oEPA
Unn«« SI«IM
DIRECTIVE NUMBER:
9242.4-01A
TITLE' TECHNICAL ASSISTANCE" TEAM (TAT) CONTRACTS
USERS MANUAL
APPROVAL DATE: 8/2/87
EFFECTIVE DATE:
ORIGINATING OFFICE:
C FINAL
9/28/87
D DRAFT
STATUS:
I
[ ]
A- Pending OMB approval
B- Pending AA-OSWER approval
For review &/0r comment
D- In development or circulating
REFERENCE (Oth«f dOCUm«nt«): headquarters
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EPA Form 1315-17 (Rev. 5-87) Prev ous editions are obsolete.
OSWER Os
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DIRECTIVE
DIRECTIVE
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Unilea States €nvironmentat Protection Agency
©‘EPA Washington DC 20460
OSWER Directive Initiation Request
1 Directive Numoec
9242.4-0
2. OrIginator information
Name of Contact Person I Mail Code Office Telephone Code
Susan A. Janowiak )WH-548B OERR/ERD I 382-7732
3 Title
Technical. Assistance Team (TAT) Contracts User’s Manual
4 Summary of 0 rective (include bnef statement at purpose)
This user’s manual provides information and guidance on management and
implementation of EPA ’s “Technical Assistance Teams (TAT) for Emergency
Response, Removal and Prevention” contracts.
5. Keywords
Superfund, CERCLA, SARA, TAT, CWA, TDD, AOC/POR
6a. Does This Directive Supersede Previous Directive s)? No Yes What directive (number, title)
9242.4-01 - Technical
Assistance Team (TAT) Contract
b. Does It Supplement Previous Directive(s)? No E] Yes Wjiat directive (numbers title)
7 Draft Level
A — Signed by A.AJDAA B — Signed by Office Director C — For Review & Comment D — In Deve opmenI
8. Document to be distributed to States by Headquarters? Yes No
This Request Meets OSWER Directives System Format Standards.
d Office Directives Coordinator
9. e .
Date
1/ -i(ã’y
Date
/ ,j —
Henry L. Longest, II, Director
10. Name and Titie of App oving icial
Office of Emergency and Remedial. Response
V
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Un itd t it (Jtf’ of Emergency trid O WF H Di t .L i 01 A
F Pvronrfl fltai )t Lt Ofl RUr1)t dIdI t S )flSr S ’pterLtr -/
4i r y V\Iashr rt n ‘L 2fl4H()
- ________ — -
EPA Technical Assistance
Team (TAT) Contracts
Users’ Manual -
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I. A A. A A
TECHNICAL ASSISTANCE TEAM
(TAT) CONTRACTS
USERS’ MANUAL
SEPTEMBER 1987
OSWER Directive 9242.4-O1A
EMERGENCY RESPONSE DIVISION —
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OSWER Directive 9242.4—O1A September 1987
NOTICE
The information in this document has been funded, wholly or
in part, by the United States Environmental Protection
Agency under Contract No. 68—03—7331 to Booz. Allen &
Hamilton Inc. It has been subject to the Agencys peer and
administrative review and has been approved for publication
as an EPA document.
This handbook is intended to present information and
guidance on management and implementation of EPA s
“Technical Assistance Teams (TAT)’ contracts.
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OSWER Directive 9242.4—O1A
September 1987
TABLE OF CONTENTS
Page
Number
INDEX OF EXHIBITS ix
LIST OF ACRONYMS xi
PREFACE Xiii
I. INTRODUCTION I-i
1. Structure of the Users Manual I—i
2. Using the Manual 1—3
II. SCOPE AND PROVISIONS OF THE 1 1—1
TECHNICAL ASSISTANCE TEAM
CONTRACTS
1. Background and Structure of the 11—2
TAT Zone Contracts
1.1 Type of Contracts 11—2
1.2 Period of Performance 11—3
1.3 Staffing Requirements 11—3
1.4 Nature of Work to Be 11—4
Performed
1.5 Zone Crossover 11—5
1.6 Personal Versus Nonpersonal 11—5
Services
1.7 Contract Equipment 11—6
1.8 Property Management 11—7
2. Contractor Requirements in 11—8
Executing SOW Activities
2.1 Health and Safety 11—8
2.2 Training Program for Contractor 11—10
Personnel
2.3 Quality Assurance 11—10
2.4 Confidentiality of Information 11—11
2 5 Conflict of Interest 11—11
2.6 Chain—of-Custody and Document 11—12
Control Procedures
2.7 ost Management Support 11—12
2.8 24—Hour, 7—Day—A—Week Call 11—13
Center
2.9 Subcontracting 11—13
2.10 Site—Specific Invoicing 11—14
iii
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OSWER Directive 9242.4—O1A September 1987
TABLE OF CONTENTS
(Continued)
Page
Number
III. CONTRACT MANAGEMENT: ORGANIZATION, 11 1-1
ROLES AND RESPONSIBILITIES
1. Relationship Between EPA Head— 111—2
quarters and Regional Offices
2. Contract Management Structure 111—4
Within EPA Headquarters
2.1 TAT Project Officers 111—4
2.2 TAT Contracting Officer 111—5
2.3 Headquarters TAT Deputy
Project Officer 111—5
3. Contract Management Structure 111—6
Within EPA Regional Offices
3.1 TAT Deputy Project Officers 111—6
3.2 On—Scene Coordinators 111—7
4. TAT Contractor Management Structure 111—8
4.1 TAT Zone Program Manager (ZPM) 111—8
4.2 Technical Assistance Team 111—9
Leaders
IV. INTERFACE WITH OTHER EPA CONTRACTS IV-1
AND EXTERNAL AGENCIES
1. National Contract Laboratory IV—2
Program (NCLP)
2. Remedial Planning and Field IV—3
Investigation Team Contracts
3. Technical Enforcement Support (TES) IV—4
Contracts
4. Emergency Response Cleanup Services IV—5
(ERCS) Contracts
5. Alternative Remedial Contract Strategy IV—5
(ARCS)
6. Underground Storage Tanks (UST)
Program IV—6
iv .
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OSWER Directive 9242.4—O1A September 1987
TABLE OF CONTENTS
(Continued)
Page
Number
7. Interaction of TAT with State IV—6
and Local Agencies, the U.S.
Coast Guard (USCG) and other Federal
Agencies
V. PROCEDURES FOR INITIATING AND MANAGING V-i
TAT ACTIVITIES
1. The Technical Direction Document V—2
(TDD)
1.1 Preparing the TDD V—3
1.2 Processing the TDD V—li
1.3 Amending the TDD V—12
1.4 Special Project TDDs V—12
2. Acknowledgment of Completion (AOC)/ V—13
Performance Observation Report (POR)
2.1 Preparing the AOC/POR V—l4
2.2 Processing the AOC/POR V—l9
VI. MONITORING PROJECT PERFORMANCE AND VI-l
F INANC IAL MANAGEMENT
1. Contractor Reports VI—2
1.1 Financial Management Report VI—3
1.2 Monthly Status Report VI—3
1.3 Monthly Summary Progress VI—4
Report by the ZPM
1.4 Site—Related Financial Reports VI—4
1.5 Program Management Information VI—4
Reports
1.6 Draft and Final Year—End Report VI—4
1.7 Cleanup Activity Reports VI—5
1.8 Pollution Reports VI—5
1.9 ZPM TAT Office Review Report VI—6
1.10 Letter Reports VI—6
1.11 Socio—Economic Reports VI—7
2. Central Filing System VI—7
3. TDD Status Tracking Log VI—7
4. Regional TAT Contractor Office VI—7
Reviews
V
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OSWER Directive 9242.4—O1A September 1987
TABLE OF CONTENTS
(Continued)
Page
Number
VII. PERFORMANCE EVALUATION PLAN Vu-i
1. Cost—Pius—Award—Fee (CPAF) VII—2
Performance Evaluation Plan
2. Regional Coordination of the VII—3
Performance Evaluation Process
2.1 Organization, Roles and Respon— VII—3
sibilities of EPA Regional and
TAT Contractor Personnel
2.2 Preparation of Award Fee VII—5
Performance Observation Reports
2.3 Preparing the Regional Perform— VII—8
ance Evaluation Package: The
Role of the Regional POR Coor-
dinator
3. Headquarters Coordination of the VII—9
Performance Evaluation Process
3.1 Headquarters Evaluation Coor— VII—9
dinator
3.2 Performance Evaluation Board Vu—il
(PEB)
3.3 Fee Determination Official Vu—li
(FDO)
4. Performance Evaluation Categories Vu—il
and Criteria
4 l Performance Evaluation VII—12
Categories
4.2 Performance Evaluation Criter .a VII—12
4.3 Rating the Performance Events VII—13
4.4 Determination of Award Fee VII—14
Percentages
vi
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OSWER Directive 9242.4—O 1A September 1987
TABLE OF CONTENTS
(Cont inued)
VIII. MISCELLANEOUS MATERIALS
APPENDIX A TAT ZONE CONTRACTS STATEMENTS OF WORK
APPENDIX B MINIMUM EQUIPMENT NEEDS
APPENDIX C TAT ZONE 2 CONTRACT TECHNICAL DIRECTION
DOCUMENT: TYPE OF ACTIVITY
APPENDIX D EXAMPLE FORMS FOR TAT CONTRACT
MANAGEMENT: TDDs AND AOC/PORS
APPENDIX E DPO CHECKLIST FOR REVIEWING TAT
CONTRACTOR’ S OFFICE
APPENDIX F GLOSSARY
APPENDIX G BIBLIOGRAPHY
vii
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OSWER Directive 9242.4—O1A September 1987
INDEX OF EXHIBITS
Page
Number
1 1—1 TAT Personnel Qualifications and 11—15
Levels of Experience
11—2 TAT Contract Staffing Distribution 11—16
11—3 TAT Staffing Disciplines 1 1—17
I l l— i EPA—Contractor TAT Management Structure 111—10
111—2 Organization of Zone 1 TAT Contract 111—11
111—3 Organization of Zone 2 TAT Contract 111—12
‘1—1 Process for Initiating and Completing \1—21
TAT Contractor Services
V—2 Sample TDD V—22
V—3 Contractor Workplan Elements V—24
V-4 Sample AOC/POR V-25
VI—l Contractor Reports VI—9
VI—2 Suggested Format for TDD Status VI— lO
Tracking Log
V u—i CPAF Performance Evaluation VII—15
Organization, TAT Contracts
VII—2 Acknowledgement of Completion Performance VII—16
Evaluation Report: Part 1
VII—3 TAT CPAF Contract Performance Obser- VII—18
vation Report (POR) Part II:
Evaluation Criteria Rating Worksheet
VII—4 Award Fee Performance Evaluation VII—19
Plan Calendar
V u—S Example Cover Memorandum VII—25
ix
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OSWER Directive 9242.4—O 1A September 1987
INDEX OF EXHIBITS
(Continued)
Page
Number
VII—6 Summary of TAT Contract Performance VII—28
Observation Reports
VII—7 Reporting Elements VII—29
VII—8 TAT Contract Performance Evaluation ‘ 1 1 1—3 1
Board
VII— 9 Award Fee Allocation Matrix for TAT ‘ 11 1—33
VI I—lO TAT Contract Performance Evaluation ‘ 111—35
Criteria
VII—11 Rating Guidelines for Performance ‘ 1 11—37
Evaluation Criteria
‘ 111—12 Award Fee Percentage Versus Performance ‘ 1 11—38
Assessment Definitions
x
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OSWER Directive 9242.4—O1A September 1987
LIST OF ACRONYMS
AOC/POR Acknowledgement of Completion/Performance
Observation Report
CEAT Contractor Evidence Audit Team
CERCLA Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (PL
96—510), As Amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA)
CO Contracting Officer
CPAF Cost—Plus—Award—Fee
CWA Clean Water Act
DPO Deputy Project Officer
ERCS Emergency Response Clearfup Services
ERD Emergency Response Division
ERT Environmental Response Team
FIT Field Investigation Team
FDO Fee Determination Official
LOE Level—of—Effort
NCLP National Contract Laboratory Program
NCP National Oil and Hazardous Substances Contingency
Plan (40 CFR Part 300)
NEIC National Enforcement Investigations Center
NPL National Priorities List
OERR Office of Emergency and Remedial Response
OHM Oil and Hazardous Materials
OSC On—Scene Coordinator
OSHA Occupational Safety and Health Administration
OWPE Office of Waste Programs Enforcement
PCMD Procurement and Contracts Management Division
PEB Performance Evaluation Board
P0 Project Officer
POLREP Pollution Report
QA Quality Assurance
RCRA Resource Conservation and Recovery Act
REM Remedial Planning Contractors
RPM Remedial Project Manager
RSO Regional Safety Officer (Contractor)
SARA Super fund Amendments and Reauthorization Act of
1986
SCBA Self—Contained Breathing Apparatus
SMO Sample Management Office (CLP)
SPCC Spill Prevention, Control and Countermeasures
SOW Statement of Work
TAT Technical Assistance Team
TATL TAT Leader
TES Technical Enforcement Support
TDD Technical Direction Document
USCG United States Coast Guard
xi
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OSWER Directive 9242.4—O1A September 1987
PREFACE
This users manual provides information and guidance on
management and implementation of EPA’s “Technical Assistance
Teams (TAT) for Eniergency Response, Removal and Prevention”
contracts. Its primary purpose is to assist Regional and
Headquarters EPA personnel in understanding their roles and
responsibilities under the contracts and to describe the
necessary procedures and requirements that should be followed
in managing the contracts. The manual is also intended to be
helpful to TAT contractor personnel in terms of their roles and
responsibilities vis—a—vis EPA. While the manual is intended
to serve as guidance in the administration of the TAT
contracts, it in no way alters the requirements of the
contracts.
Feedback on the manual is important, especially regarding
its usefulness and practicality. Therefore, any comments or
suggestions on how to improve the manual will be welcomed at
any time. They should be submitted in writing to the Zone II
TAT Project Officer, Ms. Susan Janowiak, or to the TAT Zone I
Project Officer, Mrs. Patricia Hawkins, at the U.S.
Environmental Protection Agency, Emergency Response Division
(WH—548B), 401 M Street, S.W., Washington, D.C. 20460.
xiii
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OSWER Directive 9242.4—O 1A September 1987
CHAPTER I
INTRODUCTION
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OSWER Directive 9242.4—OlA September 1987
CHAPTER I
INTRODUCT ION
Under the authority of Section 104 of the
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA or Superfund) of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986
(SARA) and Section 311 of the Clean Water Act (CWA), the
U.S. Environmental Protection Agency (EPA) has been
delegated the responsibility to undertake response actions
with respect to releases or potential releases of oil or
hazardous substances, including releases of petroleum from
underground storage tanks, that pose a threat to human
health, welfare, or the environment. In addition, EPA is
responsible for providing technical assistance to help
mitigate endangerment of the public health, welfare or
environment during other emergencies and natural
disasters. EPA’s successful implementation of these
emergency response action responsibilities requires that
technical support capabilities be provided in the form of
multidisciplinary Technical Assistance Teams (TAT) for
each EPA Region. EPA has procured the services of two TAT
contractors under the “Technical Assistance Teams for
Emergency Response, Removal and Prevention” contracts to
assist in implementing Superfund emergency response and
prevention activities.
The purpose of this users’ manual is to establish a
standard set of operating and management procedures to
assist EPA Headquarters and Regional personnel in
effectively and efficiently managing the TAT contracts.
In addition, the users’ manual is intended to define the
roles and responsibilities of EPA and contractor personnel
in managing and executing the TAT contracts.
The remainder of this introduction describes the
structure of the manual and briefly discusses instructions
for its use.
1. STRUCTURE OF THE USERS’ MANUAL
The users’ manual consists of eight chapters, five
appendices, a glossary and bibliography. This chapter,
Chapter I, provides an introduction to the manual, a
description of its structure, and how it can be used.
Each of the remaining chapters is described briefly below:
Chapter II —— Scope and Provisions of the Technical
Assistance Team Contracts describes the background and
structure of the TAT zone contracts and contractor
requirements in executing Statement of Work (SOW)
activities.
I—1
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OSWER Directive 9242.4—O1A September 1987
Chapter III —— Contract Management: Organization,
Roles and Responsibilities highlights the organization
and key management roles, responsibilities and
interactions of Federal and contractor personnel
(e.g., Project Officer (P0), Contracting Officer (CO),
Deputy Project Officers (DPOs), On—Scene Coordinators
(OSCs), TAT contractor Zone Program Managers (ZPMs),
and TAT Leaders (TATLs).
Chapter IV —— Interf ace with Other EPA Contracts and
External Agencies briefly summarizes the functions of
other EPA contracts and other government agencies with
which the TAT may interact and offers guidelines to
follow in coordinating these interactions.
Chapter V —— Procedures for Initiating and Managing
TAT Activities discusses the preparation and
processing of Technical Direction Documents (TDDs) and
Acknowledgment of Completion/Performance Observation
Report (AOC/POR) forms, including detailed
instructions for completing all required forms.
Chapter VI —— Monitoring Project Performance and
Financial Management describes TAT contractor
reporting requirements and EPA procedures for tracking
and assessing project performance.
Chapter VII —— Performance Evaluation Plan describes
the criteria, procedures and forms to be used in
evaluating contractor performance. -
Chapter VIII —— Miscellaneous Materials is reserved
for memoranda, policy guidance. and other important
correspondence issued by Headquarters concerning the
TAT contracts.
In addition to these chapters, there are also five
appendices to the manual. Appendix A presents the TAT
contract Statements of Work (SOWs); B provides a partial
list of TAT contract equipment and property; C provides
details of types of activities to be conducted under TDDs;
D provides completed examples of TDDs and AOC/POR forms;
and E presents a DPO checklist for reviewing the TAT
contractor’s office.
Also included are a glossary and bibliography. The
glossary provides definitions of terms relevant to TAT.
The bibliography lists references that provide detailed
information on subjects and matters related to TAT.
1—2
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OSWER Directive 9242.4—O1A September 1987
2. USING THE MANUAL
The TAT contract program is organized according to two
separate geographic zones. The types of services provided
in these two zones are essentially identical. However,
some differences do exist, and they are discussed in
Chapter II. The management and operating procedures
discussed in the following chapters of the manual are
applicable to both zones, except where noted otherwise.
The information contained in the manual has been
organized to permit EPA TAT Headquarters and Regional
personnel, as well as TAT contractor personnel, to have
easy access to specific procedures and responsibilities
pertaining to TAT contracts management and
implementation. Each chapter is separated by a tab
labeled with the area of contract management covered in
this chapter. Following the tab is a table of contents
indicating the pages where detailed discussions of
specific procedures and forms to be used can be found in
the chapter. A loose—leaf format has been used to
facilitate updating and to enable users to supplement the
text with notes and pertinent references appropriate to
their own activities. The manual is expected to serve as
a desk reference that will be updated periodically.
Revised pages will be distributed and then inserted into
the manual to ensure completeness.
1—3
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OSWER Directive 9242.4—O 1A September 1987
CHAPTER II
SCOPE AND PROVISIONS OF THE
TECHNICAL ASSISTANCE TEAM CONTRACTS
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OSWER Jirective 9242.4—O1A
September 1987
CHAPTER II
SCOPE AND PROVISIONS OF THE TECHNICAL
ASSISTANCE TEAM CONTRACTS
KEY TOPICS
Page
Background and Structure of the TAT Zone
Contracts 11—2
• Type of Contracts - 11—2
• Period of Performance 11—3
• Staffing Requirements 11—3
• Nature of Work to Be Performed 11—4
• Zone Crossover 11—5
• Personal Versus Nonpersonal Services 11—5
• Contract Equipment 11—6
• Property Management 11—7
• Contractor Requirements in Executing 1 1—8
SOW Activities
• Health and Safety 11—8
• Training Program for Contractor Personnel 11—10
• Quality Assurance 11—10
• Confidentiality of Information 1 1—11
• Conflict of Interest 1 1—11
• Chain—of—Custody and Jocument Control 11—12
• Cost Management Supp rt 11-12
• 24—Hour, 7 Day—A—Week Call Center 11—13
• Subcontracting 11—13
Site—Specific Invoicing 11—14
II—’
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OSWER Directive 9242.4—OIA September 1987
CHAPTER II
SCOPE AND PROVISIONS OF THE
TECHNICAL ASSISTANCE TEAM CONTRACTS
The Emergency Response Division (ERD) in the Office of
Emergency and Remedial Response (OERR) is responsible for
executing EPA ’s emergency response, removal, and
prevention program. Successful implementation of this
program requires the provision of technical and management
support to On—Scene Coordinators (OSCs) during removal
actions. EPA has contracted with two Technical Assistance
Team (TAT) contractors to provide this support. This
Chapter provides an overview of the TAT contracts
including a description of the background and structure of
the contracts an itemization of the types of services and
equipment that can be accessed through the contracts, and
requirements that must be met by the contractors in
performing the work.
1. BACKGROUND AND STRUCTURE OF THE TAT ZONE CONTRACTS
The following sections highlight background
information applicable to the TAT contracts and include
discussions of the type of contracts, the structure of the
contracts, the periods of performance. and other general
descriptive information pertaining to the contracts.
1.1 Type of Contracts
The first two TAT contracts, which began in
October 1979, and extended through January 1987, were
organized on a nationwide basis, and each was operated by
a single contractor.* They covered all ten EPA Regional
offices, Environmental Response Teams (ERTs) in
Cincinnati, Ohio and Edison, New Jersey, and EPA
Headquarters. The current TAT contracts, however, are
organized on a zone—wide basis with one contractor
providing support to Zone 1 and another contractor
providing support to Zone 2. Zone 1 consists of
Regions I—V, ERT in Edison, and EPA Headquarters. Zone 2
consists of Regions VI—X. In Zone 1 there are a total of
seven TAT offices —— one each for Regions I-V. ERT in
Edison, and EPA Headquarters. In Zone 2 there are six TAT
offices —— one each for Regions VI and VIII—X, and two for
Region VII.
* Although all “field’ worked ended under the
predecessor contract (#68—01—6669) on January 31,
1987, the contract is still technically in effect to
allow microfilming of all contract records and to
provide historical site—specific cost information.
11—2
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OSWER Directive 9242.4—O1A September 1987
Consistent with the prior TAT contracts, the current
zone contracts are Cost—Plus—Award—Fee (CPAF) contracts.
With cost reimbursement of this type, the contractors are
guaranteed a fixed base fee, paid in monthly installments,
to which an award fee can be added. Funding for the TAT
contracts is based oh contractor expenses incurred to
provide a specified level of effort (LOE) and other
resources to conduct activities specified in the Statement
of Work (SOW). Thus, EPA personnel must ensure that
sufficient work is assigned to the TAT contractors to
fully and efficiently utilize the minimum levels of effort
specified for each team. -
1.2 Period of Performance
The period of performance for the current TAT
contracts is from December 16, 1986 through September 30,
1988. EPA also has the option to extend the contracts one
additional period of 24 months, if desired. In addition,
the contracts contain two two—month Continuity of Services
(COS) options that are intended to facilitate phase—out to
the successor contractor.
1.3 Staffing Requirements
To carry out the respons bi ities of the TAT
contracts, the contractors are required to staff each TAT
office with personnel having appropriate levels of
experience and areas of expertise. To differentiate among
various levels of experience in TAT contractor staff, EPA
has established seven labor classifications for
professional and technical positions. These are
summarized in Exhibit 11—1. In addition, EPA has
specified the total number of positions for each TAT and
has provided a list of disciplines that should be used to
guide staffing of the TATs with appropriate types of
expertise. The number of positions and disciplines (both
of which will fluctuate during the contract) are shown in
Exhibits 11—2 and 11—3, respectively. The mix of
disciplines and appropriate levels of experience to staff
the number of positions required for the TATs will vary
among the Regions and generally will complement the
capabilities of EPA personnel. Requirements concerning
staffing needs for each TAT should be developed by the TAT
Deputy Project Officer (DPO) and communicated to the TAT
Project Officer (P0). With the approval of the P0 arid the
TAT Contracting Officer (CO), amendments to the existing
discipline mix may be made as required to maintain program
responsiveness.
11—3
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OSWER Directive 9242.4—OlA September 198.7
1.4 Nature of Work to Be Performed
The types of technical assistance to be provided under
the TAT contracts are described in detail in the contract
SOWs, which are included in Appendix A. These technical
support services will primarily support the On—Scene
Coordinators (OSC5) in the ten Regional offices, the ERT
office in Edison, and EPA Headquarters. They are intended
to augment EPA’s response, removal and prevention
programs. Within the overall program management effort,
tasks to be performed include: establishing and
maintaining the required TAT offices and personnel;
instituting recordkeeping, quality control and personnel
safety procedures; procuring laboratory or field analysis
services; and providing special projects support, as
needed, to the OSC.
Within the scope of the emergency response, removal
and prevention program, the TAT contractors perform
various specific tasks. In general, these tasks include:
conducting facility inspections; implementing EPA and
contractor personnel training programs; completing
pollution reports and damage assessments; reviewing and
analyzing response contingency plans; coordinating the
development and implementation of community relations -
plans; conducting removal preliminary assessments and
other Section 104(b) activities; performing mini—remedial
investigations (this is a new task under the TAT contracts
and involves the limited investigation of a site where
response activity is in progress or has been completed)
and providing direct emergency response support, as well
as response monitoring services, to the OSC during removal
actions.
Appendix A contains the SOWs for both Zone 1 and
Zone 2 TAT contracts. All EPA and contractor personnel
involved with the TAT contracts should be thoroughly
familiar with these SOWs. It is noted that both SOWs are
virtually identical, except for differences in TAT office
locations.
In addition, the TAT contractors perform special
projects and analytical services, when requested. Special
projects are intended to provide EPA with specialized
equipment, personnel and services not routinely available
from a TAT office. Examples of special projects include,
but are not limited to: renting of aircrafts; hiring of
scuba divers; retaining expert consultants; renting
specialized equipment; and providing temporary relocation
of individuals. Analytical services consist of rapid
turnaround laboratory or field analysis of multimedia
samples. The TAT contractors will coordinate these
activities with EPA’s National Contract Laboratory Program
11—4
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OSWER Directive 9242.4—O1A September 1987
(NCLP). If the NCLP is unable to handle the samples, the
TAT contractors can choose to handle the samples
themselves or contract for these services.
1.5 Zone Crossover
Each TAT contractor may be required to provide
services in the other contractors geographical zone.
This may occur in the event of a conflict of interest or
in any other situation in which it is deemed by the CO to
be in the best interest of the Government. Any use of a
contractor outside its zone must be coordinated by the
appropriate DPO, P0, and CO.
1.6 Personal Versus Nonpersonal Services
The TAT zone contracts provide for nonpersonal
services. In general, contract services can be classified
as either personal or nonpersonal. With a nonpersonal
services contract such as the TAT contracts, the TATs
provide an approved resource for EPA in the accomplishment
of their programs while avoiding an actual
employee—employer relationship. Personal services
contracts are those where the contractor or its employees
seemingly act as employees 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. Personal services are not allowed under the TAT
contracts .
The following examples of personal and nonpersonal
services are provided for illustrative purposes only:
Personal
— Contract for the furnishing of ordinary,
day—to—day stenographic and secretarial
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 particular
Government office or installation, where no
specialized skills are required and the
report would ordinarily be prepared by the
regular officers or employees of the office
or installation even if there is to be no
Government supervision and even if payment
is to be for an “end product” report;
11—5
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OSWER Direct:ve 9242.4—O1A September 1987
— Contract for the furnishing of persons to
perform the various day—to—day functions of
contract administration for a Government
agency, even if there is no Government
supervision (e.g., directing the ERCS
contractor);
— Contract for the picking up of other
Government personnel at the airport;
- Paying the luncheon tabs of Government
personnel.
Nonpersona 1
- Contract for fie.ld engineering work
requiring specialized equipment and training
personnel unavailable to the Government but
not involving the exercise of discretion on
behalf of the Government, where the
contractor performs work adequately
described in the contract, free of
Government supervision;
— Contract with an individual for delivery of
lectures without Government supervision., at
specific places, on specific dates, and on a
specialized subject 1 even if payment is by
the hour.
It is recognized that during the course of a response the
distinction between providing personal and nonpersonal
services may be unclear. For example, directing the ERCS
contractor is not the responsibility of the TAT
contractor; however, monitoring its performance is
acceptable. Should questionable situations 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 Zone Program Management Office (ZPMO), TAT P0, or
TAT CO may be contacted.
1.7 Contract Equipment
In order to perform the diverse tasks required under
the TAT contract, each TAT will be furnished equipment for
monitoring, safety and recordkeeping. Appendix B contains
a detailed listing of the minimum equipment needs required
to implement the contracts. The TAT contractor is
responsible for the maintenance of all equipment and
ensuring that disposable equipment inventories are
maintained and replenished as required. Should the TAT
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OSWER Directive 9242.4—O1A September 1987
contractor determine that certain equipment is not being
utilized, the TAT Zone Program Manager (ZPM), in
coordination with the DPO, should be notified that the
equipment is available for use in other TAT offices.
If new equipment requirements are identified as EPA
missions change, the TAT contractor (with DPO concurrence)
may request this new equipment by sending a written
request for its purchase to the P0. This request should
include justification of the needs, estimated cost and
recommended source. The DPO should consult with Chapter 5
of EPA’s Contract Management Manual for further
information on justification of needs. EPA may either
provide the required equipment to the contractor or
authorize the contractor to acquire it under the TAT
contract.
1.8 Property Management
The use of property provided either directly by the
Federal Government or procured through the TAT contracts
requires careful management. Not only is careful property
management required by Federal law and the TAT contracts,
it is essential for efficient use of contract resources.
For example, accurate property inventories allow the TAT
contractor management to distribute equ-ipment among its
offices in the most useful way.
In light of the importance of property management . the
TAT contractor is required to provide training in property
management for TAT property management officers at the
ZPMO 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 by conducting
periodic on—site visits to the contractor’s office and
reviewing all of the items contained on the DPO checklist,
presented in Appendix E. The DPO should also seek the
assistance of the EPA Superfund Property Administrator, as
necessary, in conducting these visits.
Both the TAT contracts and Federal regulations
(Federal Acquisition Regulation. Part 45) require written
standard operating procedures for property management.
The TAT must develop standard procedures in the following
areas:
Acquisition
Receiving
Recordkeeping
Storage, movement and protection
Loss, damage and destruction
Utilization rate
Maintenance and calibration
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OSWER Directive 9242.4—OlA September 1987
• Inventory
• Subcontractor use
• Contract closure and equipment disposition.
Development and use of these procedures are essential for
managing property under the TAT contracts.
Standard procedures will also aid in preparing the
periodic reports requested by the EPA Property
Administrator. To ensure proper handling of Government
property, the EPA Property Administrator requires the
following information from TAT property management
officers:
• Annual inventory of property
Immediate reports of loss, damage or destruction
of Government property
Requests for purchase or replacement of
Government property (as needed)
Semi—annual reports of Government property in
excess of needs
Justification for retention of low use items
(annually)
Certification of required training of property
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.
2. CONTRACTOR REQUIREMENTS IN EXECUTING SOW ACT IVIT IES
The following sections describe special contract
requirements to which the TAT contractors must adhere.
Included are discussions on health and safety, training,
quality assurance, confidentiality, conflict of interest,
chain—of—custody, cost management, and 24—hour call center.
2.1 Health and Safety
The nature of the work to be performed under the TAT
contracts may involve inherently hazardous situations.
The OSC is responsible for coordinating the standards of
safety for all individuals on—site at all times. The TAT
contractor, if required to work on—site, shall ensure that
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OSWER Directive 9242.4—O1A September 1987
all contractor personnel working at the site work in a
healthy and safe manner and adhere to the standard EPA
safety protocols as well as appropriate Federal/State
health and safety standards (i.e., 29 CFR 1910.120). It
is Office of Solid Waste and Emergency Response (OSWER)
draft policy that the contractor shall be responsible for
implementing the Office of Emergency and Remedial Response
(OERR) Standard Operating Safety Guides (SOSG) for its
employees and operations, including employee rights to
know. If the contractor believes that a higher level of
protection is necessary, or there is any other dispute
with respect to health and safety that cannot be resolved
between the OSC and the contractor’s Health and Safety
representative the matter will be referred to the
Response Operations Branch Regional Coordinators and to
the contractors corporate Health and Safety
representative for determination. If the health and
safety issue still cannot be resolved, then the matter
will be referred to the EPA Environmental Response Teams
(ERT) Safety and Occupational Health Manager, Edison,
N.J., in consultation with the HQ Occupational Health and
Safety Director, for final determination.
If a specific safety plan is required as part of
performance of a Technical Direction Document (TDD), or
such plan is required as part of standard operating
procedure, this plan shall be submitted to the OSC for
review. Upon review, if there is a dispute over the
safety plan that cannot be resolved between the OSC and
the contractors Health and Safety representative, the
matter shall be referred to the first line approval
committee, which is the Response Safety Committee
described in EPA Order 1440, Chapter 9. If there is still
a dispute over the safety plan, then the matter shall be
referred to the EPA ERT’s Safety and Occupational Health
Manager, Edison, N.J., in consultation with the HQ
Occupational Health and Safety Director, for final
determination. If a site safety plan is provided by the
Government, the contractor agrees to follow such a plan
unless objections are made known to the OSC within 24
hours of its submission to the contractor. In any event,
commencement of cleanup services without notification to
the OSC of objections will be deemed to constitute
acceptance of the safety plan, unless conditions in the
field change to warrant a change in the plan.
The Occupational Safety and Health Administration has
issued the “Hazardous Waste Operations and Emergency
Response Rule” (December 19, 1986), which sets forth the
following required elements for site safety plans:
Names of key personnel and health and safety
personnel
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OSWER Directive 9242.4—O1A September 1987
• Task/operation safety and health risk analysis
• Employee training for all equipment operators and
general laborers who risk exposure to hazardous
mater ials
• Personal protective equipment to be used
• Medical surveillance program
• Frequency and types of air monitoring, personnel
monitoring, and sampling techniques
• Site control measures
• Decontamination procedures
• Site standard operating procedures
• Contingency plan
• Confined space entry procedures.
2.2 Training Program for Contractor Personnel
The TAT contractor is responsible for providing
initial and routine training of workers before such
workers are permitted to engage in hazardous waste
operations that would expose them to toxic substances.
The requirements include a minimum of 40 hours of initial
instruction off the site, and a minimum of three days of
actual field experience under the direct supervision of a
trained, experienced supervisor, at the time of
assignment. These requirements however, do not apply to
workers who have already received the equivalent of such
training. Workers who may be exposed to unique or special
hazards should be provided additional training.
2.3 quality Assurance
The TAT contractor shall institute a quality assurance
program that will ensure environmental monitoring data of
known quality. The program will consist of both an
auditing and a corrective function. The auditors will
report directly to the contractor corporate management,
bypassing the contractor ZPM, 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” (qANS—004/80) contains detailed
information on EPA’s quality assurance program and can be
obtained from the Assistant Administrator for Research and
Development in the Office of Monitoring Systems and
quality Assurance.
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OSWER Directive 9242.4—O 1A September 1987
2.4 Confidentiality of Information
During the performance of the contract, TAT members
may, by necessity, be entrusted with confidential
information. All information received by EPA is subject
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.
In response to an initial submission of information
with a request of confidentiality from a responsible
party, private industry or any person or business, all EPA
personnel and contractor employees should be aware of the
proper procedures. All information requested by EPA for
which a confidentiality claim is asserted must be
submitted to the DPO or P0. Any person submitting
information to EPA may assert a business confidentiality
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 confidentiality 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 Office of Regional Counsel should be contacted to
pursue the proper legal course.
2.5 Conflict of Interest
The TAT contractor must notify the cognizant DPO “in
writing” of any actual, apparent or potential conflict of
interest with regard to any work assigned by the DPO prior
to accepting that work. This includes both personal (TAT
staff) and organizational conflicts of interest. The DPO
is then responsible for notifying the CO of this conflict.
If an organizational conflict of interest appears to
exist, the CO is responsible for determining whether the
contractor should be permitted to perform the work. The
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OSWER Directive 9242.4—OlA September 198J
Co will then notify the ZPM in writing of this
determination. If a personal conflict of interest appears
to exist, the individual TAT member who is affected will
be disqualified from taking part in any way in the
performance of the work.
The TAT contractors are required to notify each DPO in
advance of all known sites within a Region where an
organizational or personal conflict of interest may
exist. In cases where the conflict of interest does not
become known until after performance of the work has
begun, the contractor is required to notify the Co
immediately and to discontinue work until notified by the
CO of the appropriate action to be taken.
2.6 Chain—of—Custody and Document Control Procedures
Any work conducted by the TAT contractor must follow
established chain—of—custody and document control
procedures. Detailed information pertaining to procedures
for each of the areas is available in NEIC Policies and
Procedures , EPA—330/9/78/OOl—R, U.S. Environmental
Protection Agency, National Enforcement Investigations
Center (NEIC), Denver, Colorado, revised June 1985.
Copies of this document should be obtained by all EPA
Regional offices and be distributed 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 addition, Regions may establish their
own specific procedures for ensuring that the NEIC
chain—of—custody and document control requirements are met.
2.7 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 monitoring the costs.
This management system must ensure the efficient use of
public funds and enable all removal costs to be measured
against the site—specific and statutory ceilings. The
system recommended for use by OSCS is presented in the
Removal Cost Management Manual , January 1985 (revised
August 1987). This manual outlines a comprehensive 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 practices outlined in this manual.
Another EPA manual, User s Guide for Removal Cost
Management Software (Version 3.0), was developed in
conjunction with the cost management manual to describe
the application of basic computer tools to cost estimating
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OSWER Directive 9242.4—O1A September 1987
and cost tracking at CERCLA removal sites. The TATs
should also be familiar with this manual, which can be
very useful for on—site cost management. Additional
guidance on the TATs role in site cost tracking and
verification will be provided by EPA in the future.
2.8 24—Hour, 7—Day—A—Week Call Center
The TAT contractors are 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.
2.9 Subcontracting
As part of the TAT zone contracts, the contractor is
responsible for performing special projects and analytical
services. In most cases, the contractor will subcontract
this type of work utilizing competitive acquisition
procedures as required by the Competition in Contracting
Act. DPOs should ensure that reasonable lead times and
delivery—schedules are given so as not to unnecessarily
restrict the contractors efforts to obtain competition.
According to Federal Acquisition Regulation (FAR)
52.244—2, the contractor must notify the Contracting
Officer (CO) reasonably in advance of entering into any
subcontract if:
The proposed subcontract is of the
cost—reimbursement, time—and—materials, or
labor—hour type;
The proposed subcontract is fixed—price and
exceeds either $25,000 or five percent of the
estimated cost of this contract;
The proposed subcontract has experimental,
developmental or research work as one of its
purposes; or
The proposed subcontract provides for the
fabrication, purchase, rental, installation or
other acquisition of special test equipment
valued in excess of $10,000 or of any items of
facilities.
Upon notification of the CO, the contractor may be
requested to provide EPA with certain information such as
a description of the services to be subcontracted,
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OSWER Directive 9242.4—O1A September 1987
identification of the type of subcontract to be used, and
an explanation of why and how the proposed subcontractor
was selected, including the competition obtained.
According to FAR 52.244—5, the contractor shall select
subcontractors on a competitive basis to the maximum
extent consistent with the objectives and requirements of
the contract.
Depending on the dollar amount and type of subcontract
involved, the contractor must obtain the CO’s written
consent before placing any subcontract for services under
the TAT contracts.
2.10 Site—Specific Invoicing
The contractor is required to provide site—specific
billing information on monthly invoices in accordance with
EPAs “Site—Specific Invoicing Requirements for Superfund
Contractors Whose Funds Are Not Obligated Site—
Specifically , February 1986. All invoices sent to EPAs
Financial Management Division (FMD) for payment must
contain proper site and activity codes, as well as the
following additional requirements:
A cost element summary that summarizes all costs
being invoiced by cost element, such as labor,
travel, equipment, other direct, subcontractor
and overhead or indirect costs, as identified
elsewhere in the contract
A site—specific attachment, on which the invoiced
costs are broken down by:
— Each site with an EPA S/S ID
— All other sites, i.e., those without an EPA
S/S ID, on one line item per Region
— Program management
— Base and award fees
— Non—site activities, identified separately
such as training of state personnel or
coordination of Regional activities
— Non—Superfund costs, as applicable, on one
line item.
Specific instructions on completing the site—specific
invoice can be found in the above—mentioned publication.
The TAT contractor is required to submit four copies of
the invoice, one to the P0 and three to FMD.
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OSWER Directive 9242.4—O1A September 1987
EXHIBIT 11—1
TAT Personnel Qualifications and Levels of Experience
Professional Level
Zone Program Manager (ZPM)
— Masters Degree or equivalent with 12 years
or more relevant experience
— Bachelors Degree with 14 years or more
relevant experience
• Level Three
— Masters Degree or equivalent
— 6—12 years relevant experience
• Level Two
— Bachelors Degree or equivalent
— 3—8 years relevant experience
• Level One
— Bachelors Degree or equivalent
— 0—3 years relevant experience
Technical Level
• Level Three
— 6 or more years relevant experience
• Level Two
— 2—6 years relevant experience
• Level One
— 0—2 years relevant experience
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OSWER Directive 9242.4—O1A September 1987
EXHIBIT 11—2
TAT Contract Staff ing Distribution
Number of
Zone 1 Personnel
Region I 16
Region II 35
Region III 45
Region IV 33
Region V 36
Headquarters 11
ERT—Edison 5
TOTAL 181
Zone 2
Region VI 35
Region VII—ESD 29
Region VI1—WMD 1 1
Region VIII 10
Region IX 23
Region X 12
TOTAL 120
GRAND TOTAL 301
NOTE: The above staffing numbers are initial estimates
subject to change as EPA Regional needs develop.
Therefore, they will fluctuate during the contract
period of performance.
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OSWER Directive 9242.4—O1A September 1987
EXHIBIT 11—3
TAT Staffing Disciplines
Administrative Assistant
Administrative Technician
Biological Technician
Biologist
Chemical Engineer
Chemist
Civil Engineer
Community Relations Specialist
Computer Programmer
Computer Systems Analyst
Emergency Contingency Planner
Engineer
Engineering Technician
Environmental Air Pollution Specialist
Environmental Biologist
Environmental Engineer
Environmental Scientist
Equipment Technician
Geohydrologist
Geologist
Groundwater Engineer
Hydrogeologist
Hydrologist
Industrial Hygienist or Toxicologist
Interdisciplinary Scientist
Laboratory Technician
Organic Chemist
Personal Computer Specialist
Program Analyst
Response Specialist
Sanitary Engineer
Spill Prevention Engineer
Toxicologist
Writer/Editor
NOTE: The above disciplines are subject to change as EPA
Regional needs develop. Therefore, they will
fluctuate during the contract period of performance.
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OSWER Directive 9242.4—O1A September 1987
CHAPTER III
CONTRACT MANAGEMENT: ORGANIZATION, ROLES
AND RESPONSIBILITIES
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OSWER Directive 9242.4—O1A September 1987
CHAPTER III
CONTRACT MANAGEMENT: ORGANIZATION, ROLES
AND RESPONSIBILITIES
KEY TOPICS
Page
• Relationship Between EPA Headquarters 111 —2
and Regional Offices
• Contract Management Structure Within 111—4
EPA Headquarters
• TAT Project Officers 1 1 1—4
• TAT Contracting Officer 1 1 1—5
• Headquarters TAT Deputy Project Officer 111—5
• Contract Management Structure Within 111—6
EPA Regional and ERT Offices
• TAT Deputy Project Officers 111—6
• On—Scene Coordinators 111—7
• TAT Contractor Management Structure 11 1—8
• TAT Zone Program Manager (ZPM) 111—8
• Technical Assistance Team Leaders 1 11—9
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OSWER Directive 9242.4—OlA September 1987
CHAPTER III
CONTRACT MANAGEMENT: ORGANIZATION, ROLES
AND RESPONSIBILITIES
The Agency’s internal organization for managing the
TAT contract is a critical element contributing to the
Emergency Response Division’s (ERD) successful
implementation of the program. In other parts of this
manual, details are given concerning the management and
operating procedures that will be used to manage the TAT
contractors. Here, the discussion focuses on the contract
management structure and the roles and responsibilities of
EPA Headquarters and Regional personnel that will provide
the framework and network for ensuring that the procedures
are followed. Key interactions between Agency and TAT
contractor personnel are also highlighted.
The chapter is divided into four sections:
Relationship between EPA Headquarters and
Regional offices
Contract management structure within EPA
Headquarters
Contract management structure within EPA Regional
offices
TAT contractor management structure
1. RELATIONSHIP BETWEEN EPA HEADQUARTERS AND REGIONAL
OFFICES
There are two levels of management that must be
provided by the Agency in order to successfully plan,
execute, and control the work performed by the TAT
contractors. These two components of the EPA contract
management framework consist of: 1) overall contracts
management and program direction, centered in EPA
Headquarters; and 2) technical oversight and project
management, which is the responsibility of each individual
EPA Regional office and the Environmental Response Team
(ERT) in Edison, New Jersey. These two levels of
management work together to ensure that utilization of the
TAT contract resources is consistent with planned
Superfund program goals and objectives.
Exhibit I ll—i provides an overview of the EPA
Headquarters and Regional management structure that will
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OSWER Directive 9242.4—O1A September 1987
be utilized to manage the two TAT contracts. The exhibit
also depicts the key interactions between EPA and TAT
contractor management personnel. This section will focus
on the relationship between Headquarters and the Regions
and will summarize the responsibilities of each. The
contract management structure within EPA Headquarters and
Regional and the ERT offices, and the roles and
responsibilities of key Agency contracts management
personnel are discussed in subsequent sections.
Within EPA Headquarters, ERD is charged with overall
management responsibility for the TAT contract. ERD
oversees total resource utilization of the TAT contract
and coordinates implementation of the contract through the
EPA Regional offices. Basically, Headquarters contract
management is concerned with the consistency of the
services to be performed on a zone—wide basis as specified
within the Statement of Work (SOW) of the two contracts.
In addition, Headquarters must ensure that the TAT
contractors adhere to all established Agency or other
Federal regulations, procedures and guidelines. Also,
within Headquarters there is a Headquarters TAT support
function that is responsible for developing and
lmplementing guidance, strategies, briefings, regulations,
public inquiry responses, and other related activities.
Complementing the Headquarters overall contract
management structure are the Regional contract management
responsibilities of each individual EPA Regional office
and the ERT office. The EPA Regional offices and the ERT
office provide the mechanism to extend EPA Headquarters
contract management into the field. This is accomplished
by the direct oversight of the TAT contractors’ completion
of and performance on various tasks, projects, and
activities assigned to them.
Effective and efficient direction and utilization of
contract resources depends on the establishment of a close
working relationship among the Project Officer (P0), the
Headquarters staff, and the Regional Deputy Project
Officers (DPOs). To successfully implement the program,
the PC, DPOs and other appropriate EPA staff must rely on
each other for input on matters such as:
TAT program policy and guidance development and
implementation
Resolution of contract management issues
Project tracking and performance monitoring and
evaluation
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OSWER Directive 9242.4—O1A September 1987
• Coordination with overall Superfund goals and
objectives
• Utilization of, and balance between, EPA
resources and contract resources, including
setting priorities.
The working relationship will be fostered through the
frequent exchange of information both nationally and
locally at periodic, scheduled meetings, as well as
regular discussions among EPA personnel and, as required,
discussions with contractor personnel.
The following sections describe in greater detail the
organization, roles and responsibilities of the EPA
Headquarters P0, Co and DPO, Regional and ERT office DPOs,
and TAT contractor management personnel.
2. CONTRACT MANAGEMENT STRUCTURE WITHIN EPA HEADQUARTERS
2.1 TAT Project Officers
As was shown in Exhibit 111—1, the POs will serve
as the EPA officials with overall responsibility for
managing and directing technical activities under the
TAT contracts. As such, the POs provide a single
point of contact for the Contracting Officer (CO) and
the TAT contractors. The POs will interface directly
with the two TAT contractor Zone Program Managers
(ZPMs), the Headquarters TAT Leader, and the EPA
Regional and ERT DPOs. Key responsibilities of the
POs include:
General oversight of program management,
operations. direction, and coordination
Together with the CO. assessment of the
adequacy, amount and distribution of
contract resources within and across TATs
(e.g., personnel, funding, equipment)
including decisions regarding propriety and
timing of exercising contract options
Development of guidance on integrating TAT
contract activities with other Superfund
program requirements
Solicitation of comments and analyses of
significant technical and contract
management items or problems from both EPA
and contractor personnel
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OSWER Directive 9242.4-O 1A September 1987
• Review of contractor monthly financial and
technical progress reports
• Evaluation of contractor performance by
Headquarters Evaluation Coordinator for the
Award Fee Performance Evaluation process
• Resolution of issues arising within and
between Headquarters and Regional and ERT
offices.
2.2 TAT Contracting Officer
Corresponding to the program management
responsibilities of the P0. the CO is the offacial
within Headquarters with overall responsibility for
ensuring that: 1) the TAT contractors adhere to the
terms and specifications of the contract; and 2) the
TAT contractors provide the necessary personnel,
equipment, and services to provide EPA with the
support specified in the SOW. The CO will coordinate
with the P0 and ZPM to produce and maintain the TAT
contractual mechanism. As such, the CO is the only
Federal representative authorized to make changes to
the contract.
2.3 Headquarters TAT Deputy Project icer
The Headquarters DPO is responsible for
overseeing the activities of the Headquarters TAT
contractor. This involves making sure that the
Headquarters TAT contractor is fully utilized in
providing technical. planning and operations support
to EPA Headquarters.
The Headquarters DPO is responsible for
interfacing directly with the Headquarters TAT Leader
and for assigning all Headquarters—related work to the
TAT Zone I contractor. This work will consist
primarily of developing and implementing guidance.
strategies. briefings, regulations, public inquiry
responses. and other related activities as needed.
Other responsibilities of the Headquarters DPO
include:
Monitoring Headquarters TAT contractor
performance
Completing Performance Observation Reports
(POR 5)
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OSWER Directive 9242.4—O1A September 1987
• Implementing Headquarters contract
management policy and technical guidance
• Receiving and reviewing all contractor
reports (e.g., monthly financial and status
reports) for accuracy.
3. CONTRACT MANAGEMENT STRUCTURE WITHIN EPA REGIONAL AND
ERT OFFICES
3.1 TAT Deputy Project Officers
The EPk Regional offices and the ERT office are
charged with the day—to—day oversight of the TAT
contractors work in the field. In this sense, they
will ensure that program policy, procedures, goals and
objectives are carried out and met by the contractors
with respect to specific assignments. Within each EPA
Regional and ERT office, TAT DPOs will have program
management responsibilities for planning, executing
and controlling the utilization of dedicated TAT
resources.
When the DPO (including the Headquarters DPO)
plans to be out of the office and unavailable to
perform contract management functions, the DPO must
submit a written request, or telephone the TAT P0 and
CO, for approval to appoint a temporary assistant DPO
to act on his/her behalf for a discrete period of time .
The DPO will interface directly with the TAT
Leader. The DPOs will ensure that the TAT located in
their Region provides the On—Scene Coordinators (OSCs)
with necessary technical support during emergency
responses. The DPOs other responsibilities include:
Provide TAT technical direction and oversight
Issue TAT work orders [ e.g., Technical
Direction Documents (TDD5)]*
Track TAT project performance against
required schedules, budgets, and procedures
* The DPO cannot request specific contractor personnel
to work on individual TDDs.
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OSWER Directive 9242.4—O1A September 1987
Complete Acknowledgement of Completion/
Performance Observation Report (AOC/POR)
forms for the Regional Award Fee Performance
Evaluation package (see Chapter VII)
• Implement Headquarters and Regional contract
management policy and technical guidance
• Receive and review all contractor reports
(e.g., monthly financial and status reports)
for Regional accuracy.
Effective management of the TAT contract by the DPO
translates into efficient utilization of the TAT
contract resource.
3 . 2 On—Scen& Coordinators
The On—Scene Coordinator (OSC) is the Federal
official responsible for monitoring and directing all
activities conducted on site during a removal action.
The basic duties, activities and functions of an OSC
include the following:
Assess degree of threat
• Develop Action Memos
Direct response operations
Ensure site safety
Review and certify contractor cost reports
Coordinate with state, local, or Federal
agency personnel
Prepare work reports
Participate in community relations activities
Determine project status
Monitor contractor performance
Write pollution reports
• Maintain site files (cost recovery
documentation)
Track project budgets against ceilings
Control site access.
The OSC is responsible for establishing the
standards of safety for all individuals on—site at all
times. If required to work on site, the TAT shall
ensure that all TAT contractor personnel working at
the site follow the direction of the OSC with regard
to health and safety to include the required level of
protection. The ERTs Safety and Occupational Health
Manager makes the final determination concerning
safety. (Please note that an “appeals” procedure is
being developed and will be issued soon).
1 11—7
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OSWER Directive 9242.4—O1A September 1987
In addition, the OSC receives and evaluates
site—related financial reports that itemize daily
costs, and may be requested from the TAT within
twenty—four hours. To monitor contractor progress,
the OSC reviews ERCS contractor cleanup activity
reports.
4. TAT CONTRACTOR MANAGEMENT STRUCTURE
Until recently, the contractor for the TAT program has
served on a nationwide basis. EPA has modified TAT to be
a zone—based program, in which each zone contractor is
responsible for providing assistance in discrete areas of
the country. Organization of the Zone 1 and Zone 2
contractor personnel is shown in Exhibits 111—2 and 111—3,
respectively. Within each zone, the contract specifies
the following minimum key management positions for the TAT
contractors internal organization: 1) a Zone Program
Manager (ZPM), and 2) a TAT Leader for each of the TATs
(seven TATs in Zone 1 and six TATs in Zone 2). (In
practice, each TAT contractor has other ZPMO personnel who
assist the ZPM). The roles and responsibilities of these
contract—specific managers are highlighted below.
4.1 TAT Zone Program Manager (ZPM )
The ZPM shall be the single point of contact for
coordination with the P0, and be responsible for the
planning and execution of all tasks performed under
the contract. Specific responsibilities of the ZPM
include the following:
Manage the TAT Leaders at each location and
provide assistance to procure staff for each
needed team position
Provide overall supervision and
administrative support to the TAT Leaders
Monitor incurrence of costs and expenditures
of funds throughout the duration of the
contract
Develop procedures and forms as required for
execution of the program, uniformity of
recordkeeping, and project management
documentation among the TATs
Prepare and submit reports as specified in
the contract schedule and establish
procedures for the preparation and
submission of required reports by the TAT
Leader
111—8
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OSWER Directive 9242.4—OlA September 1987
Maintain separate accounting for all
assignments designated as special projects,
and site—specific accounting for work
performed in conjunction with assignments to
support the Regions during cleanup operations
• Provide a detailed explanation of how
indirect rates are determined for use as
documentation in cost recovery litigation
• Implement procedures to ensure that all
reports prepared by the ZPMO or by the TAT5
are of high quality and meet the content and
format requirements of the contract
• Meet on a monthly basis with the P0 and Co
to discuss contract status -
• Accompany the P0 during each EPA Regional
management review of the Regional TAT5
• Ensure adherence to channels of
communication in accordance with the project
organizational links (see Exhibits 111—2 and
111—3)
• Comply with all requirements for control of
property as illustrated by Part 45 of the
Federal Acquisition Regulations
4.2 Technical Assistance Team Leaders
Each TAT Leader is responsible for the overall
management and maintenance of the TAT office, the
direct supervision of TAT members, and ensuring
quality in the performance and timely completion of
tasks specified in TDDs issued by the Regional DPO.
Additional responsibilities include:
Coordination with the ZPM and Regional DPO
Submission of monthly status reports and
activity completion reports
Completion of AOC/POR 5 for contractor input
to the Regional Award Fee Performance
Evaluation package.
111—9
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EXHIBif Ill-I
EPA-CONTRACTOR TAT MANAGEMENT STRUCTURE
I
I I
THERE ARE I3TAT-DPOS RESPONSIRLE FOR OVERSEEING AND DIRECTING WORK ORDERS TO EACH OF 13 TAT.
(7 TAT. ASSOCIATED WITH ZONE I AND 6 TAT. ASSOCIATED WITH ZONE 2). ONE TAT IS ASSOCIATED WITH
EACH OF THE TEN REGIONAL OFFiCES (PLUS ONE ADDITIONAL TAT UI REGION VII), ONE TAT IS ASSOCIATED
WITH ThE ENViRONMENTAL RESPONSE TEAM IN EDISON. NEW JERSEY, AND ONE TAT PROVIDES DIRECT SUPPORT
CONTRACTING
OFFICER
PROCUREMENT AND
CONTRACTS MANAGEMENT
DIVISION
WASHINGTON, D.C.
CONTRACTOR
ZONE
PROGRAM
MANAGER
ZONE 1
(REGIONS I - V ERT
AND HO)
EPA TAT
PROJECT OFFICER
EMERGENCY RESPONSE DIVISION
OFFICE OF EMERGENCY AND
REMEDIAL RESPONSE
WASHINGTON. D.C.
EPA TAT
PROJECT OFFICER
EMERGENCY RESPONSE DIVISION
OFFICE OF EMERGENCY AND
REMEDIAL RESPONSE
WASHINGTON, D.C.
CONTRACTOR
ZONE
PROGRAM
MANAGER
ZONE 2
(REGIONS VI- X)
EPA REGIONAL
DPOV
CONTRACTOR
TAT
LEADERS
(REGIONS VI. X)
1
‘ .0
-J
TO EPA HEADQUARTERS.
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OSWER Directive 9242.4—O1A September 1987
EXHIBIT 111-2
ORGANIZATION OF ZONE 1 TAT CONTRACT
EPA
ONTRAC11NG
OFFICER
CONTRACTOR I
I I j ZONE PROGRAM
MANAGER (ZPM)
EPA _______________
PROJECT
OFFICER
__ I
HEADQUARTERS HEADQUARTERS
DEPUTY
PROJECT OFFICER [ DE ———
PROJECT OFFICER TAT LEADER
DEPUTY TOERT
ERT TAT ASSIGNED
REGION I TAT/REGION I
DEPUTY
PROJECT OFFICER - - TAT LEADER
I PUERTO RICO
SATELLITE
REGION U
DEPUTY TAT/REGION II
TAT LEADER
PROJECT OFFICER
I WHEELING
SATELLITE
REGION III
DEPUTY TAT/REGION IN
TAT LEADER
PROJECT OFFICER
_____________________ MEMPHIS
sATEu.rrE
DEPUTY ______________
REGION IV [ - TAT/REGION IV
TAT LEADER
PROJECT OFFICER
LOUISVILLE
SATELLITE
_______ CLEVELAND
SATELLITE
DEPUTY ______________
REGION V ______________ TAT/REGION V
TAT LEADER
PROJECT OFFICER
DETROIT
SATELLITE
IN INNATI
SATELLITE
PROJECT ORGANIZA11ON CCNTROL
- - PROJECT COORDINATION UNKS
hI— h
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OSWER Directive 9242.4—O1A
September 1987
EPA
CONTRACTING
OFFICER
EPA
PROJECT
OFFICER
REGION VI
DEPUTY
PROJECT OFFICER
REGION VII (ESD)
DEPUTY
.PROJECT OFFICER
REGION VII (WMD)
DEPUTY
PROJECT OFFICER
PROJECT COORDINATION UNKS
EXHIBIT 111-3
ORGANIZATION OF ZONE 2 TAT CONTRACT
CONTRACTOR
ZONE PROGRAM
MANAGER (ZPM)
HOUSTON
SATELLITE
P BATON ROUGE
SATELLITE
TAT/REGION VI
TAT LEADER
TAT/REGION VII (ESD)
TAT LEADER
REGION VIII
DEPUTY
PROJECT OFFICER
TAT/REGION VII (WMD)
TAT LEADER
REGION IX
DEPUTY
PROJECT OFFICER
TAT/REGION VIII
TAT LEADER
REGION X
DEPUTY
PROJECT OFFICER
TAT/REGION IX
TAT LEADER
- -- LOS ANGELES
SATELLITE
PROJECT ORGANIZAI1ON CONTROL
TAT/REGION X
TAT LEADER
111—12
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OSWER Directive 9242.4 —O 1A September 1987
CHAPTER IV
INTERFACE WITH OTHER EPA CONTRACTS AND PROGRAMS
AND EXTERNAL AGENCIES
-------
OSWER Directive 9242.4—O1A September 1987
CHAPTER IV
INTERFACE WITH OTHER EPA CONTRACTS AND PROGRAMS
AND EXTERNAL AGENCIES
KEY TOPICS
Page
• National Contract Laboratory Program (NCLP) IV—2
• Remedial Planning and Field Investigation IV—3
Team (FIT) Contracts -
• Technical Enforcement Support (TES) IV—4
Contracts
• Emergency Response Cleanup Services (ERCS) IV—5
Contracts
• Alternative Remedial Contract Strategy IV—5
(ARCS)
• Underground StOrage Tanks (UST) Program IV—6
• State and Local Agencies, the U.S. Coast IV—6
Guard (USCG) and other Federal Agencies
‘V-i
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OSWER Directive 9242.4—OlA September 1987
CHAPTER IV
INTERFACE WITH OTHER EPA CONTRACTS
AND EXTERNAL AGENCIES
There are six other EPA contract and program efforts
that complement the TAT contract program:
• National Contract Laboratory Program (NCLP)
contracts
• Remedial Planning (REM) and Field Investigation
Team (FIT) contracts
• Technical Enforcement Services (TES) contracts
• Emergency Response Cleanup Services (ERCS)
contracts
• Alternative Remedial Contract Strategy (ARCS)
• Underground Storage Tanks (UST) program.
In addition, significant interaction may occur between
the TAT contractor and:
• State and local agencies
United States Coast Guard (USCG)
Other Federal agencies (e.g. DOI) on a
site—specific basis.
The following sections provide a description of, and/or
highlight procedures for utilizing and interfacing with
each of the above contracts, programs or agencies.
1. NAT I ONAL CONTRACT LABORATORY PROGRAM (NCLP )
Chemical analytical support is essential to the
successful investigation and cleanup of spills and
hazardous substances sites. To meet this requirement, EPA
has established a nationwide network of contract
laboratories under the National Contract Laboratory
Program (NCLP). Wholly funded with CERCLA funds, the
NCLP’s purpose is to provide analytical data for samples
collected at sites to identify threats to public health
and the environment, base assessments of risk, institute
remedial response, and initiate response actions.
IV-2
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OSWER Directive 9242.4—OlA September 1987
The TAT contractor is encouraged to use the NCLP for
all analytical services except when samples can be
analyzed by EPA Regional labs. The TAT contractor should
contact the Regional Sample Control Center to confirm the
availability of services under the NCLP or the
Environmental Services Division. If specific services
cannot be provided by the NCLP, or if services are not
available on a timely basis, the TAT contractor may
subcontract for laboratory analytical services. When the
TAT contractor subcontracts the analytical services,
maximum competition must be obtained in accordance with
Federal Acquisition Regulations. Further, the TAT
contractor is responsible for implementing a plan for
quality assurance. That plan has to provide quality
assurance/quality control comparable to that required
under the NCLP, where analysis is being done by a non—NCLP
laboratory.
Work conducted by the NCLP is coordinated by a
contractor, the Sample Management Office (SMO). In its
efforts to match the analytical needs of the NCLP users
with appropriate contractor laboratories, the SMO has
developed a manual entitled User s Guide to the National
Contract Laboratory Program , December 1986. In addition
to describing procedures for using the NCLP, the manual
provides a complete description of all analytical
services, sample requirements, and reports offered under
the program. This is an extremely useful document and
should be referred to in assessing analytical service
-needs. For further information regarding the NCLP, write
or call: Hazardous Site Evaluation Division (WH—548A),
U.S. EPA, Washington, D.C. 20460, 202/382—7906 or
FTS 8—382—7906.
2. REMEDIAL PLANNING AND FIELD INVESTIGATION TEAM
CONTRACTS
The REM and FIT contracts provide technical and
management support for EPAs field investigation and
remedial planning activities at selected uncontrolled
hazardous substance sites. Field investigation and
remedial planning activities are divided among four
program areas including:
Field investigation (e.g , pre—remedial
preliminary assessments and remedial site
inspections of hazardous substance sites)
Remedial planning activities involving the
identification, evaluation and recommendation of
remedial response options (e.g., remedial
investigation and feasibility study)
IV-3
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OSWER Directive 9242.4—OlA September 1987
Implementation of certain non—time—critical
removal measures (e.g., Expedited Response
Actions)
Technical and management support activities
including enforcement support and community
relations.
The interface of TAT, and REM and FIT activities can
exist in the following instances:
Removal is required based on the findings made
during the conduct of field investigation
activities
Determination of a remedial action may be
required after a removal has been completed -
Emergency response must be initiated based on a
change at a site where remedial planning or
action is in progress.
Full cooperation between the personnel of these contracts
is essential. Coordination of the Regional TAT DPO, REM,
and FIT Regional Project Officers (RPOs), EPA Remedial
Project Managers (RPMs), and/or contractor efforts will
ensure a timely response to remedial sits situations. All
information regarding the status and technical evaluation
of conditions at a particular site must be communicated to
the appropriate party as warranted by a change in response
actions (i.e., removal to remedial or vice versa). For
further information regarding the REM contracts, write or
call: Hazardous Site Control Division, (WH—548E), U.S.
EPA, Washington, DC 20460; 202/382—2339 or
FTS 8—382—2339. For the FIT contracts, write or call:
Hazardous Site Evaluation Division (WH—548A), U.S. EPA,
Washington, D.C. 20460, 202/475—9748 or FTS 8—475—9748.
3. TECHNICAL ENFORCEMENT SUPPORT (TES) CONTRACTS
In addition to the technical enforcement support
provided by the TAT, REM and FIT contractors, EPA
enforcement requires other capabilities that are, in large
measure, unique to the enforcement function such as
private investigations, title searches, and acquisitions
and analyses of financial records. To obtain these and
similar capabilities, the EPA Office of Waste Programs
Enforcement (OWPE) engages the TES contractors to provide
the following services, which include, but are not limited
to:
IV-4
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OSWER Directive 9242.4—OlA September 1987
• Private investigations
• Risk/exposure assessments
• Responsible party searches
• Title searches
• Acquisitions and analyses of financial records
• Establishment of linkages among corporate entities
• General case development support.
There exists a strong potential for interaction
between the TAT contractors and TES contractors. General
management areas for coordination and communication should
be anticipated. For further information regarding the TES
Contracts, write or call: Office of Waste Programs
Enforcement (WH-527), U.S. EPA, Washington, DC 20460;
202/382—4830 or FTS 8—382—4830.
4. EMERGENCY RESPONSE CLEANUP SERVICES (ERCS) CONTRACTS
When initiating a removal action in response to a
hazardous substance release, the On—Scene Coordinator
(OSC) may require the services of the ERCS contractors for
containment, cleanup and disposal of the released
materials. Though the actual work of these cleanup
contractors is directed only by the OSC, TAT personnel may
assist the OSC by monitoring their progress and by
performing various cost control functions to verify and
document ERCS contractor costs. In this capacity, the TAT
contractor assumes only an advisory role to the OSC. Any
comments or suggestions from the TAT regarding the cleanup
contractor activities should be directed only to the OSC.
5. ALTERNATIVE REMEDIAL CONTRACT STRATEGY (ARCS )
OERR has recently developed the Alternative Remedial
Contracts Strategy (ARCS). The purpose of these contracts
is to obtain project management and technical services in
support of EPAs remedial response activities at
uncontrolled hazardous waste disposal sites. ARCS
establishes a pool of remedial response contractors
available in each Region or Multi—Regional Zone.
Contractor activities under ARCS are similar in scope to
the REM contracts described above. ARCS includes remedial
investigation, feasibility studies, remedial design, and
remedial construction.
There exists a potential for interaction between TAT &
ARCS contractors; when working on the same site,
communication and coordination between these contractors
should occur. For further information regarding ARCS,
write or call: Hazardous Site Control Division (WH—548E),
U.S. EPA, Washington, D.C. 20460, 202/382—2347 or
FTS 8—382—2347.
IV-5
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OSWER Directive 9242.4—O1A September 1987
6. UNDERGROUND STORAGE TANKS (UST) PROGRAM
Under the Superfund Amendments and Reauthorization Act
of 1986 (SARA), EPA’S Office of Underground Storage Tanks
(OUST), or a state agency under Cooperative Agreement with
EPA, has been given authority to undertake corrective
action with respect to any release of petroleum into the
environment from an underground storage tank if such
action is necessary to protect human health and the
environment. A Leaking Underground Storage Tank Trust
Fund (LUST) of $500 million has been established to
provide funds for these corrective actions.
In responding to petroleum releases from underground
storage tanks, the OSC in charge of the Federal response
may use the TAT, as well as the ERCS contractor, to
provide assistance in carrying out the cleanup effort.
The type of assistance provided by the TAT contractor may
be similar to that provided under the CERCLA and CWA 311
programs (i.e., contractor oversight, response monitoring,
site assessment, etc.). However, OSWER Directive
9360.0—16A (Guidance for Conducting Federal-Lead
Underground Storage Tank Corrective Actions) and
Appendix H of that Directive establish UST—specific
procedures for preparation and processing of TDDs for TAT
activities in the UST program. Given EPA policy that LUST
Trust Fund—financed responses at UST petroleum releases
will be conducted by states under Cooperative Agreements
with EPA, except in rare instances, TAT contractor
activity is not likel.y to be significant in this area.
Only public health emergencies will be handled by the
Federal government. Given the small amount of funding
currently available for UST activities under TAT, Project
Officer approval should be obtained before issuing a TDD
for tJST work. For further information regarding the UST
contracts, write or call: Office of Underground Storage
Tanks (WH—562A), U.S. EPA, Washington, D.C. 20460,
202/382—4756 or FTS 8—382—47 56.
7. INTERACTION OF TAT WITH STATE AND LOCAL AGENCIES, THE
U.S. COAST GUARD (USCG) AND OTHER FEDERAL AGENCIES
TAT interaction with state and local agencies, the
U.S. Coast Guard (USCG) and other Federal agencies can
occur when TAT monitoring efforts in support of the OSC
are under the supervision of any of these entities. In
some cases, the OSC may designate an OSC representative to
act in that capacity on a temporary basis. This OSC
representative may be an employee of EPA, the USCG, or a
state or local agency official. For example, the USCG can
procure the support of a TAT contractor during removal
actions in which the USCG is acting in the capacity of
IV-6
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OSWER Directive 9242.4—O 1A September 1987
OSC. The assigned OSC or OSC representative (TJSCG, state,
local or EPA) can direct the TAT only within the scope of
the TDD issued by the I WO. The TAT may not perform duties
that go beyond the scope of the TDD without the DPO’s
modification of the TDD. When conducting response
activities, the TAT contractors should be fully aware of
the particular roles and responsibilities of these
external concerns and ensure that all interactions are
carefully coordinated by the OSC.
IV-7
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OSWER Directive 9242.4 —O 1A September 1987
CHAPTER V
PROCEDURES FOR INITIATING AND
MANAGING TAT ACTIVITIES
-------
OSWER Directive 9242.4—O1A
September 1987
CHAPTER V
PROCEDURES FOR INITIATING AND
MANAGING TAT ACTIVITIES
KEY TOPICS
Page
• The Technical Direction Document (TDD) V—2
• Preparing the TDD V—3
• Processing the TDD V —il
• Amending the TDD V—12
• Special Project TDDs V—12
Acknowledgement of Completion (AOC)/Performance V—13
Observation Report (POR)
Preparing the AOC/POR V—14
Processing the AOC/POR V—19
V-i
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OSWER Directive 9242.4—O1A September 1987
CHAPTER V
PROCEDURES FOR INITIATING AND MANAGING TAT ACTIVITIES
Exhibit V—i illustrates the process for initiating and
completing work under the TAT contracts. The process
begins with the issuance of a Technical Direction Document
(TDD) by the Deputy Project Officer (DPO) or Project
Officer (P0) to the contractor TAT Leader or Zone Program
Manager (ZPM) and ends with the submission of an
Acknowledgment of Completion (AOC)/Performance Observation
Report (POR) form by the TAT Leader to the DPO. This
chapter presents a detailed description of the entire
process including an explanation of the forms that are
used to document the initiation and completion of
services. It also provides a description of EPA and
contractor roles and responsibilities in managing and
implementing the process.
1. THE TECHNICAL DIRECTION DOCUMENT (TDD )
When a need for TAT contractor services arises, the
EPA DPO or P0 prepares and issues a written TDD, which
serves as the principal mechanism for initiating these
services.* The TDD includes background data, the scope of
work to be performed, a schedule of deliverables, an
estimate of time and costs required to perform the work,
and other related information.
Only the DPO or P0 is authorized to prepare and issue
TDD5 to the TAT Leader. Each DPO can issue TDDs only to
the TAT Leader assigned to that particular DPOs Region.
For example, the Region I DPO can issue TDDs only to the
TAT Leader assigned to Region I. TDDs can also be issued
by the P0 to the TAT contractor ZPM for special ZPM
efforts within the contract Statement of Work (SOW).
* The P0 or DPO may also initiate contractor services
through a verbal TDD, but this must always be followed
by a written TDD within five calendar days.
V-2
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OSWER Directive 9242.4—O1A September 1987
1.1 Preparing the TDD
Zone 1 activities will be initiated by using the TDD
form shown in Exhibit V—2(l). Zone 2 activities will be
initiated using the TDD form shown in Exhibit V—2(2). The
elements of each TDD are described below. The Zone 1 TDD
is described first: (It should be noted that the reason
there are two slightly different versions of the TDD is
because each TAT contractor has a different accounting
system).
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—8710—3 is interpreted as
follows: 2 refers to the TAT location in
Region 2 (Edison, N.J.); 87 refers to the year
the TDD is issued; 10 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 which is printed on the
back of the form, describes the type of response
activity undertaken. The code will be entered by
the TAT Leader 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 priority), 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/SARA,
Clean Water Act (CWA) Section 311, Underground
Storage Tank (UST) Trust Fund or other (e.g.,
Federal Emergency Management Agency)]. Only one
source of funding may be used.
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. )
V-3
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OSWER Directive 9242.4—0].A September 1987
Site Name (Box 5A) : EPA site name as specified
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.
Completion dates must not be left “OPEN.”
Overtime Approved (Box 7) : The DPO must specify
whether overtime (time and 1/2) hours are
allowable for the task outlined in the TDD. (It
should be noted that in both zone contracts the
LOE hours include a 20 percent overtime factor.
Since the contractor must deliver a minimum
90 percent of the LOE hours to earn its full base
fee, overtime approval should not be unduly
withheld by the DPO. It is also noted that most
TAT members do not earn premium overtime pay
(i.e., they are paid at the straight time rate),
and that TAT Leaders generally are not entitled
to overtime payment).
Reference Info (Box 8) : This item allows the DPO
to provide the TAT contractor with any reference
materials or supplemental information necessary
to expedite TDD.completion. At the same time,
accountable control of such information is
maintained.
General Task Description (Box 9) : In this
section, the PO/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 objectives are present,
continuation of the general task description can
be made into Box 10.
Estimated Costs (Box 9A) : An estimate of the
total cost (meant to be a “not to exceed” amount)
including direct labor, travel, expenses, and
subcontracting. DPO’s should rely on previous
V-4
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OSWER Directive 9242.4—O1A September 1987
data for similar tasks to derive these
estimates. Also, they should coordinate with the
TAT contractor to obtain estimates.
Estimated Hours (Box 9A) : The estimate of the
technical labor hours needed to accomplish the
TDD assignment will be the responsibility of the
appropriate PO/DPO. The estimate should be based
on best engineering judgment considering
knowledge of the project or task requirements,
data needs, estimated cost of the project and
previous experience on similar projects.
Historically, estimated hours have been too low
in several cases. DPOs should be sure to make
reasonable allowances in the future. This
judgment is generally made in consultation with
the TAT Leader.
Specific Task Elements (Box 10) : This section is
to be used to elaborate on the general task
description and to define interim task
objectives. This section should provide the TAT
Leader with a clear understanding 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 permissible to attach
standardized detailed task descriptions to the
TDD for commonly occurring assignments [ e.g.,
Spill Prevention Control and Countermeasures
(SPCC) inspections].
Interim Deadlines (Box 11) : This box is to be
used to denote completion dates for interim task
objectives, where applicable, within the overall
task to be performed. ( If not applicable, mark
the box N/A.)
Desired Report Form (Box 12) : The DPO should
indicate the type of end product desired 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.
V-5
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OSWER Directive 9242.4—O 1A September 1987
Signatures and Dates (Boxes 14—17) : These
sections are self—explanatory. The TDDs are to
be issued and signed by the PO/DPO and received
and signed by the TAT Leader. If the TAT Leader
judges the TDD to be out of scope, or for other
reasons unacceptable, the appropriate box must be
checked to show the action. A TDD considered to
be unacceptable by the contractor should
immediately be brought to the attention of the
DPO, P0 and CO. An appropriate explanation can
be noted on the right—hand margin of the form.
The TAT Leader should also contact the DP0
immediately to explain why the TAT finds the TDD
to be unacceptable.
Descriptor (Box 18) : This box is completed by
the TAT contractor and is used for TAT contractor
internal accounting purposes.
Distribution : Distribution of the TDD will be as
indicated at the bottom of the form. Copies of
the TDD will be distributed to the following:
- TAT Leader
- ZPMO
- DPO
- P0
- CO.
Information required on the Zone 2 TDD is as follows:
Cost Center (Box lA) : This block contains the
number used to designate each TAT.
Account No. (Box 1B) : This is an internal number
that the TAT Leader will assign to each TDD.
No. (Box 2) : This number begins with T
(signifying TAT) and represents the individual
TDD number. It has nine digits: the first two
represent the Region; the second two represent
the year the TDD was issued; the third two are
the month the TDD was issued; and the last three
digits represent the number of the TDD issued for
that month. For example, the TDD number
T06—87—O1—OO1 would be interpreted as follows:
06 refers to Region 6; 87 refers to the year
1987; 01 refers to January; and 001 refers to the
first TDD issued during the month.
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OSWER Directive 9242.4—O1A September 1987
Priority (Box 3A) : This box is used to denote
the priority of the request. For example, the
priority should reflect whether an immediate
action is required (high priority), an action is
to be taken within a definite time period
designated in Box 7 (medium priority), or an
action is to be taken within a flexible time
period (low priority).
Key EPA Contact (Box 3B) : This is the name and
phone number of the EPA DPO or P0 who issued the
TDD.
Estimate of Total Hours and Total Costs (Box
4A): An estimate of the total technical hours
and costs (meant to be a “not to exceed’ amount)
including labor and other expenses needed to
accomplish the TDD assignment. The estimate
should be developed by the DPO based on best
engineering judgment considering knowledge of the
project or task requirements, data needs, and
previous experience on similar projects.
Overtime Approved (Box 4B) : The DPO must specify
whether overtime (time and 1/2) hours are
allowable for the task outlined in the TDD.
EPA Site Name (Box 5A) : EPA site name as
specified in CERCLIS. (If not applicable, mark
the box N/A.)
SSID No. (Box 5B) : This number will be supplied
by the DPO from the CERCLA Information System
(CERCLIS). ( If not applicable, mark the box N/A.)
City/County/State (Box 5C) : The city, county,
and state where the EPA Superfund site is
located. This can be entered by either the DPO
or the TAT Leader.
Source of Funds (Box 6) : The source of funding
for the TAT activity [ i.e., either CERCLA, Clean
Water Act (CWA) Section 311, Underground Storage
Tank (UST) Trust Fund or other (e.g., Federal
Emergency Management Agency)]. Only one source
of funding may be used.
Completion Date (Box 7) : This is the date
specified by the DPO for the TAT contractor
submittal of the completed TDD assignment.
Completion dates must not be left “OPEN. ”
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OSWER Directive 9242.4—O1A September 1987
Reference Info. (Box 8) : This item allows the
DPO to provide the TAT contractor with any
reference materials or supplemental information
necessary to expedite TDD completion. At the
same time, accountable control of such
information is maintained.
Subtask Code (Box 8A) : This box is for
contractor use only, and is used for
site—specific cost accounting.
Type of Activity (Box 9) : The specific type of
service to be provided by the TAT. Definitions
of these types are presented as Appendix C.
General Task Description (Box 10) : In this
section, the DPO indicates-the following:
- The type of support desired
— The level of intensity reqi.iired (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.
Desired Report Form (Box 11) : The PO/DPO should
indicate the type of end product desired for the
TDD assignment. The report may be as a formal
report, letter report, formal briefing, or other
specified format.
Specific Elements (Box 12) : This section is to
be used to elaborate on the general task
description and to define interim task
objectives. This section should provide the TAT
Leader with a clear understanding 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 permissable to attach standarized
detailed task descriptions to the TDD for
commonly occurring assignments [ e.g., Spill
Prevention Control and Countermeasures (SPCC)
inspections.]
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OSWER Directive 9242.4—O1A September 1987
Interim Deadlines (Box 13) : This box is to be
used to denote completion dates for interim task
objectives, where applicable, within the overall
task to be performed. ( If not applicable, mark
the box N/A.)
Authorizing DPO (Box 14) : Signature of the DPO
issuing the TDD.
Date (Box 15) : The date on which the TDD was
signed and issued.
Received by (Box 16) : Signature of the TAT
Leader and indication of whether the TDD is
accepted, accepted with exceptions, or rejected.
If the TDD is accepted with exceptions, this
should be explained on a separate piece of paper.
Date (Box 17) : The date on which the TAT Leader
signs the TDD.
Distribution : Indicates who gets which copies of
the TDD.
An example of a completed TDD is provided in
Appendix D. This example helps to illustrate three
important points for the DPO to keep in mind when
preparing a 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
extremely important that the DPO include in the TDD
realistic estimates for technical hours and costs needed
to accomplish the assignment.
Although exact tasks and response activities,
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—10 on either form). The task description should be as
detailed as available information permits so that there is
a clear understanding by the TAT contractor of the
activity objective yet allow some flexibility for
alternative and innovative actions by the contractor as
conditions warrant. Examples of candidate tasks which
could be performed for different types of removal response
or prevention work can be extracted directly from the TAT
contract SOWs contained in Appendix A.
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OSWER Directive 9242.4—O1A September 1987
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 SOWs. Particular attention
must be given to ensure that TDDs do not involve personal
services. For example, the DPO must not direct the TAT to
provide 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
responsibility 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 standardized work scopes for an
activity (i.e., facility surveys and inspections) and to
use this scope (modified as necessary f or a specific
situation) as an attachment to the TDD.
In addition, the TDD reporting requirements (Box 12,
TAT 1; Box 11, TAT 2) 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 a
realistic estimate of technical hours and costs needed to
accomplish the TDD assignment is included in the TDD. As
mentioned previously, DPO5 historically have not allowed
sufficient hours to accomplish many assignments. DPOs
should provide estimates that are realistic and sufficient
to do the job. 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
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 technical hours available can be
computed from the information in the contract. The
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OSWER Directive 9242.4—OlA September 1987
difference between 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 (e.g. , biweekly).
1.2 Processing the TDD
Once the TDD is completed it is signed by the DPO or
the DPO’s designee t 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 TAT
Leader as issued by the DPO, the TAT Leader signs the TDD
and proceeds with petformance 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 exceptions. 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 P0 in Headquarters for guidance. If
hecessary, the P0 will consult with the contractor ZPM to
try to resolve the situation. If it is resolved, the DPO
may issue a revised TDD reflecting the issue resolution,
and the contractor will proceed with task performance. If
the P0 and contractor ZPM 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 TAT Leader rejects the TDD, it is returned to
the DPO with an explanation of the reasons for rejection.
The DPO and TAT Leader are to confer to resolve the
situation. If a resolution is reached, a revised TDD can
be issued, if necessary, and the contractor proceeds with
* When the DPO plans to be out of the office and
unavailable to perform contract management functions,
the DPO must submit a written request, or telephone
the TAT P0 and CO, for approval to appoint a temporary
assistant DPO. This request must be for a discrete
period of time.
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OSWER Directive 9242.4—O1A September 1987
the task. If the DPO and the TAT Leader cannot resolve
the problem, the DPO should contact the P0 for guidance as
explained above.
When the TDD is acceptable to both the TAT Leader and
the DPO, it should be signed and dated. Appropriate
copies should be placed in the contractor’s and EPA’s
central TDD files. The DPO should then send copies of the
TDD to the P0 and Co.
1.3 Amending the TDD
In the event that an issued TDD needs a revision, the
DPO must issue a TDD amendment containing the appropriate
changes. Events that require TDD amendments may include,
for example, an original underestimation of a project’s
magnitude or an acceleration of a prOject’s period of
performance. For theZone I contract, the original TDD’s
number will be used together with a suffix capital
letter. For example, referring to the previously cited
example, if the TDD is revised, the TDD authorizing the
revision would be numbered 2—87l0—3A. For the Zone II
contract, however, a box is provided on the TDD (Box 2) to
indicate that it is an amendment. The revised TDD should
include the material contained in the original TDD and the
revised information so as to be capable of standing.
alone. Amendments are to be processed in the same manner
as described above.
1.4 pecial Project TDDs
Funding has been obligated for the performance of
special projects under the TAT contracts. Special
projects were discussed in Chapter II and are summarized
in Appendix A. If a special project is required, the DPO
may request the TAT Leader to prepare and submit 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 detailed to provide a base for
guiding work, measuring progress, and controlling
budgets. The contractor work plan should address the
elements specified in Exhibit V—3.
OSCs and DPOs should recognize the importance of
adequate lead times on the contractor’s ability to obtain
the required competition in subcontracting.
Upon review and approval of the TAT contractor’s work
plan, a TDD will be issued according to the following
procedures:
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OSWER Directive 9242.4—O1A September 1987
• For special projects estimated to cost under
$10,000, approval authority is granted to the
respective DPO or P0
• In instances where multiple special projects are
issued for the same site, the DPOs authority
shall be extended to a ceiling of $15,000 per site
• For special projects estimated to cost $10,000 or
more, or where the total of all special projects
at a site exceed $15,000, approval authority must
be obtained from both the Co and the P0.
Irrespective of the dollar values involved, some
Special Projects subcontracts will require Co consent
because of the contract type.
2. ACKNOWLEDGEMENT OF COMPLET ION (AOC) / PERFORMANCE
OBSERVATION REPORT (POR )
Under the previous TAT contract, the contractor was
responsible for preparing an AOC form for every completed
TDD. This form, which was submitted to the DPO, signified
that the assigned work had been completed.
Under the present zone contracts, the AOC form has
been combined with the POR form. The POR form is used by
the contractor and EPA to evaluate the contractors
performance on the TDD. The AOC and POR forms have been
combined in order to avoid unnecessary duplication of
information. By combining AOC and POR informaton on one
form, the paperwork burden will be reduced and time will
be saved, both for the contractor and for EPA. This
implements the DPOs’ suggestions to improve and streamline
the Performance Evaluation/Award Fee Process.
The AOC/POR form will be initiated by the TAT Leader,
who will be responsible for describing what actions were
taken on the assignment, what results were obtained, and
how well the contractor performed vis—a—vis the TDDs
requirements. In this way, the AOC/POR serves both as a
document that signifies completion of the assignment (AOC)
and one that provides the contractors self—assessment of
performance on the assignment (POR). Alternatively, the
AOC/POR can be treated as just an AOC (signifying
completion of the assignment) and not as a combined
AOC/POR. This occurs at the time the AOC/POR is received
by the DPO, who decides whether or not to evaluate the
contractor’s performance on the particular TDD. If the
decision is to evaluate the contractor’s performance, the
DPO will describe the performance and provide a rating,
from “1” to “5”, on the form. If the decision is not to
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OSWER Directive 9242.4—O1A September 1987
evaluate the contractor’s performance, the DPO will ignore
the evaluation parts of the form and treat it simply as an
AOC. The AOC portion of the AOC/POR includes information
on actual labor hours expended, the total cost of the
action, and the type of response taken. The POR portion
provides a description and rating of the contractor’s
performance on the TDD. It is strongly suggested that the
DPO meet with the TAT Leader each evaluation period to
discuss which AOC/POR5 should be included as part of the
award fee process.
The TAT Leader must submit the comp1et d AOC/POR to
the DPO within ten working days of task completion. The
form can be either an interim AOC/POR or a final AOC/POR,
depending on whether final cost data are available at time
of submittal. The same form should be used to record
interim and final costs. It is not necessary to prepare
separate forms.
2.1 Preparing the AOC/POR
Copies of the AOC/POR forms that will be used for Zone
1 and Zone 2 activities are shown in Exhibits V—4(1) and
V—4(2), respectively. The specific information required
on these AOC/POR forms is described below, beginning first
with the AOC/POR for Z.one 1:
Cost Center : This block contains the number used
to designate each TAT.
Contract No : The TAT Zone 1 contract number is
68—01—7367.
Contractor : The TAT Zone 1 contractor is Roy F.
Weston, Inc.
TDD Number : 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.
Reporting Element : This specifies which TAT
(i.e., assigned to which Region) performed the
work.
Date(s) of Reported Observation : This box should
contain the period of performance of the TDD
activities.
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OSWER Directive 9242.4—O1A September 1987
• Approx. No. of Hours : This box should contain
the same number that is in Box Number 9 of the
TDD.
• Report Format : This should agree with Box 12 of
the TDD (TAT Zone 1).
• Performance Evaluation Category : This should
contain the type of activity conducted under the
TDD; examples are stated in the SOW (Appendix A).
• Description of Contractor Observation : This
section should 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 and what level and quality of
performance was attained. Ambiguous phrases such
as assisted OSC’ should be avoided. In the case
of non—response—type assignments, for example,
training course attendance, description should
show how the activity is related to the overall
TAT contract SOW. The TAT Leader should
reference all deliverables produced. Where
formal briefings, information briefings, etc.,
have been requested and no formal written -
submittal of information has been requested 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 important
that the reports furnished by the contractor be
in conformance with the specific instructions
given in the TDD. NOTE: If the space is not
sufficient for the description, additional pages
should be attached to the form, as necessary.
Rating : The TAT Leader rates the quality of the
performance, with H5h1 indicating exceptional and
“1, indicating unsatisfactory. All AOC/PORs
should receive ratings. For further information,
see the description of the performance evaluation
plan, Chapter VII.
• Signature of Contractor : The TAT Leader signs
the AOC/POR form.
• Date : The TAT Leader dates the form.
For an explanation of the following items, see the
description in Chapter VII.
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OSWER Directive 9242.4—O1A September 1987
• Description of EPA Observation
• Rating
• Signature of EPA
• Date
• Rating
• Signature of HQ
• Date .
The DPO accepts or rejects the assignment as complete
by checking the following box:
• DPO Action : The DPO should check the appropriate
box to indicate the quality of the completed
project assigned by the TDD. The DPOs options
are as follows:
— If the DPO accepts the AOC, it is signed.
The original form is then returned to the
contractor and copies sent as indicated
below so that the TDD can be closed out and
payment made to the contractor.
- The DPO can accept the AOC with exceptions,
which are to be noted on the form. Copies
are then distributed as above.
- The DPO can reject the AOC. In this case,
the form is returned to the TAT Leader with
an explanation of the reasons for rejection
and measures required to bring the
assignment into conformance.
Before submitting the AOC/POR to the DPO, the TAT Leader
should also complete the following:
Cost to Date : If total cost figures are
unavailable when the AOC is submitted, the TAT
must include interim cost figures and provide the
date through which thecosts were calculated.
This is an interim AOC if total costs are not
reported.
Total Cost to Closure : This is the total cost of
work performed under the TDD including direct
labor, travel, expenses, analytical services, and
subcontracts (if applicable). If total cost
information is not available within ten working
days of task completion, an interim AOC should be
submitted with interim cost figures.
Actual Total Hours : The total technical hours
required by the TAT contractor to conduct and
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OSWER Directive 9242.4—O 1A September 1987
complete the requirements of the TDD must be
recorded in this block. Technical hours do not
include secretarial and typing support. If
information regarding total technical labor hours
expended is not available within ten working days
of task completion , an interim AOC should be
submitted with interim labor hour figures.
Signatures : The signature blocks are used to
indicate whether the form is an interim AOC or a
final AOC. 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 : After the TAT Leader completes the
AOC, the original and all copies are distributed
to the DPO , who decides whether to accept or
reject it. If rejected, the AOC is returned to
the TAT Leader. If accepted, it is completed and
distributed according to the distribution list at
the bottom of the form. An interim AOC is
distributed differently than a final AOC. If it
is interim, the DPO removes the bottom sheet
(Goldenrod), places it in the central file, and
returns the remaining copies to the TAT Leader.
When final costs become available, the TAT Leader
fi-lls in the “cost to date” and the “actual total
hours” and returns it to the DPO for signature.
The DPO then distributes the final AOC as
indicated at the bottom of the form.
— Sheet 1 (white) to the Headquarters -
Evaluation Coordinator
— Sheet 2 (white) to the DPO
— Sheet 3 (blue) to the TAT Leader
— Sheet 4 (green) to the ZPM
— Sheet 5 (canary) to the P0
— Sheet 6 (pink) to the Co.
The AOC/POR for Zone 2 will require the following
information elements:
Cost Center : Same as on the Zone 1 TDD.
Contract No. : The TAT Zone 2 contract number is
68—01—7368.
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OSWER Directive 9242.4—O1A September 1987
• Contractor : The TAT Zone 2 contractor is Ecology
and Environment, Inc.
• TDD No. : Same number as shown in Box 2 of the
Zone 2 TDD.
Reporting Element : Same description as for TAT
Zone 1 AOC/POR.
Date(s) of Reported Observation : Same
description as for TAT Zone 1 AOC/POR.
• Approx. No. of Hours : Same description as for
TAT Zone 1 AOC/POR.
• Account No. : Same as the number on the Zone 2
TDD, Box lB.
Performance Evaluation Category : Same
description as for TAT Zone 1 AOC/POR.
Description of Contractor Observation : Same
description as presented for the Zone 1 AOC/POR.
Rating Same description as for TAT Zone 1
AOC/POR.
Signature of Contractor : Same description as for
TAT Zone 1 AOC/POR.
Date : Same description as for TAT Zone 1 AOC/POR.
If the DPO will use the form as a POR, the following
items are also completed:
Description of EPA Observation
Rating
Signature of EPA
• Date
Signature of Regional POR Coordinator
Date
HQ Coordinator’s Evaluation
Rating
Signature of HQ
Date.
For an explanation of this portion of the AOC/POR, see the
description in Chapter VII. The AOC portion of the AOC/
POR continues with the following:
DPO Action : The DPO should check the appropriate
box to indicate the quality of the completed
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OSWER Directive 9242.4—O1A September 1987
project assigned by the TDD. The DPO’s options
are as follows:
— If the DPO accepts the AOC, it is signed.
The original form is then returned to the
contractor and copies sent as indicated
below so that the TDD can be closed out and
payment made to the contractor.
- The DPO can accept the AOC with exceptions,
which are to be noted on the form. Copies
are then distributed as above.
— The DPO can reject the AOC. In this case,
the form is returned to the TAT Leader with
an explanation of the reasons for rejection
and measures required to bring the
assignment into conformance.
Before submitting the AOC/POR to the DPO, the TAT Leader
should also complete the following:
Actual Total Hours : Same as for the Zone 1 AOC.
Total Cost to Date : Same as for the Zone 1 AOC.
Total Cost to Closure : Same as for the Zone 1
AOC.
Signature and Dates : Same as for the Zone 1 AOC.
Distribution : Indicates who receives which copy
of the AOC.
Finally, the TAT Leader should attach a blank copy of
Part II, the Worksheet of the POR, to the completed
Part I, before submitting it to the DPO.
2.2 Processing the AOC/POR
All AOC/POR forms are initiated by the TAT Leader, who
is responsible for completing the contractor—designated
information on the top one—third of the form. The TAT
Leader is responsible for providing a rating, from ‘l” to
11511 on every AOC/POR submitted, which provides EPA with
the contractors self—evaluation of performance on the
assignment.
If total project costs are not known at the time the
AOC/POR is due for submission (i.e., within ten working
days of project completion), the TAT Leader should prepare
and submit an interim AOC, signing the form in the
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OSWER Directive 9242.4—OlA September 1987
appropriate place. The interim AOC should contain
information on costs incurred to date. The DPO will then
complete and sign the interim AOC, retain the last copy
for the files, and return the package to the TAT Leader.
As soon as final project cost information becomes
available, the TAT Leader should submit a final AOC/POR
with this information, using the original (interim) AOC/
POR form, and signing it in the appropriate place. It is
the DPOs responsibility to ensure that this procedure is
followed.
The DPO is also responsible for deciding whether the
AOC/POR will be used only as an AOC. or as a combined AOC/
POR. In accordance with the TAT contract and the TAT
award fee plan, the DPO must ensure that evaluations (POR
portions) are prepared for at least 60 percent of the
level—of—effort hours assigned during the evaluation
period. The DPO should decide which AOC/PORs will be
treated as PORs in conjunction with the TAT Leader. If it
is used only as an AOC, the DPO does not need to describe
and rate the contractor’s performance on the form. If it
is used as a combined AOC/POR, however, then the DPO must
describe and rate the contractor’s performance.
Instructions on completing the POR portion of the AOC/POR
are presented in Chapter VII, page VII—5.
Before signing and dating the AOC/POR, the DPO should
make sure that all materials and services specified in the
TDD have been provided within the required time frame.
Also., if any written deliverables were required under the
TDD, these should be reviewed for accuracy and
acceptability. If they are not acceptable or if some
materials or services have not been provided as required,
the DPO should inform the TAT Leader of these problems and
explain how they should be resolved. Once resolved, the
DPO should approve the final AOC/POR by signing and dating
it, placing it in a central file, and forwarding copies to
the P0 and Co.
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September 1987
EXHIBIT V-i
Process for Initiating and Completing TAT Contractor Services
ORIGINATOR
RECIPIENT
* TDD -- TECHNICAL DIRECTION DOCUMENT
** AOC/POR -. ACKNOWLEDGEMENT OF COMPLETION/PERFORMANCE OBSERVATION REPORT
DOCUMENTATION
%‘ROJECT
OFFICER
V-21
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1L1W L 1 01
UbW i’ uirective
EXHIBIT V—2(1)
12D. DESIRED REPORT FORM FORMAL. REPORT LETTER REPORT FORMAL BRIEF
OTHER (SPECIFY)
13.
COMMENTS
14. AUTHORIZING OPO
15 DATE
(SIGNATURE)
16 RECEIVED BY
ACCEPTED ACCEPTED WITH EXCEPTIONS REJECTED
17 DATE
(TATL SIGNATURE)
18.DESCRIPTOR 11111111111 III 111111111111111111 11111111
• .t, - & .‘O c , IS.ge.b by TA TI. R s .g O,. 1 y. .Il
$b . 2G .... ’ - TA TI. Ca.,
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ie.i 4 Pail. - a.cr Off , .., Cap,
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1. COST CENTER
TAT — CONTRACT 68-01.7367
TECHNICAL DIRECTION DOCUMENT (TDD)
OHM EMERGENCY RESPONSE AND
SPILL PREVENTION PROGRAM
ROY F. WESTON INC.
2 NO
2A TYPE
3. PRIORITY
r—IH,GH (1)
MEDIUM (2)
LOW (3)
4. SOURCE OF FUNDS
CERCLA (1)
311 (2)
UST(3)
FEMA
5 EPA SFTE ID
5A EPASFTENAME
6. COMPLETION DATE
7.OVERTIME APPROVED
YES NO
8. REFERENCE INFO.
YES NO
ATTACHED
PICK UP
9 GENERAL TASK DESCRIPTION
9A. ESTIMATED COST S ESTIMATED HOURS
10. SPECIFIC ELEMENTS 11. INTERIM DEADLINES
V-22
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bXt i1i$1T V—. (2)
tributu0fl
Sheet I White
Sheet 2 Blue
Sheet 3 Green
Sheet 4 Canary
Sheet 5 Punk
Sheet 6 Goldenrod
DPO Copy
TAIL. Copy
ZPM Copy
P0 Copy
• CO Copy
• DPO Original (Unsigned by TATL)
1A: Cost Center:
TAT ZONE II CONTRACT
2.No.:
CONTRACT NO. 68.01.7368
TECHNICAL DIR ECTION DOCUMENT (TDD)
ECOLOGY AND ENVIRONMENT, INC.
T
lB. Account No.:
Amendment
3A. Priority
4A.Estimate of
5A. EPA Site Name:
7. Completion Date:
O High Total Hours:
Medium Total Costs
5B. SSID No.: 5C. City/County/State: 8. Reference Info:
O Low Yes D Attached
3B. Key EPA Contact: 4B. OvertIme Approved: 0 No 0 Pick-up
6. Source of Funds: Other
Name: CERCLA 8A.Subtask Code:
[ JYes E]No 311
Phone: usr
9. Type of Activity: CWA-311 CERCLA AS SPECIFIED ABOVE
SPCC Site Assessment Special Project Quality Assurance
On-Scene Monitoring Removal Funded Analytical Project L Training
Spill Clean-up Funded Removal PRP (AOICO) TITLE Ill Program Management
On- Site MonItoring UST ( Technical Assistance
FEMA [ Information Management
10. General Task DescriptIon:
11. Desired Report
Form:
R Formal Report
Letter Report
0 Formal Briefing
Other (Specify)
12. Specific Elements:
13. Interim Deadlines:
14. Authorizing DPO:
(Signature)
15. Date:
16. Received by: Accepted Accepted with Exceptions (Attached) . 0 Rejected
17. Date:
(TATL Signature)
V—23
T007037
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OSWER Directive 9242.4—O1A September 1987
EXHIBIT V—3
Contractor Workplan 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.
V-24
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Sheet 1 White - Hdqtrs Coordinator
Sheet 2 White. DPO Copy
Sheet 3 Blue - TATL Copy
Sheet 4 Green ZPM Copy
Sheet 5 Canary- Project Officer Copy
Sheet 6 Pink - Contracting Officer Copy
Sheet 7 Goldenrod - DPO (Interim Copy)
EXHIBIT ‘1—4(1)
Cost Center ACKNOWLEDGEMENT OF COMPLET1ON
PERFORMANCE OBSERVATiON REPORT: RT I
Contract No: Contractor TDD No.
68-01-7367 Roy F Weston, Inc.
Reporting Elemest Date(s) of Reported Observation ApprOx. No. of Hours 0 Format Report
o Letter Report
Performance Evaluation CSte9ofY CJ Formal Bnefirig
o Other (Specify)
Descnpbon c i Contractor Observation By
Name/Title
Rating: 5,4,3,2,1 Signature of Contractor Date:
Desaiplion of E Observation By
Name/Title
Rating: 5,4,32,1 Signature of EPk Date:
Signature ci Regional POR Coordinator Date:
HO CoordInatoi s Evaluation By
NameIlitle
Rating 5,4,32,1 ci Date
DPO frdot 0 Accepted 0 Accepted with ExceØons 0 Rejected
Cost To Date: • Date: Actual Total Houis
Total Cost To Closure:
I certify that the attached materials meet and comply with all
requiremente of the subject TDD.
TATL Signature (Interim) TAfl. Signature (Final)
Date:
Interim
Final
I acknowledge that I have been provided with the materials and
services specified in the subject TDD within ita original or
revised time frames.
DPO Signature (Interim) DPO Signature (Final)
Date:
Inter im
Final
V-25
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AFi.L J.1 V’4 ( .L I
COST CENTER ACKNOWLEDGEMENT OF COMPLETION
PERFORMANCE OBSERVATION REPORT: PART I
CONTRACT NO..
6801-7 .368
CONTRACTOR: .
Ecology and EnvIronment, Inc.
TDDNO.
REPORTING ELEMENT DATE(S) OF REPORTED OBSERVATION APPROX. NO. OF HOURS ACCOUNT NO.
PERFORMANCE EVALUATION CATEGORY —
DESCRIPTION OF CONTRACTOR OBSERVATION BY
RATING. 5. 4. 3. 2. 1 SIGNATURE OF CONTRACTOR. DATE
DESCRIPTION OF EPA OBSERVATION BY
NAME/TITLE
RATING: 5. 4. 3.2. 1 SIGNATURE OF EPA. DATE:
SIGNATURE OF REGIONAL POR COORDINATOR: DATE.
HO COORDINATOR’S EVALUATION BY.
NAME/TITLE
RATING. 5,4, 3,2, 1 SIGNATURE OF HO: DATE;
DPO ACTION. ACCEPTED ACCEPTED WITH EXCEPTIONS 0 REJECTED
COST TO DATE: DATE; ACTUAL TOTAL HOURS:
TOTAL COST TO CLOSURE.
I CERTIFY THAT THE ATTACHED MATERIALS MEET AND COMPLY WITH ALL
REQUIREMENTS OF THE SUBJECT TDD.
.
DATE.
INTERIM
FINAL
TAIL SIGNATURE (INTERIM) TAIL SIGNATURE (FINAL)
I ACKNOWLEDGE THAT I HAVE BEEN PROVIDED WITH THE MATERIALS AND
SERVICES SPECIFIED IN THE SUBJECT TOO WITHIN ITS ORIGINAL OR
REVISED TIME FRAMES •
DPO SIGNATURE (INTERIM) OPO SIGNATURE IFINAL )
DATE:
INTERIM
FINAL
o usTribution
SPisit I White
Sheet 2 Whit.
Sheet 3 BIu•
Sheet 4 Omen
Sh.et 5 Cenery
Sheet 6 Punk
Sheet 7 Goldenrod
- HOS Coordunitor
DPO Cony
TATL Copy
- ZPM Copy
• P0 Copy
CO Cooy
OPO Interim
V-26
T006A03
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OSWER Directive 9242.4—O1A September 1987
CHAPTER VI
MONITORING PROJECT PERFORMANCE
AND FINANCIAL MANAGEMENT
-------
OSWER Directive 9242.4—O1A September 1987
CHAPTER VI
MONITORING PROJECT PERFORNANCE
AND FINANCIAL MANAGEMENT
KEY TOPICS
Page
• Contractor Repbrts VI—2
• Financial Management Report VI—3
• Monthly Status Report VI—3
• Monthly Summary Progress Report VI—4
• Site—Related Financial Reports VI—4
• Program Management Information Reports VI—4
• Draft and Final Year—End Report VI—4
• Cleanup Activity Reports VI—5
• Pollution Reports VI—5
• ZPM TAT Office Review Report VI—6
• Letter Reports VI—6
• Socio—Economic Reports VI—7
• Central Filing System VI—7
• TDD Status Tracking Log VI—7
• Regional TAT Contractor Office Reviews VI—7
VI- ].
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OSWER Directive 9242.4—O1A September 1987
CHAPTER VI
MONITORING PROJECT PERFORNANCE
AND FINANCIAL MANAGEMENT
In order to ensure that the TAT contractors are
progressing satisfactorily in implementing assigned tasks
and in meeting planned financial and programmatic
objectives, it is necessary for EPA to regularly monitor
contractor performance in these areas. Such monitoring is
important to achieving an early identification and
prevention of potential problems that otherwise may
adversely affect the smooth operation and implementation
of the program.
Primary responsibility for monitoring performance of
the TAT contractors is that of the Deputy Project Officer
(DPO). Specific responsibilities include the following:
Ensuring that the TAT contractors prepare and
submit all required reports on time
Establishing and maintaining central filing
systems for appropriate contract and program
docuinentat ion
Establishing and maintaining a log for tracking
Technical Direction Documents (TDDs)
Conducting Regional TAT contractor office reviews.
The following sections discuss each of these
responsibilities in more detail.
1. CONTRACTOR REPORTS
The TAT contractors are required to submit several
reports to EPA, all of which should be used by the DPOs to
monitor project performance. A list of these reports is
presented in Exhibit VI—l. The DPO is responsible for
ensuring that all of these reports are prepared and
submitted on time by the contractors and that their
contents are accurate and appropriate. If not, the DPO
should notify the TAT Leader of any problems and make
certain that any necessary corrections are made. The
Project Officer (P0) and Contracting Officer (CO) should
also review these reports on a regular basis, and if
problems are identified, should notify the Zone Program
Manager (ZPM).
VI-2
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OSWER Directive 9242.4—O1A September 1987
Detailed information on each required contractor
report is presented below.
1.1 Financial Management Report
The ZPM is responsible for submitting an initial
Financial Management Report within fifteen days of the
effective date of the contract and should include
information on the following:
Contractor name and contract name
Total contract dollars
Time (contract period of performance in months)
The projected rate of expenditure on a cumulative
basis of the estimated contract cost over the
period of contract performance by month. This
projection (baseline) shall not change during the
life of the contract without concurrence of the
CO.
In addition, each month the ZPM is responsible f or
submitting a Financial Management Report that relates
costs incurred during the month to projected expenditures
contained in the initial report. This monthly financial
report also compares total hours expended with total hours
authorized. These data are provided both for the contract
as a whole and for each TAT office. The DPOs in each
Region should review these reports to make sure that
actual dollars and hours expended are on target with those
that have been authorized. Any problems should be
reported immediately to the P0.
As part of the monthly financial management report,
the ZPM is required to submit a detailed written report on
the status of all contract cost elements including labor,
special projects, analytical services, equipment, travel,
overtime, other direct costs, .and indirect rates/dollar
costs. This information is formatted with an executive
summary, a summary of costs on a zone—wide basis, and a
breakdown of costs on a TAT and ZPM—specific basis.
Copies of the initial and monthly financial management
reports should be distributed to the P0, CO 1 and DPOs.
1.2 Monthly Status Report
Not later than the twenty—fifth day of each month, the
TAT Leader is responsible for submitting a written report
describing the status of all tasks that have been
VI-3
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OSWER Directive 9242.4—O1A September 1987
performed during that month under TDDS issued by the
cognizant DPO. The status report should include
information on:
• Significant technical activities (provide a
breakdown by task category)
• Problems and issues (with corrective actions
taken or recommended)
• Status matrix of all active TDDs
• Manpower and personnel summary.
The DPO should review this report for accuracy and note
any inconsistencies to the P0. Copies of the report
should be distributed to the P0, CO and DPO.
1.3 Monthly Summary Progress Report by the ZPM
Fifteen days after the end of each month the ZPM is
responsible for submitting a written progress report
highlighting the activities of each TAT office during that
month and identifying any problems or unique situations
encountered during the month. The report should be
submitted to the P0 with copies simultaneously forwarded
to each DPO and to the CO.
1.4 Site—Related Financial Reports
The TAT Leader and TAT contractor field staff are
responsible for providing estimated daily cost information
within twenty—four hours on all TDDs where such cost
information is requested by the OSC. In addition, these
daily costs should be summarized each month and submitted
to the OSC in charge of the TDD as well as the cognizant
DPO.
1.5 Program Management Information Reports
At the request of the P0 the ZPM will be responsible
for developing graphical presentations of program
management information to reflect activities accomplished
by the contractor as well as the quality of the
contractor’s performance. This report should be submitted
to the P0.
1.6 Draft and Final Year—End Report
The ZPM is responsible for submitting a draft year—end
report to the PC fifteen days after the end of each
twelve—month period. The report should provide a brief
VI-4
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OSWER Directive 9242.4—O1A September 1987
summary of the activities performed and planned for
completion under the contract during the twelve—month
period being reported. The report should include an
assessment of the overall contract program (both
organizational and technical) and recommendations for
improving the effectiveness of the program.
EPA is responsible for reviewing and returning
comments on the draft report within forty—five calendar
days of receipt. The report should be reviewed by the P0,
CO , and all DPO5. All comments should be coordinated by
the PC. Ninety days after the end of the twelve—month
period, the ZPM is responsible for incorporating EPA
comments and submitting a final version of the year—end
report. Copies should be sent to the P0, CO , DPO, OSC,
Patent Adviser, and the EPA Library.
1.7 Cleanup Activity Reports
Upon request of an OSC through the DPO, the TAT Leader
and TAT contractor field staff are responsible for
providing reports with the following financial data and
document at ion:
• TAT project ceiling
• Estimated and actual costs
— Monitoring non—Federal cleanup including
personnel services, travel, and response
costs
— Federal cleanup including personnel
services, travel, other removal costs, and
equipment
— Temporary relocation of individuals and
emergency assistance including personnel
services, travel, evacuation costs, and
emergency assistance costs.
The OSC should contact the DPO if these reports are not
received within three weeks of the date of request.
1.8 Pollution Reports
Whenever the contractor is assigned to monitor an
emergency episode, a pollution report should be provided
to the DPO to document the episode for use in enforcement
actions. The report should include:
VI-5
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OSWER Directive 9242.4—O1A September 1987
• A description of the initial situation and the
cause of the spill/emergency
• A description of the organization of the response
action and the resources committed to it
• A description of the effectiveness of the
response and removal actions
• Recommendations for improving future response and
removal actions.
In addition to the pollution reports, the TAT Leader is
responsible for preparing the appropriate data forms, as
specified by the DPO, for entering information on spills
and hazardous substances into the Spill Prevention Control
and Countermeasures (SPCC) automated data system and the
Emergency Response Notification System (ERNS).
1.9 ZPM TAT Office Review Report
The ZPM is responsible for making an on—site review of
each TAT office at least once a year to check for
compliance with contract specifications and procedures and
to assess overall performance. Within three weeks of the
completion of each review, the ZPM should submit a report
of findings to the P0, CO, and cognizant DPO.
1.10 Letter Reports
At the request of the PC or DPO, the contractor is
responsible for preparing letter reports for the Office of
Waste Programs Enforcement (OWPE). These letter reports
will consist of information on:
Total labor hours and associated costs
• Total travel and administrative costs
• Total TAT costs
Statement that total cost figure is a true and
accurate accounting of costs incurred at the site
Substantiation of indirect charges
Period of work performance
Work performed
List of TDD numbers and associated hours
Copies of TDDs and Acknowledgement of Completion/
Performance Observation Reports (AOC/PORs).
VI-6
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OSWER Directive 9242.4—O1A September 1987
1.11 Socio—Economic Reports
At the end of each month the ZPM is responsible for
submitting a report that identifies the amount of funds
spent under subcontract by the TAT contractor on small
business enterprises (SBEs), minority—owned businesses
(MBEs) and woman—owned businesses (WBEs). These funds
must be tracked against contract goals established for
these business categories.
2. CENTRAL FILING SYSTEM
It is each Regions responsibility to ensure that a
centralized filing system is developed for storing all
required documentation associated with the TAT contracts.
The system should be organized to facilitate
accessibility. It is suggested that -TDDs, AOC/POR5
(interim and final), and any deliverables associated with
a project be filed together and organized sequentially.
By keeping the TDD, AOC/PORs 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) purposes is greatly simplified.
Active TDDs may be filed separately for easy access
until the project is completed and an AOC/POR (interim or
final) has been received. This will also facilitate the
tracking of projects that may become overdue.
3. TDD STATUS TRACKING LOG
It is suggested that the DPO maintain a monthly log
(manual or automated) that lists TDDs and their status.
The log may contain information such as technical hours
(estimated and actual), costs (estimated and actual),
completion date (estimated and actual), and the date the
AOC/POR is received. Many Regional TAT offices have
automated systems in place to track the status of TDDs.
Weekly reports should be generated by the contractor 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 VI—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,
it is very important that the DPO or other Regional
representatives conduct periodic spot check visits to the
contractor’s office to examine documentation such as time
VI-7 -
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OSWER Directive 9242.4—O1A September 198 7
sheets, expense records, equipment maintenance logs, and
so forth. This visit is not intended to be a formal
audit, but 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. Regular monitoring is also important to ensure
that government property is being properly maintained (see
Chapter II). Suggested guidelines for conducting a review
of Regional TAT offices are provided in Appendix D.
VI-8
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OSWER Directive 9242.4—O1A September 1987
EXHIBIT VI-1
Reports And Other Documents Required Of The TAT Contractor
Document Orlalnator Renortina Freauencv Distribution ( number of cooIes
• Financial Management ZPM 15 days after award and monthly. Each DPO 7 (Zone 1)6 (Zone 2)
Report 20 days after end of month Project Officer 1
Contracting Officer 2
• Mcnthty Status Report TAT Leader 25th day of each month Cognizant DPO 7 (Zone 1)6 (Zone 2)
Prolect Officer 1
Contracting Officer 2
• MonthlySummaryPrcgress ZPM l5daysafterendo lmonth EachDPO 7(Zonel)6(Zone2)
Report reported Project Officer 1
Contracting Officer 2
• Site-Related Financial TAT Leader & Daily, with monthly summary, as Cognizant OSC 1
Reports TAT Staff specified in eelective TDD5 Cognizant DPO 1
• TAT Of lice Review Report ZPM Once per year. 3 weeks following Project Officer 1
completion of each review Contracting Officer 2
Cognizant DPO 1
Letter Reports TAT Leader & As specified In TDD Office of Waste Programs
TAT Staff Enforcement (OWPE)
• Socio-eccnomic Reports ZPM End of each month Hazardous Sde Evaluation
Division (HSED) 1
Project Officer 1
Contracting Officer 1
Small Business Speciatist I
• Quality Assurance Data ZFM End of each month HSED 1
Reports
• Draft and Final Year-end ZPM Draft -15 days after the end Project Officer 2
Reports d each 12-month period
Anal - 90 days after the end Project Officer 5
c i each 12-monthperlod Each DPO 7(Zone l)6(Zone2)
Contracting Officer 2
Patent Advlaer 1
EPA Lbrary 1
• Program Management At direction of Project Officer Project Officer I
Information
• Pollution Reports (POLREPS) TAT Leader At the direction of the DPO Cognizant DPO I
• Cleani Activity Reports TAT Leader & Three weeks from request, as Cognizant OSC I
TAT Staff specified In selective TDDs CognIzant DPO I
Project Officer 1
Contracting Officer 1
VI-9
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EXHIBIT VI-2
SUGGESTED FORMAT FOR TDD STATUS TRACKING LOG
MONTH HOURS AVAILABLE
TDD #
DESCRIPTIVE TITLE
DATE
ISSUED
HOURS
EST. ACTUAL
COST
EST. ACTUAL
COMPLETION
DATE
EST. ACTUAL
AOC/POR
RECEIVED
(DATE)
0
c i )
ri
CD
C)
I- .’.
CD
-------
OSWER Directive 9242.4—O].A September 1987
CHAPTER VII
PERFORNANCE EVALUATION PLAN
-------
OSWER Directive 9242.4—O1A September 1987
CHAPTER VII
PERFORMANCE EVALUATION PLAN
KEY TOPICS
Page
• Cost—Plus—Award—Fee (CPAF) Performance
Evaluation Plan VII—2
• Regional Coordination of the Performance
Evaluation Process VII—3
• Organizations Roles and Responsibilities of
EPA R gional and TAT Contractor Personnel VII—3
• Preparation of Award Fee Performance
Observation Reports VII—5
• Preparing the Regional Performance Evaluation
Package: The Role of the Regional POR Vu-B
Coordinator
• Headquarters Coo rdination of the Performance
Evaluation Process VII—9
• Headquarters Evaluation Coordinator VII—9
• Performance Evaluation Board -Vu—h
• Fee Determination Official Vu—il
• Performance Evaluation Categories and Criteria Vu—h
• Performance Evaluation Categories VII—12
Performance Evaluation Criteria VII—12
Rating the Performance Events VII—13
Determination of Award Fee Percentages VII—14
Vu—i
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OSWER Directive 9242.4—OlA September 1987
CHAPTER VII
PERFORMANCE EVALUATION PLAN
1. COST—PLUS—AWARD-FEE (CPAF) PERFORMANCE EVALUATION PLAN
The TAT contracts are Cost—Plus—Award—Fee (CPAF) con-
tracts, which provide for a ‘base’ fee percentage of the
cost of the contract plus a variable “award” fee fixed at a
predetermined percentage of the estimated cost of the
contract. Each contractor is guaranteed the base fee, but
must earn all or part of the award fee through demonstrated -
performance.
Initiation of the performance evaluation process is the
responsibility of the EPA Regional offices, which are
charged with monitoring the day—to—day activities conducted
by the TAT contractors. Regional performance monitors and
Deputy Project Officers (DPOs) will review projects, tasks,
and activities performed by the contractor and complete the
Performance Observation Report portion of the Acknowledge-
ment of Completion/Performance Observation Report (AOC/POR)
forms, which are transmitted from the Region to the Proj’ect
Officer (PC), who will serve as Evaluation Coordinator. The
TAT Leader may initiate this process by preparing Part I of
the AOC/POR. Following Headquarters review, these reports
will be assembled into a package to be presented to the
Performance Evaluation Board (PEB) for award fee
determination.
Exhibit VII—l presents the organizational structure the
Agency will utilize for the award fee performance evaluation
process for the TAT contracts. This chapter outlines the
procedures that will be followed by the Regions and by Head-
quarters; their respective roles and responsibilities; and
the performance evaluation categories, criteria and sched-
ules required to successfully complete the process. The
remainder of the chapter is divided into three sections,
which include
Regional coordination of the performance evaluation
process
Headquarters coordination of the performance evalu-
ation process
Performance evaluation categories and criteria.
Example AOC/PORs and other required support documentation
are included in Appendix D for illustrative purposes.
\1II—2
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OSWER Directive 9242.4—O1A September 1987
2. REGIONAL COORD INAT ION OF THE PERFORMANCE EVALUAT ION
PROCESS
This section describes the organization, roles, and
responsibilities of EPA Regional and TAT contractor person-
nel; the preparation of AOC/PORs (hereafter referred to as
PORs); and the submission of the Regional performance
evaluation package.
2.1 Organization, Roles and Responsibilities of EPA
Regional and TAT Contractor Personnel
There are four distinct groups of EPA and contrac-
tor personnel involved with the award fee performance
evaluation process at the Regional level, which include:
EPA performance monitors
EPA TAT DPOs
EPA Regional POR Coordinators
TAT Leaders.
The roles and responsibilities of each group are high-
lighted below.
2.1.1 EPA Performance Monitors
Normally, performance monitors will be the DPO
for each Regional or ERT office where a TAT has
been assigned, and the DPO for the TAT assigned to
EPA Headquarters. On—Scene Coordinators (OSCs) may
also be designated as performance monitors by the
DPO. On occasion, performance monitors might also
include, for example, representatives from enforce-
ment or public affairs if the work performed by the
TAT contractor was explicitly assigned to support
these parties (e.g., community relations plan
development). Performance monitors will review
projects, tasks, and activities performed by the
TAT contractors, and complete CPAF PORs. DPOs are
also principally responsible for reviewing and
commenting on PORs. This may be accomplished
through consultation with appropriate performance
monitors. Details concerning the preparation of
PORs are discussed later in this section.
2.1.2 EPA Deputy Project Officers (DPOs )
The TAT DPO interfaces directly with the TAT
Leader. In addition to serving as a performance
‘111—3
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OSWER Directive 9242.4—O1A September 1987
monitor, the DPO may delegate performance monitor
responsibility to OSC5 or other appropriate
Regional personnel (see previous page), who have
been responsible for directly overseeing work ef-
forts of the TAT contractor. The DPO will also
support the Regional POR Coordinator in preparing
the Regional performance evaluation package to be
submitted to Headquarters.
2.1.3 Regional POR Coordinator
Each EPA Regional and ERT office must desig-
nate one individual who will act as the Regional
POR Coordinator and have prime responsibility for
organizing the Regional performance evaluation
package for submission to EPA Headquarters. Since
there are two TATs located in EPA Region VII that
comprise separate performance evaluation cate-
gories, this responsibility can be assumed by
either a single or two separate individuals at the
discretion of the Region.
The Regional POR Coordinator must obtain all
PORs from the DPO, and review the reports to ensure
that they have been completed accurately. In
addition, the Coordinator must review the PORs to
ensure that the rating (i.e., score) assigned’to
the performance observation is supported by the
narrative evaluation. The Regional POR Coordinator
will then organize the information into a Regional
performance evaluation package and submit the pack-
age to the Headquarters Evaluation Coordinator.
Details concerning completion of the package are
discussed later in this section.
The POR Coordinator is also responsible for
development of a numerical index of PORs and the
preparation of a narrative summary that character-
izes the quality of the contractor’s performance
during the evaluation period. This summary will
also discuss in detail the manner in which signif 1—
cant work activities were accomplished.
2.1.4 TAT Contractor Personnel
Under the direction of EPA performance
monitors each TAT Leader will prepare PORs for the
DPOs or other designated EPA performance monitor’s
review and comment. The Zone Program Manager
(ZPM) will assume responsibility for
VII—4
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OSWER Directive 9242.4—OlA September 1987
coordination of PORs prepared for overall program
management by the P0. The ZPM will also interact
with the TAT Leaders, P0, and DPOs to resolve
conflicts concerning TAT performance as reported in
individual PORs. In this capacity, the ZPM will
work with the P0 to alleviate problems identified
through the performance evaluation process, modify-
ing operating procedures for conducting activities
specified in the contract Statement of Work (SOW),
as appropriate.
2.2 Preparation of Award Fee Performance Observation
Reports
Performance information in the form of one or more
individual performance observations will be reported on
AOC/PORs and submitted directly to the cognizant Evalua-
tion Coordinator in accordance with an established
schedule. Each report will be supported by sufficient
information to provide the reader with a clear under-
standing of the significance of the observation and its
impact. The monitors will report each observation on a
separate sheet (i.e., two or more observations will not
appear on the same POR sheet).
To record the evaluation of the TAT contractors
performance, the AOC/POR form shown in Exhibits VII-2
and VII—3 will be used.* Part I, Exhibit VII—2, is
entitled Acknowledgement of Completion/Performance
Observation Report, and provides for a summary of
pertinent information regarding the work under
consideration and an overall evaluation and rating of
the TAT contractors performance. Evaluations should
document how and why the contractors performance was
meritorious or deficient. They should also be
consistent with the POR “scores given. Adjectives used
to describe the TAT5 performance should be in
accordance with those found .n the performance
spectrum. Part II, Exhibit VII—3, entitled Evaluation
Criteria Rating Worksheet, provides a worksheet that can
be used to prepare and support the overall evaluation
and rating included in Part I.
All Part I AOC/PORs will be initiated by the TAT
Leader or ZPM, who will be responsible for narratively
describing and rating contractor performance on each
completed TDD. Part II AOC/PORs, however, will be
completed only by the DPO, OSC, or P0. A blank Part II
should be attached to each AOC/POR Part I submitted by
the contractor to EPA.
* See Appendix D for a completed sample POR (Parts I and II)
VII—5
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OSWER Directive 9242.4—O1A September 1987
Once the AOC/POR is received by the DPO, a decision must
be made whether or not to treat it as a POR. The DPO is
responsible for assuring that PORs are completed on a suff 1—
cient number of Technical Direction Documents (TDDs) to rep-
resent at least 60 percent of the hours expended during the
evaluation period. If the decision is to treat it as a POR,
the DPO (or OSC) should first complete Part II of the POR
and then, based on this information, describe the contrac-
tor’s performance in the designated space on Part I of the
form and provide a rating from “1” to 5” (see Section 4.3
for an explanation of the ratings). The rating must be
consistent with the narrative description.
It is up to the DPO to decide which AOC/PORs will be
included in the Regional performance evaluation package to
be submitted to the Headquarters Evaluation Coordinator. It
is suggested that this decision be made in conjunction with
the TAT Leader. One approach is for the DPO and TAT Leader
to meet at a specified time prior to completion of each
evaluation period to discuss and decide which TDDs should be
included in the Regional evaluation package. Another
approach, and one which is strongly recommended, is to meet
several times throughout the trimester. By doing this,
submission of AOC/PORs to the P0 could be staggered and an
unnecessary rush avoided at the end of each evaluation
period.
In filling out the Part II Worksheet, the DPO should
include all these information elements:
Contract No : Should agree with TDD.
Contractor : Should agree with TDD.
TDD No. ; Should agree with TDD.
Reporting Element : The particular TAT being
observed.
Date(s) of Reported Observation : The period
of performance of the TDD activities.
Approx. No. of Hours : The level of effort of
the TDD activities.
Performance Evaluation Category : The SOW ac-
tivity being conducted.
Contractor Representative : The name of the
TAT Leader.
EPA Performance Monitor : The name of the per-
formance monitor, either the DPO or a designee.
VII—6
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OSWER Directive 9242.4—O1A September 1987
For information on preparing the remainder of Part II,
see section 4 of this chapter.
Upon completion of Part II, the following sections
of Part I (prepared by the contractor at the completion
of the activity) should be completed:
Description of EPA Observation : Presents a
summary of what was observed by the EPA per-
formance monitor.
Rating : A consensus or overall rating based
on a subjectively weighted average of the six
ratings recorded on Part II prepared by EPA.
Signature of EPA and Date : Self—explanatory.
Signature of Regional POR Coordinator and
Date : An indication that the POR has been
reviewed for completeness and consistency.
HQ Coordinators Evaluation : Completed for
each POR. The HQ Coordinator must justify any
deviation in performance rating.
Rating : Should agree with EPA performance
monitors rating, unless justified as above.
Signature of HQ and Date : Completed on all
PORs.
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 together
under one TDD. Otherwise, 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 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
Regional performance evaluation package.
Any discrepancies between performance evaluations
prepared by EPA performance monitors and TAT contractor
personnel should be addressed and discussed with the
contractor by the DPO, and resolved if possible. If
issues cannot be resolved, they should be so noted by
the DPO and forwarded through the POR Coordinator to the
Headquarters P0 for further discussion and resolution
with the contractor.
VII—7
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OSWER Directive 9242.4—O1A September 1987
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. PORs should be submitted as tasks
are completed to the Regional POR Coordinator to avoid
delays in reviewing PORs and preparing the Regional per-
formance evaluation package. At a minimum, EPA person-
nel responsible for preparing PORs should complete and
sign Part II of the POR, Evaluation Criteria Rating
Worksheet, as soon as work requested by a TDD is com-
pleted. This will aid the performance monitors recall
of the contractor’s performance, particularly when
Part I of the POR, Observation Description and Overall
Evaluation, is to be completed at a later time or by
another person.
Deadlines for submission of all PORs are specified
in the Award Fee Performance Evaluation Plan Calendar.
(See Exhibit VII—4). These deadlines must be strictly
adhered to in order to permit the Regional POR
Coordinator to prepare and submit the Regional
performance evaluation package to the Headquarters
Evaluation Coordinator. Copies of any PORs which
identify less than satisfactory contractor performance
should be forwarded immediately by the DPO through the
POR Coordinator to the Headquarters P0. DPOs need to
provide an early alert to ERD of TAT management
problems. This will permit problems to be identified
and resolved quickly.
2.3 Preparing the Regional Performance Evaluation
Package: The Role of the Regional POR Coordinator
The Regional POR Coordinator will have prime
responsibility for organizing the Regional performance
evaluation package for submission to EPA Headquarters.
The Coordinator will receive PORs from the DPO and
assess and validate the reports to ensure that they have
been completed accurately. The information will then be
organized into a Regional performance evaluation package
and submitted to the Headquarters Evaluation Coordina-
tor. The Regional performance evaluation package should
include:
A cover memorandum (i.e., narrative summary),
delineating highlights, significant events or
problems during the performance period and
give an overall evaluation of contractor per-
formance; an example is given in
Exhibit VII—5. It is very important that the
POR Coordinator provide extensive detail in
VII—8
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OSWER Directive 9242.4—O1A September 1987
the narrative summary regarding “highlights
and/or deficiencies of the contractors
performance.
A summary table, as shown in Exhibit VII—6,
with the appropriate portion completed by the
Regions indicating the approximate hours ex-
pended for each task, project, or activity
reported along with the EPA Regional and con-
tractor ratings, and an overall weighted aver-
age rating for the Region
• A comparison of the total number of hours for
which PORs have been submitted versus the
total hours worked for a given period
• PORs clearly identified by the contract
number, descriptive title of work, and TDD
number.
All information should be typed , if at all possible, and
submitted to the EPA Headquarters Evaluation Coordinator
according to the Award Fee Performance Evaluation Plan
Calendar shown in Exhibit VII—4. The POR Coordinator
should be sure that the evaluation package is complete
before it is sent. When assembling the performance
evaluation package, the Regional POR Coordinator should
clearly indicate that Part II of each POR (the
Worksheet) has been completed by the DPO or the EPA task
monitor.
3. HEADQUARTERS COORDINATION OF THE PERFORMANCE EVALUATION
PROCESS
There are three main organizational components at Head-
quarters concerned with the performance evaluation process:
Evaluation Coordinator
• Performance Evaluation Board (PEB)
• Fee Determination Official (FDO).
The roles and responsibilities of each are discussed below.
3.1 Headquarters Evaluation Coordinator
Within EPA Headquarters, the TAT P0 will be
responsible for organizing and overseeing the award fee
performance evaluation process, serving as the Head-
quarters Evaluation Coordinator. The Evaluation Coordi—
nator s primary responsibility involves coordination and
VII—9
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OSWER Directive 9242.4—O1A September 1987
presentation of a performance evaluation package to
the PEB. In addition, the Evaluation Coordinator
will prepare the PORs for the program management
evaluation category. Specific responsibilities
include:
Receive and review information contained in
Regional performance evaluation packages
Investigate and resolve EPA/contractor dis-
crepancies
• Prepare PORs for the ZPMO
Prepare an evaluation package for the PEB
containing individual PORs for each of the
performance evaluation categories and summary
information concerning the contractors per-
formance
• Attend the PEB review meetings, serving as
Executive Secretary and presenting information
contained in the evaluation package.
Preparation of the PEB evaluation package dominates the
efforts performed by the Evaluation Coordinator. The
remainder of this discussion will focus on this activity.
The Headquarters Evaluation Coordinator will review
the POR5 submitted by the Regions and the contractor.
The Evaluation Coordinator must also resolve any dif-
ferences which still remain between Regional personnel
and the contractor with respect to individual POR5.
The Headquarters Evaluation Coordinator must
provide a narrative description on all PORs, and then
sign and date the report. If the Coordinator disagrees
with the rating or information contained in the report,
the Coordinator must cite reasons for non—concurrence,
and justify any difference in the performance rating.
The PORs should be grouped according to TAT office,
which, except for the Headquarters TAT and program
management category, should coincide with the Regional
performance evaluation packages submitted.
The Headquarters Evaluation Coordinator will be
responsible for preparing and presenting all material
required by the PEB to make its assessment of the con—
tractors performance in the form of a PEB evaluation
package. The material will be organized in such a man-
ner as to enable it to serve both as the PEB’s agenda,
and as the complete documentation package which will
vu—b
-------
OSWER Directive 9242.4—O1A September 1987
support the PEB’s fee recommendation. The PEB evalua-
tion package will be organized into separate sections
for each reporting element (see Exhibit VII—7).
The entire PEB evaluation package must be sent to
the PEE members at least five (5) work days prior to
convening the PEB review.
3.2 Performance valuation Board (PEB )
The PEB will perform an in—depth review of inforrna—
tion contained in the performance evaluation package to
arrive at the recommended award fee. In accordance with
EPAAR 1516.404276, The Head of the Contracting Activity
(HCA) will determine, in concert with -the’ responsible
program office, the participants in the award fee
process.” For the TAT contracts, the FEB will consist
of a chairperson, an executive secretary and several
board members all appointed by the Head of the
Contracting Activity from within the ranks of the
Agency. The members of the PEB are listed in
Exhibit Vu—a.
The award fee will be allocated based on a fee
allocation matrix containing the maximum award fee
available for each evaluation category per each
evaluation period, for the TAT contracts. The Fee
Allocation Matrix for the TAT contracts is shown in
Exhibit VII—9.
Following the PEB meeting at which the award fee
recommendation is reached, the Executive Secretary will
prepare a Performance Evaluation Report which will be
the official record of the PEE meeting and forward this
to the Contracting Officer (Ca). The CO will prepare a
letter for signature by the Fee Determination Official
(FDO) informing the contractors ZPM of the amount and
basis of the fee awarded.
3.3 Fee Determination Official (FDO )
The FDO will review the performance evaluation and
the fee recommendation made by the PEB and make a final
determination of fee. Following concurrence by the FDO,
an award fee notification letter will be sent to the TAT
contractor, who will in turn submit a voucher for pay-
ment of the award fee.
4. PERFORMANCE EVALUATIOJ CATEGORIES AND CRITERIA
The TAT contractor’s performance will be evaluated on
the basis of the contractor’s ability to provide the neces-
sary personnel, services, equipment and materials to support
Vil—il
-------
OSWER Directive 9242.4—O1A September 1987
the EPA S emergency response, removal and prevention program
in various performance categories that correspond to the
contractor’s organization of resources to execute the
contract SOW. Performance in each of the categories will be
evaluated according to a standard set of criteria. The
following sections highlight a description of the categories
and criteria to be used by EPA personnel in evaluating the
TAT contractors performance.
4.1 Performance Evaluation Categories
Each individual TAT will be evaluated as a distinct
reporting element, as shown in Exhibit Vu—i. All work
assigned to the TAT by either the EPA Regional, ERT or
Headquarters office may be subjected to a performance
evaluation. The performance evaluation categories,
which correspond to the different types of response
activities included on the TDD form (and shown in
Appendix C), are as follows:
CWA-311
— sPCC
— On—scene monitoring
— Spill cleanup funded
CERCLA
— Site assessment
- Removal funded
- Removal PRP (AO/CO)
— On—site monitoring
Other Activities
— Special project
— Analytical project
— Title III
- UST
- FEMA
— Quality assurance
— Training
— Program management
— Technical assistance
— Information management
4.2 Performance Evaluation Criteria
In order to evaluate the TAT contractors perfor-
mance, a set of evaluation criteria has been developed
for the evaluation categories. The performance
evaluation criteria are presented in Exhibit Vil—lO.
VII—12
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OSWER Directive 9242.4—O1A September 1987
The evaluation criteria are generic and were developed
to provide a uniform basis by which to evaluate any work
performed by the contractor, regardless of the TAT
responsible for performing the work. The application of
the criteria is the responsibility of the individual
performance mLn.t”i and must be reviewed by the
Regional and Heaoguarters officials responsible for
coordinating the performance evaluation process.
The remainde’ of this section focuses on: 1) the
guidelines for raring the contractors performance with
respect to the criteria for a given performance observa—
tion; and 2) the translation of the performance evalua-
tion category ratings into award fee percentages by the
PEB.
4.3 Rating the Performance Events
Part II of the Award Fee POR (Evaluation Criteria
Rating Worksheet, Exhibit VII—3), lists the individual
criteria that the performance monitors will use in
rating the contractors performance Next to each of
the criteria is a scale ranging fr. r’ to 1, which is
interpreted as indicated below:
“5” — Exceptional
“4” — Exceeded expectations
“3” — Satisfactory
2’ — Marginal
— Unsatisfactory
Exhibit Vu—h provides example guidelines for using the
rating scale to score each of the criteria. In addition
to rating each of the individual criteria, the perfor-
mance monitor should also provide supporting comments to
justify the rating given. It is very important that the
tone of these supporting comments be consistent with the
POR ‘ratings.’ Also, the adjectives used to iescribe
the TAT’s performance should be in accordance with those
found in the perf”rmance spectrum.
A consensus or ierai1 rating for the six criteria
should then be recorded ‘ ri Part I of the POR. A consen-
sus or overall rating ili be used in lieu of an arith-
metic average rating to permit the performance monitor
to subjectively weight the individual criteria with
respect to any given performance observation. The
Part I rating should always reflect the Part II
ratings. The performance monitor must also prepare a
narrative to describe the contractor’s overall
performance for the observation, which can be drawn from
the supporting comments made on the work sheet for each
of the individual criteria.
SJII—l3
-------
OSWEi Directive 9242.4—O1A September 1987
4.4 Determination of Award Fee Percentages
There are separate PEBs for each TAT contract. The
Zone I PEB will receive a performance evaluation package
for the Zone I TAT contractor. Similarly 1 the Zone II
PEB will receive a package for the Zone II contractor.
Each package will consist of PORs grouped according to
performance evaluation category. Each evaluation
category will also be headed with a summary of the PORs
included in the category, the number of hours for each
observation, and the rating for each observation (See
Exhibit VII—6, Summary of Contract Performance
Observation Reports).
In completing the Summary of Contract Performance
Observation Reports, the Headquarters Evaluation Coordi-
nator will calculate a weighted average rating for each
performance evaluation category. The weighted average
ratlng will be calculated by multiplying the Headquar-
ters ra’ in g for a performance observation by the number
of hours expended by the TAT to complete the work
covered y :ne POR. These weighted ratings for all the
POR5 inci ded in each category will then be totaled and
divL ed by the total number of hours expended for all
rk inn ided in the summary for each category to deter-:
mine the weighted average rating.
The weighted average rating wil’ the: 1 ne considered
in determining the award fee percentages f ’ each TAT
office by the PEB. In addition to ‘ i - w’ 1Qht- d average
ratings, the PEB will also use the f .. iJc ::’c three
criteria to determine award fee percer ta es
Consistency — Contractor has demonstrated con-
sistent high/low quality in performance under
the contract
Improvement — Contractor has shown a substan-
tial or steady progression of improvement over
the previous evaluation period(s)
Unsatisfactory — Contractor has receive a sat-
isfactory or an above—average weighted average
rating for an evaluation category, but has
received unsatisfactory ratings on significant
individual performance event reports.
The PEB will also observe the definitions of performance
evaluation associated with various ranges of award fee
percentages assigned for each performance category as
shown in Exhibit VII—l2.
VII—14
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OSWER Directive 9242.4—O1A
September 1987
EXHIBIT Viii
CPAF PERFORMANCE EVALUATION ORGANIZATiON
TAT CONTRACTS
• AWARD FEE RECOMMENDATiON
• PERFORMANCE EVALUATION REPORT
PERFORMANCE EVALUATION
BOARD (PEB)
• ALL REPORTED PORS
I . SUMMARY OF SIGNIFICANT
_____I PERFORMANCE OBSERVATION REPORTS (PORs)
HO EVALUATION
_____ COORDINATOR
•I
• REGIONAL PERFORMANCE
EVALUATION PACKAGE
REGIONAL PERFORMANCE
EVAI .UA11ON COORDINATOR
r
INDIVIDUAL PORs
TATDEPUTY
PROJECT OFFICER
I I I I
I II II II I
PERFORMANCE MONITORS
• - - - - - - -. EPA PERSONNEL COORDINATE ThE COMPLETION OF
PORs WITH TAT LEADERS TO ENSURE ThAT PERSPECTIVES OF
THIRD PARTIES ARE RECEIVED ON ANY GIVEN WORK UNDER
EVALUATION.
• LETTER OF PERFORMANCE AND AWARD
FEE DETERMINATION
____ OFFICIAL ( FDO )
A
1
CONTRACTOR
CONTRACTOR
I
I
U
I
U
I
I
* 1
— — a a a a a a a a a a a a a a a a a a a
• CONTRACTOR INITIATED I
PERFORMANCE OBSERVATION
REPORTS (POR5)
I
U
4a a a a a a a a a a a a a a a a a a a a a a a a a a aa
VII—15
-------
EXHIBIT VII—2(1)
center ACKNOWLEDGEMENT OF COMPLETiON
PERFORMANCE OBSER 1ON REPORT; I
TDO No.
C itract No: Cor*racior
68 .01 .7357 Roy F aton, Inc.
Reporting ElerTlent Date(s) of Reported Observation Approx. No. of Hours 0 Format Report
0 Letier Report
Performance Evajuabon Category 0 Formal Bnellng
Descn*Ofl of Convaclor Observation By 0 Oew (SpeCify)
Narnelme
Rating: 5,42,2 .1 Sq a1ure of Contractoc
DeecnØon of E Observabon By
Namerflee
R iig: 5,4,32,1 Sqiature of E
SgiiatLzs of Regional POP Coo,c nator
HO Coordinator’s Evaluation By
Name/Titie
Date:
Rating: 5,4,32,1 Sçnature of H0
0 Rejoled
OPO A iort 0 Moe d 0 k oepled wIth E caØons
Coat To D :__________ Date:__________ A ual T I Hoin
Coat b Ctomae
I o&Wy 1a tte aI hed a la meat and con wIth
reqsiremer of the r ’je TOO.
1 L Sigriattie (WlsiiIn) 1 L Slgflet%tS (Fui&)
U-
anm
Anal
I aclu oMedge that I have been pr ded w the malenals er
services ap.c ed v i the sii, ect TOO within i orfginal or
re sed time frames
OPO Sionabse f ao m )
Fmal
Sheet 1 White• Hdqtrs Coordinator
Sheet 2 White• DPO Copy
Sheet 3 Blue• TAIL Copy
Sheet 4 Green . ZPM Copy
Sheet 5 Canary - Project Officer Copy
Sheet 6 Pink. Contracting Officer Copy
Sheet 7 Goldsnrod DPO (Interim Copy)
vII—1€
-------
.MiJ. iI V.LJ.4(4)
ptemoer 1987
DistrsbutsO. . -- -
SNsst I WP it. HOS Coo,din.,o,
SI .st 2 Wi ,t. OPO Coev
SP ..t 3 Lus TATL CODY
SPiw 4 G’-s ZPM CoDy
Sh..t S C.nwy P0 Co v
SP .st Pisk CO Coov
SP ..1 7 GeIosr ,od OPO IntSri
COST CENTER ACKNOWLEDGEMENT OF COMPLETION
PERFORMANCE OBSERVATION REPORT: PARTS
CONTRACT NO.
68017368
CONTRACTOR .
Ecology and Environment. Inc.
TOO NO.
REPORTING ELEMENT: DATE(S) OF REPORTED OBSERVATION APPROX.. NO. OF HOURS
ACCOUNT NO.
PERFORMANCE EVALUATION CATEGORY:
DESCRIPTION OF CONTRACTOR OBSERVATION BY:
RATING: 5. 4. 3.2, 1 SIGNATURE OF CONTRACTOR: . DATE:
DESCRIPTION OF EPA OBSERVATION BY:
NAMEITITLE
RATING: 5. 4. 3. 2. 1 SIGNATURE OF EPA. DATE:
SIGNATURE OF REGIONAL POR COORDINATOR: . DATE:
HO COORDINATOR’S EVALUATION BY.
NAME/TITLE
RATING. 5, 4 3, 2. 1 SIGNATURE OF HO: DATE:
OPO ACTION: ACCEPTED ACCEPTED WITH EXCEPTIONS REJECTED
COST TO DATE: DATE: ACTUAL TOTAL HOURS:
TOTAL COST TO CLOSURE;
I CERTIFY THAT THE ATTACHED MATERIALS MEET AND COMPLY WITH ALL
REQUIREMENTS OF TH( SUBJECT TDD.
S
TATL SIGNATURE (INTERIM) . TATL SIGNATURE (FINAL)
DATE:
INTERIM
FINAL
I ACKNOWLEDGE THAT I HAVE BEEN PROVIDED WITH THE MATERIALS AND
SERVICES SPECIFIED IN THE SUBJECT TDD WITHIN ITS ORIGINAL OR
REVISED TIME FRAMES .
OPO SIGNATURE (INTERIM) DPO SIGNATURE (FINAL)
DATE:
INTERIM
FINAL
T006A03.
VII—17
-------
- s _ _‘ 4_ • x
EXHIBIT VII-3
TAT CPAF CONTRACT PERFORMANCE OBSERVATION REPORT (POR)
PART II. EVALUATION CRITERIA RATING WORKSHEET
CONTRACT NO.: O1 736 CONTRACTOR: TOO NO.:
REPORTING ELEMENT: DATE(S) OF REPORTED OBSERVATION APPROX. NO. OF HOURS
PERFORMANCE EVALUATION CATEGORY:
CONTRACTOR REPRESENTATIVE
EPA PERFORMANCE MONITOR
PER FORMANCE CRITERIA
RATING
SUPPORTING COMMENTS
PROJECT PLANNING
— Organizing (E.G., Work Plan
Dev.Iopment. Oat. Reyiaw)
— Scheduling
- Budgeting
3
2
1
.
TECHNICAL COMPETENCE & INNOVATION
— Efl.ctiv.nss sofAnalyr s
— Meet Plan Goals
— Adhere to Regi. & Procedures
— Approach Cr.ativity/Ingenuity
5
4
2
.
SCHEOULE&COSTCONTROL
— Budget (Hours & Cost) Maintenance
— Priority /Schedule Adjustments
— Cost Minimization
—
5
3
2
.
REPORTING
— TimeIins of Deliverables
—Clarity
— Thoroughness
5
3
2
1
.
RESOURCE UTILIZATION
— Staffing
— Subcontracting
— Equipment. Trav.I. Etc.
5
4
3
2
I
.
Distribution.
Sheet 1 White HOS Coordinator
Sheet 2 Blue OPO Coov
Sheet 3 Green TATL Copy
Sheet 4 Canary ZPM COPY
Sheet 5 Pink P0 COPY
Sheet 6 GoId.nrod . CO Copy
EFFORT
— Responsiveness
— Mobilization
— Day.to-day
— Special Situation (E.G., Adverus/
Dangerous Conditions)
5
4
3
2
1
VII—18
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OSWER Directive 9242.4—O1A September 1987
EXHIBIT VII—4(l)
Award Fee Performance Evaluation Plan Calendar
Performance Evaluation December 16, 1986 —
Period #1 _ -- May 31, 1987
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period 5/22/87
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator 5/29/87
Regional Performance Evaluation
Package Due to Headquarters
Project Officer 6/5/87
Headquarters Performance
Evaluation Package due to PEE 6/15/87
PEB Review Meeting 6/23/87
Award Fee Notification
Letter to Contractor 7/13/87
Performance Evalua ior. June 1, 1987 —
Period #2 - - September 30, 1987
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period 9/21/87
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator 9/28/87
Regional Performance Evaluation
Package Due to Headquarters
Project Officer 10/ /87
Headquarters Performance
Evaluation PacKage due to PEE 10/12/87
PEB Review Meeting 10/22/87
Award Fee Notification
Letter to Contractor 11/11/87
VII—19
-------
OSWER Directive 9242.4—O1A September 1987
EXHIBIT VII—4(2)
Performance Evaluation October 1, 1987 —
Period #3 January 31, 1988
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period 1/25/88
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator 2/1/88
Regional Performance Evaluation
Package Due to Headquarters
Project Officer 2/8/88
Headquarters Performance
Evaluation Package due to PEB 2/15/88
PEB Review Meeting 2/23/88
Award Fee Notification
Letter to Contractor 3/12/88
Performance Evaluation February 1, 1988 —
Period #4 May 31, 1988
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period 5/23/88
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator 5/30/88
Regional Performance Evaluation
Package Due to Headquarters 6/6/88
Project Officer
Headquarters Performance
Evaluation Package due to PEB 6/13/88
PEB Review Meeting 6/21/88
Award Fee Notification
Letter to Contractor 7/11/88
VII—20
-------
OSWER Directive 9242.4—O1A September 1987
EXHIBIT VII—4(3)
Performance Evaluation June 1, 1988 —
Period #5 - September 30, 1988
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period 9/19/88
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator 9/26/88
Regional Performance Evaluation
Package Due to Headquarters
Project Officer 10/3/88
Headquarters Performance
Evaluation Package due to PEB 10/10/88
PEB Review Meeting 10/17/88
Award Fee Notification
Letter to Contractor 11/7/88
Performance Evaluation October 1, 1988 —
Period #6* January 31, 1989
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator
Regional Performance Evaluation
Package Due to Headquarters
Project Officer
Headquarters Performance
Evaluation Package due to PEB
PEB Review Meeting
Award Fee Notification
Letter to Contractor
* Only if the opt .on to extend the contract for two years
is exercised.
VII—21
-------
OSWER Directive 9242.4-O1A September 1981
EXHIBIT VII—4(4)
Performance Evaluation February 1, 1989 —
Period #7* May 31, 1989
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator
Regional Performance Evaluation
Package Due to Headquarters
Project Officer
Headquarters Performance
Evaluation Package due to PEB
PEE Review Meeting
Award Fee Notification
Letter to Contractor
Performance Evaluation June 1, 1989 —
Period #8* September 20,1989
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator
Regional Performance Evaluation
Package Due to Headquarters
Project Officer
Headquarters Performance
Evaluation Package due to PEB
PEB Review Meeting
Award Fee Notification
Letter to Contractor
* Only if the option to extend the contract for two years
is exercised.
VI 1—22
-------
OS E Directive 9242.4—O1A September 1987
EXHIBIT VII—4(5)
Performance Evaluation October 1, 1989 —
Period #9* January 31, 1990
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator
Regional Performance valuation
Package Due to Headquarters
Project Officer
Headquarters Performance
Evaluation Package due to PEB
PEB Review Meeting
Award Fee Notification
Letter to Contractor
Performance Evaluation February 1, 1990 —
Period #10* Ma131 , 1990
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator
Regional Performance Evaluation
Package Due to Headquarters
Project Officer
Headquarters Performance
Evaluation Package due to PEB
PEB Review Meeting
Award Fee Notification
Letter to Contractor
* Only if the option to extend the contract for two years
is exercised.
VII—23
-------
OSWER Directive 9242.4—O1A September 1987
EXHIBIT VII—4(6)
Performance Evaluation June 1, 1990 —
Period #11* September 30, 1990
Cut—off Date for Contractor
Activities to be considered
for Subject Evaluation Period
Last Day Performance Observation
Reports are accepted by Regional
POR Coordinator
Regional Performance Evaluation
Package Due to Headquarters
Project Officer -
Headquarters Performance
Evaluation Package due to PEB
PEB Review Meeting
Award Fee Notification
Letter to Contractor
* Only if the option to extend the contract for two years
is exercised.
VII—24
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OSWER Directive 9242.4—OlA September 1987
€0 ST4
EXHIBIT VII-5
‘ L P O
U. S. ENVIRONT ENTAL PROTECTION AGENCY
REGION X
Example Cover Memorandum f or Regional Award
Fee Performance Evaluation Package
DATE: 20 June 1986
SUBJECT: Region X TAT Performance Observation Reports for the
Period 1 February to 30 May 1986 (Second Trimester
of Fiscal Year 1986, Second TAT Contract Option -
Year) -
FROM: John Smith, Regional POR Coordinator
TO: Jack Jones, EPA Headquarters TAT Project Officer
Enclosed is the Performance Observation Report (POR)
Summary statement for the second trimester reporting period
for Fiscal Year 1986. Also enclosed are the final eleven
PORs generated during the evaluation period. A total of 35
tasks have been evaluated .during the 1 •February to 30 May
1986 reporting period. A total of 3,468 hours have been
evaluated representing 65% of the total TAT TDD hours
expended for the trimester.
The Region x team continues to provide consistent high
quality support to the Region SRES staff in all phases of
the removal and emergency response program. Due to the
restrictions in CERCLA funding tnrough most of the reporting
periods site assessment activities composed the vast
majority of the TAT effort through the spring months. The
latter part of the trimester has been solely devoted to two
major removal actions at the Bunker Hill NPL site in
northern Idaho, and at the Standard Steel Metals and Salvage
Yard in Anchorage, Alaska. However, these efforts are not
reflected in this evaluation package. The team continues to
strive to upgrade the programs overall removal and response
capabilities through improved data and information
management systems. enhanced electonic communications and
continued improvements in basic field operations.
The primary focus of the TAT effort remains with waste
site assessments and investigations. Of the total hours
evaluated in the period, 68% were for site assessment and
investigative activities, 12% were to provide training, 7%
were for oil spill responses and 5% were for contingency
planning. TDD issuance in the period follows a similar
trend of heavy TAT utilization in assessment, response and
VI 1—25
-------
OSWER Directive 9242.4—O1A September 1987
removal operations with 84% of the 44 tasks being written
for field action (23 for assessments, 6 for oil spills, 5
for removals and 3 for hazardous material spill response).
The expansion of the Region 10 TAT in the first
trimester of this year has proven to be extremely beneficial
in light of the high level of activity currently underway in
the program. The two new members have rapidly developed
into pragmatic, reliable response personnel and have proven
themselves in a wide variety of response situations. The
team remains fully staffed, ensuring maximum continuity
through the remainder of the contract.
As a result of the heavy emphasis on site assessment
operations in the past trimester, the TAT was involved in a
wide variety of field operations during the reporting
period. The team demonstrated excellent versatility in
revising a sampling program for an extensive site assessment
on very short notice. The assessment of the American
Plating Facility in Tacoma, Washington was scheduled for two
full days to inventory, characterize and sample 80
processing tanks and a septic tank including acidic, caustic
and cyanide wastes; as well as to inventory other containers
on site and conduct a soil extent—of—contamination survey.
Due to difficulties in negotiations between the responsible
party and the state DOE, access was restricted to a
five—hour time .period. The team quickly and effectively
revised field techniques and procedures and were able to
complete a thorough investigation within the time frame
imposed. The TAT has also significantly upgraded their
sample characterization procedures and were able to realize
cost savings of three to five thousand dollars by screening
and categorizing samples.
The TAT also demonstrated excellent adaptability and
overall field expertise at an assessment of the Heifrich
Property site in Portland, Oregon. Site files in the Region
and indicated that the site contained approximately 50 drums
of ui known origin. Upon arriving at the site and conducting
a pre—sampling inventory of the grounds and barn that was
used for storage, the residential site was found to have
approximately 200 55—gallon drums and several thousand
containers of various sizes, types and materials. The team
was effective in revising the assessment program to provide
a thorough materials inventory, open and sample an adequate
number of containers to achieve a reasonable representation
of materials present, perform a brief soil contamination
survey and provide a well documented evaluation of the
health and environmental threat posed by the facility.
Significant savings (perhaps twenty to fifty thousand
dollars) in analytical costs were again realized through the
teams field characterization and data was provided
VII—26
-------
OSWER Directive 9242.4—O1A September 1987
immediately indicating that many of the products in storage
were highly flammable paint products falling under RCRA
regulation. The TAT field effort required extended periods
in Level B protection. The assessment was completed in a
safe and highly effective manner.
During the report period TAT personnel also responded on
short notice to a vapor release of formaldehyde from a
leaking rail car in Alaska. Two TAT members responded
directly from the office within hours for an extended stay
on the Kenai Peninsula. The team assisted local, state and
federal personnel with air, soil and snow sampling; and with
an assessment of the impacts of the r elease on towns in the
vicinity of Moose Pass. TAT members also worked on a
response to a 60,000—gallon diesel fuel spiIl from the
ruptured Olympic Pipeline in Tukwila, Washington. The TAT
provided a rapid, acurate evaluation of the quantity of
spilled product reaching the adjacent Green River and a
wetland area. Team members closely tracked tne progress and
effectiveness of the cleanup and subsequent mitigative
measures.
In summary, the Region 10 TAT continues to serve the EPA
SRES in a highly professional, effective and competent
manner. The composition and responsiveness of the team has
proven to be highly consistent throughout the program. All
subcontract services have been provided in a timely and well
managed fashion. The team has utilized their equipment and
computer systems very effectively and are continually
seeking to upgrade the quality of service provided.
Accordingly, an award fee in the range of 70—80% is
suggested. If you have any questions regarding this
evaluation please feel free to contact me at FTS 8—555—1234.
VII—27
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September 1987
OSWER Directive 9242.4—O1A
EXHIBIT VII—6
SUMMARY OF TAT CONTRACT PERFORMANCE OBSERVATION REPORTS 7
CONTRACT NO. CONTRACTOR
PERFORMANCE EVALUATION CATEGORY PERIOD ENDING
CONTRACTOR. TATt. OR NPM TAT GPO
TOTAL HOURS REPORTED TOTAL HOURS WORKED
PERCENT OF HOURS REPORTW
1DO
NUMSIR
DESCRIPTIVE TITLE oc worn
!
wg
IA)
IS)
PENOED
IC)
WEIGHTED
RATINGS
REGION HO
(AIiICI IS) (C)
TOTAL HOURS
PENDED
l
I
REGIONAL
TOTAL OF REGIONAL WEIWITID RATINGS (A) z (C) • AVERAGE
TOTAL HOURS P1N0ED (C) •
HEADQUARTERS
TOTAL OF 140 WEIGHTED RATINGS IS) IC) • AVERAGE
• WEIGHTED
TOTAl HOURS WV’IDID (C) • RATING
REGIONAL FOR COORDINATOR (S., .i HO IVAWAT1ON COORDINATOR IS ie .
•I Iy I - -
a I *
a
VII—28
-------
OSWER D rec ive 9242.4—O1A September 1987
EXHIBIT VII—7(l)
Reporting Elements
ZO1 TE 1
Each TAT associated with the following EPA office loca-
tions will be evaluated as a separate reporting element.
These eight elements include:
Region I
Region II (including satellite office for
Puerto Rico)
Region III (including satellite office for
Wheeling, West Virginia)
Region IV (including satellite offices for
Memphis, Tennessee, and Louis-
ville, Kentucky)
Region V (including satellite offices for
Cleveland, Ohio; Detroit, Michi-
gan; and Cincinnati, Ohio)
ERT Edison
EPA Headguarters TAT
ZPMO
VII—29
-------
OSWER Directive 9242.4—O1A September 1987
EXHIBIT VII—7(2)
Reporting Elements
ZONE 2
Each TAT associated with the following EPA office loca-
tions will be evaluated as a separate reporting element.
These seven elements include:
Region VI (including two satellite offices
for Houston, Texas, and Baton
Rouge, Louisiana)
Region VII Environmental Services Division
(ESD)
Region VII Waste Management Division (WMD)
Region VIII
Region IX (including satellite office for
Los Angeles, California)
Region X
ZPMO
VII—30
-------
OSWER Directive 9242.4—O1A September 1987
EXHIBIT VII—8(1)
TAT Contract Performance Evaluation Board
Zone 1
Fee Determination Official
Mr. Richard Mueller - Acting Chief, Emergency
Response Branch
Procurement and Contracts
Management Division
Performance Evaluation Board
Mr. Walter W. Kovalick, Jr. — Deputy Director, OERR
(Chairman)
Mr. Timothy Fields, Jr. — Director, Emergency Re-
sponse Division (Alternate
Chairman)
Mr. Bruce Engelbert — Director, Office of Program
Management
Mr. Thomas Sullivan — Head, Removal Contract
Administration Section
Mr. Hans Crump—Wiesner — Deputy Director, Emergency
Response Division
Mr. Ira Wilder — Chief, Releases Control
Branch, Region II
Mr. James Makris — Director, Preparedness Staff
Mr. George Moein - Chief, Emergency Response
and Control Section,
Region IV
Mr. Thomas Voltaggio — Chief, Superfund Branch,
Region III
Evaluation Coordinator and Executive Secretary
Mrs. Patricia Hawkins — Eastern Operations Section,
Emergency Response Division
VI 1—31
-------
OSWER Directive 9242.4—O1A
September 1981
EXHIBIT VII—8(2)
TAT Contract Performance Evaluation Board
Zone 2
Fee Determination Official
- Acting Chief, Emergency
Response Branch,
Procurement and Contracts
Management Division
Performance Evaluation Board
Mr. Walter W. Kovalick, Jr. — Deputy Director, OERR
(Chairman)
Mr. Timothy Fields, Jr. — Director, Emergency Re-
sponse Division (Alternate
Chairman)
— Director, Office of Program
Management
— Head, Removal Contract
Administration Section
— Deputy Director, Emergency
Response Division
— Chief, Releases Control
Branch, Region II
— Director, Preparedness Staff
— Deputy Project Officer.
Region VI
— Deputy Project Officer,
Region VIII
and Executive Secretary
— Western Operations Section,
Emergency Response Division
Mr. Richard Mueller
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Bruce Engelbert
Thomas Sullivan
Hans Cruxnp—Wiesner
Ira Wilder
James Makris
Gerald Fontenot
Floyd Nichols
Evaluation Coordinator
Mrs. Patricia Hawkins
VI 1—32
-------
OSWER Directive 9242.4—O1A September 1987
iIBIT VII—9(1)
Award Fee Allocation Matrix for TAT Contract
Zone 1
Percent of Available Fee/Category Period*
Performance 1 2 3 4 5 6 7 8 9 10 11
Categories ?g %
Region I 10.6 10.6 10.6 10.6 10.6 10.6 10.6 10.6 10.6 10.6 10.6
Region II 17.6 17.6 17.6 17.6 17.6 17.6 17.6 17.6 17.6 17.6 17.6
Region III 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0
Region IV 13.4 13.4 13.4 13.4 13.4 13.4 13.4 13.4 13.4 13.4 13.4
RegionV 19.7 19.7 19.7 19.7 19.7 19.7 19.7 19.7 19.7 19.7 19.7
ERT 3.6 3.6 3.6 3.6 3.6 3.6 3.6 3.6 3.6 3.6 3.6
Head-
quarters 7.7 7.7 7.7 7.7 7.7 7.7 7.7 7.7 7.7 7.7 7.7
ZPMO 1.4 1.4 1.4 1.4 1.4 1.4 1.4 1.4 1.4 1.4 1.4
* Based on the following evaluation periods :
Period 1 — December 1986 — May 1987
Period 2 — June 1987 — September 1987
Period 3 — October 1987 — January 1988
Period 4 — February 1988 — May 1988
Period 5 — June 1988 — September 1988
Period 6 — October 1988 — January 1989**
Period 7 — February 1989 — May 1989**
Period 8 — June 1989 — September 1989**
Period 9 — October 1989 — January 1990**
Period 10 — February 1990 — May 1990**
Period 11 — June 1990 — September 1990**
** Only if the option to extend the contract for two years is
exercised.
VII—33
-------
OSWER Directive 9242.4—O1A
September 1987
IBIT VII—9(2)
Award Fee Allocation Matrix for TAT Contract
Zone 2
Percent of Available Fee/Category Period*
— December 1986 — May 1987
— June 1987 — September 1987
— October 1987 — January 1988
— February 1988 — May 1988
— June 1988 — September 1988
— October 1988 — January 1989**
— February 1989 — May 1989**
— June 1989 — September 1989**
— October 1989 — January 1990**
— February 1990 — May 1990
— June 1990 — September 1990**
VII —34
Performance
Categories
1
%
2
?
3
4
%
5
%
6
?
7
8
9
%
10
11
RegionVi
23.0
23.0
23.0
23.0
23.0
23.0
23.0
23.0
23.0
23.0
23.0
Region VII
ESD
25.3
25.3
25.3
25.3
25.3
25.3
25.3
25.3
25.3
25.3
25.3
Region VII
WMD
VIII
Ix
x
Region
Region
Region
ZPMO
10.3 10.3 10.3 10.3 10.3 10.3 10.3 10.3 10.3 10.3 10.3
9.3 9.3 9.3 9.3 9.3 9.3 9.3 9.3 9.3 9.3 9.3
19.5 19.5 19.5 19.5 19.5 19.5 19.5 19.5 19.5 19.5 19.5
10.3 10.3 10.3 10.3 10.3 10.3 10.3 10.3 10.3 10.3 10.3
2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3
the following evaluation periods :
* Based on
Period 1
Period 2
Period 3
Period 4
Period 5
Period 6
Period 7
Period 8
Period 9
Period 10
Period 11
** Only if the option
exercised.
to extend the contract for two years is
-------
OSWER Directive 9242.4—O1A September 1987
EXHIBIT VII—iO(i)
TAT Contract Performance Evaluation Criteria
PROJECT PLANNING
• Development of work plans
• Development of project cost estimates and schedules
• Collection and review of existing information
• Elimination of duplicative efforts
• Scheduling and budgeting multiple projects within
cost and priority requirements.
TECHNICAL COMPETENCE AND INNOVATION
• Effectiveness and thoroughness of analyses and
responses to technical direction
Accomplishment of goals and objectives
• Development of alternatives and implementation of
course of action
• Adherence to Agency and other Federal regulations,
procedures, and guidelines (e.g., health and
safety, chain—of—custody/document control, CERCLA
and RCRA regulations, subcontracting, etc.)
Provision of technical support to states and other
Agency or Federal offices
• Creativity and ingenuity in approach (e.g., devel-
opment of cost—effective or technically innovative
control/removal schemes)
SCHEDULE AND COST CONTROL
• Adherence to planned budgets and schedules
Adjustment of schedule and priority requirements
Ability to minimize costs
VII—35
-------
OSWER Directive 9242.4—OlA September 1987
EXHIBIT VII—1O(2)
REPORTING
Timeliness of deliverables (e.g., site operations
plans 1 progress reports, project reports, work plans)
Clarity and thoroughness of project documentation
(e.g., identification of problem and recommended
solution, discussion of alternatives)
RESOURCE UTILIZATION
Suitability of staffing, recruiting and training of
personnel
Supervision and direction of the TAT members by TAT
Leaders
Ability to obtain subcontractors and outside con-
sultants for special projects (e.g, lead time mini-
mization and quality)
Attention to equipment maintenance and accounting,
minimization of travel costs, etc.
EFFORT
Responsiveness
Availability, preparedness and mobilization of
resources for contract overall and specific assign-
ment
Regularity and effectiveness of day—to—day support/
communication with Regional/Headquarters personnel
and other organizations and individuals involved
with the removal program,
Performance in special situations (e.g., adverse/
dangerous conditions or expedited time frames).
VII—36
-------
‘—I
I- I
c J
EXHIBIT Vu-li
RATING GUIDELINES FOR PERFORMANCE EVALUATION CRITERIA
RATiNG
TAT PERFORMANCE EVALUAT)ON CRITERIA
PROJECT PLANNING
TECHNK AL
COMPETENCE
SCHEDULE AND
cosr cot mo
REPORTING
EFFORT
.5
EXCEPTIONAL
Enwie. that cost ne le
mb*nlzed to meet technical
dicection specifications
FaM ti fr g or atromi- ltied
pp o he e nenied ss
innovative technical ,oitjtion
applied
Results ,nayestthilah
atate-of4he-wl approach to
.d&eaa prob tens
Met original eatthlisbed
removal actIon goal. end
objective.
Original schedule met in spite
of major operation
knpedknents
Service, completed ahead of
schedule at a reduced coat to
the Government then
orlgk ,slyeathnated
Reports provide such insight
into key probimna and
potential aokjtlons as to serve
as master plan for merective
action
No re-write of report requked
by EPA personnel
Al of the confractor resource.
we applled to minimise cost,
and lane, while enhencing
overal work quality
Contingency plans always
developed
Response actions taken in
extjeme weather condition.
or high riok wee.
Personal effort well beyond
contract req mont.
I
EXCEEDED
EXPECTATIONS
Provides for al llcent
coatitbne aavfrigs end
contãra adequate
approaches to ad ess
requimrnaivts contained lv
TOO
Quality was thove average of
e ke.oa with almiter ‘ e
ci r.L. over post two
yew.
Original schedule met lv upile
of minor , tkeval
lvipedfrnents
.
Services completed on
schedule .1. reduced cost to
the Government
Al reports we of consistent
high quality, both lv content,
end presentation
No re-write of report requtred
by EPA personnel
One or a few of the contractor
resources we utlilsed
efficlenily, resulting lv coat or
lane savings end providing
apecmed quality of work
Appropriate resource
aitocstlon to counter
operations knpedknent.
Responsive to minor chenge.
lv scope of work and priority
adluatmenta
3
SATISFACTORY
Adequate to meet requle.
merits apeciled in
StaIement s) of Work,
and goal. end Objective, of
the progwn aivdtor
requimmenta
Quality was average of ax-
perimice with aimPor type
contractor. over post two
yaws
Original schedule mat
Cost was ,,eaon le
considering acepe of effort
Afl requbed reports were
delivered on lane end with
contents apeclied
•
Staffing, aobcontractbvg,
equipment, end other
resource. (a.g, travel)
adequately utilized to meat
projed end contract
requkements
Resources mobilized lv
sufficient lane to meet
established budgev schedule
Ftegutar commnnlcatlon end
interaction with Agency
personnel
2
MARGINAL
Work aa4...wd or contract
apedilcations not completely
.d&eaaed
Cost endlor tIne diapro.
portlonate to requked leval of
effort
Quality was below average of
e ,perIence with aknfl type
cor,b. , over post two
yaw.
•
rlginsI schedule slipped
without adequate awning or
iatIlcatlon -
.
Avalable cost savings not
taken advantage of
Reqr*ed reports wers
delivered within 1.5 days alter
due date but without
)jstlilcstlon or weming
Contents of report not as
apecifled
One or slew of contractor
reaources we not used
efficlantly, resulting in cost
ovonvais end lane delays
Effort was below average of
esperlence with ateufler type of
contractor, over the last two
yew. render aknli
c Ic rinst a nces
I
UNSATISFACTORY
kvconed Identification of Ladi of technical corn-
requkernents needed to meet petwvce evident lv any of
TDO SOW major todv*al or maiwge.
merit wea. addiessed
inadequate schedule to
provide quality product or
servke
Actlvitio, completed so
to have resulted in loss of
utifiy or negatively impacted
progen
Requbed reports delivered
more then one wedi late
without adequate justitlcstlon
or waning
Contents of reports
inadequate to permit
interpretation of problem. or
adions
Consistent poor utilization of
resources which hinder. lii,
iniplmnaivtatlon of the
progan
Ad hoc request. and
operational knpedknent.
unadriessed, end adequate
waning or )Jsliflcation was not
provided or was ravsccaptthle
-------
OSWER Directive 9242.4—O1A September 1987
EXHIBIT VII—12
Award Fee Percentages vs. Performance Assessment Definitions
PERFORMANCE SPECTRUM
0 20 40 50 60 80 100
0 — 19 Performance below 20 is indicative of serious
mismanagement, negligence, and/or incom-
petence. Continued performance at this level
may require the Government to consider contract
termination for cause.
20 — 39 Performance between 20 and 39 is substandard,
and requires the contractor to take immediate
corrective action. Areas of adequate or better
performance are offset significantly by poorer
performance in other areas.
40 — 59 Performance between 40 and 59 is satisfactory,
with the 50 point being the expressed level of
satisfactory performance that can be expected
from a good CPAF contractor. Areas requiring
improvement are approximately offset by better
performance in other areas.
60 — 79 Performance between 60 and 79 is superior. The
satisfactory level is exceeded and the monitors
can cite only a few minor areas requiring im-
provement.
80 — ioo Performance of 80 or above is outstanding.
There are no significant areas of poor
performance and there are factors indicating
creativity, ingenuity, initiative, and/or
excellent performance under very adverse
circumstances.
VII—38
-------
OSWER Directive 9242.4—O 1A September 1987
CHAPTER VIII
MI SCELLANEOUS MATERIALS
-------
OSWER Directive 9242.4—O 1A September 1987
CHAPTER VIII
MISCELLANEOUS MATERIALS
This chapter inc.udes copies of Headquarters policies,
correspondence, and other important materials associated
with the TAT contracts They are intended to be used for
reference purposes. Pe:iodically, Headquarters will issue
such materials, and the DPO should insert them in the
chapter.
VIII—l
-------
JSWEF. ii. ect ve 9242.4—O 1A September 1987
APPENDICES
-------
)SWER Directive 9242.4—O 1A September 1987
APPENDIX A
TAT ZONE CONTRACTS
STATEMENTS OF WORK
-------
OSWER Directive 9242.4—O 1A September 1987
APPENDIX A
STATEMENT OF WORK
ZONE 1
The contractor shall provide the personnel, materials,
and facilities (other than that furnished as Government
Furnished Property (GFP)) to establish and manage a zone
organization to augment EPA ’s response, removal, and pre-
vention programs within Zone 1 (EPA Regions I—V, EPA Head-
quarters 1 and the Environmental Response Team (ERT) in
Edison, NJ). Support as required under CERCLA, as amended
by SARA , and Section 311 of the Clean Water Act (CWA) may
also be provided to other EPA and Regional offices upon
request of the designated Project Officer (P0) and Deputy
Project Officer (DPO) for management of the Technical
Assistance Team (TAT). The contractor shall develop an
organization consisting of a:
Zone Program Manager (ZPM) and support management
effort
TAT in each EPA Zone 1 Region (Regions I-V), at
EPA Headquarters and at the ERT location in
Edison, N.J. The TAT 5 will be comprised of a TAT
Leader and a technical staff.
The contractor under this organization shall provide tech-
nical assistance in Zone 1 in the form of engineering,
scientific, technical, and managerial support for EPA’s
emergency response, removal and prevention programs.
The EPA PC will provide overall technical direction
and coordination for the technical contractual efforts.
The EPA P0 and the ZPM will work jointly to provide over-
all coordination of the effort and provide resolution of
any problems that may arise. Within the EPA organization,
the P0 will be represented by a Regional program repre-
sentative, a HQ representative and the ERT Leader who will
be designated as DPO. The contractor’s organization shall
be structured in the same manner through use of the ZPM
and the TAT Leader. In each Region, the ZPM shall work
primarily in a management mode to establish and direct the
TATs. The TAT5 shall be responsible for accomplishing
effort within this Statement of Work (SOW) at the Regional
level. Project execution at the Regional level shall be
coordinated by the DPO 5 and the TAT Leaders. The speci-
fics of these communication channels shall be further
defined by the PC and the ZPM, as required, once the
program becomes operational.
A-l
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OSWER Direct±’ie 9242.4—O1A September 1987
Technical direction shall be in the form of Technical
Direction Documents (TDDs) assigned by the DPO to the TAT
Leader. The defined effort will vary in complexity and
length of time to complete. Effort defined through TDDs
shall cover the scope of activities under emergency re-
sponse and prevention actions. This includes, but is not
limited to, monitoring non—Federal cleanup actions and
providing support, within the scope of work, to Federally
sponsored actions. TDDs may also be issued by the Project
Officer to the ZPM for special ZPM effort within the SOW.
The contractor shall support EPAs capability to ade-
quately respond to environmental emergencies caused by the
discharge or release of oil or hazardous substances to any
media (air, land, surface water, or groundwater) and per-
form spill prevention compliance inspections, process in-
spections, contingency planning, and training. To accoznp-
lish this objective, the contractor shall perform the
following:
GENERAL EFFORT
A MANAGEMENT PORTION -- ESTABLISH AND MANAGE A ZONE
PROGRAM MANAGEMENT OFFICE (ZPMO)
Designate a ZPM and provide support staff, facilities,
materials, and administrative support required to ensure
successful accomplishment of the program objectives de-
scribed in this SOW. The ZPMO shall be located within a
one—hour commute from the Washington, D.C., Standard
Metropolitan Statistical Area. The ZPM shall be the
single point of contact for coordination with the P0 and
be responsible for the planning and execution of all
effort performed under this contract. Specific
responsibilities of the ZPM shall include the following:
1. Manage the TAT Leader at each TAT location, and
assist the TAT Leaders, as required, to staff needed TAT
positions. This must include, at a minimum, on—site
review of each TAT location once each year and the submit-
tal of a report of findings to the EPA P0 within three
weeks of the completIon of each review.
2. Provide 3’Iera supervision and administrative
support to the TAT Leaders. This shall include monitoring
the workload in each Region and making recommendations to
the EPA P0 regarding staff distribution adjustments as
appropriate and providing nterRegional coordination of
personnel resources wnen assistance is needed to mobilize
a major emergency response action.
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OSWEF. Directive 9242.4—CiA September 1987
3. Monitor incurrence of costs and expenditures of
funds throughout the duration of the contract. Report on
costs on a site—specific basis as required elsewhere in
this contract.
4. Develop/modify procedures and forms, as required,
for execution of the uniform program of recordkeeping and
project management documentation among the TATs. Specific
examples include, but are not limited to: “Technical Di-
rection Document” to be used by the DPOs in issuing writ-
ten technical direction, status report forms, daily cost
report forms, and procedures for instituting emergency
response activities in response to technical direction
from a DPO.
5. Implement procedures to ensure that all reports
prepared by the ZPMO and/or by the TATs are of high qual-
ity and meet the content and format requirements of this
contract. Prepare and submit reports as specified in the
contract schedule. Establish procedures for the prepara-
tion and submission of required reports by each TAT Leader.
6. Maintain separate accounting of costs associated
with each TDD.
7. Meet on a monthly basis with the P0 and the Co to
discuss contract status.
8. Accompany the EPA P0 during each EPA Regional
management review of the Regional TATs.
9. Provide a detailed explanation of how indirect
rates are determined for use as documentation in cost re-
covery litigation.
10. Ensure adherence to channels of communication in
accordance with the project organization.
11. Comply with all requirements for control of pro-
perty as illustrated by Part 45 of the Federal Acquisition
Regulations.
B. ESTABLISH, SUPPORT, AND MANAGE TAT OFFICES
1. Establish and maintain a multi—disciplinary TAT
located within a convenient distance from the respective
EPA office and at a location agreeable to the DPO.
Satellite offices shall be established to operate from the
following areas and be headed by Assistant TAT Leaders,
who will be designated after award.
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OSWER DirectIve 242.4—OlA
September 1987
Satellite Office
ZONE 1 EPA Region II— Puerto Rico
EPA Region III- Wheeling, WV
EPA Region IV— Memphis, TN and Louisville, KY
EPA Region V— Cleveland, OH, Detroit, MI
(southern suburbs) and
Cincinnati, OH
Each TAT shall include a TAT Leader and a specified number
of personnel (which includes Assistant TAT Leaders). The
contractor shall provide all facilities, materials, equip-
ment (except that which is furnished as GFP) and support
required for each TAT to include sufficient wor c space for
each TAT member, a reference library, a common conference
room/work area, an equipment maintenance and st .Dr age area,
and a file security area.
2. Each TAT Leader shall be responsible for the
overall management and direct supervision of his TAT of-
fice and satellite offices within his Region. The TAT
Leader shall receive technical direction from the DPO and
is responsible for ensuring the quality and timely comple-
tion of all TDDs issued by the DPO. Each TAT Leader shall
provide timely documentation and reports on each TAT ac-
tivity as specified by the DPO.
C. PROVIDE SUPPORT FOR EMERGENCY RESPONSE OPERATIONS
The contractor shall be responsible for:
1. Receiving and implementing TDD5 issued by the DPO.
2. Maintaining close communication with the DPO and
On—Scene Coordinators (OSCs), and supporting the OSC in
monitoring cleanup operations.
3. Maintaining such records and providing such re-
ports as are required pursuant to reporting and record—
keeping procedures developed for the project.
4. Assuring that the performance of assigned TDDs
adheres to any and all quality assurance, quality control,
and chain—of—custody procedures directed by the DPO and as
required by the contract.
5. Obtaining, as needed, special services that may
include, but are not limited to, consultants, expert wit-
nesses, specialized cleanup equipment, aircraft, vessels,
SCUBA diving capabilities, demolition specialists public
information assistance, and first responder training.
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OSWER Direct:ve 9242.4—O1A September 1987
6. Providing rapid turnaround laboratory or field
analysis or coordinating these activities with EPAs
National Contract Laboratory Program (CLP), assuring that
all laboratory and field analyses adhere to EPAs quality
assurance standards as depicted in “Interim Guidelines and
Specifications for Preparing Quality Assurance Project
Plans (GAMS—005/80 Dec 29 1980)’. Typical rapid
turnaround could vary from twenty—four hours to fourteen
days.
7. Monitoring the incurrence of costs and expendi-
tures throughout the duration of the contract.
8. Developing procedures and forms for reporting,
recordkeeping, and program management. These reports
shall be designed to be consistent with EPA ’s needs for
administration of Superfund. Such procedures and forms
must be approved by the P0. They may be revised during
the life of the contract if approved by the P0.
9. Implementing a comprehensive safety program to
protect contractor personnel in the performance of their
duties. Developing and implementing site safety plans to
protect all personnel on removal sites, and other field
activities as required by the DPO.
10. Completing special reports or studies pertaining
to the contract effort upon direction from the 00, P0, or
the DPO.
11. Implementing any special controls upon direction
from the CO, P0, or the DPO.
12. Maintaining 24—hour, seven—day—a—week response
capabilities to provide EPA with access to technical sup-
port services at all times and to facilitate spill notifi-
cation to EPA. Maintain 24—hour, seven—day—a—week tele-
phone access for emergency response activation.
13. Supporting enforcement activities by collecting,
indexing, and preserving evidence against potentially re-
sponsible parties and maintaining all site documents.
14. Providing, as requested, all technical and cost
documentation suitable for litigation. This includes, but
is not limited to, labor costs, travel costs, special ser-
vices costs, and a certification that the total cost fig-
ure is an accurate accounting of all TAT costs incurred at
the site.
15. Providing ADP capabilities to prepare and track
management reports.
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OSWER Directive 9242.4—O1A September 1987
16. Maintain computer equipment. software, and docu-
mentation provided by EPA. Operate and maintain the Spill
Prevention and Emergency Response Information Management
System (SIMS). Changes to SIMS software can only be made
upon approval of the P0.
17. Providing, as requested. professional consulting
services capable of evaluating complex industrial pro-
cesses, and providing expert testimony.
18. complying with all req-uirements for control of
property as illustrated by Part 45 of the Federal Acquisi-
tion egulations.
19. Providing training regarding the Air Toxics Stra-
tegy. This will include training to assess the potential
risks from both routine and accidental releases of toxic
chemicals.
II SCOPE OF SPECIFIC EFFORT TO BE PERFORMED BY TATS
The contractor, through the use of the TATs, shall
per orm specific effort, within the scope of the following
areas, as specified in written TDDs issued by the EPA DPOs
c the TAT Leaders.
SPECIFIC REQUIREMENTS
A ROUTINE TASKS - PREVENTION PROGRAM
Effort in support of the Prevention Program generally
relates to non—transportation related facilities that pro-
duce, store, process, refine, handle, transfer, distri-
bute, or consume oil or hazardous substances. Initially,
the majority of effort will be directed toward facilities
handling oil, consistent with the EPA Oil Pollution Pre-
vention Regulation (40 CFR Part 112). Following final
promulgation and implementation of the Hazardous Sub-
stances Prevention Regulation, (43 FR 39276), the specific
effort in this area will be oriented increasingly toward
facilities handling the designated hazardous substances.
Each TAT shall perform specific effort within the scope of
any or all of the following areas:
1. Conduct on—site facility surveys and inspections
to ascertain compliance with the EPA Oil Poliution Pre-
vention Regulation (43 FR 39276) and, when promulgated,
the Hazardous Substances Prevention Regulation
(43 FR 39276). Such inspections may be pre—plarined, or
instituted upon discovery of a potential violation. The
inspection shall include a review and evaluation of the
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OSWER Direct:ve 9242.4—O1A September 1987
facility’s Spill Prevention Control and Countermeasures
(SPCC) Plan.
2. Prepare for submission :o the cognizant DPO a
report covering each facility inspection/survey performed,
using the format and documentation procedure prescribed by
the DPO. TATs shall also complete appropriate data forms
to be specified by the cognizant DPO developed for a pro-
posed EPA automated data system (Management Information
Control System).
3. Prepare a Notice of -Violation for violations de-
tected during a facility inspection. The format and con-
tent requirements for each notice shall be specified by
the DPO. Provide testimony regarding inspection- flndings
during SPCC pre—hearing conferences, during SPCC hearings,
and during court actions.
4. Document cases and provide testimony during hear-
ings and court proceedings for both spill prevention and
oil or hazardous substances release violations.
5. Conduct amendment inspections when a facility is
required to submit its SPCC Plan to EPA for review because
of continuing pollution problems (see 40 CFR Part 112 and
43 FR 392768 and.prepare a report which includes recommen-
dat ions for amending the SPCC Plan to prevent further dis-
charges The contractor shall provide for review and ap-
proval of these amendments by a professional engineer.
B. ROUTINE TASKS - RESPONSE PROGRAM
1. CONTINGENCY PLANNING
(a) Provide technical assistance to the OSCs and Re-
gional Response Teams (RRTs) in the review and analysis of
Regional, Federal—local, State and local response contin-
gency plans. Provide technical assistance to RRTs in
revising/updating/rewriting the Regional Contingency Plan
(RCP). Assist OSCs in developing and revising Federal—
local plans. Provide technical assistance to state and
local response personnel in developing or revising state!
local contingency plans. (b) Assist EPA Regional office
preparedness staff in implementing the Chemical Emergency
Preparedness Program (CEPP). This will entail support in
implementing the program guidance and providing technical
assistance to state and local personnel in contingency
planning. (c) Provide technical assistance to RRTs in de-
veloping and implementing their preparedness work programs.
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OSWER Directive 9242.4-O 1A September 1987
2. Training Activities
(a) In coordination with the Hazardous Response Sup-
port Division (HRSD) and ERT , assist in training EPA re-
sponse and contractor personnel . and state and local emer-
gency response personnel in skills and expertise required
for handling multimedia emergencies caused by oil, hazar-
dous substances, and toxic waste. Such training shall
include contractor personnel and State and local emergency
response personnel in skills and expertise required for
handling multimedia emergencies caused by oil, hazardous
substances, and toxic waste. Such training shall include,
but not be limited to: classroom training, exercises,
field training, and response practice drills and simula-
tions. The TAT Leaders shall be responsible for preparing
a periodic training schedule and addressing regularly
scheduled training sessions. Specific goals of the train-
ing program are to train response personnel in the follow-
ing areas:
(a) use of personal safety equipment and
appreciation of the limitations of such
equipment
(b) identification and evaluation of disposal
sites
Cc) implementation of oil and hazardous
substances contingency plans
Cd) development of proficiency in performing the
du— ties of a response team member
Ce) emergency and notification procedures
(f) assessing environmental and health hazards
(g) use of technical assistance data systems
(h) hazardous waste site entry procedures
Ci) proper decontamination procedures
Ci) methods or techniques to track all site
costs of cleanup contractor services on a
daily basis
(b) Assist EPA Regional offices in training state and
local personnel in support of the CEPP.
7
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OSWER Directive 9242 4-O1A September 1987
(c) Provide i echnical assistance to RRTs in
coordinating training in the RRT area and in developing
and implementing a coordinated, interagency training plan
for FY87 and subsequent years.
3. COMMUNITY RELATIONS PLANNING
Develop and implement or assist in the coordination of
community relations plans (CRPs) for removals and remedial
operable units (i.e., discrete part of the entire response
action that decreases a release, threat of release, or
pathway of exposure). CRPs are plans to establish a pro-
gram of public information, media relations and standard
operating procedures to ensure necessary interactions
among EPA, state and local officials. These plans will
consist typically of sections dealing with the background
nd history of community involvement at a particular site,
and specif c plan objectives and techniques to im .lement
:h pan The contractor may be required to arrange news
c...nferences, distribute news releases, provide temporary
ff:ce and conference facilities, or provide necessary
Dtf:ce and communications equipment and do such other
.n tas as may be required to implement the plan.
C EMERGENCY RESPONSE EFFORT - RESPONSE PROGRAM
Provide direction support, as directed by TDD, to the
EPA OSC during both Federal and non—Federal removal ac-
tions. The OSC is the Federal official predesignated by
EPA to coordinate and direct Federal responses. Support
shall be consistent with the National Oil and Hazardous
Substances Pollution Contingency Plan. Effort shall be
conducted to support the following response activities:
1. Response Monitoring
The overall objective of response monitoring shall be
to provide the EPA OSC with sufficient planning, fiscal,
engineering, biological, chemical, and other technical
information to carry out his responsibilities. These
monitoring efforts shall be conducted in accordance with
EPA quality assurance requirements as depicted in “Interim
Guidelines and Specifications for Preparing Quality
Assurance Project Plans (QAMS—005/80 Dec 29 1980)’
The DPO, in conjunction with Project Monitors (OSCs)
shall determine the specific scope of monitoring effort,
which shall include, but not be limited to. the follow-
ing: collecting samples, analyzing samples, providing for
laboratory analysis with EPA’s CLP; providing data to
identify the existence and extent of a release, the source
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OSWER Directive 9242.4—O1A September 1987
and nature of the hazardous substance, and the extent of
danger to the public; performing process inspections;
identifying personal safety requirements; evaluating dis-
posal options; monitoring cleanup personnel; performing
financial monitoring of site cleanup costs; assessing
feasibility and effectiveness of containment, on—site
treatment and removal options; conducting extent of con-
tamination surveys; obtaining special clearances (i.e.,
for overweight vehicles, etc.); procuring applicable
Federal, state or local permits or manifests; and perform-
ing surveillance activities using a variety of vehicles,
communication equipment and audio—visual equipment; per-
forming site assessments (e.g., Underground Storage Tanks
[ UST] — [ UST actions could result in increased removal
activity. RCRA amendments of November 1984 define an
underground tank as a tank that can be as little as ten
percent underground. Leaking tanks, containing nazardous
substances can be associated with the contamination of
surface soil, surface water and groundwater)); and pro-
viding documentation for all of the above.
All monitoring data generated shall be analyzed and
interpreted on an emergency, quick turnaround basis with
recommendations for immediate action presented to the ap-
propriate officials. All monitoring work shall take into
account appropriate Federal, state and local regulations
regarding, in particular, the collection, storage, and
transportation of hazardous substances. As requested,
reports shall be presented to appropriate officials,
either orally or in writing, recommending response op—
tions. The contractor shall provide similar support to an
OSC as needed to oversee removals conducted by responsible
parties.
2. Workplan Development
TAT personnel shall formulate workplan specifications
for all phases of response actions. The workplan specif i—
cations may be used in providing technical assistance and
cleanup support through contractual arrangements between
the government and other contractors outside the scope of
this contract. The DPO shall issue, through TDDs, the
exact scope of workplan specification effort. The effort
shall include, but not be limited to: developing safety
protocol for response workers and the public; contingency
plans; methods of hazard mitigation; containment; counter-
measures; development of on—site treatment systems; re-
moval and disposal options; cost estimates; and personnel
and equipment requirements.
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OSWER Directive 9242.4-O1A September 1987
3. Response Documentation
Prepare “after—action” or pollution reports whenever
the TAT has participated in a response to an emergency
episode. The primary emphasis of such reports shall be to
provide documentation of the response, which would be used
as a basis for subsequent enforcement actions. TAT per-
sonnel shall base their “after—action” or pollution re-
ports upon daily logs or notes taken by TAT personnel or
notes or other documentation compiled by the Federal OSC
or members of the OSCs staff.
The contractor shall also provide under the contract
all necessary services, equipment and materials to supply
full audio—visual and graphics capabilities on a quick
turnaround basis to support EPA in its response documenta-
tion needs. This shall include, but not be limited t ’.
duplicating material, photodocumentation in the form of
16mm movie film, 35mm film and video tape. and producing
charts, graphs and other briefing aids. In addition, the
contractor shall also provide letter reports and backup
documentation for letter reports containing the following
information:
(1) total labor hours and associated costs
(2) total travel and administrative costs
(3) total TAT costs
(4) statement that total cost figure is a true and
accurate accounting of cost incurred at the site
(5) substation of overhead charges
(6) period of work performance
(7) brief summary of work performed
(8) list of TDD numbers and associated hours
(9) copy of TDDs and Acknowledgments of Completion.
(AOC5).
4. Damage Assessment
Conduct assessment surveys for the restoration or re-
placement of damaged natural resources. This activity can
be divided into two distinct time frames: (1) short—term,
which provides immediate input into the emergency response
activities, and (2) long—term which will extensively docu—
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OSWER Directive 9242.4—O1A September 1987
ment the effect of both the environmental release as well
as the response efforts. Activities shall be conducted to
provide information on the extent of contamination, the
degree of cleanliness achieved by the response activi-
ties, the toxicity of the material at various levels in
the polluted media, impact of the release on drinking
water, evaluation of air quality and water quality cri-
teria, recommendations for treatment, removal, disposal,
and restoration of damaged natural resources, the impact
of the pollutant on human health and expected social and
economic impacts of the emergency.
5. Federal Disaster Assistance Related Activities
Conduct Federal disaster assistance surveys of damage
caused by natural disasters such as floods, hurricanes, or
earthquakes. Surveys could include assessment of damages
to public water or sewage treatment facilities or related
environmental problems. This effort requires that the
contractor obtain appropriate Federal Emergency Management
Agency (FEMA) training in damage assessment for at least
three, but no more than half, of the personnel in each TAT
office.
6. Emergency Response Implementation
Perform minor containment effort at the direction of
the DPO, through technical instructions, not to exceed
$1000.00 per TDD. Such effort might include, but not be
limited to: deploying sorbent booms in streams, building
small dams to interrupt flow of contaminants and emergency
pumping.
7. Emergency RCRA/TSCA Inspections
When related to a specific removal action, the con-
tractor may, at the direction of the DPO (through TDDs)
conduct on—site facility surveys and inspections at pro-
posed disposal, treatment or storage facilities. These
inspections will be conducted to ascertain compliance with
regulations promulgated under the Resource Conservation
and Recovery Act (RCRA) and the Toxics Substances Control
Act (TSCA). Such inspections will be performed for facil-
ities that are in apparent compliance with all regulations
except that they have not been inspected within six
months, and they shall be performed in accordance with
RCRA/TSCA regulations and guidance and in accordance with
CERCLA policy for planning and implementing off—site re-
sponse actions. To ensure that RCP.A compliance inspec-
tions are consistent with ongoing or planned RCRA Com-
pliance Monitoring, Enforcement and Hazardous Waste
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OSWER Directive 9242.4—O1A September 1987
Groundwater Task Force activities, and all applicable
compliance inspection protocols, DPOs are required to
obtain the express authorization of appropriate Regional
RCRA enforcement personnel prior to and while undertaking
such compliance inspections. The contractor shall control
RCP.A confidential business information.
8. Mini—Remedial Investigations
Perform mini—remedial investigations (mini—RI) for the
purpose of deleting from or reclassifying on the National
Priorities List (NPL). a site that has been cleaned up as
part of a removal program. A mini—RI is a limited in-
vestigation of the site where response activity is in pro-
gress or has been completed. A mini—RI may include, but
not be limited to: sampling, risk assessment. examination
of the administrative record, and will be subject to re-
view by the local community. The mini—RI may determine
the need for further response action and will evaluate the
consistency of the response action with the National Con-
tingency Plan (NCP) and the NCP requirements for deletion
from or reclassification of sites on the NPL.
D. EPA HQ TAT OFFICE EFFORT
The contractor shall be charged with providing techni-
cal planning and operations support needed to assist the
EPA program office in completing the specific areas in
this SOW. The EPA Headquarters TAT office shall provide
technical, planning, and operations support to assist in
developing and implementing guidance, strategies, brief-
ings, regulations, public inquiry responses, and other
related activities needed. This shall include making
available all necessary services, equipment, and materials
to supply full audio—visual and graphics capabilities
III. SPECIAL PROJECTS
The contractor shall perform special projects in sup-
port of both spill prevention and emergency response ac-
tivities. The objective of special projects shall be to
provide EPA with any specialized equipment, personnel, and
services not routinely available in a specific TAT. This
specialized equipment and personnel shall be used to tech-
nically support the EPA project monitors (i.e., the OSC).
Depending on the particular circumstances of the emer-
gency, special support services may include, but not be
limited to:
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OSWER Directive 9242.4—O1A September 1987
1. Renting of aircraft (fixed or rotary wing)
2. Renting of all—terrain vehicles
3. Drilling of sampling or extraction wells
4. Hiring of SCUBA divers
5. Renting facilities for use as command post(s)
6. Renting communication equipment, including tele-
fax, typewriters, teletypewriters, and radios
7. Temporary secretarial service support for main-
taining logs, typing, and answering telephones
8. Retaining expert consultants or specialists
(e.g., demolition or process chemists)
9. Renting specialized emergency response equipment,
such as incinerators or stream diversion systems
10. Retaining temporary meeting facilities
11. Providing testimony as may be required
12 Renting computers, only with prior approval of P0
and CO
13. Providing temporary housing for evacuees in co-
ordination with FEMA -
14. Retaining expert witnesses as may be required.
IV. SPECIAL PROJECT GUIDELINES
A request for a special project may be issued by the
DPO prior to initiating a special project. The contractor
shall prepare a workplan and cost estimate for completing
the project. The contractor shall be authorized to pro-
ceed according to the following procedures:
1. For special projects estimated to cost under
$10,000, approval authority is granted to the
respective DPO or P0.
2. In instances where multiple special projects are
issued for the same site, the DPOs authority
shall be extended to a ceiling of $15,000 per
site.
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OSWER Directive 9242 4-O1A September 1987
3. For special projects estimated to cost $10,000 or
more, or where the total of all special projects
at a site exceeds $15,000, approval authority
must be obtained from both the Co and the P0.
4. In no event will the contractor proceed with the
effort until a TDD is issued by the DPO.
V. ANALYTICAL SUPPORT EFFORT
The contractor shall provide for rapid turnaround lab-
oratory or field analysis or coordinate these activities
with EPAS CLP for multimedia samples. The contractor
shall furnish all needed personnel, services, materials,
and equipment required to collect, store, transport. an-
alyze and dispose of these samples. The use of hand-held
portable analytical instruments, mobile laboratory. and
fixed laboratory support services may be required. Al].
sample collection and analysis shall adhere to EPA quality
assurance standards as depicted in Interim Guidelines and
Specifications for Preparing Quality Assurance Project
Plans (GAMS—005/80 Dec 29 1980). Typical rapid turn-
around could vary from 24 hours to 14 days.
VI. Guidelines for Analytical Services
- A request for analytical services may be issued by the
DPO who specifies analyses and turnaround times required.
The contractor shall identify a laboratory or laboratories
capable of providing the service and provide a cost esti-
mate. The contractor shall be author.ized to proceed ac-
cording to the following procedures:
1. For analytical services estimated to cost less
than forty—four thousand nine—hundred—ninety—nine
dollars ($44,999), approval authority is granted
to the respective DPO or P0.
2. In instances where multiple analytical services
are required for the same site, the DPOs author-
ity shall be extended to a ceiling of sixty—seven
thousand five—hundred dollars ($67,500) per site.
3. For analytical services estimated to cost forty—
five thousand dollars ($45,000) or more, or for
multiple analytical services in excess of sixty—
seven thousand five—hundred dollars ($67,500) for
the same site, approval authority is granted only
to the P0.
4. In no event will the contractor proceed with the
effort until a TDD is issued by the DPO.
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OSWER Directive 9242.4—O1A September 1987
VII. QIJAL ITY ASSURANCE REQUI REMENTS
The contractor shall institute a quality assurance
program which will ensure that environmental monitoring
data of known quality are provided. The program will be
in compliance with the guidance set forth in the document
entitled ‘Interim Guidelines and Specifications for Pre-
paring Quality Assurance Project Plans (GAMS—005 80
December 29, 1980). The contractor shall use the Sample
Shipment/Tracking Record form for all sample analysis.
All analytical methods used for analysis done by fixed
laboratories must be consistent. EPA, through the CO,
shall determine that methods are consistent in nature and
application with the methodology used in other Superfund
contracts that generate analytical data. The program will
consist of both an auditing and a corrective function.
The auditors will report directly to contractor corporate
management. bypassing the ZPM to minimize any actual or
perceived bias. Corporate management will then be expec-
ted to bring the firms resources to bear on the solution
of any problems uncovered.
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OSWER Directive 9242 4—O1A September 1987
STATEMENT OF WORK
ZONE 2
The contractor shall provide the personnel, materials,
and facilities (other than that furnished as Government
Furnished Property (GFP)) to establish and manage zone
organization to augment EPA’s response, removal, and pre-
vention programs within Zone 2 (EPA Regions VI-X). Sup-
port as required under CERCLA, as amended by SARA, and
Section 311 of the Clean Water Act (CWA) may also be
required to other EPA and Regional offices upon request of
the designated Project Officer (P0) and Deputy Project
Officer (DPO) for manage— ment of the Technical Assistance
Team (TAT). The con— tractor shall develop an
organization consisting of a:
Zone Program Manager (ZPM) and support management
effort.
TAT in each EPA Zone 2 Region (Regions VI-X),
with two TATs in Region VII, are supporting the
ESD and are supporting the WMD. The TATs will be
comprised of a TAT Leader and technical staff.
The contractor under this organization shall provide tech-
nical assistance in Zone 2 in the form of engineering,
scientific, technical, and managerial support for EPA s
emergency response, removal and prevention programs.
The EPA P0 will provide overall technical direction
and coordination for the technical contractual efforts.
The EPA P0 and the ZPM will work jointly to provide over-
all coordination of the effort and provide resolution of
any problems that may arise. Within the EPA organization,
the P0 will be represented by a Regional program repre-
sentative who will be designated as DPO. The contrac-
tor’s organization shall be structured in the same manner
through use of the ZPM and TAT Leader. In each Region,
the ZPM shall work primarily in a management mode, to
establish and direct trie TATs. The TATs will be respon-
sible for accomplishing effort within this Statement of
Work (SOW) at the Regional level. Project execution at
the Regional level shall be coordinated by the DPOS and
the TAT Leaders. The specifics of these communication
channels shall be further defined by the P0 and the ZPM as
required, once the program becomes operational.
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OSWER Directive 9242.4—O1A September 1987
Technical direction shall be in the form of Technical
Direction Documents (TDDs) assigned by the DPO to the TAT
Leader. The defined effort will vary in complexity and
length of time to complete. Effort defined through TDDs
shall cover the scope of activities under emergency
response and prevention actions. This includes, but is
not limited to the monitoring of non—Federal cleanup ac-
tions and providing support, within the scope of work, to
Federally sponsored actions. TDD5 may also be issued by
the P0 to the ZPM for special ZPM effort within the SOW.
The contractor shall support EPAs capability to ade-
quately respond to environmental emergencies caused by the
discharge or release of oil or hazardous substances to any
media (air, land, surface water, or groundwater) and per-
form spill prevention compliance inspections, process
inspections, contingency planning, and training. To ac-
complish this objective, the contractor shall perform the
fol lowing:
GENERAL EFFORT
A. MANAGEMENT PORTION - ESTABLISH AND MANAGE A ZONE PRO-
GRAM MANAGEMENT OFFICE (ZMPO)
Designate a Zone Program Manager (ZPM) and provide
support staff, facilities, materials, and administrative
support required to ensure successful accomplishment of
the program objectives described in this SOW. The ZPMO
shall be located within a one hour commute from the
Washington D.C. Standard Metropolitan Statistical Area.
The ZPM shall be the single point of contact for coordina-
tion with the P0 and be responsive for the planning and
execution of all effort performed under this contract.
Specific responsibilities of the ZPM shall include the
following:
1. Manage the TAT Leader at each TAT location and
assist the TAT Leaders, as required, to staff needed TAT
positions. This must include, at a minimum, on-site re-
view of each TAT location once each year and the submittal
of a report of findings to the EPA P0 within three weeks
of the completion of each review.
2. Provide overall supervision and administrative
support to the TAT Leaders. This shall include monitoring
the workload in each Region and making recommendations to
the EPA P0 regarding staff distribution adjustments as
appropriate and providing interRegional coordination of
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OSWER Directive 9242.4—O1A September 1987
personnel resources when assistance is needed to mobilize
a major emergency response action.
3. Monitor incurrence of costs and expenditures of
funds throughout the duration of the contract. Report on
costs on a site—specific basis as required elsewhere in
this contract.
4. Develop/modify procedures and forms as required
for execution of the uniform program of recordkeeping, and
project management documentation among the TATs. Specific
examples include, but are not limited to: Technical
Direction Document” to be used by the DPOs in issuing
written technical direction, status report forms, daily
cost report forms, and procedures for instituting emer-
gency response activities in response to technical direc-
tion from a DPO. -
5. Implement procedures to ensure that all reports
prepared by the ZPMO and/or by the TATs are of high qua-
lity and meet the content and format requirements of this
contract. Establish procedures for the preparation and
submission of required reports by each TAT Leader.
6. Maintain separate accounting of costs associated
with each TDD.
7. Meet on a monthly basis with the P0 and the Co to
discuss contract status.
8. Accompany the EPA P0 during each EPA Regional
management review of the Regional TATs.
9. Provide a detailed explanation of how indirect
rates are determined for use as documentation in cost
recovery litigation.
10. Ensure adherence to channels of communication in
accordance with the project organization.
11. Complying with all requirements for control of
property as illustrated by Part 45 of the Federal Acquisi-
tion Regulations.
B. ESTABLISH, SUPPORT, AND MANAGE TAT OFFICES
1. Establish and maintain a multi—disciplinary TAT
located within a convenient distance from the respective
EPA office and at a location agreeable to the DPO.
Satellite offices shall be established to operate from the
following areas and be headed by Assistant TAT Leaders who
will be designated after award.
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OSWER Directive 9242.4—O1A September 1987
Satellite Office
ZONE 2: EPA Region VI - Houston, TX and Baton Rouge, LA
EPA Region IX — Los Angeles, CA
Each TAT shall include a TAT Leader and a specified number
of personnel (which includes Assistant TAT Leaders). The
contractor shall provide all facilities, materials, equip-
ment (except that which is furnished as GFP) and support
required for each TAT to include sufficient work space for
each TAT member, reference library, a common conference
room/work area, an equipment maintenance and storage area
and a file security area.
2. Each TAT Leader shal be responsible for the
overall management and direct supervision of his TAT of-
fice and satellite offices within his Region. The TAT
Leader shall receive technical direction from the DPO and
is responsible for ensuring the quality and timely comple-
tion of all TDD5 issued by the DPO. Each TAT Leader shall
provide timely documentation and reports on each TT acti-
vity as specified by the DPO.
C. PROVIDE SUPPORT FOR EMERGENCY RESPONSE OPE A.TIONS
The contractor shall be responsible for:
1. Receiving and implementing TDDs issued by the DPO.
2 Maintaining close commuru.cation with the DPO and
On-Scene Coordinators (OSCs), and supporting the OSC in
monitoring cleanup operations.
3. Maintaining such records and providing such re-
ports as are required pursuant to reporting and record—
keeping procedures developed for the project.
4. Assuring that the performance of assigned TDDs
adheres to any and all ‘ uality assurance, quality control,
and chain—of--custody procedures directed by the DPO and as
required by the contract.
5. Obtaining, as needed, special seriices that may
include, but are not limited to, consultants, expert wit-
nesses, specialized cleanup equipment, aircraft, vessels,
SCUBA diving capabilities, demolition specialists 1 public
information assistance, and first responder training.
6. Providing rapid turnaround laboratory or field
analysis or coordinating these activities with EPA’s
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OSWER Directive 9242.4—O1A September 1987
National Contract Laboratory Program (CLP), assuring that
all laboratory and field analyses adhere to EPA’s Quality
Assurance Standards as depicted in “Interim Guidelines and
specifications for Preparing Quality Assurance Project
Plans (QAMS—005/80 Dec 29 1980).” Typical rapid turn-
around could vary from twenty—four hours to fourteen days.
7. Monitoring the incurrence of costs and expendi-
tures throughout the duration of the contract.
8. Developing procedures and forms for reporting,
recordkeeping, and program management. These reports
shall be designed to be consistent with EPA’S needs for
administration of Superfund Such procedures and forms
must be approved by the P0. They may be revised during
the life of the contract if approved by the P0.
9. Implementing a comprehensive safety program to
protect contractor personnel in the performance of their
duties. Developing and implementing site safety plans to
protect all personnel on removal sites, and other field
activities as required by the DPO.
10 Completing special reports or studies pertaining
to the contract effort upon direction from the Conttacting
Off icér (CO) P0, or the DPO.
11. Implementing any special controls upon direction
from the CO. P0. or the DPO
12. Maintaining twenty-four hour, seven—day—a—week
response capabilities to provide EPA with access to techn-
ical support services at all times and to facilitate spill
notification to EPA. Maintain twenty—four hour, seven day
a week telephone access for emergency response activation.
13. supporting enforcement activities by collecting,
indexing, and preserving evidence against potentially
responsible parties and maintaining all site documents.
14. Providing, as requested, all technical and cost
documentation suitable for litigation. This includes, but
is not limited to, labor costs, travel costs, special
services costs, and a certification that the total cost
figure is an accurate accounting of all TAT costs incurred
at the site.
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OS ER Directive 9242 4—O1A September 1987
15. Providing ADP capabilities to prepare and track
management reports.
16. Maintain computer equipment and documentation
provided by EPA. Operate and maintain the Spill Preven-
tion and Emergency Response Information Management System
(SIMS). Changes to SIMS software can only be made upon
approval of the P0.
17. Providing, as requested, professional consulting
services capable of evaluating complex industrial pro-
cesses, and providing expert testimony.
18. Complying with all requirements for control of
property as illustrated by Part 45 of the Federal Acquisi-
tion Regulations.
19. Providing training regarding the Air Toxics Stra-
tegy. This will include training to assess the potential
risks from both routine and accidental releases of toxic
chemicals.
II. SCOPE OF SPECIFIC EFFORT TO BE PERFORMED BY TAT5
The contractor, through the use of the TATs, shall
perform specific effort, within the scope of.the following
areas, as specified in written TDDs issued by the EPA DPO 5
to the TAT Leaders.
SPECIFIC REQUIREMENTS
A. ROUTINE TASKS - PREVENTION PROGRAM
Ef fort in support of the Prevention Program generally
relates to non—transportation related facilities that
produce, store, process, refine, handle, transfer, distri-
bute, or consume oil or hazardous substances. Initially,
the majority of effort will be directed toward facilities
handling oil, consistent with the EPA Oil Pollution Pre-
vention Regulation (40 CFR Part 112). Following final
promulgation and implementation of the Hazardous Sub-
stances Prevention Regulation, (43 FR 39276), the specific
effort in this area will be oriented increasingly toward
facilities handling the designated hazardous substances.
Each TAT shall perform specific effort within the scope of
any or all of the following areas:
1. Conduct on—site facility surveys and inspections
to ascertain compliance with the EPA Oil Pollution Pre-
vention Regulation (43 FR 39276) and, when promulgated,
the Hazardous Substances Prevention Regulation (43 FR
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OSWER Directive 9242.4—O1A September 1987
39276). Such inspections may be pre—planned; or institu-
ted upon discovery of a potential violation. The inspec-
tion shall include a review and evaluation of the faci-
lity’s Spill Prevention Control and Countermeasures (SPCC)
Plan.
2. Prepare for submission to the cognizant DPO a
report covering each facility inspection/survey performed,
using the format and documentation procedures prescribed
by the DPO. TAT5 shall also complete appropriate data
forms to be specified by the cognizant DPO developed for a
proposed EPA automated data system (Management Information
Control System).
3. Prepare a Notice of Violation for violations
detected during a facility inspection. The format and
content requirements for each notice shall be specified by
the DPO. Provide te timony regarding inspection findings
during SPCC pre—hearing conferences, during SPCC hearings,
and during court actions.
4. Document cases and provide testimony during hear-
ings and court proceedings for both spill prevention and
D ii or hazardous substances release violations.
5 Conduct amendment inspections when a facility is
required to submit its SPCC Plan to EPA for review because
of continuing pollution problems (see 40 CFR Part 112 and
43 FR 39276) and prepare a report which includes recom-
mendations for amending the SPCC Plan to prevent further
discharges. The contractor shall provide for review and
approval of these amendments by a professional engineer.
B. ROUTINE TASKS — RESPONSE PROGRAM
1. CONT INGENCY PLANNING
(a) Provide technical assistance to OSCs and
Regional Response Teams (RRTs) in the review and analysis
of Regional, Federal—local, state and local response con-
tingency plans. Provide technical assistance to RRTs in
revising/updating/rewriting the Regional Contingency Plan
(RCP). Assist OSCs in developing and revising Federal—
local plans. Provide technical assistance to state and
local response personnel in developing or revising state!
local contingency pians.
(b) Assist EPA Regional office preparedness
staff in implementing the Chemical Emergency Preparedness
Program (CEPP). This will entail support in implementing
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OSWER Directive 9242.4—OlA September 1987
the program guidance and providing technical assistance to
state and local personnel in contingency planning.
(c) Provide technical assistance to RRTs in
developing and implementing their preparedness work pro-
gram.
2. TRAINING ACTIVITIES
(a) In coordination with the Hazardous Site
Evaluation Division (HSED) and the Environmental Response
Team (ERT) , assist in training EPA response and contractor
personnel, and state and local emergency response person-
nel in skills and expertise required for handling multi-
media emergencies caused by oil, hazardous substances, and
toxic waste. Such training shall include, but not be
limited to, classroom training, exercises, field training,
and response practice drills and simulations. The TAT
Leaders of the TAT shall be responsible for preparing a
periodic training schedule and addressing regularly
scheduled training sessions. Specific goals of the train-
ing program are to train response personnel in the follow-
ing areas:
(a) use of personal safety equipment and
appfeciation of the limitations of such
equipment
(b) identification and evaluation of dis-
posal sites
(c) implementation of oil and hazardous
substances contingency plans
(d) development of proficiency in perform-
ing the duties of a response team member
(e) emergency and notification procedures
(f) assessing and notification procedures
(g) use of technical assistance data systems
(h) hazardous waste site entry procedures
(i) proper decontamination procedures
(j) methods or techniques to track all site
costs of cleanup contractor services on
a daily basis
(b) Assist EPA Regional offices in training
state and local personnel in support of the CEPP.
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OSWER Directive 9242 4—O1A September 1987
(c) Provide technical assistance to RRT5 in
coordinating training in RRT area and in developing and
implementing a coordinated, interagency training plan for
FY87 and subsequent years.
3. COMMUNITY RELATIONS PLANNING
Develop and implement or assist in the coordination of
community relations plans (CRP5) for removals and remedial
operable units (i.e., discrete part of the entire response
action that decreases a release, threat of release, or
pathway of exposure). CRPs are plans to establish a pro-
gram of public information, media relations and standard
operating procedures to ensure necessary interactions
among EPA, state and local officials. These plans will
consist typically of sections dealing with the background
and history of community involvement at a particular site,
and specific plan objectives and techniques to implement
the plan. The contractor may be required to arrange news
conferences, distribute news releases, provide temporary
office and conference facilities, or provide necessary
office and communications equipment and do such other
things as may be required to implement the plan.
C. EMERGENCY RESPONSE EFFORT - RESPONSE PROGRAM
Provide direct sUpport, as directed by TDD, to the EPA
OSC during both Federal and non—Federal removal actions.
The OSC is the Federal official predesignated by the EPA
to coordinate and direct Federal responses. Support shall
be consistent with the National Oil and Hazardous Sub-
stances Pollution Contingency Plan. Effort shall be con-
ducted to support the following response activities.
1. Response Monitoring
The overall objective of response monitoring shall be
to provide the EPA with sufficient planning, fiscal,
engineering, biological, chemical, and other technical
information to carry out his responsibilities. These
monitoring efforts shall be conducted in accordance with
EPA Quality Assurance Requirements as depicted in “Interim
Guidelines and Specifications for Preparing Quality Assur-
ance Project Plans (QAMS—005/80 Dec 29 1980).”
The DPO, in conjunction with Project Monitors (OSCs)
shall determine the specific scope of monitoring effort,
which shall include, but not be limited to, the follow-
ing: collecting samples, analyzing samples, providing for
laboratory analysis with EPA’s CLP; providing data to
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OSWER Directive 9242.4—O1A September 1987
identify the existence and extent of a release, the source
and nature of the hazardous substance, and the extent of
danger to the public; performing process inspections;
identifying personal safety requirements; evaluating dis-
posal options; monitoring cleanup personnel; performing
financial-monitoring of site cleanup costs; assessing
feasibility and effectiveness of containment, on—site
treatment and removal options; conducting extent of con-
tamination surveys; obtaining special clearances (i.e.,
for overweight vehicles, etc.); procuring applicable Fed-
eral, state or local permits or manifests; and performing
surveillance activities using a variety of vehicles, com-
munication equipment and audio—visual equipment; perform-
ing site assessments (e.g., Underground Storage Tanks
(UST) — [ UST actions could result in increased removal
activity. RCRA amendirients of November 1984 define an
- underground tank as a tank that can be as little as ten
percent underground. Leaking tanks, containing hazardous
substances can be associated with the contamination of
surface soil, surface water and groundwater]); and pro-
viding documentation for all of the above.
All monitoring data generated shall be analyzed and
interpreted on an emergency, quick turnaround basis with
recommendations for immediate action presented to the
appropriate officials. All monitoring work shall take
into account appropri ate Federal, state and localregula—
tions regarding, in particular, the collection, storage,
and transportation of hazardous substances As requested,
reports shall be presented to appropriate officials,
either orally or in writing, recommending response
options. The contractor shall provide support to an OSC
as needed to oversee removals conducted by responsible
parties.
2. Workplan Development
TAT personnel shall formulate workplan specifications
for all phases of response actions. The workplan specif i—
cations may be used in providing technical assistance and
cleanup support through contractual arrangements between
the government and other contractors outside the scope of
this contract. The DPO shall issue, through TDDs, the
exact scope of workplan specification effort. The effort
shall include, but not be limited to: developing safety
protocol for response workers and the public; contingency
plans; methods of hazard mitigation; containments; coun-
termeasures; development of on—site treatment systems;
removal and disposal options; cost estimates; and per—
sonnel and equipment requirements.
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OSWER Directive 9242.4—O1A September 1987
3. Response Documentation
Prepare “after—action” or pollution reports whenever
the TAT has participated in a response to an emergency
episode. The primary emphasis of such reports shall be to
provide documentation of the response, which would be used
as a basis for subsequent enforcement actions. TAT per-
sonnel shall base their ‘after—action” or pollution re-
ports upon daily logs or notes taken by TAT personnel or
notes or other documentation compiled by the Federal OSC
or members of the OSCs staff.
The contractor shall also provide under the contract
all necessary services, equipment and materials to supply
full audio—visual and graphics capabilities on a quick
turnaround basis to support EPA in its response documenta-
tion needs. This shall include, but not be limited to,
duplicating material, photodocurnentation in the form of
16mm movie film, 35mm film and video tape, and producing
charts, graphs and other briefing aids. In addition, the
contractor shall also provide letter reports and backup
documentation for letter reports containing the following
information:
(1) total labor hours and associated costs
(2) total travel and administrative costs
(3) total TAT costs
(4) sta,tement that total cost figure is. a true and accur-
ate accounting of cost incurred at the site
(5) substantiation of overhead charges
(6) period of work performance
(7) brief summary of work performed
(8) list of TDD numbers and as”sociated hours
(9) copy of TDDs and Acknowledgments of Completion (AOCs).
4. Damage Assessment
Conduct assessment surveys for the restoration or
replacement of damaged natural resources. This activity
can be divided into two distinct time frames: (1) short—
term, which provides immediate input into the emergency
response activities, and (2) long—term which will exten-
sively document the effect of both the environmental
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OSWER Directive 9242.4—O1A September 1987
release as well as the response efforts. Activities shall
be conducted to provide information on the extent of con-
tamination, the degree of ucleanlinesshi achieved by the
response activities, the toxicity of the material at var-
ious levels in the polluted media, impact of the release
on drinking water, evaluation of air quality and water
quality criteria, recommendations for treatment, removal,
disposal, and restoration of damaged natural resources,
the impact of the pollutant on human health and expected
social and economic impacts of the emergency.
5. Federal Disaster Assistance Related Activities
Conduct Federal disaster assistance surveys of damage
caused by natural disasters such as floods, hurricanes, or
earthquakes. Surveys could include assessment of damages
to public water or sewage treatment facilities or related
environmental problems. This effort requires that the
contractor obtain appropriate Federal Emergency Management
Agency (FEMA) training in damage assessment for at least
three, but no more than half, of the personnel in each TAT
office.
6. Emergency Response Implementation
Perform minor containment effort at the direction of
the DPO, through technical instructions, not to exceed
$1,000.00 per TDD. Such effort might include but not be
limited to: deploying sorbent booms in streams, building
small dams to interrupt flow of contaminants and emergency
pumping.
7. Emergency RCRA/TSCA Inspections
When related to a specific removal action, the con-
tractor may, at the direction of the DPO (through TDDs)
conduct on—site facility surveys and inspections at pro-
posed disposal, treatment or storage facilities. These
inspections will be conducted to ascertain compliance with
regulations promulgated under the Resource Conservation
and Recovery Act (RCRA) and the Toxic Substances Control
Act (TSCA). Such inspections will be performed for faci-
lities which are in apparent compliance with all regula-
tions except that they have not been inspected within six
months, and they shall be performed in accordance with
RCRA/TSCA regulations and guidance and in accordance with
CERCLA policy for planning and implementing off—site
response actions. To ensure that RCRA compliance inspec-
tions are consistent with ongoing or planned RCRA Compli-
ance Monitoring, Enforcement and Hazardous Waste Ground-
water Task Force activities, and all applicable com-
pliance inspection protocols 1 DPOs are required to obtain
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OSWER Directive 9242.4—O1A September 1987
the express authorization of appropriate Regional RCRA
enforcement personnel prior to and while undertaking such
compliance inspections. The contractor shall control RCRA
confidential business information.
8. Mini—Remedial Investigations
Perform mini—remedial investigations (mini—RI) for the
purpose of deleting from or reclassifying on the National
Priorities List (NPL), a site that has been cleaned up as
part of a removal program. A mini—RI is a limited inves-
tigation of the site where response activity is in pro-
gress or has been completed. A mini—RI may include, but
not be limited to: sampling, risk assessment, examination
of the administrative record, and will be subject to re-
view by the local community. The mini—RI may determine
the need for further response action and will evaluate the
consistency of the response action with the National Con-
tingency Plan (NCP) and the NCP requirements for deletion
from or reclassification of sites on the NPL.
III. SPECIAL PROJECTS
The contractor shall perform special projects in sup-
port of both spill prevention and emergency response acti-
vities. The objective of special projects shall be to
provide EPA with any specialized equipment, personnel, and
services not routinely available in a specific TAT This
specialized equipment and personnel shall be used to tech-
nically support the EPA project monitors (i.e., OSCs).
Depending on the particular circumstances of the emer-
gency, special support services may include, but not be
limited to:
1. Renting of aircraft (fixed or rotary wing)
2. Renting of all—terrain vehicles
3. Drilling of sampling or extraction wells
4. Hiring of SCUBA divers
5. Renting facilities for use as command post(s)
6. Renting communication equipment, including tele-
fax, typewriters, teletypewriters, and radios
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OSWER Directive 9242.4—O1A September 1987
7. Temporary secretarial service support for main-
taining logs, typing, and answering telephones
8. Retaining expert consultants or specialists
(e.g., demolition or process chemists)
9. Renting specialized emergency response equipment,
such as incinerators or stream diversion systems
10. Retaining temporary meeting facilities
11. Providing testimony as may be required
12. Renting computers, only with prior approval of P0
and Co
13. Providing temporary housing for evacuees in coor-
dination with FEMA
14. Retaining expert witnesses as may be required.
IV. SPECIAL PROJECT GUIDELINES
A request for a special project may be issued by the.
DPO prior to initiating a special project. The contractor
shall prepare a workplan and cost estimate for completing
the project. The contractor shall be authorized to pro-
ceed according to the following procedures:
1. For special projects estimated to cost under
$10,000, approval authority is granted to the
respective DPO or P0.
2. In instances where multiple special projects are
issued for the same site, the DPO’s authority
shall be extended to a ceiling of $15,000 per
site.
3. For special projects estimated to cost $10,000 or
more, or where the total of all special projects
at a site exceeds $15,000, approval authority
must be obtained from both the CO and the P0.
4. In no event will the contractor proceed with the
effort until a TDD is issued by the DPO.
V. ANALYTICAL SUPPORT EFFORT
The contractor shall provide for rapid turnaround
laboratory or field analysis or coordinate these activi-
ties with EPA’S CLP for multimedia samples. The con-
tractor shall furnish all needed personnel, services,
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OSWER Directive 9242.4—O1A September 1987
materials, and equipment required to collect, store,
transport, analyze, and dispose of these samples. The use
of hand—held services may be required. All sample collec-
tion and analysis shall adhere to EPA quality assurance
standards as depicted in “Interim Guidelines And Speci-
fications for Preparing Quality Assurance Project Plans
(QAMS—005/80) Dec 29 1980.’ Typical rapid turnaround
could vary from twenty—four hours to fourteen days.
VI. GUIDELINES FOR ANALYTICAL SERVICES
A request for analytical services may be issued by
the DPO who specifies analyses and turnaround times
required. The contractor shall identify a laboratory or
laboratories capable of providing the service and provide
a cost estimate. The contractor shall be authorized to
proceed according to the following procedures
1. For analytical services estimated to cost less
than forty—four thousand, nine—hundred-ninety—
nine dollars ($44,999), approval authority is
granted to the respective DPO or P0.
2 In instances where multiple analytical services
are required for the same site, the DPO ’s author-
ity shall be extended to a ceiling of sixty seven
thousand five—hundred dollars ($67,500) dollars
per site.
3. For analytical serviQes estimated to cost forty—
five thousand dollars ($45,000) or more, or for
multiple analytical services in excess of sixty—
seven thousand five—hundred dollars ($67,500) for
the same site, approval authority is granted only
to the P0.
4. In no event will the contractor proceed w].th the
effort until a TDD is issued by the DPO.
VII. QUALITY ASSURANCE REQUIREMENTS
The contractor shall institute a quality assurance
program which will ensure that environmental monitoring
data of known quality is provided. The program will be in
compliance with the guidance set forth in the document
entitled “Interim Guidelines and Specifications for Pre-
paring Quality Assurance Project Plans (QAMS—005—80)
December 29, 1980.” The contractor shall use the Sample
Shipment/Tracking Record Form for all sample analysis.
All analytical methods used for analysis done by fixed
laboratories must be consistent. EPA, through the CO,
shall determine that methods are consistent in nature and
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OSWER Directive 9242.4—O1A September 1987
application with the methodology used in other Superfund
contracts that generate analytical data. The program will
consist of both an auditing and a corrective function.
The auditors will report directly to contractor corporate
management, bypassing the ZPM to minimize any actual or
perceived bias. Corporate management will then be expec-
ted to bring the firms resources to bear on the solution
of any problems uncovered.
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OSWER Jirective 9242.4—O 1A September 1987
APPENDIX B
MINIMUN EQUIPMENT NEEDS
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OSWER Directive 9242.4—O1A September 1987
APPENDIX B
MINIMUM EQUIPMENT NEEDS
The following schedules identify the minimum equipment
needs required to implement the contract. After award, the
contractor will be responsible for identifying what is
available as Government Furnished Equipment (GFE) and what has
to be acquired under the contract to satisfy these minimum
needs.
Schedule A — Work Station
1. Double pedestal desk 1 ea.
2. Swivel chair w/arrns 1 ea.
3. Bookcase, 3 shelf 1 ea.
4. 4—drawer file cabinet w/lock 1 ea.
5. Side chair w/o arms 1 ea.
Requirement: 1 per TAT Member
Schedule B — Work Station for secretary/word processor
1. Single pedestal desk
2 Side “L”
3. Swivel chair w/o arms
Requirement: 1 per secretary/word processor
Schedule C — Word Processing, Xerox, and Associated
Equipment
1. Word processor and E—Mail
capabilities compatible with
EPAs Regional systems w/printer
and Tel Modem 10 ea.
2. Xerox model or equivalent
type reproduction equipment
with sorting, reduction, and
enlargement capabilities 10 ea.
Schedule D — Personal Protective Equipment
1. Hard hat 1 ea.
2. Safety glasses 1 ea.
3. Coveralls, cotton, pr. 2 ea.
4. Coveralls, nomex, pr. 1 ea.
5. Neoprene rubber boots, 18”
w/steel toes 1 ea.
6. Artic overshoes, pr. 1 ea.
B—i
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OSWER Directive 9242.4—O1A
September 1987
7.
8.
9.
10.
11.
12.
13.
14.
Requirement:
1 per TAT member
1 ea.
1 ea.
1 ea.
1 ea.
1 ea.
1 ea.
1 ea.
1 ea.
Schedule E - Response Vehicle Equipment
1. Binoculars, Zoom 7—15 x 35
2. Camera, Polaroid SX—70A,
I Model 2 or equiv.
3. Camera, 35mm
4. 100’ steel surveying tape
5. Range finder
6. First Aid Kit, zee #155 or equiv.
7. Portable wash unit, Econ 10 Gal.
8. Rope, 16 lob, 300 , polypropyl
9. Rechargeable lantern
10. Rubber apron w/sleeves
11 Minor Automotive repair tool kit
12 Combustible gasioxygen meter
Consisting of:
Trail Antacid
EEZ Lozenges
Pain Aid
Aspirin (5 gr.)
Ammonia Inhalents
Cotton Swabs
Ice Pack
Eye Skin Neutralizer
Gauze Bandage (2” x 5 yds.)
Torniquet
Ice Pack (Large)
Salt tablets
Snake Bite Kit
Cold Tabs
Scissors
Eye Drops
Flashlight, explosive proof
Two piece rain suit
Leather work boots w/steel toe
Down filled jacket
Insulated boots, pr.
Insulated coverall, pr.
Respirators
SCBA
1 ea.
1 ea.
1 ea.
2 ea
1 ea.
1 ea.
1 ea.
1 ea.
1 ea.
1 ea.
1 ea.
1 ea.
1 per TAT office
Requirement: 1 per vehicle per Region
Schedule F — Reference Library
To consist of the following:
1. NIOSH and OSHA safety guidance
2. Phone books as applicable
3. Camera, 35mm
4. Road map atlases
5. Conference area
6. Other items as specified by the DPO
Schedule G — Medical First Aid Kit
B—2
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OSWER Directive 9242.4—O1A
September 1987
(Medium)
Requirement:
1 ea. for every two TAT members
Schedule H - Equipment Maintenance and Storage Area
1. Secure Area
2. Wet Sink
3. Repair Bench
4. Adequate lighting and ventilation
Requirement:
1 per TAT Office
Schedule I - ADP Equipment
EPA may require purchase of eleven portable computers and
seven office computers with IBM compatibility for Zone 1
under this contract to complement existing systems. If the
contractor is so authorized, the equipment will be
considered contractor acquired property under the
Government Property’ clause.
The contractor is not authorized to acquire and/or fabricate
any equipment (including that listed above) for use in the
performance of this contract without prior approval of the
Contracting Officer.
Burn Septic Spray
Spray on Bandage
Antiseptic Spray
Blood dotter
Adhesive Tape
Cohesive Tape
Tel Fa Sterile Pads
Band Aids
Finger Tip Bandages
Knuckle Bandages
Elastic Strip Bandage
Carlisle Compress Dressing
Triangle Bandage
Gauze (3” x 2”)
Gauze (2’ x 2”)
Gauze Bandage (1 x 6 yds.)
Blanket
Butterfly Closure (Large)
Curad Bandage (2 1/4 x 3 1/2)
Clean Wipe Alcohol Swabs
Tweezers
Antiseptic Swabs
First Aid Guide
Butterfly Closure
Finger Splint
Forceps (Dumont 5”)
Chigger/Tick Remover
Vasol me
Gelusil Tablets
Ex-Lax
Poison Ivy Treatment
Insect Repellent
Sting Relief
Splints
B—3
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OSWER Directive 9242.4—O 1A September 1987
APPENDIX C
TAT CONTRACT TECHNICAL
DIRECTION DOCUMENT:
TYPE OF ACTIVITY
-------
OSWER Directive 9242.4—O1A September 1987
APPENDIX C
TAT CONTRACT, TECHNICAL DIRECTION DOCUMENT:
TYPE OF ACTIVITY
The following definitions are general in nature and
response activities should not be limited to those listed as
specific examples.
I. CWA 311(k).
SPCC . The TAT shall provide technical assistance to the OSC in
the review and evaluation of a facilitys Spill Prevention
Control and Countermeasures Plan (SPCC). Technical assistance
may include: an on-site facility inspection/survey to
ascertain compliance with EPA Oil Pollution Prevention
Regulations (43 CFR Part 112); preparation of a report covering
each facility inspection survey performed; review of SPCC
plans; preparation of a Notice of Violation for violations
detected; documenting cases and preparing testimony during
hearings and court proceedings; and/or conducting amendment
inspections when a facility has continuing pollution problems.
On—Scene Monitoring . The TAT shall assist the OSC, or the OSC
may dispatch the TAT to monitor a responsible party oil spill
response. The DPO, in conjunction with the OSC, shall
determine the scope of the monitoring effort.
Spill Clean-up Funded . The TAT shall assist the OSC, or the
OSC may dispatch the TAT to monitor a CWA 311(k) funded oil
spill response. The DPO, in conjunction with the OSC, shall
determine the scope of the monitoring effort.
II. CERCLA
Site Assessment . The NCP requires a preliminary assessment of
a release or threat of a release from a hazardous waste
management facility before initiating a CERCLA—financed
response. . site assessment also includes the investigation of
actual releases or Ep..ils of hazardous materials at sites other
than a waste managemen facility (e.g., a train derailment,
roadside spill, cr. re.ease resulting from fire). The purpose
of the assessment :s :0 provide an initial indication of the
need for a Federal response. The assessment may include but is
not limited to: eva.uat in of the magnitude of the hazard;
indication of the source and nature of the release;
determination of the existence of a non—Federal party (or
parties) that is ready, willing and able to undertake a proper
response; and the evaluation of factors necessary to determine
whether a removal is necessary.
C—i
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OSWER Directive 9242.4—O1A September 1987
Specifically, a site assessment may include: review of
site management practices (collecting samples, analyzing
samples, providing for laboratory analysis with EPAs National
Contract Laboratory program; providing data to identify the
existence and extent of a release, the source and nature of the
hazardous substance, and the extent of danger to the public;
performing process inspections; identifying personal safety
requirements; conducting extent of contamination surveys; and
conducting engineering evaluations and cost analyses),
information from generators photographs, analysis of
historical photographs, literature searches, and personal
interviews conducted as appropriate.
In addition, a perimeter (off—site) inspecti n may be
necessary to determine the potential for a reiease. Finally,
if more information is needed, a site visit. may te performed,
if conditions are such that it may be performed safely.
Removal Funded . The overall objective of TAT removal support
is to provide the OSCs with sufficient technhca (planning,
fiscal, engineering, biological, chemical) information to carry
out a response action financed by CERCLA cr SARA funds.
The DPO, in conjunction with the OSCs, shall determine the
specific scope of a monitoring effort, which shall include, but
not be limited to the following: performing financial
monitoring of site cleanup costs; assessing feasibility and
effectiveness of containment, on—site treatment and other
removal actions; obtaining special clearances; procuring
applicable Federal, state or local permits or manifests; and
performing surveillance activities using a variety of vehicles,
communication equipment and audio—visual equipment.
Removal PRP . If a responsible party fails to act in response
to an OSCs oral notice, an Administrative Order may be issued
under CERCLA, Section 106, that requires the responsible party
to undertake response activities. If the recipient of an
Administrative Order agrees to undertake the response measures
contained in the order, then such an agreement may be in the
form of an Order on Consent. The OSC may utilize the TAT to
monitor a responsible party cleanup as presented in the
Administrative Order or Order on Consent.
On—Site Monitoring . On—site monitoring occurs where the state
or local authorities, or other private parties have responded
to a hazardous materials site or a spill (CERCLA funds are not
invoked) and the OSC directs the TAT to provide on—site
oversight or technical assistance to ensure that adequate
cleanup takes place.
C—2
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OSWER recti i 242 4-O1A September 1987
III. Other Activities
Special Projects . The TAT shall provide special projects to
technically support the OSCs in emergency response activities.
The objective of special projects shall be to provide OSCs with
any specialized equipment, personnel, and/or services not
routinely available in a specific TAT.
Special projects may include, but are not limited to:
renting of aircraft; renting of all terrain vehicles; drilling
of sampling or extraction wells; hiring SCUBA divers; renting
command post facilities; renting communication equipment
(telefax, typewriters, teietypewriters, and radios); temporary
secretarial services for maintaining logs, typing, and
answering telephones; hiring expert consultants or specialists
(e.g., process chemists); hiring temporary meeting facilities;
providing temporary housing for evacuees in coordination with
FEMA; and retaining expert witnesses.
Analytical Project . The TAT Shdll provide the OSC with
technical assistance for the rapid turnaround of laboratory or
field analysis, or coordinate these activities with EPA
laboratories or EPAs Contract Laboratory program, for
multimedia samples. The use of hand—held, portable analytical
instruments, mobile laboratory, and fixed laboratory support
services may be required. Typical rapid turnaround could vary
from 24 hour to 14 days.
Title III . SARA, Section 303, provides for the establishment
of local emergency planning committees which are responsible
fcir the development of an emergency response pan within two
years after the date of enactment. The OSC may task the TAT to
assist in the review and comment upon an emergency response
plan or other issues related to the preparation.
implementation. or exercise of such a plan upon the request of
a local emergency response committee.
UST . SARA, Section 205, provides for EPA to issue orders to
the owner or operator of an underground storage tank to
undertake corrective action with respect to any release of
petroleum when t is determined that such corrective action
will be done properly and promptly. If a responsible party,
state or local government cannot be found, or are unable to
undertake an UST corrective action, then EPA may undertake such
an action if it meets major public health emergency criteria.
The OSC may utilize the TAT to provide monitoring of
responsible party response actions, assist in exposure
assessments, assist with relocations, provide alternative water
supplies, and monitoring of appropriate actions to stabilize
the health emergency.
C-3
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OSWER Directive 9242.4—O1A September 1987
FEMA . Under the direction of the DPO, the TAT shall provide
technical assistance to the designated Agency Coordinator in
conducting surveys of damage caused by natural disasters such
as floods, hurricanes, or earthquakes, in accordance with
Federal Emergency Management Agency (FEMA) guidelines. Surveys
could include assessment of damage to public utility to related
environmental problems.
Quality Assurance . The TAT provides technical assistance to
the OSC by conducting a quality assurance program to ensure
that environmental monitoring data are of known quality
according to guidelines set forth in the document entitled
“Interim Guidelines and Specifications for Preparing Quality
Assurance Project Plans (QAMS—005—80) ,” dated December 29,
1980. The TAT shall alsu provide additional quality assurance
by reviewing and commenting on other reports as designated by
the DPO (e.g., peer review).
Training . The TAT shall provide technical assistance to the
OSC by developing and implementing a training program for
skills required for responding to emergencies resulting from
the release or potential release of oil or hazardous
substances. The program should address the training needs of
roth EPA and TAT personnel. It may also differentiate between
training conducted by the TAT and training conducted by other
sources. The TAT may also provide training to state or local
agencies (excluding Title III activities), or to other groups.
as requested by the DPO. Both health and safety and technical
safety skills should be addressed in this program.
Program Management Reports . The TAT shall provide technical
support to the OSC by developing program management informatior
reports. These reports shall be in addition to, or supplement.
normal management reports generated under the contract.
C—4
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OSWER Directive 9242.4—O 1A Setpember 1987
APPENDIX D
EXAMPLE FORMS FOR TAT CONTRACT MANAGEMENT:
TDDs and AOC/PORS
-------
OSWER Directive 9242.4—O1A Setpember 1987
APPENDIX D
The purpose of this appendix is to provide an example
TDD and AOC/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 TATs performance. These examples illustrate the
level of detail expected in completing the paperwork
associated with tasks performed under the TAT contract.
D— 1
-------
September 1 87
O uitrubutuon
Sheet 1 White OPO Copy
Sheet 2 Blue TAIL Copy
Sheet 3 Green ZPM Copy
Sheet 4 Can.ry P0 Copy
Sheet S Punk CO Copy
Sheet 6 Goldenrod OPO Oroinal itJn ,,aned by TATL1
OSWER Directive 9242.4-O1A
14. Con Center:
TAT ZONE II CONTRACT
2.No.:
10
CONTRACT NO. 68-01.7368
TECHNICAL DIRECTION DOCUMENT (TDD)
ECOLOGY AND ENVIRONMENT. INC.
T 10—8704—12
Account No.:
Amendment
3A. Priority
4A. Estimate of
5A. EPA Site Name:
7. Completion Date:
H h Total Hours:
256 N/A 6—15—87
Medium Total Costs
13,500 5B. SSID No.: SC. City/County/State: 8. Reference Info:
N/A Somewhere, WA DYes EJAttached
38. Key EPA Contact: 4B. Overtime Approved: J No 0 Pick-up
6. Source of Funds: 0 Other
Name: S. Jones 1CERCLA 8A.Subtask Code:
Yes E:JNo fl3t l
Phone: 555—4321 DUST 10
9. Type of Activity:
CWA-311 CERCLA AS SPECIFIED ABOVE
SPCC Site Assessment Special Project Quality Assurance
On-Scene Monitoring Removal Funded Analytical Project Training
Spill Clean-up Funded Removal PRP (AO/CO) TITLE Ill Program Management
On-Site Monitoring — UST Technical Assistance
U FEMA Information Management
10. General Task Description: Emergency Response — Route 79, Somewhere. WA..
Respond to toluene spill.
11. Desired Report
Formal Report
Letter Report
Formal Briefing
Other (Specify)
pecific Elements:
1. Contact WA State Response Team at (206) 555—1234 regarding
13. Interim Deadlines:
4/15/87
reported toluene spill. Route 79. Somewhere, WA.
2. Respond to spill in coordination with WA team
4/15/87
3. Conduct air monitoring for off—site impact
4/15/87
4. Advise DPO of initial response conditions
4/15/87
5. Preliminarily assess needs for additional investigations
(e.g., GW) and cleanup
4/16/87
6. Draft response report to EPA
6/15/87
14. Authorizing DPO:
15. Date:
DPO’s Signature
4/15/87
(Signature)
eceived by: Accepted E Accepted with Exceptions (Attached) Rejected
17. Date:
TATL’s Signature
4/16/87
(TATL Signature)
D-2
T007037
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OSWER Directive 9242.4-O1A
September 1987
COSTCENTER ACKNOWLEDGEMENT OF COMPLETION
10 PERFORMANCE OBSERVATION REPORT: PART I
CONTRACT NO,:
68-O1•7368
CONTRACTOR:
Ecology and Environment, Inc.
TOO NO -
T1O—8704—12
ACCOUNT NO.
REPORTING ELEMENT: DATE(S) OF REPORTED OBSERVATION APPROX. p OF HOURS
Region X TAT 4—15—87 to 6—15—87 z)6
PERFORMANCE EVALUATION CATEGORY:
Technical Support (Region X)
DESCRIPTION OF CONTRACTOR OBSERVATION BY: TAT performed an Extent of Contamination Study (EOCS) and
assisted the OSC during cleanup following a spill of 3500 gal. of toluene on Rt. 79 near
Somewhere, WA. TAT rapidly provided experienced personnel without negatively impacting othe
ongoing TDD assignments. These personnel quickly prepared a comprehensive QA/Sampling Plan
& HASP to support the ongoing field investigation and cleanup. TAT used an OVA to screen
core sections in the field; this expedited cleanup activities while minimizing lab costs and
the impacts of conventional lab turnaround times on the need for data to direct contractors
on site. These efforts resulted in an estimated savings of $3,500 for contractor standby
costs and $1,500 for conventional lab costs.
RATING: 5. 4, 3. 2. 1 SIGNATURE OF CONTRACTOR: DATE:
4 . TATL’s Signature 6—22—87
DESCRIPTION OF EPAOBSERVATION BY: DPO’s Name and Title
TAT provided thorough and clear reports to the stantially assisting him in mitigatin
this potentially significant spill of toluene to the ground water. TAT completed this TDD
with 15% less TAT LOE hrs. than originally approved.
COMMENTS: DPO agrees with the performance observation as described above.
provide this assistance to EPA because of the experience of its resources.
scheduling system allowed it to provide these resources without negatively
TDD assignments. The TAT’s performance was above average.
RATING: 5, 4, 3.2.1 SIGNA-TURE OF EPA: . DATE:
4 . . DPO’s Signature 8/25/87
SIGNATURE OF REGIONAL POR COORDINATOR: . DATE: -
Coordinator’s Signature 9/28/87
HO COORDiNATOR ’S EVALUATION BY.
NAMEITITLE
(To be completed by HQ Coordinator, upon request from Region X POR Coordinator).
RATING. 5, 4. 3. 2. 1 SIGNATURE OF Ha: DATE:
Coordinator’s Signature 10/6/87
DPO ACTION: ACCEPTED ACCEPTED WITH EXCEPTIONS REJECTED
COSTTO DATE: $11,400 DATE: 6/15/87 ACTUAL TOTAL HOURS:
TOTALCOSTTOCLOSURE: S13 ,200 216
I CERTIFY THAT THE ATTACHED MATERIALS MEET AND COMPLY WITH ALL
REQUIREMENTS OF THE SUBJECT TOD.
TATL’s Signature TATL’s Signature
TATL SIGNATURE (INTERIM) TATL SIGNATURE FINAL)
DATE:
6/22/87
INTERIM
8/15/87
FINAL
I ACKNOWLEDGE THAT I HAVE BEEN PROVIDED WITH THE MATERIALS AND
SERVICES SPECIFIED IN THE SUBJECT TOO WITHIN ITS ORIGINAL OR
REVISED TIME FRAMES.
.
DPO’s Signature DPO’s Signature
DPO SIGNATURE (INTERIM) DPO SIGNATURE (FINAL)
DATE:
.
INTERIM
8/19/87
TAT was able to
TAT’s manpower
impacting other
Distribution:
Sh..t 1
Sheet 2
Sh..t 3
Sh.et 4
Sheet 5
Wh its
White
Blue
Gr. en
Canary
• HOS Coordinator
• DPO Copy
TATL Copy
• ZPM Copy
•POCopv
D- 3
T 0064037
-------
OSWER Directive 924.4-O1A
September 1907
TAT CPAF CONTRACT PERFORMANCE OBSERVATION REPORT (POR)
PART II. EVALUATION CRITERIA RATING WORKSHEET
CONTRACT NO.: I CONTRACTOR: J TOO NO.:
68-O1•736.. I I
Ecology and Environment, Inc. 10—8704—12
REPORTING ELEMENT: I DATE(S) OF REPORTED OBSERVATION I APPROX. NO. OF IIOURS
Region X TAT J 4—15—87 to 6—15—87 256
PERFORMANCE EVALUATION CATEGORY:
Technical Support (Region X)
CONTRACTOR REPRESENTATIVE
EPA PERFORMANCE MONITOR
Region X TATL’s Name
Region X DPO’s Name
PERFORMANCE CRITERIA
RATING
SUPPORTING COMMENTS
PROJECT PLANNING
Org.nizin (E.G., Work Plan
D.v.IopmuntOataRvi )
X Sch.duling
— Budgiting
X
3
2
1
TAT developed sampling/QA and HASP to con—
duct an Extent of Contamination Study (EOCS)
following initial Emergency Response.
Comprehensive plans were rapidly prepared
to support ongoing field investigation and
cleanup, minimizing contractor stand—by
costs.
TECHNICALCOMPETENCE& INNOVATION
Eftsctiv.n ofAnaIyees
— M .stPIanGoaIs
X
TAT’s use of field analytical screening
techniques (e.g., OVA monitoring of core
sections) expedited clean—up activities
— Adh stoR.gs.&Procedur.s
Approach Crsativity/Ing.nuity
.
2
while minimizing laboratory costs and
impacts of conventional turnaround times to
provide data needed for directon of -
.
1
contractors.
SCHEOULE&COSTCONTROL
X
TAT’s use of its own experienced personnel
— 8ud et(Hours&Cost)Maintenanc.
— Priority/Sch.dule Adjusim its
Co Minimiiation
3
2
to perform EOCS and assist in contractor
monitoring resulted in an estimated $3,500
.
savings in stand—by costs. TAT was able to
complete TDD activities with 15% less hours
i
(TAT LOE) than originally approved.
BEPORTING
Tin ’,eIine of Deliverables
Clarity
Thoroughneu
4
X
2
1
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 cleanup.
RESOURCE UTILIZATION
X Staffing
— Sub ntracting .
— EquipmentTrav.IEtc.
S
X
3
2
TAT was rapidly able to provide experienced
personnel for this high—priority assignment
without negatively impacting other ongoing
TDD assignments.
1
EFFORT
Risponsivnes
X MobiIizat n
X Day.to.d.y
— Sp e eialShuatson(E.G..Ady.r,sI
5
X
3
TAT’s responsiveness during the planning,
mobilization, and implementation of this
TDD substantially assisted the OSC in
.
mitigating a potentially significant spill
Dang.rous Conditions)
2
of toluene.
1
Distribution.
Sh.et 1 White HQS Coerainato,
Sheet 2 Blue DPO Copy
Sheet 3 Green TATL Copy
Sheet 4
Sheet 5
Sheet 6
Canary ZPM Copy
Pink P0 Copy
Geld.nrod - CO Copy
T005037
D- 4
-------
OSWER Directive 9242.4—UIA september i ai
APPENDIX E
DPO CHECKLIST FOR
REVIEWING TAT CONTRACTOR’S OFFICE
-------
OSWER Directive 9242.4—O1A September 1987
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 contractors 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
contractors 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) TDD 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.
E— 1
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OSWER Directive 9242.4—O1A September 1987
DPO CHECKLIST FOR
REVIEWING TAT CONTRACTOR S OFFICE
REVISED DRAFT
August 1, 1987
Emergency Response Division
Office of Emergency & Remedial Response
U.S. Environmental Protection Agency
Washington, D.C.
E—2
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OSWER Directive 9242.4—O1A September 1987
DPO
CHECKLIST
FOR
REVIEWING
TAT
CONTRACTO
RS
OFFICE YE
S NO
N/A
WORK ORDER PREPARATION AND PROCESSING
1. Are copies of all TDD5 and AOCs
available in the files?
2. Are the TDD and AOC/POR files well
organized (e.g., serially by TDD)?
3. Is there a TDD assignment log?
4. Is the assignrttent log:
a) Complete?
b) Up—to—date?
5. Do log books seem:
a) Properly organized?
b) Clear?
E—3
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OSWER Directive 9242.4—O1A September 1987
)PO
CHECKLIST
FOR
REVIEWING
AT
CONTRACTOR’S
OFFICE YES
NC
N/
?ROCtJREMENT
6. Are procurement procedures established
to determine whether professional
services, equipment, material, and/or
suppliesrequested are really needed?
7. Are formal procurement procedures
established to require that equipment,
material, and supplies are obtained. on a
competitive basis?
B. Is the purpose and source selected of
every procurement documented?
9. Are prices paid for purchases under the
contract determined in writing as
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?
E-4
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OSWER Directive 9242.4—O1A September 1987
DPO
CHECKLIST FOR
REVIEWING
J’AT
CONTRACTOR
‘S
OFFICE
YES
NO
N/A
EXPENSE REPORTS
12. Are there procedures in place for
ensuring that expenditures are proper
and kept to aminimum?
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?
E— 5
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OSWER Directive 9242.4—O1A September 1987
DPO
CHECKLIST FOR
REVIEWING
TAT
CONTRACTOR
S
OFFICE
YES
NO
N /P
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?
E—6
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OSWER Directive 9242.4—O1A September 1987
DPO CHECKLIST FOR REVIEWING
TAT CONTRACTOR’S OFFICE _____________ YES NO
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?
E-7
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OSWER Directive 9242.4—O1A September 1987
DPO
CHECKLIST FOR
REVIEWING
TAT
CONTRACTOR
S
OFFICE YE
S NO
N/A
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?
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OSWER Directive 9242.4—O1A September 1987
DPO CHECKLIST FOR REVIEWING
TAT CONTRACTORS OFFICE YES NO N/A
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?
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OSWER Directive 9242.4—O1A September 1987
DPO CHECKLIST FOR REVIEWING
TAT CONTRACTOR’S OFFICE YES NO N/A
40. Is there a site safety plan for each
site?
41. Does the TAT have an approved field
sampling plan?
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OSWER Directive 9242.4—O 1A September 1987
APPENDIX F
GLOSSARY
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OSWER Directive 9242.4—O1A September 1987
GLOSSARY
Acknowledgment of Completion (AOC)/Performance Observation
Report (POR) : document submitted by the TAT Leader to the
DPO within 10 working days after task completion which
summarizes the response taken, the actual labor hours
expended, the total cost of the action, and the
performance of the contractor in carrying out the
assignment.
activity : a group of tasks that together comprise a
segment(s) of the sequence of events undertaken in
determining, planning, and completing a response to a
release or potential release of a hazardous substance.
Activities include, for example, containment and
countermeasures, feasibility studies, and construction.
allocation : according to the EPA accounting manual, an
allocation is “an amount set aside by an agency in a
separate appropriation or fund account for the use of
another agency in carrying out the purpose of an
appropriation.’
allowance : an amount established during the budgeting
process signifying the level of resources at which an
organization can operate. An allowance serves as an
unofficial spending limit from which commitments and
obligations are withdrawn.
allowable cost : means costs that are eligible,
reasonable, necessary and allocable and are permitted
under the appropriate Federal cost principles, in
accordance with EPA policy, and within the scope of the
project. For example, allowable costs might include
contractual services, response by state employees (under a
Cooperative Agreement or contract), materials and
supplies, equipment, and other direct and indirect costs.
cleanup : refers to actions undertaken during a removal or
remedial response to address a release of a hazardous
substance that poses a threat or potential threat to human
health and welfare, the environment and/or real and
personal property. Cleanup activities may include removal
and disposal of contaminated material, provision of
alternate water supplies, on—site monitoring and temporary
evacuation and relocation of threatened individuals.
commitment : an amount administratively earmarked to cover
an expected obligation. A commitment reflects the
intention to obligate funds to a specific activity. The
primary document used to commit funds is the Procurement
Request (PR) or EPA Form 1900—8.
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OSWER Directive 9242.4—O1A September 1987
Community Relations Plan (CRP) : a plan for addressing
local citizens’ and officials’ concerns to a hazardous
waste site and integrating community relation activities
into technical responses at sites to help prevent
disruptions and delays in response actions. Each CRP
should include a description of the background, history
and community concerns of the site, specific objectives of
the community relations program, specific techniques to be
used to achieve those objectives, workplan and schedule,
and budget and designation of staff who will be
accountable.
containment : an action(s) undertaken that focuses on
controlling the source of a discharge or release and
minimizing the spread of the hazardous substance or its
effects. Containment may include such actions as
construction of slurry trenches, installation of
diversionary booms, earth moving, plugging of damaged tank
cars, and/or use of chemicals to restrain the spread of
the substance.
Contracting Officer : the EPA official who has been
delegated authority to enter, modify and administer the
TAT contracts. The Contracting Officer retains sole
responsibility for most contract administration functions.
countermeasures : actions undertaken to directly protect
humans from exposure to a hazardous substance release or
potential release. Countermeasures may include such
actions as provision of alternative drinking water
sources, temporary evacuation and relocation, and closing
of public recreation facilities in the vicinity of the
release.
Deputy Project Officer (DPO) the EPA Regional official
responsible for overseeing and organizing required
interactions between Regional EPA personnel and other
Federal staff and the contractor to ensure that correct
management procedures are followed.
disbursement : actual payment for services and goods.
Disbursement is often used synonymously with the terms
“expenditure” or “outlay” in governmental accounting
literature.
discharge : as defined by section 311(a)(2) of the Clean
Water Act (CWA), includes, but is not limited to, any
spilling, leaking, pumping, pouring, emitting, emptying or
dumping of oil. For purposes of the Superfund program,
discharge shall also mean the substantial threat of a
discharge.
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OSWER Directive 9242.4—O1A September 1987
discovery : refers to the notification, observance, or
detection of a release or substantial threat of release or
discharge of a hazardous substance or oil into the
environment. A discovery may be made through notification
or investigation in accordance with statutory
requirements, incidental observation by government
agencies or the public, notifications by permit holders or
inventory efforts conducted by Federal, state or local
agencies.
disposal : the discharge, deposit, injection, decomposing,
spilling, leaking or placing of any solid waste or
hazardous waste into or on any land or water so that such
substances or any constituent thereof may enter the
environment or be emitted into the air or d-ischarged into
any waters, including groundwaters.
EPA lead : means that EPA has primary responsibility for
planning and conducting either part of or an entire
removal or remedial action.
expenditure/expense : means the incurring of a liability
or a payment of cash. The term(s) is often used
synonymously with ‘disbursement” or outlay.
facility : .(A) any building, structure, installation,
equipment, pipe or pipeline (including any pipe into a
sewer or publicly owned treatment works), well, pit, pond.
lagoon, impoundment, ditch, landfill, storage container,
motor vehicle, rolling stock, or aircraft, or (B) any site
or area where a hazardous waste has been deposited,
stored, disposed of, or placed or otherwise come to be
located; but does not include any consumer product or
vessel.
feasibility study : a study intended to a) evaluate
alternative remedial actions from a technical,
environmental, and cost—effectiveness perspective,
b) recommend the cost—effective remedial action, and
c) prepare a conceptual design, cost estimate for
budgetary purposes, and a preliminary construction
schedule.
hazardous substance : also sometimes referred to as
hazardous waste, means (a) any substance designated
pursuant to Section 31l(b)(2)(A) of the Federal Water
Pollution Control Act, (b) any element, compound, mixture,
solution, or substance designated pursuant to Section 102
of this Act, (c) any hazardous waste having the
characteristics identified under or listed pursuant to
Section 3001 of the Solid Waste Disposal Act (excluding
any waste the regulation of which under the Solid Waste
Disposal Act has been suspended by Act of Congress, (d)
any toxic pollutant listed under Section 307(a) of the
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OSWER Directive 9242.4—O1A September 1987
Federal Water Pollution Control Act, (e) any hazardous air
pollutant listed under Section 112 of the Clean Air Act,
and (f) any imminently hazardous chemical substance or
mixture with respect to which the Administrator [ EPA] has
taken action pursuant to Section 7 of the Toxic Substance
Control Act. The term does not include petroleum,
including crude oil or any fraction thereof which is not
otherwise specifically listed or designated as a hazardous
substance under Subparagraphs (a) through (f) of this
paragraph, and the term does not include natural gas,
natural gas liquids, liquefied natural gas or synthetic
gas usable for fuel (or mixtures of natural gas and such
synthetic gas).
incident : a release or potential release of oil or
hazardous substances at a waste site, abandoned facility
or. fixed operating facility or resulting from
transportation—related accident or deliberate dumping.
interagency agreement (lAG) : a legally binding agreement
between the EPA and another Federal agency where goods
and/or services are provided in exchange for monetary
reimbursement. lAGs for CERCLA activities will function
as obligating documents and as reporting documents
necessary for EPA financial and program management.
local contingency plan : a local plan maintained by an
On—Scene Coordinator (OSC) that is consistent with the
format of the NCP and provides for a well coordinated
response that is integrated and compatible with the
pollution response, fire, emergency and disaster plans of
local, state and other non—Federal entities. The plan
identifies the possible locations of discharges or
releases, the resources necessary to respond to
multi—media incidents, where such resources can be
obtained, waste disposal methods and facilities and a
local structure for responding to discharges or releases.
Memorandum of Understanding (MOU) : an agreement between
the EPA and another Federal agency which sets forth basic
policies and procedures governing the relatiorisriip on
matters of mutual interest and responsibility. There is
no exchange of funds under this type of agreement.
National Contingency Plan (NCP) : officially known as the
National Oil and Hazardous Substances Pollution
Contingency Plan, the NCP outlines the responsibilities
and authorities for responding to releases into the
environment of hazardous substances and other pollutants
and contaminants under the statutory authority of CERCLA
and section 311 of the Clean Water Act (CWA). The most
recent revision of the NCP was November 20, 1985.
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OSWER Directive 9242.4—O1A September 1987
National Priority List : a list of the highest priority
releases or potential releases of hazardous substances,
based upon state and EPA Regional submissions of candidate
sites and the criteria and methodology contained in the
Hazard Ranking System (HRS), in order to allocate funds
for remedial actions.
no further action needed : a decision either to not take
any action or terminate a removal response action to a
hazardous substance release for any of the following
reasons:
A release or potential for release does not exist.
The hazard posed by the release or potential
release does not warrant response.
A party responsible for the release or other
person is providing appropriate response.
The hazard posed by the release has been
addressed and eliminated.
obligation : a transaction which legally reserves funds
for expenditure based upon the original commitment. (An
obligation can never exceed a commitment). Obligations
are incurred with the signing of a contract or other
transactions (e.g., orders placed and payrolls) and. are
legally binding.
On—Scene Coordinator (OSC) : the Federal official
predesignated by the EPA or the USCG to coordinate and
direct a Federal response under the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP); or
the DOD official designated to coordinate and direct the
removal actions from releases of hazardous substances or
pollutants or contaminants from DOD vessels and facilities.
POLREP : pollution reports submitted by the OSC to EPA
Headquarters to report on a release, the decision to
activate the Fund, and progress at the response (including
a description of activities and status of funding).
pre—CERCLA site : one of 24 hazardous substance sites at
which response measures had been started under CWA Section
311 and were continued as removal or remedial actions
under CERCLA.
preliminary assessment : the process of collecting and
reviewing readily available information about a known or
suspected hazardous substance site or release and using
this information to determine the magnitude of the hazard,
the source and nature of a release or potential release,
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OSWER Directive 9242.4—O1A September 1987
and the identity of a responsible party, in order to
formulate response management decisions.
priority site : a site that has been included on the
National Priority List.
Project Officer : the EPA official with overall
responsibility for managing and directing activities under
the TAT zone contracts. The Project Officer provides a
single point of contact for the Contracting Officer and
the TAT zone contractors.
Regional contingency plan : consistent with the NCP at the
Regional level, the Regional Response Team’s (RRT) plan to
coordinate a timely, effective response to a discharge of
oil or release of a hazardous substance to the
environment. Regional contingency plans should include
information on all useful facilities and resources in the
Region, from government, commercial, academia and other
sources.
release : any spilling, leaking, pumping, pouring,
emitting, emptying, exploding, discharging, injecting,
escaping, leaching, dumping, or disposing into the
environment. (For statutory definition, including
e cclusions, see the NCP.)
remedial action : an action intended to provide a
permanent resolution to a release or potential release of
a hazardous substance from a site. Remedial actions are
most appropriate for long—term and costly cleanups and
generally include remedial investigations, feasibility
studies, design and construction. A Federally funded
remedial action will only be undertaken at those sites
included on the National Priority List or Interim Priority
List.
remedial investigation : an investigation intended to
gather the data necessary to: (1) determine the nature
and extent of problems at the site; (2) establish cleanup
criteria for the site; (3) identify preliminary
alternative remedial actions; and (4) support the
technical and cost analyses of the alternatives.
removal : the cleanup of released hazardous substances
from the environment; such actions as may be necessary to
monitor, assess, and evaluate the release or threat of
release of hazardous substances; the disposal of removed
material or the taking of such other actions as may be
necessary to prevent, minimize, or mitigate damage to the
public health or welfare or the environment, which may
otherwise result from such release or threat of release.
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OSWER Directive 9242.4—O1A September 1987
reportable quantity (RQ) : under section 102 of CERCLA,
the quantity of a hazardous substance established by the
U.S. Environmental Protection Agency (EPA), that if
released to the environment, may present substantial
danger to the public health or welfare or the environment
and must be reported to either the National Response
Center (NRC) or EPA. Reportable quantities are set forth
in 40 CFR Part 302. The Administrator of the EPA is
authorized to promulgate or revise regulations
establishing the quantity of the hazardous substance that
must be reported.
restart : the initiation of on—site removal activity at an
incident for which CERCLA or 311 funds have been used in
the past. (The prior 311 funding limitation applies only
to removal actions receiving 311 funds after CERCLA was
enacted on December 11, 1980.) Removals performed at
pre—CERCLA sites fall under the restart category.
responsible party : as defined by Section 107(a) of CERCLA
includes “(1) the owner or operator of a vessel (otherwise
subject to the jurisdiction of the United States) or a
facility, (2) any person who at the time of disposal of
any hazardous substance owned or operated any facility at
which such hazardous substances were disposed of, (3) any
person who by contract, agreement, or otherwise arranged
for disposal or treatment, or arranged with a transporter
for transport or disposal or treatment, of hazardous
substances owned or possessed by such person, by any other
party or entity, at any facility owned or operated by
another party or entity and containing such hazardous
substances, and (4) any person who accepts or accepted any
hazardous substances for transport to or from treatment
facilities or sites selected by such person, from which
there is a release, or a threatened release which causes
the incurrence of response costs, of a hazardous
substance. II
site : also refers to a hazardous substance site or a
hazardous waste site, is an area or a location at which
hazardous substances were stored, treated, disposed of, or
placed, or otherwise came to be located. This includes
all contiguous land, structures, other appurtenances 1 and
improvements on the land, used for treating, storing, or
disposing of hazardous substances. A site may consist of
several treatment, storage, or disposal facilities (e.g.,
impoundments, containers, buildings, or equipment).
site inspection : an aspect of field investigation,
involves the process of collecting field data from a
hazardous substance site for the purpose of characterizing
the magnitude and severity of the hazard posed by the
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OSWER Directive 9242.4—O1A September 1987
site, in order to score the site utilizing the Hazard
Ranking System (HRS). The site inspection builds on the
information collected during the preliminary assessment
and may include sampling, monitoring, surveys, testing and
other information—gathering techniques.
start : the initiation of on—site cleanup action at an
incident for which no CERCLA or 311 extramural funds have
been used previously. (The prior 311 funding limitation
applies only to removal actions receiving 311 funds after
CERCLA was enacted on December 11, 1980.)
state assurances : refers to commitments a state must make
to EPA prior to authorization of any Fund—financed
response action at a NPL site. CERCLA identifies three
specific assurances required of a state: commitment to
statutory cost—sharing requirements; commitment to obtain
adequate off—site disposal facilities for hazardous
wastes; and commitment to assume responsibility for
operation and maintenance of the response action.
Assurances are provided by a state to EPA through a
Cooperative Agreement or Superfund State Contract.
state contingency plan : a plan that outlines the
responsibilities and authorities of a state government for
responding to releases into the environment of hazardous
substances and other pollutants and contaminants,
consistent with the National Contingency Plan (NCP) and
any Regional contingency plans.
state credit : a credit against a states share of costs
for response actions at a specific release or potential
release of a hazardous substance. The credit is for
certain costs expended or obligated by the state at a
specific site for eligible response actions or claims for
damages. Site specific costs may only be applied against
the state share of costs at that specific site.
state lead . means that a state has primary responsibility
for planning and conducting either part of or an entire
removal or remedial action.
state project coordinator : designated official who
represents the state during an EPA response action not
covered by a Cooperative Agreement.
State Pro]ect Officer : designated official responsible
for direct management of the activities covered in a
Cooperative Agreement.
Statement of Work (SOW) : an element of a work assignment
package that specifies in detail the tasks and objectives
to be performed by a contractor. The SOW should contain
the salient points regarding the background of the release
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OSWER Directive 9242.4—OlA September 1987
or potential release, problem definition, purpose of the
work, and a description of the services to be performed by
the contractor.
task : a discrete piece of work that addresses a single
objective specified by a Statement of Work for planning,
evaluating, or implementing a response action (e.g.,
hydrogeological study, hazardous waste characterization,
alternative analysis, construction of a fence, or
installing a leachate control system).
Technical Assistance Team (TAT) : a contractor who
provides technical support to On—Scene Coordinators (OSCs)
in the prevention of oil spills and for emergency response
to releases of hazardous substances and oil.
Technical Direction Document (TDD) : a directive prepared
and issued by the DPO to the TAT contractor to conduct
specific services under the contract. The TDD includes
background data, scope of work to be performed. schedule
of deliverables, an estimated budget and hours, and
reporting requirements.
workplan : the contractors submittal of a written
response to a special project Technical Direction Document
(TDD) defining the technical approach for the project, the
budget, and the schedule.
Zone Program Manager (ZPN) : the TAT contractor official
who serves as the single point of contact for coordination
with the EPA Headquarters Project Officer and Regional
Deputy Project Officers. The ZPM is responsible for
supervising and managing the work of TAT Leaders.
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OSWER Directive 9242.4—O 1A September 1987
APPENDIX G
BIBLIOGRAPHY
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OSWER Directive 9242.4—O1A September 1987
BIBLIOGRAPHY
STATUTES
Clean Water Act (CWA) as amended, 33 U.S.C. Section 1251
et. seq . , PL 92—500
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 (RCR.A), 42
U.S.C. Sections 6901—6991i, PL 94—580 (amended Nov. 8,
1984).
REGULAT IONS
National Oil and Hazardous Substances Pollution
Contingency Plan (40 CFR Part 300), November 20, 1985.
Public Information: Confidentiality of Business
Information (40 CFR Part 2, Subpart B).
MEMORANDA
“CERCLA Compliance with Other Environmental Statutes.”
AA/OSWER, October 2, 1985.
“Procedures for Planning and Implementing Off—Site
Response Actions. From Jack McGraw, Acting AA/OSWER to
Regional Administators, Regions I—X, May 6, 1985.
CERCLA DELEGATIONS OF AUTHORITY
Selection and Performance of Removal Actions Costing Up to
$2,000,000, Delegation No. 14—1—A, 1987.
Removal Actions Initially Costing Over $2,000,000 at NPL
and Proposed NPL Sites, Delegation 14—2—B, 1987
Removal Actions Costing Over $2,000,000 at NPL and
Proposed NPL Sites, De1egat on 14—2—B, 1987.
Selection and Performance of Removal Actions Lasting MOre
than One Year, Delegation No. 14—3, 1987.
Selection and Performance of Federal Corrective Actions at
Leaking Underground Storage Tanks, Delegation No. 8—33,
1987.
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OSWER Directive 9242.4—O1A September 1987
EPA DOCUMENTS
Cost Recovery Actions tinder the Comprehensive
Environmental Response, Compensation, and Liability Act of
1980 (CERCLA ) OECM and OSWER, August 26, 1983.
Emergency Response Cleanup Service (ERCS) Contracts Users
Manual , U.S. Environmental Protection Agency, Office of
Emergency and Remedial Response, October 1983 (Revised
1986).
EPA Standard Operating Safety Guides , U.S. Environmental
Protection Agency, November 1984.
Guidance for State Contingency Plans for Superfund
Immediate Removals , OERR, July 1983.
Guide for Control of Government Property by Contractors ,
U.S. Environmental Protection Agency, Office of Management
Information and Support Services, November 1981.
Removal Actions at Ranked and Unranked Sites , U.S.
Environmental Protection Agency, Office of Solid Waste and
Emergency Response, May 1983.
Removal Cost Management Manual , U.S. Environmental
Protection Agency, Office of Emergency and Remedial
Response, January 1985.
Superfund Community Relations Handbook , U.S Environmental
Protection Agency, Office of Emergency and Remedial
Response, September 1983 (Revised March 1986).
Superfund Removal Procedures , ERD, August 1984 (Revised
1986).
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OSWER Directive 9242.4—O1A September 1987
EPA SUPERFUND PROCEDURES HANDBOOKS*
Community Relations Handbook , July 15, 1981. (Revised
September 1981).
Handbook prepared under EPA contract with ICF, Inc. It is
not reflective of EPA policy or opinions. (See also
SFPG—S2—1 and SFPG—82—4).
Financial Management Officers User Manual for the
Hazardous Substance Response Program , July 1982.
Provides program specific guidance to financial management
offices in carrying out their financial recording and
reporting responsibilities for tracking Superfund dollars.
Guidance on Cooperative Agreements With States Under
CERCLA Dated , March 11, 1982.
Guidance which addresses the authorization, delegated to
EPA by Executive Order 12316, to take remedial actions to
clean up uncontrolled hazardous waste sites. The four
provisions which are detailed are: Federal remedial
actiOns be undetaken only after consultation with affected
State(s); assurances that affected State must provide
regarding O&M.responsibili ies , off—site disposal, cost.
sharing; granting credit to an affected State for costs
expended or obligated between January 1, 1978 and
December 11. 1980.
Interim Standard Operating Procedures , May 1, 1981.
Manual designed to furnish On—Scene Coordinators with
criteria for selecting appropriae safety protocals on a
case—by—case basis and as a supplement to current
Headquarters/Regional safety manuals.
Notification Processing Support Procedures Manual ,
July 24, 1981.
Memoprandum transmitting new procedures to be followed
when using the revised Potential Hazardous Waste Tracking
System (Code 2070 Forms) and several f the longer-range
ADP support objectives to be implemented during the first
half of FY 1982.
* Publications are available upon request from the U.S.
Environmental Protection Agency, Office of Emergency
and Remedial Response, Washington, D.C.
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DISCLAIMER
The policies and procedures established in this document
are intended solely for the guidance of government personnel.
They are not intended, and cannot be relied upon to create any
rights, substantive or procedural, enforceable by an party -in
litigation with the United States. The Agency reserves the
right to act at variance with these policies and procedures and
to change them at any time without public notice.
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