United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency
Response
Publication 9355.5-21 FS
EPA 540/F-95/008
PB95-963305
&EPA
Scoping
the Remedial Design
Office of Emergency and Remedial Response
Hazardous Site Control Division 5203G
Quick Reference Fact Sheet
March 1995
This fact sheet presents an overview of the Environmental Protection Agency (EPA) Guidance for Scoping the Remedial Design,
a manual addressed to Remedial Project Managers (RPMs) that describes the predesign planning phase of the Superfund
remedial process. The Guidance will also apply to Superfund Accelerated Cleanup Model (SACM) projects such as non-time-
critical removals and non-emergency early actions. The Guidance provides information on managing Fund-lead and enforce-
ment-lead sites; it includes a description of the required information collection activities, standard Remedial Design (RD) tasks,
development of remediation schedules and cost estimates for remedial design, and instructions for preparing the Statement of
Work (SOW). Throughout the manual, the varying responsibilities of the RPM and other parties are distinguished according
to the type of project (i.e., Fund- or enforcement-lead). See Highlight 1, which displays the manual's organization. This fact sheet
briefly covers the same basic topics.
Highlight 1
Guidance for Scoping the Remedial Design
Chapter Topic
1 Introduction
2 Developing a Project Management Plan
3 Information Collection
4 Developing the Preliminary Remedial
Design Schedule
5 Developing an Estimate of Remedial
Design Costs
6 Developing a Statement of Work for
Remedial Design
7 Developing a Statement of Work for
Remedial Design Oversight
PROJECT MANAGEMENT PLAN
The RPM's chief task is to achieve the goals of the Record of
Decision (ROD) in a timely manner. To accomplish this end, the
Guidance presents management options that allow flexibility
for the RPM. This flexibility enables the RPM to take into
account any constraining factors of the particular site such as
restrictive technical or managerial requirements, schedule limi-
tations, or experience of the contracting party. The effective
Project Management Plan should include the following items:
• Description of organization and communications
• Determination of project constraints
• Development of a contracting strategy for Remedial
Design/Remedial Action (RD/RA).
INFORMATION COLLECTION
The RPM must verify that all necessary information for the
completion of the design has been collected. The primary
sources of information include the Remedial Investigation/
Feasibility Study (RI/FS) and the ROD. The information
contained therein serves as the initial building block for devel-
oping the SOW and for identifying accurately the technical
requirements to be fulfilled by the designer.
Information provided to the designer should cover the follow-
ing points:
• A thorough description of the site conditions
• The remedy, technology, and design approach to be
used for site cleanup
• Any Applicable or Relevant and Appropriate
Requirements (ARARs)
• A summary of data already gathered
• The identification of other possible data needs or studies
• A statement of all unresolved or pending issues.
REMEDIAL DESIGN TASKS
The RD establishes the general size, scope, and character of a
project. It details and addresses the technical requirements
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
-------
(construction plans and specifications) of the Remedial
Action (RA). The RD begins with project planning and ends
with the completion of a detailed set of engineering drawings
and specifications.
To clarify the RD process, certain activities have been desig-
nated as standard tasks; although there are 13 standard RD
tasks, some remain optional when certain remedies are se-
lected for site cleanup. The tasks shown in Highlight 2 are
typical of the RD tasks found in the SOWs for all Response
Action Contracts (RACs). These standard tasks are almost
identical to those tasks that have been used for the Alternative
Remedial Contracts Strategy (ARCS) contracts that will
eventually be replaced by the RACs contracts. Because the
RPM's key role is in seeing that these tasks are performed
properly, thorough knowledge and understanding of these
design tasks and the conditions for their implementation are
required.
Highlight 3 shows the nine principal remediation schedules
and their estimated duration in months.
Highlight 2
Remedial Design Standard Tasks1
1. Project Planning and Support
2. Community Involvement
3. Data Acquisition
4. Sample Analysis
5. Analytical Support and Data Validation
6. Data Evaluation
7. Treatability Study/Pilot Testing
8. Preliminary Design
9. Equipment/Services/Utilities
10. Intermediate Design
11. Prefinal/Final Design
12. Post-Remedial Design Support
13. Work Assignment Close Out
'The order of tasks as they appear in the SOW for
RACs contracts; certain tasks may be conducted
concurrently.
2Community involvement is a standard task
conducted throughout the RD process.
REMEDIAL DESIGN SCHEDULES
The RPM is responsible for developing a preliminary indepen-
dent schedule that will serve as the baseline for negotiating the
final schedule with the contracting party (who has developed
a schedule as well). Sample RD schedules are provided in the
Guidance and are based on the nine basic remediation tech-
nologies used for site cleanup. The RPM's knowledge of site
data will enable adaptation of the appropriate sample schedule
for the remedy-specific category to be used at the site. When-
ever more than one technology or remedy is selected for a site,
the remedial schedule with the longest duration is chosen.
Highlight 3
Total Design Durations for Nine
Remediation Categories/Schedules
Remedy Total Duration1
1. Ground-Water Treatment—Complex 13-16
2. Ground-Water Treatment—Simple 10-13
3. Ground-Water Treatment—Simple (Expedited) 4-7
4. Treatment of Soils and Sludge—Complex 13-19
5. Treatment of Soils and Sludge—Simple 9-13
6. Civil Engineering—Complex 13-15
7. Civil Engineering—Simple 9-13
8. Civil Engineering—Simple (Expedited) 4-7
9. On-Site Thermal Destruction 12-15
'Estimated durations, in months, are based on com-
pleted remedial management contract design projects;
durations could be reduced through the use of perfor-
mance specifications or "off-the-shelf designs.
Recommendations
The following recommendations are offered to further enhance
the usefulness of a generic RD schedule:
• To maximize cost and technical efficiencies and to
identify and correct possible deficiencies, initiate the
technical reviews (biddability, constructibility, environ-
mental, claims prevention, operability) during the
intermediate design phase. For similar reasons, a Value
Engineering (VE) screening should be initiated early in
the project schedule, and a formal VE review, if
deemed appropriate, should be conducted during the
intermediate design phase. (Note: Biddability and VE
reviews will not normally be required for Potentially
Responsible Party (PRP)-lead RD projects.)
• Obtain specific information about duration require-
ments and current practices for procurement, Inter-
agency Agreements (lAGs), owner reviews, and so on,
which may affect the start or overall duration of RD.
• For those sites where early RA starts are required to
protect public health and safety or for other reasons, the
RD/RA schedule can be organized to allow for early
RD completion and RA implementation on the simplest
operable units first. This allows earlier RA starts while
proceeding simultaneously with design on more
complex operable units.
• The standard tasks for RD services should provide a
consistent method of reporting the progress of design
work. They should be used to the maximum extent
possible.
-------
FUND-LEAD SITES
In addition to the general duties performed by the RPM—
management, information collection, schedule preparation—
the designation of the project as either Fund-lead or enforce-
ment-lead will create different responsibilities for the RPM.
Highlight 4 shows the RD process with different leads or
contracting parties. For Fund-lead sites, the Guidance pro-
vides information on developing the Independent Govern-
ment Cost Estimate (IGCE) and SOW for the RD.
Independent Government Cost Estimate
In preparing an IGCE for an RD project, the RPM should first
divide the work into the 13 standard tasks. The activities to be
performed under each task should then be outlined in as much
detail as possible. Although many of the activities are similar
for various sites, each site will have unique characteristics
that require an individual evaluation of the resources neces-
sary to complete the RD. To determine the needed resources,
each of the tasks should be evaluated for the specific site to
determine the expected complexity of accomplishing the task
and to identify any site-specific obstacles that might affect
completion of the task. The RPM should also consider factors
such as the amount of detail required in each of the design
documents and the level of expertise needed to evaluate the
data and develop the documents. By dividing the work into
discrete tasks and subtasks and by defining each functional
Highlight 4
The RD Process with Different Leads1
RD
CONTRACTING
PARTY
DESIGNER
State
Lead
Federal
Lead
'EPA contractor (ARCS or RACs)
2Architect/Engineer or in-house design by USAGE
Note: For abbreviations, see Glossary in Guidance.
activity and product in as much detail as possible in the SOW,
the RPM can more accurately estimate the labor hours re-
quired to accomplish the work at an individual site. The RPM
should use her or his best professional judgment, in conjunc-
tion with historical data from work assignments having a
similar scope of work, to estimate the number of labor hours
needed to complete each task.
If EPA is the contracting party, the preparation of an IGCE is
required before issuing a work assignment and the initiation of
negotiations with the selected remedial designer. (See Federal
Acquisition Regulation (FAR) at 48 CFR 36.605.) As the
Work Assignment Manager (WAM) of the contract action,
it is the RPM's responsibility to develop the IGCE during
preparation of the work assignment for design. This estimate
should include a projection of the labor hours necessary to
accomplish the work, as well as subcontractor costs and Other
Direct Costs (ODCs) such as travel and per diem, communi-
cations, equipment, sampling and laboratory analysis, print-
ing, and computer time.
RPMs should seek the assistance of the Regional IGCE
coordinator, who can review the estimate and pro vide informa-
tion on labor rates and per diem, travel, and ODCs. The IGCE
coordinators may also be able to provide computer program
spread sheets to facilitate the drafting of the estimate. Tables
showing the estimated labor hours per standard RD task for
each of the nine remediation categories are provided in Appen-
dix D of the Guidance for reference.
Statement of Work for Fund-Lead Sites
An SOW must be prepared regardless of who the contracting
party may be; however, the required contents of the SOW will
vary. For a Fund-lead project, the SOW will be used in
developing either a cooperative agreement (with a State, In-
dian tribe, or locality) or an IAG; if EPA is the contracting
party, the SOW is used to develop a work assignment to be
issued to the designer.
The SOW for an RD work assignment should be clear, concise,
and enforceable. The designer should not be required to per-
form tasks that cannot be measured. The SOW must establish
the following:
• Intent of the assignment (project scope—all required
activities to produce the final product)
• Project description (project scope—boundaries of the
authorized project)
• Estimated RD schedule, including the schedule of
submittals (documents detailing how and when the
designer's compliance with the scope of work is
reviewed and measured).
The SOW should describe project-specific professional ser-
vices to be accomplished; these services are broken down into
the 13 standard RD tasks. Understanding of the services is
enhanced when each standard task is further defined and consid-
ered separately during the negotiations between the contracting
-------
party and the designer. The division of the total services into
discrete tasks to be performed, together with consideration of
the constraints of the schedule and budget for each, form the
basis for agreement between the contracting party and the
designer. A model SOW for RD that is broken down into tasks
and subtasks is included as an appendix to the Guidance.
tasks, and a delivery schedule for the submittals. However,
even the best-written SOW might not address every potential
problem. Therefore, once the SOW is final, it is critical that
EPA meet with the Settling Defendants to discuss the SOW as
well as the details of the RD/RA task requirements that guide
the Settling Defendants' Work Plan.
ENFORCEMENT-LEAD SITES
That which ensures an effective Fund-lead SOW applies also
to the enforcement-lead version as far as clarity, specificity,
and thoroughness are concerned. However, for enforcement-
lead RD projects, the RPM will prepare the SOW, which then
becomes an attachment to the Consent Decree (CD). The
CD specifies the RD and RA project requirements to be met by
the PRPs/Settling Defendants. Each Regional Office has a
model SOW for enforcement-lead RD/RA that should be used
by the RPM in developing a site-specific SOW.
A poorly written SOW can cause serious communication
problems between EPA and the Settling Defendants. Ambigu-
ity can result in misunderstandings and in turn result hi the
execution of activities that do not conform to the CD and the
SOW. These misunderstandings can also produce incomplete
submittals, schedule delays, and disputes—possibly requiring
resolution in court. Therefore, the RPM should ensure that all
appropriate agencies are involved in the early stages of SOW
development and during reviews of the completed RD and RA.
Five key implementation-related items should be included in
the SOW:
1. The treatment system or technology
2. Performance standards
3. Points of compliance
4. Demonstration of compliance
5. Schedule.
The treatment or remedy specified in the ROD should be
incorporated verbatim into the SOW. The section in the SOW
on performance standards is extremely important and must be
clearly written to ensure enforceability. Performance stan-
dards should be specified for each medium and remedy com-
ponent involved in the RA. Methods of demonstrating compli-
ance with the specified standards and requirements of the
remedy must be described in the SOW so that the RPM will
know when criteria have been met and so that f ulfillment of the
ROD requirements can be ensured.
Remedial Action Tasks
The major difference between the Fund-lead SOW and the
enforcement-lead SOW is that the latter includes RA tasks in
addition to the RD tasks.
In the SOW, the RPM will specify the following: the RD/RA
tasks that are relevant to the project, the major submittals
(plans, drawings, and reports) associated with each of these
The RD Oversight SOW
It is the RPM's responsibility to monitor compliance with all
RD requirements included by incorporation or reference within
the CD and SOW. The RPM is assisted by an Oversight
Official who is contracted by EPA to provide technical support
in reviewing submittals and monitoring on-site activities. The
overall objective of oversight is to focus the RPM's efforts on
environmental protection, consideration of public health con-
cerns, overall project quality, scheduling, and preparation of
design documents. When developing a site-specific SOW for
RD oversight, it is the responsibility of the RPM to track the
progress of the RD effort and to establish the level of oversight
for the project accordingly. A model SOW for RD oversight is
provided in the Guidance as Appendix E.
Depending on the complexity of the RD activities and on the
Settling Defendants' performance record, the level of involve-
ment varies in terms of what the RPM deems necessary to
perform adequate oversight. However, in most instances, the
RPM will ensure that EPA and its representatives perform the
following activities:
• Review RD plan submittals (e.g., Work Plan, Health
and Safety Plan, Quality Assurance Project Plan)
• Conduct periodic progress meetings with the Settling
Defendants
• Ensure that information collection activities are
proceeding safely and correctly
• Coordinate among all involved Government entities
• Verify task completion and compliance with all
requirements
• Provide status reports as part of the community
involvement task.
For more information concerning RD oversight, refer to the
Fact Sheet entitled EPA Oversight of Remedial Designs and
Remedial Actions Performed by PRPs, Pub 9355.5-01/FS,
Feb. 1990.
Fore more information on scoping an RD, contact your RD/RA
Regional Coordinator at:
EPA Headquarters
Hazardous Site Control Division
Design and Construction Management Branch (5203G)
(703) 603-8830
Note: This Fact Sheet is intended for informational purposes
and cannot be relied upon to create any rights enforceable by
any party hi litigation with the United States.
------- |