&EPA
United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington DC 20460
EPA/540/G-87/001
(OSWER Directive 9355.1-1)
December 1986
Superfund
Superfund
Fed era I-Lead
Remedial Project
Management
Handbook
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PROPERTY OF THE
OFFICE OF SUPERFUND
EPA/540/G-87/001
(OSWER Directive 9355.1-1)
December 1986
SUPERFUND FEDERAL-LEAD
REMEDIAL PROJECT MANAGEMENT
HANDBOOK
DECEMBER 1986
OSWER DIRECTIVE
9355.1-1
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Notice
This document has been reviewed in accordance with U.S. Environmental Protection
Agency policy and approved for publication. Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.
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PROJECT COORDINATOR'S PREFACE
The Superfund Federal-Lead Remedial Project Management Handbook is intended
to serve three general purposes. First, the handbook presents the various actions and
deliverables that comprise the Federal-lead remedial project, and then it defines the
roles and responsibilities of the Remedial Project Manager (RPM) in accomplishing
those actions and deliverables. Second, the handbook serves as a pathfinder to guide
the RPM to the various resources available for support of the remedial project
management function. Finally, the handbook introduces the RPM to some of the
fundamental concepts of project management in order to aid the RPM in planning,
monitoring, controlling, and directing projects. The handbook should be useful to both
new and experienced RPMs as well as supervisory personnel and others involved with
Superfund sites.
The handbook presents the various actions and deliverables that comprise the
remedial process from initial project planning through project closeout and National
Priorities List (NPL) deletion. These actions and deliverables are shown in Exhibit 1-1 in
an order that represents their relative sequence in the project. Presenting project
components in this manner allows the RPM to find his/her position in the project and
look ahead to next events. The objective is to promote a proactive management style of
anticipating and resolving problems before they adversely impact project cost, schedule,
or technical quality. The handbook also defines the roles and responsibilities of the
RPM relative to other project participants such as the States, U.S. Army Corps of
Engineers, EPA contractors, other EPA program offices, and other agencies.
Project management can be defined as the bringing together of resources
according to a plan in order to achieve an objective (usually specified in terms of
technical quality or cost and schedule performance). The RPM has an array of
resources available to accomplish the project objectives: guidance documents, in-
house personnel, and contractor support. In serving its pathfinder function, the
handbook narrative directs the RPM to more detailed discussions in relevant guidance
documents and references, suggests areas where in-house personnel may be available
for review and consultation purposes, and describes the mechanics by which contractor
or other agency resources are accessed.
The handbook discusses in general terms some of the fundamental concepts of
project management that are readily transferrable to hazardous waste site remedial
project management. Three important management functions (planning, monitoring,
and control) are described in some detail. Also discussed are the RPM's oversight
functions (directing, coordinating, and communicating). It is anticipated that this
introduction to the concepts of project management will enhance the development of
RPMs as managers.
The Superfund Amendments and Reauthorization Act of 1986 (SARA) will cause
some changes in the way the remedial program is managed. These changes have
been reflected to a limited extent in this edition of the handbook. The reader is
encouraged to study the new statute and to look for a series of memoranda on SARA
from Headquarters. To facilitate a future revision, we are requesting that the users of
this edition provide comments as they arise which can then be incorporated into the
revised edition. In this way, the handbook is put through an extended "road test," and
the usefulness of the handbook is enhanced. It is our hope that the handbook, along
with its State-lead counterpart, will become a key document in the RPM's reference
library.
iii
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TABLE OF CONTENTS
PAGE
LIST OF EXHIBITS vi
LIST OF APPENDICES vii
LIST OF ACRONYMS viii
1. INTRODUCTION 1-1
2. PROJECT MANAGEMENT CONCEPTS
2.1 General Project Management Functions 2-1
2.2 Planning, Monitoring, and Control 2-3
2.3 Directing, Coordinating, and Communicating 2-11
3. INITIAL PROJECT PLANNING AND START-UP ACTIVITIES
3.1 Development of a Project Plan 3-1
3.2 Activities Required Before Starting RI/FS 3-9
3.3 Remedial Investigation Scoping and Development of General
Response Objectives 3-16
3.4 Procedures for Issuing Work Assignments to REM Contractor 3-18
4. REMEDIAL INVESTIGATION/FEASIBILITY STUDY
4.1 Ongoing Project Management Activities 4-1
4.2 Site Characterization 4-8
4.3 Alternatives Screening and Evaluation 4-11
4.4 Review and Approval of RI/FS Report(s) 4-14
4.5 RI/FS Closeout 4-14
5. RECORD OF DECISION AND TRANSITION TO DESIGN
5.1 Ongoing Project Management Activities 5-3
5.2 ROD Process 5-5
5.3 Transition to Design 5-10
6. REMEDIAL DESIGN
6.1 Ongoing Project Management Activities 6-1
6.2 Remedial Design Process 6-6
7. REMEDIAL ACTION
7.1 Ongoing Project Management Activities 7-1
7.2 Procurement of RA Contractor 7-4
7.3 Construction Monitoring and Inspections 7-4
7.4 Review of Progress Reports 7-4
7.5 Remedial Action Completion and Acceptance 7-5
7.6 Transition to Operation and Maintenance 7-6
8. PROJECT CLOSEOUT
8.1 NPL Deletion 8-1
8.2 Operation and Maintenance 8-3
8.3 Project Closeout 8-6
APPENDICES
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LIST OF EXHIBITS
EXHIBIT
NUMBER PAGE
1-1 Remedial Site Chronology (Federal Lead) 1-4
2-1 Remedial Process - Historical Timeframes 2-2
2-2 Sequence of Performance of Project Management Functions 2-4
2-3 Scheduling Techniques (Sample) 2-6
3-1 Initial Project Planning and Start-up Activities 3-2
3-2 Project Plan Outline 3-5
3-3 Project Plan Interface with the Remedial Process 3-6
3-4 Project Planning, Monitoring, and Control Cycle 3-7
3-5 Initial Activities 3-10
3-6 Development and Issuance of the Work Assignment Package 3-20
3-7 Estimates of Labor Hours Required to Complete
Interim Work Assignment Tasks for Simple, Moderate,
and Complex Sites 3-22
3-8 Completion of Interim Work Assignment Activities 3-24
3-9 Approval and Implementation of the Contractor Work Plan 3-29
4-1 Remedial Investigation/Feasibility Study (RI/FS) 4-2
4-2 Work Assignment Amendment Procedures 4-5
5-1 Record of Decision (ROD) and Transition to Design 5-2
5-2 The ROD Process 5-6
5-3 Record of Decision Remedial Alternative Selection 5-8
6-1 Remedial Design (RD) 6-2
6-2 Federal-Lead Remedial Design Activities 6-3
6-3 Suggested Outline for Pre-Design Report 6-8
7-1 Remedial Action (RA) 7-2
8-1 Project Closeout 8-2
8-2 Operation and Maintenance 8-4
VI
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LIST OF APPENDICES
APPENDIX
A Example Project Plan
B Work Assignment Procedures for Remedial Contracts
C Names and Telephone Numbers of REM Contracting Officers and Project Officers
and Federal-Lead Regional Coordinators
D Example Interim Work Assignment SOW, Blank Procurement
Request/Requisition, Work Assignment Completion Report
E Sample USAGE Work Assignments, and Interagency Agreements
F ROD Materials: Responsiveness Summary and
ROD Briefing Materials
VII
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LIST OF ACRONYMS
AA/OSWER - Assistant Administrator for the Office of Solid Waste
and Emergency Response
A/E - Architectural/Engineering
ARARs - Applicable or Relevant and Appropriate Federal or State Standards,
Requirements, Criteria, or Limitations
ATSDR - Agency for Toxic Substances and Disease Registry
CA - Cooperative Agreement
CBD - Commerce Business Daily
CERCLA - Comprehensive Environmental Response, Compensation and
Liability Act
CERCLIS - CERCLA Information System
CFR - Code of Federal Regulations
CLP - Contract Laboratory Program
CO - Contracting Officer (HO)
CPM - Critical Path Method
CRP - Community Relations Plan
EDO - Enforcement Decision Document
EE/CA - Engineering Evaluation/Cost Analysis
EO - Executive Order
EPA - Environmental Protection Agency
ERA - Expedited Response Action
ERRIS - Emergency and Remedial Response Information System
ERT - Environmental Response Team
ESD - Environmental Services Division
FCC - Fiscal Control Center
FMS - Financial Management System
FS - Feasibility Study
FY - Fiscal Year
GAD - Grants Administration Division
GAO - General Accounting Office
GAB - Grants Administration Branch
HQ - EPA Headquarters
MRS - Hazard Ranking System
HRSD - Hazardous Response Support Division
HSCD - Hazardous Site Control Division
IAG - Inter-Agency Agreement
IFB - Invitation for Bids
IG - Inspector General
IRM - Initial Remedial Measure
LOE - Level of Effort
MBE - Minority Business Enterprise
MOA - Memorandum of Agreement
MRD - Missouri River Division
MSCA - Multi-Site Cooperative Agreement
NCP - National Oil and Hazardous Substances Pollution
Contingency Plan (40 CFR 300)
NDD - Negotiations Decision Document
NEIC - National Enforcement Information Center
NPL - National Priorities List
OECM - Office of Enforcement and Compliance Monitoring
VIII
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LIST OF ACRONYMS
(Continued)
OERR
OGC
OLEP
O&M
OMB
ORC
OWPE
PA
PO
PRP
QAPP
PTS
RA
RC
RCRA
RD
REM
RFP
RFQ
Rl
RI/FS
ROD
RPM
RSCRC
RSPO
SARA
SCAP
SI
SMP
SOW
SPO
SPOC
SRCB
SSC
SSP
TAT
USAGE
USACE-MRD
WACR
WA
WBE
Office of Emergency and Remedial Response
Office of General Counsel
Office of Legal and Enforcement Policy
Operation and Maintenance
Office of Management and Budget
Office of Regional Counsel
Office of Waste Programs Enforcement
Preliminary Assessment
Project Officer (HQ)
Potentially Responsible Party
Quality Assurance Project Plan
Project Tracking System
Remedial Action or Regional Administrator
Regional Coordinator (HQ)
Resource Conservation and Recovery Act
Remedial Design
Remedial Planning Contractor
Request for Proposals
Request for Qualifications
Remedial Investigation
Remedial Investigation/Feasibility Study
Record of Decision
Remedial Project Manager
Regional Superfund Community Relations Coordinator
Regional Site Project Officer (RPM now used)
Superfund Amendments and Reauthorization Act of 1986
Superfund Comprehensive Accomplishments Plan
Site Inspection
Site Management Plan
Statement of Work
State Project Officer
Single Point of Contact
State and Regional Coordination Branch (HSCD)
Superfund State Contract
Site Safety Plan
Technical Assistance Team
U.S. Army Corps of Engineers
USAGE Missouri River Division
Work Assignment Completion Report
Work Assignment
Women's Business Enterprise
IX
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ACKNOWLEDGEMENTS
This document was prepared for EPA's Hazardous Site Control Division,
Russ Wyer, Director, under the direction of Paul Nadeau, Chief of the Remedial Action
and Contracts Branch. Steve Hooper was the EPA Project Coordinator. Additional EPA
support was provided by many EPA Headquarters and Regional personnel who
supplied source materials and reviewed drafts of the handbook.
Booz, Allen & Hamilton, Inc., Bethesda, Maryland, prepared the handbook (EPA
Contract No. 68-01-6888). The Booz, Allen Project Manager was Raymond Rose.
William Lamb and Robert Kravitz developed and coordinated the design and production
of the final document. Chapter 2 of the handbook was developed, in part, by CH2MHHI.
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9355.1-1
1. INTRODUCTION
Large engineering and construction projects generally proceed through four
sequential phases: planning, design, construction, and operation. These four phases can
also be used to characterize activities of Federal-lead Superfund remedial response
projects at hazardous waste sites identified on the National Priorities List (NPL). The
project planning phase for remedial response at a hazardous waste site includes initial
planning activities and the remedial investigation and feasibility study (RI/FS). This is
followed by a decision on the appropriate remedial action and then by the remedial
design (RD) phase in which the selected technology concept(s) is developed into
engineering specifications for application. After the RD is complete, the construction or
remedial action (RA) phase proceeds. Construction is frequently followed by an extended
period of treatment system operation (and, in some cases, system modification) until
appropriate public health and environmental goals are accomplished. In the case of
complex remediation needs, there may be more than one construction action and
operational system, each requiring a planning and design effort. Once cleanup is
achieved, the closeout process is initiated for deletion of the site from the NPL. Deletion
from the NPL marks successful completion of the remedial response project.
The most effective way to complete a remedial response project successfully is to
vest responsibility for the project in a single individual within EPA - the Remedial Project
Manager (RPM). The term "RPM" is defined as "... the Federal official designated by EPA
... to coordinate, monitor, or direct remedial activities..." under Subpart F of the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP) (Federal Register,
November 20, 1985). Previously, an individual in this role was known as a Regional Site
Project Officer (RSPO).
This handbook has been prepared to assist the EPA RPMs in managing Federal-
lead remedial response projects. It describes in detail the responsibilities of the RPM
during the planning, design, construction, operation, and closeout of remedial response
projects. It is designed to complement EPA's Superfund State-Lead Remedial Project
Management Handbook, which provides assistance to RPMs in overseeing State-lead,
Federally funded remedial response projects conducted under cooperative agreements
(CAs). This handbook does not specifically address the relatively few instances in which
the U.S. Army Corps of Engineers (USAGE) or another Federal agency is given the lead
for an RI/FS through an Interagency Agreement (IAG). However, such an arrangement is
somewhat analogous to a State-lead project in that the RPM is separated from the
response contractor by a layer of management.
This handbook is intended to provide the RPM with quick reference information on
what actions need to be taken during each step of the remedial process. Much of the
information presented is drawn from existing EPA policy and guidance documents
including, for example:
Guidance on Remedial Investigations Under CERCLA, June 1985
Guidance on Feasibility Studies Under CERCLA, June 1985
Superfund Remedial Design and Remedial Action Guidance, June 1986
State Participation in the Superfund Program, February 1984.
The chapters that follow are the products of an effort to compile into a single document
information concerning the RPM's roles and responsibilities for managing remedial
1-1
-------
9355.1-1
response actiivities. The handbook is not intended to replace the many detailed guidance
documents from which it was developed. At the end of each chapter, a list of titles of
helpful detailed guidance documents is provided. The RPM should have them available
for ready access.
The handbook addresses all phases of the remedial planning and implementation
process (except pre-NPL listing activities) from project startup to site closeout and NPL
deletion. Exhibit 1-1 illustrates these phases, including specific activities that occur during
the remedial planning and implementation process. The upper portion of the diagram
identifies those activities that are generally performed by the remedial planning (REM)
contractors or the USAGE under EPA oversight. The lower portion shows activities
performed by EPA. This exhibit portrays the general order in which the activities should
occur during the remedial response project. The handbook is organized in the same
order. Individual chapters are briefly described below:
Chapter 2. Project Management Concepts-- provides the RPM with
information concerning basic project management concepts and
relates these concepts to practice in the remedial response process.
This chapter provides a background for the more program-specific
discussions in the remaining chapters.
Chapter 3. Initial Project Planning and Startup- describes the
project planning efforts conducted by the RPM for the period through
initiation of the RI/FS. It identifies overall project planning activities
required before starting a remedial project and presents procedures
for issuing work assignments to the REM contractor.
Chapter 4. Remedial Investigation and Feasibility Study- provides a
description of RPM responsibilities during RI/FS. It also discusses
the RPM's responsibility for ensuring an efficient transition to the
Record of Decision (ROD) stage and to RD.
Chapter 5. Record of Decision and Transition to Design addresses
RPM responsibilities during the development, review, and approval
of the ROD, which documents the Agency's selected remedial
alternative. It also outlines the preliminary activities required for
initiation of the RD phase.
Chapter 6. Remedial Design - discusses the RPM's activities during
the development of the RD. It provides a checklist of specific
activities for which the RPM must initiate and supervise action,
promote and coordinate oversight, and act in a review/advisory
capacity.
Chapter 7. Remedial Action -- outlines RPM responsibilities during
the implementation of the RA. It also discusses the RPM's role
during the startup and initial operation of treatment systems
constructed as part of the remedy.
Chapter 8. Project Closeout - reviews the procedures followed in
closing out a project. It also describes the RPM's role and
responsibilities in NPL deletion, operation and maintenance (O&M),
and project closeout.
1-2
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9355.1-1
In each of these chapters, additional EPA guidance documents are referenced to direct the
RPM to pertinent background and supplementary information. Sample documentation and
specific procedures for processing forms and obtaining approvals have been highlighted.
Management interactions between the RPM and the USAGE, the affected State, and EPA
community relations and enforcement personnel are also appropriately noted.
The handbook can serve as a training tool for new EPA RPMs and other EPA
personnel (e.g., community relations and enforcement staff). It is an information resource
for individuals outside of the Agency, such as the REM contractor, the USAGE, and State
personnel. It should help clarify the many technical and management tasks required to
complete a Federal-lead remedial response project, and assist in their coordination in
EPA's Superfund remedial response program.
ADDITIONAL SOURCES OF INFORMATION
Comprehensive Environmental Response, Compensation, and Liability Act of 1980.
Guidance on Feasibility Studies Under CERCLA OERR and OWPE, June 1985. (OSWER
Directive 9355.0-5C)
Guidance on Remedial Investigations Under CERCLA OERR and OWPE, June 1985.
(OSWER Directive 9355.0-6B)
"Implementation Strategy for Reauthorized Superfund: Short-Term Priorities for Action,"
October 24, 1986. (OSWER Directive 9200.3-02)
National Oil and Hazardous Substances Pollution Contingency Plan (47 FR 31180),
November 20, 1985.
State Participation in the Superfund Program Volume I, OERR, February 1984. (OSWER
Directive 9375.1-4)
Superfund Amendments and Reauthorization Act of 1986.
Superfund Remedial Design and Remedial Action Guidance OERR, June 1986. (OSWER
Directive 9355.0-4A)
Superfund State-Lead Remedial Project Management Handbook OERR,
December 1986. (OSWER Directive 9355.2-1)
Work Assignment Procedures for Remedial Contracts. OERR. November 1986. (OSWER
Directive 9242.3-3A)
1-3
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EXHIBIT 1-1
Remedial Site Chronology (Federal-Lead)
CHAPTER 3
INITIAL PROJECT PLANNING
AND START-UP ACTIVITIES
CHAPTER 4
REMEDIAL INVESTIGATION / FEASIBILITY STUDY (RI/FS)
CONTRACTOR
(OR USAGE)
HATE PARTICIPATION
ONGOING PROJECT MANAGEMENT, ENFORCEMENT,
AND SUPERFUND COMMUNITY RELATIONS ACTIVITIES
m CD
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EXHIBIT 1-1
Remedial Site Chronology (Federal-Lead)
CHAPTER 5
RECORD OF DECISION (ROD)
AND TRANSITION TO DESIGN
CHAPTER 6
REMEDIAL DESIGN (RD)
CONTRACTOR
(OR USACE)
cn
[ EPA3HTE |
I DESIGN I
I CONCURRENCE I
EPA
ENFORCEMENT NEGOTIATIONS
AND ADMINISTRATIVE ORDERS
ONGOING PROJECT MANAGEMENT, ENFORCEMENT,
AND SUPERFUND COMMUNITY RELATIONS ACTIVITIES
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EXHIBIT 1-1
Remedial Site Chronology (Federal-Lead)
CHAPTER 7
REMEDIAL ACTION (RA)
CHAPTER 8
PROJECT CLOSEOUT
CONTRACTOR
(OR USAGE)
EPA
(OR STATE)
ONGOING PROJECT MANAGEMENT, ENFORCEMENT,
AND COMMUNITY RELATIONS ACTIVITIES
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2. PROJECT MANAGEMENT CONCEPTS
Throughout the handbook, the role and responsibilities of the RPM are defined
relative to other participating parties. This chapter provides the RPM with some basic
project management concepts and relates them to the Superfund site remediation
process. The reader should bear in mind that, during certain phases of the project,
many of the project management tools discussed here will actually be used by others
(such as the REM contractor project manager). Even so, the RPM, in an oversight and
coordination role, must know enough about these project management concepts and
tools to provide input, where appropriate, and use the output, when available.
The remediation of uncontrolled, hazardous waste sites is a technically complex
process of long duration. The remedial project is subject to many technical, economic,
policy, and institutional constraints; and a number of responsibility transfers occur during
the course of the project. The activities and deliverables that comprise a Superfund
hazardous site remedial project were identifed in Exhibit 1-1, in the previous chapter.
Exhibit 2-1 provides an overview of the typical schedule, process constraints, and
primary participants in a Superfund site remedial response. Close project management
and oversight are necessary because of the complexities, constraints, and numerous
parties involved in a site remediation project.
In the following paragraphs, the basic concepts of project management are
discussed as applied in both the public and private sectors for studies, engineering
designs, and construction activities.
2.1 GENERAL PROJECT MANAGEMENT FUNCTIONS
Project management is the bringing together of individuals, institutions, firms,
technologies, money, equipment, time, and other resources in accordance with a plan for
the purpose of achieving a set of objectives. Project management is accomplished most
effectively by placing the responsibility for project success in the hands of a single
individual, the project manager. The project manager is responsible for carrying out two
types of project management functions: (1) planning, monitoring, and control, and (2)
directing, coordinating, and communicating. The project manager performs these
management functions by using common-sense approaches that are based on
experience and supplemented by "tools of the trade," such as scheduling, budgeting, or
reporting systems.
In reality, a project manager is held accountable for all aspects of a project, but
seldom has the strength of authority or the control over externalities to "require" that a
project proceed according to plan. This is certainly the case for Superfund projects and
the RPM. Thus, the RPM must develop a strongly proactive approach to project
management. The proactive approach is to look ahead, which includes developing
anticipatory actions, work-around strategies, and modifications to work plans in order to
accommodate the changes, surprises, and problems that are certain to occur as the
project progresses. The project manager needs to keep a clear vision of the final
objective ~ successful completion of the project on time and within budget - without
getting into a reactive, crisis-management mode. The successful project manager must
be an organizer and a negotiator, have a knowledge of technologies, and possess well-
developed interpersonal skills. Above all, the project manager must view problems
2-1
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EXHIBIT 2-1
Remedial Process - Historical Timeframes
ro
CUMULATIVE
AVERAGE
SCHEDULE
TYPICAL
SCHEDULE FOR
PHASES
REMEDIAL
PROGRAM
PHASES
PROCESS
CONSTRAINTS
PRP Negotiations
Funding
NPL Rule-Making
PRIMARY
PARTICIPANTS
(Federal-Lead)
0
I
, 3-9
1
1
18-22
2
1
1
4
YEARS
3-6
MONTHS
3
1
1
1
1
4
6-9 ,3-4 ,
1
i
5
6-18
130 Sites/Year s.
Discovery
or
Notifi-
cation
PA/SI
HRS
& \
NPL ,
J
C
I
kj
C
-
k
RI/FS
i
:>
c
k
Remedy
(ROD)
)
6 c
)
EPA
STATE
REM
CONTR
CLP/ESD
PUBLIC
k
A/E
Selection
TO
i
k
RA
!> o
EPA
STATE
PUBLIC
USAGE
OR
OTHER
USAGE
A/E CONTR
STATE
PUBLIC
c
fr NPL fc °&M
k Deletion , k ""
itoring
I)
6
USAGE EPA STATE
CONST. STATE
CONTR
STATE
-------
and setbacks as challenges to be overcome. A list of project management references is
included at the end of this chapter. Some important project management functions are
discussed below.
2.2 PLANNING, MONITORING, AND CONTROL
Project planning is the process of identifying the scope, schedule, budget, and
resources needed to achieve project objectives effectively. Monitoring and control are
the observation of technical performance, comparing actual versus planned
performance and taking corrective action as needed. A number of project management
functions are required to plan, monitor, and control project activities. Exhibit 2-2
presents the sequence of these functions, which are described in the remainder of this
section.
2.2.1 Planning
The elements of project planning are defined as follows:
Establishing scope -- Determining project objectives and
identifying discrete tasks needed to achieve the objectives
Scheduling -- Identifying timeframes for each task and the overall
project
Budgeting -- Assigning costs to individual tasks and the total
project
Organizing -- Arranging personnel and other resources to achieve
the project objectives.
In each of the above elements, consideration must be given to funding/resource
constraints that might affect project implementation. Methods of conducting each of the
project planning elements are outlined in the following paragraphs.
2.2.1.1 Establishing Scope
The RPM's role in project scope development is to determine the conceptual
approach for the entire project to accomplish the ultimate goal of selecting, designing.
and implementing the site remedy. Establishing scope includes conceptualizing
operable units (discrete parts of the entire response action, consistent with a final
remedy, that decrease a release, threat of release, or pathway of exposure). For
example, a site may be divided into several operable units, one of which may be an
expedited response action (formerly called an initial remedial measure) to supply an
alternate drinking water supply to nearby residents. The RPM provides direction to the
REM contractor and the USAGE in identifying project objectives, operable units, and
project constraints.
2.2.1.2 Scheduling
Scheduling is a key component of planning, management, and control, since
establishing a realistic project schedule is an integral part of the RPM's responsibility to
complete program targets (ROD approval, site cleanup) on time. The Superfund
2-3
-------
EXHIBIT 2-2
Sequence of Performance of Project Management Functions
PLANNING 1 Sc<
*
Project Plan
J
I 1 1 1
Ta«k
Schedule Budget Organization ->
Definition
i
b|ective/
>P«
1
Status Reports
|
Cost Schedule
Reports Reports
Direct Schedule/Budget
Observation Milestone
Comparison
* * * *
1
!
1 1 1 1
Variance Cost
Reports Trends
Schedule Observed
Trends Status
. * * *
Exceptions
Report
CON IKOLLINU
1
1
r
1
Anticipatory Work-Around Project
j k Actions Strategy Modificiton
*
*
Plan/Policy ^__ Management ^ Schedule/
Change Action
Changes
2-4
-------
Amendments and Reauthorization Act of 1986 (SARA) imposes mandatory schedules
for starting new RI/FSs and new remedial actions at NPL sites. Scheduling is neces-
sary to anticipate when project resources (such as funding or analytical support) or
participation by others (State reviews, enforcement negotiations) will be needed. It also
allows projects to be scheduled to take advantage of external factors such as
construction seasons. Depending on the size and complexity of the project, a variety of
project scheduling systems may be used. These include milestone checks, bar charts,
and critical path method diagrams. Each is discussed below and illustrated in
Exhibit 2-3.
Milestone Charts -- Milestones are major events in the progress of a
project and can be used as checkpoints to indicate whether the
project is proceeding on schedule. Milestone charts identify the
target completion date for each major activity. The milestone chart
may include budget information, an indication of the responsible
individual, and a means of comparing actual versus planned
schedule results. The method is best for small, short-duration
projects with few participants and little interrelationship between
activities. The shortcoming of this tool is that it forecasts only
completion dates. On complex projects, this may lead to uncertainty
about when an activity should begin.
Bar Charts - This scheduling method is slightly more complex
than milestone charting. The bar chart (often referred to as a
Gantt chart) presents a list of activities along with horizontal bars
denoting scheduled start and finish dates for each activity. The
shortcoming of this method as a scheduling tool is that it does not
completely reflect interrelationships among activities, nor does it
indicate which activities are most critical to project completion.
The bar chart is a frequently used scheduling method for the
RI/FS.
Critical Path Method (CPM) Diagrams- The critical path
scheduling method overcomes some of the limitations of the bar
chart method by integrating activity interrelationships and
schedules. The method consists of systematically identifying all
project task interrelationships using a task interface diagramming
method. The duration of each task is then defined and the tasks
are put in schedule form using either a bar chart or network
format. Finally, critical tasks are determined and the path between
them is highlighted in the diagram. Determination of critical path
by manual analysis is feasible on projects with less than 100
tasks. For projects with greater than 100 tasks, microcomputer
CPM software packages are recommended. Although the major
advantage of this method is the definition of task interrelationships
and critical activities, the main disadvantage is that CPM diagrams
are sometimes hard to read and time-consuming to update. If
properly maintained they very effectively show task inter-
relationships and can be used to make changes in work flow and
thus avoid slippage in the final completion date. Some RPMs are
now using CPM at their sites.
2-5
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EXHIBIT 2-3
Scheduling Techniques
(SAMPLE)
ro
MILESTONE CHART
(REMEDIAL RESPONSE)
Initial Discovery
NPL Listing
Rl Complete
FS Complete
ROD
RD Complete
RA Complete
BAR CHART
(RVFS/ROD)
RI/FS Obligation
Rl
Data Validation
Pre-FS Meeting
Draft FS
Public Comment FS
Public Comment
Draft ROD
ROD Briefing
ROD Approval
CPM (Bar Chart Format)
(FS)
Screen Technologies
Develop Alternatives
Initial Screening
Detailed Analysis
QA Review
Draft FS Report
Draft FS Report Review
Complete FS Report
EPA Review
Public Comment FS Report
-------
All three of these techniques (or a combination) can be used in the Superfund
remedial response process. Exhibit 2-3 shows an example of how each scheduling
technique may be used. The milestone chart can indicate key events from site discovery
through remedial action. This can provide a status summary of individual sites or can be
combined to show status at a number of sites. The milestone chart can be used by the
RPM and Regional management to indicate where sites are in the remedial response
process at any time.
The bar chart generally is used to expand the level of detail provided by the
milestone chart. For example, the RI/FS and ROD milestones can be expanded to show
the timing and sequence of activities that the RPM must complete or track to achieve
program targets. This provides the key scheduling tool for use by the RPM in his
management and control functions.
At the most detailed level of project planning, individual contractors and some
RPMs can use CPM networks to schedule and control individual projects with large
numbers of tasks. This technique can be used to manage individual tasks at a greater
level of detail than can be included in the bar chart. However, the key milestones
identified by bar charts must be included in the CPM networks as well.
Used together, the three scheduling techniques can assist in the development of
an integrated site scheduling approach. Scheduling of major program activities can be
shown with a milestone chart. More detailed identification of tasks can be developed in
bar charts and CPM diagrams.
2.2.1.3 Budgeting
Budgets set the cost of the work outlined in the scope and schedule.
Establishing the project budget is always a highly project-specific process that is
dependant on the nature of the project and the organization executing it. Project
budgets can be prepared by one of the following general methods:
Top-Down Budgeting-- In this method, a pre-set total project
budget is subdivided into the individual task budgets. Top-down
budgeting is most frequently applied to projects where funding
availability is a major constraint, or where the project tasks cannot
be well defined prior to implementation. Estimates can be
prepared using generic project costs or historical averages for
similar projects. Top-down budgeting is appropriately used for
initial budgets that do not need to include detailed information on
the project tasks, making it unnessary to generate information by
guessing. This method is often the basis for cost estimates in the
Superfund Comprehensive Accomplishments Plan (SCAP). An
example of a top-down budget element is the fee for an
engineering design, which may be a set percentage of total
construction costs.
However, this method is not a good tool for monitoring and
control, since detailed task budgets are not incorporated. In
addition, it does not provide means for comparing budget
components with project objectives to ensure that the most
effective project approach is being used.
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Task-Based Budgeting -- This method involves starting from "zero" to
build individual task budgets. These are then summed to obtain the total
project budget. Task-based budgeting is appropriate when a pre-
determined budget has not been imposed, and is best used when the
project scope is well defined and can be subdivided into individual tasks.
Both unit-price and staffing-level budgeting are common applications of the task-
based budgeting technique. Unit-price budgeting is used in construction projects when
quantities are reasonably well defined. A total project budget is developed by
multiplying component quantities by their unit prices and adding appropriate
contingencies. However, the need for detailed estimates of quantities makes this
technique less suited for engineering studies.
The staffing-level approach is often appropriate for more labor-intensive projects
such as engineering studies. This approach involves estimating the labor hours
required for each project task and then applying labor rates, overhead, and
contingencies to obtain a total budget estimate.
The RPM must be familiar with both top-down and task-based budgeting
techniques since both are used in the Superfund program. Top-down budgeting is used
for overall program planning in distributing the annual remedial activities budget to
individual RI/FS, design, and remedial action projects. This is often accomplished by
using standard budget numbers for the different project types. On the other hand, the
actual budget found in the work plan for the RI/FS is usually a staffing-level, task-based
budget.
One issue with which the RPM must deal in the budget planning process is the
need to estimate funding for future activities at a site. Since the entire remedial
response project at a site spans several years and is made up of numerous activities,
the RPM will be asked to prepare budget estimates for out-year plans, including design
and construction activities. These estimates are subject to a number of uncertainties.
For example, inflation rates can change and the actual remedy is often not known when
the initial budget is estimated.
2.2.1.4 Organizing
The method of organizing personnel and other resources to accomplish the
project objectives is highly variable and depends upon the type and size of the project
and the objectives to be accomplished. In most cases, a pyramidal hierarchy is the
organizational form selected, with the project manager at its apex. This arrangement
vests the accountability for total project execution in a single individual, even though a
large number of individuals may be directly responsible for the execution of specific
project tasks. This requires both a project manager who is willing to accomplish goals
through delegation and an organizational structure with good channels of
communication.
Although many REM contractor project teams are organized using this traditional
pyramidal hierarchy, the larger structure in which the RPM operates is different. The
RPM is the principal contact between EPA and the REM contractor. The RPM's
management responsibilities involve working with a number of organizations within and
outside EPA. The RPM does not directly manage on-site activities, but must take an
active role in site management responsibilities by interpreting EPA policy and
procedures as they apply to the site and coordinating the participation of the numerous
2-8
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involved parties who do not communicate directly with each other. This role of the RPM
as coordinator is defined further in a later section of this chapter.
2.2.2 Monitoring
The primary method for monitoring site project activity is by comparison of actual
events with the schedule and budget developed in the planning phase. This can be
accomplished by progress review meetings in conjunction with obtaining regular reports
on project status so that the actual schedule and budget can be compared to the
planned targets. These reports must therefore:
Estimate progress of each task toward its objective
Estimate or detail project expenditures
Determine the schedule status of each task
Determine the budget status of each task
Determine the overall schedule and budget status.
Monitoring and reporting of Superfund project schedules can be conducted
using milestone, bar chart, and CPM scheduling techniques. Milestone scheduling is
appropriately used for monitoring key remedial response activities that can be
conducted independently of other activities. This method is more suitable for
monitoring performance than determining adverse schedule impacts, which can be
identified with bar charts and CPM networks. Bar charts and/or CPM networks can be
used when durations of sequential activities are related and delays in earlier tasks can
impact follow-on tasks. The bar chart and CPM techniques help identify critical dates on
related tasks that must be met in order to complete the overall project on schedule. The
RPM may use this information in the short term to ensure that critical milestones of the
current project are met (e.g., remedy approval). These techniques can also be used for
long-term management by advising Regional management of delays that could affect
schedule and budget decisions in follow-on work (e.g., RD and RA).
Monitoring and reporting of the budget status will depend upon the intended use
of the information. The RPM will generally use budget reports for two purposes. First,
budget reports will be used to assure that a particular activity is being accomplished
according to its overall schedule and within its budget ceiling. Second, they will be used
to identify when budget variances occur that require additional project funding. This
may result in a modification to the Regional SCAP. Techniques to control schedule and
budget variances are discussed in the following sections.
In addition to the normal process of monitoring the schedule and budget, the
RPM must perform a variety of other monitoring functions, depending upon the phase of
activity at a given site. Examples of events to be monitored include:
Performance of the remedial contractor's scope of work, e.g.,
review of contractor deliverables to ensure technical quality
The USAGE design and construction contractor selection process
and progress after award
The review of construction change orders.
Many of the monitoring and reporting methods by which the Agency and
individual Regions track progress for specific site remedial activities and provide
2-9
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necessary management support and review of the work are described elsewhere in the
handbook. These will not be addressed here.
2.2.3 Control
Trend analysis allows the project manager to gauge the importance of variances
that are identified from the schedule and budget reports obtained through monitoring
activities. Study of schedule and budget trends, in addition to direct observations of
project performance, can be highly informative, particularly when update reports on the
schedule and budget are available on a regular basis. Changes in cash flow trends as
a function of time, a steady deterioration in schedule status or deliverable quality, and
negative trends in progress toward completion with coincident higher-than-planned
cash flow are indicators of a project with problems.
Project progress meetings on project deliverables and schedule and budget
reports can identify variances from the plan that are either long-term trends or immediate
events. The process by which the project manager responds to a particular
management issue will vary based on the nature of the problem. Control is by definition
proactive, rather than a passive process (as is monitoring), and must be rigorous in
dealing with factors having potential negative impact on achievement of task or overall
project objectives.
Variances can be avoided or controlled by taking preventive or corrective
actions. The three basic types of actions may be summarized as follows:
Anticipatory Actions -- Modify external factors in such a manner
that project variances do not occur
Work-Around Strategies -- Respond to an existing negative
variance, usually schedule or budget, to accommodate changes,
but at no impact to the overall project plan
Plan Modifications- Accommodate variances by altering project
budget, schedule, or scope.
(Note: Anticipatory actions and work-around strategies are generally preferred to plan
modifications.)
Control measures the RPM may take usually involve one or more of the above
actions. The following are a few examples of such measures:
Anticipatory Actions
Request USAGE assistance in technical oversight of REM
planning contractor efforts to facilitate the transfer of
responsibility to USAGE at the design phase
Limit document reviews to essential parties and maintain
strict review schedules
Coordinate analytical needs with Contract Laboratory
Program (CLP) activity
2-10
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Increase direct observation of field activities to ensure that
program requirements are being met and avoid otherwise
unnecessary field efforts
Be aware of upcoming project milestones and associated
EPA reviews or approvals.
Work-Around Strategies
Use additional laboratory support to ensure timely turn-
around of sample data
Streamline requirements for contractor work products to
avoid repetition of data or other information
Minimize plan revisions due to contractor-controlled
schedule slippage/cost overrun
Try to limit situations where significant new information
arises that necessitates a change in scope.
Plan Modifications
Issue work assignment amendments to adjust the budget
and/or schedule resulting from work scope changes
Revise the SCAP for subsequent funding
Revise the milestone or bar chart schedule (e.g., delay
RD/RA one construction season)
Revise critical path endpoints or schedule milestones for
a specific project plan.
Exhibit 2-2 shows the relationship of project planning, monitoring, and
controlling functions. As the exhibit illustrates, the functions are interrelated and all must
be employed to achieve effective project management. Each involves techniques
applied at various stages in the project execution. However, the final areas of RPM
responsibility to be discussed - directing/coordinating/communicating -- continue
throughout all project stages.
2.3 DIRECTING, COORDINATING, AND COMMUNICATING
As a general rule, the larger the project budget, the more important is the
coordinating and communicating function of the project manager. The RPM needs to
coordinate project activities at several levels. It is necessary to coordinate internally
with programs that provide services to the project (e.g., analytical data reviews), offices
responsible for other environmental laws (e.g., Resource Conservation and Recovery
Act and Toxic Substances Control Act), and organizations external to EPA (e.g., USAGE
and the Agency for Toxic Substances and Disease Registry [ATSDR]). Without these
inputs at the appropriate times, project delays could occur. Close coordination between
the RPM and contractor is also needed to make sure that the project objectives are
being met. In addition, such coordination will help the RPM and contractor identify and
2-11
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correct problems before they adversely impact the project. Finally, the RPM needs to
coordinate all major activities with the State in order to avoid misunderstandings and
delays. By keeping the State informed, the RPM can increase the likelihood of prompt
State reviews and beneficial input at various project decision points.
Communication among the RPMs within the Agency is also important.
Innovative solutions to complex problems have been developed through experiences at
various sites. RPMs should learn from these experiences by communicating with other
RPMs (within and outside the Region) and Headquarters staff to anticipate or avoid
similar problems.
Since a large portion of the work is being done by private contractors who are
not always familiar with all program policies and goals, the coordinating and
communicating skills of the RPM are a major factor in project success.
The unique problems associated with Superfund sites require the RPM to play a
key role in ensuring project quality. The RPM is the single EPA individual responsible
for directing the contractor staff in a number of technical and policy areas. Areas in
which the RPM should be knowledgeable in order to ensure the technical quality of site-
related work include:
Sampling and analysis of contaminated media
Environmental fate and transport analysis
Risk and exposure assessment
Evaluations of remedial technologies
Environmental impact evaluation
Cost estimation
Remedial design and construction considerations.
In addition to these technical areas, the RPM should be familiar with
environmental regulations and policies that will affect how the technical disciplines are
applied to a particular site. The RPM can provide adequate quality assurance review of
project activities and be effective in the directing, coordinating, and communicating role
by integrating technical, regulatory, and policy areas.
The management skills and tools described in this chapter can be applied to all
phases of the remedial response process. The following chapters discuss the detailed
responsibilities of the RPM as they relate to the individual phases of site activity.
ADDITIONAL SOURCES OF INFORMATION
Burstein, D. and F. Stasiowski, Project Management for the Design Professional
Whitney Library of Design, 1982.
Cleland, D. I. and W .R. King, ed., Project Management Handbook. Van Nostrand
Reinhold Company, New York, 1983.
Cleland, D. I. and W. R. King, Systems Analysis and Project Management McGraw-Hill,
New York, 1983.
Drucker, P. F., Management Tasks. Responsibilities. Practices Harper and Row, New
York, 1974.
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Hall, P., Great Planning Disasters. Weidenfeld and Nicholson, London, 1980.
Kast, F.E. and J.E. Rosenweig, Organization and Management. A Systems Approach.
McGraw-Hill, New York, 1970.
Ruskin, A.M. and W.E. Estes, What Every Engineer Should Know About Project
Management. Marcel Dekker, 1982.
Souder, W.E., Management Decision Methods for Managers of Engineering and
Research. Van Nostrand Reinhold Company, New York, 1980.
Struckenbruck, L. C., The Implementation of Project Management. The Professional's
Handbook. Addison Wesley Inc., 1981.
2-13
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3. INITIAL PROJECT PLANNING AND START-UP ACTIVITIES
In Chapter 2, some basic concepts of project management were introduced.
These concepts included planning, monitoring and control, directing, coordinating, and
communicating. The focus of this chapter is project planning and its relationship to
monitoring and control. This chapter generally addresses activities to be performed
before and during the early stages of the RI/FS. It is divided into four major sections:
Development of a site management plan
Activities required before starting the RI/FS
Rl scoping and development of general response objectives
Procedures for issuing work assignments to a REM contractor.
Exhibit 3-1 illustrates all the activities that occur during the initial project planning and
start-up phase of a remedial response. The top half of the diagram represents those
activities that are the responsibility of the REM contractor or the USAGE and the bottom
those that are the responsibility of EPA.
The RPM responsibilities described in these sections are based largely on
information contained in existing EPA guidance documents, particularly:
State Participation in the Superfund Program, Volume I, February
1984 (called the State Manual)
Work Assignment Procedures for Remedial Contracts,
November 1986 (Appendix B).
For additional background information on any of the subjects discussed in this chapter,
the RPM should review these two documents.
3.1 DEVELOPMENT OF A PROJECT PLAN
The project plan, or site management plan, is the means by which the RPM can
monitor progress and exert control. The use of a project plan can promote efficiency
through better projection of resource needs, provide a baseline by which progress is
monitored, and increase RPM effectiveness by allowing the RPM to focus on elements
along the critical path.
The project plan referred to here is not the work plan prepared by the REM
contractor. The project plan is an in-house document that looks at the remedial project
as a whole: planning, design, and construction. The project plan is a management tool
that ties scope, budget, and schedule together.
Contractor assistance is available for project plan development, however. In
addition to making technical resources available to the Region, the use of a REM
contractor to assist in project plan development is a good way to involve the REM
contractor early in project planning. Procedures for accessing the REM contractor are
described in Section 3.4.
3-1
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EXHIBIT 3-1
Initial Project Planning and Start-up Activities
CONTRACTOR
(OR USAGE)
WORK PLAN
MEMORANDUM
DRAFT WORK
PLAN AND
SUPPLEMENTAL
PLANS
DEVELOP
SUBCONTRACTOR
PACKAGES
WORK PLAN AND
SUPPLEMENTAL PLANS
SAMPLING
QAPP
DATA MANAGEMENT
HEAL1H * SAFETY
COMMUNITY RELATIONS
WPLEMEHTATION
J
TO
RI/FS
Pro). Plan
Gen. Resp.
Objectives
Initial
Scoping
f SPECIAL ]
NOTICE TO I
I PRPsFOR I
^ RI/FS J
SCAP
IGR
Enf. Coord.
ATSDR
State
EPA
RtFS WORK
ASSIGNMENT
J
c
WORK PLAN MEMO
ACKNOWLEDGEMENT
INTERIM
AUTHORIZATION
f WORK PLAN 1
I APPROVAL J
DEVELOPMENT OF A PROJECT PLAN
LEGEND:
ACTIVITY
DOCUMENT
BEGIN PROJECT MANAGEMENT,
ENFORCEMENT, AND SUPERFUND
COMMUNITY RELATIONS ACTIVITIES
3-2
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The project plan should be dynamic in order to respond to changing project and
program needs. The plan provides a baseline against which progress is monitored.
Analysis of the results from project monitoring leads to action (control) that can include
revision of the project plan. Revision of the project plan should occur frequently enough
to respond to changing needs and circumstances but not so frequently so as to lose its
advantage as a baseline.
Two additional points should be considered when developing a project plan.
First, the plan is only the means to the ultimate objective which is the timely remediation
of a hazardous waste site at a reasonable cost. Second, the simpler the planning tool is
to use, the more it will be used and the more useful it will become.
The following is a suggested approach for developing a project plan that reflects
good management practices and is generally consistent with ongoing pilot projects
discussed below. It is not the only approach that might be followed, however. Each site
has unique objectives and circumstances, and a project plan should reflect these. On
the other hand, some similarity in plan format and output is desirable in order to enhance
ease of use. The format of a project plan can vary from the completely narrative to a
collection of diagrams and tables. The suggested approach is a combination of the two.
The basic organizational structure of the project, the project objectives, the delineation of
responsibility between involved parties, and other items of this nature might best be put
in narrative form with diagrams. These items tend to change less during the course of
the project. Items that change more frequently, such as schedules, milestones, and
budget figures, are more appropriately put in a data base for ease of manipulation. The
data base format should be the same for all projects in order to allow the site-specific
information to be combined into program planning reports. Also, the data base can be
linked to project management software to produce bar (Gantt) charts and critical path
networks. The remaining discussion focuses on the data base portion of the project plan,
the format of which is common to all project plans.
The baseline project plan needs to encompass all the goals, criteria, limitations,
and constraints imposed on the site project. It should be the best estimate of the activities
and resources necessary to complete the site work available to the RPM at the time the
estimate is made. The monitoring process should be designed to report on the actual
expenditures of the resources necessary to accomplish each activity within the project.
The reporting format should match the planning format so that variances can be quickly
identified and analyzed by management. Whether the variance is over or under plan,
management must decide one of two things: Have conditions changed such that the
initial plan needs to be modified or can procedures be changed to conform activities to
the baseline plan at some time in the future? The continuing process of going through
these steps will contribute significantly to successful completion of the project.
In most programs, the data base of planning and monitoring information
originates with the smallest unit within the program (here it is the specific project site
activities), and "rolls up" to provide reports to various levels of management as required.
The foundation of the program planning function is the project plan. This planning
document is the vehicle and communication link among the RPM, EPA Regional
management, and the contractors. It contains all information necessary to identify, plan,
and monitor the key elements of each project. An outline format of a project plan is
provided in Exhibit 3-2. Its flexible format will provide a common data base for program
management staff to use in the analysis and control of program delivery. (It is preferable
that the format of the project plan and the format of the contractor status reports be
consistent with regard to which milestones/tasks are identified.)
3-3
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As the project proceeds, changes are made in the project plan. A distinction
should be made between minor changes to schedule and cost data (referred to here as
updates) and substantial changes to cost, schedule, scope, or project organization
(referred to here as revisions). The project plan is updated to reflect minor schedule
slippages or cost overruns, or when key milestones are reached. Updating should occur
as new information is made available, e.g., when monthly contractor progress reports are
provided to the Region. On the other hand, attempts should be made to minimize the
frequency of project plan revisions. Project plan revisions are made when new
information necessitates a significant change in scope or project organization, or when
large variations in schedule or cost occur. Generally, project plan revisions are used as
a last resort when anticipatory actions or work-around strategies are ineffective in
maintaining the project according to plan.
In Exhibit 3-3, a suggested interface between the project plan and the remedial
process is presented. This is generally consistent with ongoing project management
pilot studies. The flags on the right-hand side indicate major milestones that should be
planned and tracked as part of project monitoring. Arrows in the left-hand column
identify the strategic points within the overall process where project planning should be
conducted or updated. The project plan is the mechanism for the planning process, and
should be reviewed (and updated or revised, as appropriate) at approximately the points
indicated by Project Plan 1,2,3, etc.
Progress reports should be prepared on each individual site project within the
program. The reports should contain current performance data such as labor and
expenses to date as well as projected cost and time to project completion. These data
would be incorporated in a project data base in the same format used for the project
plan. Status reports from the data base can provide users with actual versus planned
status information for each project element. This makes forecasting possible to anticipate
future activities as well as to identify the need for changes in current activities to keep the
project on schedule. The cycle of project plan development, monitoring, and analysis for
a site as it moves through the remedial program "pipeline" is shown in Exhibit 3-4.
The project plan is intended to be a "living document". Each revision or update of
its components should bring the site clean-up time and cost picture into clearer focus.
Casual revisions to a project plan should be avoided since it is a baseline plan to be
followed, to the maximum extent possible. However, when significant new pieces of
information are available that substantially alter the project parameters, they should be
incorporated into the baseline plan and be reflected in either a scope, schedule, or cost
revision.
A list of milestones and activities that could be tracked for each of the four project
plan iterations (shown in Exhibit 3-4) is presented in Appendix A. As the project moves
through remedial response, the focus of the planning, monitoring, and control activities
moves sequentially through the project plans.
3-4
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EXHIBIT 3-2
Project Plan Outline
1. Project Description
a. Project name
b. Project identification number
c. Project location
d. EPA Region responsible
e. EPA RPM responsible
f. Project plan number and date
2. Objectives, Goals, and Initial Scoping
3. Major Milestones and Constraints
a. Identify and set target durations for all major milestones (i.e., pre-RI/FS,
Rl, FS, ROD, etc.)
b. Identify and schedule all activities to be accomplished at the next
milestone
4. Labor and Cost Estimates
a. Estimate contractor cost required per activity or milestone
b. Estimate CLP usage
c. Estimate the cost of design and construction of the clean-up procedures
3-5
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EXHIBIT 3-3
Project Plan Interface with the Remedial Process
PROJECT PLAN 2
PROJECT PLAN 3
PROJECT PLAN 4
MAJOR
MILESTONES
Choose Lead
Consult with
State
REMEDIAL
IMPLEMENTATION
A
3-6
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EXHIBIT 3-4
Project Planning, Monitoring, and Control Cycle
Analysis / Action
Project
Plan
1
Project
Ran
2
I
Project
Plan
3
Project
Plan
4
: :
Remedial Process Pipeline
Report
Report
Report
Report
L...1 i >
Possible Parties Involved in Developing Each Project Plan
jet Plan 1 Project Plan 2 Project Plan 3 Project Plan 4
RPM
State
REM Contr.
Enforcement
Staff
RPM
REM Contr.
RSCRC
State
RPM
USAGE
State
RPM
USAGE
State
3-7
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Project Plan Iteration 1 would include detailed planning for only the
pre-RI/FS activities. Each of the other major milestones would be
treated as one activity unless enough data were available to
subdivide them into more discrete elements.
Project Plan Iteration 2 would be done at the beginning of the RI/FS
phase. Note that only the milestone start and finish dates and total
costs are included for activities preceding and following the RI/FS.
Project Plan Iteration 3 would be prepared after completion of ROD
and enforcement activities, and would include schedule and cost
data for the RD phase.
Project Plan Iteration 4 would be prepared to outline the RA
activities. Again, only summary milestone and cost data would be
provided for preceding activities.
A pilot study is currently ongoing for the purpose of applying the management
concepts of planning, monitoring, and control to Superfund projects. The pilot study is
being conducted initially in Region II, but may be expanded to other Regions. It is being
applied to fund-lead and enforcement-lead remedial projects and to removal projects.
The approach used in the pilot studies is to establish a baseline plan, monitor
project progress in order to make comparisons with the plan, and exercise control actions
when appropriate. The participating Region is using commercially available project
management and data base software on microcomputers to track project milestones and
tasks. The software being used allows the Regions and RPMs a great deal of flexibility in
choosing the level of detail desired for efficient project management. Of the three primary
project variables: (1) technical scope, (2) cost, and (3) schedule, the primary focus of the
pilot is initially on schedule, with cost to be evaluated later. The software being
evaluated in the pilot study is capable of providing on a single Gantt chart:
Major task-level tracking
Milestone tracking (major start/end dates and deliverables)
Dependencies of tasks/milestones on each other to allow critical
path scheduling
Planned versus actual scheduling.
It is envisioned that the pilot studies will improve both project and program
management. The use of a project plan should improve the RPM's ability to monitor and
control project progress. At the same time, data from individual projects can be
combined into overall status reports for Regional and Headquarters management needs
using data base software.
3-8
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3.2 ACTIVITIES REQUIRED BEFORE STARTING RI/FS
Prior to the development of the remedial planning work assignment, there are
several preliminary actions with which the RPM will be involved. The RPM should
consider the duration and appropriate starting times for these actions, as discussed in
the following narrative. Generally, these actions should be started in the quarter
preceding the quarter in which the work assignment is planned. A few of these
preliminary actions are shown in Exhibit 3-1 and are included among those listed below:
Coordination of activities with enforcement/cost recovery staff
Input to the SCAP
Obtaining site access
Initiation of intergovernmental review procedures
Coordination with community relations staff
State involvement in the remedial process.
This section will discuss the RPM's specific responsibilities for each of these initial
activities. Exhibit 3-5, on the following pages, summarizes these responsibilities.
3.2.1 Coordination of Activities with Enforcement and Cost Recovery Staff
The RPM is responsible for assisting in the development of enforcement and cost
recovery actions against potentially responsible parties (PRPs). A key determination to
be made at this point is whether or not the PRPs are going to perform the RI/FS. The
Superfund Amendments impose a mandatory enforcement negotiations moratorium
period during which EPA provides notice to all involved parties. Upon receipt of special
notice, PRPs have 60 days to submit a proposal to undertake or finance the RI/FS. If
PRPs do not submit a good faith proposal within this time, EPA may proceed with a fund-
financed RI/FS. If EPA determines that a good faith offer has been submitted by the
PRPs within 60 days, the moratorium continues for 90 days after issuance of notice while
EPA evaluates the proposal. If the PRPs' proposal is found to be satisfactory, then the
project should be conducted as an enforcement-lead project. If not, the project can
continue as a Federal-lead project. Additionally, there are three other enforcement
activities with which the RPM will become involved :
Sharing and receiving information about PRPs with State and EPA
enforcement staff to determine the viability of an enforcement action
Establishing site files and documenting all steps taken during the
remedial response to support any future cost recovery actions
Working closely with the REM contractor to make sure that the
, contractor's project manager is aware of the provisions regarding
enforcement, cost recovery, and the contractor's responsibilities for
providing evidence and documentation.
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EXHIBIT 3-5
Initial Activities
ACTMTY
RPM RESPONSIBILITIES
REFERENCES
1. Coordination of activities with enforcement/
cost recovery staff
2. Input to the Superfund Comprehensive
Accomplishments Plan (SCAP)
3. Obtaining site access and permits
Share information about responsible parties
with State and EPA enforcement staff to deter-
mine the viability of an enforcement action and
issue special notice to PRPs for RI/FS negotiations
moratorium
Establish site files and document all
steps taken during the remedial response to
support any future cost recovery actions
Work closely with the REM contractor to
make sure that the contractor's Regional
Manager is aware of the provisions regard-
ing enforcement, cost recovery, and the
contractor's responsibilities for providing
evidence and documentation.
Ensure that the proposed project is adequately
funded by the SCAP
Provide site-specific activity and financial
information and schedules to the Regional SCAP
representative
Review the SCAP and initiate adjustments
and/or amendments when necessary
Review current and potential SCAP schedule
commitments with REM contractor.
Support the State in obtaining site access
and permits
- Identify all permits that may be required
- Meet with State representative to discuss
strategies
- Obtain legal advice from the Office of
Regional Counsel
Foresee project delays and added cost at-
tributable to limited site access or permit
problems.
CERCLA Enforcement Attorney's
Manual, April 1984
Cost Recovery Actions Under CERCLA,
August 1983
"Procedures for Documenting Costs
for CERCLA 107 Actions", January 1985
See current year SCAP
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EXHIBIT 3-5
Initial Activities (Continued)
ACTIVITY
RPM RESPONSIBILITIES
REFERENCES
4. Initiation of intergovernmental review
procedures
5. Coordination with community relations staff
6. Involvement of the State in the remedial
process
Initiate intergovernmental review of all
remedial projects
- Monitor SCAP to determine the time of
projected obligation
- Formally notify the single point of con-
tact (SPOC) in the State of the proposed
action at least one quarter prior to
planned start date
Prepare written explanation and response
to the State's comments
Ensure that the Federal-lead agreement pack-
age contains the following required materials:
- A copy of the notification letter sent to
the State
A copy of the State recommendation and the
response to the notification letter
- Other letters commenting on EPA's proposed
action.
Assist in development and review of the
Community Relations Plan (CRP).
Review the State letter of request and pro-
vide comments to the Regional Administrator,
if necessary.
State Manual. Appendix D,
February 1984
40CFRPart29
Community Relations in Superfund:
A Handbook, Draft, March 1986
State Manual, February 1984
-------
It is important that the RPM meet with Regional enforcement staff early in the
remedial planning process to discuss any relevant information on the site that may be of
use in developing a cost recovery case against a PRP. Because cost recovery actions
typically lag several years behind the remedial process, it is important that well
organized, comprehensive files be kept. This responsibility is assumed by the RPM in
some Regions, while in others it is assumed by enforcement staff.
The collection and maintenance of proper documentation and the development of
quality site files are important to the development and implementation of a successful
enforcement and cost recovery action. In general, quality site files are also essential to
successful project management. Potential evidence concerning the site and PRPs must
be noted and documented before the response activity or the passage of time may
obscure or destroy it. Physical evidence essential at trial must be collected and
preserved appropriately. The RPM should make sure that Regional files document and
support all actions taken at the site. Documentation should be sufficient to identify the
sources and circumstances of site problems, provide an accurate account of Federal
costs incurred, and demonstrate actual and potential impacts to public health and welfare
or to the environment. Files should include a signed copy of the Action Memorandum.
Other communications, memoranda, and relevant documents may also be included in
the file, as appropriate. For additional details on record maintenance in the Superfund
program, the RPM should consult:
Procedures for Documenting Costs for CERCLA 107 Actions,
January 1985
Cost Recovery Actions Under CERCLA, August 1983
Appendix U of the State Manual.
The RPM should contact the contractor's Project Manager to make sure that the
contractor is aware of the provisions regarding enforcement, cost recovery, and the
contractor's responsibilities for providing evidence and documentation. These
procedures are summarized in the next chapter on RI/FS and are fully described in the
National Enforcement Investigation Center (NEIC) Policies and Procedures Manual,
February 1983.
3.2.2 Input to the Superfund Comprehensive Accomplishments Plan
The SCAP is an EPA management plan that lists site-specific Superfund financial
allocations for each fiscal year. Prior to the beginning of a fiscal year, each Region must
draft and submit a site-specific list of remedial activities, schedules, and estimated costs.
Several months before the start of the fiscal year, the RPM should begin work on the
SCAP by estimating the costs that will be required for each site. RPMs should become
familiar with the SCAP process and the SCAP for the current fiscal year.
The draft SCAP undergoes a series of Regional and Headquarters reviews and
revisions before finally being approved by the Assistant Administrator for the Office of
Solid Waste and Emergency Response (AA/OSWER). An important RPM responsibility is
providing site-specific activity and financial information and schedules to the Regional
representative who compiles, adjusts, and amends the SCAP, as well as making the
REM contractor aware of the SCAP commitment and schedule as they apply to the
contractor.
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It is important for the RPM to make sure the project funding needs are reflected in
the SCAP. The RPM also is responsible for initiating SCAP adjustments and
amendments when necessary. For example, as soon as it is known that the planned
project budget will exceed the funds provided in the SCAP, the RPM should request an
adjustment through the Regional SCAP coordinator. Adjustments are modifications to
the SCAP that neither alter the number of activities originally set forth nor exceed the
Regional advice of allowance (e.g., replacing one RI/FS with another of equal
magnitude). Amendments are modifications that increase or decrease the "new starts"
targets or exceed the Regional quarterly advice of allowance (e.g., when an RI/FS
scheduled to start during the first quarter will not begin until the second).
3.2.3 Obtaining Site Access
Obtaining site access for remedial planning activities is a critical path activity that
should begin as early as possible. The State is responsible for obtaining site access;
however, the RPM should be prepared to assist the State in this effort. The RPM should
encourage the State representative to identify specific site access requirements and to
develop a strategy and a schedule for obtaining access that will not delay field work
startup for the RI/FS. Access, even when obtained, may be restricted. For example,
access for field work near a highly traveled roadway may be allowed only during non-
peak traffic hours. The RPM must consider the impact of any access restrictions on
schedules and budgets.
Site access may be difficult to obtain in some cases. The State representative
should consult with State legal officials to determine the appropriate approach or
mechanism to obtain site access. If voluntary access cannot be obtained, the State must
use all its available legal authorities to obtain site access before EPA will consider taking
legal actions under its authorities. SARA has strengthened EPA's site access authorities.
The RPM should consult with the Office of Regional Counsel (ORC) and the Hazardous
Site Control Division (HSCD) Regional Coordinator for assistance and current policy
guidance on site access issues.
3.2.4 Initiation of Intergovernmental Review Procedures
The RPM is responsible for initiating intergovernmental review of all remedial
projects. This involves two sets of procedures, one to be followed for States that have
developed a formal review process that includes the Superfund program and one to be
followed for States that have not. For further details on intergovernmental review the
RPM should consult Appendix D of the State Manual. The RPM must be particularly
concerned with:
Identifying the designated State's single point of contact (SPOC)
and the State's review procedures
Formally notifying the SPOC, if one has been designated, at least
one quarter prior to the RI/FS obligation quarter identified in the
SCAP
Providing appropriate review opportunity to the State within overall
project requirements (e.g., submitting documents to all reviewing
entities, briefing critical State staff, etc.)
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Preparing EPA's "accommodation or explanation" of the process
recommendations, if one is transmitted through the SPOC. This
means that EPA must do one of the following:
Accept the State recommendation
Reach a mutually agreeable solution
Provide the SPOC with a written explanation for not
implementing the recommendation.
In the latter case, the RPM must prepare a letter for the Regional Administrator's
signature, informing the SPOC of the reasons for non-accommodation; a copy of each
non-accommodation should be sent to the Chief, Grants Policy and Procedures Branch
(PM-216), EPA, Washington, D.C. 20460, (202) 382-5268. If the situation is
controversial, the RPM must consult with this Branch Chief before taking action.
The RPM must include the following materials pertaining to the review in the
Federal-lead agreement package:
A dated copy of the letter notifying the SPOC of a proposed
remedial project
A copy of the State recommendation, if any, and the Regional
Administrator's response to the SPOC, if the recommendation
differs from EPA's proposed action
Any other letters commenting on EPA's proposed action, including
opinions of reviewers differing from the State recommendations.
The RPM also is responsible for summarizing the results of the intergovernmental review
in the Decision Memorandum which is prepared as part of the concurrence package for
each remedial response agreement with the State.
3.2.5 Coordination with Community Relations Staff
The RPM is responsible for contacting the Regional Superfund Community
Relations Coordinator (RSCRC) to provide information and assistance, if necessary, in
developing and reviewing the Community Relations Plan (CRP). The CRP documents
planned community relations activities. In some cases, the State may develop and
implement the CRP for a Federal-lead site. It is important that the RPM closely monitor
development of the CRP to ensure that it is prepared in a timely manner and addresses
critical site issues. If this is not done, initiation of on-site activities may be unnecessarily
delayed. The RPM should consult Community Relations in Superfund: A Handbook,
Draft, March 1986.
3.2.6 Involvement of the State in the Remedial Response
The Superfund Amendments provide broad authority and an extensive list of
requirements for State involvement in every phase of the Superfund program. EPA will
be developing guidance concerning State involvement that will provide for:
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Participation in long-term planning for all remedial actions in a State
Reasonable opportunity to review and comment on planning documents,
technical data, engineering designs, or proposed findings and decisions
to waive requirements
Notification of an opportunity for participation in negotiations with PRPs
Notification of and opportunity for comment on the proposed plan for
remedial action and other plans under consideration
Concurrence in deleting sites from the NPL.
The RPM should contact the appropriate State officials to discuss the site and EPA's
remedial program processes. It is very important to get the State involved as early as
possible in the process and to learn of any State environmental standards or
requirements that may apply to the site in question.
When EPA has lead responsibility for remedial planning activities at a site, two
options are available for initiating the project:
EPA and the State may submit a series of letters outlining the scope
of activities that EPA will undertake and the ways the State will
coordinate with EPA during those activities, or
EPA and the State may enter into a remedial response agreement.
It is left to the discretion of Regional and State staff to select the appropriate vehicle for
the project at the site in question. However, the use of EPA/State letters requesting EPA
assistance is the simpler, more direct, and more commonly-used approach. Additional
guidance on preparing and executing EPA/State remedial response agreements is
provided in the State Manual.
The EPA/State letters function as a "paper trail" to document the remedial
planning project. This process involves a series of correspondence between EPA and a
State. EPA's letter defines the scope of the proposed activities and requests State
cooperation in certain site-related tasks. The State's letter documents State concurrence
on the response and outlines how the State will interact with EPA during the project. A
remedial response agreement between EPA and a State defines the scope of work for
the project and the specific responsibilities of the respective parties.
In almost all cases, the selected option is the EPA/State letters approach, which is
a two-step process. First, the RPM prepares EPA's letter to the State agency, outlining
the project that EPA is proposing to undertake. This letter may be site-specific or may
cover activities at several sites, but should accomplish the following:
Define the objectives, scope, schedule, and estimated cost of the project
Designate the RPM for the site
Request that the State provide information on the site and access to State
files
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Request that the State obtain necessary permits and site access
Estimate the likelihood of State cost-sharing responsibility (especially for
publicly owned or operated sites)
Describe any tasks to be performed by the State
Allow for State review of the site-specific work plan, CRP, and site safety
plan before field activities begin
Allow for provision to the State of intergovernmental review comments
and EPA response.
The RPM should be sure to address any site-specific requirements, as appropriate.
In the second step, the State letter is developed in response to EPA's letter and
acknowledges State concurrence with the EPA-lead response. Although the State's
letter will usually be addressed to the Regional Administrator, the RPM must review the
letter and provide comments to the Regional Administrator, if necessary. The RPM
should ensure that the State's letter does the following:
Indicate State concurrence on the project
Designate a State Project Officer (SPO)
Confirm that the State will obtain (or has obtained ) site access and
necessary permits
Demonstrate that the State is aware of its statutory obligations for cost
sharing, off-site treatment, storage and disposal, and O&M, at the
necessary phase of the response
Agree to review the site-specific work plan and associated work products,
if the State desires
Agree to meet with EPA periodically to discuss site progress and issues
that arise.
If there are problems with the State's letter, the RPM should contact the designated SPO
to discuss and resolve them.
3.3 REMEDIAL INVESTIGATION SCOPING AND DEVELOPMENT OF
GENERAL RESPONSE OBJECTIVES
Prior to developing work plans and conducting the RI/FS, there are two crucial
steps that shape the execution of these subsequent project planning and RI/FS activities:
Initial Rl Scoping involves the collection and analysis of existing site data;
this sets the basis for developing the Rl sampling plan based on
outstanding data needs, such as the data necessary to define the
"problem" and to evaluate alternative solutions
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General Response Objectives, or classes of response, should be identified
in order to focus the scope of the RI/FS.
Each of the activities is discussed in detail in:
Guidance on Remedial Investigations Under CERCLA, June 1985
Guidance on Feasibility Studies Under CERCLA, June 1985.
These documents will hereafter be referred to as the RI Guidance and FS Guidance,
respectively.
Contractor participation in the development of a site management plan,
identification of general response objectives, and initial RI scoping can be secured
through either a forward planning work assignment or an interim RI/FS work assignment.
These activities are primarily the responsibility of the RPM, but assistance from the
contractor is available. Procedures for issuing interim work assignments to the REM
contractor are discussed in Section 3.4. The RPM should ensure that the contractor
receives all relevant site information. This may include:
Preliminary Assessment and Site Inspection (PA/SI) data
Technical Assistance Team (TAT) information
Emergency response removal action data
Contractor files
State files.
In addition, the RPM should inform the REM contractor of:
Site and study area boundaries, if known
Objectives of the study
Schedule requirements
Special site or study conditions.
The RPM should also oversee RI scoping by reviewing RI scoping outputs such as:
Site descriptions
Site history
Chronology of significant events
Site maps.
Based on preliminary site information, the RPM and the Regional Project Officer
(RPO) should tentatively identify general response objectives, or classes of response,
without necessarily identifying specific technologies. Examples of general response
objectives include the following:
Source control
Management of migration
Removal.
A more extensive list of general response classes is provided in the FS Guidance. The
general response objectives identified will shape the objectives of the RI site
characterization and the evaluation of remedial alternatives.
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Historically, the RI/FS has often been planned and executed in a serial fashion
(first the final work plan, then the Rl, then the FS), usually with a single sampling event.
This approach sometimes resulted in a situation where the Rl was not sufficient to
support the FS, causing delays and problems in technical quality. Therefore, the RI/FS
planning process has been evolving to a closed-loop approach where the anticipated
data needs of the FS are used in the Rl scoping and determination of sample needs.
The anticipated FS data requirements are determined from an early screening of
alternatives, combined with a focus on those alternatives which appear most reasonable
for the site conditions. This approach has been described in the Rl Guidance and the FS
Guidance.
This process continues to evolve, and EPA is considering further steps to
streamline the RI/FS and improve technical quality. These steps include a greater focus
on early alternatives screening; multiple sampling events, each providing feedback to the
Rl scoping and determination of additional data needs; increased analytical alternatives,
such as field screening; and revisions to the work authorization and planning process.
These changes are referred to collectively as the phased RI/FS approach. Additionally,
EPA is developing several guidance documents to assist in streamlining the RI/FS; these
include:
Data Quality Objectives Development Guidance for Uncontrolled Hazardous
Waste Site Remedial Response Activities, Draft, October 1986
Superfund Public Health Evaluation Manual, Draft, December 1985
Superfund Exposure Assessment Manual, Draft, January 1986
Field Standard Operating Procedures Manual.
The RPM, RPO, and SPO should keep this emerging approach in mind as they
consider the scope of the RI/FS and general response objectives. They should try to
visualize the possible operable units and the technologies most likely to be applicable,
and should work with the REM contractor to be sure that the scope of the Rl is sufficient
to support an evaluation of these technologies.
3.4 PROCEDURES FOR ISSUING WORK ASSIGNMENTS TO REM
CONTRACTOR
All remedial response services for Federal-lead projects are obtained through the
issuance of a work assignment to one of the EPA REM contractors by the EPA
Contracting Officer (CO) in Headquarters. A work assignment defines the tasks the
contractor is expected to perform to complete the job. Three basic steps are involved:
Step 1 -- Development and issuance of the work assignment
package
Step 2 -- Completion of interim work assignment activities
Step3 -- Approval and implementation of the contractor work plan.
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This section will discuss the responsibilities of the RPM for each of these steps. It
will also discuss some of the problems that may be encountered in developing and
issuing a work assignment and ways to avoid unnecessary delays.
3.4.1 Step 1 - Development and Issuance of Work Assignment Package
Exhibit 3-6 illustrates the process for developing and issuing a work assignment
package. As the exhibit shows, the RPM, along with the RPO, is responsible for
preparing the work assignment package. The package consists of four elements:
Work assignment form
Interim work assignment statement of work (SOW)
Complete work assignment SOW for the entire project
Procurement request/requisition (PR).
In order to avoid delays, it is essential that complete work assignment packages be
submitted. The RPM's responsibilities for each of these elements are discussed below.
Further details on the procedures to be used in initiating and monitoring the contractual
aspects of a work assignment are provided in Work Assignment Procedures for Remedial
Contracts, November 1986, which has been incorporated as Appendix B in this
document.
3.4.1.1 Work Assignment Form
The RPM is responsible for preparing the work assignment form, which is a one-
page summary of basic information about the individual work assignment. A sample
form is contained in Appendix B. It includes such items as the name and address of the
contractor, the contract number, the project name, the work assignment number, the
authorized level of effort (both for the interim authorized activities and for the complete
work assignment), the period of performance; the names of the EPA CO, RPM, and RPO;
and the names of the contractor's Site Manager and Regional Manager. The names and
phone numbers for current COs and Project Officers (POs) are presented in
Appendix C.
In preparing the form, it is very important that the RPM take extra care to ensure
that all items are completed accurately. Incorrect or incomplete information such as a
missing project name or signature may cause unnecessary delays in processing and
issuing the work assignment.
Most of the information necessary for completing the cover sheet is self-
explanatory. However, there are two items that require further explanation: 1) the work
assignment number and 2) the level of effort (LOE). The work assignment is numbered
according to the system described below:
Sample Work Assignment Number: "01-9L33"
"01" denotes the first work assignment issued
"9" denotes Region 9
"L" denotes the activity to be executed
"33" denotes the site numbered 33 in the Region.
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EXIBIT 3-6
Development and Issuance of the Work Assignment Package
ORIGINATOR
DOCUMENTATION
RECIPIENT
EPA
CONTRACTING
OFFICER
PROCUREMENT
REQUISITION
CEPA
IONTRACTING
OFFICER
CONTRACT
MOD
(SF-30)
INTERIM &
COMPLETE
WA SOW
KEY:
RPO - REGIONAL PROJECT OFFICER
RPM - REMEDIAL PROJECT MANAGER
SOW . STATEMENT OF WORK
WA - WORK ASSIGNMENT
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Only the letters and numbers shown below may be used:
"L" = Remedial Investigation/Feasibility Study
"N" = Remedial Design
"R" = Remedial Action
"S" = Operation and Maintenance and Monitoring
"X" = Monitoring responsible party remedial actions
"9" = Remedial support and management
"7" = General Superfund support and management.
The first two digits of the work assignment number should be left blank since these
numbers are assigned sequentially by the CO. The remaining digits in the number are
self-explanatory.
Information on the LOE can be obtained from the interim and complete work
assignment SOWs, as described below.
3.4.1.2 Interim Work Assignment Statement of Work
The interim work assignment provides the RPM with a great amount of flexibility
by allowing the timely start of preliminary activities during the development, review, and
approval of the overall work plan. In this way the project can get off to a quick start. Also,
these preliminary efforts, which may include some field activities, can be used as input
into the Rl scoping process, thereby improving the quality of the work plan.
The RPM is responsible for preparing the interim work assignment SOW which
defines the interim authorized tasks the contractor is expected to perform under the work
assignment. Typically, these include such things as:
Development of a work plan
Collection and evaluation of existing data
Development of a health and safety plan
Development of a quality assurance project plan (QAPP)
Topographic mapping
Development of a sampling plan
Preliminary sampling, sample screening, or other field tasks
Development of a CRP.
A copy of a sample interim work assignment SOW is shown in Appendix D.
The interim work assignment SOW also defines the authorized hours to be
expended on the interim authorized tasks. The RPM is responsible for providing the
estimated hours for professional LOE needed to complete each of the interim authorized
tasks. Exhibit 3-7 has been developed to assist the RPM in formulating these estimates.
The exhibit contains estimated hours for professional LOE, based on information in
existing work plans that have been developed for RI/FS activities at sites that can
generally be classified as either "simple," "moderate," or "complex," with regard to the
magnitude of the required remedial response activities. The RPM should use these
estimates as guidance only, rather than as strict upper or lower limits for accomplishing a
particular activity.
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EXHIBIT 3-7
Estimates of Labor Hours Required to Complete Interim Work
Assignment Tasks for Simple, Moderate, and Complex Sites*
Tasks
Work Plan Preparation
Collection and Evaluation of Existing Data
Health and Safety Plan Preparation
Quality Assurance Project Plan (QAPP) Preparation
Topographic Mapping
Sampling Plan Development
Program Management/Community Relations
Simple
100-160
40-80
30-60
30-60
40-80
80-100
40-160
Moderate
120-400
60-160
50-100
60-120
80-120
100-200
120-200
Complex
360-700
120-200
80-200
100-180
100-150
200-300
160-320
I * Estimates are based on data from previous experience
i with performance of similar tasks.
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3.4.1.3 Complete Work Assignment SOW
The RPM is also responsible for developing the complete work assignment SOW,
which defines the remaining tasks the contractor is expected to perform under the full
work assignment. It should contain the following elements:
Site background
Nature and extent of problem
Summary of work accomplished to date
Purpose of the work
Description of the services to be performed
Required deliverables
Reporting requirements.
The SOW should be sufficiently detailed to define what must be done under the
activity, yet not so detailed as to reduce the contractor's flexibility in developing an
effective work plan to respond to EPA's needs. Among EPA's needs are interactions with
the enforcement program, State involvement, and interactions with other Federal
agencies. To assist the RPM in developing activities and tasks for the complete work
assignment SOW, the RPM should refer to the model SOWs in the RI Guidance and the
FS Guidance, which provide summaries of activities/tasks that may be performed by any
of the existing REM contractors and can be used as guidance in developing the
activities/tasks to be included in the complete work assignment SOW. However, the
coverage of individual REM contracts may vary somewhat, so the RPM should also refer
to the appropriate REM contract to ensure that the activities specified in the work
assignment SOW are within the scope of the contract SOW. Questions may be
addressed to the HO Regional Coordinator or PO.
3.4.1.4 Procurement Request/Requisition
The PR (EPA Form 1900-8) is used to order the specific tasks and activities
defined in the interim and final SOWs. The RPM is responsible for preparing the PR and
obtaining all necessary approvals and signatures. The only part of the PR that the RPM
will need assistance in preparing is the section on accounting information (account
number, appropriation, and Document Control Number). The RPM should contact the
Regional Financial Management Division for this information. A sample copy of a PR is
shown in Appendix D.
3.4.1.5 Issuance of Work Assignment Package
When the four elements of the work assignment package are completed, the RPM
is responsible for sending the package to the Contracting Officer with copies to the HQ
PO. If the CO or PO has any questions concerning the package, the RPM is responsible
for resolving these questions. The CO will then issue the work assignment to the
specified REM contractor.
3.4.2 Step 2 - Completion of Interim Work Assignment Activities
Exhibit 3-8 illustrates the process followed in completing interim work assignment
activities. As the exhibit shows, the RPM is responsible for reviewing the work plan
memorandum developed and submitted by the REM contractor. The work plan
memorandum is optional, and as determined by the RPM, describes the scope of work for
the interim work assignment LOE, cost estimates for completing the interim work
assignment, and a schedule of interim work assignment SOW deliverables.
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EXHIBIT 3-8
Completion of Interim Work Assignment Activities
ORIGINATOR
DOCUMENTATION
RECIPIENT
WORK PLAN
MEMORANDUM!
RPM/RPO
,/ACK
ACKNOWLEDGE
RECEIPT
(INITIATION OF INTERIM
WA SOW AUTHORIZED TASKS)
EPA
FILES
(APPROVE OR RETURN TO
REM CONTRACTOR FOR
MODIFICATION)
DATA
ANAGEMENT
PLAN
OMMUNITY
RELATIONS
PL
KEY:
HPO - REGIONAL PROJECT OFFCER
RPM - REMEDIAL PROJECT MANAGER
SOW - STATEMENT OF WORK
WA - WORK ASSIGNMENT
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The contractor is responsible for submitting the optional work plan memorandum
within 10 days of receiving the work assignment. It is EPA's intent that the work plan
memorandum process be quick and simple. The RPM should maintain frequent contact
with contractor personnel who are responsible for developing the work plan
memorandum to make sure that they receive any inputs needed and complete the work
plan memorandum within this 10-day period. The RPM should arrange a meeting with
the contractor's Regional Manager a few days after the contractor has had an opportunity
to review the interim work assignment SOW. At this meeting, any outstanding concerns
regarding the work assignment should be discussed and resolved. The RPM also
should make certain that the contractor has initiated work on the interim authorized tasks
while the work plan memorandum is being prepared. The contractor should be
reminded that work is to begin immediately on all interim authorized tasks, such as
development of the Sampling and Analysis Plan and the QAPP.
When the work plan memorandum is received, the RPM should make sure that it
includes the following components:
A cost estimate for interim activities detailing effort by professional
level, travel costs, other direct costs, support services, and any
subcontracting
A schedule for all deliverables to complete the interim work
assignment, including the work plan.
The RPM should pay particular attention to the labor hours and costs proposed by
the contractor to make sure that they do not vary substantially from those provided in the
interim work assignment authorization. If the contractor proposes an increase in labor
hours and/or costs above the amount provided in the interim authorization, the RPM must
determine that it is justified and obtain written approval from the CO.
Following review of the work plan memorandum, the RPM is responsible for
providing to the contractor written acknowledgement of receiving the work plan
memorandum and for sending copies to the Headquarters Regional Coordinator and PO.
This review should take no more than five work days.
After the work plan memorandum acknowledgement is returned to the contractor,
the RPM should remind the contractor's Site Manager that the draft work plan, described
in the following section, for the complete work assignment should be submitted to the
Regional office as soon as it is completed, even though the remaining authorized interim
tasks may not yet be completed. This will expedite approval of the work plan and
initiation of tasks under the complete work assignment SOW by allowing Regional review
to commence as soon as possible.
3.4.3 Step 3 - Approval and Implementation of Contractor Work Plan
The contractor is responsible for submitting to the Regional office several interim
SOW deliverables according to the schedule contained in the work plan memorandum.
These may include, but are not limited to, the following:
Work plan
Health and safety plan
Quality assurance project plan
Site sampling plan
Community relations plan.
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The most significant of these is the work plan, which describes how the contractor plans
to accomplish all the activities and tasks outlined in the complete work assignment SOW.
3.4.3.1 Work Plan Review Process
Before proceeding to the administrative mechanics of work plan approval, it is
important to discuss the process of work plan review. The objective in reviewing a work
plan is to obtain a plan by which a timely, high-quality RI/FS can be accomplished at a
reasonable cost. Note that most of the tasks in the RI/FS can be examined from a
standpoint of technical quality, budget, and schedule. These three considerations form
an excellent basis from which to evaluate the work plan.
In terms of technical content, the work plan should include:
The purpose, scope, and methodology for each task
The proposed quantity and distribution of ground-water, surface
water, soil, air, and other samples
The spacing and depth of soil borings and monitoring wells
The types of analyses likely to be required, based upon near-term
technology forecasts
The use of bench- and pilot-scale studies
The use of ground-water or other models
The general relationship between the pathways to receptors, the
likely alternatives, and the scope of the RI/FS.
While reviewing the technical aspects of the plan, the "phased RI/FS" approach
should be kept in mind. The phased approach involves the use of multiple sampling
events to provide feedback for the determination of further sampling needs, increased
use of analytical alternatives such as field screening, and a greater focus on early
alternatives screening.
When examining the work plan from the standpoint of budget, consideration
should be given to overall cost, unit costs, and quantities of such items as well footage,
the use of equipment and other resources, and the proposed level of effort for each task.
Cash flow scheduling and reporting measures should be in place in order to actively
monitor and control costs during the project.
The schedule and organization of the project should be reviewed to ensure that
task durations seem reasonable, no resource conflicts exist, the sequence of tasks
seems appropriate, and events are scheduled in appropriate seasons. For instance, field
sampling should probably not be scheduled for the middle of a New England winter, nor
should high ground-water table conditions be sought in August. Sampling may also be
coordinated with the seasonal variations of the CLP workload. It is especially important
at this point to be aware of which tasks are on the critical path and give those tasks due
consideration. The REM contractors sometimes use the critical path method when
planning the RI/FS. The CPM output could be a useful tool for review of the work plan, if
it is available. Finally, the RPM should pay special attention to the presence of periods
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for the review of deliverables, milestone review meetings, and hand-off points. Key
activities and milestones should be added to the Regional data base for management
tracking and reporting.
3.4.3.2 RPM's Role in Work Plan Review and Approval
The previous paragraphs presented some of the aspects which should be
considered during the review of the work plan. The RPM's role during the work plan
review is discussed below. The RPM should strive to manage the work plan review
process to ensure a timely completion. Copies of the draft work plan are generally sent
out to technical specialists within EPA such as geohydrologists, toxicologists, chemists,
and biologists for review within their respective areas of specialization. The actual
approach may vary from Region to Region or from site to site, but the principle is valid --
the technical aspects of a multidisciplinary study plan should be reviewed as much as
possible by a multidisciplinary team. In this way, the RPM has access to a larger pool of
knowledge and experience.
The RPM also should coordinate the review with other involved parties within and
outside EPA. For instance, EPA enforcement, air program, laboratory support, and legal
staff may provide input at this stage. Also, in most cases, one or more State agencies
provide some comment at the work plan review stage. The Agency for Toxic Substances
and Disease Registry also may be involved since they will be conducting health
assessments of all NPL sites, as mandated by SARA. In many cases, ATSDR will be
using data collected by EPA before and during the RI/FS. Finally, the USAGE may be
brought into the review process at this time. This is done using seed money funded
through a technical assistance Interagency Agreement (IAG). (Looking ahead, the RPM
should ensure that technical assistance money is in the SCAP for the appropriate
quarter.)
It is important to keep the review moving and this becomes especially difficult
when outside agencies or other groups within EPA are involved, because they are not
directly under the RPM's influence, authority, or control. The RPM should establish a
reasonable review schedule and see that it is met. Ensuring that other participants
adhere to the schedule will require a combination of negotiating skill and diplomacy.
The work plan development and review process typically takes about 150 days. EPA
would like to reduce this time to 90 days.
The RPM also may provide direct review of certain aspects of the work plan such
as budget, scheduling, and selected technical areas. One approach to doing this is to
mentally review the project and try to anticipate problems based on personal
experience. For the less experienced RPM, another approach would be to compare the
work plan against experience on other RI/FSs. Comparisons can be made by looking at
actual durations of similar tasks and by calculating unit quantities such as sample
densities or costs. In this way, the RPM can become familiar with costs, appropriate
amounts of sampling, and different approaches and methodologies under various
circumstances. Some conclusions as to the relationship between sample intensity,
methodology, and the quality of the RI/FS may be tentatively drawn from those RI/FSs
from which remedies have been selected.
An alternative review process would involve a Regional team of experienced
RPMs, technical specialists, and others who convene for review of the work plan,
bringing to the effort experience and insights derived from past and current RI/FSs. Site
visits by one or more of the review team members should be a requirement.
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For very complex or extraordinary sites, a Delphi review process can be used to
supplement the normal work plan review. In the Delphi review, the Delphi manager
circulates copies of the work plan to members of a review panel especially selected for
the site in question. These panel members can be EPA staffers or contractor personnel.
The panel members independently review the document and submit comments to the
Delphi manager who then generates a summary report. The Delphi review is similar to
the review done by the RPM, except that a wider pool of reviewers is involved.
Exhibit 3-9 illustrates the process for approval and implementation of the
contractor work plan. If the work plan is acceptable, the RPM forwards it to the RPO for
review and approval. The RPM also signs a work assignment form indicating final work
plan approval and forward it along with the work plan to the RPO. If the RPO approves
the work plan, the RPO will sign the work assignment form and forward it directly to the
EPA CO. The work assignment form is forwarded by the EPA CO to the Contractor's
National Program Management Office. The exact procedures followed by the RPO may
vary depending on the particular contractor involved. The RPO should also forward a
copy of the form to the PO. Copies of the approved work plan also should be sent to the
State and ATSDR, if appropriate.
If the RPM or RPO disagrees with the work plan, the RPM will contact the
contractor to explain the reasons for the disagreement and to discuss what modifications
in the work plan will be necessary. Once the modifications are completed, the RPM and
RPO will both sign the work assignment form and the RPO will submit it, along with the
work plan, to the EPA CO.
In reviewing the work plan, the RPM should make sure that the total funding
specified in the plan is within that of the original PR. If it is not, a PR for the incremental
costs will be required at a later date. Also, the Expenditure Limit column of the work
assignment form should reflect funding limitations.
If the EPA CO has any questions about the work plan, the RPM should be
prepared to address these questions in order to make the work plan acceptable. In those
instances where modifications to the work plan are necessary, the RPM should discuss
the needed revisions with the contractor.
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EXHIBIT 3-9
Approval and Implementation of the Contractor Work Plan
ORIGINATOR
DOCUMENTATION
RECIPIENT
RPM/RPO
y.
EPA
CONTRACTING
OFFICER
(APPROVE OR RETURN TO
RPM/RPO FOR MODIFICATION)
CEPA
CONTRACTING
OFFICER
APPROVED
WORK
PLAN
REM CONTRACTOR
EXECUTES APPROVED
WORK PLAN
KEY:
RPO - REGIONAL PROJECT OFFCER
RPM . REMEDIAL PROJECT MANAGER
3-29
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ADDITIONAL SOURCES OF INFORMATION
CERCLA Enforcement Attorney's Manual. OECM, April 1984.
Community Relations in Superfund: A Handbook Draft, OERR, March 1986. (OSWER
Directive 9230.0-3A)
Cost Recovery Actions Under the Comprehensive Environmental Response. Compensation.
and Liability Act of 1980 (CERCLA). OEC and OSWER, August 26,1983.
Data Quality Objectives Development Guidance for Uncontrolled Hazardous Waste Site
Remedial Response Activities. Draft, OSWER, October 1986 (OSWER Directive 9355.0-7A)
Field Standard Operating Procedures (FSQP^ Manual. (OSWER Directive 9285.2)
Guidance on Feasibility Studies Under CERCLA.OERR. and OWPE, June 1985. (OSWER
Directive 9355.0-5C)
Guidance on Remedial Investigations Under CERCLA OERR and OWPE, June 1985.
(OSWER Directive 9355.0-6B)
Guidelines and Specifications for Preparing Quality Assurance Project Plans for National
Program Offices. Quality Assurance Management Staff, May 10,1985.
Instructions on Budget Execution. OMB Circular A-34.
Intergovernmental Review of Environmental Protection Agency Programs and Activities, Final
Rule (40 CFR Part 29).
Intergovernmental Review of Superfund State. Federal, and Enforcement Lead Remedial
Projects. OERR, November 30, 1983.
National Enforcement Investigation Center (NEIC) Policies and Procedures ManuaJNEIC.
February 1983.
"Procedures for Documenting Costs for CERCLA 107 Actions", January 1985.
"Procedures for Issuing Notice Letters," OWPE, October 12,1984.
"Remedial Financial Management Instructions," AA/OSWER, September 21, 1984. (OSWER
Directive 9275.2-1)
Superfund Exposure Assessment Manual. Draft, January 1986. (OSWER
Directive 9285.5-1)
Superfund Public Health Evaluation Manual. Draft, December 1985. (OSWER
Directive 9285.4-1)
State Participation in the Superfund Program Volume I, OERR, February 1984. (OSWER
Directives 9375.1-4)
Superfund State-Lead Remedial Project Management Handbook OERR. December 1986.
(OSWER Directive 9355.2-1)
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"Timely Initiation of Responsible Party Searches, Issuance of Notice Letters, and Release of
Information," OWPE, October 9, 1985.
Work Assignment Procedures for Remedial Contracts OERR, November 1986. (OSWER
Directive 9242.3-3A)
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4. REMEDIAL INVESTIGATION/FEASIBILITY STUDY
The Rl and FS are interdependent processes. The activities conducted during
the Rl and FS generally are performed concurrently, with each project influencing the
execution of the other. The Rl largely involves data collection, data analysis, and site
characterization, while the FS emphasizes alternatives evaluation and decision-making.
During the Federal-lead RI/FS project, a REM contractor conducts the various
activities necessary to characterize the hazardous waste site and to evaluate
alternatives to remedy the situation. The RPM oversees the REM contractor to ensure
that all RI/FS activities are conducted in an effective and timely manner, and in
accordance with relevant EPA policies and regulations. While the previous chapter
emphasized the activities required to plan and initiate an RI/FS project, this chapter
describes the RPM's duties required to ensure that the RI/FS is completed as specified
in the work assignment SOW and approved work plan. This chapter is divided into five
major sections dealing with RPM activities during the RI/FS:
Ongoing project management
Site characterization
Alternatives screening and evaluation
Review and approval of the RI/FS Report(s)
RI/FS closeout.
Exhibit 4-1 depicts the concurrent activities of the Rl and FS processes. Detailed
information on the Rl and FS processes can be found in two key guidance documents:
Guidance on Remedial Investigations Under CERCLA, June 1985
(called the Rl Guidance)
Guidance on Feasibility Studies Under CERCLA, June 1985
(called theFS Guidance).
These documents provide detailed assistance for the overall Rl and FS processes.
Individual site conditions govern the extent of data collection and analysis for each Rl
and FS activity, and review of specific options is beyond the scope of this handbook.
The reader is encouraged to rely heavily on the Rl Guidance and the FS Guidance in
conducting this phase of the remedial response project.
4.1 ONGOING PROJECT MANAGEMENT ACTIVITIES
Oversight and management of a Federal-lead RI/FS project require a number of
project management activities. Many are common to all phases of the remedial process.
Those for the RI/FS are outlined below.
4-1
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EXHIBIT 4-1
Remedial Investigation/Feasibility Study (RI/FS)
CONTRACTOR
(OR USAGE)
FROM INITIAL
PROJECT
PLANNING
AND START-UP
ACTIVITIES
EPA
ONGOING PROJECT MANAGEMENT, ENFORCEMENT,
AND SUPERFUND COMMUNITY RELATIONS ACTIVITIES
4-2
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4.1.1 Technical Progress Oversight
Oversight of technical progress is one of the main responsibilities of the RPM
during performance of the RI/FS. The RPM should firmly establish lines of
communication with the contractor and should identify key project milestones. The RPM
should monitor and guide the progress of the RI/FS including the financial and schedule
aspects of the project. The attainment of project milestones can be monitored in the
following ways:
Conduct site visits to ensure that reported progress has been
accomplished
Review progress reports, payment vouchers, and work products carefully
to ensure compliance with the technical, financial, and schedule
commitments
Communicate frequently with the contractor by telephone and through
periodic meetings.
The RPM should attempt to anticipate problems, especially those affecting major
milestones. Should problems occur, the RPM should work with the contractor to
develop solutions. Also, the RPM should inform the contractor of changes in EPA policy
that impact performance of the RI/FS.
Some control by EPA and the RPM over contractor performance is made
possible through the Award Fee process. By keeping ongoing records of contractor
strengths and weaknesses during performance of RI/FS activities, the RPM develops the
basis for Award Fee determinations. Description of the Award Fee process is provided
in EPA's REM1I Contract Award Fee Performance Evaluation Plan, July 1985.
4.1.2 Preparation and Processing of Work Assignment Amendments
Work assignment amendments are generally required if there are major changes
in the technical direction, the schedule, or the amount of resources required to complete
the project. The RPM should use progress reports and meetings to track the technical
and financial status of the project. In this way, the RPM can anticipate the need for work
assignment amendments and avoid project delays. The RPM has the following work
assignment amendment responsibilities:
Discuss potential amendments with the contractor
Seek innovative ways to control costs
Ensure that the amendment is consistent with the approved
SCAP
Approve and process the contractor Work Assignment
Amendment Package, and forward the package to the RPO
Maintain the signed copy of Work Assignment Amendment
Package in the Regional project file.
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The procedures for preparing and processing a work assignment amendment are
shown schematically in Exhibit 4-2. In general, a work assignment amendment request
should be initiated for each modification needed. However, in the case of minor
modifications, several may be combined into one amendment.
4.1.3 Coordination with State
Throughout the RI/FS process, the RPM should coordinate with State officials to
inform them of site progress and to receive their input. Under SARA, the State's role in
the remedial response program has been formalized and EPA/State coordination is
mandatory. For example, the RPM should:
Modify appropriate agreements with the State when there are
significant changes in the scope of work
Submit periodic progress reports for State review
Invite State officials to participate in site visits
Oversee State involvement if the State has entered into a
Cooperative Agreement for management assistance
Coordinate State review of RI/FS Reports
Ensure the State's involvement with community relations
activities.
As the RI/FS process is completed, the RPM must initiate the intergovernmental review
process and prepare to amend appropriate agreements with EPA which relate to the
next phase of the cleanup. For further information on the State's involvement in
Federal-lead remedial projects, consult the State Manual.
4.1.4 Data Reporting and Record Keeping
Throughout the RI/FS process, the RPM is responsible for maintaining thorough,
accurate records. These assist project management and provide documentation for
future cost recovery actions, as well as possible external audits. In addition, the
Superfund Amendments require EPA to establish an administrative record upon which
the selection of a response action will be based. The record must be available to the
public at or near the site. Also, the RPM may need to supply information for updating
EPA's automated data management systems.
The RPM must maintain site files, including documentation that will support cost
recovery actions. The type of information needed for cost recovery is described in Cost
Recovery Actions Under CERCLA , August 1983, and Procedures for Documenting Costs
for CERCLA 107 Actions, January 1985. The latter manual also presents a suggested
file structure. Examples of documentation relevant to the RI/FS that should be
maintained include:
Contractor work plans and progress reports
On-site logs, notes, and manifests
Analytical laboratory reports
Rl report
Alternatives evaluation reports.
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EXHIBIT 4-2
Work Assignment Amendment Procedures
ORIGINATOR
DOCUMENTATION
RECIPIENT
RPM
7
WA
AMENDMENT
PACKAGE
KEY:
RPO - REGIONAL PROJECT OFFICER
RPM - REMEDIAL PROJECT MANAGER
WA - WORK ASSIGNMENT
4-5
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For additional assistance in maintaining documentation, the RPM should consult the
data management chapter of the/?/ Guidance and Appendix U of the State Manual. At
the completion of the RI/FS, EPA Regional enforcement staff members may ask the RPM
to assist in preparing a Cost Recovery Summary.
Periodically, the RPM must become involved with reviewing or updating
information developed for use in one of EPA's automated data systems. The following
are the major systems of concern, along with relevant RI/FS input/review requirements:
CERCLIS (CERCLA Information System^- combines the
Emergency and Remedial Response Information System (ERRIS)
and Project Tracking System (PTS) and is used to track major
accomplishments at candidate and actual NPL sites. Activity start
and completion dates for RI/FS must be entered. The RI/FS start
date is when funds are obligated. The Rl completion date is when
the final Rl Report is submitted to EPA, or when validated data are
received from the contractor. The FS completion date is when the
ROD is signed. (When the RI/FS is funded as one project, there is
one completion date.)
SCAP -- is the official document from which the AA/OSWER
identifies funding needs for proposed Superfund activities.
Activities must be on the approved SCAP to receive funding. The
RPM should coordinate with the Regional SCAP contact to ensure
that information provided is accurate and adequate for determining
site funding needs. Particular attention must be given to ensure that
RD activities are identified on the SCAP before the estimated RD
start date.
FMS (Financial Management System) -- is used by the Office of
Emergency and Remedial Response (OERR) Funds Control Center
to prepare monthly and ad hoc financial status reports on the
remedial program. RPMs may be asked to review these reports for
accuracy.
Additional guidance is available for each of the above systems. Regional contacts or
Headquarters staff responsible for each data system can supply these documents and
can provide additional guidance as needed.
4.1.5 Coordination with Other Regional Staff
Throughout the course of the RI/FS, the RPM must maintain close contact with
both Regional enforcement and community relations staffs. The RPM's role is that of a
project advocate and facilitator. The RPM should use the project plan and schedule to
integrate/control the input/activities of others into the overall project. Coordination with
enforcement staff can involve the following actions:
Transmit any information discovered during the RI/FS that helps
identify PRPs
Review schedules of PRP negotiation windows
Assist with the preparation of Notice Letters to PRPs
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Ensure security of any confidential information obtained during
the RI/FS
Participate in negotiations with PRPs following completion of the
RI/FS.
Coordination with community relations staff during the RI/FS may involve the following
activities:
Participate in public meetings
Develop fact sheets
Schedule and coordinate public comment period following FS
draft report completion.
Community relations activities are discussed in Community Relations in Superfund: A
Handbook, Draft, March 1986. The RPM should also maintain close coordination with
the Office of Regional Counsel and other appropriate Regional staff. At sites where a
removal action has taken place, coordination with emergency response personnel is
crucial. (OERR is currently developing guidance for remedial projects requiring an
emergency response.)
4.1.6 U.S. Army Corps of Engineers Technical Assistance
For Federal-lead sites, the USAGE will provide technical assistance to EPA,
upon request, during the RI/FS. Assistance from the USAGE during the RI/FS serves
two purposes:
Assures that proposed remedial actions can be engineered and
constructed
Assures a smooth transition of the site to the design and construction
stages, which the USAGE typically leads.
Types of review assistance activities that may be requested include:
Review of work assignments, work plans, or subcontracting packages
Participation in project review meetings
Technical review of reports, plans, and specifications.
The USAGE also may become much more involved in projects that require specialized
technical expertise, such as those projects that involve dredging.
Technical assistance from the USAGE is obtained through Interagency
Agreements. Generic lAGs for technical assistance during RI/FS projects should be
executed by the Regions with the USAGE Missouri River Division (MRD). To obtain
technical assistance for a specific RI/FS project, the RPM must prepare and issue a site-
specific work assignment to USACE-MRD under the established IAG. The RPM should
ensure that funds for technical assistance lAGs are reflected in the SCAP for the
appropriate quarter. Current EPA procedures and sample IAG forms are provided in
Appendix E.
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4.1.7 Agency for Toxic Substances and Disease Registry Health Assessments
Under the Superfund Amendments, ATSDR has been charged to conduct health
assessments at NPL sites. ATSDR, in consultation with EPA, must set priorities for
health assessments at NPL sites based upon potential risk to human health and
adequacy of existing data, recognizing also EPA's NPL and RI/FS schedules. To the
extent practicable, ATSDR should complete assessments before RI/FS completion.
ATSDR health assessments do not supersede risk assessments and/or endangerment
assessments conducted by EPA during the RI/FS.
Details and procedures for coordinating ATSDR's health assessment activities
into the Superfund remedial process have not been finalized. However, it may be
assumed that the RPM will be responsible for coordinating with ATSDR to facilitate
information exchange and project completion.
4.2 SITE CHARACTERIZATION
Site characterization is one of the main functions of the Rl process. The objective
of site characterization is to collect and analyze sufficient information to determine the
need for remedial actions, the extent of any remedial action, the feasibility of remedial
action alternatives, and conceptually plan the remedial action. Site characterization
activities provide the data to support the evaluations made in the concurrent FS.
Typically, site characterization involves collecting existing data concerning a site (part of
Rl scoping), collecting new data through field studies, and following up initial field
studies with additional investigations, if required, to complete site characterization.
The RPM must actively oversee site characterization activities to the extent
necessary to be confident that the contractor meets the objectives of the project. The
RPM also must be assured that all activities are conducted in accordance with approved
work plans and with EPA policy and regulations.
4.2.1 Rl Scoping
Rl scoping involves gathering and reviewing all existing site data to characterize
the site and to determine additional data needs, including the need for bench or pilot
studies. Rl field studies are then designed to collect information to fill these gaps. Rl
scoping is conducted prior to work plan development. The RPM's responsibilities during
Rl scoping have been discussed in Chapter 3 of this handbook.
4.2.2 Reid Activities
The RPM should take an active role in oversight of field activities. Periodic site
visits should be conducted to observe such activities as well drilling, sample collection,
and sample shipment. Field activities must be conducted according to approved plans,
with particular emphasis on the QAPP and site safety plan. The RPM may be able to
obtain technical support for overseeing field activities from other offices within EPA.
Three common problems that cause project delays during this phase of the Rl
are:
Inadequate experience in contractor or subcontractor personnel
impacting technical performance
4-8
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Timeliness of analytical support process
Sufficiency of data to support decisions on remedial action.
Discussion of these problems is presented below along with suggestions for reduction
or alleviation.
Poor technical performance by the REM contractor and subcontractors due to
inexperienced personnel can delay the RI/FS. For example, inexperience with sampling
techniques, sample quality assurance methods, and chain-of-custody procedures can
result in "lost" or unusable samples. Typical sampling errors include:
Contaminated samples
Non-homogeneous sample matrices
Incorrect sample packaging for transport
Insufficient sample volumes
Insufficiently labeled samples
Incomplete sample traffic reports.
Well drillers who normally install water supply wells or geotechnical drillers who perform
soil borings for foundation studies may cause delays because they are unfamiliar with
the special precautions, requirements, and health and safety aspects of hazardous
waste work.
The analytical support process is another potential cause of delay during site
characterization. The process includes appropriate selection of data needs (data
quality objectives), review and approval of sampling plans and QAPPs, the analysis of
samples, and the validation of results. The RPM, as the project facilitator, can take
certain actions to reduce or work around these delays:
Coordinate closely with the EPA's Regional Environmental Services
Division (ESD) regarding the timing for review of sample plans and
QAPPs, the schedule for sampling, the availability of CLP services, and
the responsibility and schedule for validation of data
Implement the concept of data quality objectives (see Data Quality
Objectives Development Guidance for Uncontrolled Hazardous Waste Site
Remedial Response Activities, Draft, October 1986, which discusses
alternative analytical approaches) to tailor the number of samples, the
types of analyses, and the level of quality assurance to the decisions that
must be made.
Other actions the RPM can take include:
Review sampling plans for the proposed approach and, for example,
request specific fractions rather than full priority pollutant scans, when
appropriate
Encourage the use of field screening and mobile laboratory units
4-9
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Utilize laboratories outside of the CLP -- REM, in-house, or
subcontract -- when needed to meet particular project requirements
and the resulting quality will be consistent with project objectives.
The discovery near the end of the FS that the data developed during the Rl are
insufficient to support an evaluation of the alternatives can cause significant project
delays. This situation is most likely to occur when a single sampling event is used or
when sample turn-around time is great. This situation also can result from the taking of
too few samples in an attempt to reduce Rl costs. In either case, not fully knowing the
extent of contamination or finding some last-minute surprise can have serious impacts
on the FS schedule. For this reason, the use of the phased RI/FS approach is strongly
encouraged. This approach, already mentioned in Chapter 3, can be briefly described
as: (1) early screening of alternatives to help define data needs and the scope of the Rl,
(2) multiple sampling and analysis events, each contributing subsequent definitions of
data needs, and (3) the use of analytical alternatives (such as field screening) to more
quickly determine subsurface conditions.
4.2.3 Supplemental Rl Data Needs
The RPM must carefully review the data and meet with the REM contractor at the
earliest opportunity to determine the need for further sampling. This review process
should be initiated at the sample collection or field analysis stage. If additional work is
needed, it must be done with minimal overall schedule impact. The RPM and the
contractor must determine the following:
Are the validated data sufficient to meet the objectives of the Rl?
Are the validated data adequate for purposes of remedial
alternatives evaluation?
Can +50%, -30% cost estimates for remedial alternatives be developed?
Are the validated data sufficient to support enforcement or cost
recovery actions?
If not, the RPM and the REM contractor must develop an approach for collecting
additional data to complete the site characterization.
It also may be determined that bench studies are necessary to further
characterize a site or to evaluate potential remedies that have survived the screening
process. (Bench studies also may be conducted as part of the RD.) If bench studies are
required, the contractor must develop a tentative experimental plan as part of the Rl
statement of work. In some cases, the bench study work plan cannot be finalized until
some Rl data are available. Also, the bench studies generally should be limited to
alternatives that have survived the screening process. Objectives of the study must be
clearly specified. The RPM should coordinate the review of the experimental plan to
ensure that the following are present:
Clearly defined set of objectives
Detailed work plan by task
Completion schedule
Labor cost estimates.
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4.3 ALTERNATIVES SCREENING AND EVALUATION
Alternatives screening and evaluation is the foundation of the feasibility study
portion of the RI/FS. Using site-specific data from the pre-RI and the Rl activities,
remedial alternatives within the general response categories* are developed and
evaluated in terms of:
Technical feasibility
Environmental impacts
Public health impacts**
Institutional impacts
Costs.
The screening of alternatives is a multi-stage process that begins early during the
course of the Rl. The reader is encouraged to review the more detailed discussions in
the Rl Guidance and the FS Guidance.
The RPM provides input at several points in the alternatives screening and
evaluation process in order to ensure that a reasonable selection of alternatives is
considered. "Reasonable" implies not looking at the whole universe of alternatives to
the detriment of the cost and schedule of the FS, while at the same time not examining
so few alternatives that viable options are not considered. Generally, the RPM provides
input to the process during:
Rl scoping and development of response objectives
The Rl, as data become available
The pre-FS meeting, where the Rl results are reviewed and the
FS scope is established
The FS, as alternatives are evaluated in detail.
The RPM needs to develop a sense of what technologies are currently available and
appropriate for application at the site, while also staying knowledgeable of the emerging
technologies that are becoming available. The RPM also should be cognizant of
statutory and policy changes that may affect technology selection. For example, the
Superfund Amendments place greater emphasis on the long-term protection and
reliability of remedial actions. SARA calls for remedial actions that utilize permanent
solutions and alternative treatment or resource recovery technologies to the maximum
extent practicable. If a remedy in accordance with the preference for treatment and
permanent solutions is not selected, an explanation must be published.
For a discussion of general response categories, consult the FS Guidance and Chapter 3
of this handbook.
An enforcement-lead FS also must include an endangerment assessment, which is similar
to a public health impact analysis, but involves more formal documentation needed to
support an enforcement case; consult the FS Guidance for further information.
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4.3.1 Technical Oversight During Feasibility Study
The RPM must ensure that feasible remedial alternatives are given proper
consideration, are presented in a fashion amenable to decision-making, and are
evaluated on schedule by the contractor. The RPM should arrange for periodic
meetings with the contractor, State, and possibly the USAGE, (including the pre-FS
meeting) to discuss progress, to identify types of alternatives, to highlight possible
issues, to plan the RI/FS review, and to identify any additional data needs, including
bench and pilot studies.
4.3.2 Compliance with Other Environmental Statutes
As a general rule, the Agency's policy has been to attain or exceed applicable or
relevant and appropriate environmental and public health standards in CERCLA
response actions, unless specific mitigating circumstances exist. (See " CERCLA
Compliance With Other Environmental Statutes," October 2, 1985, and the National Oil
and Hazardous Substances Pollution Contingency Plan, November 20, 1985.) The
Superfund Amendments now require that remedial activities conducted on-site shall
meet the applicable or relevant and appropriate standards, limitations, criteria, and
requirements (ARARs) of State and Federal environmental laws. The Superfund
Amendments basically build upon EPA's site-specific approach to clean-up standards
found in VneNCP. Of particular importance to the Superfund program are the Resource
Conservation and Recovery Act (RCRA) regulations pertaining to land disposal bans.
The RPM must stay abreast of new developments in this area. The RPM must be aware
of new policy developments. This can be done by reviewing ROD abstracts and
updates, and by communicating with the Headquarters Regional Coordinator.
In general, as part of the FS, at least one alternative for each of the following
categories should be evaluated within the requirements of theFS Guidance and be
presented to the decision-maker:
Alternatives for treatment or disposal in an off-site facility, as
appropriate (See "Procedures for Planning and Implementing Off-
site Response Actions," May 6,1985).
Alternatives that attain applicable or relevant and appropriate
Federal or State public health or environmental requirements.
As appropriate, alternatives that exceed applicable or relevant and
appropriate public health or environmental requirements.
Alternatives that do not attain applicable or relevant and
appropriate public health or environmental requirements but will
reduce the likelihood of present or future threat from the
hazardous substances and that provide significant protection to
public health and welfare and the environment. This should be
an alternative that closely approaches the level of protection
provided by applicable or relevant and appropriate requirements.
A no action alternative.
The RPM is responsible for ensuring that the FS addresses each of the above
categories of alternatives, where appropriate. It may be necessary to inform the REM
contractor of applicable or relevant and appropriate standards. State representatives
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should advise the RPM of any State requirements or standards as early in the process
as possible.
The FS, and ultimately the decision documents, must state the reasons in
situations where the chosen remedial alternative does not attain or exceed the
applicable or relevant and appropriate standards. The RPM must ensure that this
requirement is addressed and should seek advance concurrence from AA/OSWER for a
waiver from consistency with other environmental laws.
4.3.3 ROD Delegation
In a March 24, 1986 memorandum, "Delegation of Remedy Selection to Regions,"
the Administrator set forth current policy for delegation of the selection of remedy
responsibility to the Regional Administrators (RAs) on a site-specific basis. All site
remedy selections will be delegated unless the circumstances below exist:
Potential fund balancing (where the total cost of all site response
is expected to exceed $40 million)
Precedent-setting or nationally significant circumstances.
In the event that the decision-making authority is delegated, consultation with
the AA/OSWER is required for sites involving:
Ground-water contamination due to multiple sources
Betterment (when the State's preferred remedy is more
expensive than the cost-effective alternative)
Precedent-setting or other nationally significant circumstances.
To determine whether it is appropriate to delegate the remedial alternative
selection, the RA submits a quarterly letter to the AA/OSWER recommending which
selections should be delegated, which will require AA/OSWER consultation, or which
should be retained by the AA/OSWER. The letter should include the criteria for the
recommendation. Delegation letters can be prepared as early as Rl completion, but
should be submitted before the FS Report goes out for public comment.
The RPM may be asked to prepare the delegation letter and transmit it to the
appropriate Regional personnel, particularly ORC, for review. The letter, signed by the
RA, is then submitted to Headquarters (AA/OSWER with a copy for the Regional
Coordinator). Upon receipt of a letter of recommendation, OERR will promptly evaluate
RA recommendations and prepare for AA/OSWER signature a ROD delegation
memorandum that lists sites for which remedy selection has been delegated. The
memorandum will be sent to RAs at least one week before the new quarter begins.
If delegation with consultation is granted, the RPM will forward the ROD package
or summary of the key issues to OSWER for consultation prior to ROD signature by the
RA. Consultation can begin with a final draft FS Report prior to public comment or can
occur immediately prior to ROD signature. Consultation generally should begin
between the RPM and the Headquarters Regional Coordinator and end with a final
request by the RA and a response by the AA/OSWER or his designee.
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4.4 REVIEW AND APPROVAL OF RI/FS REPORT(S)
The RI/FS Report(s) is the final product of the RI/FS process. It summarizes the
findings of the Rl and clearly presents the alternatives and the results of their evaluation.
It is the RPM's responsibility to ensure that the report(s) is complete and is presented in
a format that facilitates the ROD process. The RPM must also coordinate the review and
approval of the report(s). To accomplish these activities the RPM should:
Meet with the REM contractor to discuss report format and contents
Coordinate report reviews with the State
Coordinate report reviews with appropriate EPA personnel
(Regional and Headquarters)
Coordinate report reviews with the USAGE, as appropriate
Ensure that enforcement staff initiates the 60- to120-day PRP
negotiations moratorium at the time when the draft RI/FS Report is
received
Coordinate with community relations personnel to initiate the two-
week notice period and make the draft report available for the
three-week public comment period
Ensure the initiation of intergovernmental review for RD/RA
Coordinate the review and approval of the final RI/FS Report.
Information regarding RI/FS Report content and format is presented in the/?/ Guidance
and the FS Guidance. To ensure a timely review, the RPM should frequently remind
reviewers of schedule commitments, hold review meetings, and take other actions to
actively manage the review process.
4.5 RI/FS CLOSEOUT
Following completion of all work as specified in the work assignment and the
approved work plan, including the Pre-Design Report (see Chapter 6), the REM
contractor is responsible for notifying the RPM that the project can be closed. The RPM
then prepares and processes the required project close-out documentation. This
documentation includes:
Work assignment completion report
Work assignment form, indicating completion notification
Final completion voucher.
In practice, the final closeout is often delayed because of late receipt of subcontractor
invoices. Further information on project closeout is given in Work Assignment
Procedures for Remedial Contracts, November 1986.
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4.5.1 Work Assignment Completion Report
The Work Assignment Completion Report (WACR) is a three-page form that
describes the contractor's performance on the work assignment. Separate copies are
completed by both the contractor and the RPM. The WACR package then becomes part
of a subsequent Award Fee evaluation package. The RPM's responsibilities are as
follows:
Ensure that the contractor submits a WACR immediately upon
notification of completion of the project
Ensure that WACRs are filled out properly:
Do they identify trends or recurring difficulties relating to
the areas in which performance can be improved in future
assignments?
Do they address performance with respect to project
planning, technical activities, schedule and cost control,
reporting, and resource utilization and effort?
Prepare a WACR for each completed work assignment
Obtain the signature and approval of the EPA RPO on each WACR.
This also involves coordinating with the RPO and Regional
management in recommending a percentage of the Phase II Award
Fee
Submit copies of all WACRs to the Headquarters Project Officer or
Deputy Project Officer for review and use in determining Award Fee
recommendations
Solicit input from Regional, State, or other personnel involved with
the site in completing the WACR.
The RPM should contact the contractor Site Manager to discuss any problems that occur
in the preparation and submission of the WACR.
A copy of a WACR is shown in Appendix D. Additional information on the WACR
can be found in EPA's REMII Contract Award Fee Performance Evaluation Plan,
July 1985.
4.5.2 Work Assignment Closeout
The work assignment form indicating completion notification is initiated by the
REM contractor site manager and submitted to the RPM. The RPM is responsible for
sending the work assignment form back to the contractor who is then responsible for
submitting copies to EPA Headquarters. The RPM should also retain a copy of the form
for the Regional files.
Another important aspect of RI/FS closeout is the REM contractor's compilation of
the site files prior to their submittal to EPA. At this time, the exact procedures and
requirements for this activity are not yet determined. Contact the Headquarters Regional
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Coordinator or REM Deputy Project Officer for guidance (or assistance) in file
preparation.
4.5.3 Final Invoice
The final invoice for the project is submitted by the contractor to the RPM for
review, when available. In some cases, the invoice may be delayed until final
subcontractor invoices are received. Any problems with the final invoice should be
discussed with the contractor site manager as soon as they are identified. Signing the
invoice indicates that all work for which payments are claimed has actually been
performed. The RPM then forwards the final invoice to the RPO for signature.
ADDITIONAL SOURCES OF INFORMATION
"CERCLA Compliance with Other Environmental Statutes," AA/OSWER, October 2, 1985.
(OSWER Directive 9234.0-2)
Community Relations in Superfund: A Handbook Draft, OERR, March 1986. (OSWER
Directive 9230.0-3A)
Cost Recovery Actions Under the Comprehensive Environmental Response. Compensation.
and Liability Act of 198Q (CERCLAY OEC and OSWER, August 26,1983.
Data Quality Objectives Development Guidance for Uncontrolled Hazardous Waste Site
Remedial Response Activities. Draft, OSWER, October 1986. (OSWER Directive 9355.0-7A)
"Delegation of Remedy Selection to Regions," AA/OSWER, March 24,1986. (OSWER
Directive 9260.1-9)
Field Standard Operating Procedures (FSOP) Manual (OSWER Directive 9285.2)
Guidance on Feasibility Studies Under CERCLA. OERR. and OWPE, June 1985. (OSWER
Directive 9355.0-5C)
Guidance on Remedial Investigations Under CERCLA OERR and OWPE, June 1985.
(OSWER Directive 9355.0-6B)
National Oil and Hazardous Substances Pollution Contingency Plan (47 FR 31180),
November 20, 1985.
"Procedures for Documenting Costs for CERCLA 107 Actions", January 1985.
"Procedures for Planning and Implementing Off-Site Response Actions," AA/OSWER,
May 6, 1985. (OSWER Directive 9330.2-1) (supplemented by 9330.2-3)
"REM II Contract Award Fee Performance Evaluation Plan," OERR, July 1985. (OSWER
Directive 9242.3-5)
Standard Operating Safety Guide Manual. OERR, November 1984. (OSWER
Directive 9285.1-1B)
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State Participation in the Superfund Program Volume I, OERR, February 1984. (OSWER
Directive 9375.1-4)
Superfund Exposure Assessment Manual. Draft, January 1986. (OSWER
Directive 9285.5-1)
Superfund Public Health Evaluation Manual. Draft, December 1985. (OSWER
Directive 9285.4-1)
User's Guide to the EPA Contract Laboratory Program. OERR, July 1984. (OSWER
Directive 9240.0-1)
Work Assignment Procedures for Remedial Contracts. OERR. November 1986. (OSWER
Directive 9242.3-3A)
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5. RECORD OF DECISION AND TRANSITION TO DESIGN
Preparation and approval of the Record of Decision are crucial steps in the
remedial process. A ROD is required for all remedial actions financed with monies from
the trust fund. The ROD documents the Agency's remedial alternative decision-making
process and demonstrates that the requirements of CERCLA, SARA, and the NCP have
been met. The ROD also provides the basis for future cost recovery actions that may be
taken with regard to site remediation under these requirements.
The RPM has an extremely important role during the ROD process and the
transition to design. The RPM, in a sense, engineers the ROD process which bridges the
site characterization and alternatives evaluation of the RI/FS to the design and
implementation of the remedial action. The activities that take place during this phase
are shown in Exhibit 5-1. This chapter describes the activities of the RPM and others
during the ROD process and the transition to design. These include:
Ongoing project management
The ROD process (preparation through approval)
Transition to remedial design.
Additional guidance on ROD procedures can be found in Preparation of Decision
Documents for Approving Fund-Financed and Potentially Responsible Party Remedial
Actions Under CERCLA, February 27, 1984, hereafter referred to as the/?(9D Guidance).
The RPM must work closely with the representative from ORC assigned to the
project in coordinating the preparation, review, and approval of the ROD. The project
attorney assures the legal sufficiency of the Regional ROD process, the administrative
record, and the ROD document itself, while the RPM focuses more on the technical
aspects of the project and compliance with program policy.
Many Regions are now using a ROD Project Team concept, which has proven to
be successful. For example, an effective ROD Project Team would consist of the RPM
and representatives of the following:
RI/FS contractor
State
ORC
Enforcement program
Other relevant EPA programs.
By including all these members in a team, the ROD process can be greatly expedited,
since relevant concerns are uncovered early and can be resolved quickly.
Support from the Headquarters Regional Coordinators is generally available on
the larger, more complex sites. Headquarters personnel may participate in initial
scoping and pre-RI/FS meetings on a site-by-site basis. The Regions are encouraged to
enlist Headquarters support on projects with unusual issues or high priority, in particular,
those projects where the AA/OSWER's signature is likely on the ROD.
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EXHIBIT 5-1
Record of Decision (ROD) and Transition to Design
CONTRACTOR
(OR USAGE)
FROM
RI/FS
TORD
_
J
RESPOKSIVENEBS
SUHMHXt
EPA
FINAL
SX3W
TO USAGE
APPROVED
ROD
[ WACR J
Enevisee ]
Wmwwrt I
fta*TOKJI>UH J
ENFORCEMENT NEGOTIATIONS
AND ADMINISTRATIVE ORDERS
LEGEND:
ACTIVITY
DOCUMENT
5-2
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5.1 ONGOING PROJECT MANAGEMENT ACTIVITIES
During the course of the ROD process, there are a number of ongoing project
management activities that are necessary to ensure a smooth process and transition
from RI/FS to RD. These are outlined below.
5.1.1 Coordination with State
Throughout the ROD process, the RPM should coordinate with State officials to
inform them of progress and to receive their input. A State representative also can be a
member of the ROD Project Team. Specifically, the RPM should:
Modify any agreements with the State for RD
Involve the State in the remedy selection
Solicit State comments on the draft ROD, Responsiveness
Summary, and supporting documentation
Invite State officials to participate in pre-ROD briefings
Ensure State (60-day) intergovernmental review for RD (occurs during
public comment period on the draft RI/FS Report); if a formal
intergovernmental review process has not been established, or if the
process does not include the Superfund program, the RPM must
forward copies of the draft RI/FS Report to appropriate State officials.
Most importantly, the RPM must obtain the State's concurrence on the recommended
alternative. This should be documented in a letter from the appropriate State official to
the Regional Administrator. The RPM should inform State officials that the State must
make assurances to meet all statutory cost-share requirements. The State cost share is
not due until the remedial action is implemented. The State also must make an
assurance of the availability of an off-site disposal facility, if it is part of the remedy.
The Superfund Amendments add two assurances the State must make:
Effective October 17, 1989, EPA will not fund any remedial actions
requiring the use of treatment or disposal facilities unless the State enters
into a contract or CA assuring that it has adequate capacity for the
destruction, treatment, or secure disposition of all hazardous wastes
(including Superfund wastes) expected to be generated in the 20-year
period following the date of the assurance
If the remedy involves the acquisition of real property by EPA, the State
must make an assurance to accept transfer of the property in order to
allow completion of the remedial action.
Guidance is pending on both of these new assurances.
5.1.2 Data Reporting and Record Keeping
During the ROD process, the RPM must maintain full documentation of all site
data and must pay particular attention to any confidential information that, if released,
may compromise EPA's ability to negotiate with potentially responsible parties.
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Generally, any information that is used in the selection of remedy deliberations is
discoverable. Documents relevant to this phase of the remedial process include:
ROD Delegation Analysis Summary
Responsiveness Summary
Intergovernmental review comments
State concurrence letter
Final ROD.
These basic documents will be included in the Administrative Record required by SARA.
In addition, all written correspondence concerning the ROD process should be kept, as
well as written documentation of any important conversations.
The RPM must ensure that the approved SCAP budget includes sufficient funding
to cover the costs of the RD for the selected remedy. The RPM should also look beyond
to the remedial action funding needs at this time.
The CERCLA Information System data management system must also be
updated to include information relevant to the ROD process. Planned ROD start dates for
all sites with expected RD obligations during the upcoming fiscal year should be entered
at the time of the final SCAP submittal. Additionally, actual ROD start and completion
dates are to be entered. The ROD start corresponds to the date that the FS Report goes
out for public comment, and the ROD completion date corresponds to the date that the
ROD is signed by the RA or the AA/OSWER. The RPM should ensure that accurate
information is transmitted to the Regional contact working with the CERCLIS system.
5.1.3 Coordination with Regional Staff
During the ROD process, it is important that the RPM coordinate closely with key
Regional staff members on the planning of the ROD, the resolution of issues, and the
schedule for ROD signature. These staff members and their roles during the ROD
process are described below:
Enforcement (Office of Waste Programs Enforcement staff and/or their
counterparts) may be actively identifying or negotiating with PRPs to
conduct the remedial action. The RPM must maintain close
communications with enforcement staff so as not to compromise their
position nor duplicate their efforts. If EPA decides to negotiate with
PRPs for the RD and RA, SARA stipulates that another special notice,
apart from the public notice, must be sent to the PRPs, the State, and
Natural Resource Trustees. Notice for RD/RA negotiations should be
given as early as possible, but no later than when EPA has identified
a preferred alternative. Again, as with the RI/FS procedure, the PRPs
have 60 days to make a good faith proposal to conduct or finance the
RD and RA. During this time, EPA must not begin remedial action, but
may initiate design activities. If PRPs do not submit a good faith
proposal within 60 days of notice receipt, EPA may proceed with a
fund-financed RA. If a good faith proposal is submitted, the
moratorium continues for 120 days from the date of notice while EPA
evaluates the proposal.
Regional Counsel is responsible for ensuring that all enforcement -
sensitive issues are properly presented and that the requirements of
CERCLA, SARA, theAO*. and other environmental laws and
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regulations have been met. The ORC must concur on the ROD before
it is presented for approval. ORC will be directly involved in
negotiations with PRPs.
Resource Conservation and Recovery Act Program staff must review
the ROD for an off-site remedial action involving the treatment,
storage, destruction, or disposal of hazardous wastes to ensure
consistency with RCRA regulations and technical standards. The
RPM should refer to the recent off-site policy, "Procedures for Planning
and Implementing Off-Site Response Actions," May 6, 1985. (For on-
site actions, the RPM may conduct this review.)
Community Relations staff should verify that all community relations
plan activities regarding public comment on the RI/FS are complete.
The RPM should coordinate with community relations staff when
preparing the Responsiveness Summary and provide input to the
revised CRP based on the approved ROD.
Other Regional Program staff, from such programs as the Office of
Drinking Water and the Office of Pesticides and Toxic Substances,
should verify that the recommended remedy is consistent with other
environmental statutes, regulations, or program activities.
5.1.4 Coordination with Headquarters and Other Interested Parties
Headquarters involvement with the ROD process will vary depending on whether
ROD-approval authority has been delegated to the RA (see Section 4.3.3 in the previous
chapter) and on the complexity of technical and policy issues regarding the site. In either
case, an open dialogue and exchange of information should be maintained between the
Region and Headquarters. The Headquarters role at this stage is that of a facilitator. The
primary point of contact for the RPM is the Federal-lead Regional Coordinator in the
Hazardous Site Control Division. The names and telephone numbers of Federal-lead
Regional Coordinators are given in Appendix C. Similarly, staff members from ORC
must communicate with their counterparts in Headquarters. Depending on the site-
specific situation, other Federal agencies such as the Agency for Toxic Substances and
Disease Registry, the Federal Emergency Management Agency, or the U.S. Army Corps
of Engineers may become involved in reviewing appropriate documents.
5.2 ROD PROCESS
The RPM is responsible for preparing the ROD and coordinating its review and
approval. The existing ROD process for Federal-lead sites is illustrated in Exhibit 5-2.
Each of these activities is described below with appropriate guidance for the RPM.
5.2.1 Pre-ROD Meeting
As mentioned at the end of Chapter 4, the RPM should arrange and coordinate a
pre-ROD meeting with ORC, enforcement, and other appropriate personnel to discuss
the draft RI/FS Report prior to its release for public comment. If a ROD team concept is
used, all team members should attend the pre-ROD meeting. The two purposes of this
meeting are (1) to identify data gaps in the RI/FS and (2) to develop a schedule for
completing the ROD process. Data gaps should be minimal if the RPM closely monitored
the contractor's preparation of the RI/FS. It is important to identify and begin to resolve
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EXHIBIT 5-2
The ROD Process
PRE-ROO
MEETING
(IF NECESSARY)
DRAFTRt/FS
OUT FOR
PUBLIC COMMENT
PREPARE
RESPONSIVENESS
SUMMARY
HEADQUARTERS
REVIEW FOR
CONSISTENCY
(REG. DECISION ROD)
REGIONAL AND
STATE REVIEW
AND
CONCURRENCES
SIGNED BY
RA
ROD
BRIEFING AND
APPROVAL
HEADQUARTERS
REVIEW AND
CONCURRENCES
(HQ DECISION I
SIGNED BY
AA/OSWER
ROD
COPIES TO HQ
FORNATLDIST.
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issues associated with the alternatives. A pre-ROD briefing for Headquarters staff,
convened prior to transmittal of the RI/FS Report for public comment, may be necessary
for technically complex sites or when significant policy issues exist. For example, when
the selected remedy does not attain or exceed applicable environmental standards, a
pre-ROD briefing for Headquarters staff is required.
5.2.2 ROD Package
The three elements of the ROD Package are:
ROD
Summary of Remedial Alternative Selection
Responsiveness Summary.
The following three sections describe these ROD Package elements.
In order to expedite the ROD process, as much as possible of the ROD Package
should be prepared during the public comment period. Usually, the RPM can draft most
of the ROD Package; the exception is the Responsiveness Summary. The Region may
choose to use the REM contractor staff and resources to assist in preparing the ROD
Package. Drafting the ROD Package at this time tends to clarify thinking and brings
issues to the surface.
5.2.2.1 ROD
The ROD is a short document (2-5 pages), signed by either the RA or AA/OSWER,
that officially documents the remedy selected. The ROD has three sections:
Documents Reviewed -- lists the documents reviewed in selecting
among remedial alternatives; this list would include but is not limited
to the RI/FS Report, the Summary of Remedial Alternatives
Selection, and the Responsiveness Summary
Description of Selected Remedy - describes the major components
of the remedy and operation and maintenance requirements (if
applicable)
Declarations -- documents that the decision is consistent with
CERCLA, SARA, and theNCP, that it is cost effective, and provides
adequate protection of public health, welfare, and the environment.
Concurrently with the RI/FS Report public comment period, the RPM should prepare a
draft ROD. The content and format for the ROD are described in Exhibit 5-3 (see also the
ROD Guidance). The RPM should have been reviewing previously approved RODs on
an ongoing basis. At this time, the RPM should focus on RODs with similar issues by
using the ROD key word index available in the SuperfundROD Update or ROD Annual
Report.
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EXHIBIT 5-3
Record of Decision
Remedial Alternative Selection
SITE: [Site name, location]
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents describing the analysis of cost-
effectiveness of remedial alternatives for the [site name]:
[Site name] Remedial Investigation
[Site name] Feasibility Study
Summary of Remedial Alternative Selection
Responsiveness Summary
[Other relevant reports or documentation of the remedy selection process]
DESCRIPTION OF SELECTED REMEDY
[List major components of remedy]
[List operatbn and maintenance requirements, if funding will be requested]
Note: Care must be taken to list all documents used to reach the final decision. Secondary references
included in the listed documents need not be listed here.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA), the Superfund Amendment and Reauthorization Act of 1986 (SARA), and the National Oil and
Hazardous Substances Pollution Contingency Plan (40 CFR Part 300), I have determined that the [description
of remedy] at the [site name] is a cost-effective remedy and provides adequate protection of public health,
welfare, and the environment. The State of [State name] has been consulted and agrees with the approved
remedy. [Include the following if appropriate.] In addition, the action will require future operation and
maintenance activities to ensure the continued effectiveness of the remedy. These activities will be
considered part of the approved action and eligible for trust fund monies for a period of [insert funding period
not to exceed 1 year].
I have also determined that the action being taken is appropriate when balanced against the
availability of trust fund monies for use at other sites. [Include the following sentence if remedy involves off-
site action.] In addition, the off-site transport, storage, destruction, treatment, or secure disposition [use
appropriate wording based on actual remedy] is more cost-effective than other remedial action, [include the
following if appropriate] and will create new capacity to manage hazardous waste, [include the following if
appropriate] and is necessary to protect public health, welfare, or the environment.
Note: Language for fund-balancing waivers or waivers from other environmental regulations will be worked out
on a site-specific basis.
[Include the following if appropriate.] The State [or EPA] will undertake an additional remedial
investigation/feasibility study to evaluate [describe scope of RI/FS]. If additional remedial actions are
determined to be necessary, a Record of Decision will be prepared for approval of the future remedial action.
Date Assistant Administrator
Office of Solid Waste and Emergency Response
or
Regional Administrator
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5.2.2.2 Summary of Remedial Alternative Selection
The Summary provides detailed information on the remedial alternatives
reviewed during the FS and ROD process. The Summary of Remedial Alternative
Selection must discuss:
Consistency with the Superfund Amendments § 121
No action alternative
Extent of remedy and compliance with other environmental
statutes
Cost estimates
Cost-effectiveness evaluation
Off-site transport, storage, treatment, destruction, or disposal of
hazardous wastes (if applicable) and compliance with CERCLA
§101(24)
Responsiveness Summary
Operation and maintenance.
Other topics that may be appropriate depending on site-specific conditions should also
be included in the Summary text.
5.2.2.3 Responsiveness Summary
Following completion of the public comment period, a Responsiveness Summary,
which addresses all comments submitted by the public, PRPs, and States, should be
prepared as an attachment to the ROD. The Responsiveness Summary may be
prepared by the REM contractor, but ultimately the RPM is responsible for ensuring its
accuracy and completeness. The Responsiveness Summary documents for the public
record:
Comments raised before or during the public comment period on the
RI/FS Report
How EPA considered and responded to these comments.
Further information on the format and content of a Responsiveness Summary is
presented in Appendix F. In preparing the Responsiveness Summary, the RPM should
coordinate closely with the community relations staff to obtain their input. The draft ROD
and the selected remedy may need to be revised in response to public comment.
5.2.3 Draft ROD and Responsiveness Summary Review
The State and appropriate Regional program offices must review and concur on
the draft ROD and Responsiveness Summary. The State's concurrence should be
documented in a letter from the appropriate State official to the RA. The Regional review
process should include all concerned offices, but at a minimum should include ORC and
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the enforcement staff. The RPM should also submit a copy of the draft ROD and
Responsiveness Summary to Headquarters.
The key to an efficient review process is the early involvement of the concerned
reviewers. By seeking State, ORC, enforcement, and other relevant inputs (e.g.,
Headquarters) during the RI/FS, the RPM can minimize the occurrence of last minute
issues and concerns. For RODs to be signed by the AA/OSWER, or when consultation is
required, Headquarters will usually review the draft ROD to ensure consistent decision-
making among the Regions and adherence with the latest Agency policies.
5.2.4 ROD Approval
The last step in the ROD process is the ROD briefing to obtain the RA's or AA's
approval of the recommended action. The format and contents for ROD briefing
materials are presented in Appendix F. The RPM usually prepares the briefing materials
(sometimes with REM contractor support) and may be asked to present them to the RA.
The RPM should consider attending one or more other ROD briefings in the Region as a
preparatory exercise.
For RODs that must be approved at Headquarters, the RPM should prepare and
coordinate the State and Regional review prior to submission to EPA Headquarters. The
RPM must ensure that the official submission is sent to the AA/OSWER, and should
include a cover memorandum from the RA. The memorandum should summarize the
proposed project and present the State's and Region's recommendations to approve the
action. A copy of the complete submission should be sent directly to the Director, HSCD.
During the briefing for the RA or AA/OSWER, a number of last-minute questions or
issues may arise. This usually results in accelerated activity as the RPM coordinates and
facilitates the resolution of these last-minute issues. Once these issues are resolved, the
RA or AA/OSWER signs the ROD.
5.3 TRANSITION TO DESIGN
During the ROD process, there are a number of steps the RPM can take to ensure
a smooth transition to the RD. If all activities are coordinated properly, the lag time
between ROD approval and RD initiation can be minimal. To accomplish this transition,
the RPM must:
Have initiated Phase I design with the USAGE no later than the
beginning of the public comment period
Draft and finalize site-specific design Interagency Agreements with
the USAGE (ideally, this should be available for signature
concurrently with the ROD)
Oversee preparation by the REM contractor of the Pre-Design
Report (see Chapter 6)
Provide remedial planning information (including the Pre-Design
Report) to the USAGE in order to initiate design
5-10
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Make the determination, in conjunction with enforcement staff, that
the PRPs will or will not undertake both the RD and RA before
initiating RD.
These activities are discussed in the next chapter and in the Superfund Remedial Design
and Remedial Action Guidance, June 1986.
ADDITIONAL SOURCES OF INFORMATION
"CERCLA Compliance with Other Environmental Statutes," AA/OSWER, October 2, 1985.
(OSWER Directive 9234.0-2)
Community Relations in Superfund: A Handbook Draft, OSWER, March 1986. (OSWER
Directive 9230.0-3A)
National Oil and Hazardous Substances Pollution Contingency Plan (47 FR 31180),
November 20, 1985.
Preparation of Decision Documents for Approving Fund-Financed and Potentially
Responsible Party Remedial Actions Under CERCLA OWPE, February 27,1985. (OSWER
Directive 9340.2-1)
"Procedures for Planning and Implementing Off-Site Response Actions," AA/OSWER,
May 6, 1985. (OSWER Directive 9330.2-1) (supplemented by 9330.2-3)
Record of Decision Annual Report OERR.
"Superfund Records of Decision Update," OERR, Monthly.
Superfund Remedial Design and Remedial Action Guidance. OERR, June 1986. (OSWER
Directive 9355.0-4A)
5-11
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6. REMEDIAL DESIGN
The purpose of the remedial design is to develop detailed plans and
specifications for conducting the remedial action. During Federal-lead RD and RA, the
USAGE has served as contract manager for design and construction of the EPA-
approved remedy. The USAGE continues to perform in this role, when assigned. In a
few special cases, other Federal agencies, such as the U.S. Department of Interior or the
U.S. Department of Energy, or the REM contractors have assumed this role. The design
contract manager will perform the following basic tasks:
Solicit and select contractors to perform RD and RA activities
Review and approve RD plans and specifications
Monitor construction activities.
However, the RPM retains responsibility for overseeing RDs and RAs at Federal-lead
Superfund sites.
This chapter discusses the RPM's role and responsibilities during the
development of an RD. It discusses specific activities for which the RPM must initiate and
supervise action, promote and coordinate oversight, and act in a review/advisory
capacity. The Superfund Remedial Design and Remedial Action Guidance, June 1986
(RD/RA Guidance), contains a detailed description of the RD/RA process and is the
primary reference document for this and the following chapter on RA. As in other
chapters, Exhibit 6-1 highlights the major activities that occur during this stage of a
remedial response and thus provides a foundation for the following discussion. In
addition, Exhibit 6-2 provides a detailed representation of the Federal-lead RD process.
For simplicity, the handbook describes the case where the USAGE is the design contract
manager.
6.1 ONGOING PROJECT MANAGEMENT ACTIVITIES
Numerous ongoing project management activities are common to all phases of
RD and RA. Specific actions required during the RD process are outlined below.
6.1.1 Coordination with State
During the RD phase, the RPM should coordinate with State officials to apprise
them of site progress and to receive their input on all aspects of the RD. This should
include review of the design as it is developed. The RPM should make every effort to
involve the State in design review, since the State ultimately must assume responsibility
for the remedy after its implementation.
In initiating RD activities at a Federal-lead site, the RPM must begin discussions
with State officials to process a State Superfund Contract. The RPM and State officials
should refer to the State Manual for specific information on the initiation, execution, and
amendment procedures for agreements.
The State is responsible for obtaining site access and any required permits. The
RPM should assist in and coordinate these activities to see that access is obtained.
6-1
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EXHIBIT 6-1
Remedial Design (RD)
CONTRACTOR
(OR USAGE)
EPA
ONGOING PROJECTMANAGEMENT, ENFORCEMENT,
AND COMMUNITY RELATIONS ACTIVITIES
LEGEND:
ACTIVITY
DOCUMENT
6-2
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EXHIBIT 6-2
Federal-Lead Remedial Design Activities
COPIES TO
EPA HO
USAGE HO.
EPA REGION ISSUES
WA FOR INITIATING
PHASE I DESIGN
ACTIVITIES TO
USACE-MRD
USACE-MRO
DESIGN DISTRICT
EPA RPM & STATE
PROCESS STATE LETTERS
OR
AMEND EXISTING MOU
SYNOPSIZE REQMTS. IN CBD
DEVELOP A/E PRE-SELECTION LIST
CONTACT A/E FIRMS TO ASCERTAIN INTEREST
DEVELOP A/E SELECTION LIST (MIN. 3 FIRMS)
L SELECT A/E FIRM (TENTATIVELY)
ACTIVITIES CONDUCTED PRIOR
TO ROD APPROVAL
IN ORDER TO EXPEDITE
DESIGN NOTATION
(SAVES 2 - 3 MONTHS)
EPA REGION PREPARES
DRAFT SITE-SPECIFIC
DESIGN IAG CONCURRENTLY
WITH EPA REGION
SUBMITTING FINAL ROD
PACKAGE FOR APPROVAL
SELECTION OF REMEDY BY EPA
ROD APPROVAL
COPIES TO
EPA HO
USAGE HQ
EPA REGION AND
USACE-MRD FINALIZE |
DESIGN IAG
USACE-MRD
INITIATES DESIGN
ACTIVITIES THROUGH
DESIGN DISTRCT
REMEDIAL PLANNING
INFORMATION
PROVIDED TO
USACE-MRD BY
EPA RPM
DESIGN DISTRICT
ISSUES SOW FOR
DESIGN TO A'E FIRM
A/E FIRM DEVELOPS
DESIGN PACKAGE
BASED ON SOW
KEY:
CBD
IAG
MOU
NPL
ROD
RPM
SOW
USACE-MRD
WA
COMMERCE BUSINESS DAILY
INTERAQENCY AGREEMENT
MEMORANDUM OF UNDERSTAND! NO
NATIONAL PRIORITIES LIST
RECORD OF DECISION
REMEDIAL PROJECT MANAGER
STATEMENT OF WORK
U S ARMY CORPS OF ENGINEERS -
MISSOURI RIVER DIVISION
WORK ASSIGNMENT
DESIGN REVIEW SCHEDULED
AT PRE-DETERMINED
INTERVALS (I.E..
PRELIMINARY, INTERMEDIATE
PRE-FINAL, FINAL)
OVERSIGHT BY EPA RPM
USACE-MRD APPROVES AND
ACCEPTS DESIGN WITH
CONCURRENCE FROM EPA
REGION AND STATE
6-3
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6.1.2 Reporting and Record Keeping
The RPM is responsibile for maintaining thorough, accurate records during the
RD. This includes site files and relevant documentation that will support potential cost
recovery actions. The RPM also may be requested to assist in preparing a cost recovery
summary at the completion of the RD.
One continuing RPM responsibility is the periodic updating of information for
EPA's automated data systems. These systems include:
CERCLIS - RD start (date RD funds were obligated) and end dates
(dates implementation contract was advertised) must be entered.
SCAP -- official mechanism through which the AA/OSWER
identifies funding needs for proposed Superfund activities. The
RPM must coordinate with the Regional SCAP contact to ensure
that accurate information on RD activities appears on the SCAP
prior to the RD start. The SCAP must be updated as the RD
progresses so that funding needs for the subsequent RA are
identified in a timely fashion.
FMS -- provides monthly and ad hoc financial status reports on the
remedial program, which the RPM must review for accuracy.
6.1.3 Technical Progress Oversight
The RPM is responsible for overseeing technical progress during the RD. The
RPM should review all contractor progress reports to ensure that progress reported
coincides with actual performance. One particularly valuable oversight tool is the RD
schedule. The RPM should closely track RD progress against the agreed-upon project
schedule to determine whether problems exist. Significant, persistent delays or
accelerations may indicate the need to adjust the project schedule.
In addition, the RPM should work closely with the USAGE officials to oversee the
architectural and engineering (A/E) contractor's activities during all phases of the design
preparation. The RPM should establish milestones for design review that will coincide
with specific events in the RD. Representatives of the USAGE and the A/E firm should be
present at these meetings to discuss progress and cite problems, if any. Good, informal
communication among all participants in the RD, facilitated by the RPM, also can prove
invaluable to project oversight.
6.1.4 Coordination with Community Relations
The RPM must maintain communication with the Regional community relations
staff in order to coordinate:
Participation in public meetings
Development of fact sheets
Issuance of press releases
Establishment of local information repositories
Public comment period (optional).
This will ensure that the public is involved in the decision-making process during the RD.
The RPM also should encourage State involvement with community relations activities.
6-4
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Based on input from the public participation process described above, the site
Community Relations Plan must be revised, as necessary, to reflect knowledge of citizen
concerns and involvement. At the conclusion of the engineering design, a fact sheet is
prepared either by EPA or the contractor responsible for community relations
implementation. The purpose of the fact sheet is to notify the public that the design is
complete, that the design is consistent with the ROD, and to explain the nature of the
design and the potential impacts its implementation may cause. A public meeting is
recommended at this point.
6.1.5 Obtaining Permits and Site Access
The RPM is ultimately responsible for identifying all required permits and
obtaining site access agreements. However, obtaining access to the site and adjacent
properties, as well as any rights-of-way and easements necessary to implement the RA,
is a State responsibility. The RPM must encourage the State to take action during
Phase I design contractor procurement to obtain any required permits or site access
agreements for the RD and (concurrent with the design for) the RA, in order to avoid
delays in implementing the project. This is very important to implementing the project
according to its schedule. The USAGE will not open bids submitted for the RA unless site
access is secured.
The permits and approvals that may be required for a project depend on the
circumstances of the particular project, but might include, for example:
Permits All on-site and off-site RAs must comply with the
substantive requirements of applicable and relevant and
appropriate laws and standards identified in the ROD/EDO. While
environmental permits are not required for on-site RAs, any
receiving facility for material taken off site must possess all
appropriate environmental permits identified in the ROD/EDO.
Obtaining any necessary, non-environmental construction permits is
the responsibility of the RD A/E firm or construction contractor.
Site Access Access to sites where clean-up actions require short-
er long-term use of adjoining property or property within the site
.boundaries may require obtaining access agreements from, or
negotiation of rights-of-way with, the property owners. The same is
true of property along proposed pipeline routes. In order to ensure
that bid opening and remedial construction will not be delayed due
to disputes with property owners, it is essential that such
agreements be obtained prior to completion of the RD.
The RPM must coordinate closely with the RD A/E firm to define access needs for
the RA. If voluntary access cannot be obtained and resistance from property owners is
encountered, the State should make every effort, to the extent of its legal authority, to
secure site access. If necessary, EPA may be required to exercise its statutory authority
under CERCLA as amended by SARA, in which case an appropriate access order for
entry may have to be secured from a court having legal jurisdiction.
Property access agreements must cover the duration of the cleanup and
associated O&M, as necessary. The RPM is responsible for overseeing all site access
negotiations and agreements, regardless of whether they are obtained through Federal
or State channels.
6-5
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6.2 REMEDIAL DESIGN PROCESS
In addition to the responsibilities outlined above, the RPM has direct involvement
in many of the key phases of RD, such as design initiation, preparation of the SOW for the
USAGE which is attached to the IAG, and conducting various reviews. These
responsibilities are outlined in the following sections.
6.2.1 Work Assignment Issuance and Tentative A/E Selection
The RPM should initiate the selection process for obtaining the A/E firm for RD
prior to the final ROD approval. A work assignment is to be developed and issued,
consistent with the standing IAG, to the USACE-MRD to initiate the Phase I design. The
Phase I design will be based on the draft FS Report, and will serve as the basis for further
action. Phase I design activities typically require 10 weeks to complete. Therefore, they
generally should be initiated no later than the start of the public comment period.
Phase I design activities usually include:
Synoposize requirements in the Commerce Business Daily
Designate A/E pre-selection and selection boards
Develop an A/E pre-selection list
Contact A/E firms to ascertain interest in the project
Develop an A/E selection list
Tentatively select an A/E firm.
The USAGE also keeps a number of A/E firms constantly available by means of
an "open-ended" contract. With this type of contract, the USAGE tasks an A/E firm, which
is on a pre-determined list, with a site-specific assignment, thereby expediting the
selection process by avoiding site-specific contracting activities. This type of contract has
both an annual, nationwide cost ceiling and a site-specific cost ceiling, and is generally
used on smaller projects where timing is critical. Should the "open-ended" contract be
used, the RI/FS and Pre-Design Reports are employed to bring the A/E firm up to speed
as quickly as possible. Funds can be routed quickly to the A/E firm through the USAGE
by means of technical assistance funding. Contact the USAGE for further information on
the use of the "open-ended" contract.
A generic IAG may be established for all Phase I RD assignments to be
conducted during the fiscal year. As a result, only a work assignment is needed to
initiate site-specific Phase I RD activity. A sample work assignment and IAG for Phase I
design are provided in Appendix E. It is the RPM's responsibility to monitor the
preliminary A/E selection process conducted by the USAGE and to offer technical
assistance and review as needed.
6.2.2 Design Initiation
Following the selection of a remedy and approval of the ROD by the designated
EPA official, design activities are initiated. The RPM must provide the following
assistance to the USAGE.
6.2.2.1 Approved ROD and Final RI/FS Report
The RPM must provide a copy of the approved ROD and the final RI/FS Report(s)
to the USAGE as soon as possible after ROD approval.
6-6
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6.2.2.2 Pre-Design Report
The Pre-Design Report describes the engineering parameters and institutional
concerns of the selected remedy. The report, prepared by the REM contractor,
consolidates all pertinent information needed for transferring the project to the USAGE.
The RPM is responsibile for overseeing the preparation and transmittal of the Pre-
Design Report. As a general guideline, the report should be completed within two weeks
following remedy selection, with the cost limited to less than five percent of the FS cost. If
the remedy selection took a long time and the REM contractor was idle, more than two
weeks may be required. It is EPA's intention that the Pre-Design Report be completed
as quickly as possible and that it generally be a compilation and condensation of existing
work, which would not require significant new effort. Exhibit 6-3 presents a suggested
outline for the Pre-Design Report.
6.2.2.3 Site-Specific Design IAG (Phase II Initiation)
The RPM must finalize the required site-specific design IAG to initiate Phase II
activities by the USACE-MRD. After the design IAG is executed, the RPM forwards
copies to both EPA Headquarters and USAGE Headquarters. USACE-MRD then will
initiate design activities through the appropriate design district. The RPM should monitor
all design activities.
A sample site-specific design IAG is included in Appendix E. This document
includes a SOW prepared by the Region for the USAGE. The form is to be completed by
the RPM, signed by the Regional Administrator or designee, and submitted to USACE-
MRD for approval. The site-specific design IAG can be signed at the same time as the
ROD when enforcement negotiations are not planned. Details concerning preparation of
the IAG SOW and additional USAGE responsibilities are provided in the Superfund
RDIRA Guidance.
6.2.2.4 Statement of Work Preparation
The SOW for RD is prepared by the USAGE and requires that the design
contractor develop final construction plans and specifications to accomplish an RA as
defined in the ROD. Elements of the SOW include:
Plans and Specifications required to comply with certain USAGE
standards and review requirements:
Preliminary design (30 percent complete)
Intermediate design (60 percent complete)
Pre-final design (90 percent complete)
Final design package (100 percent complete)
Correlating plans and specifications
Compliance with the requirements of other
environmental statutes
Equipment startup and operator training plans
6-7
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EXHIBIT 6-3
Suggested Outline for Pre-Deslgn Report *
1. Site Description
2. Summary of Selected Remedy
Description of remedy and rationale for selection
Performance expectations
Site topographic map and preliminary layouts
Preliminary design criteria and rationale
Preliminary process diagrams
General operation and maintenance (O&M) requirements
Long-term monitoring requirements
3. Summary of Remedial Investigation and Impact on Selected Remedy
Field studies (air, surface water, ground water, geology)
Laboratory studies (bench scale, pilot scale)
4. Design/Implementation Precautions
Special technical problems
Additional engineering data required
Permits and regulatory requirements
Access, easements, rights-of-way
Health and safety requirements
Community relations activities
5. Cost Estimates and Schedules
Implementation cost estimate (order of magnitude, + 50%/-30%)
Preliminary estimate of annual O&M cost and duration
Project schedule (design, construction, permits and access)
6. Appendices
Reports, data summaries, etc.
Many ot the elements of the Pre-Design Report will have been developed during the
RI/FS. These may be incorporated by reference.
6-8
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Additional Studies necessary to supplement existing technical data
(e.g., bench and pilot studies)
Operation and Maintenance defined and cost estimates prepared
Quality Assurance Project Plan developed to identify quality control
and assurance responsibilities of the contractor, EPA, and the
Federal agency
Site Safety Plan (SSP) developed in response to site-specific data
to protect on-site personnel and surrounding communities from the
physical, chemical, and/or biological hazards of the site.
Detailed instructions for developing the SOW are found in Appendix B of theRD/RA
Guidance.
6.2.2.5 A/E Selection Oversight
The RPM is responsible for monitoring A/E firm selection by the USAGE to ensure
that there are no potential conflicts of interest based on involvement of PRPs at the site.
Interested contractors are required to provide information regarding conflict of interest,
which the RPM must evaluate prior to execution of a contract between the USAGE and
the A/E firm.
6.2.2.6 Technical Transfer Briefing
A technical transfer briefing between the REM contractor and the USAGE design
contractor must be scheduled and coordinated by the RPM prior to initiating RD. This will
help to facilitate project transfer and resolve any outstanding issues or questions. The
RPM should invite State and local officials and other EPA staff members to participate, as
appropriate.
6.2.3 Design Development and Review
The USAGE has the primary responsibility for the review, approval, and
acceptance of the final plans and specifications. As stated in Section 6.2.2 above, the
plans and specification should be submitted in several stages. The RPM, together with
State officials, must provide environmental and technical assistance to the USAGE at
each stage of the design review.
6.2.3.1 Environmental Review
The RPM must coordinate the environmental review to ensure that the
specifications include all elements necessary to address compliance with the
environmental and public health standards identified in the ROD. The environmental
review will ensure that currently accepted environmental control measures and
technology are utilized during construction, and that the O&M plan, QAPP, and SSP
specifications are adequate. The RPM may solicit the assistance of other EPA personnel
to review the design plans and specifications. For example, the Emergency Response
Team (ERT) may review SSPs.
6-9
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6.2.3.2 Technical Review
Technical review of the pre-final design is the responsibility of the USAGE, with
concurrence by EPA.
6.2.4 Approval of Design
The USACE-MRD has the authority to approve and accept the final design.
6.2.5 Major Design Changes
The EPA RPM is responsible for ensuring that the design package being
developed by the USAGE and its A/E contractor is consistent with the ROD. If major
design changes are observed that would significantly alter the remedy approved in the
ROD, the RPM should initiate a preliminary analysis of the impact of the changes, and, if
necessary, notify the USAGE design Project Officer (PO) in writing to temporarily halt
design activities. Further, the RPM should immediately notify the EPA official who has
been delegated ROD responsibility. Examples of major design changes are included in
the RDIRA Guidance. The official must determine whether the design changes warrant a
ROD amendment. Minor design changes, consistent with the approved ROD, may be
approved by the design PO with concurrence from the EPA RPM.
For fund-financed projects, the USAGE should conduct a value engineering
screening during the RD. In a value engineering screening, an RA project is examined to
determine minor modifications or refinements, such as in materials specifications and/or
quantities, that may result in reduced costs. It usually consists of reviewing the project
design, listing high-cost items that have a potential for cost savings, and considering the
use of potential, viable alternatives that do not reduce the effectiveness of the design.
Value engineering screenings, however, must be limited to consider only those project
refinements that would not significantly alter or change the remedy as approved in the
ROD.
The USAGE will notify EPA of those RA projects that were found in the screening
to have a potential to save substantial costs during the RA and to be candidates for
formal value engineering studies. Further, the USAGE will identify potential effects of the
formal study on the project schedule and provide an estimate of additional funding
requirements, if any. If additional funding is required for the formal value engineering
study, when found appropriate, the RPM must ensure that sufficient money is made
available through the SCAP and added by amendment to the IAG.
6.2.6 Coordination of Remedial Action Agreements
In order to initiate the RA, the RPM must work with the State to prepare and
execute a Stale Superfund Contract for all Federally managed remedial actions. The
purpose of the SSC is to secure State assurances for cost sharing, site access, and
O&M. Preparation of the agreement should be initiated during the RD phase; execution
of the SSC must coincide with the completion of the RD.
When the RD package is complete and the final RA cost estimate is available, a
site-specific IAG for the RA is prepared and executed by the EPA Regional office and the
USACE-MRD. Refer to iheRD/RA Guidance for information on the development of RA
cost estimates for inclusion in the SSC and IAG. The RPM should forward copies to EPA
Headquarters and to USAGE Headquarters. A sample site-specific IAG for RA is shown
in Appendix E.
6-10
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ADDITIONAL SOURCES OF INFORMATION
Superfund Remedial Design and Remedial Action Guidance. OERR, June 1986. (OSWER
Directive 9355.0-4A)
State Participation in the Superfund Program. Volume I, OERR, February 1984. (OSWER
Directive 9375.1-4)
6-11
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7. REMEDIAL ACTION
Following the completion and approval of the remedial design package, the
remedial action is implemented. The conclusion of the previous chapter described the
preliminary activities that must be conducted by the RPM in initiating the RA. These
include execution of the required agreement (i.e., State Superfund Contract) between
EPA and the State and completion of a site-specific Interagency Agreement (See
Appendix E). The USAGE performs as the construction contract manager, when
assigned. In some cases, other Federal agencies or the REM contractors may assume
this role.
Upon execution of the IAG or work assignment by the USAGE (or other
construction contract manager), implementation of the RA can begin. It starts with the
solicitation and award of an implementation (i.e., construction) contract, continues
through completion of interim and final inspections and certifications, and culminates
with acceptance of the final project. Exhibit 7-1 shows the sequence of activities that
normally are undertaken in implementing an RA.
The purpose of this chapter is to outline the RPM's responsibilities in ensuring that
the RA is implemented in accordance with the approved design. Although primary
responsibility for the actual implementation rests with the USAGE (or other construction
contract manager), the RPM must stay involved to the extent possible in order to
participate in and coordinate required inspections, reviews, and approvals. As in other
chapters in this handbook, ongoing project management activities are first described,
followed by a more specific elucidation of RPM responsibilities. For simplicity of
presentation, the handbook describes the case in which the USAGE is the construction
contract manager.
7.1 ONGOING PROJECT MANAGEMENT ACTIVITIES
Numerous ongoing project management activities are common to all portions of
remedial implementation. Specific activities required during the RA are outlined in this
section.
7.1.1 Permits and Site Access
During the RD phase, the RPM should have ensured that all required permits
were identified and site access agreements obtained for design implementation. The
RPM is responsible for ensuring compliance with all permits and the requirements of
access agreements. It is the State's responsibility to obtain access to the site and
adjacent properties, as well as rights-of-way and easements necessary to implement the
RA. Even so, the RPM should ensure that site access agreements are negotiated,
because the USAGE will not open RA bids unless site access has been secured. Further
information on this subject has been provided in Chapter 6.
7.1.2 Coordination with State
During the RA phase, the RPM should coordinate with State officials to inform
them of progress and to obtain their input on all aspects of the RA. It is very important that
States be kept informed of site work during the RA. This will help to ease the process of
transition in which the State assumes responsibility for the completed remedy. The RPM
should:
7-1
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EXHIBIT 7-1
Remedial Action (RA)
CONTRACTOR
(OR USAGE)
TOO&M
AND SITE
CLOSEOUT
EG. COMPLIANCE STATUS
OF RCRA FACILITY
EPA
(OR STATE)
ONGOING PROJECT MANAGEMENT, ENFORCEMENT,
AND COMMUNITY RELATIONS ACTIVITIES
LEGEND:
ACTIVITY I I
DOCUMENT f:!';v""l
7-2
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Prepare amendments to the Superfund response agreement
(i.e., BBC), as necessary
Ensure that the State provides its cost share, in accordance with
the payment schedule in the SSC
Coordinate with the Regional Financial Management Office to
ensure proper handling of State payment vouchers and accounts,
particularly upon activity completion and SSC closeout so that
accounts can be reconciled for final State cost share
Coordinate State participation in inspections, conferences, and
other reviews
Assist in preparing amendments to the Cooperative Agreement
for O&M, if required.
In addition, the RPM should coordinate and facilitate the State's involvement in all
community relations activities.
7.1.3 Reporting and Record Keeping
Throughout the RA, the RPM is responsibile for maintaining thorough, accurate
records. The RPM must maintain site files and relevant documentation for the purposes
of future cost recovery actions, as well as possible external audits. The RPM also must
ensure that the USAGE and the RA contractor maintain relevant documentation.
Periodic updating of information for CERCLIS, SCAP, and FMS is a continuing
responsibility of the RPM.
7.1.4 Change Orders/Claims Review and Approval
Problems may arise in the course of the RA concerning implementation of the
design. Among these may be change orders and claims. Change orders are written
orders issued in response to a request for an addition to, deletion from, or revision of the
project specification. The need for change orders usually arises when the RD is
insufficient, for whatever reasons, to meet site conditions, and it is necessary to modify
the RA within the original scope approved in the Record of Decision and the construction
contract. A claim may arise when a request for a change order, submitted by a contractor
engaged in the RA, has been denied or not handled according to pertinent procurement
requirements and policies. Claims are usually filed after the completion of a
subagreement.
The USAGE is responsible for processing change orders and claims in
accordance with USAGE procurement procedures. The USAGE'S project manager has
the authority to approve any change order requiring expenditure of up to 20 percent of
the project contingency fund, which is available for unforeseen site conditions. Any
change order exceeding 20 percent of the contingency fund requires RPM approval. The
RPM will be notified in writing by the USAGE'S project manager if a total of 75 percent of
the contingency fund is expended. In order to exceed 75 percent of the project
contingency fund, the RPM must provide written approval. The RPM should identify
changes or new conditions requiring additional funding as soon as their need becomes
apparent, and must ensure that the money is available through the SCAP process.
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Prompt action is needed in these situations to avoid project delays and additional claim
actions.
7.1.5 Coordination with Community Relations
The RPM is responsible for informing the Regional community relations staff of
any changes in RA activities or progress that could affect the level of concern or
information needs of the community. The RPM should request assistance from the
Regional community relations staff on any specific community relations activities required
during construction, and for ongoing activities such as participation in public meetings
and development of fact sheets and/or press releases.
7.2 PROCUREMENT OF RA CONTRACTOR
The USAGE is responsible for reviewing bid documents for RA activities to
determine whether or not the bidders are both responsive to the requirements of the bid
solicitation (e.g., Are the bid bonds provided in the proper form and amount? Is the
required insurance binder provided?) and responsible (e.g., Does each bidder possess
the capability and experience as required in the solicitation to perform the RA in a safe
and timely manner at the price bid? Is there any potential conflict of interest?). It is the
USAGE'S responsibility to review construction contractors' bid packages and award the
RA contract. The RPM will coordinate with the USAGE to provide assistance throughout
the contract award process. A key function for the RPM at this point is the interpretation of
EPA's off-site policy.
7.3 CONSTRUCTION MONITORING AND INSPECTIONS
The USAGE is responsible for assigning a full-time inspector(s) to be on site
during all construction activities. The RPM will make oversight visits at intervals
determined by the RPM according to the complexity of the project. The USAGE is
responsible for inspecting all on-site construction activities to verify compliance with all
contractual and environmental requirements and with health and safety procedures.
Upon review of construction activities all discrepancies must be noted. The USAGE also
acts as EPA's agent by signing RCRA hazardous waste manifests. The RPM may be
requested to assist in resolving discrepancies, interpreting extent-of-remedy
determinations, conducting site inspections, and enlisting State support.
7.4 REVIEW OF PROGRESS REPORTS
The RPM is responsible for reviewing monthly progress reports submitted by the
RA contractor and the USAGE. EPA will use these progress reports to monitor the
remedial construction activities. The content of these reports will be sufficient to develop
a chronological record of all site activities and should include the following elements:
Estimate of the percentage of the project completed and the total
project cost to date
Summaries of the following items for the reporting period:
Work performed on the site
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Community relations activities, including community
contacts, citizen concerns, and efforts to resolve any
concerns
Change orders and claims made on the contract
Problems or potential problems encountered
Status of the contingency fund to date (fund-financed RA only)
Projected work for the next reporting period
Copies of contractor daily reports, change orders, RCRA
manifests, and laboratory/monitoring data.
7.5 REMEDIAL ACTION COMPLETION AND ACCEPTANCE
The remaining two activities required to complete the RA are the:
Pre-final conference and inspection
Final inspection and certification report.
The RPM's responsibilities for the final technical report, O&M assurances, site closeout,
and deletion from the NPL are discussed separately in Chapter 8.
7.5.1 Pre-final Conference and Inspection
As the project nears completion, a pre-final construction conference and
inspection will be conducted. Participants in the pre-final construction conference and
inspection should include the RPM, State officials, construction contractor, the USAGE,
and the design A/E firm (optional).
The conference will be scheduled and chaired by the USAGE. The objective of
the conference is to discuss procedures and requirements for project completion and
closeout.
The pre-final inspection will consist of a walk-through inspection of the entire
project site. The RPM and the State should inspect the completed site work to determine
whether the project is complete and consistent with the contract documents. The RPM
and the State should identify and note any outstanding construction items discovered.
The USAGE will prepare a pre-final inspection report for submission to the RPM and the
State.
7.5.2 Final Inspection and Remedial Action Report
Upon completion of any outstanding construction items, a final inspection will be
conducted. The pre-final inspection report should be used as a checklist by the RPM and
the State, with the inspection focusing on the outstanding construction items identified in
the pre-final inspection. The contractor's demobilization activities should be completed,
except for equipment and materials required to complete outstanding construction items.
The RPM and the State should confirm that all outstanding items noted in the pre-final
inspection report have been resolved. (If any items remain unresolved, the inspection
will be considered a pre-final inspection, requiring another pre-final inspection report.)
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Following the final inspection, the RPM and the State should close out the SSC for the
RA and determine the State's final cost share. The State's cost share may be made as a
final payment or may be reconciled as part of the O&M Cooperative Agreement.
Upon satisfactory completion of the final inspection, the USAGE will prepare and
submit an RA Report within 60 days after the final inspection. The RA Report is used to
judge the effectiveness of the remedy and to assess whether criteria for deleting the site
from the NPL have been met. The RPM and the State should review the report jointly. If
the RPM and the State concur with the findings of the final inspection/certification report,
the Regional Administrator will provide written notice of EPA's acceptance of the
completed project. (See Chapter 8 for a more detailed discussion of the RA Report.)
7.6 TRANSITION TO OPERATION AND MAINTENANCE
As the RA nears completion, the RPM must prepare for the transition to O&M. As
mentioned previously, the State always assumes sole responsibility for O&M and EPA
may provide cost sharing for a period not to exceed one year. In order to ensure a
smooth transition, the RPM should meet with the State-lead RPM responsible for the site
(if different) and the State's representative to discuss transition roles. This meeting
should occur early in the RA activity.
Under the Superfund Amendments, in the case of ground-water or surface water
contamination, treatment or other measures taken to restore water quality is considered
part of the RA. With respect to such measures, the operation of treatment systems for a
period of up to ten years after the construction or installation and commencement of
operation will be considered part of the RA. Activities required to maintain the
effectiveness of such measures following this period or the completion of the RA, which
ever is earlier, will be considered O&M.
When the RA includes construction of a treatment system other than that
described above, questions may arise regarding whether the facility start-up and shake-
down periods are part of the RA or part of O&M. In some cases, shakedown may last
several months. In most cases, the facility shake-down period will be considered part of
the RA. Remedy effectiveness must be demonstrated prior to submitting the RA Report
for project completion. During the shake-down period, the State is encouraged to:
Oversee operational testing of the system to ensure treatment
effectiveness
Conduct operator training
Adjust the O&M procedures manual to reflect actual operating
conditions/parameters
Develop more accurate O&M costs.
More detailed information on O&M is included in Chapter 8, Project Closeout.
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ADDITIONAL SOURCES OF INFORMATION
"Procedures for Planning and Implementing Off-Site Response Actions," AA/OSWER,
May 6, 1985. (OSWER Directive 9330.2-1) (supplemented by 9330.2-3)
Superfund Remedial Design and Remedial Action Guidance. OERR, June 1986. (OSWER
Directive 9355.0-4A)
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8. PROJECT CLOSEOUT
This chapter discusses the procedures followed in closing out a Superfund
remedial project and the specific responsibilities of the RPM in assisting with the
implementation of these procedures. It is divided into three major sections:
National Priorities List Deletion
Operation and Maintenance
Project Closeout.
It does not discuss procedures and responsibilities for closing out an RI/FS, since these
were discussed in Chapter 4.
Exhibit 8-1 illustrates the activities that occur during O&M, project closeout, and
NPL deletion. The top half of the diagram represents those that are the responsibility of
the USAGE or the remedial action contractor and the bottom shows those that are the
responsibility of EPA and the State.
More detail on much of the information presented in this chapter is provided in
the EPA manual entitled State Participation in the Superfund Program, February 1984 (the
State Manual), and Guidance for Deleting Sites from the National Priorities List (NPL),
Draft, September 1986. The RPM should review these two source documents in
preparing for project closeout. (Note: The final procedures for deleting sites from the
NPL currently are being developed; consult with the HSCD Regional Coordinator for the
latest guidance.)
8.1 NPL DELETION
Section 300.66(c)(7) of the NCP provides that sites may be deleted from, or
recategorized on, the NPL when "no further response is appropriate." To delete a site, at
least one of the following criteria must be met:
EPA, in consultation with the State, has determined that responsible or
other parties have implemented all appropriate response actions required
All appropriate fund-financed response under CERCLA as amended by
SARA, has been implemented and EPA, in consultation with the State,
has determined that no further response is appropriate
Based on an Rl, EPA, in consultation with the State, has determined that
the release poses no significant threat to public health or the environment
and remedial measures are not appropriate.
All sites deleted from the NPL are eligible for further fund-financed remedial response
actions, should future conditions warrant such actions.
In order to determine that any of the deletion criteria has been met, the RPM
should perform a technical evaluation of the data generated from performance
monitoring and/or confirmation sampling. These data must demonstrate that the remedy
has achieved clean-up levels chosen for the site in the Record of Decision. If the no
action alternative is selected, data must confirm that the site poses no significant threat to
public health or the environment.
8-1
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EXHIBIT 8-1
Project Closeout
CONTRACTOR
(OR USACE)
TECHNICAL .
REPORT
STATE)
...: \.'.:'J
FROM
RA
END
EPA
(OR STATE)
DELETION
PACKAGE
PUBLIC
COMMENT
PERIOD
' I
NESS I
SUMMARY J
ONGOING PROJECT MANAGEMENT, ENFORCEMENT,
AND SUPERFUND COMMUNITY RELATIONS ACTIVITIES
LEGEND:
ACTIVITY
DOCUMENT
8-2
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The process of deleting a site from the NPL consists of three major phases:
Region/State joint preparation of a deletion package
Regional/State issuance of local and national Notices of Intent to Delete
Regional/State preparation of responsiveness summaries and
Headquarters' final publication of the Notice Of Deletion in the Federal
Register.
EPA's Guidance for Deleting Sites from the National Priorities List (NPL), Draft, provides a
more detailed discussion of site categorization for deletion and the deletion process.
8.2 OPERATION AND MAINTENANCE
Following completion of the RA, the State must assume responsibility for any
O&M requirements associated with the remedy. This will begin the period during which
EPA shares in the costs of O&M, a period not to exceed one year based upon the date of
project completion. This date is certified in the RA final inspection report and is formally
approved by the AA/OSWER or the Regional Administrator.
The State is required to enter into an O&M Cooperative Agreement with EPA in
order to obtain any approved EPA funds for sharing in the O&M costs. The RPM is
responsible for assisting the State in developing the O&M CA. A description of the
RPM's responsibilities in this regard can be found in the State Manual and the Superfund
State-Lead Remedial Project Management Handbook. The RPM should review both of
these guidance documents prior to completion of the RA and make arrangements to
meet with State personnel who will be responsible for developing the O&M CA.
In addition to assisting the State in developing the O&M CA, the RPM is
responsible for overseeing implementation in terms of technical, financial, and
programmatic commitments agreed upon in the CA. This includes the following
responsibilities:
Monitor agreement provisions
Review the tasks and schedule contained in the O&M plan (see
Chapter 6) and the CA
Track financial activities
Modify the CA.
Below is a detailed description of the RPM's responsibilities in carrying out each of these
activities. It is important to note that although EPA will share O&M costs for a period not
to exceed one year, the RPM is responsible for monitoring O&M activities for the entire
duration of O&M. Exhibit 8-2 summarizes these responsibilities.
8.2.1 Monitor Agreement Provisions
The RPM must ensure that both EPA and the State meet all provisions in the CA.
This includes both general assistance provisions and Superfund program provisions.
The RPM is responsible for accomplishing and/or coordinating the commitments made
by EPA. Any problems in complying with the provisions must be handled by the RPM,
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EXHIBIT 8-2
Operation and Maintenance
ACTMTY
RPM RESPONSIBILITIES
REFERENCES
1. Monitor agreement provisions
2. Review the tasks and schedules
contained in the O&M plan and
theCA
3. Track financial activities
4. Modify the CA
Ensure that all provisions
in the CA are met.
Monitor tasks and schedules
State reporting by
exception
As-needed phone
discussions with the
SPO
Monthly or quarterly
review of State progress
reports
Site visits on as-needed
basis.
Ensure that the State implements
the O&M program within its
financial commitments in the
CA budget
Review State drawdowns on
the letter of credit on a
quarterly basis
Oversee any transfer of funds
from one activity to another
Maintain a complete file of
all financial activities
Compare actual cost data in
the Financial Status Report
with cost data in the O&M
plan and the CA.
Review the amendment application
for technical and/or financial
accuracy and program consistency.
State Manual,
February 1984
State Manual,
February 1984
State Manual,
February 1984
State Manual,
February 1984
8-4
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usually through consultation with appropriate sources in the Region, State, or
Headquarters.
8.2.2 Review the Tasks and Schedules Contained in the O&M Plan and the CA
While it is the State's responsibility to implement the tasks in the O&M plan, it is
the RPM who must actively review these tasks and their schedules. This should be done
using formal and informal information sources such as site visits, telephone calls, the
State's monthly or quarterly reports, and written correspondence with the State Project
Officer. Key elements of the RPM's review strategy should be as follows:
State reporting by exception, as soon as it is noticed that any task in the
O&M plan may not be accomplished. The RPM should come to an
agreement with the SPO that any actual or anticipated deviations from
the schedule in the O&M plan, and any problems or anticipated
problems that may adversely affect the schedule, will be reported to the
RPM immediately. The RPM will then be responsible for assisting the
SPO in correcting the deviations and/or problems, either through
personal support or though the support of other personnel in the
Region.
Telephone discussions, as needed, between the RPM and the SPO to
assess progress in accomplishing key tasks and to identify problems
affecting the implementation of these tasks. The RPM is responsible for
working with the SPO to correct any problems identified.
Formal quarterly or informal monthly review by the RPM of State
progress reports to assess progress in implementing tasks in the O&M
plan. The RPM is responsible for contacting the SPO to discuss and
resolve any problems identified in the progress reports.
Site visits by the RPM on an as-needed basis. The objective is to
assess task progress against schedules in the O&M plan, identify
problems or issues adversely affecting progress and schedules, and
develop corrective actions to resolve these problems. Timing of these
visits should be based on telephone calls with the SPO or information
contained in State progress reports.
8.2.3 Track Financial Activities
Once the O&M CA has been executed, the RPM, along with the appropriate
Regional financial management personnel, is responsible for ensuring that the State
implements the O&M program within its financial commitments in the CA budget. This
responsibility pertains only to the O&M cost-sharing period.
On a quarterly basis, the RPM should review State drawdowns on the letter of
credit. This information should be available from appropriate Regional financial
management personnel. The RPM may request that the SPO submit a copy of the
standard financial report directly. The RPM should determine whether:
Expenditures correspond to technical progress
Expenditures are excessive in terms of project needs
CA account structures are being followed.
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Drawdowns should be only for EPA's percentage of funding (e.g., 90 percent of total
costs). Equipment expenditures must be conducted in accordance with EPA's
Procurement Under Assistance Agreements, 40 CFR Part 33, and Appendix T of the State
Manual.
The RPM is responsible for keeping a complete file of all financial activities, as
well as entering appropriate financial data into the CERCLA Information System data
base. The CERCLIS data base should include the O&M start date (the date the CA for
O&M is executed) and the O&M completion date (end of the O&M cost-sharing period).
Within 90 days after completion of the O&M cost-sharing period, the State is
required to submit a Financial Status Report (EPA Form 269) to the RPM. The RPM
should compare the data in this report with the data in the O&M plan and CA to make
sure that actual expenditures are in line with planned expenditures. If they are not, the
RPM should contact the SPO to discuss any problems that need to be resolved.
If the RPM and SPO see the need for additional, unanticipated O&M funds, the
RPM should assist the SPO in developing an application for a CA amendment (see the
State Manual).
8.2.4 Operation and Maintenance Report
At the completion of the fund-financed O&M activities, the State must prepare and
submit to the RPM an O&M Report. This report should include the following elements:
Description of O&M activities
Results of site monitoring, indicating that the remedy meets the
performance criteria
Explanation of future additional O&M (including monitoring) activities.
The O&M Report may be included as part of the State Quarterly Report and should be
submitted within 60 days of completion of fund-financed activities.
8.3 PROJECT CLOSEOUT
Upon the satisfactory conclusion of the fund-financed response, the site is closed
out. In site closeout, the RPM is responsible for reviewing the final remedial action report
submitted by the USACE/RA contractor and for closing out the CA for fund-financed
O&M, if applicable. (See the Superfund State-Lead Remedial Project Management
Handbook and the State Manual for details.)
8.3.1 Final Remedial Action Report
If a final technical report is required at the completion of the RA, the RPM should
ensure that the report is submitted within 60 days after the completion of the RA has been
confirmed. The RPM should stay in frequent contact with the USAGE to make sure that
this occurs.
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In reviewing the final report, the RPM should ensure that the following elements
are included:
Synopsis of the work defined in the SOW and a certification that this
work was performed
Explanation of any modifications to work in the SOW and why these
were necessary for the project
Listing of the criteria, established before the RA was initiated, for
judging the functioning of the remedy and explanation of any
modification to these criteria
Results of site monitoring and inspection, indicating that the remedy
meets the performance criteria
Explanation of the O&M (including monitoring) to be undertaken.
If information in one or more of these elements is insufficient, the RPM should contact the
USAGE representative who was responsible for preparing the report and explain what
modifications and additions need to be made. Most important is that the report provide a
sufficient basis to judge the effectiveness of the remedy and to assess whether at least
one critierion for deleting the site from the NPL has been met.
8.3.2 Final Considerations
Following deletion from the NPL, the site is technically closed out with respect to
the Federally funded remedial response. However, the RPM is cautioned to establish,
maintain, and safeguard all information collected during the entire remedial response in
well-organized site files, such as those emphasized throughout this handbook. All
information about the site must be carefully documented to support any future legal or
cost recovery actions. These actions may occur years after the data have been gathered.
As a result, it is crucial that records be sufficiently detailed and protected to provide a
complete and accurate history of the remedial response. In addition, well-organized
information will aid the RPM in answering inquiries from Congress or requests from the
general public under the Freedom of Information Act.
ADDITIONAL SOURCES OF INFORMATION
Guidance for Deleting Sites from the National Priorities List (NPL) Draft, OERR,
September 1986. (OSWER Directive 9320.2-3)
Procurement Under Assistance Agreements (40 CFR Part 33), March 28, 1983.
State Participation in the Superfund Program Volume I, OERR, February 1984. (OSWER
Directive 9375.1-4)
Superfund Remedial Design and Remedial Action Guidance OERR, June 1986. (OSWER
Directive 9355.0-4A)
Superfund State-Lead Remedial Project Management Handbook. OERR. December 1986.
(OSWER Directive 9355.2-1)
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APPENDIX A
Example Project Plan
(Iteration 1)
Milestone
Actual Schedule
(Start/Finish) Cost
Generic Schedule
(Start/Finish) Cost
Pre-RI/FS
Intergovernmental review
General response objectives/SOW
for RI/FS
SCAP allocation
Enforcement
Site Access
Funding obligation
RI/FS work assignment
Work plan memorandum
Contractor/EPA meeting
Receipt of work plan and
supplemental plans
Review of work plan and
supplemental plans
Approval of work plans
RI/FS
Public Comment/ROD
RD
RA
A-1
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APPENDIX A
Example Project Plan
(Iteration 2)
Milestone
Actual Schedule
(Start/Finish) Cost
Generic Schedule
(Start/Finish) Cost
Pre-RI/FS
RI/FS
Public meeting
Coordination of analytical support
REM contractor work plan test 1
REM contractor work plan test 2
Validation of date
Technical assistance funds (to COE,
if needed)
Pre-FS meeting
Draft RI/FS delivered
ROD delegation analysis
Design assistance fund to COE
RI/FS review
Pre-ROD meeting
Delivery of public comment FS
Public comment period/ROD
Notification of public comment
Start of public comment period
Draft ROD
Responsiveness summary
ROD briefing
Final ROD
ROD signature
Enforcement negotiations
RD
RA
A-2
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APPENDIX A
Example Project Plan
(Iteration 3)
Milestone
Actual Schedule
(Start/Finish) Cost
Generic Schedule
(Start/Finish) Cost
Pre-RI/FS
RI/FS
Public comment/ROD
RD
Pre-design report
RI/FS closeout
Funding obligation
A/E award
Technical transfer briefing
Site access permits
Notice to proceed
Community relations
30% design review
60% design review
Pre-final (90%) design review
Final design review
Value engineering
SSC signature
RA
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APPENDIX A
Example Project Plan
(Iteration 4)
Milestone
Actual Schedule
(Start/Finish) Cost
Generic Schedule
(Start/Finish) Cost
Pre-RI/FS
RI/FS
Public comment/ROD
RD
RA
Funding obligation
Advertisement for bid
Pre-bid meeting
Bidder responsibility determination
Confirmation of compliance of disposal
facility with RCRA, TSCA, and CWA
Award
Pre-construction meeting
Community relations
Authorization to proceed
Submittal of contractor safety plan
Construction oversight
Progress report 1
Progress report 2
Completion of construction
Pre-final inspection
Final inspection
Final acceptance
Certificate of completion
Warranty
Operation & maintenance
cooperative agreement
Final technical report
Deletion from NPL
A-4
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APPENDIX B
Work Assignment Procedures
for Remedial Contracts
OSWER DIRECTIVE NO.: 9242.3-3A
WORK ASSIGNMENT PROCEDURES
FOR REMEDIAL CONTRACTS
November 1986
This document has been prepared for the U.S. Environmental Protection
Agency under Contract No.: 68-01-6939 The material contained herein is not to be dis-
closed to. discussed with, or made available to any person or
persons for any reason without the expressed written approval of a responsible official of
the U.S.E.P.A.
B-1
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TABLE OF CONTENTS
EXECUTIVE SUMMARY 1
1.0 INTRODUCTION 2
1.1 Purpose 2
1.2 Modifications to the Existing Procedures 2
1.3 Work Assignment Form 3
20 DEVELOPMENT AND ISSUANCE OF WORK ASSIGNMENT 5
2.1 Summary of WA Package and Procedures 5
2.1.1 The Work Assignment Form 5
2.1.2 The Interim WA Statement of Work 6
2.1.3 The Complete Statement of Work 6
2.1.4 Procurement Request 7
2.1.5 Work Plan Memorandum 7
2.1.6 Issuance of WA Package 7
2.2 Responsibilities 9
2.3 Deliverables 10
3.0 WORK PLAN DEVELOPMENT AND APPROVAL 11
3.1 Summary 11
3.2 Work Plan Development 11
3.3 Interim Amendments 12
3.4 Responsibilities 12
4.0 IMPLEMENTINGTHE APPROVED WORK PLAN 14
4.1 Cost Tracking 14
4.2 Modifying Approved Work Plan 15
4.2.1 Utilizing EL Option 15
42.2 Technical Direction Memorandum 16
423 Amendment to Final WP Approval 18
4.3 Responsibilities 19
4.4 Deliverables - 20
5.0 COMPLETION OF THE PROJECT 21
B-2
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FIGURES AND TABLES
FIGURE 1 Work Assignment Form (WAF) and WAF Instructions
FIGURE 2 Development and Issuance of Work Assignment (EPA Submittal)
FIGURE 3 WAF - New Work Assignment (EPA Submittal)
FIGURE 4 WAF - Interim Amendment (Contractor Submittal)
FIGURE 5 Completion of Interim Work Assignment Tasks and Approval of Work
Plan
FIGURE 6A WAF - Final Work Plan Approval (Contractor Submittal)
FIGURE 6B WAF - Final Work Plan Approval (EPA Approval and Total Funding
Received)
FIGURE 6C WAF - Final Work Plan Approval (EPA Approval and Partial Funding
Received)
FIGURE 7 Implementation of Approved Contractor Work Plan
FIGURE 8 Technical Direction Memorandum (TDM; 2 pages)
FIGURE 9 Completed TDM Form (2 pages)
FIGURE 10 WAF - Technical Direction Memorandum (TDM)
FIGURE 11 WAF - Amendment to Final Work Plan Approval
FIGURE 12 WAF - Work Assignment Completion Notification
FIGURE 13 Completion of the Project
TABLE 1 Interim Statement of Work Task Menu
TABLE 2 LOE for Tasks Under REM Contracts
B-3
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ACRONYMS
CO EPA Contracting Officer
EL Expenditure Limit
EPA Environmental Protection Agency
FIT Field Investigation Teams
LOE Level of Effort
OERR EPA Office of Emergency and Remedial Response
PEB Performance Evaluation Board
PO EPA Project Officer
PR Purchase Request
PRP Potentially Responsible Party
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
RPM Remedial Project Manager
RPO Remedial Project Officer
SCAP Superfund Comprehensive Accomplishments Plan
SOW Statement of Work
TDM Technical Direction Memorandum
WA Work Assignment
WACR Work Assignment Completion Report
WAF Work Assignment Form
WP Work Plan
WPM Work Plan Memorandum
B-4
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EXECUTIVE SUMMARY
The EPA Office of Emergency and Remedial Response (OERR) has awarded four contracts for
remedial planning activities at uncontrolled hazardous substance disposal sites (REM) throughout
the ten EPA Regions across the country. The first REM contract, Remedial Response Field
Investigation Teams (REM-FIT), has been completed. The second contract, REM II, was awarded
to Camp Dresser & McKee Inc. on June 1, 1984. The third REM contract, REM III, was awarded
to Ebasco and REM IV to CH2M Hill.
The purpose of these contracts is to obtain the technical and management services in support of
EPA's enforcement and remedial planning activities at selected uncontrolled hazardous substance
disposal sites. These services encompass remedial investigations, engineering feasibility studies,
oversight of remedial planning and implementation projects performed by states and/or responsi-
ble parties, support of community relations programs, data management support of enforcement
and cost recovery proceedings, and general program management support. In addition, special
subcontracting pools are used to promote the participation of Small and Small Disadvantaged
Business Utilization with set-asides. In the REM II, III, and IV contracts, Program Management
and support hours are in addition to those technical hours planned for Remedial Response
activities.
Other services may include engineering design and implementation of Expedited Response
Actions and, in some limited situations, remedial actions. Engineering design services may also be
required where a State or EPA require assistance for the design of remedial actions that the
State or U.S. Army Corps of Engineers will implement through a construction contract.
The following Work Assignment Procedures for Remedial Contracts package has been developed
in order to provide guidance to the Regions and REM contractors. The Work Assignment
Procedures package outlines the various steps and stages of a work assignment, from inception
through completion. The procedures include a streamlined Work Assignment Form (WAF), provide
administrative and contractual procedures to implement the phased RI/FS concept, and place
strong emphasis on more regional management control. It should be noted that the following pro-
cedures apply to all RCRA and CERCLA Technical Oversight (TOS) and Community Relations
(CR) assignments as well, we have concentrated on an RI/FS assignment strictly for the purposes
of this guidance package.
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INTRODUCTION
1.1 Purpose
This document describes the procedures that are to be used in initiating and monitoring the con-
tractual aspects of a work assignment. The actions that are to be taken by both EPA and the
Contractor during each step are described within. The four key steps that are involved in the work
assignment process are:
Step 1- Development and issuance of the work assignment (Figure 2)
Step 2- Completion of the interim work assignment tasks and approval of the
Contractor work plan (Figure 5)
Step 3- Implementation of the approved Contractor work plan (Figure 7), which in-
cludes the following two elements:
Technical Direction Memoranda for phased work plan execution
Amendments to final work plan approval
Step 4- Completion of the work assignment and close-out procedures (Figure 12)
1.2 Modifications to the Existing Procedures
Several changes have been made to existing procedures in order to facilitate the management
and coordination of Federal-lead remedial projects. These changes are proposed principally to
transfer more of the management responsibility of the phased execution of the work assignments
to the Regions and streamline authorization and include the following items:
Development of a single Work Assignment Form (WAF);
Standardization of detailed interim statements of work that include a detailed description
of each interim task. LOE task assignments, estimated budget, and task and deliverable
schedules.
The Work Plan Memorandum (WPM) will be streamlined to a five to ten page document
which will outline the work assignment approach and provide cost estimates for the ex-
ecution of the interim tasks. The WPM can also transmit resume material (if the Region
requests) for the key staff proposed for the work and conflict of interest declarations.
B-6
-------
The Work Plan Memorandum will be submitted within ten (10) days of receipt of the
work assignment.
Procedures whereby the RPM/RPO provides technical direction for additional phases of
work within the scope of work and budget approved by the EPA CO.
1.3 The Work Assignment Form
The Work Assignment Form (WAF) has been developed to manage and coordinate the various ac-
tivities needed to initiate, approve, and complete a work assignment. This form consolidates all of
the work assignment "contractual" activities on one form to eliminate the misuse and misunder-
standing associated with having different forms for different phases of the work assignment pro-
cess. Each successive WAF on a WA supersedes the previous WAF and therefore ALL required
information must be provided on the updated WAF when submitted. A copy of a blank WAF is
provided in Figure 1.
The WAF is a one-page form with instructions provided on the back to facilitate its use. The form
allows for more efficient work assignment tracking and provides an up to date work assignment
status at any given time. The form is to be used whenever one of the following activities is to be
conducted:
A new Work Assignment is issued by EPA;
The Contractor requests an Interim Amendment to the work assignment;
Incremental funding is provided;
The work plan receives full or partial approval and the total funding authorization is
received;
The Contractor requests an Amendment to the Final Work Plan Approval;
The Contractor (or RPM) prepares a Technical Direction Memorandum to conduct
phased work approved under an existing work plan; or
EPA requests that an assignment be closed-out.
As shown on Figure 1. the form is divided into six (6) sections as described below:
1. Work assignment information which identifies the project name and activity, the date the
form was prepared, the Contractor name and the EPA contract number, the work assign-
ment number, the revision number, which numerically accounts for all contractual activity
on the work assignment, and the modification number. The last two are provided by
EPA.
2 Description of action defines the status of the submittal covered by the Work Assignment
Form As explained previously, there are eight basic actions that can be taken.
B-7
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FIGURE 1
USEPA
WORK ASSIGNMENT FORM
1 WORK ASSIGNMENT INFORMATION
PROJECT NAME
CONTRACTOR
WORK ASSIGNMENT NO
ACTIVITY
EPA CONTRACT NO
. REVISION NO
DATE
. CONTRACTOR CONTROL NO
. MODIFICATION NO
(Contracting Officer Use Only)
2 DESCRPTKDN OF
ACTION
E NEWWORK
ASSIGNMENT
Interim SOW,
schedule, and LOE
Complete SOW estimated
budget and schedules
REQUPED
APPROVAL
EPA REGION/
HEADQUARTERS
INTERIM
AMENDMENT
Change in LOE.
Scope by ink
Add addWonal tasks
or hinds
INCREMENTAL
FUNDING
EPA REGION/
HEADQUARTERS
PARTIAL WORK PLAN
APPROVAL
FINAL WORK PLAN
APPROVAL
Approval of work plan
Add funds
AMENDMENT TO FINAL
WORK PLAN APPROVAL
Change m LOE, scope or
budget by task
Add additional task or funds
(include OF 60 or SF 1411)
EPA REGION/
HEADQUARTERS
TECHNCALDRECTDN
D MEMORANDUM
Detailed scope, budget
and schedule
Revise expenditure level
Minor shift within SOW
(All changes must be withm
overall scope, budget, and
LOE approved by EPA CO)
EPA REGION
WORK ASSIGNMENT
Q COMPLETION NOTFCATON
(NO ATTACHMENTS)
Contractor originates
Regional determination
When signed by CO,
this constitutes a
stop work order
CONTRACTOR
TOTAL FUNDING
REC8VED
3 BUDGET INFORMATION
CURRENT
THIS ACTION
TOTAL
Option - dollar estimate may be tracked
regionally tn expenditure limt block
EPA estimated LOE noun of enure WA .
INTERIM BUDGET
(TECHNICAL LOE) (*>
INCLUDES FEES
APPROVED
WORK PLAN BUDGET
(TECHNICAL LOE)
<*)
INCLUDES FEES
EXPENDrrUHE
LIMIT (EL) '
(TECHNICAL LOE)
(*>
ESTABLISHED BY
RPM/RPO
4 WA COMPLETION DATE
CURRENT
REVBED
5 EPACOMMENTS
S APPROVALS
CONTRACTOR SIGNATURES
SITE MANAGER /FIRM
DATE
REGIONAL MANAGER/FIRM
DATE
EPA SIGNATURES;
REGIONAL PROJECT MANAGER
DATE
REGIONAL PROJECT OFFICER
APPROVED AS SUBMITTED
APPROVED WITH CHANGES
NOT APPROVED
SIGNATURE OF CONTRACTING OFFICER
DATE APPROVED
CC EPA Proisct Officer
RPCvRPM
Contracior
EPA Contracting Officer (when only
expenditure limn column is used)
UPDATE 11 13(86
B-8
ATTACH STATEMENT OF WORK
(PER DESCRIPTION OF ACTION)
-------
3. Budget information which presents the budgeted technical LOE and where required, dol-
lars associated with the approval phase under which the work assignment is being ex-
ecuted. This section also tracks current expenditure limits as set by the Region.
4. Work Assignment (WA) Completion Date which presents the current date for completion
of the work assignment and provides for documentation of subsequent revisions.
5. EPA comments section provides space for EPA personnel to make comments concerning
the submission and action taken.
6. Approvals section which provides signature blocks for approval of both the Contractor
and EPA personnel.
B-9
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2.0 DEVELOPMENT AND ISSUANCE OF THE WORK ASSIGNMENT
2.1 Summary of WA Package and Procedures
A flow chart describing the development, issuance and acceptance of the Work Assignment is
presented in Figure 2. The Work Assignment package is developed by the EPA Regional Project
Manager (RPM) in conjunction with the Regional Project Officer (RPO) The Work Assignment
package consists of the following elements:
A Work Assignment Form (WAF);
An Interim Statement of Work (SOW);
A complete SOW for the total work assignment;
A Work Plan Memorandum (WPM; optional); and
A procurement request (PR).
Note 1: An action memorandum (where required by Region) and an intergovernmental review
must be completed and approved prior to submittal of a WA package to the
Contracting Officer when conducting an RI/FS.
Note 2: Systems available to REM contracts allow for the preparation of a Work Plan
Memorandum so that it can be included as part of the work assignment package.
2.1.1 The Work Assignment Form (WAF)
The RPM/RPO is responsible for preparing the WAF that is included in the Work Assignment
package. The RPM/RPO will be responsible for completing the items on the form as shown in
Figure 3. Under Item 1 the RPM/RPO will fill in the:
Date;
Project Name;
EPA Contract Number;
Activity:
Contractor Name; and
Revision Number which will be "Initial" for new work assignments and then sequentially
numbered (i e. 1.2.3.4 ) for each subsequent action; and
Work Assignment number Last four digits, which correspond to the site-specific ac-
counting information for the site, allowing room for sequential numbering by the CO
B-10
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FIGURE 2
DEVELOPMENT AND ISSUANCE OF WORK ASSIGNMENT
CO ISSUES CONTRACT
MODIFICATION TO
CONTRACTOR WITH WA
AND AUTHORIZES
INTERIM TASK IN WPM
CONTRACTOR ACKNOWLEDGES
ACCEPTANCE OF WA BY
SIGNING AND SUBMITTING
MODIFICATION TO
CO IMMEDIATELY
CONTRACTOR REVIEWS
WA TO CONFIRM LOE,
SOW, AND SCHEDULE
AND DETERMINES STAFF
ORGANIZATIONAL
CONFLICT OF INTEREST
AND PREPARES AND
SUBMITS WPM
CONTRACTOR SUBMITS
WAF (INTERIM
AMMENDMENT) TO RPKV
HPO (WITH REVISED
WPM AS SOW
JUSTIFICATION)
FOR ACCEPTANCE
WITHIN 10 DAYS
RPM/HPO ACCEPTS
AND SUBMITS WAF
(INTERIM AMENDMENT)
AND SUBMITS PR, IF
ADDITIONAL DOLLARS
ARE NEEDED, TO CO
FOR APPROVAL
CO APPROVES WAF
(INTERIM AMENDMENT)
AND ISSUES TO
CONTRACTOR W/ COPIES
TORPM/RPOANOPO
Conflict of Interest may have been identified earlier
in the process II so, this step serves as a confirmation
-------
FIGURE 3
USEPA
WORK ASSIGNMENT FORM
1 WORK ASSIGNMENT INFORMATION
PROJECT NAME ABC CO., TX
CONTRACTOR COM INC. WORK ASSIGNMENT NO
ACTIVITY RI/FS EPA CONTRACT NO 68-01-6939 REVISIONNO
1-6L51
INITIAL
6/13/84
riATF mNTQArvrnn rnuToni wn umiFir.ATnN wr>
2 DESCHPTKDN OF
ACTION
' NEWWORK
ASSIGNMENT
Interim SOW,
schedule, and LOE
Complete SOW estimated
budget and schedules
REQUIRED
APPROVAL
EPA REGION/
HEADQUARTERS
INTERIM
D AMENDMENT
Change in LOE,
Scope by task
Add additional tas
or funds
pi INCREMENTAL
FUNDING
EPA REG
HEADQUARTI
3. BUDGET INFORMATION
TOTAL FUNDING
RECEIVED
J CTE
CURRENT
THISACTKDN
TOTAL
Option - dollar estimate may b
regionally in expenditure limit t
EPA estimated LOE hours of e
4 WA COMPLETION DATE
100,000
100,000
9 tracked
*"* 8,000
TOM* wf '
CURRENT
CJ PARTIAL WORK PLAN
APPROVAL
D FINAL WORK PLAN
APPROVAL
Approval of work plan
Add funds
D AMENDMENT TO FINAL
WORK PLAN APPROVAL
Change in LOE, scope or
budget by task
Add additional task or fun
(include OF 60 or SF 141
ON/
=RS EPA REGION
HEADQUARTER
WTERIM BUDGET
SHNICAL LOE) ($)* (fl
1,700 100,000
1,700 100,000
INCLUDES FEES
9/30/85
(Contracting Officer Use Only)
TECHNICAL DRECTION
Q MEMORANDUM
Detailed scope, budget
and schedule
Revise expenditure level
Minor shift within SOW
ds (All changes must be within
) overall scope, budget, and
LOE approved by EPA CO)
/
3 EPA REGION
APPROVED
WORKPUWflUOGET
=CHNICAL LOE) ($)
INCLUDES FEES
REVISED
WORK ASSIGNMENT
d COMPLETION NOTFCATIt^
(NO ATTACHMENTS)
Contractor originates
Regional determination
When signed by CO,
this constitutes a
stop work order
CONTRACTOR
EXPENDfTURE
LIMIT (EL) *
(TECHNICAL LOE) ($)
1,450 85,000
1,450 85,000
ESTABLISHED BY
RPM/RPO
5 EPA COMMENTS'
Expenditure Limit is set at
$85,000 to cover Phases I, II,
III
6 APPROVALS
CONTRACTOR SIGNATURES
SITE MANAGER /FIRM
REGIONAL MANAGER/FIRM
rVT] APPROVED AS SUBMITTED
ft
,-,.-..,-.,
DATE \ \
IF
*T"
DATE *£Gto>'
1 | APPROVED WrTH CHANGES
SIGNATURE OF
Wj&hhhtf
IAL PROJECT MANAGER //
ALPROJECTOFFSCER
CONTRACTING OFFCER
^A^w
Pi_
j 1 NOT APPROVED
Jx(r\iY\2 V^r Men
DATE APPROVED
CC EPA Project Officer
RPO/RPM
Contractor
EPA Contracting Officer (when only
expenditure limit column is used)
UPDATE 11/13/86
B-12
ATTACH STATEMENT OF WORK
(PER DESCRIPTION OF ACTION)
-------
The Contractor control number is to be used by the Contractor for internal controls if desired.
The modification number is to be left blank and will be completed by the EPA PO. Under Item 2
the RPM/RPO will check the box marked "New Work Assignment." Under Item 3 the RPM/RPO
will fill the "Interim Budget" column by showing the current LOE for the Interim WA SOW and the
EPA estimated hours for the entire WA. The LOE hours from the entin, assignment can be esti-
mated based on historical data. The dollar amount of the procurement request (PR) attached
should be the first funding and should be shown in the "This Action" and "Total" lines of the
"Total Funding Received" column. Using an average hourly contractor rate, to be provided to the
region on a strictly confidential basis by the Contracting Officer, and other incidental costs de-
pending upon the specific tasks authorized, the RPM/RPO may also provide a dollar estimate of
the interim budget and show this estimate in the Expenditure Limit block. Under item 4, the RPM/
RPO will fill in the WA completion date for the entire WA in the space marked "current" The
RPM/RPO will sign on the appropriate spaces in the Approvals section (Section 6).
2.1.2 The Interim WA Statement of Work
The Interim WA Statement of Work (SOW) will be prepared by the RPM/RPO for RI/FS assign-
ments. To aide the RPM/RPO. a computer assisted work assignment generation program has
been developed. The program will serve as a management tool that Regions can use to assist in
the preparation of the Work Plan Memorandum and other work assignment deliverables. The pro-
gram is based on a list of core key and optional tasks as displayed in Table 1. The program is
driven by data input from site hazard ranking information or other known data. The program is
interactive and may also produce both scope text, schedule, and LOE based upon program ex-
perience to date. The interim statement of work for other tasks is less standard and will be devel-
oped on a case-by-case basis. Table 2 presents averages and ranges of LOE for tasks under
REM contracts.
The RPM/RPO could also use the computer assisted program to determine the following
information:
The interim tasks to be conducted;
a detailed description of the work to be conducted under each task;
the Level of Effort (LOE) needed to perform each task (i.e., the number of technical
hours that can be expended in conducting each task);
the Interim Task schedule including milestones and deliverables; and
a uniform cost estimate for all tasks to be conducted under the Interim SOW generated
using the average Contractor hourly cost to be provided on a strictly confidential basis
by the Contracting Officer.
2.1.3 The Complete Statement of Work
The EPA RPM/RPO is also responsible for developing the complete Work Assignment Statement
of Work (SOW). The complete WA SOW defines the tasks that the Contractor will be expected to
perform to complete the entire work assignment. This SOW should reflect EPA's estimate of all of
the work that will be performed by the Contractor
B-13
-------
CORE TASKS
TABLE 1
INTERIM STATEMENT OF WORK TASKS
OPTIONAL TASKS
Work Plan Memorandum
Initial Site Evaluation
No Action Risk Assessment
Identify/Screen Alternatives
Work Plan Preparation
Sampling/Analysis Plan
Health and Safety Plan
Quality Assurance Project Plan
Community Relations Plan
Site Management Plan
Technical/Financial Management
Site Survey/Topographic Mapping
Site Access Assistance
Limited Site Sampling (RI)/Analysis
Procurement of Subcontractor(s)
Community Relations Development
Sr. Tech Advisory Committee Review
Engineering Evaluation/Cost Analysis-ERA
ERA/Operable Unit Implementation
B-14
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TABLE 2
LOE FOR TASKS UNDER REM CONTRACTS
PHASE
TASK
LOE HOURS
RANGE AVERAGE
Work Assignment Initiation
Work Plan Memorandum
Initial Site Evaluation
EPA Designated Activities
Community Relations Plan
Quality Assurance Project Plan
Project Operations Plan
Work Plan
Technical & Financial Management
Quality Control
Quality Assurance
Remedial Investigation (Rl)
Study Area Survey
Source Characterization
Site Characterization
Feasibility Study Testing
Data Validation
Contaminant Pathway/Transport Eval.
Public Health Evaluation/
Endangerment Assessment
Remedial Investigation Report
EPA Designated Activities
Community Relations Support
Technical & Financial Management
Quality Control
Quality Assurance
Feasibility Study (FS)
Develop Prelim. Remedial Alternatives
Screen Remedial Alternatives
Analyze Remedial Alternatives
Compare Evaluation of Acceptable Alts.
FS Report
EPA Decision Document
Preparation Assistance
Pre-Design Report
WACR Assistance
Community Relations Support
Technical & Financial Management
Quality Control
Quality Assurance
40-80
150-300
60-120
20-40
100-500
200-400
60-150
40-80
20-40
80-160
150-300
1000-2200
*
300-400
300-500
400-700
*
50-120
170-360
60-80
40-120
100-250
150-300
300-700
200-400
350-650
40-80
40-80
10-20
40-80
100-250
40-60
20-60
52
225
*
90
30
250
300
105
60
28
123
287
1600
350
400
550
*
74
252
70
80
166
225
500
300
500
60
60
15
60
162
50
40
* Level of Effort (LOE) value depends greatly on site-specific conditions.
B-15
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2.1.4 Procurement Request
The procurement request (PR: EPA Form 1900-8) is the document used to commit funds to the
work assignment by the Region Either partial or full funding can be provided through this re-
quest. If partial funding is provided with the new work assignment, the dollar amount of the PR
(indicating funding amount) should be AT LEAST the cost estimate generated by EPA for the in-
terim tasks. Additional funding may be allocated as received or needed. Each EPA regional office
has designated personnel to prepare PR's and obtain approvals. The EPA RPM is responsible for
requesting a PR and planning sufficient funding on the SCAP for the project.
2.1.5 Work Plan Memorandum (WPM)
As discussed above, the RPO/RPM can develop a WPM and include it as part of the WA pack-
age. If it is not completed at that time, it will be generated by the Contractor as the first deliver-
able completed under the interim approved tasks. The generation and approval process for the
WPM is diagrammed in Figure 2.
2.1.6 Issuance of the Work Assignment package
The work assignment package, when completed, is transmitted to the EPA Contracting Officer
(CO) with a copy to the PO. The CO assigns, or completes, the work assignment number, signs
the WAF in the appropriate section, and prepares a contract modification. The CO forwards the
original to the Contractor with a copy to the RPM/RPO and the PO. The Contractor acknowledges
acceptance of the WA by signing the contract modification and returning the original modification
to the EPA CO.
Upon acceptance of the WA, the Contractor determines the lead firm for conducting the WA,
identifies the site manager, researches and certifies that there are no conflicts of interest (if not
previously determined) for both the involved firms and key personnel, and reviews the interim and
complete SOW's. If the Contractor accepts the Interim SOW, as shown in Figure 2, the
Contractor completes and submits a WPM to the EPA RPM/RPO.
The Contractor will, through the WPM, prepare an estimate of the hours needed for the execution
of the interim tasks.
The Contractor will submit copies of the resumes of key personnel for the designated project with
the WPM if not already in the EPA regional files. The submission of this section as part of the
WPM is optional and will be determined by Regional preference.
If the Contractor determines that it is necessary to amend the Interim SOW by either increasing
the scope of work defined in one or more of the interim tasks, by adding additional task(s) to the
Interim SOW. or by substantially changing the interim LOE and costs, the Contractor submits the
completed WPM with a revised WAF (Interim Amendment) to the RPM/RPO. Justification for the
Interim Amendment will also need to be provided as part of the Interim Amendment
B-16
-------
After review and approval of the Interim Amendment, the RPM/RPO complete the appropriate sec-
tions of the WAF and submit the WAF to the EPA CO for approval. A purchase request is re-
quired if funding is not sufficient to accomplish the interim tasks. The EPA CO completes and
issues the completed WAF to the RPM/RPO, the Contractor and the EPA PO. An example of a
completed WAF (Interim Amendment) is shown in Figure 4.
B-17
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FIGURE 4
USEPA
WORK ASSIGNMENT FORM
1 WORK ASSIGNMENT INFORMATION
PROJECT NAME ABC CO., TX
CONTRACTOR COM INC.
WORK ASSIGNMENT NO
ACTIVITY RI/FS EPA CONTRACT Mr. 68-01-6939 qpuismNNO
1-6L51
1
7/24/84 999-PM1-RT-CDHB
OATE ->irrn«/>-iv>n <-<-IILITCJ/-II u/1 ""* "" wwnw u,^,^,,,,-,.,^, ,,^
2 DESCRFTIONOF
ACTION
E NEWWORK
ASSIGNMENT
Intenm SOW,
schedule, and LOE
Complete SOW estimated
budget and schedules
REOUFEO
APPROVAL
EPA REGION/
HEADQUARTERS
INTERIM
AMENDMENT
Change in LOE.
Scope by task
Add adcMonal tai
or funda
pi INCREMENTAL
FUNDING
EPA REG
HEADOUARTl
J. BUDGET INFORMATION
TOTAL FUNDING
RECEIVED
$ ' (TE
CURRENT 100,000
20,000
120,000
TOTAL
Opton - dollar i»«mate may bi
regionally in expenditure limit b
EPA estimated LOE hours of er
4 WA COMPLETION DATE
i tracked
lock
-------
2.2 Responsibilities
The RPM/RPO is responsible for the following tasks during the development, issuance, and ac-
knowledgment of the work assignment phase:
Developing the Work Assignment package;
Transmitting the original WA package to the EPA CO with a copy to the EPA PO;
Acknowledging receipt of the WPM from the Contractor in writing;
Returning copies of the acknowledgment of the WPM to the Contractor, the EPA PO
and the EPA CO; and
If the contractor submits an Interim Amendment to the WA, the RPM/RPO is responsible
for reviewing and approving the amendment, completing the WAF, and transmitting the
Interim Amendment with the WAF to the EPA CO.
The EPA Contracting Officer (CO) is responsible for conducting the following tasks during-the de-
velopment, issuance, and acceptance of a work assignment:
Assigning a complete work assignment number on the WAF (New Work Assignment);
Reviewing and approving the WAF (New Work Assignment), developing the contract
modification, and submitting these items to the Contractor
Receiving the WA acceptance from the Contractor and executing the contract
modification;
Reviewing and approving all Interim Amendments to the WA by signing the WAF (Interim
Amendment); and
Submitting copies of ALL completed WAF's to the EPA PO, the RPM/RPO and to the
Contractor.
The Contractor is responsible for the following items during the issuance and acceptance of the
Work Assignment package:
Acknowledging the acceptance of the WA by signing and returning the contract modifi-
cation to the EPA CO;
Determining team/subcontractor conflicts of interest:
Identifying the lead firm to conduct the work;
Naming the Site Manager and other key staff;
Completing the WPM and transmitting the complete WPM to the RPM/RPO (if it is not
included in the WA package); and
B-19
-------
Developing Interim Amendments (as necessary) which consist of a detailed scope, LOE,
budget, schedule and a WAF. Interim amendments would be required if there are
changes needed in the total interim LOE, a major change in scope to one or more of
the interim tasks or the addition of any new tasks to be performed as part of the interim
effort. Interim amendments may also be used to approve other RI/FS tasks prior to the
receipt of the Final Work Plan Approval.
2.3 Deliverables
The deliverables for this phase of the work assignment process include the following:
Work Assignment package (RPM/RPO);
Contract Modification (EPA CO);
Acknowledgment of WA upon receipt (Contractor);
Work Plan Memorandum submitted by the Contractor within ten days of receipt of WA
(Contractor);
EPA acknowledgment upon receipt of the WPM when the Contractor revises the EPA es-
timated WPM LOE (RPM/RPO); and
WAF (Interim Amendment) to WA if there are revisions to the interim LOE hours or bud-
get (Contractor)
B-20
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FIGURE 5
COMPLETION OF INTERIM WORK ASSIGNMENT TASKS AND
APPROVAL OF WORK PLAN
00
I
N)
WP DEVaOPED
BY CONTRACTOR
WITH KNOWN
TASKS DEVELOPED
IN DETAIL
h
RPM/RPO APPROVE
OVERALLWPAND
ESTABLISHES PHASED
CONTROL THROUGH
EL FOR WELL DEFINED
TASKS OR FUNDING
LIMITATIONS
fe
CO APPROVES
TOTAL OVERALL WP
AND ESTABLISHES
BUDGET AND LOE
LIMIT AND
SCHEDULE END
DATES
fe
CONTRACTOR
COMMENCES WORK
ON ALL TASKS.
IF EL PROVIDED
SUFFICIENT FUNDING
IS AVAILABLE
WORK COMPLETED
WORK NOT
COMPLETED
TO LEVEL 3
RPM/RPO APPROVE
ADDITIONAL TASKS
WITH SUFFICIENT
FUNDING IN EL
COLUMN
^
CONTRACTOR DEVELOPS
DETAILED TASK
DESCRIPTION ON
ADDITIONAL TASKS
WITHIN OVERALL
SCOPE
-------
3.0 WORK PLAN DEVELOPMENT AND APPROVAL
3.1 Summary
As shown on the flow chart in Figure 5 (Level 2). upon acceptance of the Work Assignment the
Contractor initiates the Interim SOW according to the scope. LOE, schedule, and budget defined
for each task. One of the first tasks the Contractor should conduct is the initial site evaluation
which will provide the Contractor with data on the site and the analysis of existing data to identify
data gaps. The Contractor will also begin to identify (specific to the Work Assignment) preliminary
remedial alternatives that can accomplish remediation of the site. These alternatives will be devel-
oped by the Contractor as part of an RI/FS work plan and they are imperative to the development
process since they are the driving force for conducting the Remedial Investigation and the
Feasibility Study (RI/FS). They will help determine the objectives that are to be accomplished dur-
ing the project, define the data gaps that will need to be filled in order to be able to conduct the
FS and determine the quality of data required.
3.2 Work Plan Development
One of the major tasks under the core list of interim tasks is the Work Plan Development task.
The work plan describes the activities and tasks the Contractor will execute to accomplish the
complete SOW under the WA. If a phased RI/FS approach is to be used, the work plan should
describe the first phase tasks in detail and proposed future tasks in a general manner. An esti-
mate for LOE, costs and time required will have to be prepared for both the first phase tasks and
the future tasks. The budget and schedule information for the first phase tasks should be straight
forward and readily accomplished. The budget and schedule information for the future tasks will
normally not be able to be prepared with the same amount of certainty or detail however, enough
information must be provided to justify the LOE and budget specified in the work plan. While it is
important that the future tasks be general to provide flexibility, enough information must be pro-
vided to allow the RPM/RPO and the Contracting Officer a solid basis for approving the work
plan.
The Contractor must also complete an Optional Form 60 (OF-60) or a Standard Form 1411
(SF-1411) as part of the work plan. The Contractor must also complete a WAF (Final Work Plan
Approval) as shown m Figure 6A. The Contractor should complete Item 1 of the WAF and should
mark the "Final Work Plan Approval box" under Item 2. The Contractor can also fill in the
Approved Work Plan Budget in the "This Action" and "Total" columns in Section 3 reflecting the
technical LOE hours and total cost budget supported in the final work plan text and the SF-1411
or OF-60. If the final approved work plan revises the completion date for the entire work assign-
ment then the Contractor should reflect this new date in the revised line of section 4 - "WA
Completion Date"
The Contractor's Regional Manager and Site Manager must sign the appropriate spaces under
Item 6 prior to transmittal of the form to the RPM/RPO. When the RPM/RPO approve the work
plan they must verify and complete section 3 of the WAF (budget information) and provide appro-
priate comments in section 5. If it is determined that the Expenditure Limit column is to be used.
the RPM/RPO will complete the EL portions of sections 2 and 3. noting the limit in the comment
section. Additional information regarding Expenditure Limit usage is provided in section 3.3.
B-22
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FIGURE 6A
USEPA
1 WORK ASSIGNMENT INFORMATION
PROJECT NAME ABC CO., TX
ACTIVITY RI/FS
9/25/84
DATE
2 DESCRPTONOF
n ^
Q NEWWORK
ASSIGNMENT . change in
Intenm SOW, Scope by
schedule, and LOE
Add add
Complete SOW estimated or Kinds
budget and schedules
G INCRE
REOURED FUN
APPROVAL
EPA REGION/ E
HEADQUARTERS HEA1
f BUDGET INFORMATION
TOTAL RINDING
RECEIVED
J
CURRENT
TOTAL
' Option dollar astlmate may be tracked
regionally in expenditure limit block -i ACO
FPA Mttrrmwd LOE noun of entire WA .U3(J
WORK ASSIGNMENT FORM
CONTRACTOR CDM INC
WORK ASSIGNMENT NO
ppirn 68-01-6939 oeuKinNM0.
999-PM1-RT-CDHB
- CONTRACTOR CONTROL NO --_... U/ITIICI^»TI/>»J ur*
Q PARTIAL WORK PLAN
ERIM APPROVAL
1-6L51
2
N/A
(Contractina Officer Use Only)
FINAL WORK PLAN
LOE APPROVAL
tuk Approval of work plan
Add funds
O AMENDMENT TO FINAL
WORK PLAN APPROVAL
MENTAI- Change in LOE, scope or
DING budget by task
Add additional task or funds
(include OF 60 or SF 1 41 1)
PA REGION/
XXIARTERS EPA REGION/
HEADQUARTERS
NTEHIM BUDGET
(TECHNICAL LOE) (»)
4 WA COMPLETION DATE
CURRENT 9/30/85
TECHNCAL DRECTCN
D MEMORANDUM
Detailed scope, budget
and schedule
Revise expenditure level
Minor »h«t withm SOW
(All changes must be within
overall scope, budget, and
LOE approved by EPA CO)
EPA REGION
APPflCVED
WOFKPUNBUOOET
(TECHNICAL LOE) ($)
7,050 550,000
7.050 550,000
INCLUDES FEES
WORK ASSIGNMENT
D COMPLETION NOTFCATON
(NO ATTACHMENTS)
Contractor originates
Regional determination
When signed by CO,
this constitutes a
stop work order
CONTRACTOR
EXPBCmjRE
LIMIT (EL) '
(TECHNICAL LOE) (J)
ESTABLISHED BY
RPM/RPO
REVISED
5 EPACOMMENTS:
Example of portion completed by the Contractor
i APPROVALS
CCtffrkACTOR aQNATURSS
S^A*AGER>L ^
/w?/)/~ Kwich'il~ PH°NE
REGIONAL MANAGER/FIRM
Q APPROVED AS SUBMITTED
/ EPA SIGNATURES.
ybf)l&
OJECT MANAGER
Q£TE ' REGIONAL PROJECT OFFICER
Q APPROVED WfTH CHANGES
SIGNATURE OF CONTRACTING OFFICER
DATE
DATE
| | NOT APPROVED
DATE APPROVED
CC E^A Project Officer
HPORPM
Contractor
EPA Contracting Officer (when only
expenditure limit column is used)
'DATE 11/13(86
B-23
ATTACH STATEMENT OF WORK
(PER DESCRIPTION OF ACTION)
-------
The RPM/RPO will then submit the work plan, WAF, OF-60 or SF-1411. and PR's as needed to
the EPA CO for approval. The package is reviewed by the CO, who then provides approval by
signing on the bottom of the form with any appropriate comments noted in section 5 If the EPA
CO does not approve the work plan, the not approved box will be checked and the. EPA CO will
initial and date the WAF. The EPA CO will send a copy of the WAF containing the approval (or
disapproval) of the work plan and funding authorization to the RPM/RPO, the Contractor, and the
authorization of funding to the RPM/RPO, the Contractor and to the EPA PO.
A completed WAF (Final Work Plan Approval) with full funding is shown in Figure 6B and with par-
tial funding in Figure 6C. Figures 6B and 6C also reflect Expenditure Limits being exercised by
the Region.
If the RPM/RPO does not approve the work plan, the Contractor will meet with the RPM/RPO to
resolve any conflicts or answer any questions. The Contractor will then modify the work plan in-
corporating the changes agreed upon and will re-submit the work plan to the RPM/RPO for ap-
proval. If approved, the approval process will follow the procedures described above.
3.3 Interim Amendments
There are times when it becomes necessary to revise a work assignment prior to work plan ap-
proval. This revision requires the preparation and submitlal of an Interim Amendment WAF. An
Interim Amendment will be required when there are changes to the SOW, LOE dollars, entire pro-
ject schedule, or if it is necessary to add additional Contractor tasks. The Contractor will initiate
the Interim Amendment request, attach documentation identifying changes in SOW, budget, and
schedule, and forward for approval to the EPA RPM/RPO. Upon approval, the amendment request
will be transmitted to the EPA CO for final approval. The EPA CO will issue a contract modifica-
tion when an increase in funding is approved, otherwise changes will be duly noted on the final
approved WAF.
3.4 Responsibilities
The duties and responsibilities for the Contractor, EPA RPM/RPO and CO are described below:
The Contractor is responsible for the following tasks:
Conducting the interim tasks;
Preparing and submitting to EPA the work plan, including SOW. budget and schedules
presented by task:
Meeting with the RPM/RPO to resolve any outstanding issues or comments by the RPM/
RPO on the work plan;
Revising the Work Plan per EPA's comments and re-submiltmg the work plan to the
RPM/RPO with the WAF and SF-1411 or OF-60;
Executing the approved scope of work upon written approval by 'he EPA CO;
B-24
-------
FIGURE 6B
USEPA
WORK ASSIGNMENT FORM
1 WORK ASSIGNMENT INFORMATION
PROJECT NAME ABCCO..TX
CONTRACTOR
COM INC.
WORK ASSIGNMENT NO
1-6L51
ACTIVITY
RI/FS
EPA CONTRACT NO
68-01-6939
. REVISION NO
DATE
9/25/84
OQQ pfull RT CDHR
. CONTRACTOR CONTROL NO. nn i-n i-v/umo uoDFICATION No
N/A
(Contracting Officer Use Only)
2 DESCRPTIONOF
ACTION
E NEWWORK
ASSIGNMENT
Interim SOW.
schedule, and LOE
Complete SOW estimated
budget and schedules
RECURED
APPROVAL
EPA REGION/
HEADQUARTERS
INTERIM
I AMENDMENT
Change In LOE.
Scop* by task
Add sdcHonal task*
or funds
INCREMENTAL
FUNDING
EPA REGION/
HEADQUARTERS
PARTIAL WORK PLAN
APPROVAL
FINAL WORK PLAN
APPROVAL
Approval of work plan
Add fund*
AMENDMENT TO FINAL
WORK PLAN APPROVAL
Chang* in LOE. scop* or
budget by task
Add additional task or fund*
(include OF 60 or SF 1411)
EPA REGION/
HEADQUARTERS
TECHNCAL DBECTCN
Q MEMORANDUM
Detailed scop*, budget
and schedule
Revise expenditure level
Minor shift within SOW
(All change* must be within
overall scop*, budget, and
LOE approved by EPA CO)
EPA REGION
WORK ASSIGNMENT
D COMPLETON NOTFCATON
(NO ATTACHMENTS)
Contractor originates
Regional determination
When signed by CO,
this constitutes a
stop work order
CONTRACTOR
BUDGET INFORMATION
CURRENT
THIS ACTION
TOTAL
TOTAL FUNDING
R6C8VB3
S
120,000
430,000
550,000
Option dollar estimate may be tracked
regionally in expendilure limit block 7 0*50
EPA estimated LOE hours ol enure WA
NTERIM BUDGET
(TECHNICAL LOE) (*,'
INCLUDES FEES
APPROVED
WORK PLAN BUDGET
(TECHNICAL LOE)
7.050
t*r
550,000
7,050
550,000
INCLUDES FSS
EXPENDITURE
LIMIT (EL) '
(TECHNCAL LOE)
ESTABLISHED BY
RPM/RPO
4 WA COMPLETION DATE
CURRENT
9/30/85
REVBED.
10/30/85
5 EPA COMMENTS'
Example of full funding - No additional controls needed.
Dollars and hours previous!/ approved under interim budget replaced
with those indicated under work plan budget column.
VALS
REGIONAL MANAGER/FIRM
EPA SI
REGIONAL
APPROVED AS SUBMnTED
APPROVED WITH C
NOT APPROVED
SIGNATURE OF CONTRACTING OFFCER
DATE APPROVED
CC EPA Project Officer
RPO/RPM
Contractor
EPA Contracting Officer (when only
expenditure limit column is used)
UPDATE IMS/86
B-25
ATTACH STATEMENT OF WORK
(PER DESCRIPTION OF ACTION)
-------
FIGURE 6C
USEPA
WORK ASSIGNMENT FORM
1 WORK ASSIGNMENT INFORMATION
PROJECT NAME ABC CO., TX
CONTRACTOR
COM INC.
WORK ASSIGNMENT NO
1-6L51
ACTIVITY
DATE.
RI/FS
EPA CONTRACT NO 68-01-6939 REVISION NO
9/25/84 999-PM1-RT-CDHB
CONTRACTOR CONTROL NO MODIFICATION NO
(Contnctmq Officer Ui
N/A
lOnly)
2 DESCRPTONOF
ACTION
E NEWWORK
ASSIGNMENT
Intenm SOW,
schedule, and LOE
Complete SOW estimated
budget and schedule*
RECUAED
APPROVAL
EPA REGION/
HEADQUARTERS
INTERIM
Q AMENDMENT
Change in LOE.
Scope by task
Add sddftonal tasks
or funds
r-i INCREMENTAL
FUNDING
EPA REGION/
HEADQUARTERS
PARTIAL WORK PLAN
APPROVAL
FINAL WORK PLAN
APPROVAL
Approval of work plan
Add funds
AMENDMENT TO FINAL
WORK PLAN APPROVAL
Change in LOE, scope or
budget by task
Add additional task or funds
(include OF 60 or SF 1411)
EPA REGION/
HEADQUARTERS
TECHNICAL DRECTON
Q MEMORANDUM
Detailed scope, budget
and schedule
Revise expenditure level
Minor shift within SOW
(All changes must be withm
overall scope, budget, and
LOE approved by EPA CO)
EPA REGION
WORK ASSIGNMENT
Q COMPLETION NOTFCATON
(NO ATTACHMENTS)
Contractor originates
Regional determination
When signed by CO,
this constitutes a
stop work order
CONTRACTOR
f. BUDGET INFORMATION
CURRENT
THIS ACTION
TOTAL
TOTAL FUNDING
RECEIVED
$ '
120,000
430,000
550,000
OpDon - dollar estimate may be tracked
regionally in sxpenddure limrt block 7 QCQ
EPA esunand LOE hours of «n«rs WA 'U3U
KTEHIM BUDGET
[TECHNICAL LOE) (*}*
INCLUDES FEES
APPROVED
WORK PLAN aUDOET
(TECHNICAL LQE>
7,050
(*)
550,000
7.050
550,000
INCLUDES FffiS
EXPENDITURE
LIMIT (EL) *
(TECHNICAL LOE) (*)
3.100 400,000
3,100 400,000
ESTABLISHED BY
RPM/RPO
4 WA COMPLETION DATE
CURRENT
9/30/85
REVISED
10/30/85
5 EPA COMMENTS'
Example of partial funding - Additional control of expenditures has been set in the Expenditure Limit column
Prior approval required before Tasks 2a(2) and 2b(2) are initiated.
,,6 APPROVALS
RECTOR SGf/ATUR
REGIONAL MANAGER/FIRM
DATE
REGIONAL PROJ EC tDFFlCER
Q] APPROVED AS SUBMITTED
ED WITH CHANGES
NOT APPROVED
DATE APPROVED
CO EPA Proiect Officer
RPO/RPM
Contractor
EPA Contracting Officer (when only
expenditure limit column is used)
UPDATE 11,13,86
B-26
ATTACH STATEMENT OF WORK
(PER DESCRIPTION OF ACTION)
-------
Submitting TDM forms where execution of task work so warrants: and
Tracking budgets and schedules to insure timely completion of the assignment on or be-
low budget.
The RPM/RPO are responsible for-
coordinating the review of the work plan with peer reviewers;
submitting comments on the work plan to the Contractor:
meeting with the Contractor to resolve any comments or outstanding issues;
approving the work plan by completing the appropriate portions of the WAF;
setting an Expenditure Limit upon approval of the work plan by the EPA CO (as specified
above);
submitting the approved work plan including the WAF, OF-60 or SF-1411, and the pur-
chase request (as required) to the EPA CO for approval;
transmitting the completed WAF, when utilizing the phased approach with an Expenditure
Limit, to the Contractor, EPA PO, and the EPA CO: and
tracking schedules and budgets to insure timely completion of the assignment on or be-
low budget.
The EPA Contracting Officer is responsible for conducting the following
tasks:
Approving the work plan and authorizing funding by signing the WAF;
obligating funds and establishing the expenditure ceiling; and
transmitting the completed WAF to the RPM/RPO, Contractor and the EPA PO
B-27
-------
4.0 IMPLEMENTING THE APPROVED WORK PLAN
The flow chart shown m Figure 7 (Level 3) describes the implementation of the Work Plan by the
Contractor Upon completion of the Work Plan, or the first phase of the Work Plan, the
Contractor reviews and interprets the data that has been developed. This review will be used to
determine if additional data will be needed in order to complete the Work Assignment and/or to
provide the information that will be necessary to support a remedial alternative. Part of this review
will consist of performing a limited FS analysis (i.e., screening of the remedial alternatives using
the data generated as part of the Rl).
During the execution of the approved tasks in the work plan, changes sometimes occur or site
conditions are encountered that are different than originally projected. Because these changes in
the execution of an approved work plan may affect the approved LOE or dollar values, the work
plan and the work plan estimates may have to be revised. It should be noted that work plans can
be modified at any time during the execution of the statement of work.
The following sections present guidelines for cost tracking and utilization of the expenditure limit
of the WAF as well as two ways of modifying an approved work plan. The first is the Technical
Direction Memorandum (TDM), which is to be used when there are modifications in the execution
of a task or work phase based upon new site conditions or data. The second source of work as-
signment modification is the amendment to the final work plan approval, when a significant fun-
ding increase is required, new tasks or phases are added, or a major change occurs during the
execution of an approved task. Table 3 provides guidance when either a TDM or an amendment
is appropriate.
4.1 Cost Tracking
It is critical that work assignment budgets,. LOE needs, and schedules are reviewed by the
Contractor Site Manager routinely to insure that no unnecessary delays are encountered due to
the lack of funds or LOE. As explained in more detail in Section 4.2.2 of this package, when the
additional funding needed to effectively continue work on the assignment is in excess of 10% of
the approved work plan budget, it becomes necessary to process an amendment request. Site
managers should track schedule, LOE, and budgets closely to be able to identify early on when
amendments will be needed.
An amendment request to a final work plan approval can be submitted at any time during the
course of an assignment when a major change has occurred or when additional funding or LOE
are required. However, at a minimum, each assignment should be reviewed in detail when ex-
pended costs are at the 75% of the total funding level, or the approved work plan dollar level,
whichever is less At this point, the Contractor is required to notify the RPM in writing if additional
funds or LOE are required and submit a work assignment amendment if this is the case. Periodic
reviews by the Contractor Site Manager will result in the flagging of potential funding needs. This
early identification and subsequent amendment processing will eliminate any interference with
overall project schedules
B-28
-------
FIGURE 7
IMPLEMENTATION OF APPROVED CONTRACTOR WORK PLAN
CONTRACTOR ANALYZES
AND INTERPRETS THE
RESULTS AND
SCREENS THE
ALTERNATIVES
ro
(0
NO ADDITIONAL
DATA NEEDED FOR
FEASIBILITY STUDY (FS)
ADDITIONAL DATA
NEEDED TO PERFORM
THE FEASIBILITY
STUDY (FS)
NOT APPROVED
L_C
CONTRACTOR DEVELOPS
DETAILED SOW.
SCHEDULE AND
BUDGET
NO MAJOR SCOPE
OR BUDGET CHANGES
REQUIRED
CONTRACTOR SUBMITS
SOW BUCKET AND
SCHEDULE WITH WAF
(TDM) INCLUDING SOW
AND BUDGET TO
RPM FOR APPROVAL
ADDITIONAL FUNDING
OR MAJOR SCOPE/SCHEDULE
CHANGE REQUIRED
CONTRACTOR PREPARES
AND SUBMITS WAF
(AMENDMENT TO WP
APPROVAL INCLUDING
SOW, SCHEDULE. BUDGET,
AND OF 60 OR SF 1411)
RPM/RPO SIGN WAF
ATTACH PR (IF ADDITIONAL
FUNDING IS NECESSARY)
AND ISSUE TO CO FOR
APPROVAL WITH
COPY TO PO
RPO/RPM APPROVE
THE TDM INCREASE
EL AND SEND COPIES
OF THE WAF TO
CO PO AND CONTRACTOR
CONTRACTOR
EXECUTES SOW
CONTRACTOR PREPARES
RI/FS REPORT
CO APPROVES WP
AMENDMENT AUTHORIZES
FUNDING AND SENDS
APPROVALAND
AUTHORIZATION TO
REGION AND CONTRACTOR
CONTRACTOR
EXECUTES SOW
EPA DEVELOPS
ROD
TO LEVEL 4
-------
TABLE 3
ACTION/EXECUTION SUMMARY
ACTION EXECUTION
Add new task or phase W.A. Amendment
Modification to task which affects W.A. Amendment
overall approved LOE, dollars, and
schedule end date
Approve phase (in phased RI/FS) TDM
that was part of entire work plan
approval and increase Expenditure
Limit (EL)
Modify execution of task or phase TDM
within approved LOE dollar limits
of assignment, prior to actual
execution
Document changes made to execution TDM
of task or phase which did not
affect overall approved LOE
or dollar limits
B-30
-------
4.2 Modifying Approved Work Plan
4.2.1 Utilizing the Expenditure Limit (EL) Option for Approved Work Plans
Upon receipt of the WAF, the RPM/RPO may choose to set a Regional Expenditure Limit (EL).
This limit provides a mechanism for the region to manage the phasing and execution of the
Approved Final Work Plan.
Expenditure Limits are a regionally controlled mechanism that can be used to:
limit execution of work to distinct phases, as in phased RI/FS studies; or
provide control over the execution of individual tasks within an approved work plan.
Since Expenditure Limits are assigned at a regional level, they can only be used to control the
execution of tasks or phases that have been approved by the EPA CO.
There are at least two different ways to write work plans using the expenditure limit column. They
are discussed in the following two examples:
EXAMPLE 1 - Is best utilized when control is desired and mobile labs are used and/or activity will
be ongoing. Tasks and descriptions are for example purposes only.
Work Plan
1. Initial Tasks $106,000
2. Field Activities
A1 Well Drilling-Known Amount & Location $ 94,000
A2 Well Drilling-Undetermined Amount/Location $ 50,000
B1 Soil Sampling-Known Amount & Location $ 50.000
B2 Soil Sampling-Undetermined Amount/Location $ 50,000
01 Sediment Sampling $ 50,000
D1 Air Sampling $ 30,000
3. Feasibility Study $ 30,000
A1 Screening $ 20.000
B1 Evaluation $ 50.000
C1 Pilot Plants $ 50,000
In this case, the RPM/PO and Contractor have decided that the amount of well drilling and soil
sampling may vary depending on the conditions found. The RPM/RPO may approve all tasks as
shown or may approve all tasks overall but control the initiation of any task by using the EL col-
umn and writing appropriate comments in the COMMENT section of the TDM. For example, an
applicable EPA comment in this case would be-
Regional Control - Prior approval required before implementing tasks 2-A2. 2-B2. and 3-C1.
B-31
-------
The dollar amount in the EL column should reflect the dollar amount of clearly defined tasks
($400.000). however, the final WP approval column should reflect the total of all tasks ($650,000)
If additional wells are required as field work progresses, the Contractor would notify the RPM/
RPO through a TDM. which would outline the number of additional wells at what cost. The RPM/
RPO would approve the WAF, providing the total project cost and LOE are within the entire work
plan, and the work would continue. In some cases, field decisions will have to be made without
the benefit of full written approved documentation. For example, if field conditions require addi-
tional well drilling, this sometimes has to be done immediately to reduce costs due to remobiiiza-
tion. etc. In this situation, logistics or time do not allow written documentation prior to approval,
therefore verbal approval may be given by the RPM/RPO. It is imperative that follow-up documen-
tation in the form of a completed WAF be submitted as soon as possible. If more money is re-
quired in task 2-A2 and less money is required in task 2-B2, approval may still be given on the
regional level providing the total dollars and LOE do not exceed the entire work plan budget.
EXAMPLE 2 - Is best utilized when discrete sampling trips are required. The second trip is
scoped out after the first is completed. Tasks and descriptions are for example purposes only:
Task 1 Initial Activities $106,000
Task 2 Phase 1-Fieldwork/Alternative Screening $294.000
Task 3 Phase 2-Fieldwork/Alternative Evaluation $ 90,000
Task 4 Phase 3-Fieldwork/Alternative Selection $ 60,000
In this case the EPA CO would have approved all tasks but the RPM/RPO may elect to regionally
limit the Contractor to working on Tasks 1 and 2. When information is gathered from Task 2, a
TDM better defining the proposed activities should be submitted to the RPM/RPO for Task 3. The
RPM/RPO would approve Task 3 and the Contractor would then execute the task. The CO signa-
ture is not required for regionally controlled tasks unless activities being added are not within the
Total LOE or Total budget, or within the approved scope of work.
Analysis of the phased work accomplished to date could result in significant revisions to the future
work tasks. It is important to note that each successive WAF for a WA supersedes the previous
WAF and therefore ALL required information must be provided. If a region establishes expendi-
ture limits to manage the phased execution of a WA and neglects to complete the expenditure
limit column in a subsequent submittal, the regional expenditure control will be voided. If this oc-
curs, the control will either be the approved final work plan or total funding received.
422 Technical Direction Memorandum
The Technical Direction Memorandum (TDM) represents the administrative procedures used to
document and authorize the execution of 1) previously generally defined tasks; 2) phases that
were included in the work plan approval but not authorized for execution (as in phased RI/FS
studies): and 3) modifications to the planned execution of tasks or phases that do not have signifi-
cant effect on the approved LOE or dollars. The TDM is important in that approval of changes
B-32
-------
documented in the TDM can be approved by the Region as long as those changes do not require
revisions to approved LOE, dollar, or schedule end dates. The task modifications, documented
with a TDM, may be a result of new site conditions, new data, or the authorization of the execu-
tion of more clearly defined tasks. In those cases, the TDM can be used by the Contractor to pro-
vide additional details on generally defined tasks. TDM's cannot be used to document major
changes in scope which would clearly exceed the overall approved budget or LOE levels for the
assignment. Changes of this nature must be documented and approved through a WA
Amendment (see 4.2.3 below).
As seen in Figure 7, upon completion of the detailed scope, schedule and budget, the Contractor
will determine if the new scope and budget are within the initial scope and budget provided in the
work plan. Changes in the execution of approved SOW tasks which fall within the total LOE and
budget are delegated to the Regional RPO for approval action. If it is determined that the task or
phase is within the scope, budget, and schedule of the Work Plan, the Contractor will prepare a
WAF and attach this to the detailed scope, schedule, and budget. The Contractor will be respon-
sible for checking the WAF in the Technical Direction Memorandum (TDM) box and submitting
this information to the RPM/RPO for approval. Figure 8 presents the two page TDM form. This
form has been developed to aid the Contractor in the preparation and documentation of the
changes being requested. This form will insure that the required data will be submitted to the
RPM/RPO in a format designed to expedite the regional approval process. The enclosed TDM
form represents one standard format for executing modifications to planned field or task work.
However, other types of documentation (in the form of letters or memorandums to the RPO) could
be used by the Region to modify the execution of work or the establishment of subsequent re-
gional expenditure limits. These expenditure limits are explained in more detail in previous section
4.2.1.
Figure 9 presents a sample completed TDM form. Section 1.0 contains the general work assign-
ment information and serves as a tracking device for the overall site activity. Section 2.0 presents
the objective and the approach of the modifications. Both the objective and the approach should
be as brief as possible, while still detailing the modifications being carried out. Section 3.0 (page
2 of the form) explains subcontractor requirements, if any, and Section 4 0 presents schedule and
deliverable changes. Section 5.0 contains the budget information which provides a task break-
down of costs and hours with the totals, including any variance. Section 6.0 summarizes the im-
pact of the current proposed TDM action on the overall assignment LOE and cost. As noted on
the bottom of page 2 of the TDM form, if there is a significant positive variance, an amendment
request may have to be processed by the site manager based on discussions with the RPO. If
there are only small positive variances (< 10% of approved work plan budget) projected which
may be absorbed throughout the course of the project, an amendment request should not be pro-
cessed at this time. Section 7.0 of the TDM is for final approval signatures by the Contractor and
Regional personnel.
The RPM/RPO will be responsible for approving the TDM by completing the appropriate sections
of the WAF and returning a copy of the completed WAF to the Contractor, the EPA PO. and the
EPA CO. A copy of a completed WAF for a TDM is shown in Figure 10. In this example, while the
B-33
-------
FIGURES
PAGE 1 OF 2
USEPA
TECHNICAL DIRECTION MEMORANDUM
1.0 WORK ASSIGNMENT INFORMATION
DATE-
PROJECT NAME:
EPA CONTRACT NO.:
CONTRACTOR-
REVISION NO.:
WORK ASSIGNMENT NO.:
SITE MANAGER/FIRM:
CONTRACTOR CONTROL NO:
2.0 TECHNICAL DIRECTION SCOPE OF WORK
OBJECTIVE:
APPROACH: (Present description of Task and Sub-task basis)
B-34
-------
FIGURE 8 (Continued)
PAGE 2 OF 2
USEPA
TECHNICAL DIRECTION MEMORANDUM
3 0 SUBCONTRACTOR REQUIREMENTS
(Description of Services)
4.0 SCHEDULE AND DELIVERABLE:
TASK NO.
START DATE:
COMPLETION DATE:
DELIVERABLE:
(TASK NO.'S PER TECHNICAL DIRECTION SCOPE OF WORK)
5.0 BUDGET INFORMATION:
TASK NO.
PROFESSIONAL
HOURS COST
SUPPORT
HOURS COST
EQUIP
TRAVEL
COGS
SUB POOL
FEES
TASK
TOTALS
TOTAL
COMMITED
TO DATE
APPROVED
BUDGET
VARIANCE
6 0 TOTAL ORIGINAL
WA BUDGET:
$
LOE
TOTAL REVISED WA BUDGET:
LOE
7 0 APPROVALS-
CONTRACTOR SIGNATURES
$
LOE
VARIANCE:
SITE MANAGER/FIRM
DATE
REMEDIAL PROJECT MANAGER
DATE
REGIONAL MANAGER/FIRM
DATE
REGIONAL PROJECT OFFICER
DATE
If there is a significant positive variance, an amendment request mav have to be
processed by the site manager after discussions with the RPO. B-35
-------
FIGURE 9
PAGE 1 OF 2
USEPA
TECHNICAL DIRECTION MEMORANDUM
1.0 WORK ASSIGNMENT INFORMATION
DATE 10/15/84
PROJECT NAME:
ABC CO., TX
EPA CONTRACT NO.:
CONTRACTOR:
REVISION NO.'
68-01-6939
COM INC.
WORK ASSIGNMENT NO.:
SITE MANAGER/FIRM:
1-6L51
JOHNNY SAMPLE - COM
CONTRACTOR CONTROL NO.:
999-PM1-RT-CDHG
2.0 TECHNICAL DIRECTION SCOPE OF WORK
OBJECTIVE: To conduct field activities at the site. Field activities that are
being conducted during Phase I include first round well drilling,
soil sampling, sediment sampling, and air sampling.
APPROACH: (Present description of Task and Sub-task basis)
Tasks affected by this TDM are as follows:
Task 2A-1 Well Drilling - Phase I
Task 2B-2 Soil Sampling - Phase I
Task 2C-1 Sediment Sampling - Phase I
Minor changes in the scope of the above listed sub-tasks occurred
during the conduct of the work assignment. The detail of the scope
changes are attached. (ATTACHMENT NOT INCLUDED IN THIS GUIDANCE
DOCUMENT). While the individual task budgets have changed, there is
no impact on the overall budget or LOE ceilings for this assignment.
B-36
-------
FIGURE 9 (Continued)
PAGE 2 OF 2
USEPA
TECHNICAL DIRECTION MEMORANDUM
3.0 SUBCONTRACTOR REQUIREMENTS
Not Applicable
(Description of Services)
4.0 SCHEDULE AND DELIVERABLE:
TASK NO.
A-1
B-1
C-1
START DATE:
3/8/85
4/16/85
4/16/85
COMPLETION DATE:
6/25/85
5/2/85
5/12/85
DELIVERABLE:
(TASK NO.'S PER TECHNICAL DIRECTION SCOPE OF WORK)
5.0 BUDGET INFORMATION:
TASK NO.
PROFESSIONAL
HOURS COST
SUPPORT
HOURS COST
EQUIP
TRAVEL
OOC'S
SUB POOL
FEES
TASK
TOTALS
A-1
1,170
27,000
130
3,000
1,000
500
1,200
47,300
5,635
85,635
B-1
608
13,500
67
1,500
1,500
700
1,700
22,600
3,020
44,520
C-1
608
13,500
67
1,500
1,500
500
2,000
21,000
2,950
42,950
TOTAL
2,386
54,000
264
6,000
4,000
1,700
4,900
90,900
11,605
173,015
COMMITED
TO DATE
3,100
100,000
310
25,000
5,000
3,000
7,000
225,000
25,250
390,250
APPROVED
BUDGET
2,500
60,000
280
7,000
4,500
2,100
5,200
104,000
13,080
195,880
VARIANCE
(114)
(6,000)
(16)
(1,000)
(500)
(400)
(300)
(13,100)
(1,475)
(22,775)
6 0 TOTAL ORIGINAL
WA BUDGET.
7 0 APPROVALS
CONTRACTOR SIGNATURES
550,000
TOTAL REVISED WA BUDGET:
$ 550,000
VARIANCE:
LOE
7,050
LOE
7,050
LOE
SITE MANAGER/FIRM
DATE
REMEDIAL PROJECT MANAGER
DATE
REGIONAL MANAGER/FIRM
DATE
REGIONAL PROJECT OFFICER
DATE
If there is a significant positive variance, an amendment request mav have to be
processed by the site manager after discussions with the RPO. B-37
-------
FIGURE 10
USEPA
WORK ASSIGNMENT FORM
1 WORK ASSIGNMENT INFORMATION
PROJECT NAME ABC CO., TX
CONTRACTOR
COM INC.
WORK ASSIGNMENT NO
1-6L51
ACTIVITY
DATE
RI/FS
EPA CONTRACT NO
68-01-6939
. REVISION NO
10/3°/84
CONTRACTS CONTROL NO
MOOF,CATON NO
N/A
(Contracting Officer Us* Only)
2 DESCRPTON OF
ACTION
E NEW WORK
ASSIGNMENT
Interim SOW,
schedule, and LOE
Complete SOW estimated
budget and schedules
REQUIRED
APPROVAL
EPA REGION/
HEADQUARTERS
INTERIM
AMENDMENT
Cheng* in LOE,
Scope by task
> Add addHonal tasks
or funds
INCREMENTAL
FUNDING
EPA REGION/
HEADQUARTERS
PARTIAL WORK PLAN
APPROVAL
FINAL WORK PLAN
APPROVAL
Approval ol work plan
Add funds
AMENDMENT TO FINAL
WORK PLAN APPROVAL
Change in LOE, scope or
budget by task
Add additional task or funds
(include OF 60 or SF 1411)
EPA REGION/
HEADQUARTERS
TECHNCAL DRECTDN
I MEMORANDUM
Detailed scope, budget
and schedule
Revise eipendrture level
Minor shift withn SOW
(All changes mutt be within
overall scope, budget, and
LOE approved by EPA CO)
EPA REGION
WORK ASSIGNMENT
D COMPLETION NOTFCATON
(NO ATTACHMENTS)
Contractor originates
Regional determination
When signed by CO,
this constitutes a
stop work order
CONTRACTOR
Ji BUDGET INFORMATION
CURRENT
THIS ACTION
TOTAL FUNDING
HECENED
$ '
600,000
600,000
TOTAL
OpQon - dollar estimate may be Tracked
regionally m expenditure limn block
EPA MDmatM LOE noun of erare WA .
NTERIM BUDGET
(TECHNICAL LOE) (*)*
INCLUDES FSES
APPROVED
WORK PLAN BUDGET
(TECHNICAL LOE)
7,050
550,000
7,050
550,000
INCLUDES FEES
EXPENDrtURE
LIMIT (EL) *
(TECHNICAL LOE) (J)
6,730 400,000
50,000
6,730 450,000
ESTABLISHED BY
RPM/RPO
4 WA COMPLETION DATE
CURRENT
9/30/85
REVISED
10/30/85
5 EPACOMMENTS-
Additional well drilling defined - still within overall scope, schedule, and budget hours.
APPROVED AS SUBMITTED
APPROVED WITH CHANGES
NOT APPROVED
SIGNATURE OF CONTRACTING OFFCER
DATE APPROVED
CC EPA Project Officer
RPO/RPM
Contractor
EPA Contracting Officer (when only
expenditure limit column is used)
L°DATE 11/1386
B-38
ATTACH STATEMENT OF WORK
(PER DESCRIPTION OF ACTION)
-------
current work plan approval amount is 7.050 hours and $550.000, the regional expenditure limit
has been set at 6.730 hours and $450.000.
4.2.3 Amendment to Final Work Plan Approval
If it is determined that additional funds are needed beyond the approved work plan, a major
scope change is required, or an overall WA completion date change is necessary, the Contractor
will be responsible for requesting an amendment to the work plan. To accomplish this, the
Contractor will submit the detailed scope, budget, and schedule for the changes to the assign-
ment to the RPM/RPO with an appropriately completed WAF The Contractor will check the box
labeled Amendment to Final Work Plan Approval on the WAF as part of this submittal. The
Contractor will also be responsible for developing and submitting an OF-60 or SF-1411 as part of
this submission. It is the RPM/RPO's responsibility to approve the Amendment to the Final Work
Plan Approval by completing and submitting the WAF along with the required attachments to the
EPA CO. In addition, the RPM/RPO will need to check the funding level of the project to deter-
mine if a procurement request will be required as well. A copy of a completed WAF for an
Amendment to Final Work Plan Approval is shown in Figure 11.
If it is necessary to make changes to the work assignment and it is determined that the changes
are minor, a TDM will be adequate. This decision must be based on discussions with the EPA
RPO, who may feel that the dollar amount of the required changes could be absorbed in other
tasks throughout the course of the assignment. If the changes are significant, a WA amendment
is prepared detailing scope, schedule, and budget changes and is submitted for approval to the
EPA RPO.
When an amendment is being prepared, the Contractor should prepare a WAF with appropriate
back-up. The back-up required includes the following:
A detailed scope of work to be performed or a detailed description of the changes that
take place in the assignment;
Schedule update, including task completion dates (milestones), and critical path sched-
ule (optional);
Identification of any subcontracting or special equipment requirements;
Staffing of each task in this phase; and
A detailed LOE and cost estimate for each task or phase being covered by the
amendment.
The EPA CO will approve the WAF, authorize funding as appropriate, and will send a copy of the
completed WAF to the RPM/RPO. EPA PO and the Contractor. In the case of an amendment to
final work plan approval, the Contractor will execute the Statement of Work upon receipt of a
WAF approved by the RPM/RPO and the EPA CO. In addition, the RPM/RPO may again set an
Expenditure Limit (EL) in order to manage the phased execution of the WA at the regional level.
B-39
-------
FIGURE 11
USEPA
1 WORK ASSIGNMENT INFORMATION
PROJECT NAME ABC CO., TX
WORK ASSIGNMENT FORM
CONTRACTOR CDM INC-
WORK ASSIGNMENT NO
ACTIVITY RI/FS FPA CQNTB4rT wo 68-01-6939 HFVISKTNNO
8/15/85 999-PM1-RT-CDHB
DATE CONTRACTOR rv"1NTRC1L NO unme*«»Ti«i»i ur>
2 DESCRPTK3NOF
ACTION NTERIM
D AMENDMENT
Q NEWWORK
ASSIGNMENT .crmnoalnLOE.
Intenm SOW, Scope by task
schedule, and LOE
Add adoWonal tu
Complete SOW estimated or funds
budget and schedules
r-i INCREMENTAL
- REOUraD FUNDING
APPROVAL
EPA REGION/ EPA REG
HEADQUARTERS HEADQUARTi
3 BUDGET INFORMATION
TOTAL FUNDING
RECENED
* ' (TE
CURRENT 450,000
110,000
THIS ACTION
560,000
TOTAL
Option dollar estimate may be tracked
regionally in expenditure lirm block
FPA evwrwed LOE noun of enBre WA
4 WA COMPLETION DATE
CURRENT
n PARTIAL WORK PLAN
APPROVAL
n FINAL WORK PLAN
APPROVAL
Approval of work plan
Add fund*
_ AMENDMENT TO FINAL
WORK PLAN APPROVAL
Change in LOE. scope or
budget by task
Add additional task or funds
(include OF 60 or SF 1411)
ION/
ERS EPA REGION/
HEADQUARTERS
KTERIM BUDGET
CHNICAL LOE) (»)
INCLUDES FEES
9/30/85
1-6L51
5
N/A
(Contractma Officer Use Only)
TECHNCAL DRECTON
P MEMORANDUM
Detailed scope, budget
and schedule
Revise expenditure level
Minor shift withm SOW
(All changes must be within
overall scope, budget, and
LOE approved by EPA CO)
EPA REGION
A°PROVEO
WORK PLAN aUDGET
(TECHNICAL LOE) (Jr (
7,050 550,000
150 10,000
7,050 560,000
INCLUDES FSS
WORK ASSIGNMENT
Q COMPLETON NOTFCATON
(NO ATTACHMENTS)
Contractor originates
Regional determination
When signed by CO,
this constitutes a
stop work order
CONTRACTOR
LIMIT (EL) *
TECHNICAL LOE) (J)
ESTABLISHED BY
RPM/flPO
REVISED 10/30/85
5 EPACOMMENTS-
VNAPPROVALS
SFJE MEAGER /FlfcM \ f A ^
N^e/it krtMb'iT
REGIONAL MANAGER/FIRM
TO APPROVED AS SUBMITTED
T~A
/"/ flrt
T^llr} iTM
1 DATE R
"fakl^/VU(K link
EOtOMALP
w
^n&'mtr*
* dfalvc
Al>/1 n
EGIONAL PnOJECTfcFFIC ER OATJE
Q APPROVED WITH CHANGES
SIGfti^/UflE OF CONTRACTING OFFICER
\ Q NOT APPROVED
DATEvAPPROVED
CC EPA Projsct Officer
RPO/RPM
Contractor
EPA Contracting Otlcer (when only
expenditure limit column is used)
UPDATE 11/13/86
B-40
ATTACH STATEMENT OF WORK
(PER DESCRIPTION OF ACTION)
-------
4.3 Responsibilities
The RPM/RPO are responsible for the following tasks:
reviewing and approving the TDM(s) submitted by the Contractor;
setting an Expenditure Limit, as appropriate, for the execution of work described in the
TDM;
transmitting a copy of the approved WAF-TDM to the Contractor, EPA PC and the EPA
CO;
reviewing and approving Amendments to the Final Work Plan Approval and completing
the WAF;
reviewing funding level when either a TDM or an Amendment to the Final Approved
Work Plan is submitted by the Contractor;
transmitting a copy of the completed WAF and the Amendment to the Final Work Plan
Approval to the EPA CO for approval and authorization;
setting an Expenditure Limit, as appropriate, upon the EPA CO's approval of the
Amendment to the Final Work Plan Approval; and
approving TDM forms submitted by the Contractor.
The EPA Contracting Officer is responsible for the following tasks:
approving Amendments to the Final Work Plan Approval by completing the WAF and au-
thorizing additional funding as appropriate; and
sending copies of the completed WAF to the Contractor, EPA PO and the RPM/RPO.
The Contractor is responsible for the following tasks:
preparing a TDM or an Amendment to the Final Work Plan Approval (together with a
WAF) depending on changes to the original work plan scope budget, and schedule;
submitting the WAF to the RPM/RPO for approval if the work is to be conducted under
a TDM;
submitting the WAF (and, as appropriate an OF-60 or SF-1411) as an Amendment to
the Final Work Plan Approval if major scope, schedule or budget changes are required:
responding to any RPM/RPO comments on the TDM or an Amendment to the Final
Work Plan Approval, and
executing the TDM or Work Plan Amendment SOW upon receipt of the appropriate writ-
ten approvals.
B-41
-------
4.4 Deliverables
The deliverables for this level of the Work Assignment process include the following:
TDM (if required) which includes a completed WAF and a detailed scope, budget and
schedule (Contractor); and
Amendment to the Final Work Plan Approval (if required) which includes a completed
WAF and a detailed scope, budget and schedule from the Contractor (and an OF-60 or
SF-141 as appropriate).
B-42
-------
5.0 COMPLETION OF THE PROJECT
Figure 12 (Level 4) presents a flow diagram identifying the steps involved in the completion ,
close-out, and subsequent invoicing of a work assignment. As shown in Figure 12 and marked by
the completion of the project, a WAF stating that the project is complete (with appropriate de-
tailed budget information) is prepared by the Contractor and submitted to the EPA RPM/RPO.
The RPM/RPO will then sign the WAF and forward it to the EPA CO with a copy to the PO. A
sample completed WAF for a work assignment completion notification is shown in Figure 13.
Upon receipt of the WAF, the EPA CO issues a "Stop Work Order" (SWO) to the Contractor and
submits copies of this SWO to the EPA RPO, RPM, and PO. This SWO will cover major technical
activities only; administrative activities relating to close-out will proceed as needed.
With the SWO in place, the Contractor will then prepare the award fee package, Work
Assignment Completion Report (WACR), and the invoice (excluding close-out costs). The package
is sent to the RPM and the RPO. During the preparation of this package, the Contractor will si-
multaneously begin the physical project close-out. The physical close-out of a work assignment
will include the following activities at a minimum:
Compiling of project files;
turning over all requested files (either in hard copy or microfiche format) to the EPA;
turning over any government owned equipment to the project inventory or to the EPA
Equipment Coordinator (if equipment was purchased with work assignment funds); and
verifying that all appropriate site charges are being processed for inclusion in the final
invoice.
All other close-out procedures and subsequent processing guidelines will be in accordance with
the Contractors Award Fee Plan, which is included in the Management Plan.
B-43
-------
FIGURE 12
COMPLETION OF THE PROJECT
DO
WAF COMPLETION
NOTIFICATION
STATING PROJECT
IS COMPLETE IS
SENT TO EPA CO
WITH A COPY TO PO
CO ISSUES STOP
WORK ORDER TO
CONTRACTOR AND
SUBMITS COPES TO
RPO/RPM AND PO
CONTRACTOR PREPARES
AWARD FEE PACKAGE,
WACa AND INVOICE
(EXCLUDES AWARD FEE
AND CLOSE OUT COSTS)
AND SENDS TO RPM/RPO
AND PO CONTRACTOR ALSO
BEGINS PHYSICAL PROJECT
CLOSE OUT SIMULTANEOUSLY
RPM/RPO PREPARES
EPAWACRAND
FORWARDS TO EPA PO
FORREVEW
EPA PO REVEWS AWARD
FEE PACKAGES, MAKES
DETERMINATION, AND
SUBMITS THE PACKAGE
TOTHEPEB
PEBDEUBERATES
AWARD FEE AND
SUBMITS
DECISION TO THE
CONTRACTS
AUTHORING OFFICIAL
THE CONTRACTS
AUTHORIZMG
OFFICIAL APPROVES
AWARD FEE
EPACOMODIFES
CONTRACT
THROUGH ISSUANCE
OF CONTRACT MOD TO
AUTHORIZE THE
CONTRACTOR TO
NVOCE
FOR THE AWARD FEE
CONTRACTOR
SUBMITS FINAL
NVOCE
-------
FIGURE 13
USEPA
WORK ASSIGNMENT FORM
1 WORK ASSIGNMENT INFORMATION
PROJECT NAME ABC CO., TX
CONTRACTOR:
CDM INC-
WORK ASSIGNMENT NO
1-6L51
ACTIVITY-
RI/FS
EPA CONTRACT NO.
68-01-6939
REVISIONNO
9/30/85
999-PM1-RT-CDHB
N/A
(Contracting Officer Use Only)
2 DESCRPTION OF
ACTION
E NEWWORK
ASSIGNMENT
Interim SOW,
schedule, and LOG
Complete SOW estimated
budget and schedules
REOJBEO
APPROVAL
EPA REGION/
HEADQUARTERS
INTERIM
AMENDMENT
Change in LOE,
Scope by task
> Add additional tasks
or funds
INCREMENTAL
FUNDING
EPA REGION/
HEADQUARTERS
PARTIAL WORK PLAN
APPROVAL
FINAL WORK PLAN
APPROVAL
Approval of work plan
Add funds
AMENDMENT TO FINAL
WORK PLAN APPROVAL
Change in LOE, scope or
budget by task
Add additional task or funds
(mcludeOF60orSFU11)
EPA REGION/
HEADQUARTERS
TECHNICAL DIRECTION
MEMORANDUM
Detailed scope, budget
and schedule
Revise expenditure level
Minor shift within SOW
(All change* must be within
overall scope, budget, and
LOE approved by EPA CO)
EPA REGION
WORK ASSIGNMENT
COMPLETION NOTFCATON
(NO ATTACHMENTS)
Contractor originates
Regional determination
When signed by CO,
this constitutes a
stop work order
CONTRACTOR
3. BUDGET INFORMATION
CURRENT
THIS ACTION
TOTAL
TOTAL FUNOfNS
RECEIVED
$ '
560,000
560,000
Option - dollar estimate may be tracked
regionally in expenditure limit block
EPA estimated LOE hours of entire WA _
NTEHIM BUDGET
(TECHNICAL LOE) (»)*
INCLUDES FEES
APPROVED
WORK PLAN BUDGET
(TECHNICAL LOE)
(*)*
INCLUDES FBS
EXPEND fTURE
LIMIT (ELj -
(TECHNICAL LOE)
(S)
ESTABLISHED BY
RPM/RPO
4 WA COMPLETION DATE
CURRENT
9/30/85
REVBED
9/30/85
5 EPACOMMENTS;
Please close out the above Identified work assignment and send the
Work Assignment Completion Report (WACR) and final invoice to Charles Berry.
.6 APPROVALS
REGIONAL MANAGER/FIRM
E
APPROVED AS SUBMrTTED
NOT APPROVED
SIGN ATUa&taF CONTRACTING OFFICER
CC EPA Project Officer
RPO/RPM
Contractor
EPA Contracting Officer (when only
expenditure limit column is used)
UPDATE 11/13/86
ATTACH STATEMENT OF WORK
(PER DESCRIPTION OF ACTION)
B-45
-------
-------
APPENDIX C
Names and Telephone Numbers of REM Contracting
Officers and Project Officers
Contract
CO/PO
Telephone
REM/FIT(Zone1)
(Expired 9/30/86)
Ron Kovach, CO
Bill Kaschak, PO
202-382-3201
202-382-3248
REM/FIT (Zone 2)
(Expired 9/30/86)
Vince Gonzales, CO
Carol Lindsay, PO
202-382-2090
202-382-2347
REM
Ulrike Joiner, CO
Steve Hooper, PO
202-382-2302
202-475-6689
REM
Ron Kovach, CO
John Smith, PO
202-382-3201
202-382-7996
REM IV
REMV
REM VI
Vince Gonzales, CO
Randy Kaltreider, PO
CO TBD
Robert Quinn, PO
CO TBD
Robert Quinn, PO
202-382-2090
202-382-2448
202-382-2350
202-382-2350
C-1
-------
APPENDIX C
Federal-Lead Regional Coordinators
REGION COORDINATOR TELEPHONE
I Bob Quinn 202-382-2350
II John Smith 202-382-7996
III Lisa Woodson 202-475-8246
IV Lisa Woodson 202-475-8246
V Carol Lindsay 202-475-6704
VI Randy Kaltreider 202-382-2448
VII Carol Lindsay 202-475-6704
VIII Randy Kaltreider 202-382-2448
IX Steve Hooper 202-475-6689
X Steve Hooper 202-475-6689
C-2
-------
APPENDIX D
Example Interim Work Assignment SOW, Blank Procurement
Request/Requisition, Work Assignment Completion Report
Example Interim Work Assignment SOW
Del Norte County Pesticide Storage Area
Initial Tasks Hours
Task 1. Site Evaluation (72 Hours)
Review and Evaluate Existing Information and Data
Review Aerial Photography
Review Local Geography and Hydrology
Task 2. Site Survey (112 Hours)
Conduct Field Survey and Prepare Site Topographic Map
Subcontractor Authorization
Site Visit
Task 3. Development of Site-Specific Plans (448 Hours)
All Administrative Activities Prior to Full Field Work Including:
Quality Assurance Project Plan (QAPP)
Site Management Plan
Data Management Plan
Health and Safety Plan
Sampling Plan
Community Relations Plan
Schedule and Costs
Work Plan Development
Task 4. Site Soil Survey (296 Hours)
EM 31 Survey
Field Sampling
Field Sample Analyses
Task 5. Additional Requirements (320 Hours)
Report on EM 31 Survey
Evaluation and Report on Chemical Analyses and
Soil Contamination
QA/QC Audit
Attend Meetings, Briefings as Needed
Total Project Hours: 1,248
Estimated Cost: $75,000.00
D-1
-------
/Shaded areas are for use ofproeurment office onM
Paae
of
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
PROCUREMENT
REQUEST/ORDER
1. NAME OF ORIGINATOR
3. MAIL CODE
4 TELEPHONE NUMBER
2 DATE OF REQUISITION
5 DATE ITEM REQUIRED
6 SIGNATURE OF ORIGINATOR
7. RECOMMENDED PROCUREMENT METHOD
LJcomcwtitiM LJ NoncoaiMtftive
8 DELIVER TO /Project Manager!
9 ADDRESS
10 MAM. CODE 11. TELEPHONE NUMBER
12 FINANCIAL DATA
(a) APPROPRIATION
NOTE: ITEM 12 (c) DOCUMENT TYPECONTRACT = "C," PURCHASE
ORDER = "P," IGA = "A," OTHER IMisc I - "X"
. FMOUSE .
W (13 digits!
DOCUMENT
CONTROL NUMBER
W(S digits)
ACCOUNT NUMBER
WHO dig**!
OBJECT
CLASS
(I) 14 digits!
AMOUNT (a)
DOLLARS
13. SUGGESTED SOURCE (Hume. Address. ZIP Code. Phone/Contacti
14 AMOUNT OF MONEY
COMMITTED IS
O ORIGINAL
O INCREASE
D DECREASE
15 CONTRACTING OFFICE D IS D IS NOT AUTHOR-
IZED TO EXCEED AMOUNT SHOWN BY 10%
16 SERVICING FINANCE OFFICE NUMBER
17. APPROVALS
BRANCH/OFFICE
DATE
d PROPERTY MANAGEMENT OFFICER/DESIGNEE
DATE
b DIVISION/OFFICE
DATE
e OTHER (Specify)
DATE
c FUNDS LISTED ABOVE ARE AVAILABLE AND
RESERVED
DATE
e OTHER /Specify!
DATE
18. DATE OF ORDER
19. ORDER NUMBER
20. CONTRACT NUMBER /if any/
21 DISCOUNT TERMS
22. FOB POINT
23. DELIVERY TO FOB POINT BY On !**,. to*,, 24. PERSON TAKING ORDER/QUOTE AND PHONE NO
25 CONTRACTOR (Name, address. ZIP Code/
26. TYPE OF ORDER
O a. PURCHASE
REFERENCE YOUR QUOTE (See Block 24)
PLEASE FURNISH THE ABOVE ON THE TERMS SPECIFIED ON BOTH SIDES
OF THIS ORDER AND ON THE ATTACHED SHEETS, IF ANY, INCLUDING
DELIVERY AS INDICATED THE PURCHASE IS NEGOTIATED UNDER
AUTHORITY OF 41 USC262(c)( ).
Db. DELIVERY PROVISIONS
DELIVERY ~ - '
OFTHEC*
ERY PROVISIONS ON T
ERY ORDER IS SUBJECT
E CONTRACT (S*, fltoc* 2O)
THE REVERSE ARE DELETED THE
* TO THE TERMS AND CONDITIONS
C. O ORAL D WRITTEN D CONFIRMING
27. SCHEDULE
ITEM
MUMBER
SUPPLIES OR SERVICES
(bl
QUANTITY
ORDERED
(c)
UNIT
(d)
ESTIMATED
UNIT PRICE
UNIT
PRICE
AMOUNT
Igl
QUANTITY
ACCEPTED
TOTAL*
28.
UNITED STATES OF AMERICA
- ' '"-"-<-
JSLJYPED NAME AND TTTUE OF CONTRACTING OFFICER
EPA Form 19OO-8 (Rev. 4-84) Replaces previous editions.
and EPA Form 1900-8T. which are obsolete
D-2
-------
PAGE 1 OF 3
EPA WORK ASSIGNMENT COMPLETION REPORT (WACR)
1 CONTRACT NO.
2 WORK ASSIGNMENT NO.
3 EPA REGION
4 CONTRACTOR/SUBCONTRACTORIS)
5 CONTRACTOR SITE MANAGER :Ntmt tna Phone \oi
6 RPM iNim* ina Phont NC.I
7 WORK LOCATION iSilt Him* A Staif,
a BRIEFLY DESCRIBE SCOPE OF WORK
9 DESCRIBE CONTRACTOR'S PERFORMANCE
10 UNUSUAL PROBLEMS'OCCURRENCES AFFECTING CONTRACTOR S PERFORMANCE
11 PHASE I AVAILABLE
12 PHASE I PAID
13 PHASE II AVAILABLE
14 PHASE ii AWARD RECOMMENCE
D YES aeCOMMENDED 5 .
n NO
15 STATE SPECIFIC REASONS FOR RECOMMENDATION FOR HHASE II AWARD Aaaittonal pages ~M.
RPM
Signituri ana Din
REM RPO
Signtturt tna Oil*
HQ EVALu- UN CCOROiNA* J
S.gn
MQ Ev*Hj*tien Coof«in«tor i
ComrKting Ott*c«r iCopvi
MM WO
RPU iCoovi
D-3
-------
PAGE 2 of 3
EPA WORK ASSIGNMENT COMPLETION REPORT (WACR)
CONTRACT NO. WORK ASSIGNMENT NO. EPA REGION
PROJECT SCHEDULE AND COST INFORMATION WORKSHEET
APPROVED WORK PLAN
AND
WA AMENDMENT
DATES
WORK PLAN APPROVAL DATE
Amendment 1
Amendment 2
Amendment 3
TOTAL PLANNED COST
TOTAL ACTUAL COST
VARIANCE
LOE&
EXPENSE
COST
SUBCON-
TRACTING
POOL
COST
TOTAL
PLANNED
COST
PLANNED
COMPLETION
DATE
ACTUAL
COMPLETION
DATE
0>«tnOuM>n
HO f
Contracting Ofhev
flfM ft*) iCowi
RPU 'Coovi
Contractor
-------
PAGE 3 of 3
EPA WORK ASSIGNMENT COMPLETION REPORT (WACR)
CONTRACT NO WORK ASSIGNMENT NO. EPA REGION
PERFORMANCE CRITERIA RATING WORKSHEET
PERFORMANCE CRITERIA
PROJECT PLANNING
- ORGANIZING IE G . WORK PLAN
DEVELOPMENT. DATA REVIEW)
- SCHEDULING
- BUDGETING
TECHNICAL COMPETENCE t INNOVATION
- EFFECTIVENESS OF ANALYSES
- MEET PLAN GOALS
- ADHERE TO REGS A PROCEDURES
- APPROACH CREATIVITY/INGENUITY
- SUPPORT COE. STATE ENFORCEMENT
EXPERT TESTIMONY
SCHEDULE & COST CONTROL
- BUDGET HOURS & COSTI MAINTENANCE
- PRIORITY SCHEDULE ADJUSTMENTS
- COST MINIMIZATION
REPORTING
- TIMELINESS OF OELIVERABLES
- CLARITY
- THOROUGHNESS
RESOURCE UTILIZATION
- STAFFING
- SUBCONTRACTING
- EQUIPMENT TRAVEL. ETC
EFFORT
- RESPONSIVENESS
- MOBILIZATION
- DAY TO DAY
- SPECIAL SITUATIONS IE G.. ADVERSE/
DANGEROUS CONDITIONS)
RATING
*
4
3
2
1
«,
4
1
1
1
4
4
\
2
1
*
4
1
2
1
S
4
1
2
1 ,
S
4
3
2
1
SUPPORTING COMMENTS
HQ EvMjCttOfl C
Contracting Offtc*
RPU iCoovi
Contractor
-------
-------
APPENDIX E
Sample USAGE Work Assignments and
Interagency Agreements
MEMORANDUM
SUBJECT: Procedures for Processing Superfund Interagency
Agreements with the U.S. Array Corps of Engineers
FROM: Paul F. Nadeau, Chief
Remedial Action and Contracts Branch
TO: Addresses
The Authority for Approving and Awarding Superfund
Interagency Agreements (lAGs) with the U.S. Army Corps of
Engineers (USAGE) was delegated to the Regions effective
October 1, 1984. The delegation include the generic lAGs for
technical assistance (TA) and Phase I design (DA), along with
the site specific lAGs for remedial design (RD) and remedial
action (RA).
Sample lAGs are attached to provide guidance in processing
and funding the lAGs with the USAGE. The procedures are
briefly summarized below. The Region should refer to the draft
Superfund RD/RA Guidance for additional information on the lAGs,
Generic lAGs for TA and DA should be established by the
Regions with the USAGE Missouri River Division (MRD). The
total amount of funds obligated in each generic IAG should be
the sum of all TA or DA shown in your approved SCAP for first
and second quarters. Site specific work assignments will then
be issued to USACE-MRD under the established generic lAGs. The
TA work assignment should be issued around the completion of
the remedial investigation, and the DA work assignment should
be issued about the time the feasibility study is made
available to the public. The Region should complete the blocks
marked with an "asterisk" on the sample IAG. The sample work
assignment should be completed at the time of issuance.
Site specific lAGs for RD and RA will be prepared, approved
and issued by the Region to the USACE-MRD. The IAG for RD
should be executed after ROD approval, and upon RD completion
the IAG for RA should be executed. The Region should complete
the blocks marked with an "asterisk" on the sample lAGs, as
well as filling in the appropriate information on the sample
scope of work.
Any administrative questions concerning the lAGs should be
addressed first to your Management Division, and if necessary
to Billie Perry of OERR at 475-8906. Any technical questions
should be addressed to Randall Kaltreider of my staff at
382-2448.
E-1
-------
SAMPLE NO. 1
IAG FOR
TECHNICAL ASSISTANCE
INTERAGENCY AGREEMENT/AMENDMENT
Part I - GENERAL INFORMATION
3 Type of Action
New Agreement
4 Program Abbreviation
*
S Hame and Address of EPA Organization
6 Name and Address of Other Agency
Department of Defense
U.S. Array Corps of Engineers (USAGE)
Engineering Division, Missouri River
3maha, Nebraska 68101-0103
7 Project Tttie
Technical Assistance Activities - FY 1985
8. EPA Project Officer (Name. Address. Telephone Number)
*
9 Other Agency Project Officer (Name. Address. Telephone Momberj
William Mulligan FTS/864-7227
USAGE, Engineering Division, Missouri River
P. 0. Box 103, Downtown Station
Omaha, Nebraska 68101-0103
10 Project Period
10/01/84 - 09/30/85
11 Sudget Period
10/01/84 - 09/30/85
12 Scope of Work (Attach additional sheets, ai needed!
This agreement obligates no more than $ * and generally no more than $10,000 per
project (except as described under Section 27, Special Conditions) to the USAGE for
technical assistance to EPA during EPA lead phases of remedial response activities.
Such activities, consistent with the Memorandum of Understanding between the USAGE and
the EPA, may Include:
1. Reviewing work plans developed by the contractor and providing comments and
suggestions on the proposed work.
2. Technical review of 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 contractor produces. 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.
13 Statutory Authority for both Transfer nf Funds and Project Activities
CERCLA, E.G. 12316 & the Economy Act of 1932, as amended (3HJSC1535)
14 Oiner Agency Typa
Federal
FUNDS
PREVIOUS AMOUNT
AMOUNT THIS ACTION
AMENDED TOTAL
15 EPA Amount
16 EPA In-Kind Amount
1 7 C'her Agency Amount
18 Other Agency In-Kind Amount
1 9 Total Pfoiect Cost
20 Fiscal Information
Program Element
TFAY9A
FY
85
Appropriation
68/20X8145
Doc. Control No.
Account Number
Object Class Obligatio°n/Deooiigai>o"
25.76
EPA Form 1610-1 (Rev. 8-84) Previous editions are obsolete.
Pag* I at5
E-2
-------
21 BudgetCategor.es
Total Itemiiation of
Ettimated Coil to Out
(I) Procurement/Assistance
fqj Construction
hi Other
(i| Total Direct Charges
SBreakdown not available.
Indirect Co»'« Rate 0000 « Base
OOQQ
Will be provided as part of
|k| Total
[EPA Shire 100
%| (Other Agency Sr»re Q SI
request for reimbursement.
$ *
22 l> equipment authorized to be lurmtned by EPA or acquired with EPA fund*?
uipmtnt coiling S I.OOO or mot*)
I No
23 Are any of these funds being used on extramural agreements?
I I Grant. I J Cooperative Agreement, or LJ Procurement
y(s
\HolSftlltm2ltl
Contactor/Recipient Name III tnownl
Total Extramural Amount Under This Protect
Percent Funded by EPA C//inown
PART III PAYMENT METHODS AND SILLING INSTRUCTIONS
24 IcS Disbursement Agreement
12£ Reimbursement
LJ Advanc
D
Allocation Transfer
Request for reimbursement of actual costs will be itemized on Sf 1081 or SF 1080 and
submitted to the Financial Management Office. Environmental Protection Agency. 26 West St
Clair. Cincinnati. OH 45268
23 Monthly LJ Quarterly LJ Upon Completion of Work
Only available for use by Federal agencies on working capital fund or with appropriate justifica-
tion of need for this type of payment method Unexpended funds at completion of wort win oe
rotur nod to CPA Quarterly cost reports will be forwarded 10 the Financial Management Office
Environmental Protection Agency. 26 West Si Clair. Cincmaii. OH 45268
Used 10 transfer obhgational authority or transfer of function between Federal agencies M ust
receive prior approval by the Office of the Comptroller Budget Division. Budget Formulation and
Control Branch EPA Headquarters
25 LJ Reimbursement Agreement
Other Agency * IAG Identification Number
Billing Address
Billing Instructions and Frequency
EPA Form 1610-1 (Rev. 8-84)
Page 2 o"
E-3
-------
26. General Conditions:
The other agency covenants and agrees that it will expeditiously initiate and complete the project work for
which funds have been awarded under this agreement.
27 Special Conditions
Work assignments for technical assistance will be Initiated via a letter signed by the
* or his designee. The letter will
identify the particular site, provide the necessary account numbers, and describe any
adjustments, including Increases in the site dollar ceiling ($10,000) and/or changes
to the scope of work.
EPA acting as manager of the Hazardous Substance Response Trust Fund, requires current
information on CERCLA response actions and related obligations of CERCLA funds for
these actions. In addition, CERCLA authorizes EPA to recover from responsible parties
all government costs incurred during a response action.
(See Attachment A)
Pan V OFFER AND ACCEPTANCE
NOTE: 1) For disbursement actions.- the agreement/amendment must be signed in duplicate and one original
returned to the Grants Administration Division for Headquarters agreements and to the appropriate
EPA IAG administration office for Regional agreements 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 28 after acceptance signature.
Receipt of a written refusal or failure to return the properly executed document within the prescribed
time may result in the withdrawal of the offer by the Agency. 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 reimbursement actions, the other agency will initiate the action and forward two original
agreements/amendments to the appropriate EPA program office for signature "he agreements/'
amendments will then be forwarded to the appropriate EPA TAG administration office for acceptance
signature on behalf of the Environmental Protection Agency. One original copy will be returned to the
other agency after acceptance.
EPA IAG Administration OHice Hot nSfnmistrtlivt/ tntn^ytmgnt amstancfl
28
Orftnuauon/Aodreu
*
EPA Program Oflice Uor ttcfiniciJ txxisttnctt
29 O'ganuaiion/Adartu
*
Decision Official on (Until of the Environmental Protection Agency Program Office
30.
Signature
Typed Name and Tula
*
Due
Action Official on Behalf of tha Environmental Protection Agency
31
Signature
Typed Name ano Tula
*
Date
Authonung Official on Behalf of the Other Agency
32
Signature
Typed Name and Tula
EPA Form 1(10-1 (Rev. 8-M)
Date
Page 3 ol 5
E-4
-------
ATTACHMENT A
27. SPECIAL PROVISIONS (continued)
In order to help assure successful recovery of CERCLA funds,
the USAGE shall maintain site specific accounts and
documentation of the following:
Employee hours and salary (timesheets)
Employee travel and per diem expenses (travel
authorizations, paid vouchers, and treasury schedules)
Receipts for materials, equipment, and supplies
Any other costs not included in the above categories.
In the event of a cost recovery action, within three weeks from
the date of a request from EPA or the Department of Justice
(DOJ), the USAGE will provide to EPA or DOJ site specific costs
and copies of the back-up documentation which supports those
costs. The USAGE will provide EPA with a contract for
obtaining such site specific accounting information and
documentation. This cost information and documentation must
also be available for audit or verification on request of the
Inspector General.
Reimbursement is contingent upon receipt and approval by EPA of
monthly progress and financial reports by site, containing an
accounting of funds and status of activities.
The USAGE will provide technical review comments for each site
to the Regional Technical Project Officer.
E-5
-------
TECHNICAL ASSISTANCE AUTHORIZATION FORM
AUTHORIZATION IS HEREBY GIVEN TO INITIATE TECHNICAL ASSISTANCE WORK
AS DESCRIBED IN IAG * DW96 -01-0. THE FOLLOWING INFORMATION IS
PROVIDED FOR COST TRACKING PURPOSES:
SITE NAME
REGION
EPA SITE I.D. #
HQ TECHNICAL PROJECT OFFICER
REMEDIAL PROJECT MANAGER
PERIOD OF PERFORMANCE
PHONE
PHONE
FROM
TO
ACCOUNTING INFORMATION
DEOBLIGATE FROM:
OBLIGATE TO:
DOCUMENT
CONTROL NO.
IAG NO.
D W9
D W9
1
1
0
0
SUPERFUND
ACCOUNT NO.
5
5 '
r F
r F
A * '
A * '
* L
* L
0
0
OBJECT
CLASS
CODE
2
2
5
5
7
7
6
6
NOT TO
EXCEED
AMOUNT
?
?
*
*
*
*
* *
* *
(Title)
EPA PROJECTOFFICER
(individual who certifies funds)
DATE
DATE
DATE
Original to:
cc:
Richard Rune, EPA
Cincinnati, OH
William Mulligan, USAGE
Noel Urban, USACE
Paul Nadeau, EPA
(very Jacobs, EPA, Room 3623M
Financial Reports and Analysis Branch
E-6
-------
Mr. William Mulligan
U.S. Army Corps of Engineers
Engineering Division, Missouri River
P.O. Box 103, Downtown Station
Omaha, Nebraska 68101-0103
Dear Mr. Mulligan:
This letter serves to initiate a work assignment for the
U.S. Army Corps of Engineers (USAGE) for technical assistance
to the U.S. Environmental Protection Agency (EPA) at the
following Superfund site:
Assistance will be given for EPA lead phases of remedial
response activities. Such activities must be consistent with
Interagency Agreement No. DW96******-01-0 between the USAGE and
EPA. Funding for costs incurred while providing these services
to EPA, authorized under the authority of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), is not expected to exceed:
$
Enclosed is the Technical Assistance Authorization Form.
This document contains the necessary account numbers that apply
specifically to this work assignment. These numbers must be
used on all financial and management reports.
Sincerely yours,
(Title)
Enclosure
cc: Richard Ruhe
Noel Urban
Paul Nadeau
Ivery Jacobs
E-7
-------
SAMPLE NO. 2
IAG FOR
FIRST PHASE DESIGN WORK
Please read instructions on pages 4 and 5
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. DC 20460
INTERAGENCY AGREEMENT/AMENDMENT
Part I - GENERAL INFORMATION
1 IAG Identification Number
3 Type of Action
New Agreement
2 Funding Location by Regior
4 Program Abbreviation
5 Name and Address of EPA Organization
6 Name and Address of Other Agency
Department of Defense
U.S. Army Corps of Engineers (USACE)
Engineering Division, Missouri River
Omaha, Nebraska 68101-0103
7 Protect Title
First Phase Design Work - FY 1985
8 EPA Project Officer (Name, Address, Telephone Number!
*
9 Other Agency Project Officer /Name. Address. Telephone Number)
William Mulligan FTS/864-7227
USACE, Engineering Division, Missouri River
P. 0. Box 103, Downtown Station
Omaha, Nebraska 68101-0103
10 Project Period
10/01/84 - 09/30/85
11 Budget Period
10/01/84 - 09/30/85
12 Scope of Work (Attach additional sheets, as needed!
This agreement obligates no more than $
and generally no more than $7,000 per
project to the USACE to initiate the selection of Architectural/Engineering firms for
the engineering design phase of Federal lead remedial action projects. The USACE will
perform all action necessary to retain an A/E firm for engineering design, including
the following:
Phase I -
° Synopsize requirement in Commerce Business Daily
° Designate A/E pre-selection and selection boards
0 Develop A/E pre-selection list
0 Contact A/E firms to ascertain interest in project
0 Approve A/E selection list
0 Tentatively select A/E firm
13 Statutory Authority for both Transfer of Funds and Project Activities
CERCLA. E.O. 12316 & the Economy Act of 1932, as amended (31USC1535)
14 Other Agency Type
Federal
FUNDS
PREVIOUS AMOUNT
AMOUNT THIS ACTION
AMENDED TOTAL
15 EPA Amount
16 EPA In-Kind Amount
17 C'her Agency Amount
18 Other Agency In-Kind Amount
19 Total Proiect Cost
20 Fiscal Information
Program Element
TFAY9A
FY
85
Appropriation
68/20X8145
Doc Control No
*
Account Number
Object Class
25.76
Obhgation/Deobliganon Arm
EPA Form 1610-1 (Rev 8-84) Previous editions are obsolete
Page 1 of 5
E-8
-------
PART II
-APPROVED BUDGET
21 Budget Categories
(a) Personnel
(b) Fringe Benefus
(cl Travel
Id) Equipment
(el Supplies
(f) Procurement/ Assistance
(a) Construction
|h) Other
d) Total Direct Charges
(j) Indirect Costs Rate S
Base 0
(k) Total
(EPA Share 100%) (Other Agency Share 0 %|
IAG IDENTIFICATION NO
Total Itemization of
Estimated Cost to Date
$
$ Breakdown not available.
Will be provided as part of
request for reimbursement.
$ *
22 Is equipment authorized to be furnished by EPA or acquired with EPA funds' j j Yes 23 No
(Identity til equipment costing fl.OOO or morel
23 Are any of these funds being used on extramural agreements' j ] Yes JIE^ No (See Item 2111
\ 1 Grant. 1 I Cooperative Agreement, or 1 1 Procurement
Contactor/Recipient Name fit known/ Total Extramural Amount Under This Project
Percent Funded by EPA {if known/
PART III PAYMENT METHODS AND BILLING INSTRUCTIONS
24 IcSl Disbursement Agreement
[2jJ Reimbursement
1 1 Advance
Request for reimbursement of actual costs will be itemized on SF 1081 or SF 1080 and
submitted to the Financial Management Office. Environmental Protection Agency 26 Wesi St
Clair. Cincinnati OH 45268
2S] Monthly l_l Quarterly 1 1 Upon Completion of Work
Only available for use by Federal agencies on working capital fund or with appropriate lustifica -
nage
LJ Allocation Transfer
rmurneo to LrA uuarteriycost reports will be forwarded to the Financial Me
Environmental Protection Agency. 26 West St Clair, Cmcmati, OH 45268
Used to transfer obhgational authority or transfer of function between Federal agencies Must
receive prior approval by the Office of the Comptroller. Budget Division Budget Formulation anc
Control Branch EPA Headquarters
25
D
Reimbursement Agreement
Other Agency s IAG Identification Number
Billing Address
Billing Instructions and Frequency
EPA Form 1610-1 (Rev 8-84)
Page 2 of 5
E-9
-------
PART IV ACCEPTANCE CONDITIONS
IAG IDENTIFICATION NO
26 General Conditions
The other agency covenants and agrees that it will expeditiously initiate and complete the project work for
which funds have been awarded under this agreement.
27 Special Conditions
Work assignments for A/E selection will be initiated via a letter signed by the
* or his designee. The letter will
identify the particular site, provide the necessary account numbers, and describe any
adjustments, including increases in the site dollar ceiling ($7,000) and/or changes
to the scope of work.
The USAGE will initiate Phase I actions upon receipt of EPA authorization. Phase II
actions will not begin until EPA has notified the USACE of the selection and approval
of a remedy and EPA approval of an Interagency Agreement for Phase II actions.
EPA acting as manager of the Hazardous Substance Response Trust Fund, requires current
information on CERCLA response actions and related obligations of CERCLA funds for
these actions. In addition, CERCLA authorizes EPA to recover from responsible parties
all government costs incurred during a response action.
(See Attachment A)
Part V - OFFER AND ACCEPTANCE
NOTE: 1) For disbursement actions, the agreement/amendment must be signed in duplicate and one original
returned to the Grants Administration Division for Headquarters agreements and to the appropriate
EPA IAG administration office for Regional agreements 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 28 after acceptance signature.
Receipt of a written refusal or failure to return the properly executed document within the prescribed
time may result in the withdrawal of the offer by the Agency Any change to the agreement by the other
agency subsequent to the document being signed by the EPA Action Off icial which the Action Official
determines to materially alter the agreement/amendment shall void the agreement/
amendment.
2) For reimbursement actions, the other agency will initiate the action and forward two original
agreements/amendments to the appropriate EPA program office for signature ~hp agreements/
amendments will then be forwarded to the appropriate EPA TAG administration office for acceptance
signature on behalf of the Environmental Protection Agency. One original copy will be returned to the
other agency after acceptance
EPA IAG Administration Office Hoi administrative/ management assistance!
28 Organization/ Address
*
EPA Program Office (for technical assistance/
29 Organization/Address
*
Decision Official on Behalf of the Environmental Protection Agency Pmgr.m n«,^.
30 Signature
Typed Name and Title
*
Date
Action Official on Behalf of the Environmental Protection Agency
31 Signature
Typed Name and Title
*
Date
Authorizing Official on Behalf of the Other Agency
32 Signature
Typed Name and Title
EPA Form 1610-1 (Rev 8-84)
Date
Page 3 of 5
E-10
-------
ATTACHMENT A
27. SPECIAL PROVISIONS (continued)
In order to help assure successful recovery of CERCLA funds, the USACE
shall maintain site-specific accounts and documentation of the following:
Employee hours and salary (timesheets)
Employee travel and per diem expenses (travel authorizations, paid
vouchers, and treasury schedules)
Receipts for materials, equipment, and supplies
Any other costs not included in the above categories
In order to assist in the development and prosecution of a cost recovery
action, within three weeks from the date of a request from EPA or the
Department of Justice (DOJ), the USACE will provide to EPA or DOJ
site-specific costs and copies of the back-up documentation which supports
those costs. EPA and DOJ may periodically request updates of the costs and
documentation after the initial request. The USACE will provide EPA with a
contact for obtaining such site-specific accounting information and
documentation. This cost information and documentation must also be
available for audit or verification on request of the Inspector General.
USACE will provide access to its files concerning the project on an
on-going basis for EPA and DOJ examination to assist in cost recovery. As
original documents may be requested for cost recovery actions, USAGE will
provide EPA and DOJ access to the original documentation when requested.
USACE will notify EPA in advance of placing any project files in storage or
archives.
Reimbursement is contingent upon receipt and approval by EPA of monthly
progress and financial reports by site, containing an accounting of funds
and status of activities.
The USACE will provide a letter report summarizing each A/E selection to
the Regional Technical Project Officer.
E-11
-------
Mr. William Mulligan
U.S. Army Corps of Engineers
Engineering Division, Missouri River
P. O. Box 103, Downtown Station
Omaha, Nebraska 68101-0103
Dear Mr. Mulligan:
This letter serves to initiate a work assignment for the U. S. Army Corps
of Engineers (USAGE) to select an architectural/engineering firm to design the
remedial action at the following superfund site:
The selected activities must be consistent with the Interagency Agreement
No. DW96******-01-0 between the USAGE and the Environmental Protection Agency
(EPA). Funding for costs incurred while providing these services to EPA,
authorized under the authority of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), is not expected to exceed:
Enclosed is the Phase I Design Authorization Form. This document contains
the necessary account numbers that apply specifically to this work assignment.
These numbers must be used on all financial and management reports.
Sincerely yours,
(Title)
Enclosure
cc: Richard Rune
Noel Urban
Paul Nadeau
Ivery Jacobs
E-12
-------
AUTHORIZATION FORM FOR PHASE I DESIGN
AUTHORIZATION IS HEREBY GIVEN TO INITIATE THE FIRST PHASE OF DESIGN
WORK AS DESCRIBED IN IAG # DW96930***-01-0. THE FOLLOWING INFORMATION
IS PROVIDED FOR COST TRACKING PURPOSES:
SITE NAME
REGION
EPA SITE I.D. #
HQ TECHNICAL PROJECT OFFICER
PHONE
REGIONAL SITE MANAGER
PHONE
PERIOD OF PERFORMANCE
FROM TO
ACCOUNTING INFORMATION
II 1 II
II II OBJECT! NOT TO
| DOCUMENT | j SUPERFUND | CLASS | EXCEED
| CONTROL NO.| IAG NO. | ACCOUNT NO. | CODE | AMOUNT
LIGATE FROM:) * * | * | * | * | * | D | W| 9 | 6 | * * | * | * | * | * | 0 | 1 | 0 | 5 | T | F | A| * | * | * | N | 0 | 0 | 2 | 5 | 7 | 6 |$|* *
SATE TO: | * | * | * | * | * | * | D | W| 9 | 6 | * * | * I * | * | * | 0 1 1 1 0 | 5 | T| F | A| * | * | * | N | * | * | 2 | 5 | 7 | 6 |$|* *
1* *l*
1*1*1*
(Title)
DATE
EPA PROJECT OFFICER
DATE
(individual who certifies funds)
DATE
ginal to: Richard Ruhe, EPA
Cincinnati, OH
William Mulligan, USAGE
Noel Urban, USAGE
Paul Nadeau, EPA
Ivery Jacobs, EPA, Room 3623M
Financial Reports and Analysis Branch
E-13
-------
SAMPLE NO. 3
IAGFOR
DESIGN OF REMEDIAL ACTION
Please read instructions on pages 4 and 5
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. DC 20460
INTERAGENCY AGREEMENT/AMENDMENT
Part I - GENERAL INFORMATION
1 IAG Identification Number
3 Type of Action
New Agreement
2 Funding Locanon by Region
*
4 Program Abbreviation
S N,-.me and Address of EPA Organisation
*
6 Name and Address of Other Agency
Department of Defense
U.S. Army Corps of Engineers (USAGE)
Engineering Division, Missouri River
Omaha, Nebraska 68101-0103
7 Project Title
Design of remedial action at
8. EPA Project Officer /Name. Address. Telephone Number)
*
9. Other Agency Project Officer (Name, Address, Telephone Humbert
William Mulligan FTS/864-7227
USAGE, Engineering Division, Missouri River
P. 0. Box 103, Downtown Station
Omaha, Nebraska 68101-0103
10. Project Period
11 Budget Period
* (same as project period)
12 Scope of Work /Attach additional sheets, as needed/
This Interagency Agreement obligates a total of $ * to the U.S. Army Corps of
Engineers (USAGE) for the design of remedial action at *
* (ID# *
). These funds are divided as
follows :
1. $ *
2. $
for a contract to design the remedial action.
for supervision and execution of the contract. Specific USAGE
responsibilities are detailed in the appended Scope of Work (Attachment A).
1 3 Statutory Authority for both Transfer of Funds and Project Activ ties
CERCLA, E.O. 12316 & Economy Act of 1932, as amended (31USC1535)
14 Other Agency Type
Federal
FUNDS
PREVIOUS AMOUNT
AMOUNT THIS ACTION
AMENDED TOTAL
15 EPA Amount
16 EPA In-Kind Amount
17 C'her Agency Amoum
18 Other Agency In-Kind Amount
19 Total Proiect Cost
20 Fiscal Information
Program Element
TFAY9A
FY
85
Appropriation
68/20X8145
Doc Control No
*
Account Number
*
Object Class
25.76
Obligation/Deobligaiicr. Ar--
EPA Form 1610-1 (Rev. 8-84) Previous editions are obsolete
Page I o<
E-14
-------
PART II APPROVED BUDGET
IAG IDENTIFICATION NC
21 Budget Categories
Total Itemization of
Estimated Cost to Date
(a) Personnel
|b) Fringe Benefits
(cl Travel
(dl Equipment
(el Supplies
(f) Procurement/Assistance
(9) Construction
("I O'ner
(i) Total Direct Charges
"$ (Breakdown not available.
(l) Indirect Costs Rate
$ Base
Will be provided prior to
(k) Total
(EPA Share 100
%l (Other Agency Share
reimbursement.)
*
22 Is equipment authorized to be furnished by EPA or acquired with EPA funds?
(Identity til eqikpment costing S l.OOO or morel
I No
23 Are any of these funds being used on extramural agreements?
I I Grant. II Cooperative Agreement, or ££! Procurement
Yes
No (See Item 2 1 fl
Contactor/Recipient Name lit known)
Unknown
Total Extramural Amount Under This Project
* (Estimate)
Percent Funded bv EPA /if known/
100
PART III PAYMENT METHODS AND BILLING INSTRUCTIONS
24 icSJ Disbursement Agreement
fi?l
1^1 Reimbursement
II Advance
LJ Allocation Transfer
Request for reimbursement of actual costs will be itemized on SF 1081 or SF 1080 and
submitted to the Financial Management Office. Environmental Protection Agency 26 West Si
Clair. Cincinnati. OH 45268
££l Monthly LJ Quarterly I I Upon Completion of Work
Only available for use by Federal agencies on working capital fund or with appropriate justifies -
tion of need for this type of payment method Unexoenued iunus ai LOinuietiGfi of ,.crk ..." ^~
returned to EPA Quarterly cost reports will be forwarded to the *mancia' Management Office
Environmental Protection Agency 26 West St Clair Cmcmati. OH 45268
Used to transfer obligational authority or transfer of function between Federal agencies Must
receive prior approval by the Office of the Comptroller. Budget Division Budget Formulation ana
Control Branch. EPA Headquarters
25 LJ Reimbursement Agreement
Other Agency $ IAG Identification Number
Billing Address
Billing Instructions and Frequency
EPA Form 1610-1 (Rev. 8-84)
Page 2 of 5
E-15
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PART IV - ACCEPTANCE CONDITIONS
LAG IDENTIFICATION NO
26 General Conditions
The other agency covenants and agrees that it will expeditiously initiate and complete the project work for
which funds have been awarded under this agreement.
Reimbursement 'is contingent upon receipt and approval by EPA of the monthly progress
and financial reports from the USAGE described below and any other reports described
in the appended scope of work. The monthly progress reports will be submitted to
(Regional P.O.) in EPA Region .(city) . (state) , and (Hq P.O.) in
EPA, Washington, D.C.
EPA acting as manager of the Hazardous Substance Response Trust Fund, requires current
information on CERCLA response actions and related obligations of CERCLA funds for
these actions. In addition, CERCLA authorizes EPA to recover from responsible parties
all government costs incurred during a response action.
(See Attachment B)
Part V OFFER AND ACCEPTANCE
NOTE: 1) For disbursement actions, the agreement/amendment must be signed in duplicate and one original
returned to the Grants Administration Division for Headquarters agreements and to the appropriate
EPA IAG administration office for Regional agreements within 3 calendar weeks after receipt or w'tthin
any extension of time as may be granted by EPA The agreement/amendment must be forwarded to
the address cited in Item 28 after acceptance signature.
Receipt of a written refusal or failure to return the properly executed document within the prescribed
time may result in the withdrawal of the offer by the Agency. 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 reimbursement actions, the other agency will initiate the action and forward two original
agreements/amendments to the appropriate EPA program office for signature ~^P agreements/
amendments will then be forwarded to the appropriate EPA TAG administration office for acceptance
signature on behalf of the Environmental Protection Agency. One original copy will be returned to the
other agency after acceptance.
EPA IAG Administration OHice /lor idministritive/mtntgcment tsiiatncel
EPA Program Orlice liar tcchmcil usistancti
28 Organization/Address
29 Organuation/Address
*
Decision Official on Behall of the Environmental Protection Agency Program Office
30 Signature
Typed Name and Title
Date
Action Official on Behalf of the Environmental Protection Agency
31 . Signature
Authorizing
32 Signature
Typed Name and Title
*
Date
Official on Behalf of the Other Agency
Typed Name and Title
Date
EPA Form 1610-1 (Rev 8-84)
Page 3 of 5
E-16
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REMEDIAL DESIGN
Scope of Work
SITE [Name, City, State]
PURPOSE
The purpose of this assignment is to obtain assistance from
the U.S. Army Corps of Engineers (USAGE) for the design of a
remedial action at the [site name].
BACKGROUND
[Briefly summarize the site in 1 or 2 paragraphs to include]
o [Location of site]
o [Brief history of operations, releases, response actions,
etc. ]
o [Quantity, types, and concentrations of hazardous substances
o [Extent of contamination]
A Record of Decision (ROD) was signed by the [AA-OSWER or
RA] 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 components:
[List major components in bullet form]
WORK STATEMENT
The USACE 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 the plans and specifications along with
[include as necessary -O&M Plan, QAPP, Site Safety
Plan, etc.).
2. Review of the design package in coordination with the
EPA-RPM at approximately 30%, 60% (if necessary),
95%, and 100% completion. Approval and acceptance of
final design, with concurrence from EPA.
3. Providing other support to include [permit assistance,
community relations assistance, etc.].
4. Reproducing design documents.
Specific USACE responsibilities are detailed in the
Super fund Rejnedial Design and Remedial Action GuijJance.
E-17
-------
27. SPECIAL PROVISIONS (continued)
In order to help assure successful recovery of CERCLA funds, the USAGE
shall maintain site-specific accounts and documentation of the following:
Employee hours and salary (timesheets)
Employee travel and per diem expenses (travel authorizations, paid
vouchers, and treasury schedules)
Receipts for materials, equipment, and supplies
Contract costs (paid invoices, treasury schedules and copy of the
contract)
Any other costs not included in the above categories
In order to assist in the development and prosecution of a cost recovery
action, within three weeks from the date of a request from EPA or the
Department of Justice (DOJ), the USACE will provide to EPA or DOJ
site-specific costs and copies of the back-up documentation which supports
those costs. EPA and DOJ may periodically request updates of the costs and
documentation after the initial request. The USACE will provide EPA with a
contact for obtaining such site specific accounting information and
documentation. This cost information and documentation must also be
available for audit or verification on request of the Inspector General.
USACE will provide access to its files concerning the project on an
on-going basis for EPA and DOJ examination to assist in cost recovery. As
original documents may be requested for cost recovery actions, USACE will
provide EPA and DOJ access to the original documentation when requested.
USACE will notify EPA in advance of placing any project files in storage or
archives.
Reporting requirments are as follows:
The USACE will provide the EPA with a completed signed SF 1080 and
monthly reports containing:
a. USACE estimate of the percentage of project completed.
b. USACE estimate of dollars expended on the project to date.
c. Summaries of all change orders and claims made on the contract
during the reporting period. Attach copies of all change
orders as appendix.
d. Summaries of all contracts with representatives of the local
community, puFTTc interest groups or State government during
the reporting period.
e. Summaries of all problems or potential problems encountered
during the reporting period.
f. Projected work for the next reporting period.
E-18
-------
SAMPLE NO. 4
IAG FOR
IMPLEMENTATION OF REMEDIAL ACTION
Please rtad instructions on pages 4 and 5
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. DC 20460
INTERAGENCY AGREEMENT/AMENDMENT
Part I GENERAL INFORMATION
1 IAG Identification Number
3 Type of Action
New Agreement
2 Funding Location by Regior
4 Program Abbreviation
5 Name and Address of EPA Organization
*
6 Name and Address of Other Agency
Department of Defense
U.S. Army Corps of Engineers (USAGE)
Engineering Division, Missouri River
Omaha, Nebraska 68101-0103
7 Project Title
Remedial action at
8 EPA Project Officer (Name, Address. Telephone Number)
9 Other Agency Project Officer (Name, Address. Telephone Number!
William Mulligan FTS/8W-7227
USAGE, Engineering Division, Missouri River
P. 0. Box 103, Downtown Station
Omaha, Nebraska 68101-0103
10. Project Period
11. Budget Period
* (same as project period)
12. Scope of Work (Attach additional sheets, as needed/
This agreement obligates a total of $ * to the U.S. Army Corps of Engineers
(USAGE) for implementation of the remedial action at *
* (EPA I0» * ).
divided as follows:
1. $
2. $
for implementation of the remedial action.
for supervision and execution of the contract awarded based on
the Invitation for Bid (IFB). Specific USAGE responsibilities are detailed
in the appended Scope of Work (Attachment A).
13 Statutory Authority for both Transfer of Funds and Proiect Activities
CERCLA, E.O. 12316 & Economy Act of 1932, as amended (31USC1535)
14 Other Agency Type
Federal
FUNDS
PREVIOUS AMOUNT
AMOUNT THIS ACTION
AMENDED TOTAL
15 EPA Amount
16 EPA In-Kind Amount
17 C'her Agency Amount
18 Other Agency In-Kind Amount
19 Total Proiect Cost
20 Fiscal Information
Program Element
TFAY9A
FY
85
Appropriation
68/20X8145
Doc Control No
Account Number
Object Class
25.76
Obligation/Deobiigddon
EPA Form 1610-1 (Rev. 8-84) Previous editions are obsolete
Page 1 o< S
E-19
-------
PART II APPROVED BUDGET
IAG IDENTIFICATION NO
21 Budget Categories
Total Itemization of
Estimated Cost to Date
lal Personnel
Ibl Fringe Benefits
|c| Travel
(d) Equipment
(e) Supplies
(f) Procurement/Assistance
(g) Construction
|h| Other
(Breakdown not available.
Will be provided prior to
|i| Total Direct Charges
(ll Indirect Costs Rate
S Base
(k) Total
(EPA Sh»»«-
100 %) (Other Agency Share 0 %|
reimbursement.)
*
22 Is equipment authorized to be furnished by EPA or acquired with EPA funds?
(Identify t/l equipment costing Sl.OOO or morel
D
Yes
I No
23 Are any of these funds being used on extramural agreements'
\ _ I Grant. I _ I Cooperative Agreement or J2SL Procurement
Yes
Ho (See Item 21 II
Contactor/Recipient Name {if knownl
Unknown
Total Extramural Amount Under This Protect
* (estimate)
Percent Funded by EPA tit known/
100%
PART III PAYMENT METHODS AND BILLING INSTRUCTIONS
24 l£l Disbursement Agreement
R?t
lol Reimbursement
LJ Advance
LJ Allocation Transfer
Request for reimbursement of actual costs will be itemized on SF 1081 or SF 1080 and
submitted to the Financial Management Office. Environmental Protection Agency, 26 Wes; St
Clair. Cincinnati. OH 45268
.2SJ Monthly LJ Quarterly LJ Upon Completion of Work
Only available for use by Federal agencies on working capital fund or with appropriate justifica-
tion of need for this type of payment meinod Unexoenued iunu* ai LOnip.etiGn of ..cr'^ ..." ^:
returned to EPA Quarterly cost reports will be forwarded to the cmancia' Management Office
Environmental Protection Agency, 26 West St Clair. Cincmati OH 45268
Used to transfer obligational authority or transfer of function between Federal agencies MUST
receive prior approval by the Office of the Comptroller, Budget Division Budget Formula! ->n and
Control Branch, EPA Headquarters
25 I I Reimbursement Agreement
Other Agency s IAG Identification Number
Billing Address
Billing Instructions and Frequency
EPA Form 1610-1 (Rev 8-84)
Page 2 of 5
E-20
-------
PART IV ACCEPTANCE CONDITIONS
LAG IDENTIFICATION NO
26. General Conditions
The other agency covenants and agrees that it will expedltiously initiate and complete the project work for
which funds have been awarded under this agreement.
27. Special Conditions:
Reimbursement is contingent upon receipt and approval by EPA of the monthly progress
reports from USAGE described below and any other reports described in the appended scope
of work. The monthly progress reports will be submitted to (Regional P.O.) in EPA
(Hq P.O.)
Region
and
in EPA, Washington, D.C.
EPA acting as manager of the Hazardous Substance Response Trust Fund, requires current
information on CERCLA response actions and related obligations of CERCLA funds for
these actions. In addition, CERCLA authorizes EPA to recover from responsible parties
all government costs incurred during a response action.
(See Attachment A)
Part V OFFER AND ACCEPTANCE
NOTE: 1) For disbursement actions, the agreement/amendment must be signed in duplicate and one original
returned to the Grants Administration Division for Headquarters agreements and to the appropriate
EPA IAG administration office for Regional agreements 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 28 after acceptance signature.
Receipt of a written refusal or failure to return the properly executed document within the prescribed
time may result in the withdrawal of the offer by the Agency. 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 reimbursement actions, the other agency will initiate the action and forward two original
agreements/amendments to the appropriate EPA program office for signature "he agreements/
amendments will then be forwarded to the appropriate EPA TAG administration office for acceptance
signature on behalf of the Environmental Protection Agency. One original copy will be returned to the
other agency after acceptance.
EPA IAG Administration Office Hot adminntntivt , mtnigcmem issistaneel
28 Organization/Address
*
EPA Program Office tfor technical tssistincu
29 Organization/Address
*
Decision Official on Behalf of the Environmental Protection Agency Program Office
30 Signature
Typed Name and Title Date
Action Official on Behalf of the Environmental Protection Agency
31 . Signature
Authorising
32 Signature
Typed Name and Title ^
Official on Behalf of the Other Agency
Typed Name and Title
Date
Date
EPA Form 1610-1 (Rev. 8-84)
Page 3 of 5
E-21
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REMEDIAL ACTION
Scope of Work
SITE [Name, City, State]
PURPOSE
The purpose of this assignment is to obtain assistance from
the U.S. Army Corps of Engineers (USAGE) for the implementation
of a remedial action at the (site name].
BACKGROUND
[Briefly summarize the site in 1 or 2 paragraphs to include]
o [Location of site]
o [Brief history of operations, releases, response actions,
etc. ]
o [Quantity, types, and concentrations of hazardous substances^
o [Extent of contamination]
A Record of Decision (ROD) was signed by the [AA-OSWER or
RA] on [date] selecting [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].
REMEDY
The remedy selected by EPA and the State of [state name],
and detailed in the IFB includes the following components:
[List major components in bullet form]
WORK STATEMENT
The USAGE will be responsible for:
1. Conducting procurement activities for remedial action.
2. Managing the contract for remedial action.
3. Providing oversight and monitoring of construction in
coordination with the EPA-RPM, to ensure compliance
with all contract requirements.
4. Conducting final inspection and certification of
completed remedial action in coordination with the
EPA-RPM.
Specific USAGE responsibilities are detailed in the
Super fund Remedial Design and Remedial Ax: tion^ Guidance.
E-22
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27. SPECIAL PROVISIONS (continued)
In order to help assure successful recovery of CERCLA funds, the USACE
shall maintain site-specific accounts and documentation of the following:
Employee hours and salary (timesheets)
Employee travel and per diem expenses (travel authorizations, paid
vouchers, and treasury schedules)
Receipts for materials, equipment, and supplies
Contract costs (paid invoices, treasury schedules and copy of the
contract)
Any other costs not included in the above categories
In order to assist in the development and prosecution of a cost recovery
action, within three weeks from the date of a request from EPA or the
Department of Justice (DOJ), the USACE will provide to EPA or DOJ
site-specific costs and copies of the back-up documentation which supports
those costs. EPA and DOJ may periodically request updates of the costs and
documentation after the initial request. The USACE will provide EPA with a
contact for obtaining such site specific accounting information and
documentation. This cost information and documentation must also be
available for audit or verification on request of the Inspector General.
USACE will provide access to its files concerning the project on an
on-going basis for EPA and DOJ examination to assist in cost recovery. As
original documents may be requested for cost recovery actions, USACE will
provide EPA and DOJ access to the original documentation when requested.
USACE will notify EPA in advance of placing any project files in storage or
archives.
Reporting requirments are as follows:
The USACE will provide the EPA with the following reports:
1. A completed signed SF 1080.
2. A monthly progress report containing:
a. USACE estimate of the percentage of project completed.
b. USACE estimate of dollars expended on the project to date.
c. Summaries of all change orders and claims made on the contract
during the reporting period. Attach copies of all change
orders as appendix.
E-23
-------
d. Summaries of all contacts with representatives of the local
community, public interest groups of State government during
the reporting period.
e. Summaries of all problems or potential problems encountered
during the reporting period.
f. Projected work for the next reporting period.
Weekly telecon construction status update(s) to * ,
EPA, Region * .
E-24
-------
APPENDIX F
ROD Materials: Responsiveness Summary and
ROD Briefing Materials
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
[SITE NAME]
INTRODUCTION
The responsiveness summary documents for the public record:
Concerns and issues raised during remedial planning
Comments raised during the comment period on the RI/FS
How EPA or the State considered and responded to these concerns.
CONCERNS RAISED PRIOR TO THE FEASIBILITY STUDY
COMMENT PERIOD
Briefly describe:
Major concerns and issues raised by State and local officials, potentially
responsible parties, and citizens. The level of concern over each of the
major issues should be discussed. Include the number of times a concern
was raised, the number of people raising the concern and names of
individuals or groups raising concerns and issues when appropriate.
Activities conducted by EPA or the State to elicit citizen input and to
address specific concerns and issues; for example, small group meeting,
news conference, and progress reports.
Changes in any remedial planning activities as a result of concerns
raised.
CONCERNS RAISED DURING THE COMMENT PERIOD
Briefly describe comments on the feasibility study made by local officials,
potentially responsible parties and citizens:
Categorize comments by major issue or topic addressed.
Summarize comments under the categories as completely as possible.
Do not be so brief that the essence is lost. For example, "concern about
health effects" is not specific enough. Which health effect is the community
worried about?
Discuss the level of concern over each of the major issues. Include how
many times the comment was raised and the number of people raising the
concern. Include names of individuals and groups raising concerns and
issues when appropriate.
Discuss when the comment period started and stopped. Mention when,
where, and level of attendance at public meeting, if held.
F-1
-------
RESPONSE TO COMMUNITY CONCERNS
Explain Agency response:
Note whether staff met with concerned citizens or conducted other
communication activities during the comment period such as a public
meeting or availability of technical staff to respond to questions.
Document any modifications or changes in the remedial alternative as a
result of comments.
Give the reasons for rejecting the community's or potentially responsible
party's preferred alternative if the Agency's selected alternative is different.
The citation of "CERCLA" alone does not explain the Agency's rationale.
A more detailed explanation is required.
Document in detail any alternatives provided by the public or potentially
responsible parties that are not evaluated in the feasibility study.
Include any letters, reports, etc., received from potentially responsible
parties.
REMAINING CONCERNS
Briefly explain:
Any areas of community concern that require Agency attention during
remedial design and construction.
How EPA or the State intends to resolve any outstanding concerns.
F-2
-------
FORMAT FOR BRIEFING THE REGIONAL [ASSISTANT] ADMINISTRATOR
RECORD OF DECISION
[SITE NAME]
PURPOSE
The purpose of this Record of Decision (ROD) is select the appropriate
remedial action at the [site name] that is consistent with the requirements
of CERCLA and the NCR. The Regional [Assistant] Administrator has
been delegated the authority for that approval.
ISSUES
[Discuss general issues that the RA or AA should be aware of:]
[State and local officials and community interest and concerns]
[Federal facility or Federal generator]
[RCRA issues for on-site actions, off-site disposal]
[TSCA, other statutes]
[State cost share, flood plain construction, new technologies, other issues]
[RC or OGC concurrence or concerns].
Note: This section will be presented by Headquarters, in the case of a ROD signature by
theAA.
MAIN POINTS
[Present:]
[Brief summary of site history]
[Brief summary of site description]
[Summary of previous and current response actions]
[Enforcement status]
[Objectives of proposed RA]
[Discuss Tabular Summary of Cost-Effectiveness Analysis including:]
[Alternatives and Costs]
[Public health, environmental, and technical considerations]
[Public comments]
[Recommended cost-effective alternative]
[Waivers from other environmental programs, if necessary].
F-3
-------
Note: This section should summarize only the information related to the proposed
remedy.
[Future RA's needed to complete site cleanup]
[Summary charts and graphics - effective charts and graphics include:]
[Aerial photo showing key features.]
[Site map and/or aerial photo showing proposed actions.]
[Table of final alternatives listing the alternatives, capital, O&M
and present worth, cost, and public health, environmental,
echnical and community considerations (see samples in
Summary of Remedial Alternative Selections)].
Note: This section will be presented by the Region.
NEXT STEPS
[Describe:]
Action Dale
[RA or AA - OSWER approves ROD]
[amend/award CA, SSC, IAG]
[sign PR]
[design remedy]
[implement remedy].
Note: This section will be presented by the Region.
Note: The Executive Summary should generally be limited to 3 to 5 pages, excluding
charts and graphics.
_- US GOVERNMENT PRINTING OFFICE 1987 - 748-121/40702
F-4
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