United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
&EPA
DIRECTIVE NUMBER: 9355.1-1
TITLE: DRAFT -- Federal-lead Remedial Project Management
Handbook, January 1986
APPROVAL DATE: January 27, 1986
EFFECTIVE DATE:
ORIGINATING OFFICE: Office of Emergency and Remedial
Response
D FINAL
a DRAFT
STATUS:
Finalization of this book is not anticipated until
Superfund is reauthorized
REFERENCE (other documents):
9355.2-2 -- DRAFT - State-lead Remedial Project Management
Handbook, January 1986
OSWER OSWER OSWER
/£ DIRECTIVE DIRECTIVE
-------
• United States Environmental Protection Agency
^ Washington. DC 20460
^EPA OSWER Directive Initiation Request
Originator Information
Name of Contact Person . Mail Code
Steve Hooper WH-548E
Lead Ofiice r~i Apcrovea
rTA i — | Signature of Office Director
LilJ OERR [J OWPE . ,
• U OSW Q AA-OSWER
Title
DRAFT -- Federal -Lead Remedial Project Management Manual ,
Interim Directive Number
' "'« '• 9355. 1-1
Telephone Number
475-6707
for Review
\^ JflfiJ^f fili
Date
jqg.
85
Summary of Directive
Assists the EPA Remedial Project Managers (RPMs) in managing Federal-lead remedial
response projects. Describes in detail the responsibilities of the RPM during the
planning, design, construction, operation, and close-out of remedial response
projects. Supplements the Remedial Project Manager (RPM) Handbook for State-Lead
Projects, which provides assistance to RPMs in overseeing State-lead, Federally-
funded remedial response projects conducted under cooperative agreements (CAs).
Region III
Library
Environmental Protection rVfenef
Type of Directive (Manual. Policy Directive. Announcement, etc.)
Manual
Status
0 Draft
LJ Final
LD New
1 — 1 Revision
Does this Directive Supersede Previous Directive(s)? [_J Yes [_] No Does It Supplement finsswos Directive(s)? jv^j Yes | ) No
If "Yes" to Either Question. What Directive (number, title)
yobb.xs.-l Kerne 01 a I — r-f-ojeut: ndiidUeT T~KBI*I / MdnuuuuK ror oiditi- reocrrr ~3^
1 lAfllSSrfrTX'f - LfOsC* f fs/r. f MA a f W f) V f.-r fA-i- '•>' f> i*/ '•" /^-^T. r+asrufuL
Review. Plan \j / (J * (J
0 AA-OSWER D OUST 0OECM D Other (Specify)
C3 OERR 00WPE 00GC
D OSW CF Regions D OPPE
!_L^
This Request Meets OSWER Directives System Format
Signature of Lead Office Directives Officer
Signature of 0>WER Directives Officer
Date.
tilwls?
Date
EPA Form 1315-17(10-85)
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JAN 271966
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Draft Federal-Lead Remedial Project Management Handbook
(OSWER Directive Number 9355.1-1)
Draft State-Lead Remedial Project Management Handbook
(OSWER Directive Number 9355.2-1)m j
FROM: Henry L. Longest II, Director
Office of Emergency and Remedi^^&Ufbonse (WH-548)
TO: Addressees
The attached draft guidances have been prepared under the
direction of my staff to assist EPA Remedial Project Managers
(RPM's) in managing Federal-lead and State-lead Superfund remedial
projects. The handbooks describe in detail the responsibilities
of the RPM during each phase of the project: RI/FS, design,
construction, operation and site close-out. The handbooks are
intended to be used as a quick reference on actions to be taken,
and they also serve to direct the RPM to more detailed discussions
fo.und in other guidance.
I would appreciate your review and written comments on the
draft handbooks by February 28, 1986. Regional review might best
be accomplished by your designation of a staff member as the
review coordinator. This individual would then distribute copies
and consolidate comments from remedial and enforcement staff,
Regional Counsel, financial management, grants administration,
and community-relations staff. Comments regarding the scope,
content, clarity, and applicability are encouraged.
Incorporation of comments into a revised draft will begin
after February 28, 1986. Because of the potential impact that
the reauthorization of Superfund may have on the contents of the
handbooks, finalization of the drafts is not anticipated until
after a new Superfund bill is passed. Questions and comments on
the State-lead handbook should be directed to Kathleen Taimi
(FTS/202-382-2449, Mail Code: WH-548E). For the Federal-lead
handbook, contact Steve Hooper (FTS/202-475-6707, Mail Code
WH-548E).
Attachments
-------
-2-
Addressees:
John Lehman, OSW (WH-565)
Dan Berry*, OGC (LE-132S)
Allan Brown, OGC (LE-132G)
Fred Stiehl, OECM (LE-134S)
Jack Stanton, OWPE/CED (WH-527)
Sylvia Lowrance, OWPE (WH-527)
Bill Topping, OARM/PCMD (PM-214F)
Fred Meadows, GAD/GPPB (PM-216)
Jack Gwynn, GAD/GOB (PM-216)
Lisa Karpf, OIG (A-109)
Thaddeus Juszczak, OSWER/AA (WH-562A)
Stan Fredericks, FMD (PM-226)
Becky Kennedy, OERR/FCC (WH-548D)
Daphne Geiranill, OERR/HRSD (WH-548A)
Jeff Byron, OERR/IMTG (WH-548)
Cristina Griffin, OERR (WH-548)
Tim Fields, OERR/ERD (WH-548B)
Steve Lingle, OERR/HRSD (WH-548A)
Jim Lourisbury, OERR/OPPM (WH-548D)
Hal Snyder, OERR/HSCD (WH-548E)
Tom Sheckells, OERR/HSCD (WH-548E)
Chief, Superfund Branch, Regions I, III, VI, VII, and X
Chief, New Jersey Remedial Action Branch, Region II
Chief, New York/Caribbean Remedial Action Branch, Region II
Chief, Emergency and Remedial Response Branch, Regions IV, and V
Chief, Superfund Remedial Branch, Region VIII
Chief, Superfund Programs Branch, Region IX
Noel Urban, USAGE
-------
f/EPA
SUPERFUND FEDERAL-LEAD
REMEDIAL PROJECT MANAGEMENT
HANDBOOK
JANUARY 1986
Region III Library
Environmental Protection Agency
DRAFT
HAZARDOUS SITE CONTROL DIVISION
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
*
OSWER DIRECTIVE NO. 9355.1-1
BOOZ-ALLEN & HAMILTON INC-
-------
TABLE OF CONTENTS
PAGE
LIST OF EXHIBITS ' iv
LIST OF APPENDICES ~ vi
1.
2.
3.
4.
5.
6.
7.
INTRODUCTION
1.1 Structure of the Handbook
12 Using the Handbook
PROJECT MANAGEMENT CONCEPTS
2.1 General Project Management Functions
22. Planning, Monitoring, and Control
2.3 Directing, Coordinating, and Communicating
INITIAL PROJECT PLANNING AND START-UP ACTIVITIES
3.1 Development of a Project Plan
3.2 Miscellaneous Activities Required Before Starting RI/FS
3.3 Rl Scoping of General Response Objectives
3.4 Procedures for Issuing Work Assignments to REM Contractor
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
4.1 Ongoing Project Management Activities
4.2 Site Characterization
4.3 Alternatives Screening and Evaluation
4.4 Review and Approval of RI/FS Report(s)
4.5 Transition to Record of Decision and Remedial Design
RECORD OF DECISION AND TRANSITION TO DESIGN
5.1 Ongoing Project Management Activities
52 ROD Process
5.3 Transition to Design
5.4 RI/FS Closeout
REMEDIAL DESIGN
6.1 Ongoing Project Management Activities
62 Remedial Design Process
REMEDIAL ACTION
7.1 Ongoing Project Management Activities
72 Procurement of RA Contractor
7.3 Construction Monitoring and Inspections
7.4 Review of Progress Reports
7.5 Remedial Action Completion and Acceptance
7.6 Transition to Operation and Maintenance
1-2
1-6
2-1
2-3
2-11
3-1
3-8
3-14
3-16
4-1
4-7
4-10
4-13
4-13
5-3
5-5
5-9
5-10
6-1
6-5
7-1
7-4
7-4
7-4
7-5
7-6
OSWER DIRECTIVE NO. 9355.1-1
-------
PAGE
8. SITE CLOSEOUT
8.1 Operation and Maintenance 8-1
8.2 Site Closeout and NPL Deletion 8-5
APPENDICES
BIBLIOGRAPHY
OSWER DIRECTIVE NO. 9355.1-1
iii .
-------
LIST OF EXHIBITS
EXHIBIT
NUMBER PAGE
1-1 Remedial Site Chronology (Federal-Lead) 1-3
2-1 Remedial Process 2-2
2-2 Sequence of Performance of Project Management 2-4
Functions
2-3 Scheduling Techniques 2-5
3-1 Initial Project Planning and Start-Up 3-2
Activities
3-2 Project Plan Outline 3-4
3-3 Project Plan Interface with the Remedial 3-6
Process
3-4 Project Planning, Monitoring, and Control 3-7
Cycle
3-5 Initial Activities 3-9
3-6 Development and Issuance of the Work Assign* 3-17
ment Package
3-7 Estimates of Labor Hours Required to Complete
Interim Work Assignment Tasks for Simple, Moderate
and Complex Sites 3-19
3-d Completion of Interim Work Assignment 3-21
Activities
3-9 Approval and Implementation of the Contractor 3-25
Work Plan
4-1 Remedial Investigation/Feasibility Study 4-2
(RI/FS)
4-2 Work Assignment Amendment Procedures 4-5
5-1 Record of Decision (ROD) and Transition to 5-2
Design
5-2 The ROD Process 5-6
5-3 Record of Decision Remedial Alternative Selection 5-7
6-1 Remedial Design (RD) 6-2
OSWER DIRECTIVE NO. 9355.1-1
iv
-------
LIST OF EXHIBITS
EXHIBIT
NUMBER PAGE
6-2 Federal-Lead Remedial Design Activities . . 6-3
6-3 Suggested Outline for Pre-Oesign Report 6-7
7-1 Remedial Action (RA) 7-2
8-1 O&M, Site Closeout, and NPL Deletion 8-2
8-2 Operation and Maintenance 8-4
8-3 Site Closeout and NPL Deletion 8-6
OSWER DIRECTIVE NO. 9355.1-1.
-------
LIST OF A P P EN DICES
APPENDIX
A Project Plan Milestones
B Example Work Assignment Cover Sheet
C Names and Telephone Numbers of REM Contracting
Officers and Project Officers
D Example Interim Work Assignment SOW
E Sample Procurement Request/Requisition
P Example Work Plan Approval Form
G Procedures for Processing Superfund Inter-
agency Agreements with the U.S. Army Corps
of Engineers
• 4
H Federal-Lead Regional Coordinators
I ROD Materials: Responsiveness Summary and
ROD Briefing Materials
J Work Assignment Completion Report and Work
Assignment Closeout Form
K Sample Work Assignment and Interagency
Agreements
OSWER DIRECTIVE NO. 9355.1-1
vi
-------
OSWER DIRECTIVE NO. 9355.1-1
-------
1. INTRODUCTION
Large, public works projects are developed generally in four sequential
phases: planning, design, construction, and operation. These four phases also
characterize the systematic application of clean-up activities in Federal-lead
Superfund remedial response projects at hazardous waste sites identified on the
National Priorities List (NPL). The project planning phase for remedial actions 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 (RO) phase in which the
selected technology concept(s) is developed into engineering specifications for
application. After the RO 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 clean-up is
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 clean-up is achieved, the dose-out 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 successfully complete of a remedial response project
is to vest responsibility for the project in a single individual within EPA - the Remedial
Project Manager (RPM). The term, "RPM" Is defined in the Federal Register (November
20, 1985) 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). 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 close-out of
remedial response projects. It is designed to complement another EPA handbook,
called the 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 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, February
1985
• State Participation in the Superfund Remedial Program, February 1984
REMIFTT Management Plan: An Illustrated Guide, April 1983.
The chapters that follow are the product of an effort to compile into a single document
all the relevant information related to the RPM's roles and responsibilities for
managing remedial response actions.
OSWER DIRECTIVE NO. 9355.1-1
-------
1.1 STRUCTURE OF THE HANDBOOK
The handbook addresses all phases of the remedial planning and
implementation process (except pre-NPL listing activities) from project start-up to site
close-out and NPL deletion. Exhibit 1-1 illustrates these phases as. well as specific
activities which occur during the remedial planning and implementation process. The
upper portion of.the diagram identifies those activities which are generally performed
by the remedial planning (REM) contractors or the U.S. Army Corps of Engineers
(USAGE) under EPA oversight; and the lower portion shows activities performed by
EPA. The exhibit portrays the general order in which these activities should occur
during the remedial response project. This order provides the basis for the
organization of the handbook, the subjects of the 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 Start-Uo - 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.
• Chanter 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.
• Chanter 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 in
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
start-up and initial operation of treatment systems constructed as part of
the remedy.
• Chanter 8. Site Closeout - reviews the procedures followed in closing
out a site and identifies the specific responsibilities of the RPM in
assisting with their implementation. Its scope includes the RPM's role in
operation and maintenance (O&M) and in site cioseout and NPU
deletion.
1-2 OSWER DIRECTIVE NO. 9355.1 -1
-------
?!|l EXHIBIT 1-1
Remedial Site Chronology (Federal-Lead)
MM 1 t» I
CMATIU *
INITIAL PROJECT PLANNING
AND STARTUP ACTIVITIES
OUPIM 4
REMEDIAL INVESTIGATION / FEASIBILITY STUDY (M / FS)
CONTRACTOR
(OR USACE)
ONOOHM MOJBCT MANAGEMENT. ENFORCEMENT
AND COMMUNITY HEIATION* ACTIVCTIES
0
8
a
-------
EXHIBIT 1-1
Remedial Sit* Chronology (Federal-Lead)
CMAPTf* I
RECORD OF DECISION (ROD)
AND TRANSITION TO DESIGN
CHAPTER •
REMEDIAL DESIGN (RD)
CONTRACTOR
(OR USAGE)
WNTA1M
«f caKim
t*tc*
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(FfttcIMMa FAMI
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-------
EXHIBIT 1-1
Remedial Site Chronology (Federal-Lead)
CHAPTU ?
REMEDIAL ACTION IHA)
' mm
CONTRACTOR
(OR U8ACE)
FROM RD
r«
+
1
ID MOM
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AMD COMMUNITY RELATIONS ACTWITEt
tr"ti mini
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-------
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.
1.2 USING THE HANDBOOK
The handbook is organized according to the sequence of activities associated
with the remedial planning and implementation process. Individual chapters provide
the RPM with information for each major phase of the remedial response project. This
arrangement assists the RPM in approaching in discrete, manageable steps what can
be administratively and technically a complicated and lengthy effort in total.
The handbook is not intended to replace the many detailed guidance
documents from which it was developed. A list of these documents is contained in the
Bibliography in the back of this handbook. The RPM should have these available for
ready access.
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 REM contractor, 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.
1"6 OSWER DIRECTIVE NO. 9355.1-1
-------
2.2 PLANNING, MONITORING, AND CONTROL
Project planning is the process of identifying the scope, schedule, budget, and
resources needed to effectively achieve project objectives. 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 OT 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 and
implementing the site remedy. The RPM provides direction to the REM contractor in
identifying project objectives and constraints. Following preparation of the detailed
work plan by the REM contractor, the RPM reviews the defined scope, schedule, and
budget to ensure their conformance with the statement of work and regional program
goals. Each task in the work plan must be sufficiently detailed to convey an
understanding of project goals to those responsible for performing the work and to
provide the basis for project schedules and budgets.
2.2.1.2 Scheduling
Scheduling is a key component of planning, management and control since
establishment of a realistic project schedule is an integral part of the RPM's
responsibility to complete program targets (e.g.. Record of Decision [ROD] approval)
on time. Scheduling is necessary to anticipate when project resources such as
funding or analytical support will be needed. It also allows projects to be scheduled
to take advantage of external factors such as construction seas9ns. 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.
2"3 OSWER DIRECTIVE NO. 9355.1 -1
-------
EXHIBIT 2-2
Sequence of Performance of Project Management Functions
PLANNING
CONTROLLING
Vtriwia
fltpora
Coit
Trandi
MMdufe
Tfwidt
Oburnd
SUtW
* * *
1
i
Pltn/Poiiev
Ctanqi
ExaiffUon*
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i
1
Airtciemorv
Action*
I
t
1
Swm»y
L_ '
D*««^^H*
rn>|»CT
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*
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SdMdul*/
Scop*/Ca
-------
2. PROJECT MANAGEMENT CONCEPTS
The remediation of uncontrolled, hazardous waste sites is a technically
complex process of long duration. Further, 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
deltverables which comprise a Superfund hazardous site .remediation, project are
presented in Exhibit 1-1. Exhibit 2-1 provides an overview of the .typical schedule,
process constraints, and primary participants in a Superfund site remedial response.
Because of the complexities, constraints, and numerous parties involved in a site
remediation project, close project management and oversight are necessary for
successful project completion.
An attempt is made throughout this handbook to define the role and
responsibilities of the RPM relative to other participating parties. The purpose of this
chapter is to introduce some basic project management concepts and to relate these
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 remedial planning (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.
In the following paragraphs, the basic concepts of project management as
applied in both the public and private sectors for studies, engineering designs, and
construction activities are discussed.
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 so as to achieve 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 carries out
the management functions using common sense approaches, based on experience,
supplemented by "toots of the trade* such as scheduling, budgeting, or reporting
systems.
In reality, the project manager is held accountable for all aspects of the project,
but seldom has the strength of authority or the control over externalities to "require"
that the project proceed accordinq to plan. This is certainly the case for Superfund
projects and the RPM. Thus, the RPM must develop a strongly pro-active approach to
project management The pro-active 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, and setbacks as challenges to be overcome. A list of project
management references is included in the Bibliography at the end of this handbook.
The more important project management functions are discussed below.
OSWER DIRECTIVE NO. 9355.1-1
-------
EXHIBIT 2-1
Remedial Process
10
O
m
3)
g
31
m
O
m
CUMULATIVE
AVERAGE
SCHEDULE
TYPICAL
SCHEDULE FOR
PHASES
REMEDIAL
PROGRAM
PHASES
PROCESS
CONSTRAINTS
PRP Negotiation*
Funding
NPL Rult Making
PRIMARY
PARTICIPANTS
(Federal L«ad)
0
1
12 346
II III -...—..»
YEARS
,3-t, W-22 , 4 3-« •-» ,3-4, i-li
130 iiM/VM> x
INwo>- HR» Q
"¥ •• A AftM! ^ ft J**—
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1 * MONTHS ' '
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^ ii«. * "° / "* * ££ * ««,
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6 .
• EPA *fPA •CORPS • CORPS • CORPS • STATE
• HEM • STATE A/E CONTR
CONTH *PUBL!C *STATE
• CLP/ESO
to
CO
Ol
01
-------
EXHIBIT 2-3
Scheduling Techniques
FYM
MILf STONf CHART
(REMEDIAL RESPONSE)
loilMl Oitcovwy
NPL Liiliot
RIComptaM
FSCompteM
ROD
HD CumpUu
RAComptau
BAH CHART
(HI/FS/HOO)
HI/FSObli».iion
HI
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fit FS MMiing
Of «H FS
Public Conwninl FS
Public ComaiMil
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HOD BtMlint
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I 11 I 11 I 11 111 I I 111 11
FYM
I I I I I I I I I
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• Milestone Charts - Milestones are major events in the progress of a
project and can be used as checkpoints to indicate whether the project
is moving forward 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 the list of activities along the left side with a sequence of
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 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 new available. 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. They are, if
property maintained, a very good forecaster of upcoming tasks and can
be used to make changes in work flow and thus avoid slippage in the
final completion date.
Since each of these techniques can be used for different management functions, all
three (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 point in time.
The bar chart generally is used to expand the level of detail provided by the
milestone chart. For example, the remedial investigation/feasibility study (Rl/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.
2"6 OSWER DIRECTIVE NO. 9355.1-1
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At the most detailed level of project planning, individual contractors may use
CPM networks to schedule and control individual projects with large numbers of
tasks. Contractors will use this technique to manage individual tasks at a greater
level of detail than can be included in the bar chart. However, the key milestones
identified by the RPM's bar chart must be included in the contractor's CPM.
Taken together the three scheduling techniques result in an integrated site
scheduling approach. The milestone chart,sets the program objectives for a site
which are then incorporated in the increasingly detailed bar chart and CPM diagram.
The level of detail for each technique is tailored to the intended use.
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 depending
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
broken down into the individual task budgets.. Top-down budgeting is
most frequently applied to projects where funding availability is a major
constraint, or the project tasks cannot be well defined prior to
implementation. Estimates can be prepared using generic project
' costs or historical averages for -similar projects. The advantage is that
initial budgets do not need to include detailed information on all the
project tasks, which prevents the need for guess work. This method is
often the basis for cost estimates included in the Superfund
Comprehensive Accomplishments Plan (SCAP). An example of a top-
down budget is the fee for an engineering design which may be a set
percentage of total construction .costs.
Disadvantages of this method are that It makes reliable monitoring and
control difficult since detailed task budgets are not available, and it fails
to examine project objectives to ensure that the most effective project
approach is being used.
• 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 used when a
predetermined budget has not been imposed. This requires that the
project scope be well defined and can be broken down into individual
tasks. Two of the most common task-based budgeting techniques
used are unit-cost budgeting and staffing-level budgeting.
Unit-cost budgeting is commonly used in construction projects when
quantities are reasonably well defined. A detailed estimate of component quantities
is developed and multiplied by the unit cost Appropriate contingencies are added to
obtain the total project budget. 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.
2"7 OSWER DIRECTIVE NO. 9355.1-1
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The RPM must be familiar with both top-down and task-based budgeting
techniques since they are used at different points in the Superfund program. Top-
down budgeting is used for overall program planning to distribute the annual
remedial action 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 with in the budget planning process
is the need to project funding for future activities at a site. Since the entire remedial
response program spans several years and is made up of numerous projects, the
RPM will be asked to prepare budget estimates for out-year activities such as design
or construction. 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 depending upon the type and size of project and
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 a project manager who is willing to accomplish goals
through delegation and requires an organizational structure with good channels of
communication.
Although many REM contractor project teams are organized in this traditional
way, the RPM must operate within a different organizational structure. The RPM is the
principal contact between EPA and the remedial contractor. The RPN/Ts management
responsibilities involve working with a number of organizations within and outside
EPA. The RPM does not directly manage site activities, but rather carries out
management responsibilities by interpreting EPA policy and procedures as they
apply to the site and coordinating the participation of the numerous 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 comparison of actual
events to 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:
Provide estimates of 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 bar chart, milestone, and CPM scheduling techniques. Milestone scheduling is
generally more suited for monitoring key remedial response activities that can be
•conducted independently of other activities. This method is more useful,to monitor
2"8 OSWER DIRECTIVE NO. 9355.1 -
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performance rather than to identify adverse schedule impacts as is the case with bar
charts and CPM networks. For example, planned completion dates can be compared
to actual dates and variances identified. Bar charts and/or critical paths 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 schedule
delays that could affect schedule and budget decisions in follow-on work (e.g.,
remedial design [RD] and remedial action [RA]).
Monitoring and reportinq of the budget status will depend upon the intended
use of the information. The RPM will generally use budget reports for two purposes.
First, to assure that a particular activity is being accomplished according to its overall
schedule and within its budget ceiling. Second, 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 U. S. Army Corps of Engineers (USAGE) design and construction
contractor selection process
The review of construction change orders.
This handbook describes many of the monitoring and reporting methods by
which the Agency and individual Regions track progress for specific site remedial
actions and provide necessary management support and review of the work. These
will not be restated 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 where
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 potential
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 pro-active, 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.
2"9 OSWER DIRECTIVE NO. 9355.1 -1
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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 remedial
contractor efforts to facilitate the transfer of responsibility to
USAGE at the design phase.
Manage or limit external reviews.
Coordinate analytical needs with Contract Laboratory Program
(CLP) activity.
Increase direct observation of field activity 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 turnaround of
sample data.
Streamline requirements for contractor work products to avoid
repetition of data or other information.
• Plan Modifications
Issue work assignment amendments to adjust the budget
and/or schedule resulting from work scope changes.
Revise the SCAP for subsequent year 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.
2'10 OSWER DIRECTIVE NO. 9355.1-1
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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: internal coordination with offices
providing services to the project (e.g., analytical data reviews) and offices
responsible for other environmental laws (e.g., Resource Conservation And Recovery
Act and Toxic Substances Control Act). Without this input 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 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 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.
Implicit in successfully meeting the objectives of any project is attaining a
high-quality result. 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 to direct the contractor staff in a number of technical and policy
areas. Areas in which the RPM must 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 must be familiar with
environmental regulations and policies that will affect how the technical
considerations are applied to a particular site. By integrating technical, regulatory,
and policy areas, the RPM can provide adequate quality assurance review of project
activities and be effective in the directing, coordinating, and communicating role.
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.
2'11 OSWER DIRECTIVE NO. 9355.1 -1
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This chapter has introduced the RPM to basic management concepts and
related them to practices in the Superfund remedial response process. The next
chapter, Chapter 3, provides a description of the RPM"s responsibilities for planning
the RI/FS, processing a work assignment, and beginning preliminary work on the
RI/FS.
2-12 OSWER DIRECTIVE NO. 9355.1 -1
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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 remedial investigation and feasibility study
(RI/FS). It is divided into four major sections:
Development of a project plan
Miscellaneous activities required before starting the RI/FS
Remedial investigation (Rl) scoping of general response objectives
Procedures for issuing work assignments to a remedial planning (REM)
contractor.
Exhibit 3-1 illustrates all the activities which occur during the initial project planning
and start-up phase of a remedial response. The top half of the diagram represents
those activities which are the responsibility of the REM contractor or U.S. Army Corps
of Engineers (USACE) and the bottom those which 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 Remedial Program, February .1984,
(called State Manual)
- • Procedures for Initiating Remedial Response Services, Draft, July 1984.
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 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 which looks at the remedial
project as a whole: planning, design, and construction. The project plan is a
management tool which 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.
OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 3-1
initial Project Planning and Start-Up Activities
CONTRACTOR
(OR USAGE)
GENERAL
RESPONSE
OBJECTIVES
LEGEND:
ACTIVITY
DOCUMENT
DEVELOPMENT OF A PROJECT PLAN
ENFORCEMENT
3-2
OSWER DIRECTIVE NO. 9355.1-1
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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)
which 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 hazardous waste sites at 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 approach to the development of a project plan is a suggested
approach which reflects good management practice. It is not the only approach that
might be followed, however. Each site has unique objectives and circumstances and
a site management plan should reflect this. 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 that of a collection of diagrams and
tables. The suggested approach is a mixture 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 dunng the course of the project. Items
which change more frequently such as schedule milestones and budget figures are
more appropriately put in a spread sheet 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. 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 program.
In any program, 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. The project plan is the standard tool by which
all site projects can be monitored. Its flexible format will provide a common data base
for program management staff to use in the analysis and control of program delivery.
During the execution of site work, a project plan wilt be updated for any one of the
following reasons:
There is significant new information to necessitate a change in the
scope, schedule, or cost of an individual project site.
3*3 OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 3-2
Project Plan Outline
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. 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
3. 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
4. Data Entry Forms
3'4 OSWER DIRECTIVE NO. 9355.1-1
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Scope, schedule, or cost vary significantly from plan.
A key milestone is reached in the site project schedule. .
Three months after each prior revision, the project plan should be reviewed to
ensure that the most recent data are being used in the plan. This is illustrated in
Exhibit 3-3, a flowchart showing the project plan interlace with the remedial process.
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 revised at approximately the points indicated by Project Plan 1, 2. 3,
etc.
Progress reports could be prepared on each individual site project within the
program. The reports could contain current performance data such as labor and
expenses to date as well as projected cost and time to project completion. This 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 cleanup 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 materially alter the project parameters, they
should be incorporated into the baseline plan and be reflected in either a scope,
schedule or cost chang'e.
A list of milestones and activities that could be tracked for each of the five
project plans (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.
For Project Plan 1, only the pre-Rl/FS activities would be planned in detail.
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 2
would be done at the beginning of the RI/FS phase and would include the information
outlined below. Note that only the milestone start and finish dates and total costs are
included for activities preceding and following the RI/FS.
Project Plan 3 would be done after the FS and would include detailed
schedule and cost information for the public comment/Record of Decision (ROD)
process.
After completion of ROD and enforcement activities, Project Plan 4 would be
prepared and would include schedule and cost data for the remedial design (RD)
phase.
Finally, Project Plan 5 would be prepared to outline the remedial actipn (RA)
• activities. Again, only summary milestone and cost data would be provided for
preceding activities.
3-5 OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 3-3
Project Plan Interface with the Remedial Process
PROJECT PLAN
PROJECT PLAN 1
PROJECT PLAN 2
PROJECT PLAN 3
PROJECT PLAN 4
PROJECT PLANS
MAJOR
MILESTONES
Assign
National
Priorities
List
ChooM Lead
Consult with
SUM
REMEDIAL
PLANNING
REMEDIAL
IMPLEMENTATION
3-6
OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 3-4
Project Planning, Monitoring, and Control Cycle
X1
I
-•
V.
i
k
1
1
J
\
\
i
i
i
\
Project Project Project
Plan Plan Plan
1 2 3
/ M
ion
I
1
1
1
Project
Plan
4
I
1
I
t
J
I
1
1
Project
Plan
S
1
\
\
\
V
%
Remedial Process Pipeline
1
R«f
:
\
\
\
i
1
tort Report
L L_
1
1
Report
j
t
1
|
Report
j
t
1
Report
I
I
' i
Possible Parties Involved in Developing each Project Plan
Project Plan 1
•RPM
•State
• REMCNTR
• Enforcement
Staff
Project Plan 2
«RPM
-REMCNTR
-RSCC
«
•
•
Project Plan 3
RPM
USAGE
REM CNTR
ORC
Enforcement
Staff
• RCRA
Project Plan 4 Project Plan 5
• RPM • RPM
• USAGE • USAGE *
• •
• •
• •
OSWER DIRECTIVE NO. 9355.1-1
3-7
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3.2 MISCELLANEOUS 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 in order to allow
enough time. 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 Superfund Comprehensive Accomplishments
Plan (SCAP)
Procurement of site access and permits
Initiation of intergovernmental review procedures
• Coordination with community relations staff
• " Initiation of remedial planning activities through a State letter
of request
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 the extent to which the PRPs are going to
participate in the RI/FS process. Should the PRPs be willing to perform the RI/FS,
then the project should be conducted as an enforcement-lead project. If not, the
project can continue as a Federal-lead project, and enforcement actions will involve
three major activities:
Sharing and receiving information about PRPs with State and EPA
enforcement staff to determine the viability of an enforcement action
the
• Establishing site files and documenting all steps taken during
remedial response to support any future cost recovery actions
• Working closely with the REM contractor to make sure that the
contractor's Regional Manager is aware of the provisions regarding
enforcement, cost recovery, and the contractor's responsibilities for
providing evidence and documentation.
It is important that the RPM meet with Regional enforcement staff early in the
remedial planning process to provide any relevant information on the site which may
be of use in developing a possible cost recovery case against a PRP. During this
meeting, the RPM should also obtain clarification from enforcement staff who will have
primary responsibility for collecting and maintaining documents which* may become
evidence in a cost recovery action. This responsibility is assumed by the RPM in
some Regions, while in others it is assumed by enforcement staff.
3-8 OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 3-5
Initial Activities
ACTIVITY
1. Coordination of activities with enforcement/
cost recovery stall
2. Input to the Superfund Comprehensive
Accomplishments Plan (SCAP)
-------
ACTIVITY
4. Initiation of intergovernmental review
procedures
G)
•
o
3)
g
3)
g
<
m
5. Coordination with community relations staff
6. Initiation of remedial planning activities
through a Stale letter of request
EXHIBIT 3-5
Initial Activities (Continued)
RPM RESPONSIBILITIES
• 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 SPOC
- 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
REFERENCES
Slate Manual. Appendix D.
February 1984
40CFRPart29
Community Relations in Superfund:
A Handbook. September 1983
Stale Manual. February 1984
to
CO
on
on
-------
The collection and maintenance of proper documentation and the
development of quality site files are critically 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 ail actions taken at the site.
Documentation should be sufficient to identify the sources and circumstances of site
problems and PRPs, provide an accurate account of Federal costs incurred, and
demonstrate actual and potential impacts to public health and welfare or to the
environment. Res should include a signed copy of the Decision 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:
• Suggested Regional File Structure, Superfund Priority Sites and Priority Site
Candidates, May 1982
Appendix E of the CERCLA Enforcement Attorney's Manual Cost
Recovery Actions Under CERCLA, August 1983
• Appendix U of the State Manual.
The RPM should contact the contractor's Regional 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, May
1978 (revised February 1983).
3.2.2 Input to the Superfund Comprehensive Accomplishments
Plan .
The SCAP is an EPA management plan which 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 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 FY 1986 SCAP.
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.
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 which 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
3-11
OSWER DIRECTIVE NO, 9355.1-1
-------
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 and Permits
The primary responsibility for obtaining site access and permits rests with the
State. The RPM should, however, be prepared to support the State in this effort. It is
important that all necessary permits for site access be identified as early as possible
through joint discussions between the RPM and the State representative so that
unnecessary project delays can be avoided.
The RPM should contact the State representative who is responsible for these
tasks and discuss which permits may be required for the project, as well as strategies
for avoiding delays and obtaining site access. The RPM should consult with the Onice
of Regional Counsel (ORC) to obtain legal advice on gaining access to sites for which
the State does not have authority, such as public utility, railroad, and Federal lands
rights-of-way.
Site access may be delayed when approval authority for right-of-way access is
located in a distant place. The RPM should be aware of this possibility and should
plan accordingly. Site access, even when granted, may be limited to certain hours of
the day (e.g., midnight until 5 a.m.) which may affect schedules and costs (i.e.
overtime) for a project.
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 which
have developed a formal review process that includes the Superfund program and
one to be followed for States which 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:
Identification of the designated State's single point of contact (SPOC)
and the State's review procedures
• Formal notification of the SPOC, if one has been designated at least
one quarter prior to the RI/FS obligation quarter identified in the SCAP
Provision of appropriate review opportunity to the State within overall
project requirements (e.g., submitting documents to all reviewing
entities, bnefing critical State staff, etc.)
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
3'12 OSWER DIRECTIVE NO. 9355.1-1
-------
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
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). 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.
3.2.6 Initiation of Remedial Planning Activities Through
State Letter of Request
When EPA has lead responsibility for remedial planning activities at a site, two
options are available for initiating the project:
• The State may submit a letter requesting that EPA undertake remedial
planning activities at the site, 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 State letter requesting EPA
assistance is the simplest, most direct, and most commonly used approach.
Additional guidance on preparing and executing Superfund-State remedial response
agreements is provided in the State Manual and the forthcoming Superfund Remedial
Response Agreements Regulation, 40 CFR Part 37.
The State letter of request is a written statement verifying that State officials are
aware of the requirements of the proposed remedial activities, in a generic sense, and
requesting that EPA undertake the project A remedial response agreement between
EPA and a State defines the scope of work for the project and the responsibilities of
the respective parties.
In almost all cases, the selected option is the State letter of request, and the
RPM's only responsibilities are to review the letter and to provide comments to the
Regional Administrator, if necessary. The RPM should make certain that the letter
stipulates the following:
3'13 OSWER DIRECTIVE NO. 9355.1-1
-------
• The State will participate in community relations activities associated
with the project.
• The State will secure site access and any required permits in a timely
manner.
• Representatives of the State will meet with EPA Regional personnel to
discuss progress of the project and, if required, exchange site
information.
In the case of a publicly owned site, the State will pay at least 50
percent of the costs of the remedial action (10 percent for privately
owned sites) at the time CERCLA-funded remedial action is undertaken
at the site.
• The State will assure its assumption of all future operation and
maintenance, the scope of which will be agreed upon prior to initiation
of the remedial action.
If there are problems with the letter, the RPM should contact the State Project Officer
(SPO) designated in the letter to discuss and resolve these problems.
3.3 Rl SCOPING OF GENERAL RESPONSE OBJECTIVES
~N
Prior to developing work plans and conducting the Rl/FS, there are two crucial
steps that shape the execution of these subsequent project planning and Rl/FS
activities:
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
• General Response Objectives, or classes of response, should be
identified in order to focus the scope of the Rl/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 Rl Guidance and FS Guidance,
respectively.
Historically, the Rl/FS has often been planned and executed in a series fashion
(first the final Work Plan, then the Rl, then the FS), usually with a single sampling
event. This approach, combined with the frequently slow turnaround for laboratory
analyses, sometimes resulted in a situation where the Rt was not sufficient to support
the FS, causing delays and problems in technical quality. Therefore, the Rl/FS
planning process has been evolving to a closed-loop approach where the anticipated
data needs of the FS were used in the Rl scoping and determination of sample needs.
The anticipated FS data requirements were determined from an early screening of
alternatives, combined with a focus on those alternatives which appeared most
reasonable for the site conditions. This approach has been described in the Rl and
FS guidance documents.
3"u OSWER DIRECTIVE NO. 9355.1-1
-------
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 possible revisions to the work
authorization and planning process. These changes are referred to collectively as the
phased RI/FS approach.
The phased RI/FS approach is in the pilot stages. The RPM and the SPO or
Regional Project Officer 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 the scope of the Rl is sufficient to
support an evaluation of these technologies.
Rl Scoping is conducted by the remedial planning contractor. 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
Enforcement status and related implications of sample analysis
techniques
Special site or study conditions.
The RPM should also oversee Rl scoping by reviewing Rl scoping outputs such as:
Site descriptions
Site history
• Chronology of significant events
Site maps.
Based on preliminary site information, the RPM and RPO should identify
general response actions, or classes of response, without necessarily identifying
specific technologies. General response actions should include the "no action"
alternative as a baseline against which other actions can be measured. Examples of
general response actions include the following:
No action
Containment
On-site treatment
Off-site disposal.
A more extensive list of general response classes is provided in the F5 Guidance. The
general response objectives identified will shape the objectives of the Rl site
characterization and the evaluation of remedial alternatives.
3"15 ' OSWER DIRECTIVE NO. 9355.1-1
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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). 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
• Steo 2 - Completion of interim work assignment activities
• Step 3 - Approval and implementation of the contractor work plan
This section will discuss the responsibilities of the RPM for each of these steps.
It will also discuss some of the problems that might 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 is responsible for preparing and
assisting the RPO in preparing the work assignment package. The package consists
of four elements:
• A work assignment cover sheet
An interim work assignment statement of work (SOW)
A complete work assignment SOW for the entire project
• A 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.
3.4.1.1 Work Assignment Cover Sheet
The RPM is responsible for preparing the work assignment cover sheet, which
is a one-page summary of basic information about the individual work assignment. A
sample cover sheet is shown in Appendix B. It includes such items as the name and
address of the contractor, the contract number, the name of the site, 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, and the
names, addresses, and phone numbers of the EPA CO, PO, RPM, and RPO. The
names and phone numbers for current COs and POs are presented in Appendix C.
In preparing the cover sheet, 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 site name, work assignment number, 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 which 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:
3"16 OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 3-6
Development and Issuance of the Work Assignment Package
ORIGINATOR
DOCUMENTATION
RECIPIENT
EPA
CONTRACTING
OFFICER
HO
REGIONAL
COORDINATOR
PROCUREMENT
REQUISITION
CEPA
CONTRACTING
OFFICER
CONTRACT
MOO
(SF-aO)
HO
REGIONAL
COORDINATOR
INTERIM ft
COMPLETE
WA SOW
KEY:
RPO -REGIONAL PROJECT OFFCER
RPM • REMEDIAL PROJECT MAN ACER
SOW - STATEMENT OF WORK
WA • WORK ASSIGNMENT
OSWER DIRECTIVE NO. 9355.1-1
3-17
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Sample Work Assignment Number: 01-9L33
01 denotes the first work assignment issued under the contract
9 .denotes Region 9
L denotes the activity to be executed. Only the letters and
numbers shown below may be used:
L a Remedial Investigation/Feasibility Study
N » Remedial Design
R • Remedial Action
S a Operation and Maintenance (O&M) and Monitoring
X a Monitoring responsible party remedial actions
9 a Remedial support and management
7 a General Superfund support and management
33 denotes the site numbered 33 in the Region.
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 work assignment
. SOW and the complete work assignment SOW, 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/quality control (QA/QC) plan
Topographic mapping
Development of a sampling plan
Preliminary sampling, sample screening or other field tasks.
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 level of effort, 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 Rl/FS
3'18 OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 3-7
Estimates ol Labor Hours Required to Complete Interim Work
Assignment Tasks for Simple, Moderate, and Complex Sites*
G)
(O
OSWERDI
31
1 •
m
z:
P
tO
01
Ol
Ol
Work Plan Preparation
Collection and Evaluation of Existing Data
Health and Safety Plan Preparation
QA Project Plan 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 Complex
120-400 360-700
60-160 120-200
50-100 80-200
60-120 100-180
80-120 100-150
100-200 200-300
120-200 160-320
* Estimates are based on data from previous experience
with performance of similar tasks.
•
-------
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.
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. To assist the RPM in developing
activities and tasks for the complete work assignment SOW, the RPM should refer to
Appendix 'A of EPA's Management Plan and Operating Procedures: Remedial
Planning/Field Investigation Team Zone Contracts, OERR, October 1982. This appendix
provides a summary 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 alternately 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
HQ 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 which
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 E.
3.4.1.5 Issuance of Work Assignment Package
When the four elements of the work assignment package are all completed, the
RPM is responsible for sending the package to the Contracting Officer with copies to
the HQ Regional Coordinator and 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 which is developed and submitted by the REM contractor. As
3"20 OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 3-8
Completion of interim Work Assignment Activities
ORIGINATOR
DOCUMENTATION
RECIPIENT
WORK PLAN
MEMORANDUM
(INITIATION OP INTERIM
WA SOW AUTHORIZED TASKS)
ACKNOWLEDGE
RECEIPT
WA
ACKNOWLEDGE
UENT
EPA
CONTRACTING
OFFICER
RPM/RPO
(APPROVE OR RETURN TO
REM CONTRACTOR FOR
MODIFICATION)
KEY:
RPO • REGIONAL PROJECT OFFICER
RPM • REMEDIAL PROJECT MANAGED
SOW- STATEMENT OF WOfK
WA • WORXASSX2NUCNT
OSWER DIRECTIVE NO. 9355.1-1
3-21
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described in Section 3.4.1.2 above, the work plan memorandum describes the scope
of work for the interim work assignment level of effort and cost estimates for completing
the interim work assignment, and a schedule of interim work assignment SOW
deliverables.
The contractor is responsible for submitting the work plan memorandum within
20 days of receiving the work assignment. It is EPA's intent that the work plan
memorandum process be quick and simple. In most cases, the memorandum should
be submitted in less than 20 days. 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 20 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 should also 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 QA/QC plan and the data management plan.
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 level and
discipline, 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 frorh those provided
in the interim work assignment authorization. If they do vary by 50 percent or more
over the interim estimate, the RPM should notify the contractor's Regional Manager to
discuss and resolve these differences. If the RPM agrees with the contractor that an
increase in labor hours and/or costs above the amount provided in the interim
authorization is justified, the RPM must 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 HQ 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:
3-22 ' OSWER DIRECTIVE NO. 9355.1-1
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Work plan
Health and safety plan
Quality assurance project plan
Site sampling plan
Community relations plan.
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.
Before proceeding to the administrative mechanics of work plan approval, it is
important to discuss the process of work plan review. This is because the quality of
the work plan is crucial to the successful completion of the RI/FS.
The objective in reviewing a work plan is to obtain a plan by which a timely,
least cost, high quality RI/FS can be accomplished. Note that most of the tasks in the
RI/FS can be examined from a standpoint of technical quality, budget, and schedule.
These three standpoints form an excellent basis from which to evaluate the work plan.
Some technical considerations 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 monitor wells;
types of analyses proposed, looking ahead to technologies that may be evaluated;
use of bench and pilot scale studies; the use of ground water or other models; and 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
emerging "phased RI/FS" approach - the use of multiple sampling events to provide
feedback foe the determination of further sampling needs, increased use of analytical
alternatives such as field screening, and a greater focus on early alternatives
screening - should be kept in mind.
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, cost control, and reporting measures should be
reviewed to see if cost overruns can be detected early on.
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 Contract
Laboratory Program (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 (CPM) 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 for
the review of deliverables and milestone review meetings.
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 here. The RPM"s primary role during the work plan review is that
of a focal point and coordinator. Copies of the draft work plan are generally sent out to
technical specialists within EPA such as geohydrologists, lexicologists, chemists, and
biologists for review within their respective areas of specialization. The
3-23 OSWER DIRECTIVE NO. 9355.1 -1
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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 must coordinate the review with other involved parties within
and outside EPA. For instance, EPA enforcement, community relations, air program,
laboratory support, and legal staff should provide input. Also, in most cases,, .one or
more State agencies provide some comment at the work plan review, stage. Finally,"
the USAGE should be brought into the review process at this time. This is done using
seed money funded through a technical assistance IAG.
It is important to keep the review mqvinq 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 review process typically takes about 120 days. EPA would like to see
this duration reduced to 90 days.
The RPM may also provide direct review of certain aspects of the work plan
such as budget, scheduling, and 'specific* or "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 learn from past experience on other RI/FSs. Comparisons can be made
by looking at actual durations of similar tasks and by calculating unit quantities such
as soil borings/acre, ground water samples/cubic meter of aquifer, dollars/foot of well
installed. In this way, the RPM can become familiar with how costs, appropriate
amounts of sampling, and which approaches and methodologies work 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 ROOs have been developed,.
Another possible approach to the review of the work plan is that of a Regional
team of experienced RPMs, technical specialists, and others who convene for the
review, bringing to the effort experience and insights derived from past and current
RI/FSs. An early site visit for one or more of the members is recommended.
Finally, 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 consensus report.
The Delphi review is similar to the review done by the RPM, except that a wider pool
or reviewers is involved.
Exhibit 3-9 illustrates the process for approval and implementation of the
contractor work plan. As shown, the RPM is responsible for receiving and reviewing
the work plan and then forwarding it through the Regional Project Officer (RPO) to the
EPA CO for approval, if it is judged to be satisfactory in meeting the requirements of
the complete work assignment SOW.
If the work plan is acceptable, the RPM should forward it to the RPO for review
and approval. The RPM should also sign a work plan approval form (see Appendix F
for an example) and forward it along with the work plan to the RPO. The work plan
approval form is initiated by the contractor.
3"24 OSWER DIRECTIVE NO. 9355.1 -1
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EXHIBIT 3-9
Approval and Implementation of the Contractor Work Plan
ORIGINATOR
RPM/RPO
CEPA
EONTRACTINQ
OFFICER
7
DOCUMENTATION
APPROVED
WORK
PLAN
RECIPIENT
y,
z
EPA
CONTRACTING
OFFICER
7
(APPROVE OR RETURN TO
RPM/RPO FOR MODIFICATION)
REM CONTRACTOR
EXECUTES APPROVED
WORK PLAN
KEY:
HPO - REGCNAL PROJECT OFFCER
RPM . REMEDIAL PROJECT MANAGER
3-25
OSWER DIRECTIVE NO. 9355.1-1
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If the RPO approves the work plan, he will sign the work plan approval form
and forward it either directly to the EPA CO or to the contractor's Regional Manager
who will, in turn, forward it to the CO through the contractor's Zone Project
Management Office. In the case of the R.EM II contractor, the work plan approval form
is forwarded to the National Program Office. The exact procedures followed by the
RPO will vary depending on the particular, contractor involved. The RPO should also
forward a copy of the work plan approval form to .the PO.
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 to correct the problems. Once the
modifications are completed, the RPM and RPO will both sign the work plan approval
form and the RPO will submit it, along with the work plan, either to the EPA CO or to
the contractor's Regional Manager.
In reviewing the work plan, the RPM must 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 must accompany the work plan approval form, or only partial
approval can be provided pending an increase in funding. A work assignment
amendment form must also be recieved from the contractor and passed on. Any
increases in funding in the PR must also be consistent with SCAP resource ceilings.
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 suggested revisions with the contractor.
This chapter has provided a description of the RPM*s roles and responsibilities
for planning the RI/FS, processing a work assignment, and beginning preliminary
work on the RI/FS. The next chapter, Chapter 4, discusses the RPM's duties in
overseeing the execution of the RI/FS, leading to the selection of a remedy, which is
covered in Chapter 5.
3"26 OSWER DIRECTIVE NO. 9355.1-1
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4. REMEDIAL INVESTIGATION/FEASIBILITY STUDY
The remedial investigation (Rl) and feasibility study (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, the remedial planning (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 statement of work (SOW) and
approved work plan. This chapter is divided into four major sections dealing with1
RPM activities during the RI/FS:
Ongoing project management
Site characterization
• Alternatives screening and evaluation
Review and approval of the RI/FS Report(s).
The chapter concludes with a discussion of the RPM's responsibility to carry the
results of the RI/FS project throuqh the Record of Decision (ROD) stage (Chapter 5)
and on to the Remedial Design (RD) phase.
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 Rl Guidance)
Guidance on Feasibility Studies Under CERCLA, June 1985 (called
FS 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 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.
.OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 4-1
Remedial Investigation/Feasibility Study (RI/FS)
CONTRACTOR
(OR USAGE)
FHOM
IMITI*L
PIANMNQ AMD
STARTUP ACTIVmU
EPA
LEGEND:
ACTIVITY
DOCUMENT
ONGOING PROJECT MANAGEMENT, ENFORCEMENT
AND COMMUNITY RELATIONS ACTIVITIES
4-2
OSWER DIRECTIVE NO. 9355.1-1
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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 Jines of
communication with the contractor and should identify key project milestones. The
RPM should monitor and guide the progress of the RI/FS. the attainment of project
milestones can be monitored in the following ways:
Conduct site visits
• Review progress reports, payment vouchers, and work products
• Communicate frequently with the contractor.
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 REMII and REM/FJT Amended Contract Award Fee Evaluation Plans,
July 1984.
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 Examples include the following conditions:
The objectives of the project are to be changed (e.g., from an
evaluation of source control alternatives to an evaluation of
management of migration measures).
The amount of assistance is to be changed.
• The scope of the project is to be substantially changed (e.g., to
characterize a larger site area than originally approved).
• A rebudgeting of indirect costs is needed to absorb increases in
direct costs.
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:
• Meet with the contractor to discuss potential work assignment
amendments
• Seek innovative ways to control costs
Ensure that the work assignment is consistent with the approved
Superfund Comprehensive Accomplishments Plan (SCAP)
4-3 OSWER DIRECTIVE NO. 9355.1-1
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Approve and process the contractor Work Assignment Amendment
Package, and forward the package to the EPA Regional Project
Officer (RPO)
Maintain the signed copy of Work Assignment Amendment Package in
the Regional project file.
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 Rl/FS process, the RPM should coordinate with State officials
to inform them of site progress and to receive their input 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 Rl/FS Reports
• Ensure the State's involvement with community relations activities.
As the Rl/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 Rl/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.
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 tinder CERCLA, September 1983. This manual also
presents a suggested file structure. Examples of documentation relevant to the Rl/FS
that should be maintained include:
Contractor work plans and progress reports
On-site logs, notes, and manifests
Analytical laboratory reports
Rl reports
Alternatives evaluation reports.
4-4 OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 4-2
Work Assignment Amendment Procedures
ORIGINATOR
DOCUMENTATION
REVISED
OPTIONAL
FORM M
PROPOSED
MODIFICATION
DESCRIPTION
RECIPIENT
RPM
7
RPM
7
WA
AMENDMENT
PACXAOI
RPO
7
ORIGINAL
V*. REVISED
EUOQET
flEVISEO
OPTIONAL
FORK «
7
j
7
EPA
CONTRACT! NO
OFFICER
CBPA
IONTRACT1NQ
OFFICER
7
KEY:
RPO
flPM • REUEDtAI
WA
XJECTUANAQEB
wovvcn uincw i ivc INU. 9000.
4-5
-------
For additional assistance in maintaining documentation, the RPM should consult the
data management chapter of the Rl 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 fCERCUV 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 National Priorities List (NPL) sites. Activity start
and completion dates for RI/FS must be entered. The Rl/FS start date
is when the contractor's work plan.is approved. 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
final FS Report is released to the public. (When RI/FS is funded as one
project, there is one completion date.)
SCAP - is the official information system from which the Assistant
Administrator for the Office of Solid Waste and Emergency Response
(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 \o 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 Svsteml - 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. Coordination with enforcement staff can involve
the following actions:
• Transmit any information discovered during the Rl/FS that helps
identify potentially responsible parties (PRPs)
• Review schedules of PRP negotiation windows
Assist with the preparation of Notice Letters to PRPs
Ensure maintenance of any confidential information obtained during
the Rl/FS
Participate in negotiations with PRPs following completion of the RI/FS.
OSWER DIRECTIVE NO. 9355.1-1
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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 ail 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 Field 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 follow approved work plans.
particularly the quality assurance project plan (QAPP) and site safety plan. The RPM
can obtain technical support for overseeing field activities from the Environmental
Service Division (ESD).
Three common problems which cause project delays during this phase of the
Rl are:
• Inadequate experience in contractor or subcontractor personnel
impacting technical performance
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.
If the RPM suspects that sampling is being done improperly, the RPM should
immediately contact ESP for support and consultation.
Well drillers who normally install water supply wells or geotechnical drillers
who perform soil borings for foundation studies may cause delays because they are
OSWER DIRECTIVE NO. 9355.1-1
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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.
The RPM should also maintain dose coordination with the Office of Regional Counsel
(ORC) 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 U.S. Army Corps of Engineers (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 or subcontracting packages
Participation in the FS
Participation in project 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 (lAGs). 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.
Current EPA procedures and sample work assignment forms are provided in
Appendix G.
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
4-7 OSWER DIRECTIVE NO. 9355.1 -1
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unfamiliar with the special precautions, requirements, and health and safety aspects
of hazardous waste work. The RPM should review the REM contractor's plans
concerning subcontractors to ensure that qualified assistance is used at the site.
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 dosely with the ESO 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 (EPA currently is
preparing the "Data Quality Objectives ana Sample Plan Guidance,"
which will discuss alternative analytical approaches) to tailor the
number of samples, the types of analyses, and the level of quality
assurance/quality contra (QA/QC) 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.
Utilize laboratories outside of the Contract Laboratory Program (CLP) -
REM, in-house or subcontract - when needed to meet.
particular project requirements.
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,
and the 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 emerging 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 sample 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.
The "Data Quality Objectives and Sample Plan Guidance," currently in preparation, will
discuss alternative analytical approaches.
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:
OSWER DIRECTIVE NO. 9355.1-1
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Are the validated data sufficient to meet the objectives of the Rl?
Are the validated data adequate for purposes of remedial alternatives
evaluation?
• 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
QAPP
Health and safety plan
Data management plan.
4.3 ALTERNATIVES SCREENING AND EVALUATION
Alternative screening and evaluation is the foundation of the feasibility study
portion of the R17FS. 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.
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.
4"1° OSWER DIRECTIVE NO. 9355.1-1
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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:
The Rl scoping and development of response objectives ...
The Rl, as data become available
The pre-FS meeting, where the Ri 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 must be
cognizant of EPA policy changes that may affect technology selection.
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 identity types of alternatives, to highlight possible
issues, to plan the Rl/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 is to attain or exceed applicable or
relevant 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 (NCP), November 20, 1985.] Additionally,
other relevant standards, criteria, advisories, or guidance must be considered in
fashioning CERCLA remedies. 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
considerations should be evaluated within the requirements of the FS Guidance and
be presented to the decision-maker
• Alternatives for treatment or disposal in an off-site facility, as
appropriate (See 'Procedures for Implementing CERCLA Delegations for
Off-site Response Actions' May 6,1985).
• Alternatives which attain applicable or relevant and appropriate
Federal public health or environmental standards.
• As appropriate, alternatives which exceed applicable or relevant and
appropriate public health or environmental requirements.
4*11 OSWER DIRECTIVE NO. 9355.1 -1
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• Alternatives which dp not attain applicable or relevant and appropriate
public health or environmental standards 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 must include an alternative which 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. It may be necessary to inform the REM contractor of
applicable or relevant and appropriate standards. State representatives should
advise the RPM of any State requirements or standards as well.
In situations where the chosen remedial alternative does not attain or exceed
the applicable or relevant standards, the FS, and ultimately the decision documents,
must state the reasons. 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
On March 3, 1985, the Administrator signed Superfund Delegation Authority
(14-5) setting forth the authority for the AA/OSWER to delegate 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)
Potential public interest exception
Precedent setting or nationally significant circumstances
• Innovative technologies.
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)
Fund balancing
• Public interest exception.
To determine whether it is appropriate to delegate the remedial alternative
selection, the RA quarterly submits a letter to the AA/OSWER recommending which
selections should be delegated, will require AA/OSWER consultation, or should be
retained by the AA/OSWER. The letter should include the criteria for the
recommendation. Delegation letters can be prepared as earty as Rl completion, but
must 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
4-12 OSWER DIRECTIVE NO. 9355.1-1
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Coordinator); Upon receipt of a letter of recommendation, OERR will promptly
evaluate RA recommendations and prepare for AA/OSWER signature a ROD
delegation memorandum which lists sites for which remedy selection has been
delegated. The memorandum wilt 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 may begin with a final draft FS Report prior to
public comment or may occur immediately prior to ROD signature. Consultation
generally should begin between the RPM and the Headquarters Regional
Cooordinator and end with a final request by the RA and a response by the
AA/OSWER or his designee.
4.4 REVIEW AND APPROVAL OF RI/FS REPORT(S)
The Rl/FS Report(s) is the final product of the RI/FS process*. It summarizes
the findings of the Rl and presents the alternatives evaluated during the FS. The
report also should reflect the alternative recommended by EPA at the time of its
publication. It is the RPM's responsibility to ensure that the report(s) is complete and
ts 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 USACE, as appropriate
• Coordinate with community relations personnel to make the draft report
available for the 3-week public comment period
• Coordinate the review and approval of the final RI/FS Report (The
RI/FS Report is sometimes finalized during or after the ROD process.)
Information regarding RI/FS Report content and format is presented in the RI and FS
Guidances.
4.5 TRANSITION TO RECORD OF DECISION AND REMEDIAL
DESIGN
As the Rl/FS draws to a close there are a number of activities initiated to
ensure a smooth, expeditious transition to the next phases.of the remedial process.
The transitional activities include:
Separate reports for Rl and FS may be developed depending on the project-specific
requirements.
OSWER DIRECTIVE*NO. 9355.1-1
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Pre-ROD Meeting should be held prior to submitting the Rl/FS
Report for public comment, in order to anticipate issues and to
develop a schedule for approving the selected remedial alternative.
The pre-ROD meeting usually includes.representatives from:
EPA Regional program offices (Superfund, RCRA, Enforcement,
ORC, air, water, etc.)
EPA Headquarters (Regional Coordinator)
State
USAGE.
The RPM should develop a list of attendees as early as possible and
plan the schedule well in advance of the meeting.
• Three-Week Public Comment Period is held to receive input on the
draft Rl/FS Report The RPM must coordinate the public comment
period with the Regional Superfund Community Relations
Coordinator. Following this period, the RPM prepares a
responsiveness summary addressing the comments received.
• Phase I Design is initiated in order to expedite the USAGE selection of
a contractor for designing the selected remedy. Phase I Design
activities can take two to three months; accordingly, they should be
started well in advance.
These transitional activities are discussed in more detail in the following chapters
concerning the ROD and RD. In addition, the RPM should consult other appropriate
guidance materials.
This chapter has provided a description of the RPM's roles and
responsibilities for conducting and completing the Rl/FS. The next chapter, Chapter
5, discusses the RPM's duties during the ROD process (approval of the remedy) and
transition to RD, which is covered in Chapter 6,
OSWER DIRECTIVE NO. 9355.1-1
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5. RECORD OF DECISION AND TRANSITION TO DESIGN
Preparation and approval of the Record of Decision (ROD) 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 arxd.demonstrates that the requirements of CERCLA and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP) have been met.
The ROD also provides the basis for future cost recovery actions that may be taken
under CERCLA
The RPM has an extremely important role in the ROD process and transition to
design. The RPM, in a sense, engineers the ROD process which bridges the site
characterization and alternatives evaluation of the remedial investigation/feasibility
study (Rl/FS) to the design and implementation of the remedial action. The activities
which 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 transition to design.
These include:
Ongoing project management
The ROD process (preparation through approval)
Transition to remedial design (RD)
Rl/FS doseout
In coordinating the preparation, review and approval of the ROD, the RPM must
work closely with the representative from the Office of Regional Council (ORC).
assigned to the project The project attorney assures the legal sufficiency of the
Regional ROD process and document while the RPM assures program compliance
and technical sufficiency.
Many .Regions are now using a ROD Project Team concept which has proven
to be successful. The ROD Project Team would consist of the RPM and
representatives of the following:
Rl/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.
For enforcement-lead sites, a Negotiations Decision Document (NOD), followed by an
Enforcement Decision Document (EDO), will be prepared (see "Preparation of Decision
DocvavMifor Approving Fund-Financed and Potentially Responsible Pony Remedial Actions
Under CERCLA.' February 27,1984, hereafter referred to as the ROD Guidance).
OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 5-1
Record of Decision (ROD) and Transition to Design
CONTRACTOR
(OR USAGE)
EPA
LEGEND:
Acnvrrv
DOCUMENT
ENFORCEMENT NEGOTIATIONS
AND AOMIN ORDERS
5-2
OSWER DIRECTIVE NO. 9355.1-1
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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 Rl/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 and ROD briefings
Ensure State (60-day) intergovernmental review for RD (occurs during
public comment period on the draft Rl/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 Rl/FS 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 (RA). The RPM should make it clear to State officials that
the State must make assurances to provide all future maintenance and that the State
will pay 10 percent (at least 50 percent for publicly owned sites) of remedial
implementation (e.g., remedial action) costs associated with the selected remedy.
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 (PRPs).
Documents relevant to this phase of the remedial process include:
ROD Delegation Analysis Summary
Draft ROD
Responsiveness Summary
Intergovernmental review comments
State concurrence letter
Final ROD.
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 Superfund Comprehensive
Accomplishments Plan (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 (CERCLIS) data management system must
also be updated to include information relevant to the ROD process. Planned ROD
5'3 OSWER DIRECTIVE NO. 9355.1-1
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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 (August 31). Additionally,
actual ROD start and completion dates are to be entered. The ROD start corresponds
to the date the FS Report goes out for public comment, and the ROD completion date
corresponds to the date the ROD is signed by the RA or Assistant Administrator for the
Office of Solid Waste and Emergency Response (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 start members and their roles during the ROD
process are described below:
Enforcement 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.
Regional Counsel is responsible for ensuring that all enforcement
sensitive issues are properly presented and that the requirements of
CERCLA, the NCP, and other environmental laws and regulations have
been met. The ORC must concur on the ROD before it is presented for
approval.
• Resource Conservation and Recovery Act (RCRA^ Program staff must
review the ROD for a 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-
She Response Actions", May 6,1985.
Community Relations staff should verify that ail community relations
plan (CRP) activities regarding public comment on the RI/FS are
complete. The RPM should coordinate with community relations staff
when preparing trie 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
point 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 (HSCD). The
names and telephone numbers of Federal-lead Regional Coordinators are given in
Appendix H. Similarly, staff members fromORC must communicate with their
counterparts in Headquarters.
5-4 OSWER DIRECTIVE NO. 9355.1-1
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Depending on the site-specific situation, other Federal agencies such as the
Centers (or Disease Control, the Federal Emergency Management Agency, or the
U.S. Army Corps of Engineers (USAGE) 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 RvFS Report prior to its availability for public comment If a ROD
team concept is used, all team members should attend the pre-ROD meeting. Two
purposes of this meeting are to identify data gaps in the RI/FS and 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 issues associated with the alternatives. A pre-ROD briefing for
Headquarters staff, 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
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.
The ROD Package consists of:
ROD
• Summary of Remedial Alternative Selection
Responsiveness Summary.
The following three sections describe these ROD Package elements.
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. It 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)
5"S OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 5-2
The ROD Process
(IP
PRE-ROO
MEETING
NECESSARY)
DRAFT fll/FS
OUT FOR
PUBLIC COMMENT
DRAFT
ROD PACKAGE
PREPARE
RESPONSIVENESS
SUMMARY
SIGNED BY
REG. AOMIN.
HEADQUARTERS
REVIEW FOR
CONSISTENCY
(REG. DECISION ROD)
1
REGIONAL AND
STATE REVIEW
&
CONCURRENCES
ROD
BRIEFING &
APPROVAL
1
HEADQUARTERS
REVIEW AND
CONCURRENCES
(HQ DECISION ROD)
SIGNED BY
AA/OSWER
ROD
COPIES TO HQ
FOR NATL DIST.
5-6
OSWER DIRECTIVE NO. 9355.1-1
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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 operation 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), and the National 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.
5-7 OSWER DIRECTIVE NO. 9355.1 -1
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Declarations -. This section documents that the decision is consistent
with CERCLA and the NCP, that it is cost effective, and provides
adequate protection of public health, welfare, and the environment.
The content and format for the BOO are further described in Exhibit 5-3.
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 section 300.68(g) through (1) of the NCP
• 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 section
101(24)
• Responsiveness Summary
Operation and maintenance (O&M).
Other topics that may be appropriate depending on site-specific conditions should
also be included in the Summary text
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 remedial planning (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.
5.2.2.3 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 is
often prepared by the REM contractor, but ultimately the RPM is responsible for
ensuring its accuracy and completeness. The Responsiveness Summary documents
for public record:
Comments raised during the public comment period on the RI/FS
Report
How EPA considered and responded to these concerns.
Further information on the format and content of a Responsiveness Summary is
presented in Appendix I. 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.
5-8 OSWER DIRECTIVE NO. 9355. 1 -1
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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 or AA. The
Regional review process should include alt concerned offices, but at a minimum
should include ORC and 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 Rl/FS, the RPM can minimize the occurrence of last minute
issues and concerns. 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 I. 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 which 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 and
Region's recommendation 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 (lAGs)
with the USAGE (ideally, this should be available for signature
concurrently with the ROD)
Oversee preparation by the REM contractor of the Pre-Oesign Report
(see Chapter 6)
Provide remedial planning information (including Pre-Oesign Report) to
the USAGE in order to initiate design.
5-9 OSWER DIRECTIVE NO. 9355.1 -1
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These activities are discussed in the next chapter and in the Superfund Remedial
Design and Remedial Action Guidance, February 1985.
5.4 Rl/FS CLOSEOUT
Following completion of alt work as specified in the work assignment and the
approved work plan, including the Pre-Oesign Report, the REM contractor is
responsible for notifying the RPM that the project can be closed. The RPM then
prepares and processes the required project closeout documentation. This
documentation includes:
• Work Assignment Completion Report
• Work Assignment Closeout Form
• Final Completion Voucher.
In practice, the final closeout is often delayed because of late receipt of subcontractor
invoices. Further information on project doseout is given in Procedures for Initiating
Remedial Response Services .Draft July 1984.
5.4.1 Work Assignment Completion Report
The Work Assignment Completion Report (WACR) is a three-page form which
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 property:
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 Regional Project Officer
(RPO) on each WACR. This also involves coordinating with the RPO in
recommending a percentage of the Phase II Award Fee
• Submit copies of all WACRs to the Headquarters Regional Coordinator
and Headquarters 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 which
occur in the preparation and submission of the WACR.
5'10 OSWER DIRECTIVE NO. 9355.1-1
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A copy of a WACR is shown in Appendix J. Additional information on the
WACR can be found in EPA's REM II and Revised REMIFIT Contract Award Fee
Performance Evaluation Plans, July 1984.
5.4.2 Work Assignment Ctoseout
The work assignment closeout form (See Appendix J for a sample copy) is
initiated by the REM contractor site manager and submitted to the RPM. .•The-'-RPMi.
then is responsible for completing the form and for indicating whether the work
assignment is completed and the project closed or whether it is incomplete and
requires additional work. The RPM should send the form to the RPO for review,
approval, and signature. If the RPM or the RPO feels that the assignment has not
been completed, this is indicated on the form and it is sent back to the REM contractor
site manager with an explanation of what additional work will be required. The RPM
should immediately contact the site manager to discuss any problems that need to be
resolved before the assignment can be considered closed. Following approval by the
RPM and the RPO, the RPM should send the closeout form back to the contractor who
is responsible for submitting copies to EPA Headquarters. The RPM should also
retain a copy of the form for the Regional files.
Although the format of the closeout form will vary slightly from contractor to
contractor since each uses its own form, the information on the form is essentially the
same for all contractors.
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 ability are not yet determined. Contact the Headquarters
Regional Coordinator or REM Deputy Project Officer for guidance (or assistance) in
file preparation.
5.4.3 Final Invoice
The final invoice for the project is submitted by the contractor to the RPM along
with the WACR and the work assignment closeout form if available. In some cases,
the invoice may be delayed until final subcontractor invoices are received. It is the
RPM's responsibility to make sure that the invoice is completed correctly, is site-
specific, and includes a dear itemization of labor, travel, subcontracting and other
direct costs. 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
sends the final invoice to the RPO for signature. The RPO then sends the final invoice
to the Headquarters Project Officer for processing and payment
With the approval of the ROD and closeout of the Rl/FS work assignment, the
remedial response project moves forward to remedial design and implementation of
the remedial alternative selected. Chapter 6 discusses remedial design, including the
transition from the Rl/FS stage. Chapters 7 and 8 discuss final implementation of the
remedy and closeout of the remedial response project, including deletion from the
National Priorities Ust
5"11 OSWER DIRECTIVE NO. 9355.1 -1
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OSWER DIRECTIVE NO. 9355.1-1
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6. REMEDIAL DESIGN
During Federal-lead Remedial Design (RD) and Remedial Action (RA), the
U.S. Army Corps of Engineers (USAGE) will serve as contract manager for design and
construction.of the EPA-approved remedy. In a few special cases, other Federal
agencies, such as the Department of Interior or the Department of Energy, may
assume this role.* The USAGE will perform the following basic tasks:
• Solicit and select contractors to perform RD and RA activities
• Review and approve RDs
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 , February
1985 (referred to as RDIRA 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, graphic representation of the
Federal-lead RD process.
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 EPA RPM must work closely
with State officials to process the appropriate Superfund response agreement. The
RPM and State officials should refer to the State Manual for specific information for 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.
During fiscal year 1986, the remedial planning (REM) contractors may perform
design and act as construction contract managers on several projects on a pilot basis.
OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 6-1
Remedial Design (RD)
CONTHACTON
(OH U1ACK)
LEGEND:
«crvmr
OOCUMCNT
ONQOINQ PHOJKCT
MANAGEMENT ACTIVITIES
6-2
OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 6-2
Federal-Lead Remedial Design Activities
COPIES TO
EPA HO
USACE HQ
EPA REGION ISSUES
WA FOR INITIATING
PHASE I DESIGN
ACTIVITIES TO
USACEMRO
USACEMRO I
DESIGN DISTRICT |
-SY»np
-------
6.1.2 Reporting and Record Keeping
The RPM is responsible 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:
CgRCLlS (CERCLA Information System) - RD start (date RD funds
were obligated) and end dates (dates implementation contract was
advertised) must be entered.
• SCAP (Superfund Comprehensive Accomplishments Plan) - Since
this system is the official mechanism through which the Assistant
Administrator for the Office of Solid Waste and Emergency Response
(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 (Financial Management System) - 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. EPA's REM
contractors may be tasked to provide technical assistance in this effort
In addition, the RPM should work closely with USAGE officials to oversee the
architectural and engineering (A/E) contractor's activities during ait 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 RA, 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).
OSWER DIRECTIVE NO. 9355.1 -1
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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.
Based on input from the public participation process described above, the site
Community Relations Plan (CRP) must be revised, as necessary, to reflect knowledge
of citizen concerns and involvement. An updated fact sheet and public notice of
completion of the engineering design must be prepared and distributed as part of the
ongoing community relations process.
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 statement of work (SOW) for the USAGE which is attached to the Interagency
Agreement (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 Record of Decision (ROD) approval. A work assignment is to be
developed and issued, consistent with the standing IAG, to the USACE-Missouri River
Division (MRD) to initiate the Phase I design. The Phase I design will be based on the
draft Feasibility Study (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 1 design activities usually include:
Synoposize requirement in Commerce Business Daily
Designate A/E ore-selection and selection boards
Develop an A/E pre-selection list
Contact A/E firms to ascertain interest in project
Apprise the 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 predetermined list with a site-specific assignment, thereby expediting
the selection process by avoiding site-specific Phase I 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 Pre-Oesign Report is 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 appropriate Regional
Coordinator in EPA Headquarters for further information on the use of the 'open-
ended* contract
A generic IAG is established for ail RD assignments to be conducted within
each fiscal year. As a result only a work assignment is needed to initiate site-specific
RD activity. A sample work assignment and IAG for Phase I design are provided in
Appendix K. It is the RPM's responsibility to oversee the preliminary A/E selection
process conducted by the USAGE and to offer technical assistance and review as
needed. For example, the RPM should encourage the use of women's or minority
businesses, where appropriate.
6'5 OSWER DIRECTIVE NO. 9355.1-1
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6.2.2 Design Initiation
Following the selection of a remedy and approval of the ROD or Enforcement
Decision Document (EDD) 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/EDO and Final Rt/FS Report
The RPM must provide a copy of the approved ROD/EDO and the final Rl/FS
Report(s) to the USAGE as soon as possible after ROD/EDO approval.
6.2.2.2 Pre-Deslgn Report
The Pre-Oesign 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 responsible for overseeing the preparation and transmittal of the
Pro-Design Report As a general guideline, the report should be completed within two
weeks following remedy selection, with the cost limited to approximately 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. In addition, project-specific
considerations may determine that the costs of preparing this report exceed the five
percent guideline. 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 1AQ (Phase II Initiation)
The RPM must finalize the required site-specific design 1AG to initiate Phase II
activities by the USACE-MRD. A draft site-specific IAQ should have been submitted
concurrently with submittal of the final ROD package for approval. After the design
IAQ 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 IAQ is included in Appendix K. 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
USAGE-MRD for approval. The site-specific design IAQ can be signed at the same
time as the ROD. Details concerning preparation of the IAQ SOW and additional
USAGE responsibilities are provided in the Superfund RD/RA 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/HDD. Elements of the SOW include:
• Plans and Specifications required to comply with certain standards and
submissions:
Preliminary design (30 percent complete)
Intermediate design (60 percent complete)
** OSWER DIRECTIVE NO. 9355.1 -1
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EXHIBIT 6-3
Suggested Outline for Pre-Design Report
1. Site Description
2. Summary of Selected Remedy
Description of remedy & rationale for selection
Performance expectations
Site topographic map & preliminary layouts
Preliminary design criteria & 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
Reid 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 & regulatory requirements
Access, easements, rights-of-way
Health & 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 & access)
6. Appendices
• Reports, data summaries, etc.
6-7 . OSWER DIRECTIVE NO. 9355.1-1
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Preflnal design (95 percent complete)
Final design package (100 percent complete)
Correlating plans and specifications
Selecting off-site treatment, storage, and disposal facilities ... , .
Compliance with the requirements of other environmental
statutes
Equipment startup and operator training plans
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 (QAPP> 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 the
SupcrfitndRDIRA Guidance.
6.2.2.5 A7E Selection Oversight
The RPM is responsible for overseeing A/E firm selection by the USACE to
ensure that there are no potential conflicts of interest based on involvement of
potentially responsible parties (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 USACE and the A/E firm. During the process of
USACE selection of an A/E firm for RO, the RPM should remain informed of the
USAGE'S bidder responsibility determination.
6.2.2.6 Technical Transfer Briefing
A technical transfer briefing between the REM contractor and the USACE
design contractor must be scheduled and coordinated by the RPM prior to initiating
RO. 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.
6.2.2.7 Obtaining permits and Site Access
The RPM is ultimately responsible for identifying all required permits and
obtaining site access agreements. However, attaining access to the site and adjacent
properties, as well as any rights-of-way and easements necessary to implement RA, is
a State responsibility. The RPM must encourage the State to take action during
Phase I activities to obtain any required permits or site access agreements for both the
RD and RA in order to avoid delays in implementing the RA. This is very important to
implementing the project according to its schedule. First, access must be obtained for
RO field work. Then, during tine window provided as the RO progresses, access must
OSWER DIRECTIVE NO. 9355.1-1
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be secured for RA activities. 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 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 ail
appropriate environmental permits identified in the ROD/EDO.
Obtaining any necessary, non-environmental construction permits is the
responsibility of the RO A/E firm or construction contractor.
• Site Access. Access to sites where cleanup actions require short- or
long-term use of adjoining property or property within the site
boundaries owned by parties other than the remedial site owner, 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
. completing of RA.
Any purchase of easements or property are considered RA activities, requiring State
cost share.
The RPM must coordinate closely with the RO 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 section 104 of CERCLA, 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 operation and maintenance (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.
8.2.3 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/EDO. 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 OSWER DIRECTIVE NO. 9355.1-1
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6.2.3.2 Technical Review
Technical review of the prefinal design is the responsibility of the USAGE, with
concurrence by EPA.
6.2.4 Approval of Design
The USACE-MRO has the authority to approve and accept the final .design.
However, the EPA RPM is responsible for coordinating .the final review and Tor
obtaining concurrence from EPA and State officials.
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 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, where there is a potential to save substantial costs during
the RA. in a value engineering screening, an RA project is examined to determine
minor modifications or refinements, such as in materials specifications and/or
quantities, which 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 be candidates for formal value engineering studies. Further, the USAGE
will identify potential affects of the formal study on the project schedule and provide an
estimate of additional funding requirements, if any. The RPM is responsible for
reviewing the results of the value engineering screening to ensure that refinements
considered do not alter the remedy as described in the ROD, nor diminish its
effectiveness. EPA's REM contractors may be tasked to assist in this review. 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 Superfuhd State Contract (SSC) for ail Federally managed remedial
actions which do not have a Cooperative Agreement (CA) in place to provide ail
applicable State assurances (e.g., cost sharing, site access, O&M). Preparation of the
appropriate agreement should be initiated during the RD phase; execution of the SSC
must coincide with the completion of 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 M^Q RDIRA Guidance for information on the development of
OSWER DIRECTIVE NO. 9355.1-1
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RA cost estimates. The RPM should forward copies to EPA Headquarters and to
USAGE Headquarters. A sample site-specific IAG tor RA is shown in Appendix K.
In addition, the RPM must work with the State to either amend an existing CA
or develop a new CA application to provide assurances for O&M cost sharing. The
RPM and the State should proceed with this CA as.soon as reliable cost estimates for
O&M are available; however, the CA does not need to be executed until the RA itself is
underway. The RPM must concur with the State on the plan for O&M prior to initiation
of the RA. The RPM should ensure that, at a minimum, the O&M plan includes the
following:
• A description and duration of O&M activities
• Operational performance standards
A contingency plan for abnormal occurrences
Safety requirements for O&M activities
• Staffing requirements
• Equipment and material requirements
Annual O&M costs
• Description of site use and disposition of facilities following completion
of O&M.
See Chapter 8 for a more detailed discussion of O&M.
This chapter described the RPM's responsibilities for oversight of the RD. The
following chapter describes the RPM's responsibilities for maintaining oversight of all
RA activities.
OSWER DIRECTIVE NO. 9355.1-1
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7. REMEDIAL ACTION
Following the completion and approval of the remedial design (RD) package,
action is taken to implement the remedial action (RA). The conclusion of the previous
chapter described the preliminary activities which must be conducted by the RPM in
initiating the RA. These include execution of the required agreement (e.g., Superfund ..
State Contract (SSC)) between EPA and the State and completion of a site-specific
Interagency Agreement (IAQ) (See Appendix K). Upon execution of the IAG by the1
U.S. Army Corps of Engineers (USAGE), RA implementation can begin, starting with
the solicitation and award of an implementation (e.g., construction) contract.
continuing through completion of interim and final inspections and certifications, and
culminating with acceptance of the final project Exhibit 7-1 graphically 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, 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 responsibilities tied to RA activities.
7.1 ONGOING PROJECT MANAGEMENT ACTIVITIES
As in ad stages of remedial response, numerous ongoing project management
activities are common to all portions of RA implementation. Specific activities required
during 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 attain 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 the RA for 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
transition period during which the State assumes responsibility for the completed
remedy. The RPM should:
• Coordinate State review of contractor bid documents
Prepare amendments to the Superfund response agreement (e.g.,
SSC), as necessary
OSWER DIRECTIVE NO. 9355.1-1
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•
EXHIBIT 7-1
Remedial Action (RA)
CONTRACTOR
(OH USAGE)
moil MO
TO O&M
AND SITE
CUOSEOUT
MIUO
CKJMTUN
VWMWGUTY
EPA (OH STATI)
*CCWT*NC« OK?
0»«
LEGEND:
ACTTVmr
DOCUMENT
ONGOING PROJECT MANAGEMENT, ENFORCEMENT
AND COMMUNITY BEUkTTONS ACTIVITIES
7-2
OSWER DIRECTIVE NO. 9355.1-1
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Ensure that the State provides its cost share in accordance with the
payment schedule in the SCO
• ' Coordinate State participation in inspections, conferences, and other
reviews
• Assist in preparing amendments to the Cooperative Agreement (CA) for
operation and maintenance (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 RA contractor maintain relevant documentation.
Periodic updating of information for EPA's automated data systems is a
continuing responsibility of the RPM. These systems include:
CERCLIS (CERCLA Information System) - Start (date the
(implementation contract was awarded) and end dates (date of final
acceptance and beneficial occupancy) for the RA must be entered.
• SCAP (Superfund Comprehensive Accomplishments Plan) - The RPM
should coordinate with the Regional SCAP contact to ensure that the
information on the SCAP is accurate and adequate to maintain RA'
activities.
• FMS (Financial Management System) - The RPM must review for
accuracy the monthly and ad hoc financial status reports on the RA.
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 RO 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 (ROD). 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.
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 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.
7"3 OSWER DIRECTIVE NO. 9355.1-1
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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 which could affect the level of concern or
information needs of the community. The RPM must 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 (i.e.. Are the bid bonds provided in the proper form and amount? Is the
required insurance binder provided?); and responsible (i.e., 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.
7.3 CONSTRUCTION MONITORING AND INSPECTIONS
The USAGE is responsible for assigning a full-time inspector(s) to be on-site
during ait 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 ail 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 Resource Conservation and
Recovery Act (RCRA) hazardous waste manifests. The RPM may be requested to
assist in resolving discrepancies, conducting site inspections, and enlisting State
support on such matters, as appropriate.
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 ail 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
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.
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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 steps required to complete the RA are;
• Conduct preflnal conference and inspection
Prepare final inspection and certification report
The RPM*s responsibilities for the final technical report, O&M assurances, site
closeout, and deletion from the National Priorities List (NPL) are discussed separately
in Chapter 8.
7.5.1 Preflnal Conference and Inspection
As the project nears completion, a prefinal construction conference and
inspection will be conducted. Participants in the prefinal 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 doseout
The prefinal 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 prefinal inspection report for submission to the
RPM and the State.
7.5.2 Final Inspection and' Certification Report
Upon completion of any outstanding construction items, a final inspection will
be conducted. The prefinal 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 prefinal 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 prefinal inspection report have been resolved. (If any items remain
unresolved, the inspection will be considered a prefinal inspection, requiring another
prefinal inspection report)
Upon satisfactory completion of the final inspection, the USACE will prepare a
final inspection/certification report. 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.
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7.8 TRANSITION TO OPERATION AND MAINTENANCE
As the RA nears completion, the RPM must prepare for transition to O&M. As
mentioned previously, the State always assumes sole responsibility lor 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 and the State's representative to discuss transition roles. This meeting should
occur early in the RA pnase.
When the RA includes construction of a treatment system, questions may arise
regarding whether the facility start-up and shakedown period are part of the RA or part
of O&M. In some cases, shakedown may last several months.ln most cases, the
facility shakedown period wilt be considered part of the RA. Remedy effectiveness
must be demonstrated prior to submitting the final technical report for the RA
completion. Since the State assumes the title to any facilities constructed during the
RA. the State may be unwilling to accept the facility until treatment effectiveness can
be demonstrated. During the shakedown 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.
Chapters 6 and 7 have highlighted the RPM*s major responsibilities for design
and construction of the selected remedial alternative. Although for most sites primary
on-site responsibility for these two phases has been delegated to the USAGE, which
acts as EPA's contract manager, the RPM has the overall responsibility for ensuring
that the remedy implemented meets the environmental, technical performance,
regulatory/legal, and Institutional requirements discussed in the RI/FS report. The
final chapter of this handbook. Chapter 8, focuses on provisions for remedy O&M, NPL
deletion, and site doseout
7"6 OSWER DIRECTIVE NO. 9355.1-1
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8. SITE CLOSEOUT
This chapter discusses the procedures followed in closing out a site and the
specific responsibilities of the RPM in assisting with the implementation of these
procedures. It is divided into two major sections:
Operation and Maintenance (O&M) ^.,
• Site Closeout and National Priority List (NPL) Deletion.
It does not discuss procedures and responsibilities for closing out a remedial
Investigation/feasbility study (Rl/FS), since these were already discussed in Chapter 5.
Exhibit 8-1 illustrates the activities which occur during O&M, site cioseout, and
NPL deletion. The top half of the diagram represents those which are the
responsibility of the U.S. Army Corps of Engineers (USAGE) or the remedial action
contractor and the bottom those which are the responsibility of EPA and the State.
Much of the information used for preparing this chapter was derived from the
EPA manual entitled State Participation in the Superfund Remedial Program (State
Manual), February 1984, and an EPA memorandum entitled "Interim Procedures for
Deleting Sites from the National Priorities .List," March 27, 1984. For additional
background on the subjects discussed in this chapter, the RPM should review these
two source documents.
8.1 OPERATION AND MAINTENANCE
Following completion of a remedial action (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 Assistatnt Administrator for the Office
of Solid Waste and Emergency Response (AA/OSWER).
The State is required to enter into an O&M Cooperative Agreement (CA) 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 Chapter 3 of the State Manual
and the RPM Handbook for State-Lead Projects. 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 of the CA 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.
OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 8-1
O&M, Sit* Closeout, and NPL Deletion
CONTRACTOR
(OR USAGE)
PROM
RA
|CCHNt
-------
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.
8.1.1 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, usually through consultation with appropriate sources in the
Region, State, or Headquarters.
8.1.2 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 must actively review these tasks and their schedules. This should be done
through 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 (SPO). 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 which 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 phone calls with the SPO or information
contained in State progress reports.
8-3 , OSWER DIRECTIVE NO. 9355.1-1
-------
EXHIBIT 8-2
Operation and Maintenance
ACTIVITY
1. Monitor agreement provisions
2. Review the tasks and schedules
contained in the O&M plan and the CA
3. Track financial activities
4. Modify the CA
RPM RESPONSIBILITIES .
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
REFERENCES
State Manual,
February 1984
State Manual,
February 1984
State Manual,
February 1984
State Manual,
February 1984
OSWER DIRECTIVE.NO. 9355.1-1
8-4
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8.1.3 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; therefore, the RPM is
responsible for monitoring technical activities only.
The RPM should review State drawdowns on the letter of credit on a quarterly
basis. The RPM should contact appropriate Regional financial management
personnel for this information. 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.
Drawdowns should be only for EPA's percentage of funding (e.g., 90% of total costs).
Equipment expenditures must be conducted in accordance with EPA's procurement
regulations, 40 CFR Part 33; OMB Circular A-102 (available from the Regional grants
office); and Appendix T of the State Manual.
The RPM is responsible for keeping a complete file of ail financial activities, as
well as entering appropriate financial data into the CERCLA Information System
(CERCL1S) data base. The CERCUS data base should include the O&M start date
which corresponds to the date of final acceptance of remedy and the O&M completion
date which corresponds to the termination of O&M cost-sharing period.
Within 90 days after completion of the O&M cost-sharing period, the State is
required to complete a Financial Status Report EPA (Form 269) and submit it to the
RPM. The RPM should compare the data in this report with those 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 CA amendment (see State
Manual).
8.2 SITE CLOSEOUT AND NPL DELETION
Upon the satisfactory conclusion of the RA, the site is closed out and
recommended for deletion from the NPL The RPM is responsible for assisting in both
of these activities. In site doseout, the RPM is responsible for reviewing the final
technical report submitted by the USACE-RA contractor. For NPL deletion, the RPM is
responsible for assisting in the preparation of the advanced public notification and the
NPL deletion package. The following two sections describe the specific
responsibilities of the RPM for these two activities. Exhibit 8-3 summarizes these
responsibilities.
OSWER DIRECTIVE NO. 9355.1-1
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EXHIBIT 8-3
Site Closeout and NPL Deletion
ACTIVITY '
1. Final technical report
2. Deletion of the site from the NPL
HPM RESPONSIBILITIES
Ensure the report is submitted
within 60 days after the com-
pleteness of the RA has been
confirmed
Review the report for adequacy
and appropriateness
Assist in preparation of the
advanced notification statement
Assist in preparation of the NPL
deletion package
• Development of the overview
memorandum
• Description of the site and
remedy
- Description of how the sits
qualifies for the deletion
criteria
- Collection of relevant
documentation
- Preparation of a technical
briefing for Headquarters
REFERENCES
Superfiuid Remedial
Design and Remedial
Action Guidance.
February 1985
"Interim Procedures
for Deleting Sites
from the national
Priorities Lot,'
March 27,1984
8-6
OSWER DIRECTIVE NO. 9355.1-1
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8.2.1 Final Technical Report
If it has been decided that a final technical report will be required at the
completion of the RA, the RPM is responsible for ensuring that the report is submitted
within 60 days after the completeness of the RA has been confirmed. The RPM should
stay in frequent contact with the USAGE and the State to make sure that this occurs.
The RPM should be prepared to provide the USACE/State with assistance and
support if required, in producing the report
In reviewing the final report, the RPM should make sure that the following
elements are discussed:
• Synopsis of the work defined in the statement of work (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 at the
site.
~ If the discussion of any of these elements is Insufficient, the RPM should
contact the USAGE representative who was responsible for preparing the report and
explain what modifications need to be made, including any additional information
which may be required. The most important requirement is that the report provide
sufficient information to judge the effectiveness of the remedy and to assess whether
at least one criterion for deleting the site from the NPL has been met (see next section
for a description of these criteria).
8.2.2 Deletion of the Site from the NPL
Regions can recommend deletion of a site from the current NPL at any time
after the RA is complete and after consultation with the State. A site can be deleted
when either of the following criteria has been met
All appropriate Fund-financed response under GERGLA has been
completed and EPA has determined that no further cleanup by
responsible parties is appropriate at that time
Based on a remedial investigation, EPA had determined that the
release poses no significant threat to public health or the environment
and, therefore, taking of remedial measures is not appropriate at that
time. This would have lead to a No Action Record of Decision (ROD).
The process of recommending a site for deletion consists of two major steps:
Preparation of an advanced notification statement
Preparation of an NPL deletion package.
The RPM's involvement in these two activities is discussed below. Additional
information can be obtained by consulting the EPA memorandum entitled "Interim
8-7 OSWER DIRECTIVE NO. 9355.1-1
-------
Procedures for Deleting Sites from the National Priorities Lisr", March 27, 1984. (Note:
the procedures for deleting sites from the NPL are currently undergoing revision;
consult the Headquarters Regional Coordinator for current procedures.)
8.2.2.1 Advanced Notification
An advanced notification statement is required to inform the public of EPA's
intent to prepare a site for deletion. The statement is prepared and issued to the
public two weeks before a three-week comment period*- • During this three-week
comment period, the public is given the opportunity to comment on the notification
statement The Region is responsible for preparing a responsiveness summary of
these comments and a summary of how the Region responded to these comments.
Primary responsibility for preparing the advanced notification statement rests
with the Regional Office of Public Affairs/Superfund Community Relations Coordinator.
The RPM should work closely with the Regional Office of Public Affairs/Community
Relations Coordinator to provide appropriate assistance and support in order to
ensure that the notification statement is prepared as required. This may include the
following:
• Assistance in preparing a Responsiveness Summary of public
comments received in response to the notification statement
• Assistance in identifying the location in the community of relevant
documents for public review (this information should be included in the
notification statement)
Assistance in preparing a description of the doseout plan for the site
and in delineating the O&M procedures to be implemented and the
monitoring program.
8.2.2.2 Deletion Package
The Regional NPL Coordinator is responsible for preparing a deletion package
and submitting it through the Regional Administrator to Headquarters for review and
concurrence. The RPM is responsible for assisting the NPL Coordinator in this effort.
Therefore, it is important that the RPM develop a close working relationship with the
NPL Coordinator and be prepared to provide assistance regarding the technical
aspects of the site.
The NPL Coordinator may request assistance from the RPM in the following
areas:
Development of the overview memorandum that will be a part of the
deletion package
• Description of the site and the implemented remedy
Description of how the site qualifies for one or more of the deletion
criteria
• Collection of relevant documentation to support the deletion
recommendation in the package
FS Report
ROD
Progress reports
Post-closure monitoring plan
8-6 OSWER DIRECTIVE NO. 9355.1-1
-------
O&M plan
Responsiveness summary
Final technical report
Preparation of a briefing for Headquarters, if requested, on complex
technical aspects of the site.
Once the deletion package has been completed,-the NFL Coordinator is responsible
for obtaining Regional concurrences and approvals and transmitting the package to
HSCD.
Following deletion from the NPL, the site is technically closed out with respect
to the Federally-funded remedial response that was undertaken. 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 pertaining to the site must be carefully
documented to support any future legal or cost recovery actions taken. These actions
may occur years after the data have been gathered. Thus, 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 the general public under Freedom of
Information Act requests, should they be filed:
OSWER DIRECTIVE NO. 9355.1-1
-------
OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX A
Project Plan Milestones
OSWER DIRECTIVE NO. 9355.1-1
-------
OSWER DIRECTIVE NO. 9355.1-1
-------
Project.Plan' 1
Actual Generic
Schedule Schedule
Milestone (Start/Finish) Cost .(Start/Finish) Cost
Pro 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
OSWER DIRECTIVE NO. 9355.1-1
-------
Project Plan 2
Actual Generic
Schedule • Schedule
Milestone (Start/Finish) Cost (Start/Finish) Cost
Pre-RI/FS
HI/PS •
Public meeting
Coordination of Analytical support
REM contractor work plan test 1
REM contractor work plan test 2
o
o
o
Validation of data
Technical assistance funds (to
COE, if needed)
Pre-FS meeting
Draft Rl/FS delivered
ROD delegation analysis
Design assistance fund to COE
RX/FS review
Pre-ROD meeting
Delivery of public comment FS
Public Comment Period/ROD
RD .
RA
A-2 OSWER DIRECTIVE NO. 9355.1 -1
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Project Plan 3
Actual Generic
Schedule . Schedule
Milestone (Start/Finish) Cost (Start/Finish) Cost
Pre-RI/FS
RI/FS
Public Comment/ROD
Notification of public comment
period
Start of public comment
Notification/negotiation with PRP
Draft ROD
Coordination with other regional
offices (OW, OSW, ORC)
Responsiveness summary
State review
Design assistance funds to Corps
of Engineers (COEDA)
ROD briefing
Final ROD
Final community relations plan
ROD signature
RD
RA
A-3 OSWER DIRECTIVE NO. 9355.1-1
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Project Plan 4
_ Actual _ _ Generic _
Schedule - Schedule
Milestone (Start/Finish) Cost (Start/Finish) Cost
Pre-RI/FS
RZ/FS
Public
RD
Pro-design report
RI/FS closeout
Funding obligation
A/E award
Tech transfer briefing
Site access permits
Notice to proceed
Community relations
30% design reviaw
60% design review
Pre-final (95%) design review
Final design review
Value engineering
SSC signature
RA
A-4 OSWER DIRECTIVE NO. 9355.1-1
-------
Project Plan 5
• Actual Generic
Schedule • Schedule
Milestone ; (Start/Finish) - Coat (Start/Finish) Cost
Pre-RI/PS
RI/FS
Public Comment/ROD
RD
RA
Funding obligation
Advertisement for bid
Pro-bid meeting
Bidder responsibility
determination
Confirmation of compliance of
disposal facility with RCRA,
TSCA, and CWA
Award
Pre-constraction meeting
Community relations
Authorization to proceed
Submittal of contractor safety
plan
Construction oversight
Progress report 1
Progress report 2
o
o
Completion of construction
Pro-final inspection
Final inspection
Final acceptance
Certificate of completion
Warranty
Operation & maintenance
cooperative agreement
Final technical report
Deletion from NFL
A-5 OSWER DIRECTIVE NO. 9355.1-1
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OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX B
Example Work Assignment Cover Sheet
OSWER DIRECTIVE NO. 9355.1-1
-------
OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX B
Example Work Assignment Cover Sheet
A. Contractor:
B. Contract Number:
Camp, Dresser & McKee
7630 Little River Turnpike
Suite 500
Annandale, VA 22003
68-01-6939
C. Site/Title:
0. Assignment Number:
E. Statement of Work:
F. Level of Effort (Work Hours):
G. Period of Performance
Del Norte, CA/RI/FS
01-9L33
Attached
1248 Interim Authorization
6500 Total Estimate
In SOW
Contracting Officer
Contracting Officer Approval
Ulrfce Joiner
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Phone 382-2302
(PM-214F)
Date
Prefect Officer
Linda Boomazian
Environmental Protection Agency
401 M Street. S.W.
Washington, O.C. 20460
Phone 382-4997
(WH-548E)
Regional Project Officer
Signature
Keith Takata
Environmental Protection Agency
Region IX
215 Freemont Street
San Francisco, CA 94150
Phone 415-974-8910
Date
Remedial Project Manager
Tom Mbc
Phone 415-974-8150
Signature
Date
GSVvER DIRECTIVE NO. a
-1
-------
OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX C
Names and Telephone Numbers of REM Contracting
Officers and Project Officers
OSWER DIRECTIVE NO. 9355.1-1
-------
OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX C
Names and Telephone Numbers of REM Contracting
Officers and Project Officers
Contract
REM/FIT(Zone1)
REM/FIT (Zone 2)
REM II
REM III
REM IV
CO/PO
Ron Kovach, CO
Bill Kaschak, PO
VInce Gonzales, CO
Nancy Willis. CO
Ulrike Joiner, CO
Linda Boomazian, PO
Ron Kovach, CO
John Kingscott, PO
VInce Gonzales, CO
Nancy Willis, PO
Telephone
201-382-3201
201-382-3248
201-382-2090
201-382-2347
201-382-2302
201-382-7997
201-382-3201
201-382-7996
201-382-2090
201-382-2347
OSWER DIRECTIVE NO. 9355.1-1
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OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX D
Example Interim Work Assignment SOW
OSWER DIRECTIVE NO. 9355.1-1-
-------
OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX D
Example Interim Work Assignment SOW
Del Norte County Pesticide Storage Area
Initial Tasks
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 Reid 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
• Reid Sampling
• Reid 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
OSWER DIRECTIVE NO. 9355.1-1
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OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX E
Sample Procurement Request/Requisition
PROCUREMENT REQUEST/REQUISITION
Iftittf *Md Mirrvmxu an ffwnr to fort curnptenitt rt» ferml.
OATt
3. OATt NtQUiPltO
OP
34. ONIOINATOM f/V«mrj
(..TtbftPMONt NO 0. MAI I COOl
». OttlVtM TQ:
, DIVISION
to, PMOJtCT MANAQSM I.ytine I
NO.
US! QNI.V
-OMOIMNO.
)>%tMCHA>CAWTMOIIITY/CONTHACT NO.
OlsCQUNT
TAKINO OMOln/QUQTINQ
FOB PQINT
VtNOOM NAMI ANO AOOMtM
CONTNACTINOyONOBAlNO O»»IC*m
«. PINANCIAl. OAT*
•. MMVIOMQ PINANC1
IM
OOCUMINT
CQNTNOhMQ.
ACCOUNT NO.
(•I
0«J«CT
OOhhAM AMOUNT
in
18 It 17 W It »
31 3Z S
41 43 43*4
47
SSM
10. AMOUNT Of MONIV SHOWN A* COMM4TTSO It:
QOMIOINAC QotCMAM
11. GONTNACT1NQ Of PICS
QAUTHQMIZSO Q
TO IXCSSO tV 10» AMOUNT SHOWN
IS.
IO NO.
STOCK Oft ITIM NO.
113)
OUCHimOM
(141
QUANTITY
nti
UNIT OP
istut
lltt
UNIT
COST
1171
AMOUNT
lit!
it. suaawTio CONTHACTOM/VINOOM
31. SIONATUMt OP ONIQINATQM
OATt
33. SIONATUMt Ol>
OATt
20. MtCOMMtNOtO PNOCUMtMINT MtTHQO
QNONCOM»CTTTIVC/./lttflflnriO»«mcA«
-------
OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX E
Sample Procurement Request/Requisition
OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX F
Example Work Plan Approval Form
OSWER DIRECTIVE NO. 9355.1-1
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OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX F
Example Work Plan Approval Form
SPM
RPM
DATE:
FROM:
TO:
WA NO.:
SITE NAME:
ACTIVITY:
Approval for entire work plan:
Budget $
LOE Hours
Estimated Completion Date
Partial approval:
Tasks Approved
Budget _
LOE Hours
Not approved:
COMMENTS:
INSTRUCTIONS FOR PROCESSING
•WORK PLAN APPROVAL*
1) SPM initiates and submits form to RPM
2) RPM completes form, gets REM-RPO
signature and returns form to SPM
3) SPM forwards completed form to ZPMO*
4) ZPMO* delivers form to EPA HQ
5) EPA HQ processes/approves form and
returns to ZPMO*
6) ZPMO* notifies SPM of approval
• NPMO FOR REMII
EPA
HQ
RPM Signature/Approval/Date
Approved as submitted
Approved with changes
Approved pending funding
Partial Approval
Not Approved
Approved as submitted
Approved with changes
Approved pending funding
Partial approval
Not approved .
REM-RPO Signature/Approval/Date
REM-DPO Approval Signature/Date
CO Authorization Signature/Date
OSWER DIRECTIVE NO. 9355.1-1
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OSWER DIRECTIVE NO. 9355.1-1
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APPENDIX G
Procedures for Processing Superfund Interagency Agreements
with the U.S. Army Corps of Engineers
OSWER DIRECTIVE NO. 9355.1-1
-------
OSWER DIRECTIVE NO. 9355.1 -1
-------
MEMORANDUM
SUBJECT: Procedures for Processing Superfund Interagency
Agreements with the U.S. Army 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 (USACE) 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 USACE. 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 USACE 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.
OSWER DIRECTIVE NO. 9355.1 -.1
G-T
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INTERAGENCY AGREEMENT/AMENDMENT
Part I - GENERAL INFORMATION
3. Type oi Action
New Agreement
4. Program A&oreviation
*
S. Mamo and Address of EPA Organisation
*
8. Name and Addrass of Omar Agency
Department of Defense
U.S. Army Corps of Engineers (USAGE)
Engineering Division, Missouri River
Omaha, Nebraska 68101-0103
7. Pro|«ctTiiia . .
.Technical Assistance Activities - FY 198S
a. EPA Proiaa Officer (N»m*. AdOnu. TVepAone /Vw/noer/
* • •
9. Other Agency Proiaa OHicar INtm*. Address. Ttfcpfiont Nomtiir)
William Mulligan FTS7864-7227
USAGE, Engineering Division, Missouri River
P. 0. Box 103, Downtown Station
Omaha, Nebraska 68101-0103
10. Protect Period
10/01/84 - 09/30/85
It. Budget Parted
10/01/84 - 09/30/85
12. Scope oi Work lAatett Haitian* i/tecu. M ne*OoV
This agreement obligates no more than S * 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
thai 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 products. These products may include such things as
sampling plans, plans and specifications for drum and bulk waste removal, and
draft and final reports on the remedial investigation or the feasibility study.
13. Statutory Authority for botn Transfer of Funds and Proiecs Activities
CERCLA, E.O. 12316 & the Economy Act of 1932, as amended (31USC153S)
14. Other Agency Type
Federal
FUNDS
PREVIOUS AMOUNT
' AMOUNT THIS ACTION
AMENDED TOTAL
1 S. EPA Amount
16. EPA In-Kind Amount
17. C'har Agency Amount
18. Other Agency In-Kind Amount
19. Total Preiact Cost
20. Fiscal Information
Program Element
TFAY.9A
FY
85
Appropriation
68/20X8145
Ooc. Control No.
Account Numoer
OSV
Obiect Class Obligation/ Oeeoiigauon Ami
25.76.
niRpnrivg NO. 9355.1 -
EPA Form 1610-1 (Rev. 3-84) Previous editions are oosoieta.
Page i of
G-2
-------
i ' 2V Budget Categories
Coffttf uction " ' ••
Otfter
'oial Oi'ect Charges
na,r«et CatM Rate 0000 « Base 0000
Total
EPA Snare 1 00 %) (Other Agency SXwre 0 *>
Total ltem7;;j.i....vo.i.J^TO7^___
Estimated Cost to Oate "M~'7Vi^rT
S
SBreakdown not available.
Will be provided as cart of
request for reimbursement.
$ *
i equipment autnorited to be luiiusned b« 6PA <* acqu«/e« witn £PA luodsf
»nu/y etf «aw<0fiMm casting 11.000 or morel
Af e eny ol UMM lunw Mine, u*ed on euramwcai •veemenu? LJ te»
J COM. LJ Coooer»iwe Aqfeemeni. or • LJ Proeuremom
IS No (5«« rtem 2 f /)
Name (it tno<**i
Total Extramural Amount Unde* Th« Projea *ercam Funded BY EPA /// inowni
PA«T 111 — PAYMENT M6THQOS AND 9ILUNG INSTRUCTIONS
I US OitburMmem Agreement:
a
a
Advance
Allocation Ttantler
Requen (or reimBunement of actual cam will bo itemued on SF tOtl or Sf 1080 and
tubnuned to We Pinancui Management QHtee. £flv«onmema» •totocsion Agency. 2ft Wen St
Claw. Cincinnati. OH 4426*
S Montnty LJ Cvuanerty LJ Upon Completion o< Work
Only available for use by Federal aqenoes on wotkmo, capital (und or wtn appropriate (unidca.
tion of need (or this type o< payment metnod. Uneipenoed (unds at completion o< wor» WIM oe
rMurned 10 £PA Quaneriy COM reports will be lorwarded to tfte Financial Manaqemem Ottice.
Environmental Protection Agency. 2ft West Si. Clatr. Cincinau. OH 4S26B.
Used to transierobli^ationel authority or trans
-------
The other agency covenants and agrees that it will expeditiously initiate and complete tie prpje a i^miv -:
which funds have been awarded under this agreement.
27. Soaciai Conditiona:
Work assignments for technical assistance will be initiated via a lett
* or his deslgnee. The le
identify the particular site, provide the necessary account numbers, a
adjustments, including increases in the site dollar ceiling (510,000)
to the scope of work.
EPA acting as manager of the Hazardous Substance Response Trust Fund,
information on CERCLA response actions and related obligations of CZRC
these actions. In addition, CERCLA authorizes EPA to recover from res
ell government costs incurred during a response action.
(See Attachment A)
er signed by the
tter will
nd describe any
and/ or changes .
requires current
LA- funds,foV, , ;..,,:;.
pbnsible parties
•
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 altar 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. "•>• 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 OHict lint •dmiru*irMiv«/maflao**iMr
vuiotanct/
28. Organisation/ Address
*
EPA Program Oftica (tor ttefutieti tuuitntti
*
Decision Official on Sanalf of The Environmental Protection Agency Program Office
axs*™*.
*
•
Action Official on Behalf of the Environmental Prataction Agency
31 . Signature
Autnorisine
32. Signature
Typed Name and Title
*
Official on Sa
naif of ttie Otner Agency
Typed Name and Title
Date
Data
•
EPA Porni 1S100 (Mew. S-«4»
OSWER DIRECTIVE NO. 93t^,Via< s
G-4
-------
TECHNICAL ASSISTANCE AUTHORIZATION FORM
AUTHORIZATION IS HEREBY GIVEN TO INITIATE TECHNICAL ASSISTANCE WORX
AS DESCRIBED in IAG t DW96««*«««-01-0. THE FOLLOWING INFORMATION IS
PROVIDED FOR COST TRACKING PURPOSES:
SITE NAME
REGION
EPA SITE 1.0. »
HQ TECHNICAL PROJECT OFFICER
REGIONAL SITE MANAGER
PERIOD OF PERFORMANCE
PHONE
PHONE
FROM
TO
ACCOUNTING INFORMATION
I
|DOCUMENT
jCONTROL NO.I
IAG NO.
SUPERFUND
ACCOUNT NO.
I OBJECT! NOT TO
I CLASS I EXCEED
I CODE !• AMOUNT
W|9|6
W|9|6
0
0
5
5
TlF
TIP
(Title)
DATS
EPA PROJECT OFFICER
DATS
(individual who certifies funds)
DATE
Original to: Richard Run*, EPA
Cincinnati, OH
cc:
William Mulligan, USAGE
*
Noel Urban, USAGE
Paul Nadeau, EPA
Ivery Jacobs, EPA, Room 3623M
Financial Reports and Analysis Branch
0-5
OSWER DIRECTIVE NO. 9355.1-1
-------
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 USACE will provide to EPA or DOJ site specific costs
and copies of the back-up documentation which supports those
costs. The USACE 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.
OSWER DIRECTIVE NO. 9355.1-1
G-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 (USACE) 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 USACE 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
OSWER DIRECTIVE NO. 9355.1-1
G-7
-------
OSWER DIRECTIVE NO. 9355.1-1
-------
APPENDIX H
Federal-Lead Regional Coordinators
OSWER DIRECTIVE NO. 9355.1-1
-------
OSWER DIRECTIVE NO. 9355.1-1
-------
APPENDIX H
Federal-Lead Regional Coordinators
REGION
TELEPHONE
III
IV
V
VI
VII
VIII
IX
X
Steve Hooper
Bill Kaschak
John Kingscott
Linda Boomazian
Elizabeth Woodson
Linda Boomazian
Elizabeth Woodson
Nancy Willis
Carol Lindsay
Randy Kaitreider
John Kingscott
Randy Kaitreider
Steve Hooper
Steve Hooper
201-475-6689
201-382-2348
201-382-7995
201-382-7997
201-475-8246
201-382-7997
201-475-8246
201-382-2347
201-475-6704
201-382-2448
201-382-7995
201-382-2448
201-475-6689
201-475=6689
OSWER DIRECTIVE NO. 9355.1-1
-------
OSWER DIRECTIVE NO. 9355.1-1
-------
APPENDIX I
ROD Materials: Responsiveness Summary and
ROD Briefing Materials
-------
APPENDIX J
Work Assignment Completion Report and Work
Assignment Closeout Form
OSWER DIRECTIVE NO. 9355.1-1
-------
OSWER DIRECTIVE NO. 9355.1-1
-------
EPA WORK ASSIGNMENT COMPLETION REPORT (WACR)
1. CONTRACT NO.
2. WORK ASSIGNMENT HO.
3. EPA REGION
4. CONTRACTOR/SUBCONTRACTORlSl
5. CONTRACTOR SITE MANAGER W«m» «ta «ww No.i
7. WORK LOCATION iSitt /V«rw « Sam
9, BRIEKT DESCRIBE SCOPf Qf WORK:
9. DESCRIBE CONTRACTOR'S PERFORMANCE;
10. UNUSUAL PflOBUM&OCCURRENCES AFFECTING CONTRACTOR'S PERFORMANCE:
11. PHASE I AVAILABLE
12. PHASE) PAID
13. PHASE » AVAILABLE
14. PHASE II AWARD RECOMMENDED?
Q vcs RECOMMENDED SIZE:
Q NO
(0-tOOSi '
15. STATE SPECIFIC REASONS FOR RECOMMENDATION FOR PHASE II AWARD: /AMrM/i« 0«gn mcy 6« «TK/»«0 i
0»n
REMRPO
tna Quit
HQ EVALUATION COORDINATOR
tr><3 Out
OSWER DIRECTIVE NO. 9355,1-1
J-1
-------
PAGE 2 of
' 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
OATtS
WORK PLAN APPROV At, OATI
Amwdnwnl
AfM0dfnivvt 2
Afft4AQfflffrVt «
~
TOTAL PLANNED COST
TOTAL ACTUAL COST
VARIANCS
LOC»
Expeisi
COST
SUSCON.
TH ACTING
POOL
COST
•
TOTAL
PLANNED
COST
•
PLANNED
COMPLETION
DATE
Wm
WM
Wm
ACTUAL
COMPLETION
DATE
i
t
fite
t^
^^
OSWER DIRECTIVE NO. 9355.1-1
MMI >C«(t
J-2
-------
PAGE 3 of 3
I
EPA WORK ASSIGNMENT COMPLETION REPORT (WACR)
CONTRACT NO. ' WORK ASSIGNMENT NO. EPA REGION
PQtFORMAMCI OUTWIA RATING WORKSHEET
PERFORMANCE CRITERIA
pROJECTKANNwio
. ORGANIZING H.G.. WORK IAN
DEVELOPMENT. DATA REVIEW!
- SCHEDULING
-BUDGETING
TICHNICAL COMPTTINCI ft MNOVATION
. CfftCnVENESS OK ANALYSES
. MCET PVAN GOALS
- AOHtm TO HCGS. * MocsouRfS
- APPROACH CRiATIVlTV/INGINUITir
. SUPPORT COL STATt. INWRCSMtNT
- fxrwrr TOTIMONV
SCMtOULf ft COST CONTROL
- 8UOGIT (HOURS ft COST1 MAMTINAMCS
. MIORITY'SCHCOUU AOJUSTMOfTS
- COST MINIMIZATION
WORT1NG
- TIMCLINISS Of> OCJVCRAtUS
- CLARITV
. THOROUGH*! SS
)
RtSOURCI UT1UZATION
- STAFFING
- SUBCONTRACTING
- EQUIPMENT. TRAVEL. ETC
6WJRT
- RESPONSIVENESS
- MOBILIZATION
- OAV.rO.QAV
- SPECIAL SITUATIONS (E.G.. ADVERSE/
DANGEROUS CONDITIONS!
RATMG
1
A
a
^
y
,—^—.1
*
____—.*
*
9
9
1
*
1
y
'•
a
V
SUWORTTNG COMMENTS
. j
(
I
i
t
-Ql.
OSWER DIRECTIVE NO. 9355.1-1
J-3
-------
Example
OSWEBOIRECTWE NO. 9355.1-1
J-*
-------
APPENDIX K
Sample Work Assignment and Interagency Agreements
OSWER DIRECTIVE NO. 9355.1-1
-------
OSWER DIRECTIVE NO. 9355.1-1
-------
Mr. William-Mulligan
0.3. Army Corp* of Engineers .
Engineering Division* Missouri River
V. O. Box 103, Downtown Station ,
Omaha, Nebraska 68101-0103
De«r Mr. Mulligans
This letter serves to initiate a work assignment for the 0. S. Army Corps
of Engineers (USACZ) to select an architectural/engineering firm to design the
remedial action at the following superfund sites
The selected activities must be consistent with the Interagency Agreement
No. DW96**«***-01-0 between the OSACZ and the Environmental Protection Agency
(EVA). Funding for costs incurred while providing these services to EPA,
authorized under the authority of the Comprehensive Environmental Response/
Compensation and Liability Act of I960 (CBRCLA), is not expected to exceeds
Enclosed is the Phase I Design Authorization Fora. 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
ees Richard Rune
Noel Urban
Paul Nadaau
Xvery Jacobs
OSWER DIRECTIVE NO. 9355.1-1
N* 1
-------
AUTHORIZATION FORM FOR PHASE I DESICT
AOTHORIZATIOH IS HEREBY GIVEH TO INITIATE THE FIRST PHASE OF DESIGN
WORK AS DESCRIBEDllM IA<3 » DW96930«**-01-0. TH8 FOLLOWING INFORMATION
IS PROVIDED FOR COST TRACKING PURPOSES:
SITE HAKE •:...
REGIOH . i
EPA SITE 1.0. t
HQ TECHNICAL PROJECT OFFICER
REGIONAL SITS MANAGER
PERIOD OP PERFORMANCE
PHOMB
PHONE
FROH
TO
ACCOUNTING INFORMATION
.
DEOBLIGATE FROM:
OBLIGATE TO:
I
1
DOCUMENT 1
CONTROL HO. \
W
W
TAG HO.
1
I
1
1 01
SUPERFUNu | «
! ACCOUNT HO. 1 Ct
OISITIFIAIM*
Ol5lT|F|Al*l«
•INIOIOUIS
*|N|*|*|2I5
• .
user
-ASS
TOE
7
7
6
6
-
NC
ES
si«l«
$!•!-•
(Titl*)
DATE
EPA PROJECT OFFICER
DATE
(individual who certifies funda)
DATS
Original tot Richard Ruh«, EVA
Cincinnati* OB
ce:
William Mulligan, USAGE
Ho«l Urban, USAGE
Paul Nadaau, EVA
rr«ry J»cob«.. BVA, too. 3623M OSWER DIRECTIVE NO. 9355.1-1
Financial Reports and Analysis Branch
K-2
-------
US ENVIRONMENTAL PROTECTION AC£NCY
WASHINGTON. OC 20*«0
INTEflAGENCY AGREEMENT/AMENDMENT
Part 1 — GENERAL INFORMATION
3. Namo «nd Adorns of EPA Organisation
*
7. Proioct Title
Firsc Phase Design Work - FT. 1985
8. EPA Project 0«icsr Warn*. A4&9**. r«/«p/M/M Numttrt
*
ia Proiect Period
10/01/84 - 09/30/85
1 . IAG Identification Numeor 2. Punaing uxai;on or -
3. Type of Action 4. Program Aoer*«iatio
New Agreement *
6. Name ana Address of Otnar Aaencv
Department of Defense
U.S. Array Corps of Engineers (USAGE)
Engineering Division, Missouri River
Omaha, Nebraska 68101-0103
• • .
9. Otner Agency Protect Officer INtm*. Aadrtss, Ttttofion* Nvmotri
William Mulligan FT3/864-7227
USAGE, Engineering Di vision, Missouri River
P. 0. Box 103, Downtown Station
Omaha, Nebraska 68101-0103
11.Budo.«Ptfiod
10/01/84 - 09/30/85
12. Scao* of Wort lAiracft •dMuoru/ inmut. u /i««dM/
This agreement obligates no more than $ • and generally no more than $7,000 per
project to the USAGE to initiate the selection of Architectural/Engineering firms for
the engineering design phase of Federal lead remedial action projects* The USAGE will
perform all action necessary to retain an.A/E firm for engineering design, including
the following:
Phase I -
Synopsize requirement ia Commerce Business Daily
Designate A/E pre-selection and selection boards
Develop A/E pre-selection list
Contact A/E firms to ascertain interest in project
Approve A/E selection list
Tentatively select A/E firm
1 3. Statutory AwiDonty for bom Transfer orf funds and Project ActtvtiMS
CERCLAT 2.0. 12316 & the Economy Act of 1932, as amended (31USC1535)
FUNDS
IS. EPA Amount
16. EPA In-Kind Amount
17. C'ti«r Aqancv Amount
18. Otnar Aqancv In-Kind Amount
19. Total Protect Con
PREVIOUS AMOUNT
AMOUNT THIS ACTION
*
*
14. Qtn«r Aoancy TYE
Federal
AMENOEO TOTAL
20. fiscal information
Prooram Elamani
TFAY9A
FY
85
Appropriation
68/20X8145
Ooc Control No.
*
Account Numoor I Ob|«aa«u
* 25.76
OSWER DIRECTIVE
1
Obligation/ 0 •0011941
*
1O.9355. 1-1
EPA Form 1«1O-1 (Row. 8>«A) Prmous adraons aro ooso
K-3
-------
PART II - APPROVED BUDGET
IV ludpat Citaqonaa
Tout Uamisation 9*
_f«imatad Can to Oata
jat Kanonnot
jttl EfinOO
lei Tfi
Suooiiaa
in Proeuramant/Aaaiitanea
imQtnar
Jil Total j
tQiaron
S Breakdown noc available
mil b< provided as par*
(klTaa*
(g»A Snara 100%l lOtnar Aq«ncv Snara 0
r«qu«st for rvimburseme:
*
a. la aawomam autnoroad to oa fumianad fty tFA or acqwrad wnn
33.
Contactor/ftMtpwm Nam* W toa»»i
Toiai Extramural Amount Unoar
by EP* /// *nown;
f MT IB — PfcYMENT MCTHQOS ANQ 8IUUNG INSTHUCHONS
24. BS OianunMrnam Ayaomanc
Koimttunamam
Madwaat for roimbunamant of actual coat* will 90 itammd on SP 1081 or SF 1080 ind
tuommaatotna Ananeal ManaoamamOlnca. Emnronmvntat r>rotact>on Aqancy. 26 Watt St.
Oa». Oncwnati. (
a
Uoon Cameictton ol Work
Q Allocation
Transfor
Onh> avaiiaol*
-------
PART IV - ACCEPTANCE CONDITIONS
2ft. G«fl«r«l Condition*:
Tha other agancy covenants and agrees that it will axpeditiousiy initial* and complete the project work for
which funds have been awarded under this agreement.
27. SowMi'Conditians: ''•',.'"
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 (57,000) and/or changes
to the scop* of work*
The USAGE will initiate Phasa I actions upon receipt of EPA authorization. Phase II
actions will not begin until EPA has notified the USAGE of the selection and approval
of a remedy and EPA approval of an Interagency Agreement for Phase* II actions.
EPA acting as manager of Che Hazardous Substance Response Trust Fund, requires current
Information on CZRCLA response actions and related obligations of CEfcCLA funds for
these actions. In addition, CEKCLA authorizes EPA to recover from responsible parties
all government costs incurred during a response action.
(See Attachment A)
- Off<* AND ACClPTANCt
NOTE: 1) For disbursement actions, the agreement/amendment must be signed in duplicate and one origin
returned to the Grants Administration Division for Headquarters agreements and to the appropria
EPA IAG administration office for Regional agreements within 3 calendar weeks after receipt or with
any extension of time as may be granted by EPA. The agreement/ amendment must be forwarded
the address cited in Item 28 after accaptanca signature.
Receipt of a written refusal or failure to return the property executed document within the prescribe
time may result in the withdrawal of the off ar by tha Agency. Any change to the agreement by the oth<
agency subsequent to the document being signed by the EPA Action Official which the Action Off 5c
determines to materially altar tha agreement/amendment shall void tha agreement
amendment.
2) For reimbursement actions, tha other agency will initiate tha action and forward two origin.
agreements/amendments to tha appropriate EPA program offica for signature. Th* agreements
amendments will then be forwarded to the appropriate EPA IAG administration office for accsptanc
signature on behalf of tha Environmental Protection Agency. One original copy will be returned to tt'-
other agency after accaptanca.
EPA UMJ MtnwM&nion Ottiev »v MfnuMWMiM/ffiMMOifflMi MJUWKM
21. Orpn«Mn/Aott
-------
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 v
Any other costs not included in the above categories .
In order to assist in the development and prosecution of a cost recovery £-
Department of Oustice (000), the USAGE will provide to EPA or 000 b%:\
site-specific costs and copies of the back-up documentation which supports
those costs. EPA and 000 may periodically request updates of the costs and
documentation after the initial request. The USAGE 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. ;
USAGE will provide access to its files concerning the project on an
on-going basis for EPA and 000 examination to assist in cost recovery. As
original documents may be requested for cost recovery actions, USAGE will
provide EPA and 000 access to the original documentation when requested.
USAGE 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 USAGE will provide a letter report summarizing each A/E selection to
the Regional Technical Project Officer.
OSWER DIRECTIVE NO. 9355.1-1
K-6
-------
BIBLIOGRAPHY
STATUTES
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), 42 U.S.C. Sections 9601-9657, PL 96-510. .
Resource Conservation and Recovery Act of 1976 (RCRA), 42 U.S.C. Sections 6901-
6991 i, PL 94-580 (amended Nov. 8, 1984).
REGULATIONS
EPA Order 1440.1, Respiratory Protection.
EPA Order 1440.2, Health and Safety Requirements for Employees Engaged in Field
Activities.
Evaluation. Review, and Coordination of Federal and Federally-Assisted Programs
and Projects. OMB Circular A-95.
Executive Order 11988, "Ftoodplains Management".
Executive Order 12372, •intergovernmental Review of Federal Programs" (47 FR
30954), July 16. 1982.
Executive Order 12432, "Development of Minority Business Enterprises," July 14,
1983.
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 EPA Programs and Activities: Procedures to Establish
Comment Period Start Dates for Programs and Activities Subject to Executive Order
12372," (48 FR 44643), September 29, 1983.
National Oil and Hazardous Substances Pollution Contingency Plan (47 FR 31180),
November 20,1985.
National Priorities List Final Rule and Proposed Update (40 CFR Part 300 and 48 FR
40658), September 8, 1983.
"Notice of Supplemental Procedures for Establishing Start Dates of Comment Period
for Activities Subject to Executive Order 12372," (48 FR 54692), EPA,- December 6,
1983.
Public Information: Confidentiality of Business Information (40 CFR Part 2, Subpart B).
EPA DOCUMENTS
§uperfund State-Lead Remedial Project Management Handbook.Draft. OERR,
January 1986.
guidance on Remedial Investigations Under CERCU\. OERR and OWPE, June 1985.
OSWER DIRECTIVE NO. 9355.1-1
-------
BIBLIOGRAPHY
OSWER DIRECTIVE NO. 9355.1-1
-------
Management Tasks. Responsibilities^ Practices. Peter F. Drucker. Harper and Row,
New York, 1974.
Organization and Management. A Systems Approach. F.E. Kast and J.E. Rosenweig.
McGraw Hill, New York, 1970.
3
MEMORANDA
"CERCLA Compliance with Other Environmental Statutes," AA/OSWER, October 2,
1985.
•Candidate Sites for Deletion from the National Priorities List.' OERR, May 24, 1985.
•Procedures for Planning and Implementing Off-Site Response Actions,' AA/OSWER,
May 6,1985.
"FY 1986 Superfund Comprehensive Accomplishments Plan,' AA/OSWER, December
24, 1984.
•Remedial Financial Management Instructions,* AA/OSWER, September 21, 1984.
•FY 1985 Superfund Implementation Plan,' AA/OSWER, August 1984.
•Interim Procedures for Deleting Sites from the National Priorities List,' AA/OSWER,
March 27, 1984.
'Participation of Potentially Responsible Parties in Development of Remedial
Investigations and Feasibility Studies Under CERCLA,' AA/OSWER and AA/OECM,
March 20, 1984.
'Superfund Community Relations Policy,' OSWER, May 9, 1983.
•Suggested Regional Rle Structure, Superfund Priority Sites and Priority Site
Candidates,* OERR, May 1982.
FORMS
Cooperative Agreement (EPA Form 5700-20A)
Financial Status Report (Standard Form 269)
Minority and Women's Business Utilization Report (EPA Form 4720)
Procurement Request/Requisition (EPA Form 1900-8)
MISCELLANEOUS
•Superfund Records of Decision Update*, OERR, Monthly.
Record of Decision Annual Report (DraftV OERR. 1985.
•Procedures for Initiating Remedial Response Services,' Draft, OERR, July 1984.
•REM II and Revised REM/FIT Contract Award Fee Performance Evaluation Plans,"
OERR, July 1984.
OSWER DIRECTIVE NO. 9355.1-1
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Guidance on Feasibility Studies Under CERCLA. OERR and OWPE, June 1985.
Guidelines apd Specifications for Preparing Quality Assurance Project Plans for
National Program Offices: Quality Assurance Management Staff, May 10,1985.
Preparation of Decision Documents for Approving Fund-Financed and Potentially
Responsible Party Remedial "Actions Un'der CERCLA. OERR, February 2, 1985.
Sunerfund Remedial Design and Remedial Action Guidance. OERR, February 1985.
User's Quids to the EPA Contract Laboratory Program. OERR, July 1984.
State Participation in the Superfund Remedial Program. QERR. February 1984.
Intergovernmental Review of Superfund State. Federal, and Enforcement Lead
Remedial Projects. OERR, November 30,1983.
Community Relations in Superfund; A Handbook, OSWER, January 1983.
Cost Recovery Actions Under the Comprehensive Environmental Response.
Compensation, and Liability Act of 1980 (CERCLA). OEC and OSWER, August 26,
1983.
REM/P1T Zone Contract Management Procedures: An Illustrated Guide. OERR, April
1983.
Model Statement of Work for Remedial Investigations and Feasibility Studies. OERR,
March 1,1983.
Management Plan and Operating Procedures: Remedial Planning/Field Investigation^
Team Contracts. Q£RR. October 1982.
EPA Interim Standard Operating Safety Guides. Revised, November 1984.
National Enforcement Investigation Center (NEIC) Policies and procedures Manual.
NEIC, May 1978 (Revised February 1983).
PROJECT MANAGEMENT DOCUMENTS
Project Management Handbook, ed. David I. CJeland and William R.
King. Van Nostrand Reinhold Company, New York, 1983.
Systerns Analysis and Project Management. David I. Cleland and William R. King.
McGraw Hill, New York, 1983.
Project Management for the Design Professional. David Burstein and Frank
Stasiowski. Whitney Library of Design, 1982.
What Every Engineer Should Know About Project Management. A.M. Ruskin and W.E.
Estes. Marcel Dekker, 1982.
The lmplem,enfotlon of Project Management. The Professional's Handbook.. Linn C.
Struckenbruck. Addison Wesley Inc., 1981.
Great Planning Disasters. P. Hall. Weidenfeld and Nicholson, London, 1980.
Management Decision Methods for Managers of Engineering and Research. W.E.
Souder. Van Nostrand Reinhold Company, New York, 1980.
OSWER DIRECTIVE NO. 9355.1-1
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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 focal 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.
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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 which 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.
,_2 OSWER DIRECTIVE NO. 9355.1-1
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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 NCP. 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 the AA.
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].
Note: This section should summarize only the information related to the proposed
remedy. ;
OSWER DIRECTIVE NO. 9355.1-1
I-3
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„
[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,
technical and community considerations (see samples in
Summary of Remedial Alternative Selections).]
Note: This section will be presented by the Region.
NEXT STEPS
[Describe:]
Action Date
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.
OSWEH DIRECTIVE NO. 9355.1-1
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