&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER:
Technical Assistance Team (TAT) Contract
TITLE:
Users's Manual - Update Paqes
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
^ FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OSWER Directive 9242.4-1
June 10, 1986
Immediately
OERR / ERD
OSWER OSWER OSWER
rE DIRECTIVE DIRECTIVE Dl
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£EPA
United States Environmental Protection Agency
Washington. DC 20460
OSWER Directive Initiation Request
Interim Directive Number
.4-1a
Originator Information
Name of Contact Person
James Jowett
Mail Code
WH 548-B
Telephone Number
382-2205
Lead Office
OERR
D OSW
D OUST
D OWPE
D AA-OSWER
Approved for Review
Signature of Office Director
Date
Title
Revisions to TAT Contract Users' Manual
Summary of Directive
Provides revision pages for the Technical Assistance Team (TAT) Contract Users
Manual, Directive 9242.4-1. Manual explains the nature of TAT contract resources;
responsibilities and authorities of EPA personnel, policies and procedures for
operating under this contract, and a means to evaluate, and compensate contractor
performance. (6/10/86, 55 pp)
Keywords: Removal program, removal action, contracts, TAT contract,
TAT operations
Signed by: Timothy Fields, Jr., Director, ERD
Type of Directive (Manuel. Policy Directive. Announcement, etc.)
Directive (Procedures)
Status
Draft
Final
New
LJ Revision
Does thts Directive Supersede Previous Directives)? fl Yes X^l No Does It Supplement Previous Directive(s)?
If "Yes" to Either Question, What Directive (number, title)
9242.4-1 Technical Assistance Team (TAT) Contract Users Manual
Review Plan
Q AA-OSWER D OUST ' D OECM
D OERR D OWPE D OGC
D OSW D Regions D OPPE
Other (Specify)
This Request Meets OSWER Directives System Format
Signature of Lead Office Directive^ Officer
Date
Signature of OSWER Directives fifficer
Date
EPA Form 1316-17 (10-86)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUN J o 1995
OSWER Directive #9242.4-la
OFFICE OF
SOLID WASTE AMD EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Revisions to the TAT Contract Users' Manual
FROM: Timothy Fields, Jr., Director
Emergency Response Division
TO: Addressees:
The attached revised sections of the Technical Assistance Team (TAT)
Contract Users' Manual have been prepared to update and modify information
on the scope and provisions of the "Technical Assistance Team (TAT) for
Emergency Response, Removal and Prevention" Contract. These sections
update and modify the requirements, procedures and responsibilities
associated with implementing and managing the contract. They have been
provided to improve the usefulness of the users' manual by presenting
additional information that was not included in the original manual.
Revisions to the manual are based on information and suggestions
provided by several sources including the EPA headquarters TAT Project
Officer and Contracting Officer, EPA's Superfund Property Administrator,
several TAT Deputy Project Officers, and the TAT Contractor National
Program Manager. Also, the results of several Regional TAT contract
management reviews, conducted during 1984 and 1985, served as an important
source of revisions and improvements, particularly in regard to contract
management requirements and procedures.
At this time, with plans for a completely revised manual to coincide
with the award of the new TAT contract, we decided to make only substantive
revisions or additions to the current manual. Following are the instructions
for updating your manuals:
Chapter I - Delete pages 1-8 through 1-11
Replace with new pages 1-8 through 1-16
Chapter IV - Delete in its entirety
Replace with new pages IV-1 through IV-16
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OSWER Directive #9242.4-la
Chapter V - Delete section on Management Information
Systems, V-4 through V-6
Replace with new pages V-4 through V-6
Chapter VI - Delete page VI-8
Replace with new page VI-8
Appendix D - Add new Appendix
Appendix E - Add new Appendix
This memorandum should be filed in the front of the TAT manual. Should
you have any questions, comments or suggestions on these revisions or on
the manual in general, please contact Jaiies Jowett, TAT Project Officer,
at (FTS) 382-2205.
Addressees:
Removal Program Division Directors
Superfund Removal Branch Chiefs
Deputy Project Officers
On-Scene Coordinators
OERR Division Directors
Attachment
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REVISIONS TO TAT MANUAL
TOPIC
INSTRUCTION
LOCATION/PAGE
Chapter I
Personal versus
Nonpecsonal services
Contract Equipment
Property Management
Health and Safety
Quality Assurance
Requirements (QA)
Contractor identification
Confidentiality of
Information
Conflict of Interest
Chain-of-Custody and
Document Control Procedures
Training Program
for Contractor
Personnel
Cost Management Support
24-hour, 7-Day-A-Week
Call Center
New Section
Delete original section
Replace with new section
New Section
Delete original section
Replace with new section
Delete original section
Replace with new section
Delete original section
Replace with new section
Delete original section
Replace with new section
Delete original section
Replace with new section
Delete original section
Replace with new section
Delete original section
Replace with new section
Delete original section
(Cost Control Support)
Replace with new section
Delete original section
Replace with new section
1-8
(1-8)
1-9
1-10
(1-8)
1-12
(1-9)
1-12
(1-9)
1-13
d-9)
1-13
(1-10)
1-14
(1-10)
1-14
(1-11)
1-15
d-11)
1-17
(1-11)
1-18
Chapter IV
Delete entire chapter
Replace with new chapter
See new Chapter IV title
page for location of
sections.
IV-1 - IV-15
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REVISIONS TO TAT MANUAL
TOPIC INSTRUCTION LOCATION/PAGE
Chapter V
Management Information Delete original section (V-4 - V-6)
Systems
Regional Proaect New section V-4
Performance Tracking
Regional TAT Contractor New Section V-4 - V-5
Office Reviews
Suggested Format for New Exhibit V-6
TDD Status Tracking Log
Chapter VI
Note: Revisions are to the October 1, 1983, version distributed to
Regional, ERT, and Headquarters personnel.
Preparation of Award Fee Delete page VI-8
Performance Observation Replace page VI-8
Reports
Appendix D
Example Forms for TAT New Appendix Appendix D
Contract Management:
TDDs, AOCs, PORs
Appendix E
DPO Checklist for New Appendix Appendix E
Reviewing TAT
Contractor's
Office
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April 7, 1986
9242.4-la
(4) Personal versus Nonpersonal Services
The service contract for the thirteen TATs pro-
vides for nonpersonal services. In general, contract
services can be classified as either personal or non-
personal. With a nonpersonal services contract such
as the TAT contract, the TATs provide an approved re-
source for EPA in the accomplishment of their programs
while avoiding an actual employee-employer relation-
ship. Personal services contracts are those where the
contractor or their employees seemingly act as employ-
ees of EPA, where EPA maintains the right to direct,
supervise, or define the work to be performed, or the
manner of performance, on a day-to-day basis. Per-
sonal services are not provided by the TAT contract.
The following examples of personal and nonper-
sonal services are provided for illustrative purposes
only.
Personal. The following are examples of
personal services:
Contract for the furnishing of ordin-
ary, day-to-day stenographic and secre-
tarial services in a Government office
under Government supervision exercised
either directly or through a contractor
supervisor, even if only for a peak
work period of two weeks;
Contract for preparation of a staff
type report on the operation of a par-
ticular Government office or installa-
tion, where no specialized skills are
required and the report would ordinar-
ily be prepared by the regular officers
or employees of the office or installa-
tion even if there is to be no Govern-
ment supervision and even if payment is
to be for an "end product" report;
Contract for the furnishing of persons
to perform the various day-to-day func-
tions of contract administration for a
Government agency, even if there is no
Government supervison (e.g., directing
the ERCS contractor).
Nonpersonal. The following are examples of
nonpersonal services:
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9242.4-la
Contract for field engineering work
requiring specialized equipment and
trained personnel unavailable to the
Government but not involving the exer-
cise of discretion on behalf of the
Government, where the contractor per-
forms work adequately described in the
contract, free of Government supervison;
Contract with an individual for deliv-
ery of lectures without Government
supervision, at specific places, on
specific dates, and on a specialized
subject, even if payment is by the hour.
Research and development contract, pro-
viding a fixed price for a level of
effort, as long as the work is per-
formed by the contractor independently
of Government direction, supervision,
and control.
It is recognized that during the course of a response
the distinction between providing personal and non-
personal services may be unclear. For example,
directing the ERCS contractor is not the responsibil-
ity of the TAT contractor, however, monitoring their
performance is acceptable. Should questionable situa-
tions arise that require interpretation, the OSC or
the TAT member should confer with the TAT DPO or
Leader, respectively. If further clarification or
interpretation is necessary the TAT National Program
Management Office (NPMO), TAT PO, or TAT CO may be
contacted.
(5) Contract Equipment
In order to perform the diverse tasks required
under the TAT contract, each TAT will be furnished
equipment for monitoring, safety and record-keeping.
Appendix B contains a detailed listing of the equip-
ment to be provided by either the Federal government
or through TAT contract resources. The TAT Leader is
responsible for the maintenance of all equipment and
ensuring disposable equipment inventories are main-
tained and replenished as required. Should the TAT
Leader determine that certain equipment is not being
utilized, he/she should inform the TAT National Pro-
gram Manager (NPM) of the equipment available for use
in other TAT offices.
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9242.4-la
If new equipment requirements are identified as
EPA missions change, the EPA DPO may request this new
equipment by sending a written request for its pur-
chase to the EPA PO. This request should include jus-
tification of the needs, estimated cost and recom-
mended source. EPA may either provide the required
equipment to the contractor or authorize the con-
tractor to acquire it under the TAT contract.
(6) Property Management
The use of property provided either directly by
the Federal government or procured through the TAT
contract requires careful management. Not only is
careful property management required by Federal law
and the TAT contract, it is essential for efficient
use of contract resources. For example, accurate
property inventories allow the TAT contractor manage-
ment to distribute equipment among the Regional
offices in the most useful way.
In light of the importance of property manage-
ment, the TAT contractor is required to provide train-
ing in property management for TAT property management
officers at the NPMO and in the Regions. The TAT must
also develop and use standard operating procedures for
all aspects of property management. The DPO should
ensure that the TAT properly manages Government
property.
At the NPMO level, the TAT property management
officer should receive training or be qualified in the
following areas:
Basic elements of property management
(acquisition, inventory, records, mainten-
ance, etc.)
Government property administration
Personal property use and disposal
Federal contract law
Contract administration
Automated data management systems.
At the regional level, the TAT property management
officer is responsible for all property in that
region. The NPMO must train the regional property
management officers in the basic elements of property
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April 7, 1986
9242.4-la
management. Similarily, the NPMO must train TAT per-
sonnel in the use of TAT contract standard operating
procedures as they pertain to property management.
Both the TAT contract and Federal regulations
(Federal Acquisition Regulation, Part 45) require
written standard operating procedures for property
management. The TAT must provide standard procedures
in the following areas:
Acquisition
Receiving
Record keeping
Storage, movement and protection
Loss, damage and destruction
Utilization
Maintenance and calibration
Inventory
Subcontractor use
Contract closure and equipment disposition.
Development and use of these procedures is essential
for managing property under the TAT Contract.
Standard procedures will also aid in preparing
the periodic reports requested to the EPA Property
Administrator. To ensure proper handling of govern-
ment property, the EPA Property Administrator requires
the following information from TAT property management
officers:
Annual inventory of property
Loss, damage or destruction of government
property (immediately)
Requests for purchase or replacement of
government property (as needed)
Government property in excess of needs
(semi-annually)
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9242.4-la
Justification for retention of low use items
(annually)
Certification of required training of prop-
erty management officers (annually).
In addition, all other reports required by the "Guide for
Control of Government Property by Contractors" should be
submitted as required. This guide is available from the
EPA Property Administrator and should be consulted when
questions arise regarding the management of government
property.
3. CONTRACTOR REQUIREMENTS IN EXECUTING SOW ACTIVITIES
(1) Health and Safety
As identified in section 300.38 of the National
Oil and Hazardous Substance Contingency Plan (40 CFR
300), the OSC must ensure on-site worker health and
safety during a response incident. The OSC health and
safety responsibilities include:
Cognizance of potential threats to human
health and safety
Application of proper precautions, proce-
dures, equipment and training
Application of all appropriate Occupational
Safety and Health Administration (OSHA) re-
quirements and other guidance
Notification to all TAT personnel of any
known dangers associated with a particular
task.
The TAT contractor will conduct on-site opera-
tions under the guidelines of a company health and
safety program provided that the program at least com-
plies with the Federally mandated requirements.
Standards that exceed those mandated by the Federal
government can be required by the contractor, however,
the DPO or OSC should contact the PO if requirements
for a particular task appear to be excessive.
(2) Quality Assurance Requirements (QA)
The TAT contractor shall institute a quality as-
surance program which will ensure that environmental
monitoring data of known quality are provided. The
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April 7, 1986
9242.4-la
program will consist of both an auditing and a cor-
rective function. The auditors will report directly
to the contractor corporate management, bypassing the
contractor NPM, to minimize any actual or perceived
bias. Corporate management will then be expected to
utilize the firm's resources to solve any problems
uncovered. The EPA publication entitled "Interim
Guidelines and Specifications for Preparing Quality
Assurance Program Plans" (QAMS-005/BO) contains de-
tailed information on EPA's quality assurance program
and can be obtained from the Assistant Administrator
for Research and Development in the Office of Moni-
toring Systems and Quality Assurance.
(3) Contractor Identification
All TAT personnel must properly identify them-
selves as corporate employees under contract to the
EPA when conducting any contract related activities.
Two forms of identification are available for in-
person activities:
EPA authorized letter of introduction,
photograph and descriptive identification
(includes Regional Administrator's signature
and the expiration date on EPA letterhead.)
Laminated corporate/EPA photo credential
(includes signature of TAT member and the
PO.)
In addition, EPA headquarters and regions may
issue building passes which permit TAT members rea-
sonable access to EPA offices. These passes should
only be used to enter the EPA facility for which they
have been issued and are not intended to be a means of
identification for other contract related activities.
(4) Confidentiality of Information
During the performance of the contract, TAT mem-
bers may, by necessity, be entrusted with confidential
information. All information received by EPA is sub-
ject to EPA's disclosure of information policy, 40 CFR
Part 2, which is based on the Freedom of Information
Act, 5 U.S.C. 552, and provisions for patents and
rights as set forth by law. Generally, information is
not confidential. However, if a TAT member should
have access to information granted confidentiality by
EPA, all TAT members shall follow Agency procedures
set forth in 40 CFR Part 2 safeguarding such
information.
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April 7, 1986
9242.4-la
In response to an initial submission of informa-
tion with a request of confidentiality from a respon-
sible party, private industry or any person or busi-
ness, all EPA personnel and contractor employees
should be aware of the proper procedures. All infor-
mation requested by EPA for which a confidentiality
claim is asserted must be submitted to the regional
EPA office or EPA headquarters. Any person submitting
information to EPA may assert a business confidential-
ity claim by covering or placing on the information,
at the time of submission to EPA, a cover sheet,
stamped or typed legend, or other form of notice with
language such as "TRADE SECRET," PROPRIETARY," or
"COMPANY CONFIDENTIAL." The EPA office handling the
information will make the initial determinations of
whether the information is entitled to confidential
treatment. Procedures for the validity of confiden-
tiality claims and special rules governing certain
information obtained under specific legislation, such
as the Clean Water Act (CWA), are set forth in 40 CFR
Part 2, Subpart B,
Provisions for rights in data and copyrights and
patents are complex and will not be discussed here.
If the question of rights with these issues should
arise, the EPA regional counsel should be contacted to
pursue the proper legal course.
(5) Conflict of Interest
All TAT contract personnel must comply with the
EPA rules on general conflict of interest to ensure
that negotiated contracts are awarded in good faith
and are not based on improper influence or favori-
tism. A conflict may arise when the contractor has
"interests which may diminish his capacity to give
impartial, technically sound, objective assistance and
advice or may otherwise result in a biased work prod-
uct or an unfair competitive advantage." The DPO
should be sensitive to potential conflicts of interest
when assigning TAT tasks.
(6) Chain-of-Custody and Document Control
Procedures
Any work conducted by the TAT contractor must
follow established chain-of-custody and document con-
trol procedures. Detailed information pertaining to
procedures for each of these subjects is available in
NEIC Policies and Procedures, U.S. Environmental Pro-
tection Agency, National Enforcement Investigations
Center (NEIC), Denver, Colorado, revised February
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April 7, 1986
9242.4-la
1983, EPA-330/9/78/001-R. Copies of this document
should be obtained by all regional offices and be dis-
tributed to the TAT contractor's offices as well. The
document will serve as the official EPA guidance for
ensuring that the procedures are followed. In addi-
tion, regions may establish their own specific proce-
dures for ensuring that the NEIC chain-of-custody and
document control requirements are met.
The DPO together with a representative from the
regional enforcement office will be responsible for
ensuring that the contractor adheres to both the
chain-of-custody and document control procedures.
Periodically, adherence to the provisions will be
evaluated by an evidence audit. The evidence audit
may be conducted by regional or headquarters person-
nel, or by a Contractor Evidence Audit Team (CEAT)
from the NEIC. Evidence audits may examine procedures
at the site, in the contractor offices, laboratories,
regional offices, or combinations thereof.
(7) Training Program for Contractor Personnel
The TAT contractor is responsible for developing
and implementing a training program for contractor
personnel in skills required for responding to emer-
gencies resulting from the release or potential re-
lease of oil and/or hazardous substances. The TAT
contractor must develop an aggressive training program
designed to meet or exceed the standard practices of
OSHA and other Federal and State agency regulations.
This includes conformance with the Hazard Communica-
tion Regulation (29 CFR 1900.1200).
There are two aspects of training which must be
addressed in this training plan. These are Health and
Safety and Technical Skills Training.
Health and Safety - All new TAT employees
must complete a Health and Safety Indoc-
trination Training Course prior to field
assignment. This course, which must be
developed and constantly updated by the
NPMO, is a refined version of the EPA-ERT
Hazardous Materials Response Operations
Course. Successful completion of this
training should be a condition of employ-
ment. These courses should be presented
monthly at the NPMO.
The NPMO also must develop appropriate
specialty skills training such as Level "A"
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9242.4-la
training and health and safety skills main-
tenance training in the form of a Refresher
Training Course which should be presented
annually. These specialty courses may be
packaged to be taken to the region.
Regional TAT Offices should bridge the gap
between Indoctrination, Special Skills and
Refresher Training. Regional Safety Offi-
cers (RSOs) and TAT Leaders are primarily
responsible for the second phase of training
and interim skills maintenance training.
This should be accomplished by formally re-
viewing all Indoctrination topics with new
employees using RSOs and experienced TATs.
This should include at a minimum an addi-
tional 24 hours of training and use of
self-contained breathing apparatus for at
least 1/2 hour each month. New employees
must not go onto hazardous materials sites
without an experienced TAT_until the RSO is
satisfied training is complete. This on-
the-job training may extend for several
months.
In addition, regional offices should provide
or arrange for training in CPR, Multi-Media
First Aid and Defensive Driving training.
With the NPMO's assistance, regional TATs
should also take as much advantage as
possible of opportunities to attend the
EPA-ERT Courses related to safety in re-
sponse such as:
Response Operations
Personnel Protection and Safety
Site Assessment
Safety Decision Making
First Responders
Air Surveillance
The NPMO should also institute a monthly
conference call with RSOs as a means of ex-
changing health and safety technology and
monitoring regional training efforts.
Regional TATs are responsible for holding
monthly safety meetings.
Technical Skills - Another very important
aspect of training serves as a mechanism for
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9242.4-la
adding to, updating and maintaining techni-
cal skills. The NPMO should develop train-
ing courses for the following technical
skills:
National Contingency Plan (NCP)
TAT Contract Indoctrination
Cost Monitoring for CERCLA Sites
ERCS Contractor Monitoring
Micro-processor Use
Performance Observation Report (POR)
Preparation
Community Relations
Groundwater Modeling
Sampling and QA
Spill Prevention, Control and
Countermeasure (SPCC) inspections
Resource Conservation and Recovery
(RCRA)
The NPMO should also use the mechanisms of
conference calls for technology exchange.
The following topics have been addressed:
Geophysical Monitoring
Groundwater Modeling
Laboratory Selection and Quality
Assurance of Laboratory Data
TAT regional offices should be encouraged to
develop in-house Technical Training to main-
tain Technical skills such as use of compu-
terized data bases, the Chemical Information
System and the Occupational Health Services
Hazardline system.
TAT regions are also provided funding to
take advantage of EPA-ERT courses such as:
Air Surveillance
Hazardous Material Sampling.
(8) Cost Management Support
During removal actions, the TATs may assist the
EPA OSC in implementing a comprehensive system for
managing the site operations and effectively moni-
toring the costs. This management system must ensure
the efficient use of public funds and enable all re-
moval costs to be measured against the program and
statutory ceilings. The system recommended for use by
the OSCs is presented in the Removal Cost Management
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April 7, 1986
9242.4-la
Manual, January 1985. This manual outlines a compre-
hensive cost management system that requires specific
on-scene cost data to be documented while offering
flexibility to the OSC in documentation techniques.
The TATs, in assisting the OSC in tracking removal
costs, should have a working knowledge of the prac-
tices outlined in this manual. Additional guidance on
the TAT's role in site cost tracking and verification
will be provided in the future.
(9) 24 Hour, 7-Day-A-Week Call Center
The TAT contractor is responsible for operating a
24-hour, 7-day-a-week call center. This call center
will provide EPA with access to TAT technical support
services at all times and may also be used to receive
initial spill notification information from the
National Response Center or the public.
The remainder of the document highlights the manage-
ment framework and procedures to be followed by EPA DPOs,
OSCs, and TAT contractors personnel for initiating ser-
vices, project monitoring, and reporting, and performance
evaluation.
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April 7, 1986
9242.4-la
CHAPTER IV
WORK ORDER PREPARATION AND PROCESSING
KEY TOPICS
Page
Procedure for Initiating and Managing TAT
Activities IV-1
Technical Direction Document (TDD) Elements IV-2
Preparing and Processing TDDs IV-6
TDD Amdendments IV-9
Special Projects: Contractor Work Plans IV-9
TDD Acknowledgement of Completion IV-10
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9242.4-la
CHAPTER IV
WORK ORDER PREPARATION AND PROCESSING
1. INTRODUCTION
The performance of various tasks and activities by the
TAT contractor will be initiated through the issuance of
written work orders by EPA.* The work orders will be com-
patible with overall TAT program goals and objectives.
The purpose of this chapter is to define procedures for
processing work orders and provide guidance on the content
and format to be used.
The four major categories of services to be provided
by the TAT contractor include:
Routine Tasks -- Prevention Program
Routine Tasks — Response Program
Emergency Response Tasks — Response Program
Special Projects.
Detailed descriptions of tasks and activities for each of
the categories are presented in the SOW contained in Ap-
pendix A. Below, the method of tasking work (i.e., the
Technical Direction Document [TDD]) to be performed by the
TAT contractor, and processing procedures, including in-
terrelationships between EPA and the TAT contractor, are
identified.
2. PROCEDURE FOR INITIATING AND MANAGING TAT ACTIVITIES
The principal objective of the TDD is to provide the
TAT contractor with available background data on the proj-
ect, a clearly defined scope of work to be performed, a
schedule of deliverables and other milestones, an agreed
upon resource budget, and a list of progress reporting
requirements. The specific steps and personnel required
to accomplish the defined task, however, are not specified
in the TDD, but are left to be determined by the TAT con-
tractor following receipt of the TDD. The preparation and
issuance of TDDs is outlined on the following pages.
Tasks and activities may also be initiated orally, but
must always be followed by a written TDD within five
(5) working days.
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9242.4-la
(1) Technical Direction Document (TDD) Elements
The preparation of a TDD will be the responsibil-
ity of the DPO. A standard format is used for the TDD
(see Exhibit IV.1>*. Each of the TDD elements, as
explained below, should be completed.
Cost Center (Box 1): This block contains
the number used to designate each TAT.
TDD Number (Box 2): This serial number
identifies the region in which the TDD is
issued, the calendar year and month, and the
sequence number of the TDD issued that
month. For example, the number 2-8510-3 is
interpreted as follows: 2 refers to the TAT
located in Region 2 (Edison, N.J.); £15 re-
fers to the year the TDD is issued; jj) is
the month the TDD is issued; and 3_ indicates
that this is the third TDD issued in the
month of October. (Special Projects are
denoted SI, S2, S3, etc.)
Type (Box 2A); This code describes the type
of response activity undertaken. The code
will be entered by the TATL and is utilized
for TAT contractor data management only.
Priority (Box 3): This box is used to
denote the priority of the request. For
example, the priority should reflect whether
an immediate action is required (high prior-
ity), an action is to be taken within a
definite time period designated in Box 6
(medium priority), or an action is to be
taken within a flexible time period (low
priority).
Source of Funds (Box 4); The source of
funding for the TAT activity (i.e., either
CERCLA, Clean Water Act (CWA) Section 311
or other, e.g., Federal Emergency Management
Agency). Only one source of funds can be
used for each TDD.
See Appendix D for example TDDs
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9242.4-la
EXHIBIT IV-1
1. COST
CENTER:
3. PRIORITY: 4. SOUR
Q HIGH (1) Q CERC
Q MEDIUM (2) D31M2
Q LOW (3) DOTME
0. DESCRIPTIVE TITLE OF T4
TECHNICAL DIRECTION DOCUMENT (TOD)
OHM EMERGENCY RESPONSE AND
SPILL PREVENTION PROGRAM
ROY F. WESTON, INC
2 NO
2A TYPE
CE OF FUNDS. 5. EPA SITE ID 6 COMPLETION 6. REFERENCE
(IF APPLICABLE): OATE INFO.
LM«| . L_ . - . .. - n VB* " "n
) 5A. EPA SITE NAME 7. OVERTII
R (3) ._ . ("B *DBl.KABLE)' H vffi n
ME O ATTACHED
NO a PICK UP
JU(6
•
OA FSTIUATVn COfiTfr
10. SPEOFIC TASK ELEMEN
aa cenuATfp ui>fiB
-------
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April 7, 1986
9242.4-la
EPA Site Identification Number (Box 5):
This number will be supplied by the DPO from
the CERCLA Information System (CERCLIS) (if
not applicable mark the box N/A).
Site Name (Box 5A): EPA site name as speci-
fied in CERCLIS (if not applicable mark the
box N/A).
Completion Date (Box 6): This is the date
specified by the DPO for the TAT contractor
submittal of the completed TDD assignment.
For low priority items, "to be determined
later" can be noted. However, completion
dates must not be left "OPEN".
Overtime Approved (Box 7): The DPO must
specify whether overtime hours incurred by
the TAT contractor are allowable for the
task outlined in the TDD.
Reference Info (Box 8): This item allows
the DPO to provide the TAT contractor with
any reference materials or supplemental in-
formation necessary to expedite TDD comple-
tion. At the same time, accountable control
of such information is maintained.
Descriptive Title of Tasks (Box 9): In this
section, the DPO indicates the following:
The type of support desired
The level of intensity required (the
depth to which certain issues should be
pursued)
Any other pertinent information.
The task description must clearly delineate
the goals and objectives of the activity and
the desired products and/or deliverables.
Ambiguous phrases such as "assist OSC" are
not sufficient. Where no interim task ob-
jectives are present, continuation of the
general task description can be made into
Box 10. Where interim task objectives are
present, continuation of the general task
description should be made on a separate
sheet of paper that can be attached to the
TDD.
IV-4
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April 7, 1986
9242.4-la
Estimated Costs (Box 9A): An estimate of
the total cost including direct labor,
travel, expenses, and subcontracting.
Estimated Hours (Box 9A): The estimate of
the technical labor hours needed to accom-
plish the TDD assignment will be the respon-
sibility of the appropriate DPO. The esti-
mate should be based on best engineering
judgment considering knowledge of the proj-
ect or task requirements, data needs, esti-
mated cost of the project and previous
experience on similar projects.
Specific Task Elements (Box 10): This sec-
tion is to be used to elaborate on the gen-
eral task description and to define interim
task objectives. This section should pro-
vide the TAT Leader with a clear understand-
ing of the objectives, expected results, and
required deliverables and/or reports. If
more space is needed, the continuation of
the description of specific task elements
should be made on a separate sheet of paper
that can be attached to the TDD. It is per-
missible to attach standardized detailed
task descriptions to the TDD for commonly
occurring assignments (e.g., Spill Preven-
tion Control and Countermeasures [SPCC]
inspections).
Interim Deadlines (Box 11): This box is to
be used to denote completion dates for in-
terim task objectives , where applicable,
within the overall task to be performed.
Desired Report Format (Box 12): The DPO
should indicate the type of end product de-
sired for the TDD assignment. Additional
information can be provided in Box 13 or by
attaching additional sheets to the TDD.
Comments (Box 13): This section can be used
for any pertinent items not covered in any
of the above sections.
Signatures and Dates (Boxes 14-17); These
sections are self-explanatory. The TDDs are
to be issued and signed by the DPO and re-
ceived and signed by the contractor TAT
Leader. If the TAT Leader judges the TDD to
IV-5
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April 7, 1986
9242.4-la
be out of scope, or for other reasons un-
acceptable, the appropriate box must be
checked to show the action. This is neces-
sary to bring the matter to the attention of
all concerned project management and the
Contracting Officer (CO). An appropriate
explanation can be noted on the right-hand
margin of the form.
Descriptor (Box 18): This box is completed
by the TAT contractor and is used for TAT
contractors internal accounting purposes.
Distribution: Distribution of the TDD will
be indicated at the bottom of the form.
Copies of the TDD will be distributed to the
following:
TAT Leader
DPO
CO
PO
Contractor National Program Manager
(NPM)
(2) Preparing and Processing TDDs
The regions must prepare the TDDs required to
initiate work on all activities and tasks to be per-
formed by the TAT contractor. This is the responsi-
bility of the DPO and appropriate staff.
1. Guidance for Preparation of TDDs
There are three important points for the DPO
to bear in mind in preparing the TDD. First, the
DPO must be as specific as possible in describing
the scope of work to be performed by the TAT.
Second, the DPO must clearly indicate contractor
reporting requirements. And finally, it is ex-
tremely important that the DPO include in the TDD
estimates for technical hours and costs needed to
accomplish the assignment.
Although exact tasks and response activi-
ties, particularly those involving emergency
situations, may be somewhat difficult to define,
it is very important to the extent possible, to
provide specific guidance to the contractor on
the expected work scope (TDD form, Boxes 9-11).
The task description should be as detailed as
available information permits so that there is a
IV-6
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April 7, 1986
9242.4-la
clear understanding by the TAT contractor of the
activity objective yet allow some flexibility for
alternative and innovative actions by the con-
tractor as conditions warrant. Examples oE can-
didate tasks which could be performed for differ-
ent types of response, removal, or prevention
work can be extracted directly from the Statement
of Work contained in Appendix A.
Care must be taken by the DPO and TAT Leader
to ensure that all tasks requested and performed
are within the bounds of the TAT contract SOW.
Particular attention must be given to ensure that
TAT TDD's do not involve personal services. For
example, the DPO must not direct the TAT to pro-
vide clerical support, travel arrangements, or
other personal services for EPA staff. The DPO
is also forbidden from specifying an individual
TAT member to perform a task. Specific TAT
staffing decisions are the responsibiity of the
TAT contractor.
The tasks included in any one activity will
depend upon the project-specific conditions. It
may prove useful for the region to develop stand-
ardized work scopes for an activity (i.e., facil-
ity surveys and inspections) and to use this
scope (modified as necessary for a specific situ-
ation) as an attachment to the TDD.
In addition, the TDD reporting requirements
(Box 12) must be spelled out such that the work
product provides the degree of detail desired by
the DPO and therefore facilitates accomplishment
of the activity objectives. The DPO may wish to
develop standard report outlines for various
types of activities (i.e., facility inspection
reports) and to attach these to the TDD as
appropriate.
Finally the DPO is responsible for ensuring
that an estimate of technical hours and costs
needed to accomplish the TDD assignment is in-
cluded on the TDD. These estimates may be used
in three important ways to ensure that the TAT
performs efficiently. First, these estimates can
serve as the basis for individual TDDs. The
actual hours and costs can then be compared with
the estimates. Any large differences between the
figures may be indicative of problems and should
be reviewed by the DPO. Secondly, the estimated
hours, used in combination with the estimated
IV-7
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April 7, 1986
9242.4-la
completion date, can help to identify the need
for overtime to complete the task. Since the
contract limits the overtime which may be
charged, overtime must be monitored.
The third use for the estimate of technical
hours is to provide the basis for comparison of
total estimated hours for all active TDDs with
the total technical hours available. Total tech-
nical hours available can be computed from the
information in the contract. The difference be-
tween the two figures will tell the DPO to what
extent available contractor resources are being
utilized. The TAT contractor can also provide
this information on a regular basis (biweekly).
2. Processing the TDD
Once the TDD is completed it is signed by
the DPO or his/her designee* and forwarded to the
contractor TAT Leader. The contractor TAT Leader
can take one of three actions on the TDD. If the
TDD is acceptable to the contractor TAT Leader as
issued by the DPO, the TAT Leader signs the TDD
and proceeds with performance of the assigned
activities. In general, the TAT contractor
should be willing to accept any assignment within
the bounds of the TAT contract SOW. However, as
stated earlier, conducting personal services for
EPA staff is not allowed.
The TAT Leader can accept the TDD with ex-
ceptions. In this case, the exceptions are to be
noted on the form and a copy is returned to the
DPO. The DPO and TAT Leader are to resolve these
exceptions prior to the contractor commencing
work. If necessary, a revised TDD should be
issued reflecting resolution of any exceptions.
If the issue cannot be resolved on this level,
the DPO should consult with the PO in headquar-
ters for guidance. If necessary, the PO will
When the DPO plans to be out of the office and un-
available to perform contract management functions,
he/she must submit a written request, or telephone the
TAT PO and CO, for approval to appoint a temporary
assistant DPO to act on his/her behalf for a discrete
period of time.
IV-8
-------
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April 7, 1986
9242.4-la
consult with the contractor NPM to try to resolve
the situation. If it is resolved, the DPO may
issue a revised TDD reflecting the issue resolu-
tion, and the contractor proceeds with task per-
formance. If the PO and contractor NPM cannot
resolve the issue, the matter is referred to the
CO for final resolution. Where possible, and
with concurrence of the DPO, the contractor
should begin work on the acceptable work elements
of the TDD, pending resolution of the points at
issue.
If the contractor TAT Leader rejects the
TDD, it is returned to the DPO with an explana-
tion of the reasons for rejection. The DPO and
TAT Leader are to confer to resolve the situa-
tion. If a resolution is reached, a revised TDD
can be issued, if necessary, and the contractor
proceeds with the task. If the DPO and the TAT
Leader cannot resolve the problem, the DPO should
contact the PO for guidance as explained above.
3. TDD Amendments
In the event that an issued TDD needs a revision,
the DPO must issue a TDD amendment containing the ap-
propriate changes. Events that require TDD amendments
may include, for example, an original underestimation
of a project's magnitude or an acceleration of a proj-
ect's period of performance. The original TDD's num-
ber will be used together with a suffix capital let-
ter. For example, referring to the previously cited
example, if the TDD is revised, the TDD authorizing
the revision would be numbered 2-8510-3A. The revised
TDD should contain the material contained in the orig-
inal TDD and the revised information so as to be cap-
able of standing alone. Amendments are to be pro-
cessed in the same manner as described above.
4. Special Projects: Contractor Work Plans
Funding has been obligated for the performance of
special projects under the TAT contract. Special
projects were discussed in Chapter I and are summar-
ized in Appendix A. If a special project is required,
the DPO may request the TAT Leader to prepare and sub-
mit a Work Plan and cost estimate for completing the
TDD. The TAT contractor's Work Plan should include a
detailed technical approach, schedule for completion
and cost breakdown. It should be sufficiently de-
tailed to provide a base for guiding work, measuring
IV-9
-------
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April 7, 1986
9242.4-la
progress, and controlling budgets. The contrac-
tor Work Plan should address the elements speci-
fied in Exhibit IV-2.
Upon review and approval of the TAT contractor's
work plan, a TDD will be issued according to the fol-
lowing procedures:
If the estimated cost of the project is less
than $10,000, the DPO or PO will issue the
TDD
If the estimated cost of the project is over
$10,000, the PO will issue the TDD with con-
currence by the CO.
3. TDD ACKNOWLEDGEMENT OF COMPLETION
For all contractor activities conducted under a TDD,
the TAT Leader must submit a TDD Acknowledgement of Com-
pletion (AOC) form. The AOC includes information on
actual labor hours expended, the total cost of the action,
and an indication of the type of response taken. TAT
leaders must expedite the tabulation of actual technical
hours and costs to date and submit AOC forms within ten
(10) working days of task completion. The form can be
either an interim or a final AOC depending on whether
final cost data is available upon submittal. The AOC form
should contain the elements as indicated in Exhibit IV-3
and described below:*
Cost Center (Box 1): This block contains the
number used to designate each TAT.
Number (Box 2): This box should contain the same
number that is in Box Number 2 of the TDD. This
information provides assurance that each TDD is
completed. In addition, the appropriate box
should be checked to indicate whether the acknow-
ledgement is for a completed TDD or for comple-
tion of an interim effort.
Response (Box 3): This section would provide a
description of the actions taken by the TAT in
response to the TDD. Sufficient detail should be
included to provide a reasonably clear indication
of what response action took place. Ambiguous
See Appendix D for example AOCs.
IV-10
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April 7, 1986
9242.4-la
EXHIBIT IV-2
Contractor work Plan Elements
1. Objectives and scope of the proposed activity and its
relationship to other activities.
2. Technical approach for the activity, anticipated
problems, and proposed solutions.
3. A detailed breakdown of tasks to be performed.
4. Description of work to be performed under each task,
including objectives and scope, information sources,
and methods to be used.
5. Analysis of resources (level) expected for each task.
6. Anticipated total labor cost for each task
7. Identification and tabulation of total direct costs
for each major work element.
8. Schedule, including critical path and milestones.
9. Listing and schedule of deliverables.
10. Safety and contingency measures
IV-11
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April 7, 1986
9242.4-la
EXHIBIT IV-3
1. COST CENTER:
ACKNOWLEDGEMENT OF COMPLETION
FOR TDD
TAT EMERGENCY RESPONSE.
REMOVAL AND PREVENTION
ROY F. WEfTON, IMC.
2. NO..
Q COMPLETE
0 INTERIM
RESPONSE
0 FORMAL REPORT
D LETTER REPORT
Q FORMAL BRIEFING
O OTHER (SPECIFY)
3A. COST TO DATE
-DATE.
3& TOTAL COST TO CLOSURE.
3C. ACTUAL TOTAL HOURS:
4. OPO ACTION:
D ACCEPTED
D ACCEPTED WITH EXCEPTIONS
D REJECTED
5. COMMENTS:.
t CERTIFY THAT THE ATTACHED MATERIALS MEET AND COMPLY WITH ALL
REQUIREMENTS OF THE SUBJECT TDD.
6A. TATL SIGNATURE AND DATE
CORRESPONDING TO 3A. ABOVE
6B. TATL SIGNATURE AND DATE
CORRESPONDING TO 3a ABOVE
7. I ACKNOWLEDGE THAT I HAVE BEEN PROVIDED WITH THE MATERIALS AND
SERVICES SPECIFIED IN THE SUBJECT TDD WITHIN ITS ORIGINAL OR
REVISED TIME FRAMES.
(AUTHORIZING DPO SIGNATURE)
8. DATE
tun i
rv-12
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April 7, 1986
9242.4-la
phrases such as "assisted OSC" should be
avoided. In the case of non-response type
assignments, for example, training course attend-
ance, the activity should be related to the over-
all Statement of Work for the TAT contract.
The TAT Leader should reference all deliverables
produced, along with document control number and
information as to where each deliverable can be
found. Where formal briefings, informal brief-
ings, etc./ have been requested and no formal
written submittal of information has been re-
quested by the DPO, copies of notes and materials
used in the presentation should be made available
to the DPO or the appropriate staff. It is im-
portant that the reports furnished by the con-
tractor be in conformance with the specific
instructions given in the TDD.
Cost to Date (Box 3A): If total cost figures are
unavailable when the AOC is submitted, the TAT
must include interim cost figures and provide the
date through which the costs were calculated.
This is an interim AOC if total costs are not
reported.
Total Cost to Closure (Box 3B) - The total cost
of work performed under the TDD including direct
labor, travel, expenses, analytical services, and
subcontracts (if applicable). If total cost in-
formation is not available within ten (10) work-
ing days of task completion, an interim AOC
should be submitted with interim cost figures.
Actual Total Hours (Box 3C): The total technical
hours required by the TAT contractor to conduct
and complete the TDD must be recorded in this
block. Technical hours do not include secretar-
ial and typing support. If information regarding
total technical labor hours expended is not
available within ten (10) working days of task
completion, an interim AOC should be submitted
with interim labor hour figures.
DPO Action (Box 4): The DPO should check the
appropriate box to indicate the quality of the
completed project assigned by the TDD. The DPO's
options are as follows:
If the DPO accepts the completion document,
he or she signs it. The original form is
then returned to the contractor and copies
IV-13
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April 7, 1986
9242.4-la
sent as indicated below so that the TDD can
be closed out and payment made to the
contractor.
The DPO can accept the completion documents
with exceptions which are to be noted on the
form. Copies are then distributed as above.
The DPO can reject the completion document.
In this case, the form is returned to the
TAT Leader with an explanation of the rea-
sons for rejection and measures required to
bring the assignment into conformance.
Comments (Box 5) - This section provides space
for any necessary explanation of Box 4.
Signatures (Boxes 6-9) - The signature blocks are
self-explanatory. The signatures are provided as
assurances that the TAT Leader has completed the
assignment in the best manner and in accordance
with the understanding of the task and that the
DPO has received the completed assignment within
the required time frame.
Distribution - Distribution for the completed
form is to be indicated at the bottom of the
form. Copies are distributed to the:
TAT Leader
DPO
Contracting Officer
Project Officer
Contractor NPM
It is very important that AOCs include information on
total costs expended. This is difficult, however, because
the TAT contractor may not know exact project costs when
preparing the AOC. Final costs may not be known until
several weeks after the AOC has been submitted. There-
fore, it is necessary to use two different AOC forms -- an
interim one which is submitted (with cost to date informa-
tion) within ten (10) working days of the task completion
and a final AOC (with total cost information) which is
submitted when final cost information becomes available.
A final AOC, with final cost information should be
submitted no later than 60 days after project completion.
IV-14
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April 7, 1986
9242.4-la
This concludes the discussion of work order prepara-
tion and processing. Chapter V discusses the monitoring
of financial and technical progress of work performed by
the contractor.
IV-15
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April 7, 1986
9242.4-la
3. REGIOMAL PROJECT PERFORMANCE TRACKING
There are a number of procedures and tracking systems
the DPO can institute in the regional office to facilitate
the tracking of project performance. The devices the DPO
should utilize are regional filing systems, log books, and
automated data systems. Each are described below.
1. Regional Filing Systems
The DPO should create or improve the region's
files to ensure that they are complete and acces-
sible. The regional filing system must meet both na-
tional standards and meet the needs of the region. It
is suggested that the TDD, AOCs (interim and final),
Performance Observation Report (POR) and any deliver-
ables associated with a project be filed together and
organized sequentially. By keeping the TDD, AOC(s),
POR and deliverables from one project all attached in
one file, the retrieval of project information for
internal (e.g., costing) or external-(e.g. audit) pur-
poses is greatly simplified.
Active TDDs may be filed separately for easy
access until the project is completed and an AOC (in-
terim or final) has been received. This will also
facilitate the tracking of projects that may become
overdue.
2. TDD Status Tracking Log
It is suggested that the DPO maintain a monthly
log (manual or automated) which lists TDDs and their
status. The log may contain information such as tech-
nical hours (estimated and actual), costs (estimated
and actual), completion date (estimated and actual),
POR requirement and the date the AOC is received.
Many regional TAT offices have automated systems in
place to track the status of TDDs. Weekly reports
should be generated by the TAT for use as a management
tool. A copy of the weekly report should be submitted
to the DPO for use as an oversight tool. A sample of
a manual TDD Status Tracking Log is given in Exhibit
V.2. It is further suggested that a log of all oral
directives given to the TAT be maintained.
4. REGIONAL TAT CONTRACTOR OFFICE REVIEWS
In order to ensure that the contractor has mechanisms
in place to ensure chain-of-custody and document control,
V-4
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April 7, 1986
9242.4-la
it is very important that the DPO or other regional repre-
sentatives conduct periodic spot checks to the Con-
tractor's office to examine documentation such as times
sheets, expense records, equipment maintenance logs, and
so forth. This visit is not intended to be a formal
audit, rather a means to determine whether an outside
audit is necessary. Ensuring that required chain-of-
custody and document control procedures are being adhered
to is important in facilitating and supporting potential
cost recovery actions against responsible parties. Regu-
lar monitoring is also important to ensure that government
property is being properly maintained (see Chapter I).
Suggested guidelines for conducting a review of the re-
gional TAT office are provided in Appendix E.
V-5
-------
EXHIBIT V-2
SUGGESTED FORMAT FOR TDD STATUS TRACKING LOG
MONTH
TDD#
HOURS
DESCRIPTIVE TITLE
> AVAILABLE
DATE
ISSUED
HOURS
EST. ACTUAL
COST
EST. ACTUAL
COMPLETION
DATE
EST. ACTUAL
AOC
RECEIVED
(DATE)
VD > »
NJT) tO
*. hi -D
N» H- (-•
cu
O
(D
3
n>
CO
0)
iQ
fP
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April 7, 1986
9242.4-la
A narrative description and rating of the con-
tractor's performance overall. (Both EPA and
contractor personnel should complete Part II of
the FOR — Evaluation Criteria Rating Worksheet,
to support the performance evaluation and rating
included in Part I. The worksheets should be
forwarded with Part I of the FOR to the Regional
POR Coordinator. Evaluation criteria and scoring
are described in Section 4 of this chapter).
Each POR should be limited to one discrete task, project,
or activity accomplished by the contractor.* The DPO is
responsible for ensuring that whoever completes the POR,
whether it be the TAT Leader or the DPO, must provide
sufficient documentation to substantiate how and why
performance is judged to be either meritorious or
deficient. A copy of Part II of the POR should be signed
and included in the performance evaluation package, and
also filed in the EPA office for future reference following
review by the POR Coordinator.
Any discrepancies between performance evaluations
prepared by EPA performance monitors and TAT contractor
personnel should be addressed and discussed with the con-
tractor by the TAT DPO, and resolved if possible. If issues
cannot be resolved, they should be so noted by the TAT DPO
and forwarded through the POR Coordinator to the HQ Project
Officer for further discussion and resolution with the
contractor.
Each regional and ERT office must submit the number of
PORs required to cover at least 60 percent of the hours
worked during the performance evaluation period by their
respective TAT. Performance Observation Reports should be
submitted as tasks are completed to the Regional POR Coord-
inator to avoid delays in reviewing PORs and preparing the
regional performance evaluation package. At a minimum, EPA
and TAT contractor personnel responsible for preparing PORs
should complete Part II of the POR - Evaluation Criteria
Rating Worksheet, as soon as work requested by a TDD is
completed. This will aid the performance monitor's or
contractor personnel's recall of the contractor's perform-
ance, particularly when Part I of the POR -- Observation
Description and Overall Evaluation -- is to be completed at
a later time or by another person.
On occasion, PORs may be prepared for groups of like
events, which separately are small in terms of level of
effort and were originally assigned to the contractor to-
gether under one Technical Direction Document.
Vl-8
-------
New Appendix
April 7, 1986
9242.4-la
APPENDIX D
EXAMPLE FORMS FOR TAT CONTRACT MANAGEMENT:
TDDs, AOCs, PORS
-------
New Appendix
April 7, 1986
9242.4-la
APPENDIX D
The purpose of this appendix is to provide an example
TDD, TDD amendment, AOC (Interim AOC indicated), and POR
for a hypothetical TAT response. In this example a
complete "paper trail" documents the directives issued
from EPA, the TAT's response, and an evaluation of the
TAT's performance. These examples illustrate the level of
detail expected in completing the paperwork associated
with tasks performed under the TAT contract.
D-l
-------
1. COST
CENTER:
TECHNICAL DIRECTION DOCUMENT (TDD)
OHM EMERGENCY RESPONSE AND
SPILL PREVENTION PROGRAM
ROY P. WESTON, INC.
2. NO
03-8404-12
2A. TYPE
12
3. PRIORITY:
Q HIGH (1)
D MEDIUM (2)
a LOW o)
4. SOURCE OF FUNDS
S CERCLA (1)
a 311 (2)
0 OTHER (3)-
5. EPA SITE ID
(IF APPLICABLE)
N/A
5A. EPA SITE NAME
(IF APPLICABLE).
N/A
6 COMPLETION
OATE
4-30-84
7. OVERTIME
3 YES D NO
8 REFERENCE
INFO.
D YES B NO
D ATTACHED
O PICKUP
9 DESCRIPTIVE T1TLF Oc TAg"e Emergency Response - Route 79. Somewhere f VA
ftA. ESTIMATED COSTS S26QQ
.98. ESTIMATED HOURS: 40.
10. SPECIFIC TASK ELEMENTS: EPft PM-S. Jones
Contact VA Stafce Response Team at fBQQl S55-123J
regarding reported ToInane Spill - Route 79, Somewhere/ VA
2 R*^oonrt to cni 1 1 in f-nnrrii na^i nn tji ^Vi V&
3. Conduct air monitoring for off-site impact
4 . Advise LD
PM of initial response condition c
5. Preliminarily assess needs for additional investigations
(e.q.t GW) and clean-up
11.'INTERIM DEADLINES
A5AP
ASAP
ASAP
ASAP
12. DESIRED REPORT FORM FORMAL REPORT Q LETTER REPORT E (2' FORMAL BRIEFING C
OTHER (SPECIFY):
13.
[ j\ Provide verbal notif icat-ion
Element
(2) Provide standard response report, with photographic
documentation, HASP, etc.
14. AUTHORIZING DPO:
DPO's Sdenature
(SIGNATURE)
15. DATE.
4/15/84
16. RECEIVED BY. BACCEPTED D ACCEPTED WITH EXCEPTIONS D REJECTED
TATL's Signature
(TAIL SIGNATURE)
17.~ DATE.
_4/16/S4
18. DESCRIPTOR
9! IT
O'L u
if un. i
-------
1. COST CENTER:
ACKNOWLEDGEMENT OF COMPLETION
FOR TOO
TAT EMERGENCY RESPONSE,
REMOVAL AND PREVENTION
ROYF.WE8TON.INC.
2. NO.:
03-8404-12
Q COMPLETE
D INTERIM
3. RESPONSE! EPA PM-S. Jones
G FORMAL REPORT
63 LETTER REPORT
D FORMAL BRIEFING
D OTHER (SPECIFY)
TAT performed an Emergency Response to a spill of 3son gal.
of toluene on Route 79. Somewhere. VA. TAT coogdinarad it-s re-
sponse with the VA State Response Team (officer Jim Black-800-555-1234) . upon
arrival on site, TAT advised EPA PM of initial response cond?fringe
H^MMMHMHHM^MHHMHMMtM^HMHHMIMHnMH^l^^^M^HH^Hl^^W^^M^M^M^HB^MH^HH^HaM^^H^HM^^^M^B^a^^M^MMMMMAAlBMMMMMAM^^M^^MMMBB^B
monitoring for possible off-site impacts. Initial clean-up recovered an, estimated
2500 gal spilled into gravel drainage ditch. TAT documented these activities in a
response report (standard format). which was submitted to the EPA PM on 4-27-84.
3A. COST TO DATE ««"« n*TC- 4-29-84
38. TOTAL COST TO CLOSURE: $2574
3C. ACTUAL TOTAL HOURS:
38 hours
4. OPO ACTION:
S ACCEPTED
D ACCEPTED WITH EXCEPTIONS
D REJECTED
5. COMMENTS: Since an estLJmafod innn
)i 1 1
during the initial response/clean-up activity, this TOP was
(03-8404-12A) to conduct an extent of contamination study (EOCS1 at this spill
site.
6. I CERTIFY THAT THE ATTACHED MATERIALS MEET AND COMPLY WITH ALL
REQUIREMENTS OF THE SUBJECT TDD.
TATL'S SIGNATURE
4/29/84
TATL'S SIGNATURE
5/29/84
6A. TATL SIGNATURE AND DATE • 6B. TATL SIGNATURE AND DATE
CORRESPONDING TO 3A. ABOVE CORRESPONDING TO 38. ABOVE
7. 1 ACKNOWLEDGE THAT 1 HAVE BEEN PROVIDED WITH THE MATERIALS AND
SERVICES SPECIFIED IN THE SUBJECT TDD WITHIN ITS ORIGINAL OR
REVISED TIME FRAMES.
DPO'S SIGNATURE
(AUTHORIZING DPO SIGNATURE)
8. DATE.
6/3/84
-------
1. COST
CENTER:
TECHNICAL DIRECTION DOCUMENT (TDD)
OHM EMERGENCY RESPONSE AND
SP&L PREVENTION PROGRAM
ROYF.WE8TON.INC.
2. NO:
2A. TYPE:
12
3, PRIORITY:
QHIGH(I)
Q MEDIUM (2)
O LOW (3)
4. SOURCE OF FUNDS:
BCERCLA(I)
0311(2)
D OTHER (3) _
5. EPA SITE ID
(IF APPLICABLE):
N/A
5A. EPA SITE NAME
(IF APPLICABLE).
6. COMPLETION
DATE
6/15/85
7. OVERTIME
DYES 3 NO
8. REFERENCE
INFO:
D YES B NO
D ATTACHED
a PICK UP
9. DESCRIPTIVE TITLE OF
Rnnf
Conduct an extent of contamination study (EOCS) at
epill
9A. ESTIMATED COSTS.
flOQ
. 9B, ESTIMATED HOURS:
1O SPECIFIC TASK ELEMENTS:
frr,m
nine the extent of
4 m«f«l «
oallonc, nf
toluene. Determine extent of groundwater
Prepare OA/Samplinq Plan and HASP
,-u report lab results to 3M
11. INTERIM DEADLINES:
5/7/85
6/15/85
12. DESIRED REPORT FORM FORMAL REPORT D LETTER REPORT B FORMAL BRIEFING D
OTHER (SPECIFY):
13. COMMENTS:.
14. AUTHORIZING DPO:
DPO Signature
(SIGNATURE)
15. DATE:
4/i7/84
16. RECEIVED BY: O ACCEPTED D ACCEPTED WITH EXCEPTIONS D REJECTED
TAT Leader Signature
(TATU SIGNATURE!
17. DATE:
4/13/84
18. DESCRIPTOR
0
4 Q
-------
1 COST CENTER:
ACKNOWLEDGEMENT OF COMPLETION
FOR TOO
TAT EMERGENCY RESPONSE,
REMOVAL AND PREVENTION
ROYF.WESTONJNC.
2. NO.:
03-8404-12A
3 COMPLETE
O INTERIM
3. RESPONSE:.
EPA PM - S. Jones
Lion Studv (EOCSJ at- the
toluene spill site.
Somewhere. VA.
Ten 3o font,
O FORMAL REPORT
B LETTER REPORT
O FORMAL BRIEFING
D OTHER (SPECIFY)
were collected and segmented into 2 foot sections. Core sections were screened for
Qn ugino an (W& on— sittt
Samles nf
with OVA
greater than 2 tines background were submitted for labor
recional lab) . EOCS results indicate approximately 20Qev of
An* CM I
• »*>
-------
TAT CPAF CONTRACT PERFORMANCE OBSERVATION REPORT (POR)
PART 1: OBSERVATION DESCRIPTION AND OVERALL EVALUATION
CONTRACT NO:
CONTRACTOR
NOYP WC8TON.INC.
TOO NO
03-8404-12A
REPORTING ELEMENT
Region III TAT
OATE(S) OF REPORTED OBSERVATION
4-15-84 to 6-15-84
APPROX NO OF HOURS
256
PERFORMANCE EVALUATION CATEGORY.
Technical Support
WAS CONTRACTOR NOTIFIED* U YES UNO
ReoiorL III PPO's Name
BY WHOM?
WHEN?
7-8-84
Region III DPO's Name
DESCRIPTION OF PERFORMANCE OBSERVATION BY.
TAT performed an Extent of
Contamination Study (EOCS) and NAME/TITLE
assisted the OSC during cleanup following a spill of 3500 gal. of toluene on Rt. 79
near Somewhere, VA. TAT rapidly provided experienced personnel without negatively
impacting other ongoing TDD assignments. These personnel quickly nrepared a compre-
hensive QA/Sampling Plan & HASP to support the ongoing field investigation & cleanup
TAT used an OVA to screen core sections in the field; this expedited cleanup activii
while minimizing lab costs & the impacts of conventional lab turnaround times on the
need for data to direct contractors on site. These efforts resulted in an estimate
wwinoc of SIS^OOO fnr oontcactor_standbv costs & S7.000 for conventional lab exists
Jit
E
RATING », 4,3.2 ORt
SIGNATURE OF INITIATOR
DATE
COMMENTOR CONCURRENCE/COMMENTS BY:
NAME/TITLE
TAT provided thorough & clear reports to the OSC, substantially assisting him in
mitigating this potentially significant spill of toluene to the ground water. TAT
completed this TDD with 15% less TAT DOE hrs. than originally approved.
COMMENTS: TAT agrees with the performance observation as described above. TAT was
able to provide this assistance to EPA because of the experience of its resources.
TAT's man-power scheduling system allowed it to provide these resources without
negatively impacting other TOD assignments.
RATING 5. 4. 1 2 OR 1
4
SIGNATURE OF COMMENTOR
Reaion III TATL's Signature
SIGNATURE OF REGIONAL POR COORDINATOR
Region III POR Coordinator's Signature
DATE.
7-10-84
DATE
7-12-84
HO COORDINATOR'S EVALUATION BY:
NAME/TITLE
To be completed by HQ Coordinator, upon request from Region III POR Coordinate
RATING 14.12 OR 1
SIGNATURE OF HO COORDINATOR
DATE.
RFWt*Ot-00>'C I
-------
1 TAT CW CONTRACT PERFORMANCE OBSERVATION REPORT (POM)
' PART Ik EVALUATION CRITERIA RATING WORKSHEET
TOO NO.
03-8407-12A
REPORTWO ELEMENT " DATE® Of REPORTED OBSERVATION APPROX NO. OF HOUR*
Region III TAT 4-15-84to 6/15/84 256
PERFORMANCE EVALUATION CATEGORY:
Technical Support
CONTRACTOR REPRESENTATIVE
Reaion III TATL's Nine
PERFORMANCE CRTfERU
PROJECT PUNMNQ
XORQAM8NQ(E.a, WORK PLAN
DEVELOPMENT. DATA REVCW)
XftCHEDUUNQ
-BUOGETMQ
TECHMCAL COMPETENCE * MNOVATON
v EFFECTIVENESS OF ANALYSES
-MEET PLAN GOALS
-ADHERE TO REGS. A PROCEDURES
X APPROACH CREATMTY/MQENUITV
SCHEDULE • vwai CUNTHUL
• BUDGET (HOURS * COST) MAINTENANCE
- PRtORTTY/SCHEDULE ADJUSTMENTS
X COST MINIMIZATION
REPORTING
X TIMELINESS OF DEUVERABLES
X CLARITY
X THOROUGHNESS
RESOURCE UTILIZATION
X STAFFING
• SUBCONTRACTWG
- EQUIPMENT. TRAVEL ETC
EFFORT
X RESPONSIVENESS
X MOBILIZATION
X DAY-TO-DAY
- SPECIAL SITUATIONS (EG, ADVERSE/
DANGEROUS CONDITIONS)
RATING
f
V A
3
9
«
X ^
•»
9
„ *
X c
4
*
9
. *
*
^
- 9
, «
*
X 4
a
9
i
- 5
X ,. *
4
9
- -1
EPA PERFORMANCE MONffOR
Reaion III DPO's Name
8UPPORTMQ COMMENTS
TAT developed sampling/QA and HASf to con-
duct an Extent of Contamination Study {EOCS)
following initial Emergency Response. Comp-
rehensive plans were rapidly prepared to
support ongoing field investigation and
clean-up, minimizing contractor stand-by
costs.
TAT's use of field analytical screening
techniques, e.g. OVA monitoring of core
sections, expedited clean-up activities while
minimizing laboratory costs and impacts of
conventional turnaround times to provide
data needed for direction of contractors.
TAT's use of its own experienced personnel tc
performed EOCS and assist in contractor mon-
itoring resulted in an estimated $15,000
savings in stand-by costs. TAT was able to
complete TDD with 15% less hours (TAT LOE)
than originally approved.
TAT provided the necessary reports in a
timely fashion. The clarity and thorough-
ness of the reports made the OSC's job
easier during the clean-up.
TAT was able to rapidly provide experienced
personnel for this high priority assignment
without negatively impacting other ongoing
TDD assignments.
TAT's responsiveness during the planning,
mobilization, and implementation of this
TDD substantially assisted the OSC in
mitigating a potentially significant spin
of toluene .
-------
New Appendix
April 7, 1906
9242.4-la
APPENDIX E
DPO CHECKLIST FOR
REVIEWING TAT CONTRACTOR'S OFFICE
-------
New Appendix
April 7, 1986
9242.4-la
APPENDIX E
DPO CHECKLIST FOR
REVIEWING TAT CONTRACTOR'S OFFICE
The purpose of this checklist is to aid the DPO in
conducting spot checks of the TAT contractor's office.
The DPO should conduct TAT office spot checks periodically
to ensure that adequate mechanisms are in place for
effective assignment management, document control,
procurement, expense reporting, government property
maintenance, and health and safety concerns. Spot checks
are not intended to be a formal audit of the TAT
contractor's office. Official audits, conducted by the
Office of the Inspector General, may be recommended by the
DPO as a result of suspected inadequacies uncovered during
these spot checks.
The checklist consists of 41 questions and is
organized into seven major areas: 1) work order
preparation and processing; 2) procurement; 3) expense
reports; 4) time sheets; 5) property management; 6}
equipment calibration and maintenance; and 7) health and
safety. All of the questions on the checklist are
formulated to yield "yes" or "no" responses with an
additional response category of "N/A" (not applicable) for
items which do not apply. Space is also provided below
each question for comments, explanations, and any
additional information deemed appropriate. Provision of
such comments and explanations is encouraged.
In using this checklist, the DPO will be able to
obtain answers to most of the questions simply by
examining the contractor's records and files. However,
some questions will require the assistance and input of
TAT staff. Therefore, the DPO should work closely with
the TAT leader and other TAT staff while conducting the
spot check visit and rely on their assistance and input
when necessary.
-------
DPO CHECKLIST FOR
REVIEWING TAT CONTRACTOR'S OFFICE
REVISED DRAFT
February 11, 1986
Emergency Response Division
Office of Emergency & Remedial Response
U.S. Environmental Protection Agency
Washington, D.C.
-------
pPO CHECKLIST FOR REVIEWING
TAT CONTRACTOR'S OFFICE
WORK ORDER PREPARATION AND PROCESSING
1. Are copies of all TDDs and AOCs
available in the files?
2. Are the TDD and AOC files well
organized (e.g., serially by TDD)?
3. Is there a TDD assignment log?
4. Is the assignment log:
a) Complete?
b) Up-to-date?
5. Do log books seem:
a) Properly organized?
b) Clear?
YES
NO
N/fl
-1-
-------
DPO CHECKLIST FOR REVIEWING
PAT CONTRACTOR'S OFFICE
PROCUREMENT
6. Are procurement procedures established
to determine whether professional
services, equipment, material, and/or
supplies requested are really needed?
7 . Are formal procurement procedures
established to require that equipment,
material, and supplies are obtained on
a competitive basis?
8. Is the purpose of every procurement
documented?
9. Do prices paid for purchases under the
contract seem reasonable?
10. Does the TAT have procedures in place
to identify any refunds, rebates, or
credits obtained?
11. Does the TAT make sure that these
refunds, etc. are passed on to EPA?
YES
NO
N/fl
-2-
-------
DPO CHECKLIST FOR REVIEWING
TAT CONTRACTOR'S OFFICE
YES
NO
EXPENSE REPORTS
12. Are there procedures in place for
ensuring that expenditures are proper
and kept to a minimum?
13. Do reporting procedures allow for
proper allocation of expenses (i.e.,
site-specific accounting),
14. Do staff keep track of every
expenditure they incur (meals,
transportation, lodging, miscellaneous)?
15. Do expense reports seem to be:
a) Complete?
b) Accurate?
16. Are all expense reports signed, dated,
and approved by the TATL?
17. Does the TAT have written travel
policies?
-3-
-------
DPO CHECKLIST FOR REVIEWING
TAT CONTRACTOR'S OFFICE
18. Do travel vouchers show the time and
purpose of travel?
19. Are all expenses clearly described and
supported on travel vouchers?
TIME SHEETS
20. Do time sheets seem to be:
a) Complete?
b) Accurate?
21. Are all time sheets signed, dated, and
approved by the TATL?
22. Is there a mechanism to ensure that all
overtime is properly documented and
approved?
YES
NO
N/fl
-4-
-------
pPO CHECKLIST FOR REVIEWING
]TAT CONTRACTOR'S OFFICE
PROPERTY MANAGEMENT
23 . Does the TAT have controls in place to
ensure that vehicles are used for
business only? (e.g., is mileage
checked, etc?)
24. Are there standard operating procedures
for controlling and maintaining
government property?
25. Does the TAT maintain an adequate
equipment inventory system?
26. Does the system provide information on
identification and physical location of
equipment and other property?
27. Is the storage area for equipment
secure?
28. Has the office notified the EPA
Property Administrator whenever:
a) Equipment is no longer required,
is uneconomical to repair, or is
declared obsolete?
YES
NO
N/fl
-5-
-------
DPO CHECKLIST FOR REVIEWING
TAT CONTRACTOR'S OFFICE
b) Equipment is missing?
c) Parts from disabled equipment and
vehicles are exchanged for parts
from good equipment and vehicles?
EQUIPMENT CALIBRATION AND MAINTENANCE
29. Is there an equipment calibration and
maintenance log book?
30. Is the log book:
a) Complete?
b) Up-to-date?
31. Are detailed calibration procedures
available?
32. Is all equipment calibrated on a
regular basis?
YES
NO
N/fl
-6-
-------
DPO CHECKLIST FOR REVIEWING
TAT CONTRACTOR S OFFICE
33. Is there an out-of -calibration
procedure?
HEALTH' AND SAFETY
34. Have all TAT members received medical
exams within one week of hire?
35. Have all TAT members received annual
medical exams?
36. Are monthly exposure/injury reports
filled out by each TAT member?
37. Are incident reports filled out for
every incident?
38. Does each TAT member have a valid Basic
First Aid and two-person CPR card?
39. Does the TAT have an approved Health
and Safety plan?
YES
NO
N/fl
-7-
-------
kpO CHECKLIST FOR REVIEWING
AT CONTRACTOR'S OFFICE
40. Is there a site safety plan for each
site?
41. Does the TAT have an approved field
sampling plan?
YES
NO
N/A
-8-
------- |