TES User Guide
Technical Enforcement Support
at Hazardous Waste Sites
U.S. EPA Contract Nos,
68-01-6769 (TES 1)
68-01-7037 (TES 2)
January, 1986
Prepared for
U.S. Environmental Protection Agency
Office of Waste Programs Enforcement
Washington, D.C. 20460
Prepared by
PRC Environmental Management, Inc.
Planning Research 303 East Wacker Drive, Suite 600
Corporation Chicago, Illinois 60601
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TES
USER GUIDE
Technical Enforcement Support
at
Hazardous Waste Sites
U.S. EPA Contract Nos.
68-01-6769 (TES 1)
68-01-7037 (TES 2)
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Waste Programs Enforcement
Washington, D.C. 20460
Prepared by:
PRC Environmental Management, Inc.
303 E. Wacker Drive
Suite 600
Chicago, IL 60601
in cooperation with
GCA Corporation
GCA/Technology Division
213 Burlington Road
Bedford, Massachusetts 01730
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TES USER GUIDE
TABLE OF CONTENTS
Page
Introduction
The TES 1 Team . . .
The TES 2 Team. . . . . . . . 1
TES Contract Features . . 2
Initiating and Executing the Work Assignments
Step 1 - Identify Needs . . . . . 3
Step 2 - Develop Statement of Work . . 4
Step 3 - Complete Work Assignment Action Form 4
Step 4 - Forward Work Assignment Request to Contractor 5
Step 5 - Review and Approve of Work Plan . . . . . 6
Step 6 - Monitor Work Assignment Execution 6
Step 7 - Review Deliverables and Close Out Work
Assignment . . 7
LIST OF APPENDICES
Appendix A. Summary of Services Available and Descriptions of
Task Types Under TES
Services Available . . . . . A-i
Task Types . . . . . . . . A-4
- Responsible Party Search . . A-4
5 - Title Search . A-6
10 - Financial Assessmentt A-7
15 - Records Compilationt . A-9
20 - Health/Endangerment Assessmentst . . . . . A-b
30 - Hydrogeologic/Geologic Studiest A-12
40 - Other Special Studiest . . . . . . . A-12
45 - Feasibility Studiest A-13
46 - Focused Feasibility Studiest A-14
50 - Sample Analysist . A-16
55 - Biological Testing t . . . . . . . . A-16
60 - Technical Review of Documentst. . . . . . . . A-16
65 - Expert Witness/Consultantt . . . . . . A-18
70 - Interrogatory Preparationt . . . . A-l9
75 - Evidence Storage/Preservationt . . . . . . . . A-19
80 - Compliance Monitoring . . . . . A-20
85 - Evidence Auditst . . . . . A-22
90 - Cost Recovery Documentation . . . . A-23
99 - Other . . . . A-23
* Pertains to both CERCLA and RCRA support services
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Appendix B. Example Work Assignment Statements of Work
Example 1: Technical Review of Documents . B-i
Example 2: Records Compilation B-3
Example 3: Feasibility Study . B-5
Example 4: Expert Witness . . . B-7
Example 5: Health/Endangerment Assessment . . . . . B-1O
Appendix C. Example Work Assignment Action Forms
Example Work Assignment Request . . . C-i
Example Work Plan Approval . . . . . . . C-2
Example Work Assignment Amendment . . C-3
Example Work Assignment Completion/Close-out. . C-4
Appendix D. Titles and Functions of Key TES Personnel . . . . . . . . D-i
Appendix E. TES Work Assignment/Work Plan Preparation
and Approval Process Flow Diagram E-l
Appendix F. TES 2 Work Assignment Performance Approval Form F-i
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TES USER GUIDE
Introduction
The U.S EPA Office of Waste Programs Enforcement (OWPE) has awarded two
contracts for Technical Enforcement Support at Hazardous Waste Sites (TES).
The first TES contract (TES 1) was awarded to GCA/Technology Division on June 9,
1983 The second TES contract (TES 2) was awarded to PRC Environmental
Management, Inc. on October 1, 1984. Both GCA and PRC are prime contractors for
teams made up of several specialty subcontractors, each team capable of providing
a wide range of technical skills and services directed at support for the
enforcement activities undertaken by OWPE and the Regions.
The TES 1 Team
The TES 1 team is headed by GCA/Technology Division, Bedford,
Massachusetts. GCA, a full service environmental engineering and consulting
firm, has served both industrial and government clients since 1958 in the areas
of air and water pollution control and hazardous waste management. (GCA is also
a member of the TES 2 team). GCA’s three subcontractor team members are describ-
ed below.
o TechLaw, Inc., Fairfax, Virginia, provides hazardous waste site case
preparation support, including title searches, responsible party
determinations and liability assessments. (TechLaw is also a member of
the TES 2 team).
o Metcalf & Eddy, Inc., Boston, Massachusetts, is an architectural and
engineering consulting firm which has had extensive experience in
industrial waste management and in hazardous waste remedial activities,
and provides preliminary remedial design and plan review for the TES 1
team.
o Clement Associates, Inc., Alexandria, Virginia, provides human health
and environmental effects services, and has many toxicologic, ecologic
and risk/exposure assessment specialists on staff.
The TES 2 Team
Planning Research Corporation (PRC) is the prime contractor for the TES
2 Contract and provides experience in the management of large, multi-disci-
plinary engineering and environmental programs. PRC offers environmental
engineering services nationwide, with particular strength in the midwest,
southeast and west. Founded in 1954, PRC is headquartered in McLean, Virginia,
and has over 150 offices world wide.
The two firms joining the PRC team as primary subcontractors for this
contract are Jacobs Engineering Group, Inc. (Jacobs) and GCA/Technology Division
(GCA). Jacobs, headquartered in Pasadena, California, supplements the team’s
engineering expertise and strengthens and enhances the team’s capabilities in the
southwest and west. GCA, the current TES 1 prime contractor, provides the team
with unparalleled knowledge of the program, as well as supplementing engineering
capabilities in the east. -
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PRC, Jacobs and GCA are augmented by the following specialty firms, each
offering demonstrated skills and technical experience directly related to the
enforcement program:
o Versar Inc. has in-depth experience in RCRA field work and endangerment
assessments, and has strong analytical capabilities.
o Booz-Allen & Hamilton is nationally recognized for its capabilities
in the area of public policy and planning for Superfund programs
o ICAIR, Life Systems, Inc., specializes in providing technical experts
for consultation and litigation support (expert testimony) and in
performing endangerment assessments.
o INTERA/GeoTrans is experienced in dealing with complex ground-water
contamination problems, hydrologic and hydrogeologic evaluations and
endangerment assessments.
o TechLaw, Inc. offers specialized capabilities in enforcement support
work, especially responsible party searches and title searches.
o Putnam, Hayes and Bartlett provides the team with capabilities in
regulatory analysis, decision modeling and financial analysis.
TES Contract Features
The TES 1 contract is capable of supporting up to 275,000 technical labor
hours of effort over its three-year maximum life. (Approximately 175,000 hours
had already been obligated at the time of award of TES 2.) The TES 2 contract
can support up to 600,000 technical labor hours of effort over its maximum
three-year life. Both TES contracts are level-of-effort (LOE) contracts which
allow specific tasks to be assigned to the contractor on an as-needed basis,
within the restrictions of the overall contract statement of work and within the
technical labor hours and dollar ceilings established by the contract. These
tasks are assigned to the contractor through the use of individual written work
assignments which contain their own statements of work, delivery schedules and
other performance specifications. GCA (under TES 1) and PRC (under TES 2)
respond to each work assignment by submitting a work plan and cost estimate to
EPA for review and approval. Upon EPA approval of each work plan, work may
begin. The work will normally be completed within the performance period
specified, and within the hours and cost budget approved in the work plan. Work
stops on a work assignment when 1) the final deliverables (reports, briefings,
etc) have been provided, 2) the budget has been expended, or 3) the Contracting
Officer so directs the contractor.
The purpose of both TES contracts is to support the enforcement activities
of OWPE and the Regions as they relate to the CERCLA and RCRA laws and their
implementation. The TES contractors provide the technical support and expertise
necessary to allow EPA to follow up more effectively on CERCLA and RCRA
administrative and judicial orders, through the execution of a wide range of
enforcement-related tasks (see Appendix A for task identification and
discussion).
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The intent of this user guide is both to acquaint the prospective user
with the capabilities and procedural requirements of the TES contracts and
to illuminate for the more experienced TES users the useful features and
capabilities available which may have been overlooked in the past. (There
are no significant differences between TES 1 and TES 2 in either function or
use, and the discussions contained within this guide apply to both, unless
otherwise specified within. This User Guide replaces the User Guide prepared by
GCA in March of 1984.) The ease of use of these contracts and the flexibility,
quick response features, and unique expertise available, make them extremely
valuable resources which can be of great use to EPA if employed to their full
potential by all Regions and OWPE
Initiating and Executing the Work Assignment
The prospective TES user will reach a point during the execution of his
or her day-to-day hazardous waste enforcement activities where it will be
obvious that resources and skills available inside EPA are either insuffi-
cient or unavailable to continue escalation of the enforcement actions underway
This is the point at which it should be clear that TES is needed. A near-crisis
situation often develops to reinforce this need. Also, by this time the need
must be fulfilled with minimal additional work burden placed on the user.
Accordingly, the following step-wise procedural outline has been provided to lead
the user quickly down the pathway toward work initiation and execution. Although
TES is an easy and flexible tool designed for use in such circumstances, it is
not a substitute for good project and enforcement case planning. The time frames
built into TES to initiate work presume that good planning has occurred The
emergency or quick response capabilities of TES should be necessary only in
isolated cases. The steps to be followed in initiating and executing a TES work
assignment are set forth below.
STEP 1 - Identify enforcement support needs and match needs to TES task types
available (Appendix A).
Example:
Enforcement Surrnprt Need Task No. Task Tyøe
RI/FS plan (120 pages) 60 Technical
submitted by potentially review of
responsible party in documents
response to CERCLA administra-
tive order must be reviewed
for technical quality,
conformance with the National
Contingency Plan, and compliance
with the Order.
Appendix A contains a detailed description of work done under each task
type. This information may be useful in matching enforcement support needs
with services available under the TES Contracts.
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STEP 2 - Develop a statement of work which describes the work to be accom-
plished, using examples provided in Appendix B.
A good statement of work contains at least the following items, and in
the order given:
1 Introduction/background (1-2 paragraphs),
2. Clear statement of enforcement need(s) and regulatory action being
supported (2-3 sentences),
3. Description of specific tasks to be performed (1 short paragraph
per task);
4. Deliverables required (reports, briefings, letters, etc.);
5. Clear, realistic schedule for task completion and deliverable due
dates;
6. Anticipated Contractor travel requirements and meeting attendance;
7 Technical level-of-effort hours estimate (see Appendix A for detailed
task descriptions and guidance for estimating hours).
STEP 3 - Complete a multipurpose work assignment action form (example work
assignment request is shown in Appendix C).
The Regional Contact has a supply of these forms, which are designed to
be used not only for initial requests, but also for work plan approvals, work
assignment amendments, and final report approval/assignment close-outs.
Enter the site name and number, task type(s) and the enforcement objective
and regulatory action being supported, as determined in STEP 1, on the indicated
parts of the form. Enter the technical level-of-effort hours estimate, period of
performance and deliverables required, as determined in STEP 2. (Add an
additional 30 days to the period of performance if a draft final report is
desired.) Identify the Primary Contact, Back-up Contact and Initiator by full
name, address, and commercial telephone number. (See Appendix D for descriptions
of titles and functions of key TES personnel). Attach the statement of work
prepared in STEP 2.
Review the work assignment/work plan preparation and approval process
flow diagram provided in Appendix E. If the schedule in the statement of
work is such that the normal approval process can occur before work must begin,
mark the “normal” box on the form If work must begin ahead of formal work plan
approval, mark the “expedited” box. In either case, work cannot begin until the
Contracting Officer approves the work assignment request. For normal requests,
the work plan submitted by the Contractor must also be approved by the
Contracting Officer before work can begin (Based on prior experience with TES,
more than 90 percent of work assignments can be handled in the normal mode.) If
the work assignment absolutely must be expedited, a written justification must be
attached to the work assignment action form. Proper justification is limited to
such occurrences as unexpected court directives, unexpected need for expert
witnesses, and emergency situations requiring quick response (e.g. evidence
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preservation on scene, or need for private investigator on location.) The
Project Officer will enter the document control number (DCN), identify the TES
contractor and TES contract (TES 1 or TES 2) to be used, and will assign a work
assignment number.
Should an expert witness or consultant be required, PRC or GCA will match
qualified experts available within the ranks of the TES team to those needs
specified within the statement of work. Infrequently, it may be necessary to
search for qualified experts from outside the TES team. In those situations, a
search will be conducted to develop list of up to five qualified candidates,
which EPA can interview and from which a final selection can be made (Please
note that a completed Subcontract with the expert witness or consultant must be
approved by the Contracting Officer before work can begin, if outside the TES
team.)
Concurrence by appropriate CERCLA and RCRA management of the completed
work assignment action form must be obtained prior to submittal for appro-
val. This concurrence process will vary from region to region and within
OWPE.
STEP 4 - The fully completed and authorized work assignment request is sent
through the Regional Contact to the OWPE Project Officer, as shown in the
Appendix E flow chart.
Once the Contracting Officer approves the work assignment, a copy is
sent to the Contractor. The Contractor acknowledges receipt of the work assign-
ment within five days by returning a signed copy of the form to the contracting
officer. PRC, GCA or the TES team member assigned, prepares within 15 calendar
days a work plan which is reflective of the requirements in the work assignment,
and forwards the work plan to the Project Officer, the Contracting Officer and
the Primary Contact for approval. In most instances, telephone communication is
made by the Work Assignment Project Manager to the EPA Primary Contact before the
plan is prepared. This allows further clarification and scoping of the assign-
ment, and helps to avoid time delays in approval of the plan. All work plans
contain the following elements:
1. Introduction and synopsis of work statement
2. Project approach
3. Deliverables
4. Work schedule
5 Personnel
6. Interviews, subcontractors, consultants required
7. Exceptions to the assignment, anticipated problems,
special requirements
8. Quality assurance considerations
9 Cost estimate
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STEP 5 - Review and approve submitted work plan Communicate approval through
the Regional Contact to the Project Officer.
Within 15 calendar days of receipt of the work plan, EPA will review and 1)
approve the work plan as written, 2) approve it with changes, or 3) disapprove
it, using the work assignment action form work plan approval example shown in
Appendix C. If good verbal communication has occurred between the Work Assign-
ment Project Manager and the EPA Primary Contact, virtually all work plans
will be approved either as written or with mitior changes.
STEP 6 - Monitor, track and direct the execution of the work assignment.
Work by the Contractor begins upon receipt of work plan approval from
the Contracting Officer During the active life of each work assignment,
beginning on the twentieth day of the month following approval, and monthly
thereafter, progress reports are submitted by the Contractor to the Project
Officer, the Contracting Officer and the Regional Contact. These progress
reports contain the following information
1. Project status
2. Next activities planned
3. Schedule problems, if any
4 Cumulative costs and labor hours expended
5 Costs and labor hours expended for the reporting period
6. Total budgeted costs and labor hours
7. Cost/hour problems, if any
Effective and frequent communication between the Work Assignment Project
Manager and the EPA Primary Contact will help to reduce the occurrence of
schedule or cost problems Any problems anticipated by either the Contractor or
the EPA must be communicated to the other party as soon as possible The monthly
report is a formal communication device, and is not intended to serve as the only
means of information transfer on the work assignment
Occasionally, the scope of work, the period of performance or the cost
originally approved will have to be changed to fit the changing needs of an
ongoing enforcement case. Since only the Contracting Officer has authority
to redirect the Contractor (see Appendix D, titles and functions of key person-
nel), an amended work assignment must be prepared and forwarded for the approval
of the Contracting Officer, using the procedures set forth in STEPS 2 through 4
above. (A revised work plan may or may not be necessary, depending on the
magnitude and complexity of t e changes required.)
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STEP 7 - Review deliverables and close out work assignment.
A final report must be prepared by the Contractor for each work assign-
ment. Draft reports or other deliverables may also be required (see STEP
2). Copies of each specified draft or final report will be provided to the
Project Officer (Regional Coordinator, if appropriate) and the Regional Contact
for review and approval. (Draft reports must be submitted at least 30 calendar
days before the due date of the final report.) Within 15 calendar days of
submittal, EPA will review and 1) approve the report as written and close Out
the project, 2) approve it subject to specified changes, or 3) disapprove it.
The work assignment action form will be used to effect this communication
(close-out example shown in Appendix C), and will be initiated by the primary
contact and forwarded through the Regional Contact to the Project Officer
All final reports will have attached to them a Contractor Performance
Appraisal Form (example provided in Appendix F). The Primary Contact will
complete this form and return it through the Regional Contact and the Project
Officer to the Contractor. It is important that written feedback, whether
positive or negative, occur for each work assignment at completion. It is also
important that verbal feedback occur during the life of each work assignment, in
order to allow the TES team to be immediately responsive to the user.
This user guide will be updated as required to keep it current with respect
to procedures, personnel and task information. In order to facilitate communica-
tion of the updated information to the users, it is asked that form below be
filled out and returned to OWPE. Users who filled out a mailing list form from
the original TES manual will be included on the mailing list for this guide
Clip here and return to:
Michael Kosakowski
Chief, Technical Support Branch (WH 527)
OWPE
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
User Name: _________________________
Title: ____________________________
Address: _____________________________
Commercial
Telephone No.: _______________________
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APPENDIX A
SUMMARY OF SERVICES AVAILABLE
AND
DESCRIPTION OF TASK TYPES
UNDER TES
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SERVICES AVAILABLE
Work Assignments awarded under this contract support EPA enforcement
actions authorized under the Comprehensive Environmental Response, Compensa-
tion and Liability Act (CERCLA) and the Resource Conservation and Recovery
Act (RCRA). The types of services available include the following work areas:
Task Np, Task TyDe
Responsible Party Search
5 Title Search
10 Financial Assessment
15 Records Compilation
20 Health/Endangerment Assessment
30 Hydrogeologic/Geologic Studies
40 Special Studies
45 Feasibility Studies
50 Sample Analysis
55 Biological Testing
60 Technical Review of Documents
65 Expert Witness/Consultant
70 Interrogatory Preparation
75 Evidence Storage/Preservation
80 Compliance Monitoring
85 Evidence Audits
90 Cost Recovery Documentation
99 Other
It should be noted that the TES contract cannot be used to hire attorneys
for litigation support.
For each task type (and sometimes for identifiable sub-tasks), an effort has
been made to estimate for both CERCLA and RCRA- support the cost in technical
labor hours required for completion. These estimates are based on the experience
of the TES 2 contractor (PRC Environmental Management) since October 1984.
Because the experience with certain task types has been limited, estimates of
levels of effort for those tasks may not be a good indicator of future require-
ments. Please note that the technical labor hours estimate must include work
assignment management time required by the prime contractor: This will usually
fall within a range from 5 to 10 percent of the total technical level of effort
estimate, and will depend on such factors as project duration and technical
complexity.
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TABLE A-i. LEVELS OF EFFORT FOR ENFORCEMENT TASKS
UNDER TES CERCLA AND RCRA (TES 2 - July i985)
CERCLA Total Labor Hours (TLH)
No. of Per Site Studied
Task Np, Task Type Tasks High Low Average
Responsible Party 129 4,075 75 318
Search
5 Title Search 17 481 23 131
10 Financial Assess- 7 600 69 240
ment
15 Records Compil- 14 1,700 40 439
ation
20 Health & Endanger- 9 640 348 445
ment Assessments
30 Hydrogeologic/Gep- 3 6,200 400 2,640
logic Studies
40 Special Studies 3 500 97 359
45 Feasibility Studies 7 2,271 248 973
50 Sample Analysis 2 200 108 154
55 Biological Testing NA NA NA NA
60 Technical Review 20 1,000 80 333
of Documents
65 Expert Witness 34 1,692 4 136
Consultant
70 Interrogatory 1 283 283 283
Preparation
75 Evidence Storage/ NA NA NA NA
Preservation
80 Compliance 4 2,000 1,000 1,500
Oversight
85 Evidence Audits NA NA NA NA
90 Cost Recovery 8 2,100 85 696
Documentation
a NA - Not available.
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TABLE A-i. (Continued)
RCRA
Task No Task Type
1 Responsible Party
Search
5 Title Search
10 Financial Assess-
ment Documentation
15 Records Compilation
20 Health/Endangerment
Assessments
30 Hydrogeologic/
Geologic Studies
40 Special Studies
45 Feasibility Studies NA
50 Sample Analysis
55 Biological Testing
60 Technical Review
of Documents
65 Expert Witness
Consultant
70 Interrogatory
Preparation
75 Evidence Storage/
Preservaion
80 Compliance
Oversight
85 Evidence Audits
90 Cost Recovery
Documentation
a NA - Not available
NA NA NA
126 126
Total Labor Hours (TLH)
No of Per Site Studied
Tasks High Low Average
NA NA NA NA
126
2
183
136
160
NA
NA
NA
NA
NA
NA
NA
NA
8
371
39
156
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
6
1600
50
363
4
200
8
95
NA
NA
NA
NA
NA
NA
NA
NA
9
1000
60
237
NA
NA
NA
NA
NA
NA
NA
NA
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TASK TYPES
1 - RESPONSIBLE PARTY SEARCH
The search for responsible parties can take several forms, ranging from
the piecing together of inferences and insights gained only after the most
exacting efforts to locate relevant files or knowledgeable individuals, to
the detailed review of concise and comprehensive documentation on hazardous
waste shipments. When a responsible party search is requested, the technical
approach will depend on the timetable envisioned for completion of the Remedial
Investigation/Feasibility Study (RI/FS) and initiation of enforcement action, the
efforts previously made by EPA and/or state or local agencies to identify the
location of relevant documentation and any specific objectives enumerated by the
Regional contacts.
To facilitate identification of objectives, responsible party search
strategies may be classified broadly as shown below. (The level-of-effort esti-
mates given here should only be used as a guide. Work Assignment-specific
requirements may result in wide variations in these level-of-effort estimates.)
Preliminary Investigation and Cpmøosite Case File Develoøment
This is used when EPA is interested only in gaining background informa-
tion about the site and previous activities associated with identification
of responsible parties. A title search may be included (see discussion below),
however, the essence of this effort is the systematic review of all files
developed to date in conjunction with interviews with knowledgeable state and
local officials
The result is a report which summarizes the status and location of known
records, prior efforts to identify responsible parties, the results of these
efforts (including a discussion of general waste disposal practices in the
area), and any additional information relevant to further investigation. In
addition to the report, this effort results in the development of a compo-
site case file which combines specific documents from all offices contacted
in a systematic and organized manner. Where information directly related to
specific potentially responsible parties is uncovered, it is highlighted in
the report. Recommendations for further investigation also are included.
This effort usually requires approximately 120-150 hours to complete (exclusive
of title search).
Field Investigation
This is used when there exist no owner/operator records or any other
documentation specifically linking parties to the site, and where EPA must
identify responsible parties as concretely as possible. This effort involves
undertaking any number of a variety of tasks (including a title search) designed
to develop leads and inferences with respect to responsible parties. Usually,
state and local officials are interviewed first to develop a general picture of
the site and its operational characteristics.
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Further investigation involves the development of an inventory of facilities
(relying on various publications, including industrial manuals and phone books)
which, based on the general disposal practices in the area, were likely to have
used the site. Industrial process and waste stream information is developed for
these facilities and matched against components found at or around the site
during sampling. This comparison often leads to strong inferences of linkage to
the site. In addition, personal interviews are conducted with individuals
identified as most knowledgeable about the site. Often, these interviews can
confirm that certain facilities on the preliminary inventory have used the site.
Ex-employees of local generators and haulers, local government officials and
residents and consumer groups often provide the most useful evidence During the
course of this investigation, documents which provide concrete links between
certain parties and the site are routinely uncovered through interviews and
library research.
A field investigation culminates in a report which details the respon-
sible parties identified and provides citations to specific evidentiary materials
(including interview statements) This effort routinely requires the expenditure
of between 175 and 500 hours (exclusive of title search), depending on the
complexity of the site and disposal area.
Record Review
When records exist which establish direct links between certain parties
and the site, it is often best to focus on those records. In many cases,
site owner/operator records or the records of a leading waste hauler in the
area are comprehensive and provide an extensive list of responsible parties.
This effort involves obtaining the records, organizing them systematically into
individual company files, and recording relevant information regarding company
name, address, type of documentation, volume of waste disposed, years involved
with the site, and other useful data. Often this information is placed in a
computerized data base for easy access during further enforcement activities.
The level of effort varies depending on the volume and complexity of
documentation and the amount of information to be recorded. For example,
invoices, ledgers, cancelled checks, cash receipts, and waste tickets could
number in the thousands, yet each document must be reviewed to assure that
no responsible parties are omitted. Experience indicates that it can require
between 300 and 1,000 hours to complete this kind of effort.
Transactional Data Base
Where documents are available which provide specific and uniform data
on waste shipments, this effort results in a detailed computer data base summari-
zing each shipment for each company. It is the most comprehensive product that
can be provided in detailing responsible party involvement and permits EPA to
develop generator and transporter ranking lists which are extremely important in
initiating enforcement activity and negotiations among potential defendants for
clean up or cost recovery actions. The tasks associated with this effort consist
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of document organization by responsible party, piecing together of documents
evidencing separate waste shipments, and extracting data, such as company name,
waste type, waste components, waste volume, type of transaction, relevant dates,
and site location. The data are entered into a computer, a data base is created
and transactional reports and ranking lists are generated. This data base is
then updated as EPA proceeds through negotiations or litigation and new data
become available.
The resources required for a transactional data base depend on the volume of
documentation. Experience indicates a range of approximately 400 to 1,500 hours
can be necessary to complete these assignments.
Company Address Update
Responsible party searches also include tasks necessary to locate the
current addresses of companies uncovered during the investigation In many
cases, this requires research through industrial manuals, industry publica-
tions, SEC and Commerce Department publications, tax records, ownership and lease
records, state corporation commission records and telephone books. More often
than not, attempts at telephone contact can confirm otherwise ambiguous addres-
ses. Company address updates are normally estimated to average 0.5 to 1.0 hour
per company
5 - TITLE SEARCH
A Title Search is requested individually, or as a part of a broader Respon-
sible Party Search. The phrase “Title Search” is used to encompass a variety of
possible research efforts, each yielding a somewhat different packet of present
and historical information regarding ownership and/or use of a site. The speci-
fic information requested is predicated on EPA’s need; such as, simply to collect
title documents for a single parcel or alternatively, for several related
parcels, to obtain a clear description of the history of ownership of each
parcel, an Abstract of Title and certified copies of relevant documents.
An Abstract of Title focuses on each recorded document and presents relevant
information from that document; for example, book and page number, mortgage
amount, lien amount, and so on. This document is usually prepared by an attorney
or title company. Where a history of ownership is needed, the land descriptions
in the title documentation are reviewed and a sequential listing of owners of
each parcel of interest is constructed. This effort often is complicated by
numerous transactions, involving parts of parcels and transactions involving
multiple parcels. The end product enables EPA to identify readily the owner of
any parcel at any point in time within the duration of the title search.
For any Title Search request, the contractor will determine with EPA
the specific information needed, contact several local title companies and/or
attorneys specializing in title research, select one capable of providing the
written contract setting forth the terms agreed to, and review the title documen-
tation to assure that the required information/or documentation has been provid-
ed. These are minimum requirements that are necessary for even the simplest
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title requests. As a result, the ratio of contractor hours to title company
hours will be higher for less complex title searches than for some requests
requiring a greater number of title company hours.
For purpose of explanation, two broad categories of Title Search requests
can be described. The levels of effort described include both contractor and
title company hours The estimates should be used only as a guide since specific
work assignment requirements may cause significant variations in these estimates.
Simple Request For Title Documents
For the simplest Title Search requests calling for copies of deeds for
a single parcel over a brief period of time, a level of effort in the range of
25 to 50 hours (total contract and Title Company) can be expected. In this case,
no Abstract of Title or History of Ownership is requested.
Complex Request
More complex requests for title documents may cover several parcels of
land and require the development of a complete history of transactions for
each. -
o Documents and Abstract of Title
Experience with requests of this sort indicates that a level of effort
can range from 20 to 40 hours depending upon the amount of documenta-
tion to be reviewed and abstracted. Obtaining an Abstract of Title for
between 20 and 40 interrelated parcels can require a level of effort in
the range of 60 to 125 hours, respectively.
The final product in these cases includes a Title Abstract and Title
Documents but does not include a History of Ownership.
o History of Ownership
The level of effort required to prepare a History of Ownership is
necessarily influenced by the number of transactions and can range from
10 to 60 hours depending upon the complexity of the documentation.
10 - FINANCIAL ASSESSMENT
In establishing liability, it is not enough to identify the responsible
party or parties contributing to environmental risk. As a practical matter,
the ability of the responsible party to pay for the cost of remedial actions
must also be assessed to establish the extent of payment possible.
Financial assessments involving publicly owned companies or those where
detailed information is available from Dun & Bradstreet are usually conduc-
ted by National Enforcement Investigations Center (NEIC). The TES contrac-
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tor often provides financial assessments for small privately-held companies
or individuals. Because available information varies considerably, it is
difficult to predict time and cost required to conduct the assessment.
Most financial assessment tasks usually fall into one of the following
categories: (1) a search of corporate structure and assets, (2) an audit of
financial records, (3) an investigation of company business practices and
assets, or (4) a property appraisal.
Corporate structure searches are usually performed for 10 to 50 companies,
requiring approximately 5 to 50 hours per company, and involve the following
tasks:
o Obtaining and reviewing records from State Corporation Divisions
to learn the status of a company (such as, active, dissolved, bankrupt,
and so on), name changes, corporate mailing address and location, and
names and addresses of the company’s registered agent and corporate
officers;
o Contacting local tax assessors’ offices; and
o Examining industrial directories, trade journals, local newspapers, and
other sources to acquire additional information on the company’s
status, structure, and history.
Auditing of financial records tends to be a medium-size financial assessment
task (approximately 100 hours). However, these tasks can be disproportionately
expensive because they require the services of a Certified Public Accountant.
Contractor time is required to locate a suitable accountant as well as to monitor
the accountant’s performance.
An investigation of a company’s business practices and assets usually
involves locating and contracting with a private investigator to follow up
such leads as bankruptcy claims, property transactions, and so on. Past employ-
ees may be interviewed, as in field investigations. Investigations of business
practices and assets typically require 200 to 300 hours, although this estimate
will vary with the extent of existing documentation and the ease of locating and
interviewing former employees.
A property appraisal task involves selecting an appraiser and the appraisal
itself. Selection entails locating a qualified appraiser near the site, arrang-
ing for a meeting between the appraiser and the EPA coordinator (if necessary),
and monitoring the appraiser’s performance. In general, 20 to 30 hours are
required to locate an appraiser approved for government work and to arrange a
subcontract. Costs for these tasks are difficult to determine in advance, as
most appraisers will not submit a cost estimate without viewing the property
first Factors which affect cost include the number of sites for which an
appraisal is required, and whether special work such as soil borings must be
performed. At times, two appraisals are necessary -- one pre-remedial action and
one post-remedial action.
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With regard to RCRA assignments involving financial assessments, the
assessment of a facility’s ability to pay administrative penalty is commonly
undertaken under the TES contracts. Also relevant would be the determina-
tion of possible economic savings or economic benefit accruing to an owner/opera-
tor who deferred timely installation of an acceptable ground-water monitoring
system or other required equipment. The owner/operator’s ability to properly
insure the facility is another item which can be clarified by financial assess-
ments under TES. RCRA financial assurance tests, as required under the April
1982 regulations can be reviewed or conducted by TES’ team members.
15 - RECORDS COMPILATION
Various assignments, including responsible party searches, discussed
above, involve compilation of records and analysis of documents. For obvious
reasons, the level of effort required to compile records and/or analyze docu-
ments is influenced by specific end product required by EPA and by the nature and
extent of the documents from which this product is to be developed. More so than
for other facets of responsible party searches, records compilation and document
analysis are decidedly unique to the particular task at hand. Major features of
a project that affect the level of effort include, number of documents; type of
documents (clearly legible, chronologically ordered invoices; assortments of
letters; invoices; 104(e) responses); document organization required (none;
chronological ordering, numbering; organization by responsible party); and
information extraction (name only; name, address, waste weight, volume; key word
indexing). Similarly, EPA’s end product may require anything from a listing of
names to the construction of a waste transactional data base or a payments data
base to support cost recovery actions. RCRA records compilation assignments may
include the collection, organization and review of ground-water monitoring
reports, RCRA Part B permit applications or other documents as they may be
associated with enforcement actions, either contemplated or under way.
The specific project requirements will be worked out at the outset of
these tasks. Experience with relatively simple and quite complex record compila-
tion and document analysis tasks indicates that the level of effort can range
from a few hundred to several thousand hours. The following is a broad breakdown
of tasks:
Document Location and ComDilation
The various document processing steps begin with locating and compiling
originals or working copies of relevant documents. Often this involves sending
personnel to the place where documents are located for purposes of sorting and
copying relevant documents It can take between 4-8 hours to review one box to
Sort out relevant documents, depending on the information being searched It
typically requires an additional 4-8 hours of effort to copy a box documents.
Estimates for various projects of this type range from 50 hours to 250 hours.
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Document Organization
Documents must then be organized, in some cases by simply numbering pages or
in more complex cases, by sorting the documents into specific categories.
Organizing a group of documents according to specific categories (for example,
generators, payments) can require between 40 to 150 hours, depending on the
volume of documents and number of files being created
Document Inventory - Bibliogrpnhjc
EPA often requests that documents be inventoried. This routinely requires
extraction of bibliographic and other information onto document coding sheets.
This information is then entered into a computer data base. The level of effort
for this task depends on the number of documents to be coded and the involvement
of the contractor in the design and preparation of the computer coding sheets and
computer structure. An inventory of this sort typically requires 500 or more
hours.
Document Inventory - Bibliographic and Key Wording
In many cases, a document inventory is made more complex by the additional
requirement to derive key words to describe document content. The key word
coding task requires the application of more subjective reasoning. It also
requires substantial interaction between EPA and contractor personnel in the
design of the system and determination of key words. A project of this sort can
require between 500 and 1,500 hours.
Record Analysis
Finally, in the most comprehensive cases, substantive information is
extracted from single documents or batches of documents onto work-sheets and
subsequently entered into a computer data base. This type of record analysis is
called for in the case of a transactional data base for potentially responsible
party searches or the creation of a payments and costs data base for cost
recovery actions. Development of a payments data base entails the detailed
piecing together of invoices and payment records related to specific clean-up
work done at a hazardous waste site in order to establish a complete accounting
of costs. This type of effort also requires extensive interaction between
contractor and EPA personnel to assure that proper assumptions are being used and
that the data base will be flexible enough to address all of EPA’s objectives.
Tasks required for records analysis typically take between 400 and 1,500 hours.
20 - HEALTH/ENDANGERMENT ASSESSMENTS
Health/endangerment assessments are usually conducted to support a finding
of possible imminent and substantial endangerment to human health, welfare, or
the environment from a particular site or facility. All future assessments will
be included as a part of the enforcement Remedial Investigation/Feasibility Study
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(RI/FS) and need not be budgeted separately. However, separate endangerment
assessments are needed for all old cases initiated before this policy became
effective.
Under the new RCRA regulations, potential TSD permittees must provide
to EPA a statement of “potential release” or “exposure assessment”, the review of
which the Agency may assign to the TES contractors. An exposure assessment may
also be initiated by the Agency through TES to support its authority to take
enforcement actions under RCRA.
In general, health/endangerment assessments take 300 to over 1000 hours
for completion. The actual amount of time required to complete this task
depends on location of the site, availability of data, adequacy of data (data are
considered inadequate if they are old, such as, the site ecology has since
changed, or incomplete), and complexity of the problem. Tasks which require
further sampling data and development of a sampling plan will require 100 to 150
extra hours for completion, as well as a longer period of performance (to analyze
the results of additional sampling). The task becomes more complex if many
chemicals and/or many pathways are involved. The nature of the chemicals
involved can also add complicating factors. If definition of pathways requires
computer modeling, an additional 150 to 300 hours should be allotted, as well as
additional funding to cover computer costs.
Costs may be increased if computerized literature searches are required
to obtain toxicological or other relevant information. Furthermore, endangerment
assessments may be more expensive on an hourly basis than other tasks because
senior staff time will be needed for approximately half of the project hours.
Focused endangerment assessments are sometimes requested. If the focus
of the assessment is defined and agreed upon in advance and the assessment
is a simple one involving only a few chemicals and pathways, fewer hours (approx-
imately 200) are usually needed for completion. Typically, the following
subtasks are involved to complete a health/endangerment assessment.
Gather Background Information
This step is initiated through an organizational meeting between the
contractor and officials involved with the case. It may include searching
background records and conducting a site visit. A site visit is extremely
important if the site is involved in a case being litigated, because a consul-
tant’s professional opinion is much more credible if he/she has been to the
site. Gathering background information generally requires 10 percent or less of
the total project time.
Assess Site Conditions. Chemicals Present, and Toxicity
In these subtasks an environmental scientist, a hydrogeologists, a chemist,
and a toxicologist define present site conditions, the physical and chemical
properties of the contaminants involved, and the health effects of these contami-
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nants, respectively. Fate and transport of contaminants is also investigated.
Typically, 25 percent of the hours are required to complete these subtasks
Exoosure Assessment
This subtask requires approximately 15 percent of the total task hours
and identifies populations that could be at risk through evaluation of topo-
graphic, geologic, hydrogeologic, chemical, and other data specific to the site.
Risk Assessment
Actual or potential risks to human health, the environment, and human
welfare are identified and evaluated. This subtask generally requires 25
percent of the total hours for completion.
Preparation of Rei orts and Senior Scientist Review
Approximately 25 percent of the total task hours are required for report
preparation and for review by senior scientists/engineers to evaluate the
report’s accuracy and completeness.
30 - HYDROGEOLOGIC/GEOLOGIC STUDIES
(See discussion in Other Special Studies section below.)
40 - OTHER SPECIAL STUDIES
In the course of negotiation/litigation, additional environmental data
are often required to supplement the remedial investigation (this is especially
true for older sites which never had a formal RI). These studies include
hydrogeologic, geologic or hydrologic studies, soil or sediment studies, air
transport studies, or engineering tests. The TES contractor can be called on to
augment the activities of REM/FIT, the U.S. Geological Survey (USGS), the Army
Corps of Engineers (COE), and others in conducting these studies.
Special studies are undertaken to assist in the assessment of possible
risk as applicable under both RCRA and CERCLA by determining the amount and
composition of contamination and the rate and direction of contaminant migration
from the source. As CERCLA and RCRA enforcement evidence-gathering tools, such
studies can also be used to identify sources of contaminants, thus establishing
the responsibility of contributing parties. These studies often require sampling
to identify and quantify contaminants present at the site. Costs for special
studies have ranged from $5,000 to $200,000, depending on whether samples are to
be taken and the analytical requirements for these samples.
Special studies involving hydrogeologic and or geologic data fall under
Task No. 30. Other special studies (Task No. 40) are field, laboratory, or
other studies and activities not included under Task No. 30 or remedial investi-
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gations The following four technical subtasks are generally required for each
special study:
Establishment of Present Conditions
Included in this subtask is a review of all previous studies, existing
information on the site, and applicable regulations. Site visits and inter-
views are often conducted. The time and cost required to complete this subtask
will depend on the amount of data and the travel requirements. In general, about
30 percent of the total hours (exclusive of sampling time) or 60 to 300 hours,
are required for completion.
Identification of Data Gaps
This subtask identifies data that are unavailable but required to accomplish
the objectives of the special study (usually identifying contaminants and their
fate and transport, and possibly the risks associated with them). The identifi-
cation subtask usually requires about 10 percent of the hours (20 to 100 hours)
and the same proportion of the total expenditures. Actual time required will
vary with the volume of information to be gathered. Again, this percentage is
based on cost and time estimates exclusive of those related to sampling.
Samnling to Obtain Required Data and Subsequent Analysis
Sampling and analytical costs and levels of effort will be site specific.
They will depend primarily on the data gaps that have been identified, the number
and types of samples required to fill these gaps, and the analytical work
necessary to derive useful information from the samples. Because of variations
in these factors, cost estimates must be developed on a site-by-site basis.
Further, since the sampling costs depend on data needs identified during a
special study, it may be difficult to estimate such costs beforehand.
To arrive at a reasonable estimate of sampling and analytical costs for
a special study, it is necessary to: (1) determine the information needs (includ-
ing the required level of sophistication of data; (2) determine the time and
number of people required to collect and analyze the information; (3) determine
the number of sources to be sampled at each site, and, (4) account for such
variables as scheduling conflicts, computer and site access problems, time
required to prepare for sampling, and travel and equipment cost and time
Sampling and analytical costs can add considerably to the cost of a special
study. They must be added to the cost estimates given here for the other three
subtasks (refer to Task No 50, Sample Analysis, on page A-l6).
45 - FEASIBILITY STUDIES
Feasibility studies are designed to analyze and select remedial actions
based on comparisons of cost and effectiveness. The amount of time to complete a
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typical feasibility study generally ranges from 2,000 to 3,000 hours and depends
on the complexity of the problem. Among the factors to be considered are the
number of sites involved, the number of previous owners, current conditions at
the site (such as, degree of contamination, site ecology, site use), amount of
data available, status of the site investigation (integration of new information
can be time consuming and can increase the number of hours), the chemicals
involved (many standard priority pollutants, metals and volatile organic carbons
already have established technology for clean-up; poly-aromatic hydrocarbons,
polychiorinated biphenyls, dioxins, phenols, and suspected or confirmed carcino-
gens have less developed technologies and generate greater public attention), the
medium that is contaminated (soil problems are easiest to resolve, while air
and river/ocean sediment problems are the most difficult, with ground-water
problems having an intermediate level of difficulty), types of remedial actions
appropriate (soil removals are less complex and are easier to evaluate, while
more complex treatments, for example, mobile incineration and biological treat-
ment, take more time to evaluate), number of remedial actions being considered,
and the extent of the community relations program.
Cost and time requirements can also be increased by nontechnical aspects of
the problem. Precedent setting cases, policy changes, and tight schedules, can
all increase the cost and time required to complete a project. Furthermore,
feasibility studies can be more expensive than other tasks of comparable level of
effort because all subtasks except the initial site description and initial
description of proposed responses require the efforts of experienced engineers
for completion.
The review of RCRA Corrective Action Plans also falls within the scope
of this task area under TES. Both the relative effectiveness and cost of the
alternatives identified in these plans may be reviewed and critiqued by the TES
contractors. This type of assignment is quite similar to the review of a respon-
sible party’s feasibility study under CERCLA.
46 - FOCUSED FEASIBILITY STUDIES
When a quick response is required and a site description is available,
focused feasibility studies are conducted. These average approximately 1,000
hours, with a range of 800 to 1,500 hours required. The main thrust of a focused
feasibility study is the evaluation of previously selected alternatives. Once
again, the complexity of the problem dictates the number of hours required to
complete this task.
Feasibility studies typically involve the following subtasks:
Project Scoping
This subtask includes a description of the contaminants on site, routes
of exposure, and receptors. When completed as part of a feasibility study,
it requires approximately 20 percent of the total hours allotted This subtask
is equivalent to an endangerment assessment (Task No. 20) and may be considered
separately from the feasibility study. A considerable amount of background
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information is typically collected and reviewed during performance of this
subtask.
Description of Proposed Responses
All remedial measures that are technologically applicable are presented
in the report generated from this subtask. Typically, this subtask requires
5 to 10 percent of the total hours.
Identification of Alternatives
Alternative remedial actions are developed based on the results of the
endangerment assessment and EPA policy. These may include source control,
offsite remedies, and combinations of both alternatives. The no-action alterna-
tive and all other alternatives will be developed in accordance with all EPA
administrative laws. This subtask typically takes 5 percent of the total task
hours
Initial Screening of Alternatives/Technologies
Alternatives are screened on the basis of the following factors: environ-
mental effects, public health effects and cost.Typically, this subtask requires 5
to 10 percent of the total hours.
Identification of Laboratory Studies
Laboratory studies needed to determine treatability of contaminated media
and effectiveness of remedial technologies are identified This subtask may
include the collection of additional data on the physical characteristics of the
site. Approximately 5 percent of the total number of hours for the task are
required to perform this subtask.
Detailed Analysis of the Alternatives
Alternatives that survive the initial screening process are evaluated in
detail for technical feasibility, cost, protection of public health and the
environment, compliance with institutional requirements, and so on. This subtask
typically requires 25 percent of the total hours.
Preparation of a Draft Final Report
The draft final report describes the feasibility study, presents the results
of all previous subtasks, and contains a detailed summary suitable for public
presentation. Typically, this requires 5 to 10 percent of the hours.
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ConceDtual Design
A conceptual design is prepared for the remedial alternative selected by
EPA, the state, and the public. The presentation should include an engineering
approach, an implementation schedule and requirements, a safety plan, costs, and
so on. Typically, this takes 10 percent of the total hours.
Preparation of the Final Renort
The final report should address any comments made by the Agency Approxi-
mately 5 to 10 percent of the total hours are required for completion of this
task
Additional Requirements
Often, additional requirements include participation in meetings and an
ongoing public relations program. Depending on the nature of the problem and
public response, additional requirements can take approximately 10 percent or
more of the task hours.
50 - SAMPLE ANALYSIS
During the conduct of tasks, it may become necessary to obtain, through
chemical and physical analyses, data which can be used to establish endangerment
potential, source responsibility,treatability, transport and fate of contami-
nants. The TES contractor can be called on to conduct these analyses or to
identify and arrange for a suitable subcontractor to perform the assignment.
QA/QC and strict chain-of-custody procedures must be followed to insure the
acceptability of the data. Specific cost and level of effort estimates must
be developed on a case-by-case basis; the TES contractor can assist the initiator
in this aspect of work assignment preparation. Note that the Contract Laboratory
Program (CLP) Contracts are the preferred source for analytical support. TES can
provide back-up support. RCRA assignments (for example ground-water monitoring
program evaluations) can be directly undertaken by the TES team laboratories.
55 - BIOLOGICAL TESTING
Biological testing is employed to support endangerment assessments. Types
of tests include acute and chronic bioassays, mutagenic screening tests, and soil
respiration tests. Also, testing may be conducted to determine if a specific
waste is treatable by biological degradation. The TES contractor will arrange
these services should the need arise.
60 - TECHNICAL REVIEW OF DOCUMENTS
This work area can cover a variety of assignments but usually focuses on a
review of those documents associated with remedial actions. For example, as a
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result of EPA enforcement actions, plans for cleanup of a designated RCRA
facility (or closure/post-closure plan, ground-water assessment plan, Part B
submittal, and so on) or CERCLA Site may be prepared by a Defendant or Respon-
dent. To ensure that these plans will adequately meet technical and economic
objectives, the project team may be called upon to assist in their review.
The primary criterion used in evaluating plans is compliance with the
National Contingency Plan (NCP) and the terms of governing documents, including
agreements by negotiation, consent decrees, administrative orders or other
proposals agreed upon by the Defendant(s) or Respondent(s). However, the review
must also consider aspects of the remedial plans which may not be detailed in
such documents but which are important to the overall effectiveness and cost of
the proposed remedy.
Price packages submitted by Defendant(s) or Respondent(s) will be reviewed
to evaluate the completeness and accuracy of the estimates. Attention will be
given to identifying gaps in the estimate that may have a substantial impact on
cost, so that appropriate contingencies may be applied or steps taken to correct
the deficiencies. In addition to review of costs, plans for remedial measures
proposed by another party will be reviewed for technical feasibility. Each
proposed remedial action will be evaluated with respect to its capability to
achieve the desired remedial objective, ease of implementation, as well as its
reliability, safety, operating complexity, and maintainability.
The review of documents requires technical expertise, as well as familiarity
with the NCP. Here again, the necessity of using senior staff may increase cost
on a per-hour basis. In general, it takes 100 to 200 hours to review each
document or study area. Actual time required will depend on the complexity of
the site, including such factors as the chemicals present and the type and number
of problems on-site (for example, air, ground water, soil). The primary subtasks
are as follows:
Evaluation of the Existing Data Base
Evaluation of the existing data base requires approximately 30 percent
of the total hours necessary to complete a technical review of documents task.
Evaluation of the Reoort Conclusions
Conclusions regarding the quality of the data and the process of data
acquisition are made by reviewing the report. The objectives of this review
and the subsequent conclusions are to determine conformance with the requirements
of the NCP and what additional data are required. The greatest proportion
(approximately 50 percent) of the task hours are spent on this subtask
Identification of Problems and Recommendations for Rectification
Identification of problems and development of recommendations for rectifying
them require approximately 20 percent of the total hours
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65 - EXPERT WITNESS/CONSULTANT
For an expert witness/consultant task, the contractor identifies suitable
experts, provides EPA with the information necessary to choose an expert, retains
the services of the expert chosen (if not already in-house), provides support for
and monitors performance of the expert, and prepares any necessary confiden-
tiality certification. OWPE keeps a file of experts which can be accessed by
litigation teams through a request to OWPE’s Regional Coordinators. If an expert
cannot be found through OWPE, a task can be initiated with the TES contractor to
identify potential candidates. Once an appropriate expert has been selected, the
expert will be hired and managed under the TES contract as described above.
Identification of suitable candidates and retention of the expert selected
can be expected to take 20 to 50 hours, while management and support activities
can be expected to take 10 percent of the task hours. Expert witness fees
typically range from $50 to $75 per hour for non-trial work to $100 to $150 per
hour for testimony. (Only the TES contractors can negotiate fees with prospec-
tive expert witnesses or consultants) Travel and equipment fees, if necessary,
should also be included. In general, expert witnesses and consultants are called
on to do one or more of the following subtasks.
Document Review
An expert consultant may evaluate a small number of documents to determine
their suitability as a sampling or analysis plan to be used to assess a defen-
dant’s plan of action. Such reviews are usually very limited in scope and are
site-specific They typically take 100 hours to complete. The cost per hour can
range from $50 to $150, depending on the fee the expert requires.
Support Throughout Litigation
For this subtask, an expert may perform background research, prepare
affidavits, serve as an expert witness during the trial, and consult with
EPA and/or DOJ before, during, and after the trial. Usually the person selected
is a background expert (a person whose expertise is in a certain discipline, for
example, toxicologist, hydrologist, and so on), rather than a person knowledge-
able about the particular site involved. These subtasks generally require 150 to
200 hours, but the level of effort may vary depending on the duration of the
trial.
Research to Gather Site-Specific Data
A sampling and analysis effort or an extensive data evaluation of previous
studies may be needed. These subtasks can also involve preparing affidavits and
court testimony. In general, these are the most complex tasks and may take 200
or more hours of the expert’s time as they require application of technical
expertise to the conditions on-site.
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For all of the above a lower graded professional level contract staff
member can work in coordination with the expert, thereby reducing costs and
minimizing the number of hours needed for high-level work.
70 - INTERROGATORY PREPARATION
Contractors are sometimes required to review information, interview staff,
and to assist EPA in preparing questions or responses to interrogatories. In
general, the subtasks invo1ved in preparing responses are as follows:
Document Review
A document review is comprised of the following subtasks:
o Categorize documents according of their applicability to the interro-
gatories;
o Answer interrogatories, which sometimes involves interviewing EPA
staff and others who have worked on the case; and
o Index and attach relevant documents to the interrogatory replies.
Compile Resoonses into Final Form
While typical interrogatory responses take 80 to 160 hours depending on
the complexity of the questions, the actual time required will depend on a
number of factors, among them the number of interrogatories received, the
extent of the case files, the number of defendants involved, the number of
agency employees and divisions involved, the organization of the files, the
availability of program staff to assist the contractor, the complexity of
the litigation, and the complexity of the responses required. Time can be
saved if files are well organized (including index sheets containing a summary of
contents and author’s names), a list of all documents relevant to the case is
available, and memoranda are prepared documenting all decision making and
significant in-house conversations, meetings, and events.
75 - EVIDENCE STORAGE/PRESERVATION
The storage and preservation of evidence is normally done by Environ-
mental Services Division (ESD) or National Enforcement Investigations Center
(NEIC). TES contractors should be used only when the above organizations
are unable to perform the task. When the task is being funded under TES,
the contractor maintains the direct physical evidence, either in the form of
samples or documents, under chain-of-custody and proper security. This assures
that the evidence is not destroyed or compromised. The subtasks involved can
include the following:
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o Review of sample documentation;
o Interim securing and storage of samples/documents;
o Sample/document inventory;
o Assessment of techniques for linking samples with generators or
organization of documents by generator; and
o Final sample/document storage
If documents are involved, the amount of time required to complete the
task will depend on the location, number and organization of the documents
If samples are involved, the time required to complete the task will
depend on the number of samples, the amount of handling, inventory require-
ments (dependent on site set-up and sample condition), and the amount of travel
required. Because of extremely limited TES experience with this task, it is not
possible to estimate a typical level of effort.
80 - COMPLIANCE MONITORING
Section 3007 of RCRA authorizes EPA to perform compliance inspections
of facilities that generate, store, treat, transport, dispose or otherwise
handle, or have handled hazardous wastes. In using this Contract, EPA may
authorize the TES Team to serve as its representative to perform these inspec-
tions on behalf of the Agency. The authorized representative is empowered to
enter facilities at reasonable times, make inspections, take samples and copy any
records relating to the handling of wastes. The purpose of these inspections is
to help the Agency assure compliance with permit conditions under RCRA. The
activities to be included in a RCRA inspection are specified by EPA and may
include record reviews and surveillance and analysis.
For example, the TES 2 team has been tasked to conduct many compliance
audits at major commercial landfills and industrial facilities. The primary
objective of these audits is to evaluate compliance with the ground-water
monitoring requirements set forth in 40 CFR Part 265, Subpart F. A typical
audit includes at minimum the following items.
1. Preliminary records collection and review to determine.
a. site history and operations, including location, facility descrip-
tion and hazardous waste materials handled,
b. hazardous waste disposal practices, past and current,
c. site hydrogeology and surface hydrology
d. well monitoring data, monitoring plan and monitoring system
quality and completeness, including well installation procedures
• and materials.
[ A-20J
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2. On-site inspection of ground-water monitoring system.
a. well locations,
b. well condition and security.
3. Evaluation of Facility’s Sampling Capabilities
a. equipment used,
b. procedures used,
c. field Quality Assurance and chain of custody.
4 Split sampling with facility (optional) analysis by TES team.
5. TES team sampling and analysis (optional).
The typical level of effort required for this type of audit is approxi-
mately 200 to 300 technical labor hours per audit. Split sampling with the
facility and analysis by the TES team, or both sampling and analysis by the TES
team, will substantially increase this estimated level of effort (and associated
costs ) proportionately with the number of samples to be collected and the number
and types of pollutants of concern. Travel costs can be substantial for this
type of audit, but can be minimized by scheduling records collection and review
tasks immediately prior to the field audit at the facility, and by requesting (or
requiring) that the owner/operator perform his or her monitoring during a period
coincidental to that of other audit candidates in the same geographic area. With
sufficient lead time and planning, considerable cost savings can be realized.
The TES team has also been conducting Preliminary Assessments and Site Investiga-
tions, (PAs and SIs) in accordance with the corrective action provisions in
Sections 3004(u), 3004(v), and 3008(h) of the RCRA Hazardous and Solid Waste
Amendments of 1984. The purpose of these PAs is to:
1) Identify which units/areas/facilities do not require a site inspection
2) Identify units/releases that require either a preliminary site investi-
gation or a remedial investigation
3) Identify units/releases that require immediate removal action under
CERCLA
The purpose of the SIs is to:
1) Determine if solid waste management units or hazardous waste management
units have, or have potential to, release hazardous substances into
the environment
2) Determine the need for and extent of any immediate corrective action at
the facility
[ A-21]
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3) Determine the scope of any required remedial investigation for the
facility
4) Verify information obtained from the PA in support of any recommenda-
tions resulting from the investigation
The typical level of effort for PAs is approximately 30 to 60 technical labor
hours. The approximate technical labor hours requirement for SIs is 175 to 250
hours, exclusive of analysis costs, which will increase with the number of
samples to be analyzed and types of analyses required
Compliance monitoring and Responsible Party oversight support services under
CERCLA can also be provided by the TES contractors. Subtasks in this area
typically include:
1) RI/FS work plan review
2) QAPP review
3) Oversight work plan preparation
4) RI report review
5) FS report review
6) Endangerment Assessment (data quality review)
7) RI field oversight (split sampling, verification of plan implemen-
tation, etc.
8) RD/RA field oversight
The requirement in technical labor hours to carry out the above Responsible
Party oversight tasks can vary quite widely, depending on such factors as the
duration of the project, its complexity, and the cooperativeness of the Respon-
sible Party(ies). See Table 1 on page A-2 to determine which task most closely
fits the subtasks to carried out during the oversight project and use the
corresponding cost ranges as a guide in preparing your work assignment.
85 - EVIDENCE AUDITS
Evidence audits are designed to assess the suitability in legal proceedings
of evidence obtained by enforcement personnel and their representatives. (This
type of Work Assignment will not normally be done under TES but under separate
contract to NEIC for TechLaw’s services.)
EPA has developed evidence audit procedures that provide project and
program managers with assurance that the evidence developed in specific cases
will withstand the procedural rigors of the courtroom; alternatively, the audit
will detect lapses in the security and/or integrity of evidence prior to its
[ A-22]
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introduction. These evidence audit procedures are adapted for use by contractor
evidence audit teams in the document “Procedures Manual for Evidence Audit and
Support of EPA Enforcement Cases by Contractor Evidence Audit Teams.”
Personnel from TechLaw were instrumental in the development and use of
EPA’s Contractor Evidence Audit Team (CEAT). These teams were created to
monitor hazardous waste site investigations to ensure compliance with EPA
policies and procedures regarding handling and documentation of evidence obtained
and/or generated by contracted field and laboratory personnel. The CEAT is fre-
quently assigned to assist EPA Regional enforcement attorneys in hazardous waste
site case preparation.
The typical evidence audit includes collection of raw data pertaining
to investigator activities, analysis of that data to determine the investi-
gator’s adherence to prescribed procedures, and preparation of a summary report.
Evidence audits are expected to require 100 to 400 hours to complete.
90 - COST RECOVERY DOCUMENTATION
The TES contractors can, in some instances, assist in cost recovery actions
by compiling and documenting relevant contractor cost information for enforcement
action Because of confidential Business Information and other restrictions, TES
contractor assistance to EPA may be limited.
99 - OTHER
Certain activities under this contract do not fall under any of the headings
listed above. One example is activities that can best be described as program
management; such as, they do not pertain directly to an individual waste site or
type of task Rather, they are administrative functions required to ensure the
smooth operation of the Project Team and satisfactory performance of the project
as a whole. They include documentation of Project Team expenditures for each
waste site investigated so that EPA may attempt cost recovery at a later stage of
the site investigation. Work assignments of this type are issued primarily by
the OWPE staff rather than the EPA Regional Offices.
[ A-23]
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APPENDIX B
EXAMPLE
WORK ASSIGNMENT STATEMENTS OF WORK
-------
EXAMPLE 1:
Technical Review of Documents
Background
From 1941 until 1964, Jones, Inc. a subsidiary of the Johnson Pump Company,
operated a naval ordinance manufacturing facility at Smith, Minnesota. Beginning
in the mid-1940’s, a tract of land south of the facility (the “XYZ Site”) was
used by Jones for burning and disposal of general shop wastes including indus-
trial liquids. In 1964, XYZ acquired the Jones operation and the disposal site
from Johnson Pump. Disposal continued in the XYZ site until 1969, at which time
XYZ closed the site. A portion of the site is now owned by Burlington Northern
Railroad.
In June 1983, the U.S. EPA, the Minnesota Pollution Control Agency and
XYZ entered into an Administrative Order and Interim Response Order by Consent
(Consent Order) whereby XYZ agreed to accomplish the following:
a) Excavate approximately 70,000 cubic yards of contaminated soil and
place in a secure on-site containment facility; and
b) Prepare a remedial investigation and feasibility study to address
remaining ground-water contamination problems.
Work To Be Performed
1. The Contractor should review the following background documents:
a. Evaluation of Past Disposal Practices, Phase I Initial Assessment,
XYZ Corporation, Smith, Minnesota, April 10, 1981, Eugene A. Hickok and
Associates (approx. 40 pgs.);
b. Evaluation of Past Disposal Practices, Phase II - Hydrogeological
Investigation, XYZ Corporation, Smith, Minnesota, December 31, 1981,
Eugene A. Hickok and Associates (approx. 100 pgs.);
c. Comments of XYZ Corporation on EPA’s Proposed National Priorities
List and the listing of XYZ’s Smith Facility, Preliminary Evaluation:
Potential Impacts of Trichioroethylene and Lead at XYZ Site, Arthur D.
Little, Inc., February 1983 (approx. 25 pgs.);
d. Site Investigation Program, BNR Study Area, Jones Plant Smith,
Minnesota, March 1983, Conestoga - Rovers & Associates Limited (approx.
50 pgs,.);
e. Summary Report on Ground-Water Conditions, XYZ Jones Division Plant,
April 1983, S. S. Papadopulos & Associates, Inc. (approx. 50 pgs);
f. Supplemental Site Investigation Program, South Study Area, Jones
Plant, June 1983, Conestoga - Rovers & Associates Limited (approx.
100 pgs.);
g. Report on Phase I Investigation Program, XYZ Jones Division Plant,
[ B - 1]
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November 1983, S. S. Papadopulos & Associates, Inc. (approx. 60
pgs.);
h. Definition of Clay Till Contains, BNR Study Area, Jones Plant, August
1984, Conestoga-Rovers & Associates Limited (approx. 40 pgs.);
i. Final Report, Design and Construction, Excavation and Securement
of Contaminated Soils, South and BNR Study Areas, Volume 1, August
1984, Conestoga-Rovers & Associates Limited (approx. 120 pgs.);
j. Final Report, Phase I & II Investigative Programs, Jones Division,
August 1984, S. S. Papadopulos & Associates, Inc. (approx. 250 pgs.);
and
k. Summary of Analytical Data for XYZ Jones Plant, July 1983,
Conestoga-Rovers & Associates Limited (approx. 550 pgs.).
2. The Contractor shall duplicate these reports as necessary and return the
originals to U.S. EPA.
3. The Feasibility Study is expected to be submitted by XYZ to U.S. EPA on or
about December 12, 1984. This report shall be reviewed by the Contractor
immediately upon receipt from U.S. EPA.
4. The contractor’s reviewer should have capabilities and experience such that
the reviewer can attend negotiating sessions with XYZ in an expert capacity.
5. The Contractor shall submit a letter report to U.S. EPA providing comments
on the Feasibility Study taking into consideration the other background
documents which have been reviewed. The review of the Feasibility Study
shall be to evaluate the plan’s compliance with the National Contingency
Plan. Specifically, the review should address 1) whether the recommended
alternative has any adverse environmental effects; 2) whether the alterna-
tive is likely to achieve adequate control of source material and effec-
tively mitigate and minimize the threat of harm to public health, welfare or
the environment; and 3) whether the alternative is feasible for the location
and conditions of the release, is applicable to the problem and represents a
technically reliable means of addressing the problem.
6. The Contractor shall attend one meeting in Chicago and two meetings in
Minneapolis to advise and assist U.S. EPA in negotiations with XYZ.
Comoletion Date
This project is expected to be completed by February 15, 1985.
Deliverables and Due Date
Within 2 weeks of receipt, the Contractor shall duplicate the background
documents received and return the originals to U.S. EPA.
2. A letter report commenting on the Feasibility Study should be submitted to
U.S. EPA within 7 work days of receipt of the Feasibility Study, expected to
be about December 12, 1984.
[ B - 2]
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EXAMPLE 2:
Records Compilation
Background
_______ operations began at the Sacramento, California Facility in the early
1950’s, and _______ operated manufacturing facilities within the _______ complex
from 1973-1979. The Facility occupies approximately 22,000 acres and is located
about 15 miles east of Sacramento and south of the American river near Nimbus Dan
and State Fish Hatchery. Within the area of the Facility is about 8,500 acres of
land, referred to as “The Site”, bordered on the west by Sunrise Boulevard, south
by White Rock Road, east by Prairie City Road, and north by Folsom Boulevard.
Contiguous to the 8,500-acre site is an additional 13,500 acres owned, leased, or
used in the past or present by _______
_______ manufactures liquid- and solid-propellant rocket engines and formu-
lates rocket propellant agents, pharmaceuticals, agricultural and industrial
chemicals and conducts chemical research. Since 1953, _______ and _______ Chemical
have disposed of unknown quantities of hazardous wastes on-site, including rocket
propellants, herbicides, arsenicals, solvents, sewage wastes, and other organic
and inorganic chemicals. Disposal has occurred through controlled burning,
surface impoundments, landfills, deep injection wells, and direct discharge to
the ground through surface disposal and floor and sink drains to leach fields.
Wastes were also disposed of in open areas on nearby off-site locations.
Sampling conducted since 1979 has shown contamination of soil, surface water, and
ground water on and off _______ property. Analyses were conducted primarily to
identify volatile organic compounds; trichloroethylene was measured as the most
prevalent chemical in ground water.
Some chemicals have been found only under the _______ property, while others
have migrated into nearby wells and into the American River. Trichloroethylene,
perchloroethylene, and dichioroethane have been found On-site in ground water at
concentrations of 580,000 ppb, 40,000 ppb, and 39,000 ppb respectively. Off-site
contamination of ground water includes chloroform at 1400 ppb, freon 113 at 8,000
ppb, and trichloroethylene at 2,500 ppb. A limited sampling program found
dimethylnitrosamine and several halogenated organic chemicals in off-site
wells, some a mile from the _______ boundaries. Sampling has also suggested
that plumes of contaminants are moving into the American River toward water
supply wells. Property owners have private wells in the _______ vicinity, and
residents of communities in Rancho Cordova, Fair Oaks, Carmichael, and Sacramento
use the American River and/or threatened wells for municipal water supply. The
American River is also used for recreation.
Beginning in 1979, a number of administrative actions were initiated by
the Central Valley Region 1 Water Control Board against _______ and _______ and in
1979 the State of California filed suit against _______ and _______ following detec-
tion of ground water contamination under and around the facility. In addition,
during 1981 a number of private-party lawsuits were filed against _______ because
of contamination of private drinking water supplies. EPA has requested informa-
tion on _______ activities pursuant to RCRA (Resource Conservation and Recovery
Act) and CERCLA (Superfpnd). _______ has analyzed samples of soil and water.
These data, which now cop prise some twenty volumes, must be compiled and
presented in an organized, summary form.
[ B - 3]
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Objectives
To compile existing data and present it in an organized, summary form.
Data are located at EPA headquarters in Washington, D.C. and must be reviewed in
headquarters, unless contractor can provide extensive xeroxing of over 20 volumes
of confidential material.
Material Being Transmitted
Extensive data are available in volumes located at EPA in Washington,
D.C. These are available from technical contacts for use at EPA.
Confidentially
Data are being prepared in anticipation of litigation and should be consi-
dered confidential.
SDecific Requirements
Data must be summarized in clear, organized, concise manner.
Schedule
Data reports are due by completion date.
Deliverables
Two copies of data report are due by completion date, one to project
officer and one to technical contact at EPA in Washington, D.C.
[ B - 4]
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EXAMPLE 3:
Feasibility Study
Background
In October of 1979, the EPA began an investigation of the water supply
contamination by trichloroethylene (TCE) in the Township of _______. Sample
analyses of public drinking water wells in the area revealed TCE concentrations
ranging from 0 to 500 ppb. As a result of hydrogeologic and sampling studies,
potential sources of TCE were found. On October 8, 1980, EPA filed suit against
one of the alleged sources, the _______ Company, seeking relief from the alleged
ground-water contamination.
As a result of further investigation, the ________ site ( ) was identi-
fied as an additional source of TCE contamination. EPA and DOJ representatives
attempted to negotiate a sampling program and cleanup proposal with _______ and
its parent company, _______. Negotiations have not resulted in Site clean-up.
EPA’s belief that _______ is the source of contamination was based on the
results of sampling analyses and the hydrogeology of the area. Analyses of
samples from _______ wells showed TCE concentrations in excess of 30,000 ppb. In
addition, soil analyses performed by a consulting firm, hired by _______, demon-
strated TCE contamination of the soil at the Site.
The _______ case was referred to DOJ in March of 1983. The case was tempo-
rarily held at DOJ pending the outcome of the _______ case. Negotiations with
_______ resulted in a settlement but took almost 2 years to achieve a Consent
Decree. Once the _______ case settlement, DOJ now wishes to file the _______ case.
EPA policy requires a RI/FS with a suggested remedy prior to filing a case. In
addition, new well data just released indicate TCE concentrations of 1,000 to
4,000 ppb immediately adjacent to the _______ site.
ScoDe of Work
The EPA requests the assigned contractor to perform a “focused” Feasibility
Study (FS) for the _______ case. The objectives for the FS will be established by
the U.S. EPA’s Office of Waste Programs Enforcement and the Region 3 enforcement
Office. This effort should be performed by a multi-disciplinary team of engin-
eers and scientists.
The work assignment will be finalized during the first meeting between
the contractor and the EP in the Philadelphia Office but will encompass some of
the following items:
1. Meet with EPA rep1c entatives at the Philadelphia Office to collect and
review all the _______ files and report documents.
2. Determine focused FS objectives and assumptions necessary to complete the
focused study in a limited time schedule.
3. Develop a list and describe all possible remedial alternatives for the
_______ site based o available site information and past site reports.
[ B - 5]
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4. Perform initial screening of the list of remedial alternatives, evaluate
alternatives in accordance with the National Contingency Plan, develop
long-term monitoring plan and estimate costs for each of the possible reme-
dial alternatives.
5. Review technical data to insure that it supports a defensible FS.
6. FS should follow the latest version of the Guidance Document for performing
FS work. This document will be supplied by EPA if the contractor does not
have one.
No endangerment assessment will be necessary since this work is being
performed in-house.
Travel Requirements
The contractor will be required to travel the Region 3 office in
Philadelphia to review and copy the necessary documents. In addition, it
will probably be necessary to travel to Washington, DC to review the work
being performed with the Backup contact (John Segna) and the Technical Support
Branch of
OWPE.
2-trips to Philadelphia
1-trip to Washington, DC
1-potential site visit to Township.
Justification for Expedited Work Assignment
The Department of Justice wishes to file this case within the next several
weeks. Because this case was referred almost two years ago they do not wish to
wait much longer. A RI/FS and a selected remedy for the site are required before
the case can be filed. Wjthput the completion of this work assignment, the case
will be referred back to the region where it may Sit indefinitely since the site
is not on the NPL and is not targeted for 1985 resources. We need to set the
work in motion so that a completion date in January 1985 (the latest) can be
submitted to DOJ by Friday December 14, 1984.
[ B - 6]
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EXAMPLE 4:
Expert Witness
Site Background
o _______ is a secondary lead smelting and lead battery recycling facility
in Leeds, AL.
o _______ began operation in 1967; on 8/20/82 _______filed for Chapter II
bankruptcy, while continuing to operate; on 3/16/84 _______ceased its
battery recycling operation but continued lead smelting.
o _______ has generated or continues to generate the following RCRA hazar-
dous wastes: Waste battery acid, wastewater treatment (WWT) sludge,
blast furnace slag, and baghouse dust; these waste streams are hazar-
dous due to corrosivity and/or EP toxicity (for lead and cadmium).
o Wastes have been “managed” in at least 6 on-site units consisting
of 3 waste piles, 2 surface impoundments, and a landfill (the _______
parking lot); only one waste pile and one surface impoundment (erro-
neously designated as a tank by _______) were identified in _______ Part
A application for interim status; 5 of the 6 on-site units continue to
receive waste.
o Three off-site disposal areas have been identified by _______ as having
received slag and WWT sludge; the sites are
o Lead and cadmium are the hazardous constituents of concern; only
lead has been analyzed for to date; lead levels at the _______parking
lot and the 3 off-site disposal sites range from 100,000 to 150,000
ppm; lead is toxic to animals at .18 ppm and is irritable to plants at
.005 ppm; lead and cadmium bioaccumulate in the food chain.
o The _______ site was certified by CDC to be an immediate human health
threat because of the toxicity of lead and the potential for exposure
to the surrounding population; routes of exposure are direct contact,
consumption, or inhalation of contaminated soil, ground water, or
surface water; _______ was cleaned up by EPA in 4/84.
o The _______ parking lot, City of _______ landfill, and _______ Nightclubs
pose hazards similar to the _______ site.
Contacts
Technical:
Harold Taylor Enforcement/Region 404/881-2641
Ed Hatcher On-sceüe Coordinator 404/881-3931
Larry Weiner Enforcement/Headquarters 202/382-4832
[ B - 7]
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Legal:
Keith Casto Regional Attorney 404/881-2641
Henry Frohsin Assistant U.S. Attorney 205/254-1785
Scott Fulton Department of Justice 202/382-3105
Doug Greenhaus Headquarters Attorney 202/382-3105
Objectives
o Provide expert technical advice in the area of human toxicology,
specifically the toxicology of lead.
Level of Effort
o 80 hours/lO days
o Estimate three, two-day trips--one each to Atlanta, Georgia,
Birmingham, Alabama; and Leeds, Alabama.
Snecific Requirements
o Review all background material and data by the EPA. Perform a careful
in-depth review of all relevant information regarding lead contamina-
tion at the Site, for example, levels of lead, monitoring data, and
relevant exposure information. Provide a scientific evaluation of this
data.
o Conduct site visit for general familiarization with the site and
detailed observation.
o Provide expert technical advice to EPA and the Department of Justice
for case development and support of a preliminary injunction.
o Participate in depositions and write affidavits as necessary.
o Participate in negotiations with responsible parties if necessary.
o Attend pre-trial meetings prior to testifying.
o Testify in court in support of government’s request for a prelimi-
nary injunction.
[ B - 8]
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Deliverables
o Provide written or oral briefings as requested.
o Provide affidavit(s) as requested. Affidavit(s) will probably be
five to ten single spaced typewritten pages. The affidavits will
summarize the health effects of lead and assess the potential for
human endangerment associated with exposure(s) at the site.
Justification for Expedited Work Assignment
An expert is needed as soon as possible because the situation at the
_______ and _______ Night club parking lots poses an immediate human health threat
EPA is seeking a preliminary injunction to mitigate the immediate health threat.
Plans are to file a complaint with the district court before 12/31/84.
[ B - 91
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EXAMPLE 5:
Health/Endangerment Assessment
Background
The _______ Landfill is located approximately 3 miles south of the City of
_______ The site is approximately 50 acres in size and is located in an old
strip mine (see the attached map).
Landfill operations at the site were carried out from 1969 through
mid-1979. During that time, paints, sewage or septage, oily wastes, halogenated
solvents, caustics, phenols, PCB’s, metals, melamine, methanol, acetone and epoxy
resin reportedly were disposed of at the site. Unburied and partially buried
refuse, including drums, can be found around the site. The site is generally
covered with soil. Leachate streams migrate offsite to nearby surface waters.
There is a liquid filled pit, approximately 30 feet in diameter, on the Site that
contains deteriorating drums.
Status (August 1984 )
The U.S. EPA has sampled leachate at the Site in May 1983, February 1984 and
May 1984. The sampling results, to date, reveal the release of DDT, other
pesticides and other contaminants from the site.
Task I - Review of U.S. EPA Files
Review all U.S. EPA files to become familiar with all information avail-
able. The U.S. EPA shall provide all necessary information. This task shall
take approximately 60 hours.
Task 2 - Human Health and Endangerment Assessment
The focus of a Human Health and Endangerment Assessment should be the
surface water pathway. The Assessment shall include the following items:
1. Environmental Fate apd Transport
a. physical-chemj l properties of specified chemicals/substances (for
example, soil/sediment adsorption coefficients, vapor pressures,
solubility, and o on)
b. photo-degrad tjon rates, decomposition rates, hydrolysis rates,
chemical tran fprmations, and so on
c. local topography
d. description of the hydrological setting and flow system
e. soil analyses
f. climatic factors and other factors affecting fate and transport
g. prediction of fate and transport (where necessary using modeling
methods)
[ B - 10]
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2. ToxicoloRical ProDerties (hazard identification )
a. metabolism
b. acute toxicity
c. subchronic toxicity
d. chronic toxicity
e. carcinogenicity
f. mutagenicity
g. teratogenicity/reproductive effects
h. other health effects as relevant including neurotoxicity,
immuno-depressant activity, allergic reactions, and so on
i. epidemiological evidence (chemical-specific or site-specific)
j. aquatic/non-human terrestrial species toxicity/environmental quality
impairment
3. Exi osure Assessment
a. demographic profile of population at risk including sub-populations at
special risk
b. background chemical exposures
c. life style and occupation histories
d. population macro- and micro-environments
e. exposure routes
f. magnitude, source, and probability of exposure to specified substances
4. Risk Assessment ang JmDact Evaluation
a. carcinogenic risk assessment
b. probability of non-carcinogenic human health effects
c. non-human species risk assessment
d. environmental impacts/ecosystem alterations
5. Conclusions
6. Documentation (Aoi epdices)
Level of Effort
[ B - 11]
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This task is estimated to take no more than 300 hours.
Due Date
The draft final report is due 40 calendar days after all analytic data
has been received.
Travel Requirements
Two trips to Chicago to meet with the OSC and attorney.
[ B - 12J
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APPENDIX C
EXAMPLE WORK ASSIGNMENT
ACTION FORMS
-------
EXAMPLE WORK ASSIGNMENT REQUEST
Appropriation No
i I CERCLA682OX8 145
D RCRA 684/50108
U OTHER
DCN
ENVIRONMENTAL PROTECTION AGENCY
TechnIcal Support for Enforcement
at Hazardous Waste Sites
0 TES1 0 TES2
Contractor
Work AssignmeniNo
No of Pages to Follow
Original Work Assignment 0 Work Plan Approval
0 Amendment No — A revised Work Plan 0 is 0 is not required
The Contractor shall furnish facilities, materials, and the necessary professional, technical and supporting personnel for performance
of the work required by this Work Assignment, described below
TITLE ABC SITE TECH REVIEW OF DOCUM.
SiteName j .,.uL,J. ., . . .,,i ii . i , ,iTaskDesc ..i.....i. TaskType6.,j .t
Priority 1 Normal 0 Expedite Reference Information 0 Attached 12 Transmitted Separately 0 Not Applicable
Site Identifier No TGB81 5 4 B&.
Government Est
Contractor Est
Effort (Technical Labor Hours) Previous
This Action
Total
250
250
Eripert Witness Hours (Not to be included in LOE Hours)
Peiiod of Performance From Effective Date (see below)
— or To Completion 01 Deliverables March 31, 1985
Site Location (City or County) St. Paul
State Region 5
Statement of Work Summary (enforcement ob(ective and regulatory action being supported here, attach statement of work)
The enforcement objective is to support EPA in the review of technical
information submitted by t)-.e responsible party in response to an Administrative
Order. (See attached statement of work - 3 pages)
P.’c rting Requirements 0 Briefing(s) Letter Report 0 Draft Final Report U Other
Submit all deliverables to Region (Note Monthly Reports and Final Reports are required for all work assignments )
P mary Contact (Name, Address, Tel No)
230 South Dearborn, Chicago, 60604
John Doe, Region 5, Remedial Response Branch, 312/886-3000
Backup Contact (Name Address, Tel No) 230 South Dearborn, Chicago, 60604
Mary Smith, Region 5, Office of Regional Counsel 312/886—2000
Initiator (Signature) Date November 25, 1984
ProlectOfficer (Signature) Date November 25, 1984 Tel (202)3824842(FTS)
( Signature ) November 29, 1984
Contracting Officer DATE
(effective date)
( Signature) December 1, 1984
Contractor Acknowledgement of Receipt DATE
lsignature & tiflel
Justification Required
Sheet 1 While—Contracting Officer Copy (Washington 0 C) Sheet 3 Green—Contractor Copy
Sheet 2 BIue—Pro(ect Ofticer Copy (Washington, DC) Sheet 4 Yellow—Acknowledgement Copy
Aer se9 Spienroei 984
c—i
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EXAMPLE WORK PLAN APPROVAL
Appropriation No
1 CERCLA682OX8145
fl RCRA 684150108
D OTHER
DCN T2AO11
ENVIRONMENTAL PROTECTION AGENCY
Technical Support for Enforcement
at Hazardous Waste Sites
0 TES-1 TES•2
Work Plan Approval
Contractor
Work AssignmenlNo
No of Pages to Follow _Q_.
0 Original Work Assignment
Amendment No ,J.,....-.. A revised Work Plan 0 is is not required
The Contractor shall furnish facilities, materials, and the necessary professional, technical and supporting personnel for performance
of the work required by this Work Assignment. described below
TITLE SITE TECH REVIEW OF DOCUM. 60
SiteName , ,ihi ,,,i iiTaskDesc. i.L_ TaskTypeL.i_
1 Not Applicable
Priority [ Normal 0 Expedite Reference InformatiOn 0 Attached 0 Transmitted Separately
Est Contractor Est
Site Identifier No TGB81 5 498 —
Effort (Technical Labor Hours) Previous
This Action
Total
300
250
50 hrs.
50
300
j ricrease
iustified in work
Expert Witness Hours (Not to be included in LOE Hours)
plan)
Period of Performance From Effective Date (see below)
or To Completion of Deliverables
1985
March 31,
State Region 5
Site Location (City or County) st. Paul
Statement of Work Summary (enforcement obtective and regulatory action being supported here, attach statement of work)
__ Work Plan su} nitted on December 15, 1984 is approved as written .
Reporting Requirements 0 Briefing(s) 1 Letter Report 0 Draft Final Report 0 Other
‘ IX Submit au deliverables to Region (Note Monthly Reports and Final Reports are required for all work assignments )
Primary Contact (Name Address. Tel No) Remedial Response Branch
John Doe, Region 5, 230 So. Dearborn, Chicago, IL 60604 312/8863000
Backup Contact (Name, Address, Tel No) Office of Regional Counsel
Mary Smith, Region 5, 230 So. Dearborn, Chicago, IL 60604 3l2/8862000
L tiator CSignature) Date November 26, 1984
Project Officer (Signature) Date November 28, 1984 let (202) 382 4842(FTS)
( Signature Decett’iber 30, 1984
Contracting Officer DATE
(effective data)
( Signature) January 2, 1985
Contractor Acknowledgement of Receipt DATE
(signature & title)
Justification Required
Aev aQ Sepiin’De, iSti
Sheet 1 White—Contracting Officer Copy (Washington, DC) Sheet 3 Green—Contractor Copy
Sheet 2 Blue—Protect Otficer Copy (Washington, 0 C ) Sheet 4 Yellow_Acknowledgement Copy
C— 2
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EXAMPLE WORK ASSIGNMENT AMENDMENT
AporopriatiOn No
L CERCLA6820X8145
o RCRA 684150108
o OTHER
DCN T2AO11
ENVIRONMENTAL PROTECTION AGENCY
Technical Support for Enforcement
at Hazardous Waste Sites
0 TES1 [ TES-2
Contractor PRC
WorkAssignmentNO J.QQ.
No of Pages to Follow
0 Original Work Assignment 0 Work Plan Approval
J Amendment No L_. A revised Work Plan 0 is is not required
The Contractor shall turnish facilities, materials, and he necessary professional, technical and supporting personnel for performance
of the work required by this Work Assignment esctibed below
TITLE ABC SITE TECH REVIEW OF DOCUM.
SiteName i,’. . iTaskDesc
Priority gi Normal 0 Expedile Reference Information 0 Attached 0 Transmitted Separalely E Not Applicable
Site Identifier No TGBB1 . 4’
Government Est
Contractor
Effort (Technical Labor Hours) Previous
This Action
Total
300
100
400
Espert Witness Hours (Not to be included in LOE Hours)
Period of Performance From Effective Date (see below)
or To Completion of Deliverables
March 31. 1985
Site Location (City or County) St. Paul State MN Region 5
Statement of Work Summary (enforcement oblective and regulatory action being supported here, attach statement of work)
New information has been provided by the responsible party which must
be reviewed along with the information already provided to the contractor.
This work assignment must therefore be amended to include the additional review
by the required deadline.
Reporting Requirements 0 Briefing(s) Letter Report 0 Draft Final Report 0 Other
k] Submit all deliverabies to Region fNole Monthly Reøorts and Final Reports are required for all work assignments )
Primary Contact (Name. Address, Tel No) Remedial Response Branch
John Doe, Region 5, 230 So. Dearborn, Chicago, IL 60604 312/886—3000
BackuD Contact (Name, Address, Tel No) Office of Regional Counsel
Mary Smith, Region 5, 230 So. Dearborn, Chicago, IL 60604 312/886-2000
Initiator (Signature) Date January 6. 1985
Prolect Officer (Signature) Date January 8. 1985 Tel (202) 382 4842(FTS)
( Signature) January 10, 1985
Contracting Officer DATE
(effective date)
( Signature) January 12, 1985
Contractor Acknowledgement of Receipt DATE
(signature & title)
Justification Required
Ae ,,110a 5.pien re, 9114
Sheet i White—Contracting Officer Copy (Washington D C) Sheet 3 Green—Contractor Copy
Sheet 2 Blue—Prolect Officer Copy (Washington. DC) Sheet 4 Yellow—Acknowledgement Copy
C—3
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EXAMPLE WORK ASSIGNMENT COMPLETION/CLOSE—OUT
Appropriation No
LI CERCLA 68 20X8145
o RCRA684/50108
o OTHER
DCN T2AO11
ENVIRONMENTAL PROTECTION AGENCY
Technical Support for Enforcement
at Hazardous Waste Sites
0 TES-1 K] TES-2
Contractor PRC
Work Assignment No
No of Pages to Follow
0 Original Work Assignment 0 Work Plan Approval
U Amendment No A revised Work Plan 0 is 0 is not required
The Contractor shall furnish facilities, materials, and the necessary professional, technical and supporting personnel for performance
of the work required by this Work Assignmen described below
TITLE ABC SITE TECH REVIEW OF DOCtJM. 60
SiteName ‘i i. TaskOesc TaskTypei.....i.....4
Priority 1 Normal 0 Expedite Reference Information 0 Attached 0 Transmitted Separately K] Not Applicable
Site Identifier No TGB81 —
Government Est
Contractor Est
Effort (Technical Labor Hours) Previous
This Action
Total
400
a
400
Expert Witness Hours (Not to be included in LDE Hours)
Perod ot Performance From Effective Date (see below)
or To Completion of Deliverables
March 31, 1985
Ste Location (City or County( St. Paul
State MN Region 5
Statement of Work Summary (enforcement ob(sctive and regulatory action being supported here, attach statement of wwk)
—- The letter report has been received, reviewed and approved as written .
This work assignment is complete and considered closed .
Reporting Requirements 0 Briefing(s) L Letter Report 0 Draft Final Report 0 Other
Submit all deliverables to Region (Note Monthly Repo s and Final Reports are required for all work assignments )
Primary Contact (Name Address, Tel No) Remedial Response Branch
230 So. Dearborn, Chicago, IL 60604 312/886—3000
John Doe, Region 5,
Backup Contact (Name, Address, Tel No) Office of Regional Counsel
230 So. Dearborn, Chicago, IL 60604 312/886-2000
Mary Smith, Region 5,
Initiator (Signature) Date April 5, 1985
Prolect Officer (Signature) Date April 7, 1985 Tel (202) 382 4842(FTS)
(Signature) April 9, 1985
Contracting Officer DATE
(effective date)
( Signature) April 11, 1985
Contractor Acknowledgement of Receipt DATE
(signature & title)
Justification Required
Sheet 1 White—Contracting Ctficer Copy (Washington, DC) Sheet 3 Green—Contractor Copy
Sheet 2 Blue—Pro(ect Olficer Copy (Washington D C) Sheet 4 Yellow—Acknowledgement Copy
Re , seø Septen ow 984
C —4
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APPENDIX D
TITLES AND FUNCTIONS
OF KEY TES PERSONNEL
-------
APPENDIX D
TITLES AND FUNCTIONS OF KEY TES PERSONNEL
o ContractIng Officer - EPA employee with sole authority to execute
contractual agreement, redirect contractor or modify terms of the
contract.
o Project Officer - EPA employee at OWPE who provides overall techni-
cal management of the contract.
o Regional Coordinator - EPA employee within OWPE who coordinates
enforcement activities with a Region, OWPE and the Department of
Justice.
o Regional Contact - EPA employee in the Regional Office who coordinates
TES enforcement activities for the Region.
o PrImary Contact - EPA employee responsible for principal coordina-
tion of a work assignment under TES.
o Initator - EPA employee (usually the primary contact) who makes
request for services under TES.
o Program Manager - Contractor employee responsible for overall TES
program operations.
o Work Assignment Project Manager - TES team member responsible for
planning, management and execution of the services requested by
EPA.
o Technical Monitor - Contractor employee responsible for technical
work output of TES subcontractor team members assigned by Program
Manager.
o Contracts Manager - Contractor employee responsible for all contractual
and financial issues associated with the execution of the TES contract.
ED-i]
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IDENTITY AND LOCATION OF KEY TES PERSONNEL
Contracting Officer - Mr. Bruce Bakaysa
Headquarter Procurement Operations
U.S. EPA
499 So. Capital Street, S.W.
Fairchild Building, Third Floor
Washington, D.C. 20003
Chief, Technical - Mr. Michael Kosakowski
Support Branch Office of Waste Programs Enforcement (WH 527)
U.S. EPA
401 M Street S.W.
Washington, D.C. 20460
Commercial 202/382-5611
FTS 382-5611
Contracts Team Leader - Mr. Howard Beard
Office of Waste Programs Enforcement (WH 527)
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
Commercial 202/382-2105
FTS 382-2105
TES Senior Project - Mr. Elwood (Woody) Martin
Officer Office of Waste Programs Enforcement (WH 527)
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
Commercial 202/382-4103
FTS 382-4103
TES 2 Project Officer - Ms. Nancy Deck
Office of Waste Programs Enforcement (WH 527)
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
Commercial 202/382-3058
FTS 382-3058
TES 1 Program Manager - Mr. Thomas Hopper, P.E.
GCA/Technology Division
213 Burlington Road
Bedford, Massachusetts 01730
617/275-5444
TES 1 Deputy Program - Mr. Russell Wilder
Manager GCA/Technology Division
213 Burlington Road
Bedford, Massachusetts 01730
617/776-5400
[ D - 21
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IDENTITY AND LOCATION OF KEY TES PERSONNEL - (Continued)
TES 2 Program Manager Mr. Wallace J. Beckman, P.E.
PRC Environmental Management, Inc.
303 E. Wacker Drive, Suite 600
Chicago, Illinois 60601
312/938-0300
TES 2 Deputy Program Dr. Thomas D. Brisbin (Assistant-
Manager Edward J. DiDomenico)
PRC Environmental Management, Inc.
303 E. Wacker Drive, Suite 600
Chicago, Illinois 60601
312/938-0300
[ D-3]
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TES CERCLA REGIONAL CONTACTS (AS OF 7/1/85)
Region 1: Susan Svirsky
Waste Management Division
USEPA Region 1
JFK Federal Building
Boston, MA 02203
Tel.: FTS 223-5709; CML (617) 223-1943
Region 2: Cathy Moyik
Site Investigation and Compliance Branch (Rm. 402)
USEPA Region 2
26 Federal Plaza
New York, NY 10278
Tel.: FTS 264-8123; CML (212) 264-8123
Region 3: Kathy Hodgkiss
CERCLA Enforcement Section (3HW12)
USEPA Region 3
841 Chestnut St., 6th Floor
Philadelphia, PA 19107
Tel.. FTS 597-8177; CML (215) 597-8177
Region 4: Ron Joyner
Investigations and Compliance Section
USEPA Region 4
345 Courtland St.
Atlanta, GA 30365
Tel.: FTS 257-2930; CML (404) 881-2930
Region 5: Fred Norling
Waste Management Division, (5HR)
USEPA Region 5
230 South Dearborn St.
Chicago, IL 60604
Tel.: FTS 353-6431; CML (312) 353-6431
Region 6: Connie Codner
Superfund Compliance Section (6H-EC)
USEPA Region 6
1201 Elm St.
Dallas, TX 75270
Tel.: FTS 729-9738; CML (214) 767-9738
(continued)
[ D-4]
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TES CERCLA REGIONAL CONTACTS (Continued)
Region 7: John Chen
Air & Waste Management Division
USEPA Region 7
726 Minnesota Avenue
Kansas City, KS 66101
Tel.: FTS 758-6864; CML (913) 236-2856
Region 8: Roland Lech
Air & Waste Management Division
USEPA Region 8
999 18th St. (1 Denver Place) Tower 1
Denver, CO 80295
Tel.: FTS 327-1798; CML (303) 293-1798
Region 9: Alexis Strauss
Toxics & Waste Management Division (T-4)
USEPA Region 9
215 Fremont St.
San Francico, CA 94105
Tel.: FTS 454-8915; CML (415) 974-8915
Region 10: James Everts
Hazardous Waste Division (Mailstop 524)
USEPA Region 10
1200 6th Ave.
Seattle, WA 98101
Tel.: FTS 399-1993; CML (206) 442-1993
[ D-5]
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TES RCRA REGIONAL CONTACTS (AS OF 7/1/85)
Region 1: Steve Fradkoff
Environmental Engineer
U.S. EPA Region 1
JFK Building
Boston, MA 02203
Room 1903 - 19th Floor
Mail Code (HSE)
(8-223-1961)
Region 2: Eddy Louie
Environmental Engineer
SW Branch
U.S. EPA Region 2
26 Federal Plaza
New York, NY 10278
(8-264-1369)
Region 3: Jeff Barnett
Compliance Officer
RCRA Enforcement Section
U.S. EPA Region 3
841 Chestnut St., 6th Floor
Philadelphia, PA 19107
Mail Code (3HW1 1)
(8-597-668 8)
Region 4: Beverly Foster
Environmental Engineer
Residuals Management Branch
U.S. EPA Region 4
Waste Compliance Section
345 Courtland Protection Agency
Atlanta, GA 30365
(8-257-4552)
Region 5: Arlene Kaganove
RCRA Enforcement Section
HW Enforcement Branch
U.S. EPA Region 5
230 South Dearborn Sreet
Chicago, IL 60604
Mail Code (5HE-12)
(8-886-4463)
[ D-6]
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TES RCRA REGIONAL CONTACTS (Continued)
Region 6: Linda Thompson
Hazardous Materials Branch
U.S. EPA Region 6
First International Building
1201 Elm Street
Dallas, TX 75270
Mail Code (6AWHE)
(8-729-2949)
Region 7: Steve Wilhelm
Chief, RCRA Compliance Section
RCRA Branch
U.S. EPA Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(8-758-2891)
Region 8: Roland Lech
Waste Management Division
U.S. EPA Region 8
1 Park Central
Tower #1
999 18th Street
Denver, CO 80295
(8-327-1798)
Region 9: Paul Blais
Chief, Waste Enforcement Section
Toxic & Waste Management Division
U.S. EPA Region 9
215 Fremont Street
San Francisco, CA 94105
Mail Code (T-2-4)
(8-454-8129)
Region 10: Chuck Rice
Chief, RCRA Compliance Section
U.S. EPA Region 10
1200 6th Avenue
Seattle, WA 98101
Mail Code (MS-533)
(8-399-0695)
[ D-7]
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REGIONAL COORDINATORS/HEADQUARTERS (AS OF 7/1/85)
CERCLA
Region Headquarters Contact Phone Number Room Number
1 Deborah Dalton 382-7788 3603A
Kate Sellers 382-7790 3609
2 Hamid Saebfar 382-4839 3609C
Susan Delpero 382-4845 3609C
3 John Quander 382-4843 3609
Madeline Nawar 382-4834 3609C
4 Larry Weiner 382-4832 3609A
Susan Delpero 382-4845 3609C
5 Chris Grundler 382-7789 3603C
Kate Sellers 382-7790 3609
6 Brad Wright 382-4837 3603C
7 Cheryl Peterson 382-5617 3603D
8 Sharon Foote 382-4831 3603A
9 Frank Russo 382-4838 3609A
Ross Natoli 382-2063 3609E
10 Carolyn McAvoy 382-4848 3609E
RCRA
Region Headquarters Contact Phone Number Room Number
1 Sandy Crystall 475-8733 355
2 Sandy Crystall 475-8733 355
3 Lorraine Smith 475-8730 355
4 Tim Mott 475-8731
5 Cindy Byron 475-8728 355
6 Dave Levenstein 475-8727 355
7 Dave Levenstein 475-8727 355
8 Kathy Margolis 475-6720 355
9 Kathy Margolis 475-6720 355
10 Cindy Byron 475-8728 355
[ D-8]
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APPENDIX E
TES
WORK ASSIGNMENT/WORK PLAN
PREPARATION AND APPROVAL
PROCESS FLOW DIAGRAM
-------
- MANAGEMENT
CONCURRENCE
IF INITIATED IN REGION.
REGIONAL CONTACT FORWARDS
ACTION FORM TO OWPE
CONTRACTING OFFICER REVIEWS
AND APPROVES/DENIES
WORK ASSIGNMENT REQUEST
(15 CALENDAR DAYS AFTER
RECEIPT OF WORK PLAN
FROM TES CONTRACTOR)
CONTRACTING OFFICER REVIEWS
AND APPROVES/DENIES WORK
PLAN; INCORPORATES INPUT
FROM REGION, OWPE
PRIMARY CONTACT AND
PROJECT OFFICER REVIEW
WORK PLAN
(REGIONAL COORDINATOR INPUT)
PROJECT OFFICER REVIEWS
AND APPROVES/DENIES
WORK ASSIGNMENT REOUEST
(REGIONAL COORDINATOR INPUT)
APPROVAL
APPROVAL
TES PROGRAM MANAGER
SELECTS TEAM AND
TECHNICAL MONITOR
(CONTRACTS MANAGER REVIEWS
WORK ASSIGNMENT)
SUBMITTAL
PRIME
/ CONTRACTOR
/ LEAD
1
(15 CALENDAR DAYS AFTER
RECEIPT OF WA FROM EPA)
TES SUBCONTRACTOR
WA PROJECT MANAGER
PREPARES WORK PLAN
SUBCONTRACTOR
LEAD
WORK ASSIGNMENT/WORK PLAN APPROVAL PROCESS
INITIATOR (USUALLY PRIMARY
CONTACT) PREPARES WORK
ASSIGNMENT REQUEST ON
6 PART ACTION FORM
TES CONTRACTOR/SUBCONTRACTOR
BEGINS WORK UPON RECEIPT
OF WORK PLAN APPROVAL
APPROVAL
TES CONTRACTOR
WA PROJECT MANAGER
PREPARES WORK PLAN
(TECHNICAL MONITOR REVIEWS
SUBCONTRACTOR WORK PLAN)
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APPENDIX F
TES 2
WORK ASSIGNMENT
PERFORMANCE APPRAISAL FORM
-------
TES 2
WORK ASSIGNMENT
PERFORMANCE APPRAISAL FORM
Work Assignment Number:
Person Completing Appraisal’: _________________________________
Date: ____________________________________
Score: (Circle One)
1 Unsatisfactory
2 Minimally Satisfactory
3 Fully Successful (performed scope of work within schedule)
4 Exceeds Expectations
5 Outstanding
Comments:
* This form should be completed by the Primary Contact for each work assign-
ment.
[ F- 11
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