. 10-88)
51-043-33(3)A
D-3
-------
RD/RA Handbook
Model for USAGE Remedial Design IAG (cont.)
Page 7 of 8
Part IV - Acceptance Conditions (continued)
EPA IAG Identification Number
28. Special Conditions (continued)
8. Minority Business Utilization
In accordance with CERCLA, as amended (P.L. 99-499), Section 105(f), any Federal agency awarding contracts,
grants or cooperative agreements utilizing Superfund monies shall consider the availabliiity of minority contractors
for participation in contracts. This includes, but is not limited to: contracts, subcontracts, SBA 8(a) awards and
any subagreements.
The USAGE, as a recipient of Superfund monies under this IAC, must report annually on minority contractor
participation and efforts taken to encourage (outreach endeavors) the utilization of minority firms.
Reports will be forwarded annually (by November 15th) to the Minority Business Enterprise Coordinator,
EPA-Region 3, Hazardous Waste Management Division (3HW43). Reports will be submitted on EPA Forms
6005-3, Superfund Minority Contractors Utilization Report", 6005-3A, "Superfund Minority Contractors Utilization
Report - Part 2".
9. As a recipient of monies under this IAG, the USAGE must ensure to the fullest extent possible that at least
8% of funds for prime or subcontracts and subgrants for services are made available to businesses owned or
controlled by socially and economically disadvantaged individuals, women-owned businesses, and Historically
Black, Colleges and Universities.
The USAGE must submit a report to EPA showing the actual amount and percentage of extramural funds
awarded to DBEs on Forms 6005-3 and 67005-3a, by December 15, of each year. Reports should be submitted
to:
Mr. George Mori, Senior Program Officer
Office of Small and Disadvantaged Business Utilization (A-149C)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
D-4
S1-043-33(4)A
-------
Appendix D • Model RD, RA, and Technical Assistance (AGs
Attachment A * Scope of Work for Remedial Design IAG
Site
Name, City, State
Site/Spill Identifier
Purpose
The purpose of this agreement is to obtain assistance from the U.S. Army Corps of Engineers (USAGE) for
the implementation of a remedial design for remedial action at site name.
Background
Briefly summarize the site in one or two paragraphs to include:
location of site
brief history of operations, releases, response actions, etc.
quantity, types, and concentrations of hazardous substances
extent of contamination
operable unit name and number, event name and number, and project name, if applicable
A Record of Decision (ROD) was signed by the name of AA-OSWER or Regional Administrator on date
selecting description of remedy as the cost effective remedy for the site name.
Remedy
The remedy selected by EPA and the State of state name includes the following major components (list
major components in bullet format):
Work Statement
The USAGE will be responsible for:
1. Developing the technical statement of work and awarding and managing a contract to a private firm
for the design of description of remedy. The design package will consist of plans and specifications
along with include as necessary operations and maintenance (O&M) plan, quality assurance project
plan (QAPP), site safety plan, etc.
2. Reviewing the design package in coordination with the EPA RPM at preliminary and prefinal
design stages. Approval and acceptance of the final design, with comment from EPA.
3. Conducting value engineering screening to assess the need for a value engineering study. Conduct-
ing value engineering studies when indicated.
4. Preparing a Real Estate Planning Report to be submitted to the EPA Regional Office during the
preliminary design phase of the project.
5. Providing other support to include permit assistance, community relations assistance, etc.
6. Reproducing design documents.
7. Conducting procurement activities for remedial actions up to the point of award.
D-5
-------
RD/RA Handbook
1 i il
,1
, , „, , j
Attachment B • Special Conditions for Remedial Design IAG
•••• .• j
The USAGE agrees to meet the site-specific financial management and recordkeeping responsibilities con-
tained in EPA's "Superfund Financial Management and Recordkeeping Guidance for Federal Agencies"
(January 1989).
j
Cost Documentation Requirements
• i
EPA acting as manager of the Hazardous Substances Superfund requires current information on CERCLA
response actions and related obligations of CERCLA funds for these actions. In addition, CERCLA, as
amended, authorizes EPA to recover from responsible parties all government costs incurred during a re-
sponse action. To help assure oversight and successful recovery of CERCLA funds, both USAGE and EPA
have responsibilities under this agreement. The USAGE accounting system reports must be supported by
site- and activity-specific cost documentation. The USAGE will organize and retain in a site file documen-
tation of costs by site and activity (e.g., vouchers, billing statements, evidences of payment, audit reports) as
follows:
1. Direct Costs
Payroll - timesheets or timecards to support hours charged to a particular site, including the
signature of the employee and/or the employee's supervisor.
Travel - travel authorizations (including purpose of trip), local travel vouchers, traveler's
reimbursement vouchers, carrier bills (including airline tickets, government-owned vehicle
bills, appropriate receipts for hotel, car rental, etc., proof of payment. Proof of payment is
satisfied by providing a copy of standard form (SF) 1166 "Voucher and Schedule of Pay-
ment" or equivalent.
Contractor services - copies of contracts, requests for proposals (RFPs), detailed evaluation
of contractor bids, contractor invoices, USAGE project officer approval of invoices, proof of
payment. Proof of payment is satisfied by providing a copy of the accomplished SF 1166 or
equivalent.
Supplies and Equipment - EPA authorization to purchase non-expendable property of
$l,()00.0p or more, vendor invoices, proof of payments, and hourly records of equipment use,
whqn applicable.
i : ii
Any other direct costs not included in the above categories.
2. Indirect Costs
If indirect costs are r|bt calculated by the US ACE accounting system, a worksheet showing calculations of
indirect costs charged to a site will be retained by the USAGE.
.i. 'H , ' ' • > |
Under the IAG, the USAGE certifies that: 1) any indirect costs included in billings to EPA represent, in
accordance with GAO principles, indirect costs that would not have been otherwise incurred by the USAGE;
or 2) explicit Congressional authority exists for charging other than incremental costs of performance.
Reporting Requirements
1. The USAGE will provide monthly progress reports to the RPM listed on the IAG form containing:
1 ' 1
Site name and IAG number
Summary of work performed
Estimate of the percentage of the project completed
D-6
-------
Appendix D • Model RD, RA, and Technical Assistance (AGs
Accounting of funds expended during the reporting period and on the project to date, which
includes budget category cost breakdown
Summaries of all change orders and claims made on the contract during the reporting period
Summaries of all contacts with representatives of the local community, public interest
groups, or state government during the reporting period
Summaries of all problems or potential problems encountered during the reporting period
Projected work for the next reporting period
Attachment of a copy of all certified contractor invoices for contract costs and request for
reimbursement (SF 1080) for all USAGE in-house cost submitted to the EPA Financial
Management Center, Cincinnati, for payment during the reporting month
2. The USAGE will submit certified contractor invoices and/or a completed and signed SF 1080,
Request for Reimbursement, to the EPA Financial Management Center, Cincinnati, containing, as
appropriate, USAGE cost by budget category identified by site, site-specific account number, and
IAG number.
3. USAGE will provide a final inventory of property, (before final-eontract payment) within one
month of the end of the IAG performance period, describing the condition of each item (and
requesting disposition instructions). USAGE will require all contractors to provide a final inven-
tory of property prior to their final contract payment. If the duration of the project is greater than
one year, USAGE will provide an annual inventory of all property acquired by or furnished to
USAGE with EPA funds.
Cost Recovery
In the event of a contemplated cost recovery action, the USAGE will provide to EPA or the Department of
Justice (DOJ) a cost documentation package detailing site-specific costs and including copies of the back-
up documentation. In some cases, these requests from EPA or DOJ may require the documentation to be
provided in less than thirty days. If additional time is required to comply with a request, USAGE will
negotiate with EPA or DOJ a schedule for responding. USAGE will provide EPA with a contact for obtain-
ing necessary site-specific accounting information and documentation.
Record Retention Requirements
The USAGE (and its contractors) will retain the documents described in these "Special Conditions" for a
minimum of ten years after submission of a final SF 1080 for a site or sites, after which USAGE must obtain
written permission from the authorized EPA official before disposing of any of the records. USAGE will
require all contractors entering into cost reimbursable type contracts to establish and maintain cost docu-
mentation as described above.
Project Specific Conditions
1. The USAGE will invite (with reasonable notice) the EPA RPM to participate in contractor meetings
in which scope of the project or progress is discussed.
2. The USAGE will invite the EPA RPM to participate in the contractor selection process, as appropri-
ate.
3. The USAGE Project Manager will brief the EPA RPM regularly on the current status of the project.
Briefings will be monthly unless a different frequency is mutually agreed upon by both project
managers. Emphasis shall be placed on project budget, expenditure rates, and schedule.
D-7
-------
RD/RA Handbook
4. The USAGE personnel and its contractors will have the appropriate safety training and be involved
in a medical monitoring program as specified in 29 Code of Federal Regulations (CFR) Part 1910;
51 CFR 45663 - 45675; and Section 125(e) of CERCLA, as amended.
; ,i ., • . - |
5. EPA will provide indemnification of USAGE contractors for extraordinary risk to the extent that
CERCLA funds are available in accordance with Section 119 of CERCLA and EPA implementing
guidance.
6. The USAGE will furnish to the EPA RPM a copy of the Quality Assurance Management Plan.
7. The USAGE will have final authority, with EPA comment, for approving QAPjPs, Sampling
Analysis Plans (SAPs), which reflect environmental sampling and laboratory analysis, and Health
and Safety Plans (HASPs).
Audits
I
1. Superfund cost documentation information must be available for audit or verification upon request
of authorized auditing agencies.
2. If an audit determines that any direct or indirect cost charged to EPA are unallowable, EPA will be
notified immediately following the resolution of the audit
Other EPA Involvement
1. Payment to USAGE contractors is contingent upon receipt of a USAGE certified payment request.
Reimbursement to USAGE for in-house costs is contingent upon receipt of a USAGE certified
reimbursement for request (SF 1080). Final project payments for specific contracts and in-house
cost shall be reviewed and approved by the EPA Regional program office.
i • • i: ' • '<„ 1 ,
2, EPA will m>ld title to all property acquired with Superfund monies. EPA will provide the USAGE
the property disposition instructions upon termination of the IAG. EPA will receive fair-market
value for any property disposed of or used for non-Superfund activities.
D-8
-------
Appendix D • Model RD, RA, and Technical Assistance (AGs
Model for USAGE Remedial Action IAG
©EPA
United States Environmental Protection Agency
Washington, DC 20460
Interagency Agreement/
Amendment
Part 1 - General Information
6. Name and Address of EPA Organization
[Regional Address]
1. EPA IAG Identification Number 4. Funding Location by
DW 96 Reaion
2. Other Agency IAG ID Number (if known) [As appropriate]
5. Program Office
3. Type of Action Abbreviation
New Agreement [As appropriate]
7. Name and Address of Other Agency
U.S. Army Corps of Engineers (USACE)
Engineering Division, Missouri River
Omaha, Nebraska 68144-3869
8. Project Title
Design of Superfund Remedial Action at [site name, city, and state]
9. EPA Project Officer (Name, Address, Telephone Number)
[Regional Project Officer]
U.S. Environmental Protection Agency
[Regional Address]
[Telephone Number]
11. Project Period
10. Other Agency Project Officer (Name, Address, Telephone Number)
U.S. Army Engineer, Missouri River Division
ATTN: Lucy Harris
1 2565 West Center Road
Omaha, NE 68144-3869 (402)697-2422
12. Budget Period r . ,,
[same as project period]
1 3. Scope of Work (Attach additional sheets, as needed)
This interagency agreement will allow the USAGE and U.S. Environmental Protection Agency to utilize
the Direct Fund Cite/Revised Reimbursable methods for costs incurred during this action. The funds
are divided as follows:
Revised Reimbursable $
Direct Fund Cite $
Total
$
Contracts financed under the Direct Fund Cite Procedure will cite the following accounting classification:
68/20X8145, (Account Number)
1 4. Statutory Authority for Both Transfer of Funds and Project Activities 1 5. Other Agency Type
CERCLA as amended (42 USCA 9601 et seq.) Executive Order 1 2580 and Economy F , ,
Act of 1 932 as amended (31 USC 1 535)
Funds Previous Amount
16. EPAAmount
17. EPA In-Kind Amount
1 8. Other Agency Amount
19. Other Agency In-Kind Amount
20. Total Project Cost
Amount This Action Amended Total
21. Fiscal Information
Program Element
FAY9A
FY Appropriation Doc. Control No.
94 68/20X8145
Account Number Object Obligation/Deobligation Amt.
Class
25.76
EPA Form 1610-1 (Rev. 10-88) Previous editions are obsolete.
S1-043-34(1)A
D-9
-------
RD/RA Handbook
Model for USAGE Remedial Action IAG (cont.)
Part II - Approved Budget
I EPA IAG Identification Number
DW
22. Budget Categories
Itemization of
This Action
Itemization of Total Project
Estimated Cost to Date
(a) Paraonno)
(b)Frtnga Benefits
(o) Trawl
(d) Equipment
(9) Supples
(I) Procuremanl/Assistancfl
(9) USAGE Divtston Costs
(h) Otter
§1btal Direct Ctwges
OJImfraclCost
Rale:
M Total
(EPA Share 100%)
(Other Agency Share 0%)
$
23, Is equipment authorized to be furnished by EPA or leased, purchased, or rented with EPA funds?
(Identify all equipment costing $1,000 or more)
USAGE Mjdpment rweds am unknown at this time. USACE shall report equipment acquisition in accordance
with paragraph 3 of Attachment B - Special Provisions.
Yes
D
No
24, Are any of these funds being used on extramural agreements? (See item 22f)
[Xj Yes [J N
Typa of Extramural Agreement
D
Grant
n
Cooperative Agreement
Procurement (Includes Small Purchase Order)
Contractor/Recipient Name (H known)
Unknown
Total Extramural Amount Under This Project
[estimate]
Percent Funded by EPA (if known)
100
Part III - Funding Methods and Billing Instructions
25.
X I Funds-Out Agreement
I X I Disbursement Agreement
I X I Repayment
(Note: EPA Agency Location Code (ALC) - 68010727)
Request for repayment of actual costs must be itemized on SF 1081 or SF 1080 and submitted to the
Financial Management Center, EPA, Cincinnati, OH 45268:
Monthly
n
Quarterly
Upon Completion of Work
D
Only available for use by Federal Agencies on working capital fund or with appropriate justification of
Advance need for tnls tyP9 °' payment method. Unexpended funds at completion of work will be returned to
EPA. Quarterly cost reports will be forwarded to the Financial Management Center, EPA, Cincinnati,
OH 45268.
n
Used to transfer obligational authority or transfer of function between Federal agencies. Must receive
Allocation prior approval by the Office of the Comptroller, Budget Division, Budget Formulation and Control Branch,
Transfer-Out EPA Headquarters. Forward appropriate reports to the Financial Reports and Analysis Branch, Financial
Management Division, PM-226F, EPA, Washington D.C. 20460.
26,
I I Funds-ln Agreement
I I Reimbursement Agreement
n
Repayment
Advance
Allocation Transfer-In
Otter Agency's IAG Identification Number
EPA Program Office Allowance Holder/Responsibility Center Number
72E
Other Agency's Billing Address (Include Agency Location Code
or Station Symbol Number)
Other Agency's Billing Instructions and Frequency
EPA Form 1610-1 (Rev. 10-88)
51-043-34(2)A
D-10
-------
Appendix D • Model RD, RA, and Technical Assistance tAGs
Model for USAGE Remedial Action IAG (cont.)
Part IV - Acceptance Conditions
EPA IAG Identification Number
DW96
27. General Conditions
The other agency covenants and agrees that it will expeditiously initiate and complete the project for which funds
have been awarded under this agreement.
28. Special Conditions (Attach additional sheets if needed)
(See Attachment B)
Part V - Offer and Acceptance
Note:1)For Funds-out actions, the agreement/amendment must be signed by the other agency official in duplicate and one
original returned to the Grants Administration Division for Headquarters agreements or to the appropriate EPA Regional
IAG administration office within 3 calendar weeks after receipt or within any extension of time as may be granted by EPA.
The agreement/amendment must be forwarded to the address cited in Item 29 after acceptance signature.
Receipt of written refusal or failure to return the properly executed document within the prescribed time may result in the
withdrawal of the offer by EPA. Any change to the agreement by the other agency subsequent to the document being
signed by the EPA Action Official, which the Action Official determines to materially alter the agreement/amendment,
shall void the agreement/amendment.
2) For Funds-in actions, the other agency will initiate the action and forward two original agreements/amendments to the
appropriate EPA program office for signature. The agreements/amendments will then be forwarded to the appropriate
EPA IAG administration office for acceptance signature on behalf of the EPA. One original copy will be returned to the
other agency after acceptance.
EPA IAG Administration Office (for administrative assistance)
EPA Program Office (for technical assistance)
29. Organization/Address
[EPA IAC Administration Office]
[Organization/Address]
30. Organization/Address
[EPA Program Office]
[Organization/Address]
Certification
All signers certify that the statements made on this form and all attachments thereto are true, accurate, and complete. Signers
acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or both under
applicable law.
Decision Official on Behalf of the Environmental Protection Agency Program Office
31. Signature
Typed Name and Title
Date
Action Official on Behalf of the Environmental Protection Agency
32. Signature
Typed Name and Title
Date
Authorizing Official on Behalf of the Other Agency
33. Signature
Typed Name and Title
Date
EPA Form 1610-1 (Rev. 10-88)
51-043-34(3)A
D-11
-------
RD/RA Handbook
Model for USAGE Remedial Action IAG (cont.)
Part IV -Acceptance Conditions (continued)
EPA IAG Identification Number
28. Special Conditions (continued)
8. Minority Business Utilization
In accordance with CERCLA, as amended (P.I. 99-499), Section 105(f), any Federal agency awarding contracts,
grants or cooperative agreements utilizing Superfund monies shall consider the availablitity or minority contractors
for participation in contracts. This includes, but is not limited to: contracts, subcontracts, SBA 8(a) awards and
any subagreements.
The USAGE, as a recipient of Superfund monies under this IAG, must report annually on minority contractor
participation and efforts taken to encourage (outreach endeavors) the utilization of minority firms.
Reports will be forwarded annually (by November 15th) to the Minority Business Enterprise Coordinator,
EPA-Region 3, Hazardous Waste Management Division (3HW43). Reports will be submitted on EPA Forms
6005-3, "Superfund Minority Contractors Utilization Report", 6005-3A, "Superfund Minority Contractors Utilization
Report - Fart 2".
9. As a recipient of monies under this IAG, the USAGE must ensure to the fullest extent possible that at least
8% of funds for prime or subcontracts and subgrants for services are made available to businesses owned or
controlled by socially and economically disadvantaged individuals, women-owned businesses, and Historically
Black, Colleges and Universities.
The USAGE mustsubmit a report to EPA showing the actual amount and percentage of extramural funds
awarded to DBEs on Forms 6005-3 and 67005-3a, by December 15, of each year. Reports should be submitted
to:
Mr. George Mori, Senior Program Officer
Office of Small and Disadvantaged Business Utilization (A-149C)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
51-043-34(4)A
D-12
-------
Appendix D • Model RD, RA, and Technical Assistance lAGs
Attachment A • Scope of Work for Remedial Action JAG
Site
Name, City, State
Site/Spill Identifier
Purpose
The purpose of this agreement is to obtain assistance from the U.S. Army Corps of Engineers (USAGE) for the
implementation of a remedial action at site name.
Background
Briefly summarize the site in one or two paragraphs to include:
location of site
brief history of operations, releases, response actions, etc.
quantity, types, and concentrations of hazardous substances
extent of contamination
operable unit name and number, event name and number, and project name, if applicable
A Record of Decision (ROD) was signed by the NAME OF AA-OSWER or Regional Administrator on date select-
ing description of remedy as the cost effective remedy for the site name. The remedial design (RD) for the remedy
was performed by the USAGE or other party. A Superfund State Contract was signed by the State of state name on
date providing assurances, including cost share for the remedial action (RA), required by CERCLA Section 104(c).
Remedy
The remedy selected by EPA and the State of state name includes the following major components (list major
components in bullet formal):
Work Statement
The USAGE will be responsible for:
1. Managing the contract for the RA including procurement activities for any subsequent modifications and
revisions to the original RA contract award.
2. Providing oversight and monitoring of construction in coordination with the EPA RPM to ensure compli-
ance with all contract requirements.
3. Conducting final inspection and certification of completed remedial action in coordination with the EPA
RPM.
4. Assessing submitted Value Engineering Construction Proposals (VECPs) in accordance with the Value
Engineering clause in the Federal Acquisition Regulation 52.248-1. USAGE shall consult with EPA on any
VECP that may affect the site remedy before making any change.
D-13
-------
RD/RA Handbook
Attachment B •Special Conditions for Remediai Action IAG
The USAGE agrees to meet the site-specific financial management and recordkeeping responsibilities contained in
EPA's "Superfund Financial Management and Recordkeeping Guidance for Federal Agencies" (January 1989).
Cost Documentation Requirements
EPA acting as manager of the Hazardous Substances Superfund requires current information on CERCLA response
actions and related obligations of CERCLA funds for these actions. In addition, CERCLA, as amended, authorizes
EPA to recover form responsible parties all government costs incurred during a response action. To assure oversight
and successful recovery of CERCLA funds, both USAGE and EPA have responsibilities imder this agreement. The
USAGE accounting system reports must be supported by site- and activity-specific cost documentation. The USAGE
will organize and retain in a site file documentation of costs by site and activity (e.g. vouchers, billing statements,
evidence of payment, audit reports) as follows.
1. Direct Costs
• Payroll - timesheets or timecards to support hours charged to a particular site, including the signature
of the employee and/or the employee's supervisor.
Travel - travel authorizations (including purpose of trip), local travel vouchers, traveler's reimburse-
ment vouchers, carrier bills (including airline tickets), government-owned vehicle bills, appropriate
receipts for hotel, car rental, etc., proof of payment. Proof of payment is satisfied by providing a
copy Of standard form (SF) 1166 "Voucher and Schedule of Payment" or equivalent.
Contractor services - copies of contracts, requests for proposals (RFPs), detailed evaluation of
contraclpr bids, contractor invoices, USAGE project officer approval of invoices, proof of payment.
Proof5 of payment is satisfied by providing a copy of SF 1166 or equivalent.
»" ''f "• ' II'!'I ' ' ' , ! . || ' ,1 ,!•'
Supplies and Equipment - EPA authorization to purchase non-expendable property of $1,000.00 or
more, vendor invoices, proof of payments, and hourly records of equipment use, when applicable.
, • •, ' . | -
Any other direct costs not included in the above categories.
•f / !
2. Indirect Costs
If indirect costs are not calculated by the USAGE accounting system, a worksheet showing calculations of indirect
costs charged to a site will be retained by the USAGE.
Under this IAG, the USAGE certifies that: 1) any indirect costs included in billings to EPA represent, in accordance
with GAO principles, indirect costs that would not have been otherwise incurred by the USAGE; or 2) explicit
Congressional authority exists for charging other than incremental costs of performance.
Reporting Requirements
1. The USAGE will provide monthly progress reports to the RPM listed on the IAG form containing:
,' : . .1' . :• ill' ' . i • I
Site name and IAG number
, !
Summary of work performed
Estimate of the percentage of the project completed
t Accounting of funds expended during the reporting period and on the project to date, which includes
budget category cost breakdown
1 i '
Summaries of all change orders and claims made on the contract during the reporting period
D-14
-------
Appendix D • Model RD, RA, and Technical Assistance lAGs
Summaries of all contacts with representatives of the local community, public interest groups, or state
government during the reporting period
Summaries of all problems or potential problems encountered during the reporting period
Projected work for the next reporting period
Attachment of a copy of all certified contractor invoices for contract costs and request for reimburse-
ment (SF 1080) for all USAGE in-house cost submitted to the EPA Financial Management Center,
Cincinnati, for payment during the reporting month
2. The USAGE will submit certified contractor invoices and/or a completed and signed SF 1080, request for
reimbursement, to the EPA Financial Management Center, Cincinnati, containing, as appropriate, USAGE
cost by budget category identified by site, site-specific account number, and IAG number.
3. USAGE will provide a final inventory of property, (before final contract payment) within one month of the
end of the IAG performance period, describing the condition of each item (and requesting disposition
instructions). USAGE will require all contractors to provide a final inventory before their final contract
payment. If the duration of the project is greater than one year, USAGE will provide an annual inventory or
all property acquired by or furnished to USAGE with EPA funds.
Cost Recovery
In the event of a contemplated cost recovery action, the USAGE will provide to EPA or the Department of Justice
(DOJ) a cost documentation package detailing site-specific costs and including copies of the back up documenta-
tion. In some cases, these requests from EPA or DOJ may require this documentation to be provided in less than
thirty days. If additional time is required to comply with a request, USAGE will negotiate with EPA or DOJ a
schedule for responding. USAGE will provide EPA with a contact for obtaining necessary site-specific accounting
information and documentation.
Record Retention Requirements
The USAGE will retain the documents described in these "Special Conditions" for a minimum of ten years after
submission of a final SF 1080 for a site or sites, after which USAGE must obtain written permission from the
authorized EPA official before disposing of any of the records. USAGE will require all contractors entering into
cost reimbursable type contracts to establish and maintain cost documentation as described above.
Project Specific Conditions
1. The USAGE will invite (with reasonable notice) the EPA RPM to participate in contractor meetings in
which scope of the project or progress is discussed.
2. The USAGE will invite the EPA RPM to participate in the contractor selection process, as appropriate.
3. The USAGE will have final authority for RA bids, shop drawings and contract modifications (within [the
15%] contingency fund limitations).
4. The USAGE Project Manager will regularly brief the EPA RPM on the current status of the project. Brief-
ings will be monthly unless a different frequency is mutually agreed upon by both project managers.
Emphasis shall be placed on project budget, expenditure rates, and schedule.
5. The USAGE personnel and its contractors will have the appropriate safety training and be involved in a
medical monitoring program as specified in 29 Code of Federal Regulations (CFR) Part 1910; 51 CFR
45663 - 45675; and Section 125(e) of CERCLA, as amended.
6. EPA will provide indemnification of USAGE contractors for extraordinary risk to the extent that CERCLA
funds are available in accordance with Section 119 of CERCLA and EPA implementing guidance.
D-15
-------
RD/RA Handbook
7. The USAGE will furnish to the EPA RPM for their information a copy of the Quality Assurance Manage-
ment Plan.
8. The USAGE will have final authority, with EPA comment, for approving Quality Assurance Project Plans
(QAPjPs), Sampling Analysis Plans (SAPs) which reflect environmental sampling and laboratory analysis,
and Health and Safety Plans (HASPs).
Audits
1. Superfund cost documentation information must be available for audit or verification upon request of
authorized auditing agencies.
2. If an audit determines that any direct or indirect cost charged to EPA are unallowable, EPA will be notified
immediately following the resolution of the audit.
Other ERA Involvement
1. Payment to USAGE contractors is contingent upon receipt of a USAGE certified payment request. Reim-
bursement to USAGE for in-house costs is contingent upon receipt of a USAGE certified reimbursement
for request (SF 1080). Final project payments for specific contracts and in-house cost shall be reviewed
and approved by the EPA Regional program office.
2. EPA will hold titie to all property acquired with Superfund monies. EPA will provide the USAGE the
property disposition instructions upon termination of the IAG. EPA will receive fair-market value for any
property disposed of or used for non-Superfund activities.
D-16
-------
Appendix D * Model RD, RA, and Technical Assistance lAGs
Decision Memorandum
Regional Superfund Interagency Agreement for Technical Assistance
SUBJECT: Superfund Interagency Agreement with the U.S. Army Corps of
Engineers (USAGE)
TO:
Regional Administrator, Region.
FROM:
I recommend that you, as the EPA Action Official, approve and sign the attached Interagency
Agreement (IAG). Under the IAG, the USAGE will provide EPA with technical assistance
during EPA lead phases of remedial response activities.
The USAGE will provide specialized support services to EPA. It may also utilize extramural
agreements to carry out the Scope of Work.
The lAG's project (site) activities and provisions are in compliance with the following statutory
and EPA policy requirements:
1) Statutory - Economy Act of 1932, as amended (31 USC 1535)
- CERCLA, as amended (42 USCA 9601 et seq.)
2) Policy - Executive Order 12580
- EPA IAG Policy and Procedures Compendium
- Chapter 51. "Managing lAGs". EPA Assistance Administration Manual
-SCAP
- Memorandum of Understanding
NOTE: If an "increase-in-funds" amendment, add:
The increase in funds will cover costs for additional sites and activities related to the original
Scope of Work under the IAG. These activities are necessary to maintain the progress towards
the successful completion of the SCAP.
D-17
-------
RD/RA Handbook
Model for USAGE Technical Assistance
United States E
®EPA Inter
Part
jivironmentat Protection Agency
Washington, DC 20460
agency Agreement/
Amendment
1 - General Information
6, Name and Address of EPA Organization
(Regional Address]
1. EPA IA6 Identification Number
nwqfi
2. Other Agency IAG ID Number (if
3. Type of Action
New Agreement
4. Funding Location by
Region
known) LAS appropriate]
5. Program Office
[As appropriate]
7. Name and Address of Other Agency
U.S. Army Corps of Engineers (USAGE)
Engineering Division, Missouri River
Omaha, Nebraska 68144-3869
8. Project Title
Design of Superfund Remedial Action at [site name, city, and state]
9. EPA Projact Officer (Name, Address, Telephone Number)
[Regional Project Officer]
U.S. Environmental Protection Agency
[Regional Address]
[Telephone Number]
11. Project Period
10. Other Agency Project Officer (Name, Address, Telephone Number)
U.S. Army Engineer, Missouri River Division
ATTN: Lucy Harris
12565 West Center Road
Omaha, NE 68144-3869 (402)697-2422
12. Budget Period [game as prQJect perjod]
13, Scope of Work (Attach additional sheets, as needed)
1 . Reviewing work plans developed by EPA contractors and providing comments and suggestions
on the proposed work
2. Technical review of remedial investigation/feasibility study.
3. Providing comments on all plans and specifications for the cleanup.
4. Attending status briefings. The USAGE will participate in site-specific status briefings whenever
such meetings are deemed necessary by the Regional Project Officer.
5. Reviewing other EPA contractor products. These products may include such things as sampling
plans, plans and specifications for drum and bulk waste removal, and draft and final reports on
the remedial investigation or the feasibility study.
14. Statutory Authority for Both Transfer of Funds and Project Activities 15. Other Agency Type
CERCLA as amended (42 USCA 9601 et seq.) Executive Order 12580 and Economy Federal
Act of 1 932 as amended (3 1 USC 1535)
Funds
17. EPA In-Kind Amount
18. Other Agency Amount
19. Olrtw Agency In-Kind Amount
SO. Tolal Project Cost
21. Fiscal Information
Previous Amount
Amount This Action
Program Etement FY Appropriation Doc. Control No.
FAY9A 94 68/20X8145
Amended Total
Account Number Object Obligation/Deobligation Amt.
Class
25.76
EPA Form 1610-1 (Rev. 10-88) Previous editions are obsolete.
51-043-43(1 )A)
D-18
-------
Appendix D • Model RD, RA, and Technical Assistance lAGs
Model for Technical Assistance (cont.)
Part II - Approved Budget
EPAIAG Identification Number
DW
22. Budget Categories
Itemization of
This Action
Itemization of Total Project
Estimated Cost to Date
(a) Personnel
(b) Fringe Benefits
(o) Travel
(d) Equipment
(e) Supplies
(f) Procurement/Assistance
(g) USAGE Division Costs
(h) Omar
(i) Total Direct Charges
Q) Indirect Cost:
Rate:
Base$
(k) Total
(EPA Share 100%)
(Other Agency Share 0%)
$
23. Is equipment authorized to be furnished by EPA or leased, purchased, or rented with EPA funds?
(Identify all equipment costing $1,000 or more)
See Special Conditions, Item 28 regarding documentation and disposition
No
24. Are any of these funds being used on extramural agreements? (See 'item 22f)
X Yes
No
Type of Extramural Agreement
Grant
n
Cooperative Agreement
Procurement (Includes Small Purchase Order)
Contractor/Recipient Name (if known)
Unknown
Total Extramural Amount Under This Project
[estimate]
Percent Funded by EPA (if known)
100
Part III - Funding Methods and Billing Instructions
25.
X | Funds-Out Agreement
I X I Disbursement Agreement
(Note: EPA Agency Location Code (ALC) - 68010727)
X I Repayment Request for repayment of actual costs must be itemized on SF 1081 or SF 1080 and submitted to the
__J Financial Management Center, EPA, Cincinnati, OH 45268:
X Monthly
Quarterly
Upon Completion of Work
Advance
Only available for use by Federal Agencies on working capital fund or with appropriate justification of
need for this type of payment method. Unexpended funds at completion of work will be returned to
EPA. Quarteriy cost reports will be forwarded to the Financial Management Center, EPA, Cincinnati,
OH 45268.
Used to transfer obligational authority or transfer of function between Federal agencies. Must receive
Allocation prior approval by the Office of the Comptroller, Budget Division, Budget Formulation and Control Branch,
I 1 Transfer-Out EPA Headquarters. Forward appropriate reports to the Financial Reports and Analysis Branch, Financial
Management Division, PM-226F, EPA, Washington D.C. 20460.
26.
I I Funds-ln Agreement
| j Reimbursement Agreement
n
Repayment
Advance
Allocation Transfer-In
Other Agency's IAG Identification Number
EPA Program Office Allowance Holder/Responsibility Center Number
72E
Other Agency's Billing Address (Include Agency Location Code
or Station Symbol Number)
Other Agency's Billing Instructions and Frequency
EPA Form 1610-1 (Rev. 10-88)
51-043-43(2)A
D-19
-------
B'll":!!1: I " I."1!!1
RD/RA Handbook
Model for Technical Assistance (cont.)
Part IV - Acceptance Conditions
EPA IAQ Identification Number
DW96
27. General Conditions
The olher agency covenants and agrees that it will expeditiously initiate and complete the project for which funds
have been awarded under this agreement.
28. Special Conditions (Attach additional sheets if needed)
(See Attachment A)
Part V - Offer and Acceptance
Nota:1)For Funds-out actions, the agreement/amendment must be signed by the other agency official in duplicate and one
original returned to the Grants Administration Division for Headquarters agreements or to the appropriate EPA Regional
IAG administration office within 3 calendar weeks after receipt or within any extension of time as may be granted by EPA.
The agreement/amendment must be forwarded to the address cited in Item 29 after acceptance signature.
Receipt of written refusal or failure to return the properly executed document within the prescribed time may result in the
withdrawal of the offer by EPA. Any change to the agreement by the other agency subsequent to the document being
signed by the EPA Action Official, which the Action Official determines to materially alter the agreement/amendment,
shall void the agreement/amendment.
2) For Funds-in actions, the other agency will initiate the action and forward two original agreements/amendments to the
appropriate EPA program office for signature. The agreements/amendments will then be forwarded to the appropriate
EPA IAG administration office for acceptance signature on behalf of the EPA. One original copy will be returned to the
other agency after acceptance.
EPA IAG Administration Office (for administrative assistance)
29. Organization/Address
(EPA IAG Administration Office]
[Organization/Address]
EPA Program Office (for technical assistance)
30. Organization/Address
[EPA Program Office]
[Organization/Address]
Certification
All signers certify that the statements made on this form and all attachments thereto are true, accurate, and complete. Signers
acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or both under
applicable law.
Decision Official on Behalf of the Environmental Protection Agency Program Office
31. Signature
Typed Name and Title
Date
Action Official on Behalf of the Environmental Protection Agency
32. Signature
Typed Name and Title
Date
Authorizing Official on Behalf of the Other Agency
33. Signature
Typed Name and Title
Date
EPA Form 1610-1 (Rev. 10-88)
51-043-43(3)
D-20
-------
Appendix D • Model RD, RA, and Technical Assistance (AGs
Attachment A • Special Conditions for Technical Assistance
The USAGE agrees to meet the site-specific financial management and recordkeeping responsibilities con-
tained in EPA's "Superfund Financial Management and Recordkeeping Guidance for Federal Agencies"
(Draft August 1988).
1. Cost Documentation Requirements
EPA acting as manager of the Hazardous Substances Superfund requires current information on
CERCLA response actions and related obligations of CERCLA funds for these actions. In addition,
CERCLA, as amended , authorizes EPA to recover from responsible parties all government costs
incurred during a response action. In order to help ensure oversight and successful recovery of CERCLA
funds, both the USAGE and EPA have responsibilities under this agreement. The USAGE accounting
system reports must be supported by site- and activity-specific cost documentation. The USAGE will
organize and retain in site file(s) documentation of costs by site and activity (e.g. vouchers, billing
statements, evidence of payment, audit reports) as follows:
a. Direct Costs
Payroll - timesheets or timecards to support hours charged to a particular site, including
the signature of the employee and/or the employee's supervisor.
Travel - travel authorizations (including purpose of trip), local travel vouchers,
traveler's reimbursement vouchers, carrier bills, (including airline tickets), government
owned vehicle bills, appropriate receipts for hotel, car rental, etc., proof of payment.
Proof of payment is satisfied by providing a copy of the accomplished SF1166
"Voucher and Schedule of Payment" or equivalent. »
Contractor services - copies of contracts, requests for proposals (RFPs), detailed
evaluation of contractor bids, contractor invoices, USAGE project officer approval of
invoices, proof of payment. Proof of payment is satisfied by providing a copy of the
accomplished SF1166 or equivalent.
Supplies and Equipment - EPA authorization to purchase non-expendable property of
$1,000 or more, vendor invoices, proof of payment, and hourly records of equipment
use, when applicable.
Any other direct costs not included in the above categories.
b. Indirect Costs
If indirect costs are not calculated by the USAGE accounting system, a worksheet showing
calculations of indirect costs charged to site(s) will be retained by the USAGE.
Under this IAG, the USAGE certifies: 1) that any indirect costs included in billings to EPA
represent, in accordance with GAO principles, indirect costs that would not have been
otherwise incurred by the USAGE, or 2) that explicit Congressional authority exists for
charging other incremental costs of performance.
D-21
-------
RD/RA Handbook
, ' |!i ' I!
2. Reporting Requirements
a. The USAGE will provide monthly progress reports to the Regional Project Officer and the
Chief of the Design and Construction Management Branch (OS-220), EPA, Washington, DC,
20460, containing:
f! ' ' ' 1
Site name and TAG number
Summary of work performed
• Estimate of the percentage of project completed
• Accounting of funds expended during the reporting period and on the project to date,
Which includes budget category cost breakdown
Summaries of all problems or potential problems encountered during the reporting
period
Projected work for the next reporting period
b. The USAGE will provide the EPA Financial Management Center, Cincinnati, with a com-
pleted and signed SF1080 (request for reimbursement) monthly containing, as appropriate:
USAGE costs by budget category identified by the site, site-specific account number, and
IAG number.
c. USAGE will provide a final inventory of property, within 30 days of project completion,
describing the condition of each item and requesting disposition instructions. If the duration
of the project is greater than one year, USAGE will provide an annual inventory of all
property acquired by or furnished to USAGE with EPA funds.
3. Cost Recovery
!i ' • ',*' '•! |.
In the event of a contemplated cost recovery action, the USAGE will provide to EPA or the Depart-
ment of Justice (DOJ) a cost documentation package detailing site-specific costs and including copies
of the back up documentation. In some cases, these requests from EPA or DOJ may require that this
documentation be provided in less than thirty days. If additional time is required to comply with a
request, USAGE will negotiate with EPA and DOJ a schedule for responding. USAGE will provide
EPA with a contact for obtaining necessary site-specific accounting information and documentation.
4. Record Retention Requirements
The USAGE and its contractors will retain the documents described in these "Special Conditions" for
a minimurn of six years after submission of a final SF1080 for a site or sites, after which the USAGE
and its contractors must obtain written permission from the appropriate regional award official before
disposing of any of the records.
5, Audits
a. Certain agencies are required by CERCLA, as amended, to perform annual audits of transac-
tions involving the Superfund. The USAGE may also be required to perform annual audits.
Cost documentation information must be available for audit or verification upon request of
the DOD Inspector General.
D-22
-------
Appendix D • Model RD, RA, and Technical Assistance lAGs
b. If an audit determines that any direct or indirect costs charged to EPA are unallowable, EPA
will be notified immediately following the resolution of the audit and EPA will be credited
with those costs.
6. Other EPA Involvement
a. EPA's substantial involvement in this IAG will include reimbursement to the USAGE contin-
gent upon:
Receipt and approval by the EPA regional program office of the monthly progress
reports and any other technical reports described in the Scope of Work.
Acceptance and approval of requests for reimbursement (SF1080) by the authorized
representatives of the EPA regional program office and the EPA regional IAG adminis-
tration office (optional).
b. EPA will hold title to all property acquired with Superfund monies. EPA will provide the
USAGE with property disposal instructions upon termination of the IAG and receive fair-
market value for any property disposed of or used for non-Superfund activities.
D-23
-------
-------
AppendkE
Model RD, RD Oversight, RA, andRA
Oversight SOWs
-------
-------
(date)
MODEL STATEMENT OF WORK FOR REMEDIAL DESIGN
SITE, COUNTY, STATE
ATTACHMENTS
Attachment 1. Summary of Major Submittals for the Remedial Design at (Site) 24
Attachment 2. Work Breakdown Structure 28
Attachment 3. Regulation and Guidance Documents _ 34
Attachment 4. Transmittal of Documents for Acceptance by EPA 36
Attachment 5. Transmittal Register 37
Points for the Work Assignment Manager or Remedial Project Manager (WAM/RPM) to consider in
preparing the Statement of Work (SOW) for Remedial Design (RD):
The purpose of this SOW is twofold:
1. To tell the contractor what you want done. Be as specific as possible in describing what you want
the contractor to do. The contractor will write a work plan and budget describing how and at what cost the
requirements will be met and ultimately will be responsible for performing those requirements. Whenever
there is an absolute requirement (e.g., prepare the Quality Assurance Project Plan (QAPP) in accordance
with QAMS-005/80 (December 29, 1980)), state it. Add the attachments to the SOW: (1) Summary of
Major Submittals for the Remedial Design at (Site), (2) Work Breakdown Structure, and (3)
Transmittal of Documents for Acceptance by EPA.
2. To give the contractor a work breakdown structure for recording costs. In this manner, work plan
costs and final costs of different remedial design projects can be compared and analyzed.
Use of a Work Breakdown Structure (WBS)
1. A WBS has been developed for this model work assignment for EPA to track the initial and final costs
of each element used for preparing future cost estimates and to share this data with other Federal agencies.
The WBS is, essentially, the outline for this work assignment and is included as Attachment 2 to the SOW.
2. If an element is not to be used, do not change the numbering system: instead, insert "not used" or
"N/A" after the element number after deleting the text for that element.
3. For the items used for a given project, additional descriptions (e.g., type of samples and estimated
number) should be added in order for the contractor and WAM/RPM to develop estimated costs on a
common basis
3.0 Introduction
.0.1 Site Description
Provide a brief site description and site history.
.0.2 Purpose
The purpose of this Statement of Work (SOW) is to set forth the requirements for the Remedial
Design (RD) of the selected remedy as defined in the Record of Decision (ROD) issued on
Model RD SOW (6/95)
-------
'I
(date). The RD is generally defined as those activities to be undertaken by the
contractor to develop the final plans and specifications, general provisions, and special
requirements necessary to translate the ROD into the remedy to be constructed under the remedial
action (RA) phase. The RA is generally defined as the implementation phase of site remediation or
construction of the remedy, including necessary operation and maintenance, performance
monitoring, and special requirements. The RA is based on the RD to achieve the remediation goals
specified in the ROD. This SOW is designed to provide the framework for conducting the RD
activities at (site). The goal is to complete and deliver the final plans and
specifications within months after approval of the work plan. The estimated completion
date for this work assignment is .
.0.3 General Requirements
.0.3.1 The contractor shall conduct the RD in accordance with this SOW arid consistent with the
ROD issued on (date), the Remedial Design/Remedial Action (RD/RA)
Handbook (U.S. EPA Office of Solid Waste and Emergency Response (OSWER), 9355.0-
04B, EPA 540/R-95/059, June 1995), and all other guidance used by EPA in conducting
an RD. The primary contact for this work assignment is , Tel. ; the
secondary contact is ; Tel. .
,0.3.2 A summary of the major deliverables and a suggested schedule for submittals are attached
(Attachment 1). The contractor shall submit the major deliverables using the form
Transmittal of Documents for Acceptance by EPA. Attachment " .
The attachments to this model SOW may be copied and completed for a given RD. Attachment 4 is a form
for use by the contractor in the transmittal of documents to EPA and should be an attachment to the
completed SOW. Attachment 5 is a transmittal register log for use by the WAM/RPM in tracking
documents submitted by the contractor.
.0.3,3 Specifically, the RD involves the design of .
.0.3.4 The contractor shall furnish all necessary and appropriate personnel, materials, and
services needed for, or incidental to, performing and completing the RD.
.0.3.5 A list of primary guidance and reference material is attached (Attachment 3). In all cases,
the contractor shall use the most recently issued guidance.
.0.3.6 The estimated cost of the RA, as outlined in the ROD, is $ .
.0.3 ?7 The contractor shall communicate at least weekly with the Work Assignment Manager or
Remedial Project Manager (WAM/RPM), either in face-to-face meetings or through
conference calls.
.0.3.8 The contractor shall notify the WAM/RPM when 75 percent of the approved work
assignment budget has been expended and when 95 percent has been expended.
.0.3.9 The contractor shall document all decisions that are made in meetings and conversations
With EPA. The contractor shall forward this documentation to the WAM/RPM within two
• ; working days of the meeting or conversation.
It is the WAM's responsibility to document fully all decisions made. The contractor's documentation is
used for confirmation only. ||
; i ' ,:: . ; • • i
.0.3.10 EPA will provide oversight of contractor activities throughout the RD. EPA review and
approval of deliverables is a tool to assist this process and to satisfy, in part, EPA's
responsibility to provide effective protection of public health, welfare, and the
environment. EPA will review deliverables to assess the likelihood that the RD will
achieve its remediation goals and that its performance and operations requirements have
been correctly identified. Acceptance of plans and specifications by EPA does not relieve
the contractor of responsibility for the adequacy of the design.
.0.4 Record-Keeping Requirements
Model RD SOW (6/95)
-------
The contractor shall maintain all technical and financial records for the RD hi accordance with the
contract. At the completion of the RD, the contractor shall submit copies of the official
record of the RD in (format) to the WAM/RPM.
1. Technical and financial records must support decisions made during the RD as well as cost recovery.
2. Check with the Regional Records Manager and with Regional Counsel regarding the distribution,
number of copies, and preferred format (i.e., hard copy, microform, CD-ROM) for the official records of
the RD.
.0.5 Equipment Transfer
At the completion of the RD work assignment, the contractor shall transfer to the EPA Equipment
Coordinator all equipment purchased with contract funds in accordance with the contract.
.0.6 Project Closeout
At the completion of the RD work assignment, the contractor shall perform all necessary project
closeout activities as specified in the contract. These activities may include closing out any
subcontracts, indexing and consolidating project records and files as required in Paragraph 0.4
above, and providing a technical and financial closeout report to EPA. Final costs shall be
reported to EPA (on disk) broken down into the cost for each element of the Work Breakdown
Structure (WBS) (Attachment 2) for this work assignment.
3.1 Project Planning and Support
The purpose of this task is to determine how the site-specific remediation goals, as specified in the ROD,
will be met. The following activities shall be performed as part of the project planning task:
.1.1 Project Planning
.1.1.1 Attend Scoping Meeting. Before or concurrent with developing the Work Plan, the
contractor shall attend a scoping meeting to be held at the EPA Regional Office.
Location of meetings and RPM expectations for the number of contractor personnel to attend should be
specified for cost estimation purposes.
.1.1.2 Conduct Site Visit. The contractor shall conduct a site visit with the EPA WAM/RPM
during the project planning phase to assist in developing a conceptual understanding of the
RD requirements for the site. Information gathered during the visit shall be used to better
scope the project and to help determine the extent of additional data necessary to
implement the RD. A Health and Safety Plan (HASP) is required for the site visit. The
contractor shall prepare a report that documents all EPA, contractor, and site personnel
present at the visit; all decisions made during the visit; any action items assigned,
including person responsible and due date; any unusual occurrences during the visit; and
any portions of the site that were not accessible to the contractor and the effect of this on
the RD. This report shall be submitted to the EPA WAM/RPM within 10 calendar days of
the site visit.
.1.1.3 Evaluate Existing Information. The contractor shall obtain, copy (if necessary), and
evaluate existing data and documents, including the Remedial Investigation/Feasibility
Study (RI/FS), the ROD, and other data and documents as directed by EPA. This
information shall be used to determine if any additional data are needed for RD
implementation. The documents available for review are listed in Attachment
Model RD SOW (6/95)
-------
The WAM/RPM will create an attachment to this SOW. Additional documents to list in the attachment
could include the summary of the "Information Collection" effort (see Chapter 3 of the Guidance for
Scoping the Remedial Design), Focused Feasibility Studies (FFSs), State documentation, hydrogeological
information, and RPM file data. However, to control expenses, limit review to pertinent documents
specific to the site.
.1.1.4 Develop Work Plan. The contractor shall present the general approach that will be used
for the RD at a Work Plan scoping meeting with the WAM/RPM. This meeting will be
held at the Region office.
If the RD will be complex, consider modifying subtask 3.1.1.4(1) to include a scoping meeting. A scoping
meeting held before the contractor finalizes the technical approach ensures that the government and the
contractor agree on the approach to be taken and that the work plan reflects the agreed-upon approach. The
contractor may not have to rewrite the work plan if this is done.
(1) Develop Draft Work Plan. The contractor shall prepare and submit a draft RD Work
Plan within 30 calendar days after Work Assignment (WA) initiation. The contractor
submits the original to the Contracting Officer (CO), one copy to the Project Officer
(PO), and one copy to the WAM/RPM. The Work Plan shall include a comprehensive
description of the additional data collection and evaluation of activities to be
performed, if any, and the plans and specifications to be prepared. A comprehensive
design management schedule for completion of each major activity and submittal shall
also be included. The Work Plan shall be developed in conjunction with the Sampling
and Analysis Plan (SAP) and HASP, although each plan shall be delivered under
separate cover within 30 days after WA initiation.
1. The submittal requirements in this SOW must be in accordance with the submittal requirements for the
contract.
2. An independent government cost estimate (IGCE) for the RD must be prepared before the work
assignment (WA) is issued to the contractor.
3. Verify the work plan submittal timeframe with the PO.
4. Additional copies of the work plan can be submitted to the WAM/RPM, if specified, for distribution to
other technical staff.
(a) Develop Narrative. Specifically, the Work Plan shall present the following:
- A statement of the problem(s) and potential problem(s) posed by the site and
how the objectives of the RD will address the problem(s).
- A background summary setting forth: (1) a brief description of the site
including the geographic location and a description of the physiographic,
hydrologic, geologic, demographic, ecological, cultural, and natural resource
features of the site; (2) a brief synopsis of the history of the site including a
summary of past disposal practices and a description of previous responses that
have been conducted by local, State, Federal, or private parties at the site; (3)
a summary of the existing data including physical and chemical characteristics
of the contaminants identified and their distribution among the environmental
media at the site.
- The contractor's technical and management approach to each task to be
performed, including a detailed description of each task; the assumptions used;
Model RD SOW (6/95)
-------
the identification of any technical uncertainties (with a proposal for the
resolution of those uncertainties); the information needed for each task; any
information to be produced during and at the conclusion of each task; and a
description of the work products that will be submitted to EPA. The
contractor shall identify any subcontractors it plans to use to accomplish all or
part of a task's objectives. Tasks and subtasks shall be presented in the same
WBS format as provided in this work assignment.
A schedule for specific dates for the start and completion of each required
activity and submission of each deliverable required by this SOW. (See
Attachment 1 for format.) This schedule shall also include information about
timing, initiation, and completion of all critical p;ath milestones for each
activity and deliverable and the expected review time for EPA.
For schedule development, the WAM/RPM should indicate to the contractor whether design activity will
continue concurrent with EPA design review or whether work will stop until the contractor receives design
review comments. In deciding which to prescribe, weigh the trade off between the cost of possible rework
versus a shortened schedule.
(b) Develop Cost Estimate. The contractor's estimated cost to complete the work
assignment shall be broken down into the Level of Effort (by P-level) and cost for
each element of the Work Breakdown Structure (Attachment 2) and submitted to
EPA on disk.
(c) Internal QA and Submission of Draft Work Plan.
(2) Prepare Final Work Plan
(a) Attend Negotiation Meeting. The contractor shall attend a Work Plan negotiation
meeting at the Region office.
(b) Modify Draft Work Plan and Cost Estimate. If the contractor finds that the
remedial action being designed differs significantly from the ROD or that an
ARAR cannot be met, the contractor shall describe the issue and recommend
technical solutions in a memo to the WAM/RPM. The contractor shall make
revisions to the Work Plan as a result of EPA's comments and/or negotiation
agreements. The final work plan shall be submitted within 15 days after receipt of
EPA comments.
(c) Internal QA and Submission of Final Work Plan.
. 1.2 Preparation of Site-Specific Plans
.1.2.1 Develop Site Management Plan. After EPA approval of the RD Work Plan, the contractor
shall prepare a Site Management Plan (SMP) that provides EPA with a written
understanding of how access, security, contingency procedures, management
responsibilities, and waste disposal are to be handled.
(1) Develop Pollution Control and Mitigation Plan
(2) Develop Transportation and Disposal Plan (Waste Management Plan)
.1.2.2 Develop Health and Safety Plan. Prepare a site-specific HASP that specifies employee
training, protective equipment, medical surveillance requirements, standard operating
procedures, and a contingency plan in accordance with [40 CFR 300.150 of the NCP and]
29 CFR 1910.120 1(1) and (1)(2). Whenever possible, refer to the HASP developed for
the RI/FS when preparing the HASP for the RD. A task-specific HASP must also be
prepared to address health and safety requirements for site visits.
.1.2.3 Develop Sampling and Analysis Plan (Chemical Data Acquisition Plan)
(1) Quality Assurance Project Plan. The contractor shall prepare a Quality Assurance
Project Plan (QAPP) hi accordance with EPA QA/R-5 (latest draft or revision). The
QAPP shall describe the project objectives and organization, functional activities, and
quality assurance/quality control (QA/QC) protocols that shall be used to achieve the
desired Data Quality Objectives (DQOs). The DQOs shall, at a minimum, reflect use
of analytical methods for identifying contamination and addressing contamination
5 Model RD SOW (6/95)
-------
consistent with the levels for remedial action objectives identified in the National
Contingency Plan. The QAPP developed for the RI/FS should be referenced or
adapted whenever possible when preparing the QAPP for the RD.
(2) Field Sampling Plan. Prepare a Field Sampling Plan (FSP) that defines the sampling
and data collection methods that shall be used for the project. The FSP shall include
sampling objectives; sample locations and frequency; sampling equipment and
procedures; sample handling and analysis; and a breakdown of samples to be analyzed
through the Contract Laboratory Program (CLP) and through other sources, as well as
the justification for those decisions. The FSP shall consider the use of all existing data
and shall justify the need for additional data whenever existing data will meet the same
objective. The FSP shall be written so that a field sampling team unfamiliar with the
site would be able to gather the samples and field information required. The FSP
developed for the RI/FS must be referenced or adapted whenever possible when the
FSP is prepared for the RD; the contractor shall document any required changes to the
; FSP in a memorandum to the WAM/RPM. '
1. Depending on the complexity of the sampling effort needed to support the RD, the FSP and QAPP can
be combined into a single Sampling and Analysis Plan (SAP).
2. Minimize the duplication of data collection by requiring the contractor to use existing data whenever
practicable. Contractors tend to "mistrust" data collected by others regardless of the quality. Limiting date
collection can shorten the design period.
3. Reduce time and costs by using an on-site laboratory to analyze routine samples rather than going
through the CLP.
4. Identify whether audits will be performed and specify contractor response items.
(3) Data Management Plan
(4) Develop Other Plan(s)
. 1.3 Project Management
.1.3.1 Prepare Periodic Status Reports. The contractor shall prepare Monthly Progress Reports.
(1) Document Cost and Performance Status. The contractor shall document the status of
! each task and report costs and level of effort (by P-level) expended to date.
(2) Prepare and Submit Invoices
.1.3.2 Meeting Participation and Routine Communications. The contractor shall attend project
meetings, provide documentation of meeting results, and shall contact the WAM by
telephone on a weekly basis to report project status.
.1.3.3 Perform Engineering Network Analysis
.1.3.4 Manage, Track, and Report Equipment Status. The contractor shall manage, track, and
report the status of all site-specific equipment.
.1.3.5 Work Assignment Closeout
The RPM/WAM should specify the format for submissions (e.g., Monthly Progress Reports) if there are
Region-specific requirements or other specific requirements.
__ -
.1.4 Subcontract Procurement and Support Activities
.1.4.1 Identification and Procurement of Subcontractors. Procure and administer the necessary
subcontracts, including, but not limited to the following:
XI) Drilling Subcontractor
(2) Surveying Subcontractor
(3) Geophysical Subcontractor
Model RD SOW (6/95)
-------
(4) Site Preparation Subcontractor
(5) Analytical Services Subcontractors)
(6) Waste Disposal Subcontractor
(7) Treatability Subcontractor(s)
(8) Other(s)
.1.4.2 Establish and Carry Out a QA Program for Subcontracts
.1.4.3 Perform Subcontract Management
3.2 Community Relations
The contractor shall provide community relations support to EPA throughout the RD. The contractor
shall provide community relations support in accordance with Community Relations in Superfund: A
Handbook, June 1988. Community relations shall include the following subtasks:
Listed below are a number of possible community relations activities the RPM/WAM may require
.2.1 Develop Community Relations Plan (CRP)
The contractor shall develop an RI/FS CRP to address community relations requirements during the
RD. This CRP may be modified from an existing CRP to meet site-specific requirements.
.2.1.1 Conduct Community Interviews
.2.1.2 Prepare the CRP
(1) Draft CRP
(2) Final CRP
.2.2 Prepare Fact Sheets
The contractor shall prepare a fact sheet that informs the public about activities related to the final
design, a schedule for the RA, activities to be expected during construction, provisions for
responding to emergency releases and spills, and any potential inconveniences such as excess traffic
and noise that may affect the community during the RA.
.2.3 Public Hearing, Meetings, and Availability Support
The contractor shall support and assist in public hearings, meetings, and open houses. The
contractor shall prepare presentation materials and provide support as needed for public meetings.
1. The number and location of anticipated public meetings should be identified in the SOW.
2. The RPM should specify the number of contractor personnel expected to attend the public meetings
.2.3.1 Technical Support. The contractor shall provide technical support for community
relations. This support may include preparing technical input to news releases, briefing
materials, and other community relations vehicles, and helping the WAM/RPM to
coordinate with local agencies.
.2.3.2 Logistical and Presentation Support
.2.3.3 Public Notice Support
.2.4 Maintain Information Repository and Mailing Lists
The contractor shall develop or revise site mailing lists and maintain a repository of information on
activities related to the site-specific remedial design as described in Appendix A.8, page A-19, of
Community Relations in Superfund: A Handbook, June 1988.
The RPM/WAM should specify the format for Community Relations submissions (e.g., fact sheets, news
releases) if there are Region-specific requirements or other specific requirements.
Model RD SOW (6/95)
-------
3.3 Data Acquisition
Data acquisition entails collecting environmental samples and information required to support the RD.
The planning for this task is accomplished in Task 3.1, Project Planning and Support, which results in the
plans required to collect the field data. Data acquisition starts with EPA's approval of the FSP and ends
with the demobilization of field personnel and equipment from the site.
. '*' /'I , i •• '. :< , , i.'j
The contractor shall perform the following field activities or combination of activities for data acquisition
in accordance with the EPA-approved FSP and QAPP developed in Task 3.1.
Before beginning field activities, consider specifying a kickoff meeting with all principal personnel to clarify
objectives, communication channels, etc., to ensure the efficient use of available funds.
.3.1 Mobilization and Demobilization
Provide the necessary personnel, equipment, and materials for mobilization and demobilization to
and from the site for the purpose of conducting the sampling program under subtask 3.3.2, Field
Investigation.
,3 .,1.1 Identify Field Support Equipment, Supplies, and Facilities
.3.1.2 Mobilization. Mobilize and set up a field laboratory to facilitate rapid turnaround times
for analytical results and identification of sample locations for subsequent sampling rounds.
(1) Site Preparation
(a) Perform Demolition
(b) Clearing and Grubbing
(c) Perform Earthwork
- Provide Borrow Pit
- Construct Haul Roads
- Construct Roads, Parking, Curbs, and Walks
Install Storm Drainage and Subdrainage
- Install Fencing and Site Security
(2) Installation of Utilities
(a) Install Electrical Distribution
(b) Install Telephone and Communication System(s)
(c) Install Water, Sewage, and Gas Distribution
(d) Install Fuel Line Distribution
(3) Construction of Temporary Facilities
(a) Construct Decontamination Facilities
(b) Construct Sample and Derived Waste Storage Facility
(c) Construct Field Offices
(d) Construct Mobile Laboratory
(e) Construct Other Temporary Facilities
.3.1.3 Demobilization. Demobilize the field laboratory.
(1) Removal of Temporary Facilities
(2) Site Restoration
.3.2 Field investigation. Conduct environmental sampling to include the following:
.3.2.1 Perform Site Reconnaissance. The contractor shall conduct site surveys including
property, boundary, utility rights-of-way, and topographic information. These surveys are
to refine the survey data from the RI/FS and to ensure the accuracy of the information for
theRD.
For items of this Model Statement of Work that are not needed for a given project, please retain the
numbers for the items, but enter "Not Used" or "N/A" after the numbers of those items.
For the items used for a given project, additional descriptions (e.g., type of samples and estimated number)
should be added in order for the contractor and RPM/WAM to develop estimated costs on a common basis.
Model RD SOW (6/95)
-------
(1) Ecological Resources Reconnaissance
(a) Well Inventory
(b) Residential Well Sampling
(c) Land Survey
(d) Topographic Mapping
(e) Field Screening
.3.2.2 Conduct Geological Investigations (Soils and Sediments)
(1) Collect Surface Soil Samples
(2) Collect Subsurface Soil Samples
(3) Soil Boring and Permeability Sampling
(4) Collect Sediments Samples
(5) Survey Soil Gases
(6) Test Pit
.3.2.3 Conduct Air Investigations
(1) Sample Collection
(2) Air Monitoring Station
.3.2.4 Conduct Hydrogeological Investigations: Ground Water
(1) Install Well Systems
(a) Accomplish Mobilization
(b) Develop Wells
(c) Conduct Downhole Geophysics
(d) Install Monitoring Wells
(e) Install Test Wells
(f) Install Gas Wells
(2) Collect Samples
(3) Collect Samples During Drilling (e.g., HydroPunch or Equivalent)
(4) Conduct Tidal Influence Study
(5) Perform Hydraulic Tests (Pump Tests)
(6) Measure Ground-Water Elevation
.3.2.5 Conduct Hydrogeological Investigations: Surface Water
(1) Collect Samples
(2) Study Tidal Influence
(3) Measure Surf ace-Water Elevation
.3.2.6 Conduct Waste Investigation
(1) Collect Samples (Gas, Liquid, Solid)
(2) Dispose of Derived Waste (Gas, Liquid, Solid)
.3.2.7 Conduct Geophysical Investigation
(1) Surface Geophysical Activity [can just list these]
(2) Magnetometer
(3) Electromagnetics
(4) Ground-Penetrating Radar
(5) Seismic Refraction
(6) Resistivity
(7) Site Meteorology
(8) Cone Penetrometer Survey
(9) Remote Sensor Survey
(10) Radiological Investigation
.3.2.8 Conduct Ecological Investigation
(1) Wetland and Habitat Delineation
(2) Wildlife Observations
(3) Community Characterization
(4) Identification of Endangered Species
(5) Biota Sampling and Population Studies
.3.2.9 Collect Contaminated Building Samples.
Model RD SOW (6/95)
-------
.3.2.10 Dispose of Investigation-Derived Waste. Characterize and dispose of investigation-derived
wastes hi accordance with local, State, and Federal regulations as specified in the FSP (see
the Fact Sheet, Guide to Management of Investigation-Derived Wastes, 9345.3-03FS
(January 1992)).
1. The WAM/RPM must determine the types of sampling that will be needed and select from the list
above.
2. The numbers of samples anticipated should be specified so that both the contractor and the WAM/RPM
can develop the cost estimates.
3. The WAM/RPM should consult with the Technical Review Team to determine the types and numbers of
samples to be collected. The numbers may be refined upon negotiation with the contractor.
4. The WAM/RPM should specify the expected written and/or photographic documentation to be recorded
in the field.
5. The WAM/RPM should specify the type of field activity reports that are expected, the frequency, and
required distribution (RPM, State representative, etc.).
3.4 Sample Analysis
I
The contractor shall arrange for the analysis of environmental samples collected during the previous task.
The sample analysis task begins with reserving sample slots in the CLP and the completion of the field
sampling program. This task ends with the contractor validating the analytical data received from the
laboratory.
1. The RPM/WAM should consider adding a subtask for on-site laboratory analysis. The purpose of this
new subtask would be to perform screening analyses only.
2. If special analytical services (SAS) are required, they must be specified in a subtask.
The contractor shall perform the following activities or combination of activities to analyze test results:
.4.1 Screening-Type Laboratory Sample Analysis
.4.1.1 Analyze Air and Gas Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.2 Analyze Ground-Water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.3 Analyze Surface-Water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.4 Analyze Soil and Sediment Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.5 Analyze Waste (Gas) Samples
(1) Organic
(2) Inorganic
10
Model RD SOW (6/95)
-------
(3) Radiochemistry
.4.1.6 Analyze Waste (Liquid) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.7 Analyze Waste (Solid) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.8 Analyze Biota Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.9 Analyze Bioassay Samples
.4.1.10 Perform Bioaccumulation Studies
.4.2 CLP-Type Laboratory Sample Analysis
.4.2.1 Analyze Air and Gas Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.2 Analyze Ground-Water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.3 Analyze Surface-Water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.4 Analyze Soil and Sediment Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.5 Analyze Waste (Gas) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.6 Analyze Waste (Liquid) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.7 Analyze Waste (Solid) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.8 Analyze Biota Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.9 Analyze Bioassay Samples
.4.2.10 Perform Bioaccumulation Studies
3.5 Analytical Support and Data Validation
The contractor shall arrange for the validation of environmental samples collected during the previous
task. The sample validation task begins with reserving sample slots in the CLP and the completion of the
11 Model RD SOW (6/95)
-------
field sampling program. This task ends with the contractor validating the analytical data received from the
laboratory.
Perform appropriate data validation to ensure that the data are accurate and defensible.
1. For RD, full data validation procedures are usually not necessary. The WAM/RPM may want to
specify the level of data validation required.
2. The WAM/RPM should specify the format for submissions if there are Region-specific requirements or
if you have specific requirements.
The contractor shall perform the following activities or combination of activities to validate test results:
.5.1 Prepare and Ship Environmental Samples
.5.1.1 Ground-Water Samples
.5.1.2 Surface and Subsurface Soil Samples
.5.1.3 Surface-Water and Sediment Samples
.5.1.4 Air Samples
.5.1.5 Biota Samples
.5.1.6 Other Types of Media Sampling and Screening
*5.2 Coordinate with Appropriate Sample Management Personnel
.5.3 Implement EPA-Approved Laboratory QA Program.
.5.4 Provide Sample Management (Chain of Custody, Sample Retention, and Data Storage)
Ensure the proper management of samples. Ensure accurate chain-of-custody procedures for
sample tracking, protective sample packing techniques, and proper sample-preservation techniques.
.5.5 Validate Data
.5.5.1 Review Analysis Results Against Validation Criteria
.5.5.2 Provide Written Documentation of Validation Efforts
The WAM/RPM should specify the format for submissions if there are Region-specific requirements or if
the WAM/RPM has specific requirements.
3.6 Data Evaluation
The contractor shall organize and evaluate existing data and data gathered during the previous tasks that
will be used later in the RD effort. Data evaluation begins with the receipt of analytical data from the
data acquisition task and ends with the submittal of the Data Evaluation Summary Report. Specifically,
the contractor shall perform the following activities or combination of activities during the data evaluation
effort:
.6.1 Data Usability Evaluation and Field QA/QC
.6.2 Data Reduction, Tabulation, and Evaluation.
Evaluate, interpret, and tabulate data in an appropriate presentation format for final data tables.
Design and set up an appropriate database for pertinent information collected that will be used
during the RD.
.6.2.1 Evaluate Geological Data (Soils and Sediments)
.6.2.2 Evaluate Air Data
.6.2.3 Evaluate Hydrogeological Data: Ground Water
.6.2.4 Evaluate Hydrogeological Data: Surface Water
.6.2.5 Evaluate Waste Data
.6.2.6 Evaluate Geophysical Data
.6.2.7 Evaluate Ecological Data
.6.3 Modeling
.6.3.1 Contaminant Fate and Transport
j
1
12 Model RD SOW (6/95)
-------
.6.3.2 Water Quality
.6.3.3 Ground Water
.6.3.4 Air
.6.3.5 Other Modeling
.6.4 Develop Data Evaluation Report. Evaluate and present results in a Data Evaluation Summary
Report and submit to the WAM/RPM for review and approval. After the WAM/RPM's review,
attend a meeting with EPA to discuss data evaluation results and next steps.
The WAM/RPM should specify the format for submissions if there are Region-specific requirements or if
the WAM/RPM has specific requirements.
The WAM/RPM should specify that the contractor shall prepare and submit a Technical Memorandum to
the WAM/RPM if new analytical data needs or significant data problems are identified during the
evaluation.
3.7 Treatability Study and Pilot Testing
The purpose of the treatability study is to provide sizing and operations criteria that are used in design
drawings and specifications and in the engineer's cost estimate to optimize the RD. The task begins with
the preparation of a Treatability Study Work Plan that provides the technical specifics of the study and
ends with the contractor's submittal of the Treatability Study Evaluation Report. In some instances,
information on technology performance can be found in the current literature and should be reviewed
before the Treatability Study is designed.
The three levels of treatability studies are laboratory screening, bench-scale testing, and pilot-scale testing.
The laboratory screening is used to establish the validity of a technology to treat waste and is normally
conducted during the FS. Bench-scale testing is used to identify the performance of the technology
specific to a type of waste for an operable unit. Often bench-scale tests are conducted during the FS.
Pilot-scale testing is used to provide quantitative performance, cost, and design information for
remediation and is typically performed during RD (see the Fact Sheet, Guide for Conducting Treatability
Studies Under CERCLA, November, 1993).
In accordance with the design management schedule established in the approved RD Work Plan, the
contractor shall perform the following activities:
.7.1 Literature Search
.7.2 Develop Treatability and Pilot Work Plan
Prepare the Treatability Study Work plan and submit to the WAM/RPM for review and approval.
The Treatability Study Work Plan shall describe the technology to be tested, test objectives, test
equipment or systems, experimental procedures, treatability conditions to be tested, measurements
of performance, analytical methods, data management and analysis, health and safety procedures,
and residual waste management. The DQOs for the treatability study shall also-be documented.
The Treatability Study Work Plan shall also describe pilot plant installation and startup, pilot plant
operation and maintenance procedures, and operating conditions to be tested.
If testing is to be performed off-site, permitting requirements shall be addressed. A schedule for
performing the treatability study shall be included with specific dates for each task and subtask,
including EPA review periods. Key milestones that should have completion dates specified
included, but are not limited to, the procurement of contractors and the completion of sample
collection, the performance period, sample analysis, and report preparation.
In the SOW, the WAM/RPM should be clear about the expected schedule, and specify deadlines for each
activity to maintain the overall RD schedule. When reviewing the contractor's Work Plan, check to see that
the schedule in the Treatability Study Work Plan is consistent with the schedule in the RD Work Plan.
13 ' Model RD SOW (6/95)
-------
The Treatability Study Work Plan shall describe in detail the treatment process and how the
proposed vendor or technology will meet the performance standards for the site. The Treatability
Study Work Plan shall address how the contractor will meet all discharge or disposal requirements
for any and all treated material, air, water, and expected effluents. Additionally, the Work Plan
shall explain the proposed final treatment and disposal of all material generated by the proposed
treatment system.
1. List the treatment train and components of the system if possible.
2. Where do treated water and residuals go?
3. Will there be discharges to air? Is an air pathway analysis needed to ensure the protection of workers
and the public?
4. Does the contractor need to consider land disposal restrictions?
5. Consider having a contingency plan in case problems develop.
Conduct the Treatability Studies, as necessary, to determine whether the remediation technology or
vendor of the technology can achieve the performance standards. Treatability studies shall be
conducted as described in the EPA-approved Final Treatability Study Work Plan.
The following activities may be required during the performance of the treatability study and pilot
testing:
.7.3 Bench Test
.7.3.1 Procure Test Facility and Equipment. The contractor shall procure test facility
and equipment, including the procurement procedures necessary to acquire the
vendor, equipment, or facility to execute the tests.
.7.3.2 Provide Vendor and Analytical Service
.7.3.3 Test and Operate Equipment. The contractor shall test equipment to ensure
operation, then start up and operate equipment.
.7.3.4 Retrieve Sample for Testing. The contractor shall obtain samples for testing as
specified in the Treatability Work Plan.
.7.3.5 Perform Laboratory Analysis. The contractor shall establish a field laboratory to
facilitate fast-turnaround analysis of test samples, or, if necessary, shall procure
outside laboratory services to analyze the test samples and evaluate test results.
.7.3.6 Characterize and Dispose of Residuals
.7.4 Pilot-Scale Test
,7.4.1 Procure Test Facility and Equipment. The contractor shall procure test facility
and equipment, including the procurement procedures necessary to acquire the
] vendor, equipment, or facility to execute the tests.
.7.4.2 Provide Vendor and Analytical Service
.7.4.3 Test and Operate Equipment. The contractor shall test equipment to ensure
operation, then start up and operate equipment.
.7.4.4 Retrieve Sample for Testing. The contractor shall obtain samples for testing as
specified in the Treatability Work Plan.
.7.4.5 Perform Laboratory Analysis. The contractor shall establish a field laboratory to
facilitate fast-turnaround analysis of test samples, or, if necessary, shall procure
;„ outside laboratory services to analyze the test samples and evaluate test results.
.7.4.6 Characterize and Dispose of Residuals
.7.5 FjeldTest
.7.5.1 Procure Test Facility and Equipment. The contractor shall procure test facility
and equipment, including the procurement procedures necessary to acquire the
vendor, equipment, or facility to execute the tests.
.7.5.2 Provide Vendor and Analytical Service
14 ; Model RD SOW (6/95)
-------
.7.5.3 Test and Operate Equipment. The contractor shall test equipment to ensure
operation, then start up and operate equipment.
.7.5.4 Retrieve Sample for Testing. The contractor shall obtain samples for testing as
specified in the Treatability Work Plan.
.7.5.5 Perform Laboratory Analysis. The contractor shall establish a field laboratory to
facilitate fast-turnaround analysis of test samples, or, if necessary, shall procure
outside laboratory services to analyze the test samples and evaluate test results.
.7.5.6 Characterize and Dispose of Residuals
.7.6 Develop Treatability Study Report.
days after completion of the Treatability Study, the contractor shall prepare and
submit the Treatability Study Evaluation Report that describes the performance of the
technology. The study results shall clearly indicate the performance of the technology or
vendor compared with the performance standards established for the site. The report shall
also evaluate the treatment technology's effectiveness, implementability, cost, and final
results compared with the predicted results. The report shall also evaluate full-scale
application of the technology, including a sensitivity analysis identifying the key parameters
affecting full-scale operation.
Specify the format for submissions if there are Region-specific requirements or if there are other specific
requirements.
Consider holding a project review meeting with the Technical Review Committee and other team members
after completing the above task to present treatability study results and to summarize the RD status.
3.8 Preliminary Design
Preliminary Design begins with the initial design and ends with the completion of approximately 30
percent of the design effort. At this stage, the contractor shall have field-verified the existing conditions
of the site, as necessary. The contractor shall provide supporting data and documentation with the design
documents defining the functional aspects of the project to prove that the completed project will be
effective in meeting the remediation goals and applicable or relevant and appropriate requirements
(ARARs). For projects where the U.S. Army Corps of Engineers (USAGE) is responsible for RA
performance, the contractor shall prepare design submittals to conform to the format prescribed in
Technical Requirements for Pre-Design and Design Submittals, USAGE, ETL 1006. In accordance with
the schedule established in the RD Work Plan, the contractor shall submit to EPA the Preliminary Design,
which shall consist of the following subtasks:
Depending on the RA complexity, the WAM/RPM may require design submittals at 30 percent and again at
95 to 100 percent, eliminating the intermediate design submittal at 60 percent design completion.
.8.1 Preliminary Design
The contractor shall prepare a Design Criteria Report that defines in detail the technical parameters
upon which the design will be based. Specifically, the Design Criteria Report shall include the
preliminary design assumptions and parameters, including (1) waste characterization; (2) pretreating
requirements; (3) volume and types of each medium requiring treatment; (4) treatment schemes
(including all media and byproducts), rates, and required qualities of waste streams (i.e., input and
output rates, influent and effluent qualities, potential air emissions, and so forth); (5) performance
standards; (6) long-term performance monitoring and operations and maintenance (O&M)
requirements; (7) compliance with all ARARs, pertinent codes, and standards; (8) technical factors
of importance to the design and construction including use of currently accepted environmental
control measures, constructability of the design, and use of currently acceptable construction
15 Model RD SOW (6/95)
-------
practices and techniques. In addition to a Design Criteria Report, the contractor shall do the
following:
It is recommended that a Design Criteria Report be submitted at approximately 10 percent completion. |
.8.1.1 JRecommend Project Delivery Strategy and Scheduling. The schedule shall include an
evaluation of a phased approach to expedite the RA.
.8.1.2 Prepare Preliminary Construction Schedule. A preliminary RA schedule appropriate to the
size and complexity of the project shall be included in the plans and specifications.
.8.1.3 Prepare Specifications Outline. The general specifications outline shall include all
specification sections to be used. Format and organization shall be as described in Chapter
10 of the Architect Engineer Manual, USAGE, AEIM-14, Omaha District, July 1989,
which incorporates the Construction Specification Institute (CSI) format. USAGE also
developed standardized specifications for RDs that should be used whenever possible. Ms.
Tpmmian McDaniel at EPA Headquarters (Tel. 202-761-4363) may be contacted for more
information.
;. . - - ; ;v: • , , ' „ • j
I The need for performance specifications hi lieu of a detailed design is determined under this subtask.
"
.8.1.4 Prepare Preliminary Drawings. The drawings and schematics shall reflect organization
and clarity. This submittal should include (1) an outline or listing of proposed drawings
and schematics; (2) facility representations including a revised process flow diagram and a
preliminary piping and instrumentation diagram; (3) a general arrangement diagram; and
(4) site drawings. Engineering drawings shall be submitted in full size and half size
reproductions. Standard formats for use in preparing design drawings shall be those
described in the USAGE Architect Engineer Manual.
The character of the drawings and schematics will vary according to the remedy. Formatting requirements
for the drawings should be specified in this subtask.
.8.1.5 Prepare Basis of Design Report. The contractor shall submit a detailed description of the
evaluations conducted to select the design approach as part of the Basis of Design Report.
This report shall include a Summary and Detailed Justification of Assumptions. This
summary shall include (1) calculations supporting the assumptions; (2) a draft process flow
diagram; (3) a detailed evaluation of how all ARARs will be met; (4) a plan for
1 minimizing environmental and public impacts; and (5) a plan for satisfying permitting
requirements.
.8.1.6 Prepare Preliminary Cost Estimate. The preliminary RA cost estimate shall be a
preliminary evaluation of the costs of all the elements of the RA. The estimate should be
accurate within plus percent and minus percent and be prepared by using the
tyl-CACES Gold cost estimating system for remedial action. Results of the value
engineering (VE) screening are presented as part of the RA cost estimate. (See subtask
3.8.4.)
16
-------
1. In the subtask above, use plus 40 percent and minus 20 percent for simple projects; plus 50 percent and
minus 30 percent for complex projects.
2. M-CACES Gold Estimating System is the computer software currently used for estimating construction
costs by the U.S. Army of Corps of Engineers (USAGE) for its RA projects and will facilitate its review of
the cost estimate. The use of this system is required under Response Action Contracts (RACs) but is
optional under ARCS contracts.
.8.2 Describe Variances with the ROD
If the contractor finds that the RA being designed differs from the ROD or that an ARAR cannot
be met, the contractor shall describe the issue and recommend technical solutions in a
memorandum to the WAM/RPM.
.8.3 Land Acquisition and Easement Requirements
The need for land acquisition for access and easement requirements shall be identified and
submitted as part of the Basis of Design Report.
.8.3.1 Identify Need and Locations
.8.3.2 Provide Technical Support for Land Acquisition Efforts
.8.4 Conduct and/or Assist in Value Engineering Screening
The VE screening shall include an evaluation of cost and function relationships, concentrating on
high-cost areas. The VE screening shall be performed by an independent Value Engineering group
that is not otherwise participating in the RD. The outcome of the screening shall be a
recommendation for or against a full-scale VE study (a subtask performed during intermediate
design) based on the potential for cost savings as a result of design changes. [Value Engineering
Fact Sheet, May 1990.]
.8.5 Respond to Design Review Comments
The contractor shall consolidate and respond to design review comments. A written response to
each comment shall be provided. The response shall indicate whether the contractor has decided to
implement a design change as a result of the comment, and how the change will impact the selected
remedy, RD/RA costs, and/or schedule. A summary of the responses to comments shall be
submitted to the WAM prior to initiation of Intermediate Design. The design changes shall be
incorporated under Intermediate Design (Task 3.10).
.8.6 Participate in Preliminary Design Review or Briefing
The contractor shall participate in design review meetings to be held at Region offices.
The WAM/RPM should specify the format for submissions if there are Region-specific requirements or
other specific requirements.
The contractor shall implement QC procedures to ensure the quality of all reports and submittals to
EPA. These procedures shall include, but are not limited to, internal technical and editorial
review; the independent verification of all calculations used in the design; and the documentation of
all reviews, the problems identified, and corrective actions taken.
[NOTE: ITEMS 3.8.2 THROUGH 3.8.6, INCLUSIVE, ARE NOT INCLUDED IN THE 6-PERCENT
DESIGN LIMITATION CALCULATIONS.]
3.9 Equipment, Services, and Utilities
This task includes all efforts necessary to procure long-lead equipment and/or services.
.9.1 Identify Long-Lead Equipment Services and/or Utilities
The contractor shall prepare a list of any elements or components of the facility that will require
custom fabrication or long lead time for procurement. The list shall also state the basis for such
need, and list the recognized sources of such procurement.
17 Model RD SOW (6/95)
-------
This task does not include contract award. Contract award should normally be conducted as part of a
separate RA work assignment.
.9.2 Procure Long-Lead Equipment Services and/or Utilities
The contractor shall prepare necessary plans and specifications, advertise for, and evaluate bids for
equipment and services.
i
3.10 Intermediate Design
The intermediate design begins at the completion of the preliminary design phase and ends with the
completion of approximately 60 percent of the total design effort. The contractor shall submit to EPA the
Intermediate Design submittal which shall consist of a continuation and expansion of the Preliminary
Design submittal. Review comments on the Preliminary Design shall be reflected in the Intermediate
Design. A Value Engineering Study shall be performed based on approved recommendations from the VE
screening submitted with the preliminary design. The Intermediate Design documents shall be submitted
in accordance with the approved design management schedule and shall consist of the following subtasks:
.10.1 Update Construction Schedule
The schedule for implementation of the RA shall identify the timing for initiation and completion of
all critical path tasks. The schedule shall specifically identify duration for completion of the project
and major milestones.
.10.2 Prepare Intermediate Specifications
Plans and specifications shall conform to acceptable standards and shall be formatted in accordance
with CSI requirements. Plans and specifications shall include preliminary specifications for
construction, installation, site preparation, and field work standards, including an equipment startup
and operator training plan. A table of contents for the general specifications shall be provided with
this submittal. All specifications shall conform to CSI format.
.10.3 Prepare Intermediate Drawings
The contractor shall submit an outline or listing of drawings: facility representations containing a
process flow diagram, a piping and instrumentation diagram, and a control logic table; and
continuation and expansion of drawings submitted with the Preliminary Plans and Specifications.
Include engineering drawings for grading/paving, foundation, and electrical, structural, and
mechanical elements, etc.
.10.4 Prepare and Submit Revised Basis of Design Report
The contractor shall submit a revised summary of the evaluations conducted to select the design
approach as part of the revised Basis of Design Report. The report shall include the following
components:
• Summary and Detailed Justification of Assumptions. This summary shall include: (1)
design calculations supporting the assumptions; (2) a revised process flow diagram; (3) a
detailed evaluation pf how ARARs will be met; (4) a plan for minimization of
environmental and public impacts; and (5) heat and mass balances.
.: • Recommended RA Contracting Strategy. The contractor shall address the management
approach for procuring the RA contractor, including procurement methods, phasing
alternatives, and contractor and equipment availability concerns.
• Plan for Satisfying Permitting Requirements. EPA comments shall be incorporated into an
updated Permits Plan.
• Identification of Easement and Access Requirements. The need for land acquisitions for
access and easement requirements shall be identified and submitted as part of the
Intermediate Design.
Identification of the projected O&M requirements and development of an estimate of annual O&M
costs.
.10.5 Prepare Revised RA Cost Estimate
This revised estimate of the RA shall be developed using flow sheets, layouts, and equipment
details. The estimate shall be accurate within plus percent and minus percent and be
prepared using the M-CACES Gold Cost Estimating System for Remedial Action.
18 ! Model RD SOW (6/95)
-------
1. In the subtask above, use plus 30 percent and minus 15 percent for simple projects; plus 40 percent and
minus 20 percent for complex projects.
2. Use of M-CACES Gold Estimating System computer software for the cost estimate is required for EPA
RD work assignments under RACs and is recommended for ARCS. This system is used by USAGE for
construction cost estimating and will enable contractor-prepared construction estimates to be reviewed more
readily for accuracy.
.10.6 Participate in Intermediate Design Review or Briefing
The contractor shall participate in a variety of design review activities, including design review
meetings to be held at Region . The contractor shall also perform and submit a report
describing the results of the following design reviews:
.10.6.1 Initial Constructability Review. The contractor shall review and provide written comments
for the Initial Constructability Review. The constructability review shall be conducted to
evaluate the suitability of the proposed project and its components in relation to the project
size.
.10.6.2 Initial Biddability Review. The contractor shall review and provide written comments for
the initial biddability review.
.10.6.3 Initial Operability Review. The contractor shall review and provide written comments for
the Initial Operability Review. The operability review shall assure that the completed
project will conform to applicable performance and operations requirements.
.10.6.4 Initial Environmental Review. The contractor shall review and provide written comments
for the Initial Environmental Review.
.10.6.5 Initial Claims Prevention Screening. The contractor shall review and provide written
comments for the Initial Claims Prevention Screening. The claims prevention review is to
be conducted to eliminate conflicts, inconsistencies, ambiguities, errors, omissions, or
other identifiable problems in the plans, specifications, and contract documents that are
subject to change orders and contractor claims.
.10.7 Perform VE Study and Report Recommendations
The VE Study shall be conducted and the Report prepared by an independent Value Engineering
group that is not otherwise participating hi the RD (as in subtask 3.8.4).
.10.8 Describe Variances with the ROD
If the contractor finds that the remedial action being designed differs from the ROD, or that an
ARAR cannot be met, the contractor shall describe the issue and recommend technical solutions in
a memorandum to the WAM/RPM.
.10.9 Respond to Design Review Comments
A written response to each comment shall be provided. The response shall indicate whether the
contractor has decided to implement a design change as a result of the summary of the responses to
comments shall be submitted to the WAM prior to initiation of Intermediate Design. The design
changes shall be incorporated under Intermediate Design (Task 3.10).
[NOTE: ITEMS 3.10.6 THROUGH 3.10.9 ARE NOT INCLUDED IN THE 6-PERCENT DESIGN
LIMITATION CALCULATIONS.]
3.11 Prefinal and Final Design
The contractor shall submit the Prefinal Design according to the design management schedule. The
Prefinal Design shall function as the draft version of the Final Design. The Prefinal Design shall address
comments generated from the Intermediate Design Review and clearly show any modifications of the
design as a result of incorporation of the comments. After EPA review and comment on the Prefinal
Design, the Final Design shall be submitted. All Final Design documents shall be approved by a
Professional Engineer registered in (state where site is located). EPA approval of the Final
Design is required before initiating the RA, unless specifically authorized by EPA.
19 Model RD SOW (6/95)
-------
.11.1 Prepare Prefinal Design Specifications
A complete set of construction drawings and specifications (general specifications, drawings, and
schematics) shall be submitted at the prefmal stage. All specifications shall conform to CSI format.
Value engineering report recommendations (submitted with the intermediate design) that have been
approved by EPA shall be incorporated into the prefmal design drawings and specifications. The
final design plans and specifications must be consistent with the technical requirements of all
ARARs. Any off-site disposal shall be in compliance with the policies stated in the Procedure for
Planning and Implementing Off-Site Response Actions (Federal Register, Volume 50, Number 214,
November 1985 pages 45933-45937) and other applicable guidance.
General correlation between drawings and technical specifications is a basic requirement of any set
of working construction plans and specifications. Before submitting the project specifications, the
contractor shall coordinate and cross-check the specifications and drawings; and complete the
proofing of the edited specifications and the cross-checking of all drawings and specifications.
.11.2 Prepare Prefinal Drawings
The final submittals shall include a complete set of construction drawings and specifications as well
as a set of one-half size reductions of drawings. All specifications shall conform to CSI format.
.11.3 Prepare Final Basis of Design Report that incorporate any changes since the intermediate design
submittal.
.11.4 Prepare Revised RA Cost Estimate
The contractor shall prepare a definitive cost estimate of the offers to be received for RA for each
work item from definitive engineering data, within an accuracy of plus 15 percent to minus 5
percent. The definitive cost estimate should be accompanied by a range estimate and analysis of
the project's potential scope, cost, and schedule change during RA, broken down by work activity.
One copy of the quantity takeoff sheets, including the appropriate items, shall be included with
each estimate submitted. All work items shall be broken down into labor, materials, and
equipment. The contractor shall provide the basis for development of all unit prices used in the
estimate. Unit prices, overhead, profit, and other categories shall be shown as separate items. The
final estimate will be based on the advertised plans and specifications including amendments. It
should reflect current prices for labor, materials, and equipment. The estimate shall separately
identify contingencies within the defined project scope. The contractor shall prepare the RA cost
estimates by using the M-CACES Gold Estimating System.
The use of M-CACES Gold Estimating System for the cost estimate is required for RD work assignments
under RACs and is recommended under ARCS.
.11.5 Prepare 100-Percent Design Submittal
.11.6 Participate in Prefinal/Final Design Review
The contractor shall participate in a Prefinal Design review meeting. The meeting shall be held at
Region ___ headquarters. The contractor shall also consolidate and respond to Intermediate and
Prefinal Design review comments. A written response for each comment shall be provided before
incorporating the changes into the design. The changes shall be incorporated as part of the 100-
Percent Design submittal.
.11.7 Prepare Subcontract Award Documents
The contractor shall prepare complete contract documents, including (1) complete RA SOW
including, wherever appropriate, drawings and specifications, complete cost proposal, and the
required schedule; (2) terms and conditions of the contract including payments, delivery schedule,
point of delivery, and acceptance criteria; (3) method of procurement including evaluation, basis,
and method of awarding contract; (4) criteria to be employed in evaluating bids and offers; (5)
prevailing wage determinations (DBA); (6) deadline and location for submitting bids and offers, if
applicable; and (7) appropriate contract clauses.
.11.8 Perform Biddabiliry, Operability, and Constructability Reviews
The contractor shall conduct final constructability, biddability, Operability, environmental, and
claims prevention reviews and document results.
20 Model RD SOW (6/95)
-------
.11.9 Prepare Revised Project Delivery Strategy
.11.10 Document VE Modifications
.11.11 Draft Operations and Maintenance (O&M) Manual
The manual should include the following:
.11.11.1 An operations and maintenance plan that includes a description of normal operation and
maintenance including start-up procedures, tasks for operation, tasks for maintenance,
prescribed treatment or operation conditions, and schedule for each O&M task
.11.11.2 A description of potential operating problems including common and/or anticipated
remedies and useful-life analysis of significant components and replacement costs
.11.11.3 Quality Assurance Plan for O&M including a description of routine monitoring tasks,
description of required laboratory tests and their interpretation, required data
collection, and location of monitoring points comprising the points of compliance
monitoring
.11.11.4 Alternate procedures to prevent releases or threatened releases of hazardous substances,
pollutants, or contaminants, which may endanger health and the environment or cause
an exceedance of any cleanup standard
.11.11.5 Corrective action to be implemented in the event that cleanup standards for ground
water, surface water discharges, and air emissions are exceeded and a schedule for
implementing these corrective actions
.11.11.6 Safety Plan for O&M including a description of precautions and necessary equipment
for site personnel, safety tasks required in event of systems failure, and safety tasks
necessary to address protection of nearby residents.
.11.11.7 Description of equipment including the equipment identification numbers, installation of
monitoring components, maintenance of site equipment, and replacement schedule for
equipment and installed components
[NOTE: ITEMS 11.6 THROUGH 11.10, INCLUSIVE, ARE NOT INCLUDED IN THE 6-PERCENT
DESIGN LIMITATION CALCULATIONS.]
.11.11.8 Records and reporting mechanisms required including daily operating logs, laboratory
records, records for operating costs, mechanism for reporting emergencies, personnel
and maintenance records, and reports to U.S. EPA, its designates, and the State.
If RA does not require O&M, delete the text and insert "not used" or "N/A" after line item 3.11.11.
.11.12 Construction Quality Assurance Plan
The contractor shall submit as part of the Prefinal Design a draft Construction Quality Assurance
(CQA) Plan. The CQA Plan shall be prepared in accordance with "Construction Quality Assurance
for Hazardous Waste Land Disposal Facilities" (EPA, October, 1986). The CQA Plan shall then
be finalized and submitted with the Final Design. At a minimum, the draft QA Plan shall provide
requirements for the following elements:
.11.12.1 Responsibility and authority of all organization and key personnel involved in the
remediation action construction
.11.12.2 CQA Personnel Qualifications. The contractor shall establish the minimum
qualifications of the CQA Officer and supporting inspection personnel.
.11.12.3 Inspection Activities. The contractor shall establish the observations and tests that will
be required to monitor the construction and/or installation of the components of the
Remedial Action(s). The plan shall include the scope and frequency of each type of
inspection to be conducted. Inspections shall be required to verify compliance with
environmental requirements and include, but not be limited to, air quality and
emissions monitoring records, waste disposal records (e.g., RCRA transportation
manifests), etc. Inspections shall also ensure compliance with all health and safety
procedures.
21 Model RD SOW (6/95)
-------
.11.12.4 Sampling requirements. The contractor shall establish the requirements for sampling
activities, sample size, sample locations, frequency of testing, criteria for acceptance
and rejection, and plans for correcting problems as addressed in the project
specifications.
.11.12.5 Documentation. The contractor shall describe the reporting requirements for CQA
activities. This shall include such items as daily summary reports and inspection data
sheets.
.,. - ,'i • , j
3.12 Postremedjal Design Support
This task consists of support required to prepare contract bidding documents and issue the Invitation for
Bids or the Request for Proposals. The task starts with EPA's approval of contract documents developed
under Task 11 and ends with the submittal of construction contractors' bids. The contractor shall perform
the following postremedial design activities:
.12.1 Prebid (Presolicitation) Activities
.12.1.1 Printing and Distribution of Contract Documents. Print and distribute to prospective
bidders the contract documents that were finalized in Taslc 11.
.12,1.2 Advertising and Soliciting of Bids. Advertise and solicit bids for construction services.
An advertisement shall be prepared and published in
(1) Prebid (Presolicitation) Meetings. The contractor shall arrange and attend prebid
meetings to provide clarification on plans, specifications, and contract documents to all
bidders.
(2) Resolution of Inquiries and/or Issuing Addenda. The contractor shall resolve bidder
inquires and document all contact with potential bidders, and issue amendments to
contract documents if additional information becomes available that all bidders should
I
be made aware of after solicitation.
(3) On-Site Visits. The contractor shall participate in on-site visits tfiat may be required to
;, further clarify the services required.
.12.2 Preaward Activities
.12.2.1 Receipt of Bids (Offers)
(I) Determination of Responsive, Responsible Bidders (Offerers)
(2) Perform Reference Checks
(3) Prepare Bid (Offer) Tabulation
(4) Perform Bid (Offer) Analysis
.12.2.2 Receipt and review of Followup Items from Lowest Responsible Bidder (Offerer)
.12.2.3 Review of EEO and MBE Requirements and SDB Subcontracting Plans
.12.3 Update Site-Specific Plans
. 12.3.1 Modify Site Management Plan (if necessary)
.12,5.2 Modify Sampling and Analysis Plan (if necessary)
.12.3.3 Modify Health and Safety Plan (if necessary)
.12.3.4 Modify Community Relations Plan (if necessary)
In some cases, it may be advisable to use this task to initiate the procurement process, although these
services can be procured as part of the RA work assignment.
22
Model RD SOW (6/95)
-------
3.13 Work Assignment Closeout
. 13.1 Return Documents to Government
.13.2 Duplicate, Distribute, and Store Files
.13.3 Archive Files
.13.4 Prepare Microfiche, Microfilm, and Optical Disk
.13.5 Prepare Closeout Report. The contractor shall include a breakdown on disk of final costs and
Level of Effort (by P-level) in the same detail and format as the Work Breakdown Structure
(Attachment 2).
23 Model RD SOW (6/95)
-------
Attachment 1
Summary of Major Submittals for the Remedial Design at
(Site)
TASK
3.1.1.2
3.1.1.4
3.1.1.4
3.1.2.1
3.1.2.1
3.1.2.3(1)
3.1.2.3(2)
3.1.2.2
3.1.2.3(2)
3.1.2.3(1)
3.1.2.2
3.2.1
3.2.1
DELIVERABLE
Site Visit Report
RD Work Plan
Final RD Work Plan
Draft Site Management Plan
(SMP)
Final SMP
Draft QAPP
Draft FSP
Draft HASP
Final QAPP
Final FSP
Final HASP
Draft Revised CRP
Final Revised CRP
REF
NO.*
21
8
5
36
19
21
8
5
36
19
4
4
NO. OF
COPIES
3
3
3
3
3
3
3
3
3
3
3
3
3
DUE DATE
(calendar days)
10 days after site visit
30 days after initiation of work
assignment (WA)
15 days after receipt of EPA
comments
(#) days after approval of RD
Work Plan
(#) days after receipt of EPA
comments
30 days after initiation of WA
30 days after initiation of WA
30 days after initiation of WA
15 days after receipt of EPA
comments
15 days after receipt of EPA
comments
15 days after receipt of EPA
comments
(#) days after initiation of WA
(#) days after receipt of EPA
comments
EPA REVIEW
PERIOD
7 days after receipt of report
21 days after receipt of Work
Plan
NA
10 days after receipt of SMP
NA
21 days after receipt of QAPP
21 days after receipt of FSP
21 days after receipt of HASP
NA
NA
NA
14 days after receipt of revised
CRP
NA
-------
Attachment 1
Summary of Major Submittals for the Remedial Design at
(Site) (continued)
TASK
3.2.2
3.6.4
3.7.2
3.7.2
3.7.6
3.7.6
3.8.1
3.8.1.5
3.8.1.5
3.8.1
3.8.4
DELIVERABLE
Fact Sheets
Data Evaluation Summary
Report
Treatability Study Work Plan
Final Treatability Study Work
Plan
Treatability Study Evaluation
Report
Final Treatability Study
Evaluation Report
Design Criteria Report
Basis of Design Report
Basis of Design Report
(Revision)
Preliminary Plans and
Specifications**
VE Screening Report
REF
NO.*
16
41 (FS)
16
41 (FS)
16
42 (FS)
16
41 (FS)
NO. OF
COPIES
3
3
3
3
3
3
3
3
3
3
3
DUE DATE
(calendar days)
As needed
10 days after receipt of analytical
results from laboratory
45 days after RD Work Plan
approved
15 days after receipt of EPA
comments
30 days after completion of
Treatability Study
15 days after receipt of EPA
comments
45 days after RD Work Plan
approved
45 days after RD Work plan
approved
Revised and distributed as
necessary (dynamic document)
60 days after RD Work Plan
approved
(#) days after RD Work Plan
approved
EPA REVIEW
PERIOD
10 days after receipt of fact sheet
15 days after receipt of report
21 days after receipt of
Treatability Study Work Plan
NA
21 days after receipt of report
NA
21 days after receipt of report
21 days after receipt of report
15 days after receipt of report
30 days after receipt of plans &
specs
21 days after receipt of report
-------
Attachment 1
Summary of Major Submittals for the Remedial Design at
(Site) (continued)
TASK
3.8.5
3.9.1
3.9.2
3.10
3.10.7
3.10.9
3.11
3.11.5
3.11.6
3.11.7
3.11.7
DELIVERABLE
Response to Design Review
Comments
List of Long-Lead Procurement
Items
Plans and Specifications for
Procurement of Long-Lead
Procurement Items
Intermediate Plans and
Specificationst
Value Engineering Report
Response to Design Review
comments
Prefinal Plans and
Specifications11'
100-Percent Design
Response to Prefinal Design
review comments
Draft RA contract documents
Final RA contract documents
REF
NO.*
NO. OF
COPIES
3
3
3
3
3
3
3
3
3
3
3
DUE DATE
(calendar days)
(#) days after design review
meeting
(#) days after Preliminary Design
approved
(#) days after receipt of EPA
comments on the Long-Lead
Procurement Item List
30 days after Preliminary Design
approved
(#) days after initiation of VE
Study
(#) days after Intermediate Design
Review Meeting
(#) days after Intermediate Design
approved
(#) days after prefinal design
comments received
(#) days after design review
meeting
(#) days after Final Design
approved
(#) days after receipt of EPA
comments on Draft RA contract
documents
EPA REVIEW
PERIOD
15 days after receipt of response
10 days after receipt of list
15 days after receipt of plans &
specs
21 days after receipt of int. plans
& specs
21 days after receipt of report
15 days after receipt of response
21 days after receipt of plans &
specs
NA
15 days after receipt of response
21 days after receipt of RA
documents
NA
*See Attachment 3 for list of references.
**Preliminarv Plans and Specifications Submittal Items:
-------
Attachment 1
Summary of Major Submittals for the Remedial Design at
(Site) (continued)
3.8.1.1 Project Delivery Strategy and Scheduling
3.8.1.2 Preliminary RA Schedule
3.8.1.3 Specifications Outline
3.8.1.4 Preliminary Drawings and Schematics
3.8.1.5 Basis of Design Report
3.8.1.6 Preliminary RA Cost Estimate
3.8.2 Variances from the ROD
Intermediate Plans and Specifications Submittal Items:
3.10.1 Update Construction Schedule
3.10.2 Intermediate Specifications
3.10.3 Intermediate Drawings and Schematics
3.10.4 Revised Basis of Design Report
3.10.5 RA Cost Estimate
3.10.8 Variances from the ROD
ttPrefinal Plans and Specifications Submittal Items:
3.11.1 Prefinal Drawings and Specifications
3.11.2 Prefinal Drawing Reductions
3.11.3 Final Basis of Design Report
3.11.4 Revised RA Cost Estimate
3.11.7 Subcontract Award Documents
3.11.8 Biddability, Operability, and Constructability Reviews
Reports
3.11.9 Revised Project Delivery Strategy and Schedule
3.11.10 Document VE Modifications
3.11.11 Draft Operations and Maintenance (O&M) Manual
3.11.12 Construction Quality Assurance Plan
-------
Attachment 2
Work Breakdown Structure (WBS) for Remedial Design (RD)
'!"' • ii
!'! ' • I
3.0 Remedial Design
.01 Project Planning and Support
.01 Project Planning
.01 Attend Scoping Meeting
.02 Conduct Site Visit
.03 Evaluate Existing Information
.04 Work Plan Development
.01 Draft Work Plan Development
.01 Develop Narrative
.02 Develop Cost Estimate
.03 Internal QA & Submission
.02 Final Work Plan Preparation
.01 Attend Negotiation Meeting
.02 Modify Draft Work Plan/Cost Estimate
.03 Internal QA & Submission
.02 Preparation of Site-Specific Plans
.01 Develop Site Management Plan
.01 Develop Pollution Control & Mitigation Plan
.02 Transportation & Disposal Plan (Waste Management Plan)
.02 Develop Health & Safety Plan
.03 Sampling & Analysis Plan (Chemical Data Acquisition Plan)
.01 Quality Assurance Project Plan
.02 Field Sampling Plan
.03 Data Management Plan
.04 Other Plan(s)
,03 Project Management
.01 Prepare Periodic Status Reports
.01 Document Cost and Performance Status
.02 Prepare/Submit Invoices
.02 Meeting Participation/Routine Communications
.03 Perform Engineering Network Analysis
.04 Manage, Track, and Report Equipment Status
.05 Work Assignment Closeout
.04 Subcontract Procurement/Support Activities
.0| ID and Procurement of Subcontractors
.01 Drilling Subcontractor
.02 Surveying Subcontractor
.03 Geophysical Subcontractor
.04 Site Preparation Subcontractor
.05 Analytical Services Subcontractor(s)
.06 Waste Disposal Subcontractor
.07 Treatability Subcontractor
.08 Other(s)
.02 Establish and Carry Out a QA Program
.03 Perform Subcontract Management
.02 Community Relations
.01 Community Relations Plan (CRP) Development
.01 Conduct Community Interviews
.02 Prepare CRP
.01 Draft CRP
.02 Final CRP
.02 Prepare Fact Sheets
.03 Public Hearing, Meetings, & Availability Support
.Of Technical Support
.02 Logistical & Presentation Support
.03 Public Notice Support (writing, or placement of)
;; •••} • j
28 Model RD SOW (6/95)
-------
.04 Maintain Information Repository/Mailing List
.03 Data Acquisition
.01 Mobilization/Demobilization
.01 ID field support equipment/supplies/facilities
.02 Mobilization
.01 Site Preparation
.01 Perform Demolition
.02 Clearing and Grubbing
.03 Perform Earthwork
.01 Provide Borrow Pit
.02 Construct Haul Roads
.04 Construct Roads/Parking/Curbs/Walks
.05 Install Storm Drainage/Subdrainage
.06 Install Fencing/Site Security
.02 Installation of Utilities
.01 Install Electrical Distribution
.02 Install Telephone/Communication System(s)
.03 Install Water/Sewer/Gas Distribution
.04 Install Fuel Line Distribution
.03 Construction of Temporary Facilities
.01 Construct Decontamination Facilities
.02 Construct Sample/Derived Waste Storage Facility
.03 Construct Field Offices
.04 Construct Mobile Laboratory
.05 Construct Other Temporary Facilities
.03 Demobilization
.01 Removal of Temporary Facilities
.02 Site Restoration
.02 Field Investigation
.01 Perform Site Reconnaissance
.01 Ecological Resources Reconnaissance
.02 Well Inventory
.03 Residential Well Sampling
.04 Land Survey
.05 Topographic Mapping
.06 Field Screening
.02 Conduct Geological Investigations (Soils/Sediments)
.01 Surface Soil Sample Collection
.02 Subsurface Soil Sample Collection
.03 Soil Boring/Permeability Sampling
.04 Sediments Sample Collection
.05 Soil Gas Survey
.06 Test Pit
.03 Conduct Air Investigations
.01 Sample Collection
.02 Air Monitoring Station
.04 Conduct Hydrogeological Investigations—Ground Water
.01 Well Systems Installation
.01 Accomplish Mobilization
.02 Perform Well Development
.03 Conduct Downhole Geophysics
.04 Install Monitoring Wells
.05 Install Test Wells
.06 Install Gas Wells
.02 Collect Samples
.03 Hydro Punch
.04 Conduct Tidal Influence Study
.05 Conduct Hydraulic Tests (Pump Tests)
.06 Perform Ground-Water Elevation Measurement
.05 Conduct Hydrogeological Investigations—Surface Water
29 Model RD SOW (6/95)
-------
.01 Collect Samples
.02 Conduct Tidal Influence Study
.03 Perform Surface Water Elevation Measurement
.06 Conduct Waste Investigation
.01 Collect Samples (Gas, Liquid, Solid)
.02 Derived Waste Disposal (Gas, Liquid, Solid)
.07 Conduct Geophysical Investigation
.01 Surface Geophysical Activity
.02 Magnetometer
.03 Electromagnetics
.04 Ground Penetrating Radar
.05 Seismic Refraction
.06 Resistivity
.07 Site Meteorology
.08 Cone Penetrometer Survey
.09 Remote Sensor Survey
.10 Radiological Investigation
.08 Conduct Ecological Investigation
.01 Wetland and Habitat Delineation
.02 Wildlife Observations
.03 Community Characterization
.04 Identification of Endangered Species
.05 Biota Sampling/Population Studies
.09 Collect Contaminated Building Samples
. 10 Disposal of Investigation-Derived Waste
.04 Sample Analysis
.01 Screening-Type Laboratory Sample Analysis
.01 Analyze Air/Gas Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.02 Analyze Ground-Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.03 Analyze Surface Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.04 Analyze Soil/Sediment Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.05 Analyze Waste (Gas) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.06 Analyze Waste (Liquid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.07 Analyze Waste (Solid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.08 Analyze Biota Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.09 Analyze Bioassay Samples
30
Model RD SOW (6/95)
-------
. 10 Perform Bioaccumulation Studies
.02 CLP-Type Laboratory Sample Analysis
.01 Analyze Air/Gas Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.02 Analyze Ground-Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.03 Analyze Surface Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.04 Analyze Soil/Sediment Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.05 Analyze Waste (Gas) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.06 Analyze Waste (Liquid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.07 Analyze Waste (Solid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.08 Analyze Biota Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.09 Analyze Bioassay Samples
. 10 Perform Bioaccumulation Studies
.05 Analytical Support and Data Validation
.01 Prepare and Ship Environmental Samples
.01 Ground-Water Samples
.02 Surface and Subsurface Soil Samples
.03 Surface Water & Sediment Samples
.04 Air Samples
.05 Biota Samples
.06 Other types of media sampling and screening
.02 Coordinate with appropriate Sample Management personnel
.03 Implement EPA-approved Laboratory QA program
« .04 Provide Sample Management (Chain of Custody, sample retention, & data storage)
.05 Perform Data Validation
.01 Review analysis results against validation criteria
.02 Provide written documentation of validation efforts
.06 Data Evaluation
.01 Data Useability Evaluation/Field QA/QC
.02 Data Reduction, Tabulation and Evaluation
.01 Evaluate Geological Data (Soils/Sediments)
.02 Evaluate Air Data
.03 Evaluate Hydrogeological Data—Ground Water
.04 Evaluate Hydrogeological Data—Surface Water
.05 Evaluate Waste Data
.06 Evaluate Geophysical Data
.07 Evaluate Ecological Data
31 Model RD SOW (6/95)
-------
.03 Modeling
.Ql Contaminant Fate and Transport
.02 Water Quality
.03 Ground Water
.04 Air
.05 Oilier Modeling
.04 Develop Data Evaluation Report
.07 Treatabiiity Study/Pilot Testing
.01 Literature Search
.02 Develop Treatability/Pilot Work Plan
.03 Bench Test
.01 Procure Test Facility and Equipment
.02 Provide Vendor & Analytical Service
.03 Test and Operate Equipment
.04 Retrieve Sample for Equipment
.05 Perform Laboratory Analysis
.06 Characterize and Dispose of Residuals
.04 Pilot-Scale Test
.0! Procure Test Facility and Equipment
.02 Provide Vendor & Analytical Service
.03 Test and Operate Equipment
.04 Retrieve Sample for Testing
.05 Perform Laboratory Analysis
.06 Characterize and Dispose of Residuals
.05 Field test [
.01 Procure Test Facility and Equipment
.02 Provide Vendor & Analytical Service
.03 Test and Operate Equipment
.04 Retrieve Sample for Testing
.05 Perform Laboratory Analysis
.06 Characterize and Dispose of Residuals
.06 Develop Treatability Study Report
.08 Preliminary Design
.01 Preliminary Design
.01 Recommend Project Delivery Strategy and Scheduling
.02 Prepare Preliminary Construction Schedule
.03 Prepare Specifications Outline
.04 Prepare Preliminary Drawings
.05 Prepare Basis of Design Report/Design Analysis
.06 Prepare Preliminary Cost Estimate
.02 De^cribf Variances with ROD
.03 Land Acquisition/Easement Requirements
.01 Identify need for, and locations
.02 Provide Technical Support in Land Acquisition Efforts
.04 Conduct and/or assist in Value Engineering (VE) screening
.05 Respond to Design Review Comments
.06 Participate in Preliminary Design Reviews/Briefing
• . '" 1 :. I •
[NOTE: ITEMS 8.02 THROUGH 8.06, INCLUSIVE, ARE NOT INCLUDED IN THE 6-PERCENT
DESIGN LIMITATION CALCULATIONS]
.09 Equipment/Services/Utilities
.01 Identify long-lead equipment services, and/or utilities
.02 Procure long-lead equipment services, and/or utilities
. 10 Intermediate Design
.01 Update Construction Schedule
.02 Prepare Preliminary Specifications
.03 Prepare Intermediate Drawings
.04 Prepare Basis of Design Report/Design Analysis
.05 Prepare Revised Cost Estimate
32 Model RD SOW (6/95)
-------
.06 Participate in Intermediate Design Review/Briefing
.07 Perform VE Study and Report Recommendations
.08 Describe Variances with ROD
.09 Respond to Design Review Comments
[NOTE: ITEMS 10.06 THROUGH 10.09, INCLUSIVE, ARE NOT INCLUDED IN THE 6-PERCENT
DESIGN LIMITATION CALCULATIONS]
.11 Prefinal/Final Design
.01 Prepare Prefmal Design Specifications
.02 Prepare Prefinal Drawings
.03 Prepare Basis of Design Report/Design Analysis
.04 Prepare Revised Cost Estimate
.05 Prepare 100-Percent Design Submittal
.06 Participate in Prefinal/Final Design Review
.07 Prepare Subcontract Award Document(s)
.08 Perform Biddability (offerability) and Constructability Reviews
.09 Prepare Revised Project Delivery Strategy
. 10 Document VE Modifications
.11 Draft O&M Manual
. 12 Prepare Construction QA Plan
[NOTE: ITEMS 11.06 THROUGH 11.10, INCLUSIVE, ARE NOT INCLUDED IN THE 6-PERCENT
DESIGN LIMITATION CALCULATIONS]
.12 Post Remedial Design Support
.01 Prebid (Presolicitation) Activities
.01 Printing & Distribution of Contract Documents
.02 Advertising/Soliciting of Bids
.01 Prebid (presolicitation) meetings
.02 Resolution of inquiries/Issuing Addenda
.03 On-site visits
.02 Preaward Activities
.01 Receipt of Bids (offers)
.01 Determination of responsive, responsible bidders (offerers)
.02 Perform Reference checks
.03 Bid (offer) Tabulation
.04 Bid (offer) Analysis
.02 Receipt of follow-up items from lowest responsible bidder (offerer)
.03 Review of EEO, MBE requirements, SDB subcontracting plans
.03 Update Site-Specific Plans
.01 Modify Site Management Plan (if necessary)
.02 Modify Sampling & Analysis Plan (if necessary)
.03 Modify Health & Safety Plan (if necessary)
.04 Modify Community Relations Plan (if necessary)
. 13 Work Assignment Close Out
.01 Return Documents to Government
.02 File Duplication/Distribution/Storage
.03 File Archiving
.04 Microfiche/Microfilm/Optical Disk
.05 Prepare Closeout Report
33 Model RD SOW (6/95)
-------
Attachment 3
Regulations and Guidance Documents
The following list, although not comprehensive, comprises many of the regulations and guidance documents that
apply to the RD process:
1. American National Standards Practices for Respiratory Protection. American National Standards Institute
Z88.2-1980, March 11, 1981.
2, ARCS Construction Contract Modification Procedures September 89, OERR Directive 9355.5-01/FS.
3. CERCLA Compliance with Other Laws Manual, Two Volumes, U.S. EPA, Office of Emergency and
Remedial Response, August 1988 (DRAFT), OSWER Directive No. 9234.1-01 and -02.
4. Community Relations in Superfund — A Handbook, U.S. EPA, Office of Emergency and Remedial
Response, June 1988, OSWER Directive No. 9230.0-3B.
5. A Compendium of Superfund Field Operations Methods, Two Volumes, U.S. EPA, Office of Emergency
and Remedial Response, EPA/540/P-87/001a, August 1987, OSWER Directive No. 9355.0-14.
6. Construction Quality Assurance for Hazardous Waste Land Disposal Facilities, U.S. EPA, Office of Solid
Waste and Emergency Response, October 1986, OSWER Directive No. 9472.003.
7. Contractor Requirements for the Control and Security of RCRA Confidential Business Information, March
1984.
8. The Data Quality Objectives Process for Superfund: Interim Final Guidance, U.S. EPA,
EPA/540/R-93/071, September 1993.
9. Engineering Support Branch Standard Operating Procedures and Quality Assurance Manual, U.S. EPA
Region IV, Environmental Services Division, April 1, 1986 (revised periodically).
10, EPA NEId iPplicies and Procedures Manual, EPA-330/9-78-001-R, May 1978, revised November 1984.
11. Federal Acquisition Regulation, Washington, DC: U.S. Government Printing Office (revised periodically).
12. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final,
U.S. EPA, Office of Emergency and Remedial Response, October 1988, OSWER Directive NO.
9355.3-01.
13. Guidance on EPA Oversight of Remedial Designs and Remedial Actions Performed by Potential
Responsible Parties, U.S. EPA Office of Emergency and Remedial Response, EPA/540/G-90/001, April
1990.
14. Guidance on Expediting Remedial Design and Remedial Actions, EPA/540/G-90/006, August 1990.
15. Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites, U.S. EPA Office of
Emergency and Remedial Response (DRAFT), OSWER Directive No. 9283.1-2.
16. Guide for Conducting Treatability Studies Under CERCLA, U.S. EPA, Office of Emergency and Remedial
Response, Prepublication version.
17. Guide to Management of Investigation-Derived Wastes, U.S. EPA, Office of Solid Waste and Emergency
Response, Publication 9345.3-03FS, January 1992.
18. Guidelines and Specifications for Preparing Quality Assurance Project Plans, U.S. EPA, Office of Research
and Development, Cincinnati, OH, QAMS-004/80, December 29, 1980.
19. Health and Safety Requirements of Employees Employed in Field Activities, U.S. EPA, Office of
Emergency add Remedial Response, July 12, 1982, EPA Order No. 1440.2.
20. Interim Guidance on Compliance with Applicable of Relevant and Appropriate Requirements, U.S. EPA,
Office of Emergency and Remedial Response, July 9, 1987, OSWER Directive No. 9234.0-05.
21. Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans, U.S. EPA, Office of
Emergency and Remedial Response, QAMS-005/80, December 1980.
22", Methods for Evaluating the Attainment of Cleanup Standards: Vol. 1, Soils and Solid Media, February
1989, EPA 23/02^89-042; vol. 2, Ground water (Jul 1992).
23. National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule, Federal Register 40 CFR
Part 300, March 8, 1990.
24 NIOSH Manual of Analytical Methods, 2nd edition. Volumes I-VII for the 3rd edition, Volumes I and II,
National Institute of Occupational Safety and Health.
25 Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, National Institute of
Occupational Safety and Health/Occupational Health and Safety Administration/United States Coast
Guard/Environmental Protection Agency, October 1985.
26 Permits and Permit Equivalency Processes for CERCLA On-Site Response Actions, February 19, 1992,
OSWER Directive 9355.7-03.
27 Procedure for Planning and Implementing Off-Site Response Actions, Federal Register, Volume 50,
Number 2l4"} November 1985, pages 45933-45937.
34
tfodel RD SOW (6/95)
-------
28. Procedures for Completion and Deletion of NPL Sites, U.S. EPA, Office of Emergency and Remedial
Response, April 1989, OSWER Directive No. 9320.2-3A.
29. Quality in the Constructed Project: A Guideline for Owners, Designers and Constructors, Volume 1,
Preliminary Edition for Trial Use and Comment, American Society of Civil Engineers, May 1988.
30. Remedial Design/Remedial Action (RD/RA) Handbook, U.S. EPA, Office of Solid Waste and Emergency
Response (OSWER), 9355.0-04B, EPA 540/R-95/059, June 1995.
31. Revision of Policy Regarding Superfund Project Assignments, OSWER Directive No. 9242.3-08,
December 10, 1991. [Guidance, p. 2-2]
32. Scoping the Remedial Design (Fact Sheet), February 1995, OSWER Publ. 9355-5-21 FS.
33. Standard Operating Safety Guides, U.S. EPA, Office of Emergency and Remedial Response, November
1984.
34. Standards for the Construction Industry, Code of Federal Regulations, Title 29, Part 1926, Occupational
Health and Safety Administration.
35. Standards for General Industry, Code of Federal Regulations, Title 29, Part 1910, Occupational Health and
Safety Administration.
36. Structure and Components of 5-Year Reviews, OSWER Directive No. 9355.7-02, May 23, 1991.
[Guidance, p. 3-5]
37. Superfund Guidance on EPA Oversight of Remedial Designs and Remedial Actions Performed by
Potentially Responsible Parties, April 1990, EPA/540/G-90/001.
38. Superfund Remedial Design and Remedial Action Guidance, U.S. EPA, Office of Emergency and Remedial
Response, June 1986, OSWER Directive No. 9355.0-4A.
39. Superfund Response Action Contracts (Fact Sheet), May 1993, OSWER Publ. 9242.2-08FS.
40. TLVs-Threshold Limit Values and Biological Exposure Indices for 1987-88, American Conference of
Governmental Industrial Hygienists.
41. Treatability Studies Under CERCLA, Final. U.S. EPA, Office of Solid Waste and Emergency Response,
EPA/540/R-92/071a, October 1992.
42. USEPA Contract Laboratory Program Statement of Work for Inorganic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, July 1988.
43. USEPA Contract Laboratory Program Statement of Work for Organic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, February 1988.
44. User's Guide to the EPA Contract Laboratory Program, U.S. EPA, Sample Management Office, August
1982.
45. Value Engineering (Fact Sheet), U.S. EPA, Office of Solid Waste and Emergency Response, Publication
9355.5-03FS, May 1990.
35 Model RD SOW (6/95)
-------
^ttacbtaent 4
TRANSMITTAL OF DOCUMENTS FOR ACCEPTANCE BY EPA
TO:
SUBTASK NO.
DATE:
FROM:
DELIVERABLE
NO. OF
COPIES
TRANSMITTAL NO.
1 1 New Transmittal
1 1 Resubmittal of
Transmittal No.
REMARKS
ACCEPTANCE ACTION
DOCUMENTS FOUND ACCEPTABLE (LIST BY SUBTASK NO.)
NAME/TITLE/SIGNATURE OF REVIEWER
DATE
-------
Attachment 5
TRANSMITTAL REGISTER
PROJECT TITLE AND LOCATION
d
Z
£t
-------
., I
-------
(date)
MODEL STATEMENT OF WORK FOR REMEDIAL DESIGN OVERSIGHT
SITE, COUNTY, STATE
ATTACHMENTS
Attachment 1. Summary of Major Submittals for the Remedial Design at (Site) 15
Attachment 2. Work Breakdown Structure 17
Attachment 3. Regulation and Guidance Documents 22
Attachment 4. Transmittal of Documents for Acceptance by EPA 24
Attachment 5. Transmittal Register 25
Points for the WAM/RPM to consider in preparing the Statement of Work for Remedial Design Oversight:
The purpose of this Statement of Work is twofold:
1. To tell the contractor what you want done. Be as specific as possible in describing what you want
the contractor to do. The contractor will write a work plan and budget describing how and at what cost the
requirements will be met and ultimately will be responsible for performing those requirements. Whenever
there is an absolute requirement (e.g., that the contractor prepare the QAPP in accordance with QAMS-
005/80, December 29, 1980), state it. Add the attachments to the SOW: (1) Summary of Major Submittals
for the Remedial Design at (Site), (2) Work Breakdown Structure, and (3) Transmittal of Documents
for Acceptance by EPA.
2. To give the contractor a work breakdown structure for recording costs. Work plan costs and final
costs of different RD oversight projects can be compared and analyzed with a work breakdown structure.
Use of a Work Breakdown Structure (WBS)
1. A WBS has been developed for this model work assignment so EPA may track the initial and final costs
of each element used for preparing future cost estimates. The WBS is, essentially, the outline for this work
assignment and is included as SOW Attachment 2 .
2. If an element is not used, do not change the numbering system; instead, insert "not used" or "N/A"
after the element number after deleting the text for that element.
3. For the items used for a given project, additional descriptions (e.g., type of samples and estimated
number) should be added hi order for the contractor and RPMAVAM to develop estimated costs on a
common basis.
6.0 Introduction
.0.1 Site Description
Provide a brief site description that contains information relative to RD oversight planning and
implementation such as location, operational history, remedial response history, waste types, quantities, and
milestones specified within the ROD.
Model RD Oversight SOW (6/95)
-------
.0.2 Purpose
The purpose of this work assignment is to obtain contractor support for the oversight of the
remedial design (RD) at the (site). Implementation of the RD shall be performed by
the Potentially Responsible Parties (PRPs). The estimated completion date for this work assignment
is .
.0.2.J Description of the RD
Describe the specific RD for which oversight is required. Provide a summary of the general response
objectives, description of the remedy, and expected period of performance of the RD.
.0.2.2 Objectives of Oversight. The primary objective of PRP oversight is to ensure that the
remedies specified hi the RD and used in the remedial action (RA) protect public health and
the environment during the life of the project and are implemented in compliance with the
terjns of the Settlement Agreement. Oversight meets its objectives by observing and
documenting that the PRP has complied with all applicable laws, regulations, and
requirements, and has met all performance standards specified in the Settlement Agreement.
.0.3 General Requirements
.0.3.1 The contractor shall conduct the RD Oversight in accordance with this Statement of Work
(SOW) and to ensure consistency with the ROD issued on (date), the Consent
Decree, the Remedial Design/Remedial Action (RD/RA) Handbook (U.S. EPA Office of
Solid Waste and Emergency Response (OSWER), 9355.0-04B, EPA 540/R-95/059, June
1995) and all other guidance used by EPA hi conducting an RD/RA. See references listed
in Attachment 3. The primary contact for this work assignment is , Tel. ; the
secondary contact is , Tel. .
.0.3.2 A summary of the major deliverables and the schedule for submittal is attached. See
Attachment 1. The contractor shall submit the major deliverables using the form
Transmittal of Documents for Acceptance by EPA. Attachment 4
The attachments to this model SOW may be copied and completed for a given RD. Attachment 4 is a form
for use by the contractor hi the transmittal of documents to EPA. Attachment 5 is a transmittal register log
for use by the WAM/RPM hi tracking documents submitted by the contractor.
.0.3.3 Specifically, the RD involves the design of
.0.3.4 The contractor shall furnish all necessary and appropriate personnel, materials, and services
nefeded, or incidental to, performing and completing the RD oversight.
.0.3,5 A list of primary guidance and reference material is attached. See Attachment 2. In all
cases, the contractor shall use the most recently issued guidance.
.0.3.6 tlys contractor shall maintain oversight files as specified in the contract and by the Work
Assignment Manager or Remedial Project Manager (WAM/RPM). The WAM/RPM may
periodically audit the site files and record-keeping procedures.
.0.3.7 The contractor shall communicate at least weekly with the WAM/RPM, either in person or
through conference calling, to report on oversight progress.
.0.3.8 The contractor shall notify the WAM/RPM when 75 percent and when 95 percent of the
approved work assignment budget has been expended.
.0.3.9 The contractor shall document all decisions that are made in meetings and conversations
With EPA or the PRP. The contractor shall forward this documentation to the WAM/RPM
within 2 working days of the meeting or conversation.
It is the WAM's responsibility to document fully all decisions made. The contractor's documentation is
used for confirmation only.
Model RD Oversight SOW (6/95)
-------
.0.3.10 EPA will provide oversight of contractor activities throughout the RD oversight efforts.
EPA review and approval of the contractor's deliverables is a tool to assist this process
and to satisfy, in part, EPA's responsibility to provide effective protection of public
health, welfare, and the environment during the Contractor's oversight of the PRP's
remedial activities. EPA will review the deliverables prepared during the oversight to
assess the likelihood that the RD will achieve its remediation goals and that all
performance requirements applicable to the
RD have been correctly identified and implemented. However, acceptance of deliverables
by EPA does not relieve the contractor of responsibility for the adequacy of the deliverable.
.0.4 Oversight Official
The contractor shall designate one or more Oversight Officials to work directly with the
WAM/RPM during the RD oversight. The Oversight Official(s) is (are) the individual(s)
responsible under this Statement of Work for providing technical support in monitoring PRP
compliance with the Settlement Agreement.
.0.5 Equipment Transfer
At the completion of the work assignment, the contractor shall transfer all equipment purchased with
contract funds to the EPA Equipment Coordinator in accordance with the contract.
.0.6 Project Closeout
At the completion of the work assignment, the contractor shall perform all necessary project
closeout activities as specified in the Contract. These activities may include closing out any
subcontracts, indexing and consolidating project records and files as required in 6.0.3.6 above, and
providing a technical and financial closeout report to EPA.
The task structure that follows has been drafted to support the development of a comprehensive RD
Oversight SOW to execute a well-defined RD, but can be tailored to support a phased RD SOW to which
amendments will be made over the project life cycle as more specific requirements for RD oversight
activities are determined.
6.1 Project Planning and Support
.1.1 Project Planning. This task includes efforts related to project initiation.
.1.1.1 Attend Scoping Meeting. The contractor shall attend a scoping meeting to be held at the
EPA Regional Office before or concurrent with developing the oversight Work Plan.
The location of meetings (and approximate number of contractor attendees) should be specified for cost-
estimating purposes.
. 1.1.2 Conduct Site Visit. The contractor shall conduct a 1-day site visit with the EPA
WAM/RPM during the project planning phase to develop a conceptual understanding of the
site and the RD scope and requirements. A Health and Safety Plan (HASP) is required for
the site visit. The contractor shall prepare a letter report that documents all EPA,
contractor, and site personnel present at the visit; all decisions made during the visit; any
action items assigned, including person responsible and due date; any unusual occurrences
during the visit; and any portions of the site that were not accessible to the contractor and
the impact of this on oversight of the remedial design. This report shall be submitted to the
EPA WAM/RPM within 10 calendar days of the site visit.
Model RD Oversight SOW (6/95)
-------
kl.1.3 Evaluate Existing Information. The contractor shall obtain, copy (if necessary), and review
available information pertaining to the site from EPA. The contractor shall evaluate the
existing data and documents, including the Record of Decision (ROD), the Consent Decree
(CD), the PRP Work Plan for the RD/RA, and other data and documents as directed by
EPA. The specific documents to be reviewed are listed in Attachment 3.
The RPM will create an attachment to this SOW that lists site-specific information that the contractor may
use in oversight of the remedial design (see Chapter 3 of the Guidance for Scoping the Remedial Design).
To streamline this task and control expenses, limit the review to documents that help the contractor to scope
the project accurately and optimize oversight tasking. Specify reports and other documentation that
establish the nature and extent of contamination: a summary of risk(s), a list of cleanup targets, and the
basis for design. At a minimum, this should include the ROD, the CD, and the PRP work plan.
Additional documents that may be appropriate include the Remedial Investigation/Feasibility Study (RI/FS),
Focused Feasibility Studies (FFS), State documentation, applicable or relevant and appropriate requirements
(ARARs), evaluations, hydrogeological information, and other material located in the site file.
.1.1.4 (Not Used)
.1.1.5 Develop RD Oversight Work Plan
(1) Develop Draft Oversight Work Plan. The contractor shall prepare and submit a Draft
RD Oversight Work Plan within 30 calendar days after initiation of the work
assignment (WA). The contractor shall use information from the EPA-approved PRP
Work Plan, appropriate guidance, and direction provided by the EPA WAM/RPM as
the basis for preparing the RD Oversight Work Plan. RD oversight work must be
coordinated and properly sequenced with EPA and PRP RD activities. Submit the
Original to the Contracting Officer (CO), one copy to the Project Officer (PO), and one
copy to the WAM/RPM.
1. The RPM/WAM should verify the draft and final work plan submittal timeframes with the PO.
2. Additional copies of the work plan can be submitted to the WAM/RPM, if specified, for distribution to
other technical staff.
(a) Develop Narrative. The RD Oversight Work Plan shall include a comprehensive
description of project tasks, the procedures to accomplish them, quality
assurance/quality control (QA/QC) systems and project-specific QA/QC
procedures to be followed, project documentation, and project schedule.
Specifically, the Work Plan shall include the following:
- Identification of RD project elements and the associated oversight tasking
including review of PRP planning, design, and activity reporting
documentation; field sampling and analysis activities, and treatability study
activities. Output of this task will be a detailed work breakdown structure of
the RD oversight project.
- The contractor's technical and management approach to each task to be
performed, including a detailed description of each task; the assumptions used;
the identification of any technical uncertainties (with a proposal for the
resolution of those uncertainties); the information needed for each task; any
information to be produced during and at the conclusion of each task; and a
description of the work products that will be submitted to EPA. Information
Model RD Oversight SOW (6/95)
-------
shall be presented in a sequence consistent with the work breakdown structure
format defined in the standard WBS. See Attachment .
A schedule with specific dates for the start and completion of each required
activity and submission of each deliverable required by this SOW. (See
Attachment 1 for format.) This schedule shall also include information
regarding timing, initiation, and completion of all critical path milestones for
each activity and deliverable and the expected review time for EPA.
A project communications and management plan, including a data management
plan and contractor reporting requirements, such as meetings and presentations
to EPA at the conclusion of major phases of the project. The data
management plan shall address the requirements for project management
systems including tracking, storing, and retrieving data and also shall identify
software to be used, minimum data requirements, data format, and backup data
management. The plan shall address both data management and document
control for all oversight activities conducted during the RD.
The WAM/RPM should consider issuing the RD oversight WA in phases and modifying the SOW for
funding as more information is available. This will enable the WAM/RPM to prepare a more detailed and
accurate SOW and IGCE for each tasked phase.
The oversight contractor may be tasked to conduct oversight activities in the following steps:
1. Review documents, including the PRP work plan, to develop the oversight work plan. If the PRP work
plan is unavailable, then the WAM/RPM may want to task the contractor to review background information
and to provide general startup support.
2. Develop the oversight work plan.
3. Modify the scope of work for funding to include RA oversight activities.
(b) Develop Cost Estimate. The contractor's estimated cost to complete the work
shall be broken down into the Level of Effort (by P-level) and cost for each
element of the Work Breakdown Structure (Attachment 2) and submitted to EPA
on disk.
(c) Perform Internal QA and Submit Draft Oversight Work Plan
(2) Prepare Final Oversight Work Plan
(a) Attend Negotiation Meeting. The contractor shall attend a Work Plan negotiation
meeting at the Region office. EPA and the Oversight Contractor will refine
the SOW requirements and funding issues related to the Oversight Work Plan.
(b) Modify Draft Oversight Work Plan and Cost Estimate
Model RD Oversight SOW (6/95)
-------
If the RD project is implemented using a phased approach to develop additional information throughout the
RD phase, the WAM/RPM should specify the anticipated number of modifications and, to the extent
possible, the scope of the modification(s).
Examples:
1. If the extent of contamination is not fully defined, indicate that the length of field work is not fully
delineated and a modification may be required to accommodate this unqualified field element.
2. If treatability testing is ongoing and may significantly affect RD activities, but oversight is required for
treatability activities, specify that the RD Oversight Work Plan will be completed in multiple phases
(c) Perform Internal QA and Submit Final Oversight Work Plan within 15 days after
receipt of EPA comments on the draft work plan.
.1.1.6 Review PRP Plans. The contractor shall review the following PRP-developed work plans
for conformance with applicable EPA standards and guidance (see also Task 6.7 for review
instructions) and provide written review comments to the WAM/RPM.
(1) Review PRP Site Management Plan
(a) Review PRP Pollution Control & Mitigation Plan
(b) Review PRP Transportation and Disposal (of site-derived wastes) Plan
(2) Review PRP Health and Safety Plan
(3) Review PRP Sampling and Analysis Plan (Chemical Data Acquisition Plan)
(a) Review PRP Quality Assurance Project Plan (QAPP)
(b) Review PRP Field Sampling Plan (FSP)
(c) Review PRP Data Management Plan
(4) Review Other PRP Plan(s)
.1.2 Preparation of Site-Specific Plans
.1.2,1 (l|otused)
.1,2.2 Develop Health and Safety Plan. Prepare a site-specific HASP that specifies employee
training, protective equipment, medical surveillance requirements, standard operating
procedures, and a contingency plan in accordance with 29 CFR 1910.120 1(1) and (1)(2).
Whenever possible, use the HASP developed for the Remedial Investigation/Feasibility
Study (RI/FS) in preparing the HASP for the RD.
1. The HASP may not constitute an Emergency Response Plan. Site conditions may warrant a separate
deliverable.
2. EPA does not approve the contractor's HASP, but reviews it to ensure that it is complete and adequately
protective.
.1.2.3 Envelop Sampling and Analysis Plan (Chemical Data Acquisition Plan). Prepare an FSP
: that defines the oversight sampling and information-collection methods that shall be used for
the project. It shall include sampling objectives; sample locations and frequency; sampling
equipment and procedures; sample handling and analysis; and which samples are to be
Analyzed through the Contract Laboratory Program (CLP), which through other sources,
arid the justification for those decisions. The FSP shall be written so that a field sampling
team unfamiliar with the site would be able to gather the samples and field information
required. The FSP developed for the RI/FS should be used whenever possible in preparing
the FSP for the RD oversight activities.
Model RD Oversight SOW (6/95)
-------
1. Depending on the complexity of the sampling effort needed to support the RD, the FSP and QAPP can
be combined into a single Sampling and Analysis Plan (SAP).
2. Minimize FSP preparation costs by requiring the oversight contractor to utilize the RI/FS FSP as a
reference during the development of its sampling plan.
(1) Quality Assurance Project Plan. Prepare a QAPP in accordance with QAMS-005/80
(December 29, 1980). The QAPP shall describe the project objectives and
organization, functional activities, and QA/QC protocols that shall be used to achieve
the desired Data Quality Objectives (DQOs). The DQOs shall, at a minimum, reflect
use of analytical methods for identifying contamination and addressing contamination
consistent with the levels for remedial action objectives identified in the National
Contingency Plan.
(2) Field Sampling Plan. The contractor shall prepare an FSP that defines the oversight
sampling and information-collection methods that shall be used for the project. It shall
include sampling objectives; sample locations and frequency; sampling equipment and
procedures; sample handling and analysis; and description of which samples are to be
analyzed through the CLP, which through other sources, and the justification for those
decisions. The FSP shall be written so that a field sampling team unfamiliar with the
site would be able to gather the samples and field information required. The FSP
developed for the RI/FS should be used whenever possible in preparing the FSP for the
RD/RA Oversight activities.
(3) Data Management Plan
1.2.4 Other Plan(s)
.1.3 Project Management
The contractor shall perform general work assignment management including management and
tracking of costs, preparation of Monthly Progress Reports, attendance at project meetings, and
preparation and submittal of invoices.
If the contractor finds that the RA being designed differs significantly from the ROD, the
construction or implementation is not consistent with the design, requirements delineated within the
Consent Decree are not being met, or that there are compliance issues with applicable or relevant
and appropriate requirements (ARARs) at any point hi the process, the contractor shall notify the
WAM/RPM immediately to describe the issue. The contractor shall then recommend technical
solutions in a memorandum ASAP.
.1.3.1 Prepare Periodic Status Reports. The contractor shall prepare monthly progress reports.
(1) Document Cost and Performance Status. The contractor shall document the status of
each task and report costs and Level of Effort (by P-level) expended to date.
(2) Prepare and Submit Invoices
.1.3.2 Participate hi Meetings and Communicate Routinely. The contractor shall attend project
meetings, provide documentation of meeting results, and shall contact the WAM/RPM by
telephone on a weekly basis to report project status.
.1.3.3 (Not used)
.1.3.4 (Not used)
.1.3.5 (Not used)
.1.3.6 Manage, Track, and Report Equipment Status
.1.3.7 Work Assignment Closeout
. 1.4 Subcontract Procurement and Support Activities
.1.4.1 Identify and Procure Subcontractors
(1) (Not used)—Drilling Subcontractor
(2) (Not used)—Surveying Subcontractor
7 Model RD Oversight SOW (6/95)
-------
(3) (Not used)—Geophysical Subcontractor
(4) (Not used)—Site Preparation Subcontractor
(5) Analytical Services Subcontractor(s)
(6) (Not used)—Waste Disposal Subcontractor
(7) (Not used)—Treatability Subcontractor(s)
(8) Other(s)
.1.4.2 Develop Subcontractor QA Program
.1.4,3 Perform Subcontract Management
:• !<'. :-i • ," •• j
6.2 Community Relations
This task includes efforts related to the update and implementation of the Community Relations Plan
(CRP) for the site. The contractor shall provide community relations support to EPA throughout the RD
in accordance with Community Relations in Superfund — A Handbook, June 1988. Community relations
shall encompass the following subtasks:
Listed below are a number of possible community relations activities the WAM/RPM may require. The
WAM/RPM should determine the community relations activities the PRP is conducting and coordinate to
the extent practical to avoid duplication of effort.
.2.1 Develop Community Relations Plan
.2.1.1 Conduct Community Interviews
.2.1.2 Update CRP. The contractor shall update the RI/FS CRP to address community relations
requirements during the RD.
(1) Draft CRP
(2) Final CRP '
.2.2 Prepare Fact Sheets
The contractor shall prepare a fact sheet to inform the public about activities related to the final
design, a schedule for the RD and later for the RA, activities to be expected during construction,
provisions for responding to emergency releases and spills, and any potential inconveniences such as
excess traffic and noise that may affect the community during onsite activities.
.2.3 Public Hearing, Meetings, and Availability Support
The contractor shall prepare presentation materials and provide support as needed for public
meetings. The contractor shall assist in communication and coordination with local agencies. The
contractor shall attend citizen advisory group meetings
The number and location of anticipated public meetings should be identified in the SOW for cost estimating
purposes.
.2.3.1 Technical Support. The contractor shall prepare technical input to news releases, briefing
materials, and other community relations vehicles.
.2.3.2 Logistical and Presentation Support
.2.3.3 Writing and Placement of Public Notice Support
.2.4 Maintain Information Repository/Mailing List
The contractor shall maintain a repository of information on activities related to the RD as described
in Appendix A.8, page A-19, of Community Relations in Superfund—A Handbook, June 1988. The
contractor shall also maintain and update mailing lists to ensure that all companies, persons, and/or
agencies are notified of site activities and scheduled public meetings as required.
Model RD Oversight SOW (6/95)
-------
The WAM/RPM should specify the format for submissions if there are Region-specific or other
requirements.
6.3 Data Acquisition Oversight
This task involves oversight of work efforts related to sampling during both RD and RA. The purpose of
the sampling is to compare results with PRP data. The planning for this task is accomplished in Task 6.1,
Project Planning, whereby all of the necessary plans required to collect the field data are determined and
arranged. This task begins with EPA's approval of the FSP prior to RD and ends with the demobilization
of field personnel and equipment from the site after RA is complete.
The contractor shall perform the following field activities or a combination of activities for the data
acquisition effort in accordance with the EPA-approved FSP and QAPP developed in Task 6.1:
Before beginning field activities, consider specifying a kickoff meeting with all principal personnel to clarify
objectives and communication channels to ensure the efficient use of available funds.
.3.1 Mobilization and Demobilization Oversight
The contractor shall oversee procurement of the necessary personnel, equipment, and materials for
efficient mobilization and demobilization to and from the site.
.3.1.1 (Not used) ;
.3.1.2 Mobilization Oversight
(1) (Not used)
(2) Installation of Utilities
(3) Construction of Temporary Facilities
(a) Construct Decontamination Facilities
(b) Construct Sample or Derived Waste Storage Facility
(c) Construct Field Offices
(d) Construct Mobile Laboratory
(e) Construct Other Temporary Facilities
.3.1.3 Demobilization Oversight
(1) Removal of Temporary Facilities
(2) Site Restoration
.3.2 Perform Field Investigation Oversight
The contractor shall collect a percentage of split samples for analysis during RD. Split sampling
during RD is required for comparison with the remediation contractor's data.
The WAM/RPM should specify the expected written and/or photographic documentation to be recorded in
the field as well as the type of field activity reports expected by the RPM, the frequency, and the required
distribution (RPM, State representative, etc.).
Ensure the proper management of samples by the PRP, including accurate chain-of-custody
procedures for sample tracking, protective sample-packing techniques, and proper sample-
preservation techniques. Ensure that the PRP characterizes and disposes of investigation-derived
wastes in accordance with local, State and Federal regulations as specified in the FSP (see the Fact
Sheet Guide to Management of Investigation-Derived Wastes, 9345.3-03FS, January 1992).
.3.2.1 Perform Site Reconnaissance Oversight
(1) Ecological Resources Reconnaissance
Model RD Oversight SOW (6/95)
-------
(2) Well Inventory
(3) Residential Well Sampling
(4) Land Survey
(5) Topographic Mapping
(6) Field Screening
.3.2.2 Perform Geological Investigations Oversight (Soils and Sediments)
.3.2.3 Perform Air Investigations Oversight
.3.2.4 Perform Hydrogeological Investigations Oversight—Ground Water
(1) Well Systems Installation
(2) Sample Collection
(3) Samples collected during drilling (e.g., hydro punch or equivalent)
(4) Tidal Influence Study
(5) Hydraulic Tests (Pump Tests)
(6) Ground-Water Elevation Measurement
.3.2.5 Perform Hydrogeological Investigations Oversight—Surface Water
.3.2.6 Perform Waste Investigation Oversight
.3.2.7 Perform Geophysical Investigation Oversight
.3.2.8 Perform Ecological Investigation Oversight
.3.2.9 Perform Contaminated Building Samples Oversight
.3.2.10 Perform Disposal of Investigation-Derived Waste Oversight
.3.2.11 Perform Prepare Data Acquisition Oversight Reports
I : ' •: • , • .. . I
111 ' " i
6.4 Analysis of Split Samples
.4.1 Perform Screening-Type Laboratory Sample Analysis
,4.1.1 Analyze Air and Gas Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.2 Analyze Ground-Water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.3 An&lyze Surface-Water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.4 Analyze Soil and Sediment Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.5 Analyze Waste (Gas) Samples
(1| Organic
(2) Inorganic
(3) Radiochemistry
.4.1.6 Analyze Waste (Liquid) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.7 Analyze Waste (Solid) Samples
(1) Organic
(2) Inorganic
10 Model to Oversight SOW (6/95)
-------
(3) Radiochemistry
.4.1.8 Analyze Biota Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.9 Analyze Bioassay Samples
.4.1.10 Perform Bioaccumulation Studies
.4.2 CLP-Type Laboratory Sample Analysis
The contractor shall request CLP analytical services in accordance with procedures outlined in the
User's Guide to the Contract Laboratory Program, EPA, December 1986.
.4.2.1 Analyze Air/Gas Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.2 Analyze Ground-Water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.3 Analyze Surface-Water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.4 Analyze Soil and Sediment Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.5 Analyze Waste (Gas) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.6 Analyze Waste (Liquid) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.7 Analyze Waste (Solid) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.8 Analyze Biota Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.9 Analyze Bioassay Samples
.4.2.10 Perform Bioaccumulation Studies
6.5 Analytical Support and Data Validation of Split Samples
The contractor shall arrange for the analysis and validation of environmental split samples collected. The
sample analysis and validation task begins with reserving sample slots in the CLP and the completion of
the RD field sampling program. This task ends with contractor validation of the analytical data received
from the laboratory. The contractor shall perform the following activities or combination of activities to
analyze and validate test results:
11 Model RD Oversight SOW (6/95)
-------
.5.1 Prepare and Ship Environmental Samples
.5.1.1 Ground-Water Samples
.5.1.2 Surface and Subsurface Soil Samples
.5.1.3 Surface-Water and Sediment Samples
.5.1.4 Air Samples
,5.1.5 Biota Samples
.5.1.6 Other Types of Media Sampling and Screening
.5.2 Coordinate With Appropriate Sample Management Personnel
.5.3 Implement EPA-Approved Laboratory QA Program
.5.4 Provide Sample Management (chain of custody, sample retention, and data storage)
,5.5 Perform Data Validation
The contractor shall perform appropriate data validation to ensure that the data are accurate and
defensible. Complete the necessary summary tables, validation worksheets, and DQO summary
forms, '' , '.,..!.
For the RD, full data validation procedures are usually not necessary. The WAM/RPM may want to
specify the level of data validation required.
.5.5.1 Review Analysis Results Against Validation Criteria
.5.5.2 Provide Written Documentation of Validation Efforts
Implement quality control procedures to ensure the quality of all reports and submittals to
EPA.
The WAM/RPM should specify the format for submissions if there are Region-specific or other specific
requirements.
6.6 Data Evaluation of Split Samples
This task involves comparison of the PRP's data that will be used in the remedial design effort with data
resulting from the analysis of split samples. Data evaluation begins with the receipt of analytical data
from the data acquisition task and ends with the submittal of a Data Evaluation Summary Report.
Specifically, the contractor shall compare, evaluate, interpret, and tabulate data in an appropriate
presentation format for final data tables.
.6.1 Data Useability Evaluation and Field QA/QC
.6.2 Data Reduction, Tabulation, and Evaluation
.6.2.1 Evaluate Geological Data (Soils and Sediments)
.6.2.2 Evaluate Air Data
.6.2.3 Evaluate Hydrogeological Data—Ground Water
.6.2.4 Evaluate Hydrogeological Data—Surface Water
.6.2.5 Evaluate Waste Data I
.6.2.6 Evaluate Geophysical Data
.6.2.7 Evaluate Ecological Data
.6.3 Modeling
.6.3.1 Contaminant Fate and Transport
.6.3.2 Water Quality
.6.3.3 Ground Water
.6.3.4 Air '
.6.3.5 Otfjer Modeling
.6.4 Develop Data Evaluation Report
12
Model RD Oversight SOW (6/95)
-------
The contractor shall evaluate and present results in a Data Evaluation Summary Report to .submit to
the WAM/RPM for review and approval. The report will include a comparison of the split sample
data collected with PRP data. After the WAM/RPM's review, attend a meeting with EPA to
discuss data evaluation results and next steps.
Implement quality control procedures to ensure the quality of all reports and submittals to EPA.
These procedures shall include, but are not limited to, internal technical and editorial review; and
the documentation of all reviews, the problems identified, and corrective actions taken.
The WAM/RPM should specify that the contractor prepare and submit a Technical Memorandum to the
WAM/RPM if new analytical data needs or significant data problems are identified during the evaluation.
6.7 Review of PRP Remedial Design Documents
This task involves work efforts to review PRP RD submittals. The contractor shall perform reviews to
focus on the technical and engineering merit. Letter reports will be submitted upon the completion of
each
review by the oversight contractor within 21 calendar days of the start of the review, identifying specific
issues and suggested corrective action. The following factors are to be considered during the review of all
PRP submittals:
• Technical requirements of the ROD, Unilateral Administrative Order (UAO), Administrative Order
of Consent (AOC), CD, and compliance with ARARs
• Standard professional engineering practices
• Applicable statutes, EPA policies, directives, and regulations (see Attachment 3)
• Spot checking design calculations to assess accuracy and quality of design activities
• Examination of planning and construction schedules for meeting project completion goals
The oversight contractor shall review the PRP-prepared planning, predesign, and design project
documentation to ensure professional quality, technical accuracy, compliance with the PRP RD Work
Plan, the ROD and Consent Decree, CERCLA, and all ARARs.
.7.1 Review PRP Remedial Design Documents
.7.1.1 Review Preliminary Design
(1) Project Delivery Strategy and Scheduling
(2) Preliminary Construction Schedule
(3) Specifications Outline
(4) Preliminary Drawings
(5) Basis of Design Report/Design Analysis
(6) Preliminary Cost Estimate
(7) PRP Description of Variances with ROD
(8) PRP Response to Design Review Comments
(9) Participate in Preliminary Design Review/Briefing
.7.1.2 Review (PRP Remedial) Intermediate Design Documents
(1) Construction Schedule
(2) Preliminary Specifications
(3) Intermediate Drawings
(4) Basis of Design Report/Design Analysis
(5) Revised Cost Estimate
(6) PRP Description of Variances with ROD
(7) PRP Response to Design Review Comments
(8) Participate in Intermediate Design Review/Briefing
13 Model RD Oversight SOW (6/95)
-------
.7.2
.7.1.3 Review Prefinal/Final Design
(1) Prefmal Design Specifications
(2) Prefinal Drawings
(3) Basis of Design Report/Design Analysis
(4) Revised Cost Estimate
(5) Final Design Submittal
(6) Participate in Prefinal/Final Design Review
(7) Subcontract Award Document(s)
(8) Biddability (Offerability) and Constructability Reviews
(9) Revised Project Delivery Strategy
(Not used)
6.8 Technical Meeting Support
." ' ' ' ' • • .'• ' • | :
This task includes work efforts related to attendance at and documentation of meetings with EPA, PRPs,
the PRP contractor, and the State Agency. The contractor shall attend meetings and provide
documentation of meeting results. Within days after a meeting, the contractor will submit to the
WAM/RPMa written report summarizing the meeting results. Meetings may be scheduled to coincide
With the following specific milestones during the RD/RA:
'" ' ' '' '•• I ' : "! ' ,'.!., I?" 1 ,
• At PRP RD Work Plan Review
• At Design Submittal Reviews
• Before initiating onsite field sampling and treatability study during design
• At completion of all sampling during design
6.9 Work Assignment Closeout
ii
.9.1 Return Documents to Government
.9.2 Duplicate, Distribute, and Store Files
.9.3 Archive Files
V il; j1 , Hull j III' I ' i 'i1 I , ,
.9.4 Prepare Microfiche, Microfilm, and/or Optical Disk
,9.5 Prepare Closeout Report. The contractor shall include a breakdown on disk of final costs and Level
of Effort (by P-level) in the same detail and format as the Work Breakdown Structure
(Attachment 2).
14
Model RD Oversight SOW (6/95)
;:il
-------
Attachment 1
Summary of Major Submittals for the Remedial Design Oversight at
(Site)
TASK
6.1.1.2
6.1.1.5
6.1.1.5
6.1.1.6
6.1.2.2
6.1.2.3(1)
6.1.2.3(2)
6.1.2.2
6.1.2.3(1)
6.1.2.3(2)
6.2.1
6.2.1
DELIVERABLE
Site Visit Report
Draft RD Oversight Work Plan
Final RD Oversight Work Plan
Comments on Reviews of PRP
Plans
Draft HASP
Draft QAPP
Draft FSP
Final HASP
Final QAPP
Final FSP
Draft Revised CRP
Final Revised CRP
REF
NO.*
5
8
19
21
36
36
19
21
8
5
36
19
21
8
5
4
4
NO. OF
COPIES
3
3
3
3
3
3
3
3
3
3
3
3
DUE DATE
(calendar days)
10 days after site visit
30 days after initiation of work
assignment (WA)
15 days after receipt of EPA
comments
21 days after receipt of work plans
from EPA
30 days after initiation of WA
30 days after initiation of WA
30 days after initiation of WA
15 days after receipt of EPA
comments
15 days after receipt of EPA
comments
15 days after receipt of EPA
comments
(#) days after initiation of WA
(#) days after receipt of EPA
comments
EPA REVIEW
PERIOD
7 days- after receipt of report
21 days after receipt of Work Plan
NA
NA
21 days after receipt of HASP
21 days after receipt of QAPP
21 days after receipt of FSP
NA
NA
NA
14 days after receipt of revised
CRP
NA
-------
Attachment 1
Summary of Major Stibmittals for the Remedial IJesign Oversight at
(Site) (continued)
lift
TASK
6.2.2
6.6.4
6.7
DELIVERABLE
Fact Sheets
Data Evaluation Summary
Report
Letter Reports
REF
NO.*
NO. OF
COPIES
3
3
3
DUE DATE
(calendar days)
As needed
10 days after receipt of analytical
results from laboratory
21 days after receipt of PRP
design submittal
EPA REVIEW
PERIOD
10 days after receipt of fact sheet
15 days after receipt of report
14 days after receipt of letter
report
*See Attachment 3 for list of references
-------
Attachment 2
Work Breakdown Structure (WBS) for
Remedial Design Oversight (RDO)
6.0 Remedial Design Oversight
.01 Project Planning and Support
.01 Project Planning
.01 Attend Scoping Meeting
.02 Conduct Site Visit
.03 Evaluate Existing Information
.04 Oversight Work Plan Development
.01 Draft Oversight Work Plan Development
.01 Develop Narrative
.02 Develop Cost Estimate
.03 Internal QA & Submission
.02 Final Oversight Work Plan Preparation
.01 Attend Negotiation Meeting
.02 Modify Draft Work Plan and Cost Estimate
.03 Internal QA & Submission
.05 Review PRP Plans
.01 Review PRP Site Management Plan
.01 Review PRP Pollution Control & Mitigation Plan
.02 Review PRP T&D Plan
.02 Review PRP Health & Safety Plan
.03 Review PRP Sampling & Analysis Plan (Chemical Data Acquisition Plan)
.01 Review PRP Quality Assurance Project Plan
.02 Review PRP Field Sampling Plan
.03 Review PRP Data Management Plan
.04 Other PRP Plan(s)
.02 Preparation of Site-Specific Plans
.01 Not used
.02 Develop Health & Safety Plan
.03 Sampling & Analysis Plan (Chemical Data Acquisition Plan)
.01 Quality Assurance Project Plan
.02 Field Sampling Plan
.03 Data Management Plan
.04 Other Plan(s)
.03 Project Management
.01 Prepare Periodic Status Reports
.01 Document Cost and Performance Status
.02 Prepare/Submit Invoices
.02 Meeting Participation/Routine Communications
.03 Maintain Cost/Schedule Control System
.04 Perform Value Engineering
.05 Perform Engineering Network Analysis
.06 Manage, Track, and Report Equipment Status
.07 Work Assignment Closeout
.04 Subcontract Procurement/Support Activities
.01 ID and Procurement of Subcontractors
.01 Not used —Drilling Subcontractor
.02 Not used -Surveying Subcontractor
17 Model RD Oversight SOW (6/95)
-------
.03 Not used -Geophysical Subcontractor
.04 Not used-Site Preparation Subcontractor
.05 Analytical Services Subcontractor(s)
.06 Not used—Waste Disposal Subcontractor
.07 Not used—Treatability Subcontractor(s)
.08 Other(s)
.02 Contractor QA Program
.03 Perform Subcontract Management
.02 Community Relations
.01 Community Relations Plan (CRP) Development
.01 Conduct Community Interviews
.02 Update CRP
.01 Draft CRP
.02 Final CRP
.02 Prepare Fact Sheets
.03 Public Hearing, Meetings, & Availability Support
.01 Technical Support
.02 Logistical & Presentation Support
.03 Public Notice Support (writing, or placement of)
.04 Maintain Information Repository/Mailing List
.03 Data Acquisition Oversight
.01 Mobilization/Demobilization Oversight
.01 Not used-ID field support equipment/supplies/facilities
.02 Mobilization Oversight
.01 Site Preparation
.01 Perform Demolition
.02 Clearing and Grubbing
.03 Perform Earthwork
.01 Provide Borrow Pit
.02 Construct Haul Roads
.04 Construct Roads/Parking/Curbs/Walks
.05 Install Storm Drainage/Subdrainage
.06 Install Fencing/Site Security
.02 Installation of Utilities
.01 Install Electrical Distribution
.02 Install Telephone/Communication System(s)
.03 Install Water/Sewer/Gas Distribution
.04 Install Fuel Line Distribution
.03 Construction of Temporary Facilities
.01 Construct Decontamination Facilities
.02 Construct Sample/Derived Waste Storage Facility
.03 Construct Field Offices
.04 Construct Mobile Laboratory
.05 Construct Other Temporary Facilities
.03 Demobilization Oversight
.01 Removal of Temporary Facilities
.02 She Restoration
.02 Field Investigation
.01 Site Reconnaissance Oversight
.01 Ecological Resources Reconnaissance
.02 Well Inventory
.03 Residential Well Sampling
.04 Land Survey
.05 Topographic Mapping
.06 Field Screening
18 Model RD Oversight SOW (6/95)
-------
.02 Geological Investigations Oversight (Soils/Sediments)
.01 Surface Soil Sample Collection
.03 Air Investigations Oversight
.04 Hydrogeological Investigations Oversight-Ground Water
.01 Well Systems Installation
.02 Collect Samples
.03 Hydro Punch
.04 Tidal Influence Study
.05 Hydraulic Tests (Pump Tests)
.06 Ground-Water Elevation Measurement
.05 Hydrogeological Investigations Oversight-Surface Water
.06 Waste Investigation Oversight
.07 Geophysical Investigation Oversight
.08 Ecological Investigation Oversight
.09 Contaminated Building Samples Oversight
. 10 Disposal of Investigation-Derived Waste Oversight
.11 Prepare Data Acquisition Oversight Reports
.04 Sample Analysis of Splits
.01 Screening-Type Laboratory Sample Analysis
.01 Analyze Air/Gas Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.02 Analyze Ground-Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.03 Analyze Surface Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.04 Analyze Soil/Sediment Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.05 Analyze Waste (Gas) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.06 Analyze Waste (Liquid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.07 Analyze Waste (Solid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.08 Analyze Biota Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.09 Analyze Bioassay Samples
.10 Perform Bioaccumulation Studies
.02 CLP-Type Laboratory Sample Analysis
.01 Analyze Air/Gas Samples
19 Model RD Oversight SOW (6/95)
-------
.01 Organic
.02 Inorganic
.03 Radiochemistry
.02 Analyze Ground-Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.03 Analyze Surface Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.04 Analyze Soil/Sediment Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.05 Analyze Waste (Gas) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.06 Analyze Waste (Liquid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.07 Analyze Waste (Solid) Samples
.0.1 Organic
.02 Inorganic
.03 Radiochemistry
.08 Analyze Biota Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.09 Analyze Bioassay Samples
.10 Perform Bioaccumulation Studies
.05 Analytical Support and Data Validation of Split Samples
.01 Prepare and Ship Environmental Samples
.01 Ground-Water Samples
" "M! ; iiil'Wi ' Li •"• • i I
.02 Surface and Subsurface Soil Samples
.0$ Surface Water & Sediment Samples
.04 Air Samples
.05 Biota Samples
.06 Other types of media sampling and screening
.02 Coordinate with appropriate Sample Management personnel
.03 Implement EPA-approved Laboratory QA program
.04 Provide Sample Management (Chain of Custody, sample retention, & data storage)
.05 Perform Data Validation
.01 Review analysis results against validation criteria
.02 Provide written Documentation of validation efforts
.06 Data Evaluation of Split Samples
.01 Data Useability Evaluation/Field QA/QC
.02 Data Reduction, Tabulation and Evaluation
.01 Evaluate Geological Data (Soils/Sediments)
.02 Evaluate Air Data
.03 Evaluate Hydrogeological Data-Ground Water
.04 Evaluate Hydrogeological Data-Surface Water
.05 Evaluate Waste Data
20 Model RD Oversight SOW (6/95)
-------
.06 Evaluate Geophysical Data
.07 Evaluate Ecological Data
.03 Modeling
.01 Contaminant Fate and Transport
.02 Water Quality
.03 Ground Water
.04 Air
.05 Other Modeling
.04 Develop Data Evaluation Report
.07 Review PRP Remedial Design Documents
.01 Review Preliminary Design
.01 Project Delivery Strategy and Scheduling
.02 Preliminary Construction Schedule
.03 Specifications Outline
.04 Preliminary Drawings
.05 Basis of Design Report/Design Analysis
.06 Preliminary Cost Estimate
.07 PRP Description of Variances with ROD
.08 PRP Response to Design Review Comments
.09 Participate in Preliminary Design Review/Briefing
.02 Review Intermediate Design
.01 Construction Schedule
.02 Preliminary Specifications
.03 Intermediate Drawings
.04 Basis of Design Report/Design Analysis
.05 Revised Cost Estimate
.06 PRP Description of Variances with ROD
.07 PRP Response to Design Review Comments
.08 Participate in Intermediate Design Review/Briefing
.03 Review Prefinal/Final Design
.01 Prefinal Design Specifications
.02 Prefinal Drawings
.03 Basis of Design Report/Design Analysis
.04 Revised Cost Estimate
.05 Final Design Submittal
.06 Participate in Prefinal/Final Design Review
.07 Subcontract Award Document(s)
.08 Biddability (offerability) and Constructability Reviews
.09 Revised Project Delivery Strategy
.10 Document VE Modifications
.07.02 (Not Used)
.08 Technical Meeting Support
.09 Work Assignment Close Out
.01 Return Documents to Government
.02 File Duplication/Distribution/Storage
.03 File Archiving
.04 Microfiche/Microfilm/Optical Disk
.05 Prepare Closeout Report
21 Model RD Oversight SOW (6/95)
-------
Attachment 3
Regulations and Guidance Documents
Th? following list, although not comprehensive, comprises many of the regulations and guidance documents
that apply to the RD process:
1. American National Standards Practices for Respiratory Protection. American National Standards
Institute Z88,2-1980,March 11,1981.
2. ARCS Construction Contract Modification Procedures September 89, OERR Directive 9355.5-01/FS.
3. CERCLA Compliance with Other Laws Manual, Two Volumes, U.S. EPA, Office of Emergency and
Remedial Response, August 1988 (DRAFT), OSWER Directive No. 923471-01 and -02.
4. Community Relations in Superfund-A Handbook, U.S. EPA, Office of Emergency and Remedial
Response, June 1988, OSWER Directive No. 9230.0-3B.
5. A Compendium of Superfund Field Operations Methods, Two Volumes, U.S. EPA, Office of Emergency
and Remedial Response, EPA/540/P-87/001a, August 1987, OSWER Directive No. 9355.0-14.
6. Construction Quality Assurance for Hazardous Waste Land Disposal Facilities, U.S. EPA, Office of
Solid Waste and Emergency Response, October 1986, OSWER Directive No. 9472.003.
7. Contractor Requirements for the Control and Security of RCRA Confidential Business Information,
March 1984.
8. The Data Quality Objectives Process for Superfund: Interim Final Guidance, U.S. EPA, EPA/540/R-
93/071, September 1993.
9. Engineering Support Branch Standard Operating Procedures and Quality Assurance Manual, U.S. EPA
Region IV, Environmental Services Division, April 1, 1986 (revised periodically).
10. EPA NEIC Policies and Procedures Manual, EPA-330/9-78-001-R, May 1978, revised November 1984.
11. Federal Acquisition Regulation, Washington, DC: U.S. Government Printing Office (revised
periodically).
12. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim
Final, U.S. EPA, Office of Emergency and Remedial Response, October 1988, OSWER Directive NO.
9355.3-01.
13. Guidance on EPA Oversight of Remedial Designs and Remedial Actions Performed by Potential
Responsible Parties, U.S. EPA Office of Emergency and Remedial Response, EPA/540/G-90/001, April
1990.
14. Guidance on Expediting Remedial Design and Remedial Actions, EPA/540/G-90/006, August 1990.
15. Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites, U.S. EPA Office of
Emergency and Remedial Response (DRAFT), OSWER Directive No. 9283.1-2.
16. Guide for Conducting Treatability Studies Under CERCLA, U.S. EPA, Office of Emergency and
Remedial Response, Prepublication version.
17, Guide to Management of Investigation-Derived Wastes, U.S. EPA, Office of Solid Waste and
Emergency Response, Publication 9345.3-03FS,January 1992.
18, Guidelines and Specifications for Preparing Quality Assurance Project Plans, U.S. EPA, Office of
Research and Development, Cincinnati, OH, QAMS-004/80, December 29,1980.
19. Health and Safety Requirements of Employees Employed in Field Activities, U.S. EPA, Office of
Emergency and Remedial Response, July 12,1982, EPA Order No. 1440.2.
20. Interim Guidance on Compliance with Applicable of Relevant and Appropriate Requirements, U.S.
EPA, Office of Emergency and Remedial Response, July 9, 1987, OSWER Directive No. 9234.0-05.
21. Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans, U.S. EPA, Office
of Emergency and Remedial Response, QAMS-005/80, December 1980. "
22. Methods for Evaluating the Attainment of Cleanup Standards: Vol. 1, Soils and Solid Media, February
1989, EPA 23/02-^89-042; vol. 2, Ground water (Jul 1992).
23. National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule, Federal Register 40
CFR Part 300, March 8, 1990.
24. NIOSH Manual of Analytical Methods, 2nd edition. Volumes I-VII for the 3rd edition, Volumes I and
II, National Institute of Occupational Safety and Health.
22 Model RD Oversight SOW (6/95)
I|lI it ! .,M ,i,iiiiiiii-i, ,-i.i Illlllill^^^^^ In.-I 11^^ Jiliillllli I, I iiii!llB,iiaiai jj.iJill^^^^ ., i.Ji „,!'!:' ...In .„ MuJ.i: ' LU ',11,1, ll i I if J •. a. .. .. ..i,; Jill..1,1 t , ,:...l i , I :..:, i, ,t:J.l
-------
25. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, National
Institute of Occupational Safety and Health/Occupational Health and Safety Administration/United
States Coast Guard/Environmental Protection Agency, October 1985.
26. Permits and Permit Equivalency Processes for CERCLA On-Site Response Actions, February 19,1992,
OSWER Directive 9355.7-03.
27. Procedure for Planning and Implementing Off-Site Response Actions, Federal Register, Volume 50,
Number 214, November 1985, pages 45933-45937.
28. Procedures for Completion and Deletion of NPL Sites, U.S. EPA, Office of Emergency and Remedial
Response, April 1989, OSWER Directive No. 9320.2-3A.
29. Quality hi the Constructed Project: A Guideline for Owners, Designers and Constructors, Volume 1,
Preliminary Edition for Trial Use and Comment, American Society of Civil Engineers, May 1988.
30. Remedial Design/Remedial Action (RD/RA) Handbook, U.S. EPA, Office of Solid Waste and
Emergency Response (OSWER), 9355.0-04B,EPA 540/R-95/059, June 1995.
31. Revision of Policy Regarding Superfund Project Assignments, OSWER Directive No. 9242.3-08,
December 10,1991. [Guidance, p. 2-2]
32. Scoping the Remedial Design (Fact Sheet), February 1995, OSWER 9355-5-21FS.
33. Standard Operating Safety Guides, U.S. EPA, Office of Emergency and Remedial Response, November
1984.
34. Standards for the Construction Industry, Code of Federal Regulations, Title 29, Part 1926, Occupational
Health and Safety Administration.
35. Standards for General Industry, Code of Federal Regulations, Title 29, Part 1910, Occupational Health
and Safety Administration.
36. Structure and Components of 5-Year Reviews, OSWER Directive No. 9355.7-02,May 23,1991.
[Guidance, p. 3-5]
37. Superfund Guidance on EPA Oversight of Remedial Designs and Remedial Actions Performed by
Potentially Responsible Parties, April 1990,EPA/540/G-90/001.
38. Superfund Remedial Design and Remedial Action Guidance, U.S. EPA, Office of Emergency and
Remedial Response, June 1986, OSWER Directive No. 9355.0-4A.
39. Superfund Response Action Contracts (Fact Sheet), May 1993, OSWER Publ. 9242.2-08FS.
40. TLVs-Threshold Limit Values and Biological Exposure Indices for 1987-88, American Conference of
Governmental Industrial Hygienists.
41. Treatability Studies Under CERCLA, Final. U.S. EPA, Office of Solid Waste and Emergency
Response, EPA/540/R-92/071a, October 1992.
42. USEPA Contract Laboratory Program Statement of Work for Inorganic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, July 1988. •
43. USEPA Contract Laboratory Program Statement of Work for Organic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, February 1988.
44. User 's Guide to the EPA Contract Laboratory Program, U.S. EPA, Sample Management Office,
August 1982.
45. Value Engineering (Fact Sheet), U.S. EPA, Office of Solid Waste and Emergency Response, Publication
9355.5-03FS,May 1990.
23 Model RD Oversight SOW (6/95)
-------
Attachment 4
TRANSMITTAL OF DOCUMENTS FOR ACCEPTANCE BY EPA
TO:
SUBTASK NO.
DATE:
FROM:
DELIVERABLE
NO. OF
COPIES
TRANSMITTAL NO.
1 1 New Transmittal
1 1 Resubmittal of
Transmictal No.
REMARKS
ACCEPTANCE ACTION
DOCUMENTS FOUND ACCEPTABLE (LIST BY SUBTASK NO.)
NAME/TITLE/SIGNATURE OF REVIEWER
DATE
-------
Attachment 5
TRANSMITTAL REGISTER
PROJECT TITLE AND LOCATION
d
£
•«
1
DELIVERABLE
0 3
6 &
Z U
u a
3 a
0 Q
CONTRACT NO.
Transmittal
No.
Date
Received
Date Comments
Sent to
Contractor
WORK ASSIGNMENT NO.
EPA
Acceptance
Date
REMARKS
-------
-------
(Date)
MODEL STATEMENT OF WORK FOR REMEDIAL ACTION
SITE, COUNTY, STATE
ATTACHMENTS
Attachment 1. Summary of Major Submittals for the Remedial Action at (Site) 22
Attachment 2. Work Breakdown Structure 24
Attachment 3. Regulation and Guidance Documents 30
Attachment 4. Transmittal of Documents for Acceptance by EPA 32
Attachment 5. Transmittal Register 33
1. To tell the contractor what EPA wants done. The WAM/RPM should be as specific as possible in
describing what you want the contractor to do. The contractor will write a work plan and budget
describing how and at what cost the requirements will be met and ultimately will be responsible for
performing to those requirements. Whenever there is an absolute requirement (e.g., prepare the
QAPP in accordance with QAMS-005/80 (December 29, 1980 or prepare the Remedial Action Report
in accordance with OSWER Publication 9355.0-39FS (June 1992)), state it.
2. To give the contractor a structure for recording costs. Work plan costs and final costs of different
remedial action projects can be compared and analyzed.
Use of a Work Breakdown Structure (WBS)
1. A WBS has been developed for this model work assignment in order for EPA to track the initial and
final costs of each element used and share this data with other Federal agencies. The WBS is,
essentially, the outline for this work assignment and is included as Attachment 2 to this SOW.
2. If an element is not to be used, do not change the numbering system: instead, insert "not used" or
"N/A" after the element number and then delete the text for that element.
3. For the items used for a given project, additional descriptions (e.g., type of samples and estimated
number) should be added hi order for the contractor and RPM/WAM to develop estimated costs on a
common basis.
7.0 Introduction
.0.1 Site Description
Provide a brief site description and site history.
.0.2 Purpose
The purpose of this Statement of Work (SOW) is to set forth the framework and requirements for
implementing the Remedial Action (RA) at (site) in accordance with the objectives of the
Remedial Design (RD). The Record of Decision (ROD) issued on (date) defines the selected
remedy. The RA is the implementation phase of site remediation or construction of the remedy, including
1 Model RA SOW (6/95)
-------
necessary operation and maintenance, performance monitoring, and special requirements. The RA is
based on t% RE) to achieve the remediation goals specified in the ROD. The goal for completion of this
RA is ._ months after work plan approval. The estimated completion date for this work assignment
is
For the purposes of this model SOW, the RA contractor, also referred to as "the contractor", is defined
as the firm responsible for performing the SOW. The RA contractor is under contract to EPA through the
Alternate Remedial Contracting Strategy (ARCS) or Remedial Action Contractor (RAC) contracting
vehicles. The construction contractor, also referred to as the "constructor" is responsible for planning
and managing the construction activities hi accordance with the contract documents. In most cases, the
constructor is a subcontractor to the RA contractor and will utilize the services of specialty subcontractors
in order to accomplish the RA.
During the RA, there are many participating team members that will have specific roles and responsibilities
throughout the RA. Up front in the SOW, the RPM may consider defining the nomenclature used to refer
to the different participants. Defining the RA contractor, the construction contractor, and other
subcontractors will ensure that the terms are used consistently throughout the SOW and Work Plan and will
facilitate a clear understanding of whom is expected to do what parts of the SOW. The RPM may consider
adding appropriate definitions to section 0.2.
.0.3 General Requirements
.0.3.1
.0.3.2
-0.3.3
.0.3^4
.0.3.5
.0.3.<5
.0.3.7
The contractor shall conduct the RA in accordance with this SOW and the final plans and
specifications developed during the RD. The RA shall also be consistent with the ROD
issued on (date), the Remedial Design/Remedial Action (RD/RA) Handbook
(U.S. EPA Office of Solid Waste and Emergency Response (OSWER) 9355.0-04B, EPA
540/R-95/059, June 1995), and all other guidance used by EPA in conducting an RA. The
primary contact for this work assignment is , tel. ( _) ; the
secondary contact is , tel. (__) .
A summary of the major deliverables and a suggested schedule for submittals is attached.
See Attachment 1. : '
Specifically, the RA involves the construction and implementation of
Jj ,^___ (briefly explain the major components of the RA).
The contractor shall furnish all necessary and appropriate personnel, including
subcontractors, materials, and services needed for, or incidental to, performing and
completing the RA.
A list of primary guidance and reference material is attached. See Attachment 2. In all
cases, the contractor shall use the most recently issued guidance.
Ifhe estimated cost of the RA, as outlined in the RD cost estimate, is $ .
The contractor shall communicate at least weekly with the Work Assignment Manager or
Remedial Project Manager (WAM/RPM), either in face-to-face meetings or through
conference calls.
.0.3.8 flie contractor shall notify the WAM/RPM when 75 percent of the approved work
assignment budget has been expended and when 95 percent has been expended.
.0.3.9 The contractor shall document all decisions that are made in meetings and conversations
v^ith EPA. The contractor shall forward this documentation to the 'Vy'AM/RPM within two
working days of the meeting or conversation.
.0.3.10 EPA will provide oversight of contractor activities throughout the RA. EPA review and
approval of deliverables is a tool to assist this process and to satisfy, in part, EPA's
responsibility to provide effective protection of public health, welfare, and the
environment. EPA will review deliverables, including specific deiiverables from the
constructor to the RA contractor, to assess the likelihood that the constructed remedy will
Model RA SOW (6/95)
II;
-------
achieve its remediation goals and that its performance and operations requirements have
been met. Acceptance of plans and design-required submittals (i.e., shop drawings, design
details) by EPA does not relieve the RA contractor, the constructor, or any subcontractors
from their professional responsibilities.
.0.4 Record-Keeping Requirements
The contractor shall maintain all technical and financial records for the RA in accordance with the
contract. At the completion of the RA, the contractor shall submit copies of the official record
of the RA in (format) to the WAM/RPM.
1. Technical and financial records must support decisions made during the RA as well as to support cost
recovery.
2. The WAM/RPM should check with the Regional Records Manager and with Regional Counsel
regarding the distribution, number of copies, and preferred format (i.e., hard copy, microfilm,
microfiche, CD-ROM) for the official records of the RA.
.0.5 Equipment Transfer
At the completion of the RA work assignment or when government personal property is no longer
required at the site, the contractor shall arrange for the proper disposition of government-furnished or
contract-acquired property (purchased with contract funds) in accordance with the contract requirements.
The disposition (transfer, sale, or abandonment) of government personal property and the tracking of such
equipment (see item . 1.2.4) shall be coordinated with the Contract Property Administrator. For additional
information, refer to Contractor's Guide for Control of Government Property, Office of Administration
and Resources Management, December 1988.
.0.6 Project Closeout
At the completion of the RA work assignment, the contractor shall perform all necessary project closeout
activities as specified in the contract. These activities may include closing out any subcontracts, indexing
and consolidating project records and files as required in Paragraph 0.4 above, and providing a technical
and financial closeout report to EPA. Final costs shall be reported to EPA (on disk) broken down into the
cost for each element of the WBS for this work assignment (see item .1.2.5, Project Management, Work
Assignment Closeout).
7.1 Project Planning and Support
.1.1 Project Planning
The purpose of this task is to plan for the execution and overall management of this work assignment.
The technical and managerial activities required to implement the RA and the associated costs are
developed during the planning phase and are detailed in the RA Work Plan. Activities required for
general work assignment management that will occur throughout the duration of the project are included in
this task. This task may begin before or after the approval of the final design package and will continue
through work assignment closeout. The following activities shall be performed as part of the project
planning and support task:
Model RA SOW (6/95)
-------
1. Depending on project status and if the designer will continue as the RA contractor, the WAM/RPM
may not need to task some of the following tasks (e.g. conduct site visit [1.1.2] or evaluate existing
information [1.1.3]) that are needed to familiarize a new contractor with the site.
2. Before developing the RA SOW, the WAM/RPM should review the RD SOW or RD work plan to
confirm if any RA planning or pre-construction activities were tasked during the RD work
assignment. Some activities may have been conducted by the RD contractor in Task 12, Post RD
Support)
3. In order to expedite the RA, initial planning for the RA may start before final approval of the design
package and therefore, overlap with RD or post-RD activities tasked to the designer. This is possible
when the designer will oversee the construction as the RA contractor.
.1.1.1 Attend Scoping Meeting. Before or concurrent with developing the RA Work Plan, the
contractor shall attend a scoping meeting to be held at the EPA Regional Office.
The meeting location and the RPM's expectations for the number of contractor personnel to attend should
be specified for cost estimation purposes. Consider having the designer, if different than the RA
contractor, attend the meeting to present any special considerations and to facilitate the transfer of site and
design information prior to work plan development.
.1.1.2 Conduct Site Visit. The contractor shall conduct a site visit with the EPA WAM/RPM and
: designer's representative (if appropriate) during the RA planning phase to assist in
developing an understanding of the site and any construction logistics. Information
gathered during the visit shall be used to better scope the project and to implement the RA.
A Health and Safety Plan (HASP) is required for the site visit. The contractor shall
prepare a report that documents the site visit and any required action items or decisions.
This report shall be submitted to the EPA WAM/RPM within 10 calendar days of the site
visit.
.1.1.3 Evaluate Existing Information. The contractor shall obtain, copy (if necessary), and
evaluate existing data and documents, including the final Design Package, the RD Work
Plan, the ROD, Remedial Investigation/Feasibility Study (Sl/FS), ancl other data and
documents as directed by WAM/RPM. This information shall be used to determine if any
additional data are needed prior to procuring the constructor. The documents available for
review are listed hi Attachment 3.
The WAM/RPM should specify the following key documents for the RA contractor to review:
Final Drawings and Specifications
(100% Design)
Final Basis of Design and
Design Analysis
RA Cost Estimate
Construction Quality Assurance Plan
• Project Delivery Strategy
• VE Modifications
• Draft O&M Manual
• Quality Assurance Plan for O&M
Additional documents to list in Attachment 3 could include the summary of the "Predesign Information
Collection" Effort (see Chapter 3 of the Guidance for Scoping the Remedial Design), Focused Feasibility
Studies (FFS), State documentation, hydrogeological information, and RPM file data. However, to control
expenses, limit review to pertinent documents specific to the site and construction of the remedy.
Ipdel RA SOW (6/95)
-------
.1.1.4 Develop Work Plan. The contractor shall prepare and submit a RA Work Plan which
includes a detailed description of construction activities, operations and maintenance,
performance monitoring, and an overall management strategy for the RA. The contractor
shall present the general approach that will be used for the RA at a Work Plan scoping
meeting with the WAM/RPM. This meeting will be held at the Region office.
If the RA will be complex, consider modifying subtask 3.1.1.4 (1) to include an additional scoping meeting
to be held before the contractor finalizes the technical approach. This will ensure that the WAM/RPM and
the contractor are in agreement as to the approach to be taken and that the agreed-upon approach is
reflected in the Work Plan. The contractor may not have to rewrite the Work Plan if this is done.
. 1.1.4 Develop Work Plan (continued)
(1) Develop Draft Work Plan. The contractor shall prepare and submit a draft RA Work
Plan within 30 calendar days after initiation of the work assignment (WA). Submit the
original to the Contracting Officer (CO), one copy to the Project Officer (PO), and one
copy to the WAM/RPM or hi accordance with contract requirements. The Work Plan
shall include a detailed description of the technical approach for the remediation and
construction activities in accordance with the final design and ROD. The necessary
procedures, inspections, deliverables, and schedules shall be specified. A
comprehensive construction management schedule for completion of each major activity
and submittal shall also be included.
1. The WAM/RPM should verify the work plan submittal timeframe with the PO. Additional copies of
the work plan can be submitted to the WAM/RPM, if specified, for distribution to other technical
staff.
2. The WAM/RPM should ensure that the submittal requirements in this SOW are in accordance with
the submittal requirements for the RA contract as specified in the plans and specifications.
3. The WAM/RPM must prepare an Independent Government Cost Estimate (IGCE) for the RA before
the WA is issued to the contractor. The WAM/RPM should use the designer's final RA cost
estimate, prepared as part of the final design (RD SOW, Task 11) as a starting point and add the costs
associated with the construction management and oversight activities performed by the RA contractor,
as specified in this SOW. Contact Regional IGCE Coordinators for assistance.
(a) Develop Narrative. Specifically, the Work Plan shall present the following:
- A statement of the problem(s) and potential problem(s) posed by the site and
how the objectives of the completed RA will address the problem(s).
The contractor's technical approach to each task to be performed, including a
detailed description of each task; the assumptions used; the information needed
for each task; any information to be produced during and at the conclusion of
each task; and a description of the work products that will be submitted to
EPA. Tasks and subtasks shall be presented hi the same WBS format as
provided in this work assignment-SOW. The technical descriptions shall
include enough detail to back up the costs and level of effort presented in
A schedule for specific dates for completion of each required activity and
submission of each deliverable required by this SOW. (See Attachment 1).
This schedule shall also include information about timing, initiation, and
completion of all critical path milestones for each activity and deliverable and
the expected review time for EPA.
5 Model RA SOW (6/95)
-------
- An organizational structure which outlines the responsibilities and authority of
all organizations and key personnel involved in the RA. A description of key
project personnel's qualifications (project manager, resident engineer, quality
assurance official, etc.) shall be provided.
(b) Develop Cost Estimate. The contractor's estimated cost to complete the work
assignment, including subcontractors' costs, shall be prepared for each element of
the WBS (Attachment 2) and submitted to EPA on disk [specify format]. The
contractor shall provide a breakdown of the cost and Level of Effort (LOE), by
professional levels, for each subtask of the Work Assignment.
(c) Internal QA and Submission of Work Plan.
(2) Prepare Final Work Plan
(a) Attend Negotiation Meeting. The contractor shall attend a Work Plan negotiation
meeting at the Region office. Any technical issues and possible solutions
shall be discussed at this meeting. The contractor shall confirm these discussions
and suggested plan of action in a memorandum to "the WAM/RPM within 2 days
of the meeting.
(b) Modify Draft Work Plan and Cost Estimate. The contractor shall make revisions
to the Work Plan as a result of EPA's comments and/or negotiation agreements.
(c) Internal QA and Submission of Final Work Plan within 15 days after receipt of
EPA comments on the draft Work Plan.
. 1.2 Project Management
1. The WAM/RPM should specify the format for submissions (e.g., Monthly Progress Reports) if there
are Region-specific or other requirements.
2, During construction, there may be especially active periods. The WAM/RPM should specify
additional communication requirements or status reports from the RA contractor. Also, the
WAM/RPM should arrange for personal visits to the site during these times.
.1.2.1 Prepare Periodic Status Reports. The contractor shall prepare Monthly Progress Reports.
(1) Document Cost and Performance Status. The contractor shall document the technical
progress and status of each task in the WBS for the reporting period in accordance
with contract requirements. The contractor shall report costs and level of effort (by P-
level) for the reporting period as well as cumulative amounts expended to date.
(2) Prepare and Submit Invoices. Monthly invoices will be prepared and submitted in
accordance with the level of detail as specified in the contract.
.1.2.2 Nfeeting Participation and Routine Communications. The contractor shall attend project
meetings, provide documentation of meeting results, and shall contact the RPM by
telephone on a weekly basis to report project status.
.1.2.3 Maintain Cost/Schedule Control System. The contractor shall develop and maintain a
system to monitor and control the costs and schedule of the Work Assignment. The
contractor shall specify the process to continuously update the information in the system as
a result of engineering network analyses and changing field conditions. The system shall
have the capability to compare technical progress with expenditures and predict completion
dates and cost to complete information. In addition to reporting cost and progress of the
elements of this SOW, the cost/schedule control system must report and control costs
within Task 8, RA Implementation, in sufficient detail to control construction costs.
.1.2.4 Manage, Track, and Report Equipment Status. The contractor shall manage, track, and
report the status of all government-furnished equipment and contract-acquired property in
a^pordance with contract requirements. Labelling and record keeping requirements for
government personal property are outlined in the Contractor's Guide for Control of
Model RA SOW (6/95)
-------
Government Property, Office of Administration and Resources Management, December
1988.
.1.2.5 Work Assignment Closeout. The contractor shall perform the necessary activities to
closeout the work assignment in accordance with contract requirements.
.1.2.6 Coordinate with Local Emergency Response Teams. The contractor shall coordinate with
local emergency responders to ensure the proper implementation of the HASP and
specifically the Emergency Response Plan. The contractor shall review and complete the
emergency responder agreement, if necessary, conduct a kickoff meeting at the site with
all local emergency responders, and notify the responders of any changes to the
Emergency Response Plan throughout the RA. [For more information, refer to Emergency
Responders Agreements for Fund-Lead Remedial Actions, publication 9285.6-04FS, March
1994]
7.2 Community Relations
The contractor shall provide community relations support to EPA throughout the RA. The contractor shall
provide community relations support in accordance with Community Relations in Superfund: A Handbook, June
1988. This task begins with the approval of the RA Work Plan and continues throughout the duration of the
work assignment. Community relations shall include the following subtasks:
1. Listed below are a number of possible community relations activities the WAM/RPM may require,
depending on the specific situation. Refer to the Community Relations in Superfund: A Handbook,
Chapter 7 and Appendix A, for suggested community relations activities during RA.
2. With implementation of the remedy, site activity increases and so does the likelihood of community
concerns and questions. In addition to the community relations activities listed below in the WBS, the
WAM/RPM may consider the following activities to communicate progress during construction:
arranging site tours and workshops; establishing observation decks; and videotaping cleanup activities.
These activities may be tasked in items .2.3.1. Technical Support, or added to the WBS under as a
separate item and numbered accordingly (i.e., .2.3.5). The WAM/RPM should plan for and develop
a proactive and effective program with the assistance of the Regional Community Relations Specialist.
3. The WAM/RPM should review the current community relations plan, if one exists, and direct the RA
contractor to update the existing CRP to address activities and concerns specific to the RA.
4. The WAM/RPM should specify the format for Community Relations submissions (e.g., fact sheets,
news releases) if there are Region-specific or other requirements.
.2.1 Develop Community Relations Plan (CRP)
.2.1.1 Conduct Community Interviews. The contractor shall assist the WAM/RPM in conducting
community interviews to identify community concerns associated with the RA. The
contractor shall assist the WAM/RPM in identifying key community members, establishing
an interview schedule, conducting interviews, and summarizing the results.
.2.1.2 Prepare the CRP. The contractor shall update the existing CRP to address community
relations requirements and community concerns during the RA.
(1) Draft CRP. The contractor shall update the CRP and submit a draft version within 14
days after completion of the community interviews.
(2) Final CRP. Within 7 days of receipt of EPA comments, the contractor shall submit a
final CRP.
.2.2 Prepare Fact Sheets
7 Model RA SOW (6/95)
-------
This subtask may have been completed during the RD. In that case, the WAM/RPM may task the
RA contractor to revise the fact sheet before construction begins with the current schedule, expected
conditions, and relevant points of contact.
Depending on the complexity of the RA, the WAM/RPM should consider communicating construction
progress by sending out regular fact sheets. Specify to the contractor the anticipated number of fact
sheets, topics, and number of copies required.
The contractor shall assist the WAM/RPM in preparing a fact sheet that informs the public about
activities related to the final design, the schedule for the RA, activities to be expected during
construction, measures to be taken to protect the community, provisions for responding to
emergency releases and spills, and any potential inconveniences such as excess traffic and noise
that may affect the community during the RA.
: ., , j
, i! i"; -, . "
.2.3 Public Meetings and Availability Support
The number and location of anticipated public meetings should be identified hi the SOW for cost estimation
purposes. Similarly, the RPM should specify the number of contractor personnel expected to be in
attendance at the public meetings.
.2.3.1 Technical Support. The contractor shall assist the WAM/RPM in providing technical
support for community meetings that may be held during the RA. This support may
include preparing technical input to news releases, briefing materials, arranging other
community relations vehicles (i.e., site tours), and helping the WAM/RPM to coordinate
with local agencies.
.2.3.2 Logistical and Presentation Support. The contractor shall assist the WAM/RPM in
p'reparing technical briefing materials and in arranging for the logistical details for the
riieeting(s).
.2.3.3 Public Notice Support. The contractor shall assist the WAM/RPM hi drafting public
notices, announcing the public meetings and placing the notice in a local paper of general
circulation.
.2.4 Maintain Information Repository and Mailing Lists
The contractor shall assist the WAM/RPM in developing or revising site mailing lists and
maintaining a repository of information on activities related to the site-specific remedial action as
described in Appendix A.8, page A-19, of Community Relations in Superfund: A Handbook, June
1988.
i.' ',' "'' , ' I" '
7.3 Site Specific Plans
The purpose of this task is to review the existing site-specific plans that were prepared during RD, and update,
as n'ecessary, for the RA contractor to implement the RA. Typical plans include a health and safety plan,
sanjpling and analysis plan, and construction quality assurance plan. This task begins with approval of the RA
Work Plan and will occur throughout the duration of the work assignment. The RA contractor has the overall
responsibility to prepare, update, and/or maintain the necessary site-specific plans for implementation of the
RA. Since the constructor and any subcontractors will prepare their own RA plans, the RA contractor will
incorporate the plans and procedures received from any subcontractors into the overall site plans. Construction
plans and procedures are living documents and the contractor shall update the appropriate plans, as necessary,
throughout the RA.
Model RA SOW (6/95)
-------
1. The RPM/WAM should check to see if the update and/or preparation of RA site specific plans were
tasked during the RD (Task 12, Post Remedial Design Support).
2. The RA Contractor is tasked in this section to update any necessary plans for RA implementation. It
should be noted that the Constructor and any subcontractors will prepare their own plans. The
WAM/RPM should budget for the RA contractor to modify site plans to incorporate plans and
procedures received from any subcontractors and to account for changing field conditions.
3. Typical sampling and analysis activities by the RA contractor include confirmatory sampling (i.e.,
take split samples with the constructor) to ensure cleanup standards have been met; air sampling and
analysis to monitor air quality around the site perimeter; and wastewater discharge sampling to
monitor National Pollutant Discharge Elimination System (NPDES) requirements.
.3.1 Update Site Management Plan. After EPA approval of the RA Work Plan (see Item 3.1.1.4), the
contractor shall update the Site Management Plan (SMP) that was prepared during RD. This plan
provides EPA with a written understanding of how access, security, health and safety, contingency
procedures, management responsibilities, and waste disposal are to be handled during construction.
The contractor shall update the plan, as necessary, to incorporate any subcontractors' plans.
.3.1.1 Update Health and Safety Plan. Prepare a site-specific HASP that addresses overall health
and safety considerations for all personnel onsite. The contractor shall incorporate the
constructor's and any subcontractors' HASPs into the overall site plan. The RA contractor
shall provide the overall framework for site safety and ensure that adequate warning
systems and notifications are understood by all parties. The HASP shall specify employee
training, protective equipment, medical surveillance requirements, standard operating
procedures, and a contingency plan in accordance with [40 CFR 300.150 of the NCP and]
29 CFR 1910.120 1(1) and (1)(2). Whenever possible, refer to the HASP developed for
the RI/FS or RD when preparing the HASP for the RA. For any site visits, a task-specific
HASP must also be prepared to address health and safety requirements.
.3.1.2 Update Sampling and Analysis Plan (Chemical Data Acquisition Plan). Prepare a sampling
and analysis plan to reflect the specific objectives of any data acquisition conducted during
construction. The SAP will outline the data collection and quality assurance requirements
of any sampling and analysis conducted by the contractor.
(1) Quality Assurance Project Plan. The contractor shall prepare a Quality Assurance
Project Plan (QAPP) in accordance with EPA QA/R-5 (latest draft or revision). The
QAPP shall describe the project objectives and organization, functional activities, and
quality assurance/quality control (QA/QC) protocols that shall be used to achieve the
desired data quality objectives (DQOs). The DQOs shall, at a minimum, reflect use of
analytical methods for identifying contamination and addressing contamination
consistent with the levels for remedial action objectives identified in the National
Contingency Plan. The QAPP developed for the RD and/or RI/FS should be
referenced or adapted whenever possible when preparing the QAPP for the RA.
(2) Field Sampling Plan. Prepare a Field Sampling Plan (FSP) that defines the sampling
and data collection methods that shall be used for the project. The FSP shall include
sampling objectives; sample locations and frequency; sampling equipment and
procedures; sample handling and analysis; and a breakdown of samples to be analyzed
through the Contract Lab Program (CLP) and through other sources, as well as the
justification for those decisions. The FSP shall consider the use of all existing data and
shall justify the need for additional data whenever existing data will meet the same
objective. The FSP shall be written so that a field sampling team unfamiliar with the
site would be able to gather the samples and field information required. The FSP
developed for the RD and/or RI/FS must be referenced or adapted whenever possible;
9 Model RA SOW (6/95)
-------
the contractor shall document any required changes to the FSP in a memorandum to
the WAM/RPM.
1. The Sampling and Analysis Plan (SAP) may be optional during certain RAs. It is prepared and
updated from the SAP prepared during RD if the RA contractor has sampling and analysis
responsibilities outside of those required of the constructor. In most cases, the RA contractor will
split samples with the constructor to confirm and validate cleanup actions. These samples will be
analyzed through the CLP (Level 4 data are required).
2. The WAM/RPM should reduce time and costs by using an onsite laboratory to analyze routine
samples as construction proceeds (i.e., to delineate excavation limits) rather than going through the
CLP. This is usually the constructor's responsibility and is included in the contract documents.
3. The WAM/RPM may consider requesting a plan for acquiring permits throughout the construction
process. This plan could be part of the Construction Management Plan, and may avoid timely and
costly construction delays.
4. The WAM/RPM should identify whether audits will be performed and specify contractor response
items.
.3.1.2 Update Sampling and Analysis Plan (continued)
(3) Data Management Plan. Prepare a Data Management Plan that outlines the procedures
for storing, handling, accessing, and securing data collected during the RA.
(4) Develop Other Plan(s)
.3.2 Update Pollution Control & Mitigation Plan. Prepare a Pollution Control & Mitigation Plan that
outlines the process, procedures, and safeguards that will be used to ensure contaminants or
pollutants are not released off-site during the implementation of the RA. Any plans and procedures
prepared during the RD should be referenced or adapted whenever possible (ile, sediment and
erosion control plan and air monitoring plan).
.3.2.1 Update Transportation & Disposal Plan (Waste Management Plan). Prepare a
Transportation & Disposal Plan that outlines how wastes that are encountered during the
RA will be managed and disposed of. The contractor shall specify the procedures that will
be, followed when wastes will be transported off-site for storage, treatment, and/or
disposal.
.3.3 Update Construction Quality Assurance (CQA) Plan. The contractor shall review and update the
final Construction Quality Assurance (CQA) Plan as submitted as part of the final design
documents, The CQA Plan shall outline the necessary steps to inspect and sample construction
materials (i.e., membranes, concrete) and to ensure the overall quality of the constructed project.
The CQA Plan shall be in accordance with "Construction Quality Assurance for Hazardous Waste
Land Disposal Facilities" (EPA, October, 1986) and will include the following elements:
Responsibility and authority of all organization and key personnel involved in the
remediation action construction.
CQA Personnel Qualifications. The contractor shall establish the minimum qualifications
of the CQA Officer and supporting inspection personnel.
Inspection Activities. The contractor shall establish the observations and tests that will be
re'quired to monitor the construction and/or installation of the components of the RA(s).
The plan shall include the scope and frequency of each type of inspection to be conducted.
Inspections shall be required to verify compliance with environmental requirements and
include, but not be limited to, air quality and emissions monitoring records, waste disposal
records (e.g., RCRA transportation manifests), etc. Inspections shall also ensure
compliance with all health and safety procedures.
10
Model RA SOW (6/95)
-------
Sampling requirements. The contractor shall establish the requirements for sampling
activities, sample size, sample locations, frequency of testing, criteria for acceptance and
rejection, and plans for correcting problems as addressed in the project specifications.
Documentation. The contractor shall describe the reporting requirements for CQA
activities. This shall include such items as daily summary reports and inspection data
sheets.
7.4 Procurement of Subcontract
The purpose of this task is to solicit, evaluate, select, and award the necessary subcontracts to construct and
implement the RA. This task begins with the approval of the RA Work Plan and review and modification of the
contract documents prepared during the RD. After advertising and evaluating bids, this task ends with the
award of one or more construction contracts to implement the RA. The contractor shall perform the following
procurement activities:
1. The prebid and preaward activities may have been tasked to the RD contractor during Task 12, Post
Remedial Design Support. The RA contractor will need to update the general conditions and dates
prior to printing and distribution.
2. The WAM/RPM should consider having a project meeting with the RA contractor early in this task to
review procedures and schedules for evaluating bids. It is important for the WAM/RPM to be
involved during this process to ensure that the Contracting Officer's requirements for consent are met.
This will help ensure that construction proceeds on schedule.
3. The WAM/RPM's role during this task is to oversee the technical information that is provided to
bidders, monitor the overall procurement process and schedule, review written questions and
responses, and attend any prebid and preconstruction conferences.
4. In an Invitation for Bid (IFB) or low bid procurement, the successful bidder is referred to as the
lowest responsible bidder (offerer). If a request for cost and technical proposal (RFP) is used instead
of the IFB, the procurement process and associated terminology for successful bidders are different
(i.e., proposals in the competitive range versus lowest responsible bidder). The WAM/RPM should
refer to the Remedial Design/Remedial Action (RD/RA) Handbook (U.S. EPA Office of Solid Waste
and Emergency Response (OSWER) 9355.0-04B, EPA 540/R-95/059, June 1995) for more
information on the different types of procurement.
.4.1 Prebid (Pre-Solicitation) Activities
.4.1.1 Printing & Distribution of Contract Documents. Print and distribute to prospective bidders
the contract documents that were finalized during RD.
.4.1.2 Advertising/Soliciting of Bids. Advertise and solicit bids for construction services. An
advertisement shall be prepared and published in .
(1) Prebid (pre-solicitation) Meetings. The contractor shall arrange and attend prebid
meetings to provide clarification on plans, specifications, and contract documents to all
bidders.
(2) Resolution of Inquiries/Issuing Addenda. The contractor shall resolve bidder inquires
and document all contact with potential bidders, and issue amendments to contract
documents if additional information becomes available that all bidders should be made
aware of after solicitation.
(3) On-site Visits. The contractor shall participate in onsite visits that may be required to
further clarify the services required.
.4.1.3 Readvertise/Resolicit Bids, if necessary. The contractor shall readvertise and resolicit bids
hi accordance with the Federal Acquisition Regulations (FAR) requirements.
11 Model RA SOW (6/95)
-------
.4.2 PreAward Activities
.4.2.1 Receipt of Bids (offers). After receipt of all bids within the solicitation period, the
contractor shall perform the necessary activities to review, compile, and evaluate all bids
received. The contractor shall conduct any necessary reference checks to ensure
qualifications of responsible bidders.
(1) Determination of Responsive, Responsible Bidders (offerers) or proposals in the
competitive range.
(2) Perform Reference Checks
(3) Bid (offer) Tabulation
(4) Bid (offer) Analysis
.4.2.2 Receipt of Follow-up Items from Responsible Bidder(s) (offerers). The contractor shall
""!'.', request the necessary follow-up items (i.e., subcontracting plan), from the responsible
. bidder(s), if the follow-up items are evaluated as part of the selection criteria.
.4.2.3 Review of Equal Employment Opportunities (EEO), MBE Requirements, Small
Disadvantaged Business (SDB) Subcontracting Plans. The contractor shall review the
bidder(s) plans to ensure that the successful bidder meets the requirements set forth in the
bidding documents.
.4.2.4 Request for Consent from EPA. After a comprehensive review of the lowest responsible
bidder's submittals, the contractor shall request EPA's consent to award.
,|
.4.3 Post Award Activities
.4.3.1 Attend Post Award Meetings/Preconstruction Conference. The contractor shall arrange
and conduct the necessary post award meetings with the successful bidder, including the
preconstruction conference. The purpose of the preconstruction meeting(s) is to develop
common goals, lines of communication, and construction-specific procedures. The
contractor shall prepare a meeting agenda, invite key personnel, and prepare minutes of the
meeting.
.4.3.2 Review Permits, Insurance, Bonds. The contractor shall review the successful bidder's
permit plan, insurance coverage, warranties, and bond to minimize site risks and potential
financial damages.
.4.3.3 Review and Approve RA Subcontractor's Schedule. The contractor shall review the
successful bidder's schedule and evaluate that schedule in regards to the overall project
schedule.
.4.3.4 Review and Approve RA Subcontractor's Measurement and Payment Schedule
.4.3.5 Review RA Subcontractor's Submittals - Issue Notice to Proceed (NTP)
.4.3.6 Review Revisions/Addendum of RA Subcontractor's Submittals
7.5 Subcontract Management Support
The, purpose of this task is to provide management and oversight of the subcontractor(s) responsible for remedial
construction. This task begins with the RA contractor issuing a Notice to Proceed to the constructor and ends
With the completion of the RA and final payment to the constructor. The contractor shall institute procedures,
monitor progress, and maintain systems and records to ensure that the work proceeds according to requirements
specified in the contract documents. The contractor shall perform the following subtasks:
12
M
odel RA SOW (6/95)
-------
1. EPA is required to perform technical and cost analyses for any changes to the construction contracts.
Refer to ARCS Construction Contract Modification Procedures, OSWER Directive 9355.5001/FS,
September 1989
2. The WAM/RPM may specify EPA review of any non-conformance reports to assess the status of
construction activities.
3. The WAM/RPM should evaluate if value engineering support is required (see items .5.4.2 and .6.3.2)
and then consult with the Project Officer or Contracting Officer for the latest guidance regarding
value engineering proposals under the RAC contracts.
.5.1 Financial Management.
.5.1.1 Review/Approve Invoices. The contractor shall promptly review and approve progress
payments as determined prior to construction in the Measurement and Payment Schedule
(see item .4.3.4).
.5.1.2 Review/Approve Subcontract Modifications. The contractor shall promptly review any
necessary subcontract modifications, confer with the WAM/RPM, and approve appropriate
changes.
.5.1.3 Maintain Tracking Systems. The contractor shall maintain the necessary tracking systems
to monitor quality of work, resource requirements, and cost and schedule status.
(1) Construction Codes of Accounts
(2) Work Breakdown Structure (WBS)
(3) Schedule (CPM, PERT)
.5.2 Cost Monitoring.
.5.2.1 Weekly/Monthly Tracking
.5.2.2 Analyze Progress Payments. The contractor shall monitor costs of the constructor and all
subcontractor(s) in relation to the status of construction or percentage of work completed.
The contractor shall track and project progress payments to ensure the overall financial
progress of the RA.
.5.2.3 Monitor RA Subcontractor for Compliance with Davis-Bacon Act
.5.3 Engineering Support
.5.3.1 Review Field Logs. On a weekly basis, the contractor's design team shall review field
logs that document the daily activities and inspections. The contractor shall provide
recommendations to improve site operations and inspections, if required.
.5.3.2 Periodic Attendance at Meetings. At the subcontractor's request, the RA contractor shall
attend any construction-related meetings to provide design clarification and technical
support.
.5.4 Engineering Support Option
.5.4.1 Review Field Change Requests. The contractor's design team shall review any changes to
the construction documents and specifications due to actual field conditions and submit to
EPA for review and approval.
.5.4.2 Review VE Proposals. The contractor shall review any VE proposal submitted by the RA
subcontractor.
.5.4.3 Review Non-Conformance Reports
.5.4.4 Review Re-Design Proposals
13 Model RA SOW (6/95)
-------
7.6 Detailed Resident Inspection (Resident Engineer)
This task includes the field supervision and documentation of the RA constructor's work as
The task begins with the constructor's mobilization to the site and ends with the final inspection
Will provide the necessary personnel to observe the constructor's daily activities, procedures
behalf of EPA.
it proceeds onsite.
The contractor
, and inspections on
1. The WAM/RPM must carefully review the design package to assure coordination and compatibility of
Resident Engineer's inspection activities with construction contract documents.
2. The WAM/RPM should specify the expected written and/or photographic documentation to be
recorded in the field.
3. The WAM/RPM should specify the required frequency and distribution for any field activity reports
(RPM, State representative, etc.).
.6.1 Attend Periodic Meetings. The contractor shall attend any meetings, at the request of the
constructor, to provide clarification on contract documents and specifications.
.6.2 Provide Field Presence and Oversight. The contractor shall provide a Resident Engineer to observe
and document the daily field activities of the constructor. Specific subtasks may include:
.6.2.1 Maintain Field Logs and Daily Diaries
.6.2.2 Interpret Subcontract Documents
.6.2.3 Develop Sketches Reflecting Field Conditions
.6.2.4 Review Submitted Construction Drawings
.6.2.5 Prepare Reports on Inspections
.6.2:6 Monitor, Update, and Report Construction Progress
.6.2,7 Review/Recommend Time Extensions
.6.2.8 Coordinate with Home Office/Management Support
.6.2.9 Perform Davis-Bacon Act Inspections
.6.2.10 Conduct Final Inspection
(1) Conduct Site Walkover
(2) Prepare Draft Final Inspection Report
(3) Respond to Comments
(4) Prepare Final Inspection Report
.6.3 Provide Engineering Support to Design Team
.6.3.1 Recommend Actions on Health and Safety Considerations
.6.3.2 Provide Support on VE Proposals.
.6.313 Review/Recommend Design Changes
.6.3.4 Provide Support on Change Order Requests. The Resident Engineer shall assist in the
evaluation and processing of change order requests.
.6.3.5 Provide Support in Claims Resolution. The Resident Engineer shall maintain records to
support the resolution of any claims filed by the constructor.
.6.3.6 Provide Support for Construction Schedule Changes
.6.4 Perform Field Testing. The contractor shall provide the necessary personnel and equipment to
collect any confirmatory samples, perform any necessary field testing, and conduct inspections of
'. work. '" , ' !
.6.5 Monitor Quality Assurance/Quality Control Procedures
ii i i, in , ij
7tf Cleanup Validation
- . i
The purpose of this task is for the RA contractor to perform confirmatory sampling of any data collected by the
constructor during construction and to verify that final cleanup levels or standards, as specified in the ROD,
14
Model RA SOW (6/95)
-------
have been achieved. This task may also include regular confirmatory testing of materials used during
construction to determine if they are consistent with the requirements of the construction contract documents
(i.e., soils testing, materials testing, chemical or biochemical testing of water). Analyses of confirmatory
samples, validation of data, and evaluation of results are included in this task. This task may begin during the
early stages of construction, continue throughout construction, and end with the final inspection to ensure
cleanup levels have been met.
1. The Work Breakdown Structure for field investigations, sampling, and analyses presented below was
compiled for all phases of a remedial project from Remedial Investigation through final construction
of the remedy. The detailed list is included to preserve the WBS. The WAM/RPM should specify in
the SOW only the investigations that are required for RA.
2. Confirmatory sampling is usually quite focused and limited depending on the site and remedy-specific
conditions. The WAM/RPM, in conference with the Technical Review Team, should determine the
level of confirmatory sampling and specify the number of samples so both the contractor and the
WAM/RPM can develop accurate cost estimates. The actual numbers may be refined upon
negotiation with the contractor.
3. The cleanup validation activities may serve as the basis for site delisting and therefore, it is critical
that the data quality objectives defined in the RA Work Plan and Sampling and Analysis Plan are met.
In order to document construction procedures and results, which are defensible, Contract Laboratory
Program data (level 4) are required.
.7.1 Mobilization/Demobilization
.7.1.1 Mobilize. The contractor shall acquire all necessary equipment, supplies, and personnel to
set up onsite operations for confirmatory sampling and analyses.
.7.1.2 Demobilize. The contractor shall dismantle and pack up all equipment associated with the
confirmatory sampling activities.
.7.2 Field Investigation
.7.2.1 Conduct Geological Investigations (Soils/Sediments)
(1) Surface Soil Sample Collection
(2) Subsurface Soil Sample Collection
(3) Soil Boring/Permeability Sampling
(4) Sediments Sample Collection
(5) Soil Gas Survey 0
(6) Test Pit.
.7.2.2 Conduct Air Investigations
(1) Sample collection
(2) Air Monitoring Station
.7.2.3 Conduct Hydrogeological Investigations: Groundwater
(1) Well Systems Installation
(A) Accomplish Mobilization
(B) Develop Wells
(C) Conduct Downhole Geophysics
(D) Install Monitoring Wells
(E) Install Test Wells
(F) Install Gas Wells.
(2) Collect Samples
(3) Collect Samples during Drilling (e.g. Hydro Punch or equivalent)
(4) Conduct Tidal Influence Study
(5) Perform Hydraulic Tests (pump tests)
(6) Measure Groundwater Elevation
.7.2.4 Conduct Hydrogeological Investigations: Surface Water
15 Model RA SOW (6/95)
-------
(1) Collect Samples
|2) Study Tidal Influence
(3) Measure Surface Water Elevation
.7.2.,5 Conduct Waste Investigation
(1) Collect Samples (Gas, Liquid, Solid)
(2) Dispose of Derived Waste (Gas, Liquid, Solid)
.7.2.6 Conduct Geophysical Investigation
(1) Surface Geophysical Activity
(2) Magnetometer
(3) Electromagnetics
(4) Ground Penetrating Radar
{5) Seismic Refraction
(6) Resistivity
(7) Site Meteorology
(8) Cone Penetrometer Survey
JJ9) Remote Sensor Survey
(10) Radiological Investigation
.7.2.7 Conduct Ecolpgical Investigation
|l) Wetland and Habitat Delineation '[
(2) Wildlife Observations
(3) Community Characterization
(4) Identification of Endangered Species
|5) Biota Sampling and Population Studies
.7.2^8 Collect Contaminated Building Samples.
.7.2.9 Dispose of Investigation-Derived Waste. Characterize and dispose of investigation-derived
wastes in accordance with local, State, and Federal regulations as specified in the FSP and
the Waste Management Plan (For more information, refer to the Fact Sheet entitled, Guide
• lo Management of Investigation-Derived Wastes, 9345.3 -03FS [January 1992]).
.7.3 Sample Analysis
Analyses of soil and sediment samples (physical properties), surface and ground water samples, waste
samples, discharge samples, and air samples are the most likely types of confirmatory samples taken
during RA. However, additional analyses are presented below to preserve the WBS and to provide
the WAM/RPM consideration with a comprehensive listing for consideration.
The WAM/RPM should consider adding a subtask for onsite laboratory analysis, if required. The
constructor will usually provide this service through the construction contract and there may be no
reason for the contractor to provide an independent onsite laboratory.
For cleanup validation and to ensure that the cleanup standards have been met, CLP analyses are
more likely to be performed than screening analyses. Some screening analyses in combination with
CLP may be required as construction proceeds. The WAM/RPM should specify the types of sample
analyses required at specific milestones during construction.
.7.3.1 Screening Type Laboratory Sample Analysis. The contractor shall arrange for and conduct
tlie appropriate combination of screening analytical tests for any materials and/or
confirmatory samples taken at the site:
(1) Analyze Air and Gas Samples
(A) Organic
16
Model RA SOW (6/95)
-------
(B) Inorganic
(C) Radiochemistry
(2) Analyze Ground Water Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(3) Analyze Surface Water Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(4) Analyze Soil and Sediment Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(5) Analyze Waste (Gas) Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(6) Analyze Waste (Liquid) Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(7) Analyze Waste (Solid) Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(8) Analyze Biota Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(9) Analyze Bioassay Samples
(10) Perform Bioaccumulation Studies
.7.3.2 CLP Type Laboratory Sample Analysis. The contractor shall arrange for and conduct the
appropriate combination of CLP analytical tests for any materials and/or confirmatory
samples taken at the site:
(1) Analyze Air and Gas Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(2) Analyze Ground Water Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(3) Analyze Surface Water Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(4) Analyze Soil and Sediment Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(5) Analyze Waste (Gas) Samples
(A) Organic
17 Model RA SOW (6/95)
-------
-K'K! !!'*Hf aiBIB
(B) Inorganic
(C) Radiochemistry
(6) Analyze Waste (Liquid) Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(7) Analyze Waste (Solid) Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(8) Analyze Biota Samples
(A) Organic
(B) Inorganic
(C) Radiochemistry
(9) Analyze Bioassay Samples
(10) Perform Bioaccumulation Studies
.7.4 Analytical Support and Data Validation
1. For RA, full data validation procedures are usually not necessary. The WAM/RPM may specify the
level of data validation required.
2. The WAM/RPM should specify the format for submissions if there are Region-specific or other
requirements.
.7.4.1 Prepare and Ship Environmental Samples. The contractor shall ensure the proper
management of samples in the field and arrange for shipment to the designated laboratory.
Accurate chain-of-custody procedures for sample tracking, protective sample packing
techniques, and proper sample-preservation techniques will be used.
(1) Ground Water Samples
(2) Surface and Subsurface Soil Samples
(3) Surface Water and Sediment Samples
(4) Air Samples
(5) Biota Samples
(6) Other Types of Media Sampling and Screening
.7.4.2 Coordinate with Appropriate Sample Management Personnel
.7.4.3 Implement EPA-Approved Laboratory QA Program.
.7.4,4 Provide Sample Management (Chain of Custody, Sample Retention, and Data Storage)
.7.4.5 Perform Data Validation. The contractor shall validate appropriate data to ensure that the
confirmatory data are accurate and defensible.
(1) Review Analysis Results against Validation Criteria
(2) Provide Written Documentation of Validation Efforts
.7.5 Data Evaluation
1. The WAM/RPM should specify the format for submissions if there are Region-specific or other
requirements.
2. The WAM/RPM should require the contractor to prepare and submit a Technical Memorandum to the
WAM/RPM summarizing the quality of data, preliminary results of evaluation, and if significant data
problems are identified early in the evaluation.
18
Model RA SOW (6/95)
-------
.7.5.1 Data Useability Evaluation/Field QA/AC
.7.5.2 Data Reduction, Tabulation, and Evaluation. The contractor shall evaluate, interpret, and
tabulate data in an appropriate presentation format for final data tables. The contractor
shall design and set up an appropriate database for pertinent information collected that will
be used to validate the RA.
(1) Evaluate Geological Data (Soils and Sediments)
(2) Evaluate Air Data
(3) Evaluate Hydrogeological Data: Ground Water
(4) Evaluate Hydrogeological Data: Surface Water
(5) Evaluate Waste Data
(6) Evaluate Geophysical Data
(7) Evaluate Ecological Data
.7.5.3 Modeling. The contractor shall perform limited and focused computer modeling of data
(i.e., air monitoring data) to facilitate data evaluation and interpretation.
(1) Contaminant Fate and Transport
(2) Water Quality
(3) Ground Water
(4) Air
(5) Other Modeling
.7.5.4 Develop Data Evaluation/Cleanup Status Report. Evaluate and present the sampling and
analytical results in a summary report and submit to the WAM/RPM for review and
approval. The report will assess the progress of the RA based on these results and identify
any actions required. After the WAM/RPM's review, the contractor shall attend a meeting
with EPA to discuss data evaluation results and next steps.
7.8 Remedial Action Implementation (Subpool Activities)
The purpose of this task is to provide the contractor with a structure for recording the activities performed and
costs incurred by the constructor and any subcontractors during RA implementation. A funding reserve is
allocated in this task to account for unforeseen site conditions and associated adjustments (i.e., change orders.
The use of MCACES Gold for construction cost estimates and the USAGE WBS will provide consistency
for construction cost estimates so that costs for similar RAs can be compared.
.8.1 Remedial Action Subcontract Cost. The contractor shall monitor and track the costs associated
with the constructor's implementation of the remedy.
.8.2 Remedial Action Reserve (15% of Remedial Action Subcontract). The contractor shall monitor and
track the reserve in relation to any approved change orders and notify the WAM/RPM when 75 %
of the reserve has been expended.
7.9 Project Performance (Operation and Maintenance [O&M])
The purpose of this task is to perform the activities necessary to protect the integrity of the remedy and to
evaluate system performance. This task begins during the later stages of construction with the revision of the
O&M manual and ends with submittal of final technical memoranda summarizing project performance.
The services provided here must be integrated with design document requirements. Design decisions will
dictate the level of effort required of the RA contractor versus the constructor.
.9.1 Operation and Maintenance (O&M)
19 Model RA SOW (6/95)
-------
•." •: . • I
.;; J , . • , .. . ; . }
.9.1.1 Review O&M Manual. The contractor shall review and update the O&M Manual, as
necessary, to include as-built drawings and equipment data sheets. The revised manual
shall be submitted to the WAM/RPM 30 days prior to the start of operation.
(1) Describe/Analyze Potential Operating Problems
(2) Review Conformity to Applicable Performance and Operations Requirements
.9.1.2 Ensure Adequate Training for O&M Staff. The contractor shall support all necessary
training of the O&M staff, including State personnel and contractors.
.9.1.3 Develop Corrective Action Plans. The contractor shall identify any potential system
failures and develop corrective action plans, if necessary.
.9.1.4 Review Records/Reporting Requirements
.9.1.5 Review Laboratory Procedures
.9.1.6 Review Process Systems
.9.1.7 Review Safety and Emergency Systems. The contractor shall perform the necessary
reviews of safety and emergency systems
.9.1.8 Review Warranty Information and Files
.9.2 System Performance
.9.2.1 Evaluate Equipment including operating parameters and performance. At a minimum, the
performance data to be collected shall be as needed to satisfy the requirements for
greparing the Cost and Performance Reports required under Section 7.9.3"
.9.2.2 Performance Tests Oversight. The contractor shall oversee any performance tests
conducted by the constructor and document procedures and results.
.9.2.3 Gather and Test Samples (see task 7 for details).
:|
i
.9.3 Report Project Performance
.9.3.1 The contractor shall prepare a technical memorandum to summarize the system's
performance and required O&M procedures. The contractor also shall prepare a Cost and
Performance Report in accordance with the guidance document entitled Guide to
Documenting Cost and Performance for Remediation Projects. Publication EPA-542-B-95-
002, March 1995. The report shall summarize the performance data collected under
section .9.2.1 as well as project costs. The Draft Technical Memoranda and Draft Cost
and Performance Report shall be submitted to the WAM/RPM 30 days prior to the final
inspection.
.9.3.2 Respond to Comments
.9.3.3 The contractor shall respond to any comments from EPA and prepare the Final Technical
^lemoranda and Cost and Perforrnance Report within 10 days of receipt of comments.
7.10 Project Completion and Close Out
The purpose of the project completion and close-out activities is for the RA contractor to conduct the necessary
inspections to verify completed work, make final payments, close out subcontracts, and prepare a Remedial
Action Report.
••'•!i i ' ' •. .. . . ••' . I
1. The RPM/WAM should identify when government accepts transfer of the constructed facilities at the
completion of the work assignment.
2, It is important for the WAM/RPM to consider the nature of any site improvements that will be funded
with Superfund monies. Often reasonable activities that restore the physical appearance of the site
and result in the long-term effectiveness of the remedy are included in the construction contract (i.e.,
road improvements). If not, the WAM/RPM may task the RA contractor to complete these activities.
20
Model RA SOW (6/95)
-------
.10.1 Demobilization
.10.1.1 Removal of Temporary facilities. The contractor shall dismantle, pack up, and move off-
site any temporary facilities (i.e., trailers) or equipment used during the course of the RA.
.10.1.2 Site Restoration. At the direction of the WAM/RPM, the contractor shall conduct
reasonable activities that restore the physical appearance of the site (i.e., road restoration,
fence removal, limited landscaping).
.10.1.3 Termination of Engineering Support Activities.
.10.2 Pre-fmal/Final Activities
.10.2.1 Make pre-final/final inspection. The contractor shall conduct the prefinal inspection with
the constructor and develop a punch list of deficiencies. The contractor shall prepare and
submit a prefinal inspection report which includes the list of deficiencies, completion dates
for outstanding items, and the date for a final inspection.
.10.2.2 Make Lockout Inspection. The contractor shall arrange for the final lockout inspection and
determine if all terms of the contract have been satisfied.
.10.3 Final Payment/Punch List
. 10.3.1 As-built resolution/certification
.10.3.2 Trial Period Oversight
. 10.4 Remedial Action Report
.10.4.1 Prepare draft Remedial Action Report. The contractor shall prepare and submit to the
WAM/RPM the Remedial Action Report, in accordance with the fact sheet entitled,
Remedial Action Report, Documentation for Operable Unit Completion, Publication
9355.0-39FS, June 1992. The report shall summarize RA events, performance standards
and construction quality control, construction activities, final inspection, certification that
the remedy is operational and functional, O&M, and RA costs.
.10.4.2 Respond to Comments
.10.4.3 Prepare/Issue Final Remedial Action Report. After receipt of EPA comments, the
contractor shall prepare and submit the final Remedial Action Report to the WAM/RPM.
7.11 Work Assignment Closeout
.11.1 Return Documents to Government
.11.2 Duplicate, Distribute, and Store Files
.11.3 Archive Files
.11.4 Prepare Microfiche, Microfilm, and Optical Disk
.11.5 Prepare Closeout Report. The contractor shall include a breakdown on disk of final costs and level
of effort (by P-level) in the same detail and format as the Work Breakdown Structure (Attachment
2).
21 Model RA SOW (6/95)
-------
Attachment 1
rSummary of Major; Srabmittals fbrtbesRemedial Action at
(Site)
TASK
1.1.2
1.1.4
1.1.4
1.2.1
2.1.2
2.1.2
3.1
3.1
3.1.1
3.1.1
3.1.2
3.1.2
3.2
DELIVERABLE
Site Trip Visit Report
RA Work Plan
Final RA Work Plan
Status Reports
Draft Community Relations
Plan (CRP)
Final CRP
Draft Revised Site
Management Plan (SMP)
Final Revised SMP
Draft Revised Health and
Safety Plan (HASP)
Final Revised HASP
Draft Revised Sampling and
Analysis Plan (SAP)
Final Revised SAP
Draft Revised Pollution
Control & Mitigation Plan
REF
NO.
NO. OF
COPIES
3
3
3
3
3
3
3
3
3
3
3
3
3
DUE DATE
(calendar days)
10 days after site visit
30 days after initiation of work
assignment (WA)
15 days after receipt of EPA
comments
Monthly and as directed by
WAM/RPM
14 days after completion of
community interviews
7 days after receipt of EPA
comments
21 days after approval of RA
Work Plan
10 days after receipt of EPA
comments
21 days after approval of RA
Work Plan
10 days after receipt of EPA
comments
21 days after approval of RA
Work Plan
10 days after receipt of EPA
comments
21 days after approval of RA
Work Plan
EPA REVIEW
PERIOD
7 days after receipt of report
21 days after receipt of Work
Plan
NA
NA
7 days after receipt of draft CRP
NA
14 days after receipt of SMP
NA
14 days after receipt of plan
NA
14 days after receipt of plan
NA
14 days after receipt of plan
-------
TASK
3.2
3.3
3.3
6.2.10
6.2.10
7.5.4
7.5.4
9.1.1
9.3
9.3
10.4
10.4
11.5
11.5
11.6
DELIVERABLE
Final Revised Pollution Control
& Mitigation Plan
Draft Revised Construction
Management Plan
Final Revised Construction
Management Plan
Draft Final Inspection Report
Final Inspection Report
Draft Data Evaluation
Summary Report
Final Data Evaluation
Summary Report
Draft Revised Operations and
Maintenance (O&M) Manual
Draft Technical Memorandum
Final Technical Memorandum
Draft Remedial Action Report
Final Remedial Action Report
Draft Closeout Report
Final Closeout Report
Final Costs
REF
NO.
NO. OF
COPIES
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
DUE DATE
(calendar days)
10 days after receipt of EPA
comments
21 days after approval of RA
Work Plan
10 days after receipt of EPA
comments
10 days after Final Inspection
7 days after receipt of EPA
comments
14 days after receipt of analytical
results from laboratory
7 days after receipt of EPA
comments
30 days before Final Inspection
10 days after completion of
performance tests
10 days after receipt of EPA
comments
30 days after Final Inspection
14 days after receipt of EPA
comments
30 days after final RA Report
submitted
14 days after receipt of EPA
comments
90 days after WA closeout
EPA REVIEW
PERIOD
NA
14 days after receipt of plan
NA
NA
NA
14 days after receipt of report
NA
21 days after receipt of report
21 days after receipt of
memorandum
NA
21 days after receipt of report
NA
21 days after receipt of report
NA
NA
-------
Attachment 2
Work Breakdown Structure (WBS) for
Remedial Action (RA)
TASK 1 PROJECT PLANNING AND SUPPORT
l.Q Project Planning and Support
.01 Project Planning
.01 Attend Scoping Meeting
.02 Conduct Site Visit (if necessary)
.03 Evaluate Existing Information (if necessary)
.04 Work Plan Development
.01 Draft Work Plan Development
.01 Develop Narrative
.02 Develop Cost Estimate
.03 Internal QA & Submission
.02 Final Work Plan Preparation
.01 Attend Negotiation Meeting
.02 Modify Draft Work Plan/Cost Estimate
.03 Internal QA & Submission
.02 Project Management
.01 Prepare Periodic Status Reports
.01 Document Cost and Performance Status
.02 Prepare/Submit Invoices
.02 Meeting Participation/Routine Communications
.03 Maintain Cost/Schedule Control System
.04 Manage, Track, and Report Equipment Status
.05 Project Closeout
.06 Coordinate with Local Emergency Response Teams
;;;:•:, . " : :|, ify ; , •: . : ;" ' :!', - ;j
TASK 2 COMMUNITY RELATIONS
: . • , K ;i: I . . I
2.Q Community Relations
.01 Community Relations Plan (CRP) Development
.01 Conduct Community Interviews
.02 Prepare CRP
.01 Draft CRP
.02 Final CRP
.02 Prepare Fact Sheets
.03 Public Hearing, Meetings, & Availability Support
.01 Technical Support
.02 Logistical & Presentation Support
.03 Public Notice Support (writing, or placement of)
.04 Maintain Information Repository/Mailing List
11, : ':!:' !!! • • . .";:i: ;: , ' • ' ; : ' i II
TASK 3 DEVELOPMENT AND UPDATE OF SITE SPECIFIC PLANS
J ,"• ' „ li Jl'lij .'; : I '.'" ' I
3.Q Development and Update of Site Specific Plans
.pi Update Site Management Plan
.01 Update Health & Safety Plan
.02 Update Sampling & Analysis Plan (Chemical Data Acquisition Plan)
,01 Quality Assurance Project Plan
.02 Field Sampling Plan
,03 Data Management Plan
.02 Update Pollution Control & Mitigation Plan
.01 Transportation & Disposal Plan (Waste Management Plan)
.03 Update Construction Quality Assurance Plan
N"'' ' ' ii: '''Mi : , i
TASK 4 PROCUREMENT OF SUBCONTRACT
24
Model RA SOW (6/95)
-------
4.0 Procurement of Subcontract
.01 Prebid (Pre-Solicitation) Activities
.01 Printing & Distribution of Contract Documents
.02 Advertising/Soliciting of Bids
.01 Prebid (pre-solicitation) meetings
.02 Resolution of inquiries/Issuing Addenda
.03 On-site Visits
.03 Readvertise/Resolicit bids if necessary
.02 Pre-Award Activities
.01 Receipt of Bids (offers)
.01 Determination of responsive, responsible bidders (offerers)
.02 Perform Reference checks
.03 Bid (offer) Tabulation
.04 Bid (offer) Analysis
.02 Receipt of follow-up items from lowest responsible bidder (offerer)
.03 Review of EEO, MBE requirements, SDB subcontracting plans
.04 Request for Consent from EPA
.03 Post-Award Activities
.01 Attend Post Award Meetings/Preconstruction Conference
.02 Review permits, insurance, bonds, etc.
.03 Review & approve RA subcontractor schedule
.04 Review & approve RA subcontractor measurement and payment schedule
.05 Perform RA subcontractor Submittal Review - Issue Notice to Proceed (NTP)
.06 Review Revisions/Addendum of RA subcontractor Submittals
TASK 5 MANAGEMENT SUPPORT
5.0 Management Support
.01 Financial Management
.01 Review & approve Invoices
.02 Review & approve Subcontract Modifications
.03 Maintain Tracking Systems
.01 Construction Codes of Accounts
.02 Work Breakdown Structure (WBS)
.03 Schedule (CPM, PERT, etc.)
.02 Cost Monitoring
.01 Weekly/Monthly Tracking
.02 Analyze Progress Payments
.03 Monitor RA Subcontractor for Compliance with Davis-Bacon Act
.03 Engineering Support
.01 Review Field Logs
.02 Periodic Attendance at Meetings
.04 Engineering Support Option
.01 Review Field Change Requests
.02 Review VE Proposals
.03 Review Non-Conformance Reports
.04 Review Re-Design Proposals
TASK 6 DETAILED RESIDENT INSPECTION (Resident Engineer)
6.0 Detailed Resident Inspection
.01 Attend Periodic Meetings
.02 Provide Field Presence and Oversight
.01 Maintain Field Logs and Daily Diaries
.02 Interpret Subcontract Documents
.03 Develop Sketches Reflecting Field Conditions
.04 Review Submitted Construction Drawings
.05 Prepare Reports on Inspections
.06 Monitor^ Update, & Report Construction Progress
.07 Review/Recommend Time Extensions
25 Model RA SOW (6/95)
-------
.08 Coordinate with Home Office/Management Support
.09 Perform Davis-Bacon Act Inspections
.10 Final Inspection
.01 Conduct Site Walkover
,02 Prepare draft Final Inspection Report
.03 Respond to Comments
.04 Prepare Final Inspection Report
.03 Provide Engineering Support to Design Team
.01 Recommend Actions on H&S Considerations
.02 Review/Recommend Action on VE Proposals
.03 Review/Recommend Design Changes
.04 Provide Support on Change Order Requests
.05 frovide Support in Claims Reduction
.06 Provide Support for Construction Schedule Changes
.04 Perform Field Testing
.05 Monitor Quality Assurance/Quality Control Procedures
TASK? CLEANUP VALIDATION
7.0t Cleanup Validation
,01 Mobilization/Demobilization
.01 Mobilize (acquire equipment/supplies/personnel)
.02 Demobilize
.02 Field Investigation
.01 Conduct Geological Investigations (Soils/Sediments)
.01 Surface Soil Sample Collection
.02 Subsurface Soil Sample Collection
.03 Soil Boring/Permeability Sampling
.04 Sediments Sample Collection
.05 Soil Gas Survey
.06 Test Pit
.02 Conduct Air Investigations
',,01 Sample Collections
.02 Air Monitoring Station
.03 Conduct Hydrogeological Investigations - Groundwater
.01 Well Systems Installation
.01 Accomplish Mobilization
.02 Perform Well Development
.03 Conduct Dpwnhole Geophysics
.04 Install Monitoring Wells
.05 Install Test Wells
.06 Install Gas Wells
.02 Sample Collection
.03 Hydro Punch
.04 Tidal Influence Study
.05 Hydraulic Tests (Pump Tests)
.06 Groundwater Elevation Measurement
.04 Conduct Hydrogeological Investigations—Surface Water
.01 Sample Collection
.02 Tidal Influence Study
.03 Surface Water Elevation Measurement
.05 Conduct Waste Investigation
.01 Sample Collection (Gas, Liquid, Solid)
",(fe Derived Waste Disposal (Gas, Liquid, Solid)
.06 Conduct Geophysical Investigation
,01 Surface Geophysical Activity
.02 Magnetometer
,03 Electromagnetics
.04 Ground Penetrating Radar
.05 Seismic Refraction
26
Model RA SOW (6/95)
-------
.06 Resistivity
.07 Site Meteorology
.08 Cone Penetrometer Survey
.09 Remote Sensor Survey
. 10 Radiological Investigation
.07 Conduct Ecological Investigation
.01 Wetland and Habitat Delineation
.02 Wildlife Observations
.03 Community Characterization
.04 Identification of Endangered Species
.05 Biota Sampling/Population Studies
.08 Collect Contaminated Building Samples
.09 Dispose of Investigation Derived Waste
.03 Sample Analysis
.01 Screening Type Laboratory Sample Analysis
.01 Analyze Air/Gas Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.02 Analyze Groundwater Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.03 Analyze Surface Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.04 Analyze Soil/Sediment Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.05 Analyze Waste (Gas) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.06 Analyze Waste (Liquid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.07 Analyze Waste (Solid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.08 Analyze Biota Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.09 Analyze Bioassay Samples
. 10 Perform Bioaccumulation Studies
.02 CLP-Type Laboratory Sample Analysis
.01 Analyze Air/Gas Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.02 Analyze Groundwater Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.03 Analyze Surface Water Samples
.01 Organic
27 Model RA SOW (6/95)
-------
.02 Inorganic
.03 Radiochemistry
.04 Analyze Soil/Sediment Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.05 Analyze Waste (Gas) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.06 Analyze Waste (Liquid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.07 Analyze Waste (Solid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.08 Analyze Biota Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.09 Analyze Bioassay Samples
.10 Perform Bipaccumulation Studies
.04 Analytical Support and Data Validation
.01 Prepare and Ship Environmental Samples
01 Groundwater Samples
.02 Surface and Subsurface Soil Samples
.03 Surface Water & Sediment Samples
,Q4 Air Samples
.05 Biota Samples
.06 Other Types of Media Sampling and Screening
.02 Coordinate with Appropriate Sample Management Personnel
.03 Implement EPA-Approved Laboratory QA Program
.04 Provide Sample Management (Chain of Custody, Sample Retention, & Data Storage)
.05 Perform Data Validation
.01 Review Analysis Results Against Validation Criteria
.02 Provide Written Documentation of Validation Efforts
Data Evaluation
.06
.01 Data Useability Evaluation/Field QA/QC
.02 Data Reduction, Tabulation and Evaluation
.01 Evaluate Geological Data (Soils/Sediments)
.02 Evaluate Air Data
.03 Evaluate Hydrogeological Data—Groundwater
.04 Evaluate Hydrogeological Data—Surface Water
.05 Evaluate Waste Data
.06 Evaluate Geophysical Data
.07 Evaluate Ecological Data
.03 Modeling
.51 Contaminant Fate and Transport
.02 Water Quality
.03 Groundwater
•04 Air
.05 Other Modeling
.04 Document Data Evaluation Efforts
TASK 8 REMEDIAL ACTION IMPLEMENTATION (SUBPOOL ACTIVITIES)
': ' ' • • 3"; ,;:;.;! ' ' ••, t •
8.Q Remedial Actiqn Implementation
.01 Remedia] Action Subcontract Cost
28
Model RA SOW (6/95)
-------
.02 Remedial Action Reserve (15% of Remedial Action Subcontract)
TASK 9 PROJECT PERFORMANCE
9.0 Project Performance (O&M)
.01 Operation & Maintenance (O&M)
.01 Review O&M Manual
.01 Describe/Analyze Potential Operating Problems
.02 Review Conformity to Applicable Performance & Operations Performance
.02 Ensure Adequate Training for O&M Staff
.03 Develop Corrective Action Plans (if necessary)
.04 Review Records/Reporting Requirements
.05 Review Laboratory Procedures
.06 Review Process Systems
.07 Review Safety and Emergency Systems
.08 Review Warranty Information and Files
.02 System Performance
.01 Evaluate Equipment
.02 Site Restoration
.03 Gather and Test Samples (see Task 7 for details)
.03 Report Project Performance
.01 Develop Draft Technical Memoranda and Cost and Performance Report
.02 Respond to Comments
.03 Prepare Final Technical Memoranda and Cost and Performance Report
TASK 10 PROJECT COMPLETION AND CLOSE OUT
10.0 Project Completion and Close Out
.01 Demobilization
.01 Removal of Temporary Facilities
.02 Site Restoration
.03 Termination of Engineering Support Activities
.02 Pre-Final/Final Activities
.01 Make Pre-Final/Final Inspection
.02 Make Lockout Inspection
.03 Final Payment/Punch List
.01 As-built Resolution/Certification
.02 Trial Period Oversight
.04 Remedial Action Report
.01 Prepare Draft Remedial Action Report
.02 Respond to Comments
.03 Prepare/Issue Final Remedial Action Report
TASK 11 WORK ASSIGNMENT CLOSE OUT
11.0 Work Assignment Close Out
.01 Return Documents to Government
.02 File Duplication/Distribution/Storage
.03 File Archiving
.04 Microfiche/Microfilm/Optical Disk
.05 Prepare Closeout Report
29 Model RA SOW (6/95)
-------
Attachment 3
Regulations and Guidance Documents
The following list, although not comprehensive, comprises many of the regulations and guidance documents that
apply to the RD process:
1. American National Standards Practices for Respiratory Protection. American National Standards Institute
Z88.2-1980,March 11, 1981.
2. ARCS Construction Contract Modification Procedures September 89, OERR Directive 9355.5-01/FS.
3. CERCLA Compliance with Other Laws Manual, Two Volumes, U.S. EPA, Office of Emergency and
Remedial Response, August 1988 (DRAFT), OSWER Directive No. 9234.1-01 and -02.
4. Community Relations hi Superfund — A Handbook, U.S. EPA, Office of Emergency and Remedial
Response, June 1988, OSWER Directive No. 9230.0-3B.
5. A Compendium of Superfund Field Operations Methods, Two Volumes, U.S. EPA, Office of Emergency
and Remedial Response, EPA/540/P-87/001a, August 1987, OSWER Directive No. 9355.0-14.
6. Construction Quality Assurance for Hazardous Waste Land Disposal Facilities, U.S. EPA, Office of Solid
Waste and Emergency Response, October 1986, OSWER Directive No. 9472.003.
7. Contractor Requirements for the Control and Security of RCRA Confidential Business Information, March
"" 1984. "
8. Data Quality Objectives for Remedial Response Activities, U.S. EPA, Office of Emergency and Remedial
Response and Office of Waste Programs Enforcement, EPA/540/G-87/003, March 1987, OSWER
Directive No: 9335.0-7B.
9. Engineering Support Branch Standard Operating Procedures and Quality Assurance Manual, U.S. EPA
Region IV, Environmental Services Division, April 1, 1986 (revised periodically).
10. EPA NEIC Policies and Procedures Manual, EPA-330/9-78-001-R, May 1978, revised November 1984.
1L Federal Acquisition Regulation, Washington, DC: U.S. Government Printing Office (revised periodically).
12". Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final,
U.S. EPA, Office of Emergency and Remedial Response, October 1988, OSWER Directive NO.
• • ' !": 9355.3-01. !
13. Guidance on EPA Oversight of Remedial Designs and Remedial Actions Performed by Potential
Responsible Parties, U.S. EPA Office of Emergency and Remedial Response, EPA/540/G-90/001, April
1990.
14. Guidance on Expediting Remedial Design and Remedial Actions, EPA/540/G-90/006, August 1990.
15^ Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites, U.S. EPA Office of
Emergency and Remedial Response (DRAFT), OSWER Directive No. 9283.1-2.
16, Guide for Conducting Treatability Studies Under CERCLA, U.S. EPA, Office of Emergency and Remedial
Response, Prepublication version.
17. Guide to Management of Investigation-Derived Wastes, U.S. EPA, Office of Solid Waste and Emergency
Response, Publication 9345.3-03FS, January 1992.
18. Guidelines and Specifications for Preparing Quality Assurance Project Plans, U.S. EPA, Office of Research
and Development, Cincinnati, OH, QAMS-004/80, December 29, 1980.
19. Health and Safety Requirements of Employees Employed in Field Activities, U.S. EPA, Office of
Emergency and Remedial Response, July 12, 1982, EPA Order No. 1440.2.
20. Interim Guidance on Compliance with Applicable of Relevant and Appropriate Requirements, U.S. EPA,
Office of Emergency and Remedial Response, July 9, 1987, OSWER Directive No. 9234.0-05.
21. Interim GuiSelines and Specifications for Preparing Quality Assurance Project Plans, U.S. EPA, Office of
Emergency and Remedial Response, QAMS-005/80, December 1980.
22. Methods for Evaluating the Attainment of Cleanup Standards: Vol. 1, Soils and Solid Media, February
1989, EPA 23/02-89-042; vol. 2, Ground water (Jul 1992).
23. National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule, Federal Register 40 CFR
Part 300, March 8, 1990.
24. NIOSH Manual of Analytical Methods, 2nd edition. Volumes I-VII for the 3rd edition, Volumes I and II,
National Institute of Occupational Safety and Health.
251 Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, National Institute of
Occupational Safety and Health/Occupational Health and Safety Administration/United States Coast
Guard/Environmental Protection Agency, October 1985.
26. Permits and Permit Equivalency Processes for CERCLA On-Site Response Actions, February 19, 1992,
OSWER Directive 9355.7-03.
27. Procedure for Planning and Implementing Off-Site Response Actions, Federal Register, Volume 50,
Number 214, November 1985, pages 45933-45937.
30 Model RA SOW (6/95)
-------
28. Procedures for Completion and Deletion of NPL Sites, U.S. EPA, Office of Emergency and Remedial
Response, April 1989, OSWER Directive No. 9320.2-3A.
29. Quality in the Constructed Project: A Guideline for Owners, Designers and Constructors, Volume 1,
Preliminary Edition for Trial Use and Comment, American Society of Civil Engineers, May 1988.
30. Remedial Design/Remedial Action (RD/RA) Handbook, U.S. EPA, Office of Solid Waste and Emergency
Response (OSWER) 9355.0-04B, EPA 540/R-95/059, June 1995.
31. Revision of Policy Regarding Superfund Project Assignments, OSWER Directive No. 9242.3-08,
December 10, 1991. [Guidance, p. 2-2]
32. Scoping the Remedial Design (Fact Sheet), February 1995, OSWER Publ. 9355-5-21 FS.
33. Standard Operating Safety Guides, U.S. EPA, Office of Emergency and Remedial Response, November
1984.
34. Standards for the Construction Industry, Code of Federal Regulations, Title 29, Part 1926, Occupational
Health and Safety Administration.
35. Standards for General Industry, Code of Federal Regulations, Title 29, Part 1910, Occupational Health and
Safety Administration.
36. Structure and Components of 5-Year Reviews, OSWER Directive No. 9355.7-02, May 23, 1991.
[Guidance, p. 3-5]
37. Superfund Guidance on EPA Oversight of Remedial Designs and Remedial Actions Performed by
Potentially Responsible Parties, April 1990, EPA/540/G-90/001.
38. Superfund Remedial Design and Remedial Action Guidance, U.S. EPA, Office of Emergency and Remedial
Response, June 1986, OSWER Directive No. 9355.0-4A.
39. Superfund Response Action Contracts (Fact Sheet), May 1993, OSWER Publ. 9242.2-08FS.
40. TLVs-Threshold Limit Values and Biological Exposure Indices for 1987-88, American Conference of
Governmental Industrial Hygienists.
41. Treatability Studies Under CERCLA, Final. U.S. EPA, Office of Solid Waste and Emergency Response,
EPA/540/R-92/071a, October 1992.
42. USEPA Contract Laboratory Program Statement of Work for Inorganic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, July 1988.
43. USEPA Contract Laboratory Program Statement of Work for Organic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, February 1988.
44. User's Guide to the EPA Contract Laboratory Program, U.S. EPA, Sample Management Office, August
1982.
45. Value Engineering (Fact Sheet), U.S. EPA, Office of Solid Waste and Emergency Response, Publication
9355.5-03FS, May 1990.
31 Model RA SOW (6/95)
-------
Attachment 4
TRANSMITTAL OF DOCUMENTS FOR ACCEPTANCE BY EPA
TO:
SUBTASK NO.
DATE:
FROM:
DELIVERABLE
NO. OF
COPIES
TRANSMITTAL NO.
1 1 New Transmittal
1 — 1 Resubmittal of
Transmittal No.
REMARKS
ACCEPTANCE ACTION
DOCUMENTS FOUND ACCEPTABLE (LIST BY SUBTASK NO.)
NAME/TITLE/SIGNATURE OF REVIEWER
DATE
II I si -,f-
-------
Attachment 5
TRANSMITTAL REGISTER
PROJECT TITLE AND LOCATION
Subtask No.
DELIVERABLE
•g $
d'S1
2 U
§1
Q Q
CONTRACT NO.
Transmittal
No.
Date
Received
Date Comments
Sent to
Contractor
WORK ASSIGNMENT NO.
EPA
Acceptance
Date
REMARKS
-------
<. ' t
-------
(Date)
MODEL STATEMENT OF WORK
FOR REMEDIAL ACTION OVERSIGHT
SITE, COUNTY, STATE
ATTACHMENTS
Attachment 1. Summary of Major Submittals for the Remedial Action Oversight at (Site) 21
Attachment 2. Work Breakdown Structure 23
Attachment 3. Regulation and Guidance Documents 28
Attachment 4. Transmittal of Documents for Acceptance by EPA 30
Attachment 5. Transmittal Register _-. 31
Purpose of RA Oversight Model SOW
1. To tell the contractor what EPA wants done. This model SOW is for contractors to provide
oversight of RAs being conducted by Potentially Responsible Parties (PRPs). Be as specific as
possible in describing what the RA oversight contractor is required to do. In that way, the contractor
will understand the requirements, will write a RA Oversight Work Plan and associated budget to meet
those requirements, and will be ultimately responsible for satisfying those requirements. Whenever
there is an absolute requirement (e.g., that the contractor prepare the Quality Assurance Project Plan
(QAPP) hi accordance with QAMS-005/80, December 29, 1980), state that requirement.
2. To give the contractor a structure for recording costs. A structured cost schedule will simplify
cost comparisons of specific tasks being performed at similar RA oversight projects.
Use of Work Breakdown Structure (WBS)
1. A WBS was developed for this model SOW for the WAM/RPM to track the initial and final costs of
each element and to share these data with other Federal agencies. The WBS is, essentially, the
outline for this model SOW and is included as Attachment 2 to this document.
2. If an element is not to be used, do not change the numbering system, instead, insert "Not used" for
that element number after deleting the text for that element.
3. For elements in the SOW for a given project, additional descriptions (e.g., type of samples and
estimated number) should be added to the SOW for the contractor and WAM/RPM to develop
estimated costs on a common basis.
8.0 Introduction
.0.1 Site Description
Provide a brief site description that contains information relative to RA oversight planning and
implementation such as location, operational history, remedial response history, waste types, quantities, and
milestones specified in the Record of Decision (ROD) and Remedial Design (RD) documents.
.0.2 Purpose
Model RA Oversight SOW (6/95)
-------
The purpose of this SOW is to provide the framework and requirements for the contractor to
provide oversight of the construction and implementation of the RA, including system start-up and
diagnostic testing, operation and maintenance, and performance monitoring, at (site).
Actual construction and implementation of the RA shall be performed by the PRP's constructor.
The ROD issued on (date) describes the RA selected for this sitej and the RD
documents provide the construction and implementation detail required to achieve the selected RA.
The goal is to complete the RA by . The estimated completion date for this work
assignment is .
Many contractors, subcontractors, and other participating team members will be involved hi the completion
of the RA. The WAM/RPM may consider identifying and defining each team member to avoid potential
confusion. Upfront definitions will ensure that the names and titles of team members are used consistently
throughout the completion of the RA, and that the roles and responsibilities of each team member are clear
in the SOWs, project plans, and other critical project and contract documents.
For the purposes of this model SOW, the "contractor" is defined as the firm responsible for performing the
SOW. The contractor is under contract with EPA to provide oversight of the "RA constructor," who is
under contract with the PRPs. The contractor may be contracted through the Alternate Remedial
Contracting Strategy (ARCS) or Remedial Action Contractor (RAC) contracting vehicles, but will not be
performing RA construction or implementation tasks.
For a PRP-lead remediation project, it is likely that RD and RA would be performed by PRP constructors
and contractors, with oversight provided by EPA contractors. This model SOW is written with the
assumption that the contractor (providing RA oversight) is not the same as the contractor that provided RD
oversight. If the same contractor is used, some of the tasks described in this model SOW could be
modified or "Not used."
.0.2.1 Description of the RA
A brief description should include a summary of the general response objectives for the subject site, the
selected RA described hi the ROD to achieve those objectives, and a description of subsequent RD
documents required for construction and implementation of the RA.
.0.2.2 Objectives of Oversight. The primary objective of PRP oversight is to ensure that the RA,
as specified in the ROD and the RD documents, is accurately interpreted and adhered to
during construction and implementation. The RA must protect public health and the
environment during the life of the project and must comply with the terms of the Settlement
Agreement or Consent Decree (CD). Successful RA oversight is accomplished by observing
and documenting that the PRP has complied with all applicable laws, regulations, and
requirements, and has met all performance standards specified hi the CD.
.0.3 General Requirements
.0.3.1 The contractor shall perform RA oversight in accordance with this SC)W and shall ensure
consistency with the ROD, RD documents produced for the site, the CD, the Remedial
Design and Remedial Action Handbook (U.S. EPA Office of Solid Waste and Emergency
Response (OSWER) 9355.0-04B, EPA 540/R-95/059, June 1995) and other relevant
guidance used by EPA in conducting RAs. The primary contact for this work assignment is
, Tel. (___) ; the secondary contact is , Tel.
I I.
id]!!.
Model RA Oversight SOW (6/95)
Uti:. ,;>, iii h.iin.., Ad: ..... ''_*! ..... '.;'.,'>.'• ..... -i; ...... i kdJIIII:' fi
-------
.0.3.2 A summary of the major deliverables and the schedule for submittal is attached. See
Attachment 1.
.0.3.3 Specifically, the RA involves the construction and implementation of
(briefly describe the major components of the RA).
.0.3.4 The contractor shall furnish all necessary and appropriate personnel, materials, and services
needed, or incidental to, performing and completing the RA oversight.
.0.3.5 A list of primary guidance and reference material is listed in Attachment 2: In all cases, the
contractor shall use the most recently issued guidance.
.0.3.6 The contractor shall maintain RA oversight files as specified in the contract and by the
WAM/RPM.
.0.3.7 The contractor shall communicate at least weekly with the WAM/RPM, either iri person or
through conference calls, to report on RA oversight progress.
.0.3.8 The contractor shall notify the WAM/RPM when 75 percent and when 95 percent of the
approved work assignment budget has been expended.
.0.3.9 The contractor shall document all decisions that are made hi meetings and conversations
with EPA or the PRP. The contractor shall forward this documentation to the WAM/RPM
within 2 working days of the meeting or conversation.
Although the contractor is being tasked to document decisions made in meetings and conversations with
EPA or the PRP, the WAM/RPM is ultimately responsible for documenting the decisions and should not
solely rely on the contractor to do this.
.0.3.10 EPA will provide oversight of contractor activities throughout the RA oversight efforts.
EPA review and approval of the contractor's deliverables is a tool to assist this process
and to satisfy, in part, EPA's responsibility to provide effective protection of public
health, welfare, and the environment during the contractor's oversight of the PRP's
remedial activities. EPA will review the deliverables prepared during the oversight to
assess the likelihood that the RA will achieve its remediation goals and that all
performance requirements applicable to the RA have been correctly identified and
implemented. However, acceptance of deliverables by EPA does not relieve the
contractor of responsibility for the adequacy of the deliverable.
.0.4 Oversight Official
The contractor shall designate an Oversight Official (i.e., the contractor's site manager responsible
for the work assignment) to report directly to the WAM/RPM during RA oversight. The Oversight
Official is the point-of-contact (POC) from the contractor, who acts as a liaison between the
WAM/RPM, the PRP, the PRP's RA constructor, and the PRP's Independent QA Team. The
Oversight Official is responsible for providing technical support in monitoring PRP compliance with
the CD. Specific responsibilities of the Oversight Official include ensuring that the PRP is working
with an Independent QA Team, assisting in the review of professional qualifications, reviewing RA
submittals, and providing summary and activity reports to the WAM/RPM.
.0.5 Equipment Transfer
Model RA Oversight SOW (6/95)
-------
I
At the completion of the RA, or when government property is no longer required at the site, the
contractor shall arrange for the proper disposition of government-furnished or contract-acquired
property (purchased with contract funds) in accordance with the contract requirements. The
disposition (transfer, sale, or abandonment) of government personal property and the tracking of
such equipment shall be coordinated with the Contract Property Administrator. For additional
mformatiqn, refer to Contractor's Guide for Control of Government Property, Office of
Administration and Resources Management, December 1988.
1 !'! ' ' . i,' ' ''
.0.6 Project Closeout
At the completion of the RA, the contractor shall perform all necessary project closeout activities as
specified in the contract. These activities may include closing out any subcontracts, indexing and
consolidating project records and files, and providing a technical and financial closeout report to
EPA. Final costs shall be reported to EPA electronically, categorized by each cost element in the
WBS.
8.1 Project Planning and Support
The purpose of this task is to plan for the execution and overall management of this SOW. Technical and
management activities required to oversee the PRP's implementation of the RA, along with associated
costs, are developed during the planning phase and are detailed in the contractor's RA Oversight Work
Plan. Activities required for general work assignment management, including preparation of monthly
progress report and invoices, that will occur throughout the duration of the project are included in this
task. This task may begin before or after approval of the final RD and will continue through the RA
oversight work assignment closeout.
.1.1 Project Planning
.1.1.1 Attend Scoping Meeting. The contractor shall attend a scoping meeting to be held at the
EPA Regional Office before or concurrent with developing the contractor's RA Oversight
Work Plan.
Location of meetings and the WAM/RPM's expectations for the number of contractor personnel to attend
should be specified for cost estimation purposes. Consider having the RD oversight contractor, if different
than the RA oversight contractor, attend initial meetings and site visits to present any special considerations
and to facilitate the transfer of site and design information prior to the development of the RA Oversight
Work Plan.
.1.1.2 Conduct Site Visit. The contractor shall conduct a one-day site visit with the WAM/RPM
during the project planning phase to develop a conceptual understanding of the site and the
RA scope and requirements. A Health and Safety Plan (HASP) is required for the site visit.
The contractor shall prepare a letter report that documents all EPA, RA constructor, RA
oversight contractor, and site personnel present at the visit, all decisions made during the
visit, any action items assigned, including person responsible and due date, any unusual
occurrences during the visit, and any portions of the site that were not accessible to the
contractor and die impact of this on oversight of the RA. This report shall be submitted to
the WAM/RPM within 10 calendar days of the site visit.
• • " - • "•* • • !•• '
.1.1.3 Evaluate Existing Information. The contractor shall obtain, copy (if necessary), and review
available information pertaining to the site from EPA. The contractor shall evaluate the
existing data and documents, including the ROD, the CD, and the PRP's RA Work Plan, if
available. The specific reference documents to be reviewed are listed in Attachment 3.
Model RA Oversight SOW (6/95)
-------
The WAM/RPM may want to specify that the contractor focus on the review of RD documents submitted
by the PRP's RD contractor. The contractor should perform a relatively thorough review of final design
documents to gain an understanding of the RA to be constructed and implemented at the subject site. A
detailed review of earlier stages of design (i.e., review of preliminary and intermediate design documents,
described under Task 6.7.1 in the WBS) would not likely be required of the RA oversight contractor.
In addition to providing the contractor with final design documents, the WAM/RPM may want to compile
summaries contained in project reports to describe the nature and extent of contamination, cleanup goals and
objectives, the selected RA, and critical aspects of the ongoing community relations program. The
WAM/RPM could also provide reference documents for the selected RA, such as technology summaries
and fact sheets.
.1.1.4 Develop Technical Project Goals and Objectives. The contractor shall prepare data needs
and data quality objectives (DQOs) for analytical sampling to be performed during
oversight. The goals and objectives should be used to define the analytical methods and
protocols, decontamination procedures, and EPA reporting levels (e.g., I, II, III, IV)
required to match those used by the PRP's RA constructor.
(1) Not used - Develop Conceptual Site Model
(2) Identify Preliminary Project Requirements
(a) Data Needs and Data Quality Objectives
(b) Not used - RA Objectives and Potential Alternatives
(c) Not used - Possible Treatability Studies
(d) Not used - ARARs and/or Standards
(e) Not used - NEPA Requirements
(f) Not used - Other Regulatory Requirements/Restrictions
The WAM/RPM should require the contractor to identify DQOs for the collection of samples during RA
oversight. Other requirements and standards that may be applicable to the contractor's SOW should also be
identified.
.1.1.5 Develop RA Oversight Work Plan
(1) Develop Draft RA Oversight Work Plan. The contractor shall prepare and submit a
Draft RA Oversight Work Plan within 45 calendar days after initiation of the work
assignment. The contractor shall use information from the EPA-approved PRP's RA
Work Plan, if available, appropriate guidance, and direction provided by the
WAM/RPM as the basis for preparing the RA Oversight Work Plan. RA oversight
work must be coordinated and properly sequenced with EPA and PRP RA activities.
Submit the original to the Contracting Officer, one copy to the Project Officer, and one
copy to the WAM/RPM.
1. The WAM/RPM should verify the work plan submittal timeframe with the PO.
2. Additional copies of the work plan can be submitted to the WAM/RPM if specified, for distribution to
other technical staff.
(a) Develop Narrative. The RA Oversight Work Plan shall include a comprehensive
description of project tasks, the procedures to accomplish them, quality
assurance/quality control (QA/QC) systems and project-specific QA/QC
Model RA Oversight SOW (6/95)
-------
procedures to be followed, project documentation, and project schedule.
Specifically, the RA Oversight Work Plan shall include the following:
Identification of RA project elements and the associated oversight tasks
including review of PRP planning, construction, and implementation
documentation. This task will result in a detailed breakdown of subtasks
within the WBS tasks.
- The contractor's technical approach to each task to be performed, including a
detailed description of each task, the assumptions used, the information needed
for each task, any information to be produced during and at the conclusion of
each task, and a description of the work products that will be submitted to
EPA. Information shall be presented in a sequence consistent with the work
breakdown structure format defined in the standard WBS.
- A schedule with specific dates for completion of each required activity and
submission of each deliverable required by this SOW. This schedule shall also
include information regarding tuning, initiation, and completion of all critical
path milestones for each activity and deliverable and the expected review time
for EPA. ;
- A project communications and management plan and contractor reporting
requirements, such as meetings and presentations to EPA at the conclusion of
major phases of the project.
(b) Develop Cost Estimate. The contractor's estimated cost to complete the work
shall be broken into Level of Effort (by P-level) and cost for each element of the
Work Breakdown Structure (Attachment 2) and submitted to EPA on disk.
(c) Perform Internal QA and Submit Draft RA Oversight Work Plan
(2) Prepare Final RA Oversight Work Plan. The contractor shall prepare a Final RA
Oversight Work Plan 15 days after receipt of EPA comments on the draft, this final
version shall incorporate comments on the draft version as directed by the
WAM/RPM.
(a) Attend Negotiation Meeting. The contractor shall attend a Work Plan negotiation
meeting at the EPA Regional Office. EPA and the contractor will refine the SOW
requirements and funding issues'related to the RA Oversight Work Plan.
(b) Modify Draft RA Oversight Work Plan and Cost Estimate.
(c) Perform Internal QA and Submit Final RA Oversight Work Plan.
.1.1.6 Review PRP Plans. Tjie contractor shall review upfront plans prepared by the PRP's RA
constructor. These plans should constitute a complete set of construction-related work plans
and project plans, based on generic guide specifications for construction.
1 ' ' • ' '
The review of PRP plans under this task includes those plans which can be prepared prior to the preparation
of detailed construction plans. The review of detailed construction plans is described hi Task 6.7, "Review
of PRP Documents." Generic guide specifications for construction may be used by the PRP's RA
constructor to prepare these upfront PRP plans. The RA oversight contractor should recognize the
preliminary level of detail that can be expected during their review of upfront plans.
(1) Review PRP Site Management Plan
(a) Review PRP Pollution Control & Mitigation Plan
(b) Review PRP Transportation and Disposal (of site-derived wastes) Plan
(2) Review PRP Health and Safety Plan
(3) Review PRP Sampling and Analysis Plan
(a) Review PRP Quality Assurance Project Plan
(b) Review PRP Field Sampling Plan
(c) Review PRP Data Management Plan
(4) Review Other PRP Plan(s)
Model RA
Oversight SOW (6/95)
-------
. 1.2 Preparation of Site-Specific Plans
The site-specific plans to be prepared by the contractor may consist of revisions or modifications to existing
plans. If the RA oversight contractor was also the RD oversight contractor, this task should be abbreviated
to reflect only revisions to existing plans. Similarly, if a new RA oversight contractor is being used,
previous site plans can be provided by the WAM/RPM as examples to streamline this task.
.1.2.1 Not used
.1.2.2 Develop Health and Safety Plan (HASP) that specifies employee training, protective
equipment, medical surveillance requirements, standard operating procedures, and a
contingency plan in accordance with 29 CFR 1910.120. Whenever possible, use the HASP
developed for the RI/FS and/or RD oversight work assignments in preparing the HASP for
RA oversight. Provisions hi the RA constructor's HASP may also be incorporated into the
contractor's HASP.
1. The HASP may not constitute an Emergency Response Plan. Site conditions may warrant the
preparation of a separate Emergency Response Plan.
2. EPA does not approve the contractor's HASP, but reviews it to ensure that it is complete and
adequately protective.
.1.2.3 Develop Sampling and Analysis Plan (SAP) or Chemical Data Acquisition Plan to reflect the
specific objectives of data acquisition to be conducted during RA construction oversight.
The SAP will outline the data collection and QA/QC requirements of sampling and analysis
to be conducted by the contractor. The SAP may be composed of the Field Sampling Plan
(FSP) and Quality Assurance Project Plan (QAPP) under separate covers, or it may be a
single document, containing the essential elements of both the FSP and QAPP. The
contractor shall use the SAPs prepared for the RI/FS and/or RD oversight portions of the
project, whenever possible.
The Sampling and Analysis Plan (SAP) may not be required for certain RA oversight WAs. If required,
the SAP can be prepared by updating the SAP prepared for the RD. The contractor may collect split (or
duplicate) samples for laboratory analysis as samples are collected by the PRP's RA constructor. These
split samples are collected under Task 6.5 to assess the quality of analytical results provided by the PRP.
For a direct comparison, samples should be analyzed using the same analytical methods and EPA reporting
levels as those used by the PRP's RA constructor.
(1) Develop Quality Assurance Project Plan hi accordance with QAMS-005/80 (December
29, 1980). The QAPP shall describe the project objectives and QA/QC protocols to be
used in achieving the desired DQOs. The DQOs shall, at a minimum, reflect use of
analytical methods for identifying contamination and addressing contamination
consistent with the levels for RA objectives identified hi the National Contingency Plan
(NCP). The selected analytical methods and reporting levels shall parallel those being
used by the PRP's RA constructor.
(2) Develop Field Sampling Plan to define the oversight sampling and information-
collection methods that shall be used for the project. It shall include sampling
objectives, sample locations and frequency, sampling equipment and procedures,
sample handling and analysis, and description of which samples are to be analyzed
through the Contract Laboratory Program (CLP), which through other sources, and
7 Model RA Oversight SOW (6/95)
-------
the justification for those decisions. The FSP shall be written so that a field sampling
team unfamiliar with the site would be able to gather the samples and field information
required. The FSP developed for the RI/FS or RD oversight should be used whenever
possible in preparing the FSP for the RA oversight activities.
(3) Develop Data Management Plan to address requirements for project management
systems including tracking, storing, and retrieving data. The plan shall also identify
software to be used, minimum data requirements, data format, arid backup data
management. The plan shall address both data management and document control for
all RA oversight activities.
1.2.4 Other Plan(s)
, •(:• ,'ii'l • . ;
.1.3 Project Management
The WAM/RPM should specify the format for submissions; e.g., Monthly Progress Reports, if there
are Region-specific requirements or if you have specific requirements.
During construction, there may be especially active periods and the WAM/RPM should specify
additional communication requirements or status reports from the contractor. Also, the WAM/RPM
should arrange for personal visits to the site during these times.
.1.3.1 Prepare Periodic Status Reports. The contractor shall prepare Monthly Progress Reports.
(1) Document Cost and Performance Status. The contractor shall document the technical
progress and status of each task in the WBS for the reporting period in accordance
with contract requirements. The contractor shall report costs and level of effort (by P-
level) for the reporting period as well as cumulative amounts expended to date.
(2) Prepare and Submit Invoices. Monthly invoices will be prepared and submitted in
accordance with the level of detail as specified in the contract.
• ',• ,:;!ilnj • , ,,, ' ' ,' '„ , ',!;,! ," , j| !
.1.3.2 Meeting Participation and Routine Communications. The contractor shall attend project
meetings, provide documentation of meeting results, and shall contact the WAM/RPM by
telephone on a weekly basis to report project status. The contractor shall notify the
WAM/RPM immediately if inconsistencies with the design or non-compliance with the CD
or applicable or relevant and appropriate requirements (ARARs) are apparent. The
contractor shall describe the problem and provide recommended solutions in a technical
memorandum to the WAM/RPM.
,1.3.3 Not Used - Maintain Cost/Schedule Control System.
.1.3.4 Not used - Perform Value Engineering
.1.3.5 Not used - Perform Engineering Network Analysis
,1.3.6 Not used - Manage, Track, and Report Equipment Status.
.1.3.7 Work Assignment Closeout. The contractor shall perform the necessary activities to
closeout the work assignment in accordance with contract requirements.
.1.4 Subcontract Procurement and Support Activities
Model RA Oversight SOW (6/95)
-------
Other than a CLP laboratory, it is unlikely that the contractor will require subcontractors for RA oversight
activities. A special laboratory may be desired in addition to a CLP laboratory to perform geotechnical
testing or biologic parameter testing for certain sites. Using non-CLP laboratories should be considered on
a case-by-case basis.
.1.4.1 Identify and Procure Subcontractors. The contractor shall identify, solicit, and award any
subcontracts that are required to complete the RA oversight activities.
(1) Not used - Drilling Subcontractor
(2) Not used - Surveying Subcontractor
(3) Not used - Geophysical Subcontractor
(4) Not used - Site Preparation Subcontractor
(5) Analytical Services Subcontractors)
(6) Not used - Waste Disposal Subcontractor
(7) Not used - Treatability Subcontractor(s)
(8) Other(s)
.1.4.2 Develop Subcontractor QA/QC Program. The contractor shall review, approve, and
monitor the subcontractor's QA/QC program and conduct audits, as required.
.1.4.3 Perform Subcontract Management. The contractor shall perform the necessary management
and oversight of any subcontractor(s) needed for RA oversight. The contractor shall
institute procedures, monitor progress, and maintain systems and records to ensure that the
work proceeds according to contract requirements. The contractor shall review and approve
subcontractors' invoices and issue any necessary contract modifications.
8.2 Community Relations
The contractor shall provide community relations support to EPA throughout the RA. The contractor shall
provide community relations support in accordance with Community Relations in Superfund: A Handbook,
June 1988. This task begins with the approval of the contractor's RA Oversight Work Plan and continues
throughout the duration of the work assignment.
Model RA Oversight SOW (6/95)
-------
Generally, EPA retains responsibility for community relations during a PRP-lead RA. The CD may
specify the level of PRP participation in these activities and the WAM/RPM should define the role of
the contractor and the level of interaction with the PRP.
A variety of possible community relations activities may be appropriate during the RA, based on the
characteristics and specific circumstances at your site. Refer to the Community Relations in
Super/and: A Handbook, Chapters 6 and 7 and Appendix A, for suggested community relations
activities during RA activities.
With implementation of the remedy, site activity increases and so does the likelihood of community
concerns and questions. In addition to the community relations activities listed below in the WBS, the
WAM/RPM may consider the following activities to communicate progress during construction:
arranging site tours and workshops, establishing observation decks, and videotaping cleanup
activities. These activities may be covered under Task 6.2.3.1, "Technical Support," or added to the
WBS as a separate item and numbered accordingly (i.e., 6.2.3.5). The WAM/RPM should plan for
and develop a proactive and effective program with the assistance of the Regional Community
Relations Specialist.
The WAM/RPM should review the current community relations plan, if one exists, and direct the
contractor to update the existing CRP to address activities and concerns specific to the RA.
The WAM/RPM should specify the format for Community Relations submissions (e.g., fact sheets,
news releases) if there are EPA Region-specific or other requirements.
II
.2.1 Develop Community Relations Plan
.2.1.1 Conduct Community Interviews. The contractor shall assist the WAM/RPM in conducting
community interviews to identify community concerns associated with the RA. The
contractor shall assist the WAM/RPM in identifying key community members, establishing
an interview schedule, conducting interviews, and summarizing the results.
1
.2.1.2 Update the CRP. The contractor shall update the existing CRP to address community
relations requirements and community concerns during the RA.
(1) Draft CRP. The contractor shall update the CRP and submit a draft version within 14
days after completion of the community interviews.
(2) Final CRP. Within 7 days of receipt of EPA comments, the contractor shall submit a
final CRP.
;,;,, ..;;.; , ' ;j
,2.2 Prepare Fact Sheets
The contractor shall assist the WAM/RPM in preparing a fact sheet that informs the public about
activities related to the final design, the schedule for the RA, activities to be expected during
construction, measures to be taken to protect the community, provisions for responding to
emergency releases and spills, and any potential inconveniences such as excess traffic and noise that
may affect the community during the RA.
10
Model RA Oversight SOW (6/95)
-------
1. This subtask may have been completed during the RD. In that case, the WAM/RPM may task the
contractor to revise the fact sheet before construction begins with the current schedule, expected
conditions, and relevant points of contact.
2. Depending on the complexity of the RA, the WAM/RPM should consider communicating construction
progress by sending out regular fact sheets. Specify to the contractor the anticipated number of fact
sheets, topics, and number of copies required.
.2.3 Public Meetings and Availability Support
The number and locations of anticipated public meetings should be identified in the SOW for cost estimation
purposes. Similarly, the WAM/RPM should specify the number of contractor personnel expected to be in
attendance at the public meetings.
.2.3.1 Technical Support. The contractor shall assist the WAM/RPM in providing technical
support for community meetings that may be held during the RA. This support may include
preparing technical input to news releases, briefing materials, arranging other community
relations vehicles (i.e., site tours), and helping the WAM/RPM to coordinate with local
agencies.
.2.3.2 Logistical and Presentation Support. The contractor shall assist the WAM/RPM in
preparing technical briefing materials and in arranging for the logistical details for the
meetings.
.2.3.3 Public Notice Support. The contractor shall assist the WAM/RPM in drafting public
notices, announcing the public meetings, and placing the notice in a local paper of general
circulation.
.2.4 Maintain Information Repository and Mailing Lists
The contractor shall assist the WAM/RPM in developing or revising site mailing lists and
maintaining a repository of information on activities related to RA, as described in Appendix A.8,
page A-19, of Community Relations in Superfund: A Handbook, June 1988.
8.3 Data Acquisition Oversight
This task involves oversight of the PRP's collection of samples during the RA. The review of the PRP's
project plans required for this sampling effort is performed under Task 6.1.1.6. This task begins with
EPA's approval of the PRP's SAP, FSP, and QAPP prior to the PRP's mobilization, and ends with the
PRP's demobilization at the completion of the RA.
11 Model RA Oversight SOW (6/95)
-------
11
is;.
. .'Ill
Mobilization and demobilization oversight includes ensuring that the PRP's RA constructor and their
subcontractors efficiently perform start-up and closeout field activities per the overall schedule in the CD.
The RA oversight contractor should monitor site preparation and the construction of utilities and temporary
facilities, and ensure that an appropriate work sequence is followed while minimizing site disturbances. A
logical sequence for major mobilization and demobilization activities to be conducted by the RA constructor
may be as follows:
Mobilization
• stage and organize equipment and materials onsite
• prepare exclusion zone, decontamination area, and waste storage/staging area
• construct utilities and temporary facilities
Daily Demobilization
• consolidate and store debris and excess materials
• decontaminate personnel and equipment
• maintain secure waste storage/staging area
Final Demobilization
• dismantle utilities and temporary facilities that are no longer required
• ensure site has minimum disturbances (i.e., remove trash, debris, excess materials)
• properly label waste stored/staged onsite, and ensure that provisions are in-place for its removal
.3.1 Mobilization and Demobilization Oversight
i
.3.1.1 Identify Field Support Equipment/Supplies/Facilities. The contractor may require a field
trailer and related utilities if it is infeasible to share the RA constructor's trailer. Other
support equipment, supplies, or facilities required for performing oversight activities should
be identified in this task.
,,',,,!
.3.1,2 Mobilization Oversight. Mobilization activities to be conducted by the PRP's constructor
include preparing an exclusion zone, staging and organizing onsite equipment, and
constructing utilities and temporary facilities.
(1) Not used - Site Preparation
(2) Installation of Utilities
(a) Install Electric Distribution
(b) Install Telephone/Communication System
(c) Install Water/Sewer/Gas Distribution
(d) Install Fuel Line Distribution
(3) Construction of Temporary Facilities
(a) Construct Decontamination Facilities
(b) Construct Sample or Derived Waste Storage Facility
(c) Construct Field Offices
(d) Construct Mobile Laboratory
(e) Construct Other Temporary Facilities
"i'1."!" . ' ... ij
i
.3.1.3 Demobilization Oversight. Demobilization activities to be conducted by the PRP's
constructor include consolidating and storing materials, decontaminating personnel and
" equipment, and maintaining a secure waste storage/staging area.
(i) Removal of Temporary Facilities
(2) Site Restoration
",: .':.: ' ' „ : , j
.3.2 Perform Field Investigation Oversight. Field activities that require oversight include site
reconnaissance, data acquisition of air, groundwater, surface water, and other environmental media
12
Model RA Oversight SOW (6/95)
-------
samples, as well as the characterization, management and disposal of investigation-derived wastes
(IDW). The contractor shall ensure the proper collection and management of samples acquired by
the PRP, including accurate chain-of-custody (COC) procedures for sample tracking, protective
sample-packing techniques, and proper sample-preservation techniques. Ensure that the PRP
characterizes and disposes of investigation-derived wastes in accordance with local, State and
Federal regulations as specified in the FSP (see the Fact Sheet Guide to Management of
Investigation-Derived Wastes, 9345.3-03FS, January 1992).
The WAM/RPM should specify the expected written and/or photographic documentation to be recorded
in the field. The WAM/RPM also should specify the type of field activity reports expected by the
WAM/RPM, the frequency, and the required distribution (WAM/RPM, State representative, etc.).
.3.2.1 Perform Site Reconnaissance Oversight
(1) Ecological Resources Reconnaissance
(2) Well Inventory
(3) Residential Well Sampling
(4) Land Survey
(5) Topographic Mapping
(6) Field Screening
.3.2.2 Perform Geological Investigations Oversight - Soils and Sediments
.3.2.3 Perform Air Investigations Oversight
.3.2.4 Perform Hydrogeological Investigations Oversight - Groundwater
(1) Well Systems Installation
(2) CLP Sample Collection
1 (3) Screening Sample Collection. A screening sampling event can consist of temporary
sampling points to estimate the approximate distribution and range of contaminant
concentrations. CLP sampling can then be performed after the screening event to
confirm specific concentrations. Screening techniques include temporary piezometers,
well points, and direct push technology (DPT) sampling techniques such as piezocones,
resistivity cones, groundwater samplers, and soil gas samplers.
(4) Tidal Influence Study
(5) Hydraulic Tests (Pump Tests)
(6) Groundwater Elevation Measurement
.3.2.5 Perform Hydrogeological Investigations Oversight - Surface Water
.3.2.6 Perform Waste Investigation Oversight
.3.2.7 Perform Geophysical Investigation Oversight
.3.2.8 Perform Ecological Investigation Oversight
.3.2.9 Perform Contaminated Building Samples Oversight
.3.2.10 Perform Disposal of Investigation-Derived Wastes Oversight
.3.2.11 Prepare Data Acquisition Oversight Reports
13 Model RA Oversight SOW (6/95)
-------
f':! '!
8.4 Analysis of Split Samples
.4.1 Perform Screening-type Laboratory Sample Analysis
The contractor shall request appropriate analytical services to match those being used by the PRP's RA
constructor. Using the same level of analysis will provide the data required to perform an accurate quality
comparison. The contractor should reference the procedures outlined in the User's Guide to the Contract
Laboratory Program, EPA, December 1986. Frequently, the PRP's RA constructor will use EPA Level II
analytical reporting using non-CLP methods for this task; the RA oversight contractor should use the same
level of analysis.
.4.1.1 Analyze Air and Gas Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.2 Analyze Groundwater Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.3 Analyze Surface water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.4 Analyze Soil and Sediment Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.5 Analyze Waste (Gas) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.1.6 Analyze Waste (Liquid) Samples
(1) Organic
(2J Inorganic
(3) Radiochemistry
.4.1.7 Analyze Waste (Solid) Samples
(l| Organic
(2) Inorganic
(3) Radiochemistry
i ji1 i, :;iiii
.4.1.8 Analyze Biota Samples
(1) Organic
Inorganic
Radiochemistry
.4.1.9 Analyze Bioassay Samples
14
Model RA Oversight SOW (6/95)
-------
.4.1.10 Perform Bioaccumulation Studies
.4.2 Perform CLP-type Laboratory Sample Analysis
The contractor shall request appropriate analytical services to match those being used by the PRP's RA
constructor. Using the same level of analysis will provide the data required to perform an accurate quality
comparison. The contractor should reference the procedures outlined in the User's Guide to the Contract
Laboratory Program, EPA, December 1986. Typically, the PRP's RA constructor will be using EPA
Level IV analytical reporting using CLP methods for this task; the RA oversight contractor should use the
same level of analysis.
.4.2.1 Analyze Air/Gas Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.2 Analyze Groundwater Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.3 Analyze Surface water Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.4 Analyze Soil and Sediment Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.5 Analyze Waste (Gas) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.6 Analyze Waste (Liquid) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.7 Analyze Waste (Solid) Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.8 Analyze Biota Samples
(1) Organic
(2) Inorganic
(3) Radiochemistry
.4.2.9 Analyze Bioassay Samples
15 Model RA Oversight SOW (6/95)
-------
I1 ilIT™1''!!!1'*1! lllll'ii'1!1!1!!1!1!1""!1'" I I'!"'1 I1!""1!1'"!!!!!
„'!! hii'l:' ''liPilllll i!!;,1'!'I'll1 HI
r :=:
.4.2.10 Perform Bioaccumulation Studies
j
8.5 Analytical Support and Data Validation of Split Samples
i
The contractor shall collect split (or duplicate) samples of samples collected by the PRP's RA constructor,
and shall arrange for the analysis and validation of those samples. The contractor's split samples are to be
compared to samples collected by the PRP's RA constructor to assess the validity of the RA constructor's
Sampling program. The sample collection, analysis, and validation task begins with reserving sample slots
in the CLP, and ends with the contractor's data validation letter report.
1. Sample collection procedures, analytical methods, and EPA reporting levels for the contractor's split
samples should be consistent with the procedures, methods, and levels being used by the PRP's RA
constructor.
2. For RA oversight purposes, full data validation procedures are usually not necessary. The
WAM/RPM may want to specify the level of data validation required.
3. The WAM/RPM should specify the format for submissions if there are Region-specific or other
requirements.
.5.1 Prepare and Ship Environmental Samples. The contractor shall properly collect and manage split
samples in the field, and arrange for appropriate shipment to the designated laboratory. The
contractor shall follow the procedures specified in the contractor's SAP, FSP, QAPP, and HASP
for proper sample preservation and protective sample packing, and then ship via an overnight carrier
to the designated laboratory.
.5.1.1 Groundwater Samples
.5.1.2 Surface and Subsurface Soil Samples
.5.1.3 Surface water and Sediment Samples
.5.1.4 Air Samples
.5.1.5 Biota Samples
.5.1.6 Other Types of Media Samples
.5.2 Coordinate With Appropriate Sample Management Personnel. The contractor shall arrange
shipment and delivery schedules with the appropriate sample management personnel and provide any
clarification on the data collection procedures that may be required.
.5.3 Implement EPA-Approved Laboratory QA Program. The contractor shall ensure the QA/QC
protocols, as specified in the QAPP, are followed.
.5.4 Provide Sample Management (COC, sample retention, and data storage). The contractor shall
follow accurate COC procedures for sample tracking.
.5.5 Perform Data Validation. The contractor shall perform appropriate data validation to ensure that
the data are accurate and defensible. The contractor shall review the appropriate laboratory data
packages according to the protocols specified in the contractor's RA Oversight Work Plan and
complete the necessary summary tables, validation worksheets, and DQO summary forms. The
contractor shall prepare and submit a data validation letter report within 21 calendar days of receipt
of the analytical results.
-ill 11, •. I
.5.5.1 Review Analysis Results Against Validation Criteria
.5.5.2 Provide Written Documentation of Validation Efforts
16
Model RA Oversight SOW (6/95)
-------
8.6 Data Evaluation of Split Samples
This task involves comparison of the PRP's data that is collected during the RA with data resulting from
the analysis of split samples collected by the contractor during RA oversight. Data evaluation begins with
the receipt of analytical data from the data acquisition task and ends with the submittal of a Data
Evaluation Summary Report. Specifically, the contractor shall compare, evaluate, interpret, and tabulate
data in an appropriate presentation format for final data tables.
1. The WAM/RPM should specify the format for submissions if there are Region-specific or other
requirements.
2. The WAM/RPM should specify that the contractor prepare and submit a Technical Memorandum to
the WAM/RPM if new analytical data needs or significant data problems are identified during the
evaluation.
.6.1 Data Useability Evaluation and Field QA/QC. The contractor shall review the data collected and
the QA/QC protocols to evaluate if the data are appropriate for the intended use.
.6.2 Data Reduction, Tabulation, and Evaluation. The contractor shall evaluate, interpret, and tabulate
data in an appropriate presentation format for analysis. The contractor shall design and set up an
appropriate database for pertinent information collected that will be used to validate the RA. Data
management should be performed according to the contractor's Data Management Plan.
.6.2.1 Evaluate Geological Data - Soils and Sediments
.6.2.2 Evaluate Air Data
.6.2.3 Evaluate Hydrogeological Data - Groundwater
.6.2.4 Evaluate Hydrogeological Data - Surface Water
.6.2.5 Evaluate Waste Data
.6.2.6 Evaluate Geophysical Data
.6.2.7 Evaluate Ecological Data
.6.3 Modeling. The contractor shall perform limited and focused computer modeling of data (e.g., air
monitoring data) to facilitate data evaluation and interpretation.
.6.3.1 Contaminant Fate and Transport
.6.3.2 Water Quality
.6.3.3 Groundwater
.6.3.4 Air
.6.3.5 Other Modeling
.6.4 Develop Data Evaluation Report. The contractor shall evaluate and present results in a Data
Evaluation Summary Report to submit to the WAM/RPM for review and approval. The report will
include a comparison between the contractor's split sample data and the PRP's data, will provide an
assessment of this comparison, and will identify any actions required. After the WAM/RPM's
review, attend a meeting with EPA to discuss data evaluation results and next steps.
17 Model RA Oversight SOW (6/95)
-------
p
8.7 Review of PRP Documents
Task 6.1.1.6 in the WBS is "Review of PRP Plans," which is intended to include the review of upfront,
generic project plans, such as the SAP, FSP, QAPP, and HASP. This task (Task 6.7) is intended to
include the review of updates, amendments, or modifications to the upfront plans, as well as the review of
detailed construction plans, specifications, and related submittals.
!||li;:|fl: i ' ,' I, i i1 Hlll'i,!, !l"'jTi'|i| ' '''' '. ' ''"'' ''' '' '' "':' '''' ' '"' ' "''" " "I1 ' ' i'''! ' " ' '' i1''."!1 'i ' ••'. "ii'1 '' ''I"'!'1 i " ' '•!! . If ' ' i ''I11 .' '
This task involves work efforts to review detailed construction plans and related documents prepared by
the PRP's RA constructor. In addition to the review of project plans (e.g., SAP, FSP, QAPP, HASP)
Under TasO.1.1.6, the RA oversight contractor shall perform reviews as directed by the WAM/RPM.
The following factors are to be considered during the review of PRP submittals:
" ,'• • • Jiw i n'ii'iiK'i '. : '•' i • ,!,''• ii, , " • " ' liii, i ' ' M .1," ' ','Hi ii- .• " ifli'i"!* ,' , ij j H ' i, • i1' ' f!
• Technical requirements of the ROD, Unilateral Administrative Order (UAO), Administrative Order
of Consent (AOC), CD, and compliance with ARARs
• Standard professional engineering practices
• Applicable statutes, EPA policies, directives and regulations
• Spot checking design calculations to assess accuracy and quality of design activities
• Examination of planning and construction schedules for meeting project completion goals
""'.',,, . , ,' ,'""" . ","„! . ' . „ . . . "I j , ,
The contractor shall review the planning, construction, and implementation documentation as directed by
the WAM/RPM to ensure professional quality, technical accuracy, and compliance with the ROD and CD,
CERCLA guidance, and ARARs. Specific documents to be reviewed include the PRP's RA Work Plan,
Construction QAPP (CQAP), cut sheets, material lists, equipment lists and specifications, operation and
maintenance plans, and updates or modifications to the upfront project plans (e.g., SAP, FSP, QAPP,
HASP).
: , • ' ••'• '::;; : ,. • • ' ]• ' I " '-
.7.1 Not used - Review of PRP Remedial Design Documents
Task 6.7.1 hi the WBS is "Review PRP Remedial Design Documents." Because RD documents should be
provided to the contractor to review under Task 6.1.1.3, this task is not likely to be required.
.7.2 Review of PRP Remedial Action Documents. The contractor's review of PRP documents should be
focused on the technical and engineering aspects of the detailed construction-related submittals.
Letter reports shall be submitted upon the completion of each review by the contractor within 21
calendar (lays of the start of the review, identifying specific issues and suggested revision or other
action.
.7.2.1 Site Management for Construction
.7.2.2 PRP's Remedial Action Work Plan
.7.2,3 O&M Manual
,7.2.4 Remedial Action Report
.7.2.5 As-build Drawings
.7.2 6 Construction QAPP
.7.2.7 Construction QA Reports
18
Model RA Oversight SOW (6/95)
iii, <; ,i . , iitiii .In; i ivihinlii! IJl^ ; iiiiiiiii ,! i iiui ,.i Si ,.-nt Jii: iL a . i:;n i,.; i'riiiiviilfait 1,;. i. ,.:,,iiK i .,,1. iliiiiil'ii.^ liiiiik '.:;; :, ,iili l,i.:iBii.i,:, illiiliili.J;1,,.. iaiiii!,i,i,i.; H. i; njlii ..i,, lai liij I iJlliililir liliiit ,...ifc ill I
-------
8.8 Remedial Action Oversight
This task is intended to include general field oversight of the PRP's RA constructor during construction and
implementation of the RA. This task is separate from other field tasks to be performed under the SOW
(e.g., mobilization/demobilization oversight and data collection oversight). Field observations, recordings,
photographs, and other compliance-related oversight activities are to be performed under this task.
This task includes work efforts to provide technical field oversight of PRP RA activities to ensure that
construction and implementation is performed in accordance with RD plans, specifications, and the CD.
Oversight activities include observing and recording compliance with specific aspects of project plans and
design documents, photographing major field activities, maintaining a daily field notebook, and providing
reports to the WAM/RPM. The contractor's Oversight Official should coordinate with the PRP's
Independent QA Team and communicate and report to the WAM/RPM according to an agreed-upon
schedule.
.8.1 On-site Oversight of Construction
The WAM/RPM must define the appropriate level of oversight needed. For example, will oversight be
continuous over a long period or are short visits appropriate, will overnight stays be required, and is one
person adequate to oversee the whole RA?
.8.2 Periodic RA Oversight Reports
The appropriate frequency and level of detail must be specified (i.e., whether the reports are to be weekly
or periodic, whether the content is to be short and informal or very detailed).
.8.3 Participation in Remedial Action Meetings
.8.3.1 EPA Regional Office Meeting
.8.3.2 On-site Meetings
8.9 Technical Meeting Support
This task includes work efforts related to attendance at and documentation of meetings with EPA, PRPs,
PRP constructors and contractors, and state and local regulatory agencies. The contractor shall attend
meetings and provide documentation of meeting results. Within 7 days after a meeting, the contractor will
submit to the WAM/RPM a written report summarizing the meeting results. Meetings may be scheduled
to coincide with the following specific milestones during the RA:
• Review of PRP RA Work Plan
• PRP preconstruction conference
• Technical progress meetings between the PRP constructor and the Independent QA Team
• Kick-off, progress, and completion of any confirmatory (split) sampling
• Prefinal/final inspections
19 Model RA Oversight SOW (6/95)
-------
8.10 Work Assignment Closeout
:::,: ', . .. . , . . ; I . . ' ,; ;
, „ ' " , |j
.10.1 Retupi Documents to Government
ill ' '' I''1 , ! ' I" 'I'' II !, ,11 '
.10.2 Duplicate, Distribute, and Store Files
• '.' •:-. ,' ': " ' . ' " . :".' ',',':!
.10.3 Archive Files '
;;':" i; "••' • " ' : ' • • ' ' ' '• ';' ' ' ' | ' ••'• '" '
.10.4 Prepare Microfiche, Microfilm, and/or Optical Disk
,10.5 Prepare Closeout Report. The contractor shall include a breakdown on disk of final costs and Level
of Effort (by P-level) hi the same detail and format as the Work Breakdown Structure (Attachment
'"
20
Model RA Oversight SOW (6/95)
-------
ATTACHMENT 1
SUMMARY OF MAJOR DELIVERABLES FOR THE REMEDIAL ACTION OVERSIGHT AT
(SITE)
TASK
1.1.2
1.1.5
1.1.5
1.1.6
1.1.6
1.2.2
1.2.2
1.2.3
1.2.3
1.3.1
1.3.2
2.1.2
2.1.2
DELIVERABLE
Site Visit Letter Report
Draft RA Oversight
Work Plan
Final RA Oversight
Work Plan
Draft Technical
Memoranda Summarizing
Review of Upfront PRP
Plans
Final Technical
Memoranda Summarizing
Review of Upfront PRP
Plans
Draft Health and Safety
Plan (HASP)
Final HASP
Draft Sampling and
Analysis Plan (SAP)
Final SAP
Status Reports
Technical Memoranda
Summarizing Meeting
Results, Project Status,
and Non-Compliance
Issues
Draft Community
Relations Plan (CRP)
Final CRP
REF
NO.
NO. OF
COPIES
3
3
3
3
3
3
3
3
3
3
3
3
3
DUE DATE
(Calendar Days)
10 days after site visit
45 days after initiation
of work assignment
(WA)
15 days after receipt
of EPA comments
30 days after initiation
ofWA
10 days after receipt
of EPA comments
21 days after approval
of RA Work Plan
10 days after receipt
of EPA comments
21 days after approval
of RA Work Plan
10 days after receipt
of EPA comments
Monthly and as
directed by WAM
As required
14 days after
completion of
community interviews
7 days after receipt of
EPA comments
EPA REVIEW
PERIOD
7 days after
receipt of report
30 days after
receipt of work
plan
NA
14 days after
receipt of
memoranda
NA
14 days after
receipt of plan
NA
14 days after
receipt of plan
NA
NA
NA
7 days after
receipt of draft
CRP
NA
21
Model RA Oversight SOW (6/95)
-------
5.5
6.4
6.4
7.2
7.2
8.2
8.2
9.0
9.0
Data Validation Letter
Report
Draft Data Evaluation
Summary Report
Final Data Evaluation
Summary Report
Draft Letter Report
Summarizing Review of
PRP RA Documents
Final Letter Report
Summarizing Review of
PRP RA Documents
Draft RA Oversight
Reports
Final RA Oversight
Reports
Draft Technical
Memoranda Summarizing
Meeting Results
Final Technical
Memoranda Summarizing
Meeting Results
3
3
3
3
3
3
3
3
3
21 days after receipt
of analytical results
from laboratory
45 days after receipt
of analytical results
from laboratory
7 days after receipt of
EPA comments
21 days after receipt
of PRP document
from EPA
10 days after receipt
of EPA comments
As required
7 days after receipt of
EPA comments
7 days after attendance
at meeting(s)
7 days after receipt of
EPA comments
NA
14 days after
receipt of report
NA
14 days after
receipt of letter
report
NA
As required
NA
10 days after
receipt of
memoranda
NA
22
Model RA Oversight SOW (6/95)
jiatiliis •Hi ill ..... : it; , , msi ...... liji iii.:,.-!] ..... laulS ililllill ..... Jillll,ii.ii, ; ..... lilii^^ ....... I; .......... liilinni ' . ...... IliiliHiu -»,.- "ifv;.i! in ...... :ii.. 'i ....... iiiiiiii.'il ..... Hi ........ In. .......... i'*l ..... lir iiiiliiillii - ....... 11181*- .Bias; ...... maitm i j.
..... i ..... i> ..... IM,I ai.i ...... i . ;• .................... • ....... i.i.1, ,„ i. ; ..... ..... ................ .1 ..... i .................................. i. ......
-------
Attachment 2
Work Breakdown Structure (WBS) for
Remedial Action Oversight
8.0 Remedial Action Oversight
.01 Project Planning and Support
.01 Project Planning
.01 Attend Scoping Meeting
.02 Conduct Site Visit
.03 Evaluate Existing Information
.04 Develop Technical Project Goals & Objectives
.01 Not Used - Develop Conceptual Site Model
.02 Preliminary ID of Project Requirements
.01 Data Needs & DQOs
.02 Not Used - RA Objectives & Potential Alternatives
.05 Work Plan Development
.01 Draft Work Plan Development
.01 Develop Narrative
.02 Develop Cost Estimate
.03 Internal QA & Submission
.02 Final Work Plan Preparation
.01 Attend Negotiation Meeting
.02 Modify Draft Work Plan/Cost Estimate
.03 Internal QA & Submission
.06 Review of PRP Plans
.01 Review PRP Site Management Plan
.01 Review PRP Pollution Control and Mitigation Plan
.02 Review PRP Transportation and Disposal Plan
.02 Review PRP Health and Safety Plan
.03 Review PRP Sampling & Analysis Plan
.01 Review PRP Quality Assurance Project Plan
.02 Review PRP Field Sampling Plan
.03 Review PRP Data Management Plan
.04 Other PRP Plan(s)
.02 Preparation of Site Specific Plans
.01 Not used
.02 Develop Health & Safety Plan
.03 Sampling & Analysis Plan (Chemical Data Acquisition Plan)
.01 Quality Assurance Project Plan
.02 Field Sampling Plan
.03 Data Management Plan
.04 Other Plan(s)
.03 Project Management
.01 Prepare Periodic Status Reports
.01 Document Cost and Performance Status
.02 Prepare/Submit Invoices
.02 Meeting Participation/Routine Communications
.03 Not Used - Maintain Cost/Schedule Control System
.04 Not Used - Perform Value Engineering
.05 Not Used - Perform Engineering Network Analysis
.06 Not Used - Manage, Track, and Report Equipment Status
.07 Work Assignment Closeout
.04 Subcontract Procurement/Support Activities
.01 ID'and Procurement of Subcontractors
23 Model RA Oversight SOW (6/95)
-------
.01 Not Used - Drilling Subcontractor
.02 Not Used - Surveying Subcontractor
.03 Not Used - Geophysical Subcontractor
.04 Not Used - Site Preparation Subcontractor
.05 Analytical Services Subcontractor(s)
.06 Not Used - Waste Disposal Subcontractor
.07 Not Used - Treatability Subcontractor(s)
.08 Other(s)
.02 Contractor QA/QC Program
.03 Perform Subcontract Management
i >} ' ' , i :,, ' !'#|:! ' , fl- , ' .
.02 Community Relations
.01 Community Relations Plan (CRP) Development
.61 Conduct Community Interviews
.02 Update CRP
.01 Draft CRP
.02 Final CRP
.02 Prepare Fact Sheets
.03 Public Hearing, Meetings, & Availability Support
.01 Technical Support
.02 Logistical & Presentation Support
.03 Public Notice Support (writing, or placement of)
.04 Maintain Information Repository/lVfailing List
.03 Data Acquisition Oversight
.01 Mobilization/Demobilization Oversight
.01 ID Field Support Equipment/Supplies/Facilities
.6| Mobilization
.01 Not Used - Site Preparation
.02 Installation of Utilities
.01 Install Electrical Distribution
.02 Install Telephone/Communication System(s)
.03 Install Water/Sewer/Gas Distribution
.04 Install Fuel Line Distribution
.03 Construction of Temporary Facilities
.01 Construct Decontamination Facilities
.02 Construct Sample/Derived Waste Storage Facility
.03 Construct Field Offices
.04 Construct Mobile Laboratory
.05 Construct Other Temporary Facilities
.03 Demobilization Oversight
.01 Removal of Temporary Facilities
.02 Site Restoration
.02 Field Investigation Oversight
.01 Site Reconnaissance Oversight
.01 Ecological Resources Reconnaissance
.02 Well Inventory
.03 Residential Well Sampling
.04 Land Survey
.05 Topographic Mapping
.06 Field Screening
.02 Geological Investigations (Soils/Sediments) Oversight
.03 Air Investigations Oversight
.04 Hydrogeological Investigations Oversight - Groundwater
.01 Well Systems Installation
.02 CLP Sample Collection
.03 Screening Sample Collection
24 Model RA Oversight SOW (6/95)
i
-------
.04 Tidal Influence Study
.05 Hydraulic Tests (Pump Tests)
.06 Groundwater Elevation Measurement
.05 Hydrogeological Investigations Oversight — Surface Water
.06 Waste Investigation Oversight
.07 Geophysical Investigation Oversight
.08 Ecological Investigation Oversight
.09 Contaminated Building Samples Oversight
. 10 Disposal of Investigation-Derived Waste Oversight
. 11 Prepare Data Acquisition Oversight Reports
.04 Sample Analysis of Splits
.01 Screening Type Laboratory Sample Analysis
.01 Analyze Air/Gas Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.02 Analyze Groundwater Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.03 Analyze Surface Water Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.04 Analyze Soil/Sediment Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.05 Analyze Waste (Gas) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.06 Analyze Waste (Liquid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.07 Analyze Waste (Solid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.08 Analyze Biota Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.09 Analyze Bioassay Samples
. 10 Perform Bioaccumulation Studies
.02 CLP-Type Laboratory Sample Analysis
.01 Analyze Air/Gas Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.02 Analyze Groundwater Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.03 Analyze Surface Water Samples
.01 Organic
.02 Inorganic
25 Model RA Oversight SOW (6/95)
-------
.03 Radiochemistry
.04 Analyze Soil/Sediment Samples
.01 Organic
.02 Inorganic
> ;;j ilj .03 Radiochemistry
.05 Analyze Waste (Gas) Samples
•v; :J .01 Organic' " " '
.02 Inorganic
.03 Radiochemistry
.o| Analyze Waste (Liquid) Samples
jp: "s! .01 Organic'
.02 Inorganic
,03 Radipchemistry
.6? Analyze Waste (Solid) Samples
.01 Organic
.02 Inorganic
.03 Radiochemistry
.08 Analyze Biota Samples
,01 Organic
.02 Inprganic
.03 Radiochemistry
.09 Analyze Bioassay Samples
.10 Perform Bioaccumulation Studies
.05 Analytical Support and Data Validation of Split Samples
.01 Prepare and Ship Environmental Samples
.01 Groundwater Samples
.02 Surface and Subsurface Soil Samples
.03 Surface Water & Sediment Samples
.04 Air Samples
.05 Biota Samples
.06 Other types of media sampling and screening
.02 Coordinate with appropriate Sample Management personnel
.03 Implement EPA-approved Laboratory QA program
.04 Provide Sample Management (Cham of Custody, sample retention, & data storage)
.05 Pe|form Data Validation
.01 Review analysis results against validation criteria
.02 Provide written documentation of validation efforts
' 1 '
.06 Data Evaluation of Split Samples
.01 Data Useability Evaluation/Field QA/QC
.02 Data Reduction, Tabulation and Evaluation
.01 Evaluate Geological Data (Soils/Sediments)
.02 Evaluate Air Data
.03 Evaluate Hydrogeological Data—Groundwater
.04 Evaluate Hydrogeological Data—Surface Water
.05 Evaluate Waste Data
.06 Evaluate Geophysical Data
.07 Evaluate Ecological Data
.03 Modeling
,01 Contaminant Fate and Transport
,02 Water Quality
.03 Groundwater
'' -' .04 Air
.05 Other Modeling
.04 Develop Data Evaluation Report
,07 Review of PRP Documents
.01 Not Used - Review PRP Remedial Design Documents
26 Model RA Oversight SOW (6/95)
-------
.01 Not Used - Review Preliminary Design
.02 Not Used - Review Intermediate Design
.03 Not Used - Review Pre-Final/Final Design
.02 Review PRP Remedial Action Documents
.01 Site Management Plan for Construction
.02 Remedial Action Work Plan
.03 O&M Manual
.04 Remedial Action Report
.05 As Built Drawings
.06 Construction QAPP
.07 Construction QA Reports
.08 Remedial Action Oversight
.01 On-Site Oversight of Construction
.02 Periodic RA Oversight Reports
.03 Participation in Remedial Action Meetings
.01 Region Office Meetings
.02 On-Site Meetings
.09 Technical Meeting Support
. 10 Work Assignment Close Out
.01 Return Documents to Government
.02 File Duplication/Distribution/Storage
.03 File Archiving
.04 Microfiche/Microfilm/Optical Disk
.05 Prepare Closeout Report
27 Model RA Oversight SOW (6/95)
-------
Attachment 3
Regulations and Guidance Documents
The following list, although not comprehensive, comprises many of the regulations and guidance documents that
apply to the RD process:
1. American National Standards Practices for Respiratory Protection. American National Standards Institute
Z88.2-1980, March 11, 1981.
2. ARCS Construction Contract Modification Procedures September 89, OERR Directive 9355.5-01/FS.
3. CERCLA Compliance with Other Laws Manual, Two Volumes, U.S. EPA, Office of Emergency and
Remedial Response, August 1988 (DRAFT), OSWER Directive No. 9234.1-01 and -02.
4. Community Relations in Superfund — A Handbook, U.S. EPA, Office of Emergency and Remedial
Response, June 1988, OSWER Directive No. 9230.0-3B.
5. A Compendium of Superfund Field Operations Methods, Two Volumes, U.S. EPA, Office of Emergency
and Remedial Response, EPA/540/P-87/001a, August 1987, OSWER Directive No. 9355.0-14.
6. Construction Quality Assurance for Hazardous Waste Land Disposal Facilities, U.S. EPA, Office of Solid
Waste and Emergency Response, October 1986, OSWER Directive No. 9472.003.
7, Contractor Requirements for the Control and Security of RCRA Confidential Business Information, March
1984.
8. Data Quality Objectives for Remedial Response Activities, U.S. EPA, Office of Emergency and Remedial
Response and Office of Waste Programs Enforcement, EPA/540/G-87/003, March 1987, OSWER
Directive No. 9335.0-7B.
9. Engineering Support Branch Standard Operating Procedures and Quality Assurance Manual, U.S. EPA
Region IV, Environmental Services Division, April 1, 1986 (revised periodically).
10. EPA NEIC Policies and Procedures Manual, EPA-330/9-78-001-R, May 1978, revised November 1984.
11. Federal Acquisition Regulation, Washington, DC: U.S. Government Printing Office (revised periodically).
12. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final,
U.S. EPA, Office of Emergency and Remedial Response, October 1988, OSWER Directive NO.
*' 9355.3"-01. "
13. Guidance on EPA Oversight of Remedial Designs and Remedial Actions Performed by Potential
Responsible Parties, U.S. EPA Office of Emergency and Remedial Response, EPA/540/G-90/001, April
1990.
14. Guidance on Expediting Remedial Design and Remedial Actions, EPA/540/G-90/006, August 1990.
15~ Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites, U.S. EPA Office of
Emergency and Remedial Response (DRAFT), OSWER Directive No. 9283.1-2.
16'. Guide for Conducting Treatability Studies Under CERCLA, U.S. EPA, Office of Emergency and Remedial
Response, Prepublication version.
177" Guide to Management of Investigation-Derived Wastes, U.S. EPA, Office of Solid Waste and Emergency
Response, Publication 9345.3-03FS, January 1992.
18^ Guidelines and Specifications for Preparing Quality Assurance Project Plans, U.S. EPA, Office of Research
and Development^ Cincinnati, OH, QAMS-004/80, December 29, 1980.
19. Health and Safety Requirements of Employees Employed in Field Activities, U.S. EPA, Office of
Emergency and Remedial Response, July 12, 1982, EPA Order No. 1440.2.
20. Interim Guidance on Compliance with Applicable of Relevant and Appropriate Requirements, U.S. EPA,
Office of Emergency and Remedial Response, July 9, 1987, OSWER Directive No. 9234.0-05.
21. Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans, U.S. EPA, Office of
""Emergencyand"lemedial Response, QAMS-005/80, December 1980.
22" Methods for Evaluating the Attainment of Cleanup Standards: Vol. 1, Soils and Solid Media, February
1989, EPA 23/02-89-042; vol. 2, Ground water (Jul 1992).
23. National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule, Federal Register 40 CFR
Part 300, March 8, 1990.
24. NIOSH Manual of Analytical Methods, 2nd edition. Volumes I-VII for the 3rd edition, Volumes I and II,
National Institute of Occupational Safety and Health.
25. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, National Institute of
Occupational Safety and Health/Occupational Health and Safety Administration/United States Coast
Guard/Environmental Protection Agency, October 1985.
28 Model RA Oversight SOW (6/95)
-------
26. Permits and Permit Equivalency Processes for CERCLA On-Site Response Actions, February 19, 1992
OSWER Directive 9355.7-03.
27. Procedure for Planning and Implementing Off-Site Response Actions, Federal Register, Volume 50,
Number 214, November 1985, pages 45933-45937.
28. Procedures for Completion and Deletion of NPL Sites, U.S. EPA, Office of Emergency and Remedial
Response, April 1989, OSWER Directive No. 9320.2-3A.
29. Quality in the Constructed Project: A Guideline for Owners, Designers and Constructors, Volume 1,
Preliminary Edition for Trial Use and Comment, American Society of Civil Engineers, May 1988.
30. Remedial Design/Remedial Action (RD/RA) Handbook, U.S. EPA, Office of Solid Waste and Emergency
Response (OSWER) 9355.0-04B, EPA 540/R-95/059, June 1995.
31. Revision of Policy Regarding Superfund Project Assignments, OSWER Directive No. 9242.3-08,
December 10, 1991. [Guidance, p. 2-2]
32. Scoping the Remedial Design (Fact Sheet), February 1995, OSWER Publ. 9355-5-21 FS.
33. Standard Operating Safety Guides, U.S. EPA, Office of Emergency and Remedial Response, November
1984.
34. Standards for the Construction Industry, Code of Federal Regulations, Title 29, Part 1926, Occupational
Health and Safety Administration.
35. Standards for General Industry, Code of Federal Regulations, Title 29, Part 1910, Occupational Health and
Safety Administration.
36. Structure and Components of 5-Year Reviews, OSWER Directive No. 9355.7-02, May 23, 1991.
[Guidance, p. 3-5]
37. Superfund Guidance on EPA Oversight of Remedial Designs and Remedial Actions Performed by
Potentially Responsible Parties, April 1990, EPA/540/G-90/001.
38. Superfund Remedial Design and Remedial Action Guidance, U.S. EPA, Office of Emergency and Remedial
Response, June 1986, OSWER Directive No. 9355.0-4A.
39. Superfund Response Action Contracts (Fact Sheet), May 1993, OSWER Publ. 9242.2-08FS.
40. TLVs-Threshold Limit Values and Biological Exposure Indices for 1987-88, American Conference of
Governmental Industrial Hygienists.
41. Treatability Studies Under CERCLA, Final. U.S. EPA, Office of Solid Waste and Emergency Response,
EPA/540/R-92/071a, October 1992.
42. USEPA Contract Laboratory Program Statement of Work for Inorganic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, July 1988.
43. USEPA Contract Laboratory Program Statement of Work for Organic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, February 1988.
44. User's Guide to the EPA Contract Laboratory Program, U.S. EPA, Sample Management Office, August
1982.
45. Value Engineering (Fact Sheet), U.S. EPA, Office of Solid Waste and Emergency Response, Publication
9355.5-03FS, May 1990.
29 Model RA Oversight SOW (6/95)
-------
AttachmeiQt 4
TRANSMITTAL OF DOCUMENTS FOR ACCEPTANCE BY EPA
TO:
SUBTASK NO.
DATE:
FROM:
DELIVERABLE
NO. OF
COPIES
TRANSMrrrAL NO.
1 1 New Transmittal
1 1 Resubmittal of
Transmittal No.
REMARKS
ACCEPTANCE ACTION
DOCUMENTS FOUND ACCEPTABLE (LIST BY SUBTASK NO.)
NAME/TITLE/SIGNATURE OF REVIEWER
DATE
-------
Attachment 5
TRANSMITTAL REGISTER
PROJECT TITLE AND LOCATION
Subtask No.
DELIVERABLE
•S J
d §•
Z u
«> a
3 rt
Q Q
CONTRACT NO.
Transmittal
No.
"8
S .>
c3 D
Q 8
OS
Date Comments
Sent to
Contractor
WORK ASSIGNMENT NO.
< | &
w §"Q
REMARKS
-------
! i I !! I H i
-------
Appendix F
"RD/RA Fact Sheets and Other Guidance
*Fact sheets to be added by the RPMfor reference.
-------
; :i 'at
-------
Suggested RD/RA Fact Sheets
"ARCS Construction Contract Modification Procedures"
OSWER Directive 9355.5-01/FS (September 1989)
"Emergency Responder Agreements for Fund-Lead RAs"
OSWER Directive 9285.6-08/FS (March 1994)
"EPA Oversight of Remedial Designs and Remedial Actions Performed by PRPs"
OSWER Directive 9355.5-01/FS (April 1990)
"EPA/USACE Payment Process: Direct Cite/Revised Reimbursement Methods"
OSWER Directive 9355.5-14/FS (May 1990)
"Expediting Remedial Construction"
OSWER Directive 9355.5-02/FS (October 1989)
"Guide to Addressing Pre-ROD and Post-ROD Changes"
OSWER Directive 9355.3-02/FS (April 1991)
"Guide to Discharging CERCLA Aqueous Wastes to Publicly Owned Treatment Works (POTWs)"
OSWER Directive 9330.2-13/FS (March 1991)
"Guide to Management of Investigation-Derived Wastes"
OSWER Directive 9345.3-02/FS (May 1991)
"Health and Safety Roles and Responsibilities at Remedial Sites"
OSWER Directive 9285.1-02/FS (July 1991)
"Notification of Out-of-State Shipment of Superfund Site Wastes"
OSWER Directive 9330.2-07/FS (May 1991)
"Overview of Off-Site Rule for OSCs and RPMs"
OSWER Directive 9834.11/FS (September 1993)
"Procedure for Use of USAGE Preplaced Contracts to Expedite Superfund Cleanup Tasks"
OSWER Directive 9355.5-05/FS (April 1994)
"Public Awareness Signs at Superfund Sites"
OSWER Directive 9375.5-10/FS (October 1990)
"Real Estate Acquisition Procedures for USAGE Projects"
OSWER Directive 9355.5-01/FS (February 1990)
"Remedial Action Report"
OSWER Directive 9355.0-39/FS (June 1992)
"Scoping the Remedial Design"
OSWER Directive 9355.5-21/FS (March 1995)
"Value Engineering"
OSWER Directive 9355.5-03/FS (May 1990)
F-1
-------
, iliii -
-------
Appendk G
*State-Lead
^Materials to be added by the RPM as developed.
-------
-------
Appendk H
* Enforcement-Lead
^Materials to be added by the RPM as developed.
-------
-------
Appendk I
* Operations and Maintenance
*Materials to be added by the RPM as developed.
-------
------- |