United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
9355.0-43
EPA/540/R-95/025
PB95-963308
March 1995
Guidance for
Scoping the
Remedial Design
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EPA-540/R-95/025
PB95-963308
9355.0-43
March 1995
GUIDANCE
FOR SCOPING THE
REMEDIAL DESIGN
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
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The policies and procedures set forth here are intended as
guidance to Agency and other Government employees.
They do not constitute rulemaking by the Agency and may
not be relied on to create a substantive or procedural right
enforceable by any other person. The Government may
take action that is at variance with the policies and
procedures in this manual.
Additional copies of this report may be obtained from the
following source:
National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650
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CONTENTS
PREFACE xi
EXECUTIVE SUMMARY xiii
CHAPTER 1 INTRODUCTION 1-1
PURPOSE OF THIS GUIDANCE 1-1
RPM RESPONSIBILITIES 1-1
EPA as the Contracting Party 1-1
State or Other Government Agency as the Contracting Party 1-3
PRP as the Contracting Party 1-3
Preparation of the SOW for Remedial Design 1-3
Preparation of the SOW for Remedial Design Oversight 1-3
CHAPTER 2 DEVELOPING A PROJECT MANAGEMENT PLAN 2-1
CHAPTER OVERVIEW 2-1
PLANNING ACTIVITIES 2-1
Establishing the Technical Review Team 2-1
Developing the Project Management Plan 2-2
1. Specifying Organization and Communications 2-2
1.1 Determining Roles and Responsibilities 2-2
Establishing the Lead 2-2
Assembling the Technical Review Team 2-2
1.2 Establishing a Communications Matrix 2-2
2. Determining Project Constraints 2-3
2.1 Funding Constraints 2-3
2.2 Schedule Constraints 2-4
2.3 Other Constraints 2-4
Regulations and Permits 2-4
Health and Safety 2-4
Equipment 2-4
Access Needs 2-4
Community Involvement 2-4
Weather 2-5
Change in RPMs 2-5
3. Developing a Contracting Strategy for RD and RA 2-5
3.1 Opportunities To Accelerate the Schedule 2-5
Phasing 2-5
Fast-Tracking 2-5
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CONTENTS (continued)
Use of Preplaced or Prequalified Contracts 2-6
3.2 Design Approach 2-6
Design Specifications 2-6
Performance-Based Specifications 2-6
3.3 The RA Contract (for Fund-lead projects) 2-6
Fixed-Price Contracts 2-7
Cost-Reimbursement Contracts 2-7
Time and Materials Contracts 2-8
Indefinite Quantity Contracts 2-8
Separation of Construction and Service Activities 2-8
3.4 RA Procurement Strategies 2-8
Competitive Procurement 2-8
Sole-Source Procurement 2-9
Updating Budget and Schedule 2-9
CHAPTER 3 INFORMATION COLLECTION 3-1
CHAPTER OVERVIEW 3-1
DATA COMPILATION 3-1
Site Conditions 3-2
1. Site Description 3-2
1.1 Site History and Current Status 3-2
1.2 Chemical, Physical, and Geological Characteristics of Site 3-2
1.3 Proximity to Homes and Schools, and Land and Ground-Water Use
Surrounding Site 3-2
1.4 Basis for Property Lines on Drawings 3-2
1.5 Likely Future Use of Site 3-2
2. Real Estate Issues 3-3
2.1 Real Estate Requirements Assessment 3-3
2.2 Real Estate and Access Issues 3-3
3. Availability of Utilities 3-3
3.1 Location and Availability 3-3
3.2 Existing Agreements or Conditions 3-3
Performance Standards 3-3
Availability of Data 3-4
1. Physical and Chemical Data Collected to Date 3-4
2. Data Retrieval 3-4
Technology and Design Approach 3-4
1. Waste Characterization 3-4
2. Treatment Scheme 3-4
2.1 Schematic Diagram 3-4
2.2 Pretreatment Requirements 3-4
2.3 Treatment Design Criteria 3-4
3. Long-Term Monitoring and Maintenance Requirements 3-5
4. Sole Source or First-Time Use of a Technology or Innovative Technology 3-5
5. Treatability Study 3-5
6. Special Design Conditions 3-6
IV
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CONTENTS (continued)
7. Flexibility in Design 3-6
8. Schedule Constraints That Could Affect the Rate of Treatment or Unit Size 3-6
9. Confirmation Monitoring (Achievement of Performance Standards) 3-6
Materials 3-7
1. Volume Estimation and Basis of Calculations 3-7
2. Spatial Requirements, Staging, Logistics 3-7
3. Durability of Materials 3-7
4. Materials and Equipment Availability 3-7
5. Mixed Materials 3-8
ARARs/Permits/State Involvement 3-8
1. ARARs List 3-8
2. On-Site Versus Off-Site Waste Management 3-9
3. Permits and Land-Use Restrictions 3-9
4. Extent of State Involvement 3-9
Unresolved Issues 3-9
Health and Safety Concerns 3-9
Miscellaneous Concerns 3-10
1. Community Involvement Activities 3-10
2. Confidential Business Information 3-10
3. Other RD/RA Requirements 3-10
CHAPTER 4 DEVELOPING THE PRELIMINARY REMEDIAL DESIGN SCHEDULE 4-1
CHAPTER OVERVIEW 4-1
THE PRELIMINARY RD SCHEDULE 4-1
Schedule Components 4-1
Generic RD Schedules and Assumptions 4-1
Schedule Development 4-6
REMEDY-SPECIFIC SCHEDULES AND ASSUMPTIONS 4-7
Ground-Water Treatment—Complex 4-7
Ground-Water Treatment—Simple 4-7
Ground-Water Treatment—Simple (Expedited) 4-7
Treatment of Soils and Sludge—Complex 4-7
Treatment of Soils and Sludge—Simple 4-8
Civil Engineering—Complex 4-8
Civil Engineering—Simple 4-8
Civil Engineering—Simple (Expedited) 4-8
On-Site Thermal Destruction 4-8
RECOMMENDATIONS 4-9
CHAPTER 5 DEVELOPING AN ESTIMATE OF REMEDIAL DESIGN COSTS 5-1
CHAPTER OVERVIEW 5-1
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CONTENTS (continued)
IGCE COORDINATORS 5-1
DEVELOPING THE ESTIMATE 5-1
Estimation of Design Labor Hours and/or Level of Effort 5-1
Cost Estimation 5-2
Design Fee Limitation 5-2
REMEDY-SPECIFIC COST ESTIMATES 5-2
Ground-Water Treatment—Complex 5-2
1. Assumptions 5-3
1.1 Task 1. Project Planning 5-3
1.2 Task 2. Community Involvement 5-3
1.3 Task 3. Data Acquisition 5-3
1.4 Task 4. Sample Analysis and Validation 5-3
1.5 Task 5. Data Evaluation 5-3
1.6 Task 6. Treatability Study and Pilot Tests 5-3
1.7 Task 7. Preliminary Design 5-3
1.8 Task 8. Equipment and Services Procurement 5-3
1.9 Task 9. Intermediate Design 5-3
1.10 Task 10. Prefmal and Final Design 5-3
1.11 Task 11. Post-Remedial Design Support 5-3
2. Summary 5-4
Ground-Water Treatment—Simple 5-4
1. Assumptions 5-4
2. Summary 5-4
Ground-Water Treatment—Simple (Expedited) 5-4
1. Assumptions 5-4
2. Summary 5-4
Treatment of Soils and Sludge—Complex 5-4
1. Assumptions 5-4
2. Summary 5-5
Treatment of Soils and Sludge—Simple 5-5
1. Assumptions 5-5
2. Summary 5-5
Civil Engineering—Complex 5-5
1. Assumptions 5-5
2. Summary 5-5
Civil Engineering—Simple 5-5
1. Assumptions 5-5
2. Summary 5-5
Civil Engineering—Simple (Expedited) 5-5
1. Assumptions 5-5
2. Summary 5-6
On-Site Thermal Destruction 5-6
1. Assumptions 5-6
2. Summary 5-6
VI
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CONTENTS (continued)
CHAPTER 6 DEVELOPING A STATEMENT OF WORK FOR REMEDIAL DESIGN 6-1
INTRODUCTION 6-1
FUND-LEAD DESIGN 6-1
Roles and Responsibilities 6-1
1. Remedial Project Manager's Role 6-1
2. The Designer's Role 6-1
Design Reviews 6-2
Value Engineering During Design 6-3
Developing a Fund-Lead SOW for RD 6-3
1. Background 6-3
2. RACs Standard Tasks 6-3
2.1 Benefits of Using Standard Tasks 6-3
2.2 Use of Standard Tasks in SOWs 6-5
2.3 Standard Task Categories 6-5
2.4 Using a Standard Task To Develop a Detailed Task 6-5
2.5 Work Breakdown Structure 6-5
2.6 Completing the Detailed SOW 6-8
ENFORCEMENT-LEAD DESIGN 6-8
Background 6-8
The Consent Decree 6-8
Roles and Responsibilities 6-8
1. RPM's Role: Oversight 6-9
2. Settling Defendants' Role: Implementation 6-9
Developing an Enforcement-Lead SOW for RD/RA 6-10
CHAPTER 7 DEVELOPING A STATEMENT OF WORK FOR
REMEDIAL DESIGN OVERSIGHT 7-1
CHAPTER OVERVIEW 7-1
ROLES AND RESPONSIBILITIES 7-1
Remedial Project Manager's Role 7-1
Oversight Official's Role 7-2
1. Duties and Responsibilities 7-2
2. Limitations of Authority 7-3
DEVELOPING AN SOW FOR RD OVERSIGHT 7-4
LIST OF EXHIBITS
Exhibit 1-1 The RD Process With Different Leads 1-2
Exhibit 2-1 Developing the Project Management Plan: Key Decisions 2-3
Exhibit 2-2 Recommended Procurement Strategies for Hazardous Waste Remediation 2-10
Exhibit 3-1 RD Information Collection Categories 3-1
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CONTENTS (continued)
Exhibit 4-1 RACs (Response Action Contracts) Standard Tasks for Remedial Action 4-2
Exhibit 4-2 Total Design Durations for Nine Remediation Categories/Schedules 4-6
Exhibit 5-1 List of LOE Tables (in Appendix D) for Remediation Categories 5-3
Exhibit 6-1 RACs Standard Tasks 6-4
Exhibit 6-2 Benefits From Using Standard Tasks 6-5
Exhibit 6-3 Excerpt From Standard Task 1 From RACs SOW 6-6
Exhibit 6-4 "Detailed" Task IFrom Model (Appendix A) SOW 6-6
Exhibit 6-5 Superfund RD/RA Project Roles and Responsibilities (Enforcement-Lead) 6-11
Exhibit 6-6 Relationships Among Parties During Enforcement-Lead RD/RA 6-12
APPENDIXES
APPENDIX A
MODEL STATEMENT OF WORK FOR REMEDIAL DESIGN A-l
Attachment 1. Summary of Major Submittals for the Remedial Design at (Site) .... A-31
Attachment 2. Work Breakdown Structure A-35
Attachment 3. Regulations and Guidance Documents A-43
Attachment 4. Transmittal of Documents for Acceptance by EPA A-47
Attachment 5. Transmittal Register A-49
APPENDIX B GENERIC REMEDIATION SCHEDULES (BAR CHARTS B.1-B.9) B-l
Chart B.I Ground-Water Treatment—Complex B-2
Chart B.2 Ground-Water Treatment—Simple B-3
Chart B.3 Ground-Water Treatment—Simple (Expedited) B-4
Chart B.4 Treatment of Soils and Sludge—Complex B-5
Chart B.5 Treatment of Soils and Sludge—Simple B-6
Chart B.6 Civil Engineering—Complex B-7
Chart B.7 Civil Engineering—Simple B-8
Chart B.8 Civil Engineering—Simple (Expedited) B-9
Chart B.9 On-Site Thermal Destruction B-10
APPENDIX C GUIDANCE ON PREPARING INDEPENDENT GOVERNMENT COST
ESTIMATES (IGCEs) C-l
APPENDIX D LEVEL OF EFFORT (LOE) ESTIMATING TABLES AND RD COST
ESTIMATING FORMS D-l
Table D.I LOE Summary: Ground-Water Treatment—Complex D-2
Table D.2 LOE Summary: Ground-Water Treatment—Simple D-3
Table D.3 LOE Summary: Ground-Water Treatment—Simple (Expedited) D-4
Table D.4 LOE Summary: Treatment of Soils and Sludge—Complex D-5
Table D.5 LOE Summary: Treatment of Soils and Sludge—Simple D-6
Table D.6 LOE Summary: Civil Engineering—Complex D-7
Table D.7 LOE Summary: Civil Engineering—Simple D-8
Table D.8 LOE Summary: Civil Engineering—Simple (Expedited) D-9
Table D.9 LOE Summary: On-Site Thermal Destruction D-10
Vlll
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CONTENTS (continued)
COST ESTIMATING FORMS
Other Direct Costs and Subcontractor Descriptions D-ll
Independent Cost Estimate Summary Sheet D-12
Estimate of RD Labor Hours D-13
Other Direct Costs (ODCs) Estimating Form D-14
Travel and Per Diem Cost Estimating Form D-15
Subcontract Estimating Form D-16
Design Cost Limitation Check D-17
APPENDIX E MODEL STATEMENT OF WORK FOR REMEDIAL DESIGN OVERSIGHT E-l
Attachment 1. Summary of Major Submittals for the Remedial Design at (Site) .... E-l9
Attachment 2. Work Breakdown Structure E-21
Attachment 3. Regulation and Guidance Documents E-27
Attachment 4. Transmittal of Documents for Acceptance by EPA E-31
Attachment 5. Transmittal Register E-33
APPENDIX F GLOSSARY OF ABBREVIATIONS AND ACRONYMS F-l
INDEX 1-1
IX
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PREFACE
This Guidance for Scoping the Remedial Design provides, for EPA's Remedial Project Managers
(RPMs), information about preparing the Statement of Work (SOW) to facilitate remedial design for
Superfund cleanup projects (both Fund-lead and Enforcement-lead). It includes instruction for preparing a
Project Management Plan, remediation schedules, cost estimates, and model SOWs for oversight of
Fund-lead projects and for RD oversight. The Guidance applies to Superfund Accelerated Cleanup
Model (SACM) projects as well. The Appendixes provide schedules and forms that will be useful in
assisting RPMs to develop complete, detailed guidance for contractors tasked with implementing remedial
design and remedial action activities.
Questions, comments, and/or recommendations concerning this manual are welcomed and should be
forwarded to:
Kenneth Skahn
Hazardous Site Control Division (5203G)
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
(703) 603-8801
XI
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EXECUTIVE SUMMARY
This Guidance for Scoping the Remedial Design describes the activities to be performed in the
predesign planning phase of the Superfund remedial process. The planning process involves the synthesis
of information from the Record of Decision (ROD) and other supporting documents to determine and
define (scope) EPA's technical and managerial requirements for the development of the remedial design
(RD) and the implementation of remedial action (RA).
The Guidance presents information to help in performing the basic predesign activities as follows:
• Preparing the RD/RA management plan
• Collecting predesign technical information
• Developing approximate RD schedules
• Preparing Independent Government Cost Estimates (IGCEs) for RD work assignments to be
performed by contractors
• Developing the Statement of Work (SOW) for the RD
• Developing an SOW for the oversight of RDs conducted by Potentially Responsible Parties.
This guidance manual is organized to lead the Remedial Project Manager through the logical progression
of tasks to be performed as preparation to develop an SOW for the RD.
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CHAPTER 1
INTRODUCTION
PURPOSE OF THIS GUIDANCE
This Guidance for Scoping the Remedial Design
describes the activities to be performed in the
predesign planning phase of the Superfund remedial
process. This Guidance will also apply to Superfund
Accelerated Cleanup Model (SACM) projects such as
non-time-critical removals and non-emergency early
actions. Predesign planning takes place after the
Record of Decision (ROD) has been signed.
However, many of the appropriate activities can be
performed before signing the ROD to expedite the
project. The planning process involves the synthesis of
information from the ROD and other supporting
documents to scope EPA's technical and managerial
requirements for the development of the remedial
design (RD) and the implementation of remedial action
(RA).
This Guidance is addressed to EPA's Remedial
Project Managers (RPMs). It also should be of
interest to the other possible participants (States, other
Government agencies, or Potentially Responsible
Parties (PRPs)) in the RD process in that the
Guidance describes some of their roles and
responsibilities. The RPM's role in the RD scoping
process will vary depending on the RD contracting
party (i.e., the party that orders the services) that is
designated as the choice to be the lead party. Exhibit
1-1 depicts how the choice of the lead or a contracting
party affects the RD process.
The Guidance presents information for performing the
basic predesign activities, including the following:
• Performance of RD/RA management planning
• Collection of predesign technical information
• Development of approximate RD schedules
• Preparation of Independent Government Cost
Estimates (IGCEs) for RD work assignments
to be performed by contractors
• Development of the Statement of Work
(SOW) for the RD
• Development of an SOW for the oversight of
PRP-conducted RDs
RPM RESPONSIBILITIES
Depending on the RD contracting party, you, as RPM,
will be faced with slightly varying responsibilities,
which include developing cost estimates and
negotiation. In general, responsibilities can be
described under three different lead RD groupings,
because in all three cases you will be responsible for
• Developing the Project Management Plan
(Chapter 2)
• Collecting predesign technical information
(Chapter 3)
• Refining the RD schedule (Chapter 4)
• Drafting the SOW (Chapter 6)
EPA as the Contracting Party
For EPA-lead sites (i.e., where EPA is the contracting
party), you are responsible for preparing the SOW, a
design schedule, and an IGCE. Guidance for preparing
an IGCE appears in Chapter 5. These documents will
be used in developing a work assignment to be issued
to the designer. Under no circumstances shall the
IGCE be made available to the designer. The designer
will then prepare and submit to the EPA contracting
officer a Work Plan addressing the items in the SOW,
including discussion of any need to vary from the
SOW. The designer's Work Plan will also include a
proposed schedule and cost estimate. You will review
the Work Plan for consistency with the SOW and will
compare the designer's schedule and cost estimate
with the independently prepared Government
documents.
You will assist the Contracting Officer in negotiating
with the designer to resolve any significant differences
in the proposed design
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Introduction
Exhibit 1-1
The RD Process With Different Leads
Remedial Design
Scoping
Statement of
Work
Negotiation(s)
with Viable PRPs
Enforcement
Lead
Federal
Lead
±.
RD
CONTRACTING
PARTY
DESIGNER
*EPA Contractor (ARCS or RACs)
**Architect/Engineer or in-house design by U.S. Army Corps of Engineers
Note: See glossary for abbreviations.
1-2
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schedule or estimated cost. When agreement is
reached, you will prepare the Work Plan approval
package. This package should include documentation
of any required deviation from the SOW or changes to
the IGCE. Once the package is completed, you will
forward it through the Project Officer to the
Contracting Officer for approval.
State or Other Government Agency as the
Contracting Party
As was the case for EPA as the contracting party, you
will be responsible for preparing a comprehensive
SOW, a design schedule, and an IGCE. The SOW,
schedule, and IGCE will be used to develop either a
cooperative agreement (with a State, Indian tribe, or
locality) or an interagency agreement. The State or
agency will reach a separate agreement with the
designer to carry out the work.
PRP as the Contracting Party
For Enforcement-lead projects (i.e., where the PRP is
the contracting party), you will be responsible for
preparing an SOW (using the information contained in
the ROD) and an RD schedule. The SOW, including
the schedule of deliverables, will become an appendix
Chapter 1
to the Consent Decree. A cost estimate and SOW will
also be needed for the performance of EPA RD
oversight activities, usually by a Response Action
Contracts (RACs) contractor.
Preparation of the SOW for Remedial Design
This guidance manual has been organized to lead you
through the logical progression of tasks that are
performed as preliminary preparation for the
development of an SOW for the RD. Thus, even
though the specific guidance for developing the SOW
is described in Chapter 6, all the earlier chapters will
be preparation for completion of the SOW. In effect,
by the time you have completed the preliminary tasks,
much of the work required for the actual preparation
of the SOW will have been accomplished.
Preparation of the SOW for Remedial Design
Oversight
A model SOW for the performance of RD oversight
activities for Enforcement-lead projects has been
provided for your use (Appendix E) in preparing a
site-specific, comprehensive RD oversight SOW.
Oversight activities and the preparation of the
oversight SOW are described in Chapter 7.
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CHAPTER 2
DEVELOPING A PROJECT MANAGEMENT PLAN
CHAPTER OVERVIEW
The purpose of this chapter is to provide you, the
Remedial Project Manager (RPM), with an overview
of the management options available for remedial
design (RD) and remedial action (RA) to achieve the
goals of the Record of Decision (ROD) in a timely
manner. You should consider these options and
develop a Project Management Plan prior to the
initiation of the RD. The decisions made throughout
the development of the Project Management Plan will
be incorporated into the Statement of Work (SOW)
and, ultimately, into the designer's Work Plan. The
Project Management Plan is an evolving document and
should be updated on a regular basis as the project
becomes more defined. The U.S. Army Corps of
Engineers (USAGE) conducts similar planning
exercises and, although the content is slightly varied,
these plans are made available to you for review
before you initiate the RD/RA.
PLANNING ACTIVITIES
The key to effective project management is planning.
You must devote adequate attention to the initial
planning activities (before the RD begins) to ensure
that the RD can proceed on time and within budget.
During this transition period between the ROD and the
development of the RD SOW, you should be
concerned with undertaking the following activities
(described in more detail below):
• Establish the technical review team.
• Develop the Project Management Plan.
• Update budget and schedule in CERCLIS
(Comprehensive Environmental, Response,
Compensation, and Liability Information
System).
Establishing the Technical Review Team
The complexity of a typical RD/RA project requires
in-depth knowledge of a variety of engineering and
geological fields including chemical, structural,
mechanical, and electrical engineering, as well as a
knowledge of hydrogeology. Because it is unlikely that
any single RPM will possess such a broad knowledge
base, it is imperative that you assemble and coordinate
a project team that incorporates technical knowledge
in the applicable fields. The project "team" approach,
which is used by other Federal agencies engaged in
design and construction management (e.g., USAGE),
results in higher technical quality and improved project
efficiency.
Before beginning a remedial design, review the nature
of the project and select the appropriate technical
assistance. Your technical review team may include
Regional support staff (including ground-water, quality
assurance/quality control (QA/QC), risk assessment,
and engineering experts), other experienced RPMs,
representatives from USAGE, the State (who focus on
Applicable or Relevant and Appropriate Requirements
(ARARs) and permit requirements), EPA's Office of
Research and Development (ORD), or other EPA
offices such as Air, Water, and Solid Waste. It is
important to obtain early involvement from the
pertinent State or other agency that may have the
expertise to assist in the interpretation of a regulation
to ensure compliance with the substantive
requirements.
When USAGE has been tasked to manage the
RD/RA contract, they will use the team approach by
using their own in-house resources. You must identify
additional resources, both internal and external, to
ensure success. When issuing work assignments under
EPA contracts (e.g., Alternative Remedial Contracts
Strategies (ARCS), Response Action Contracts
(RACs), Emergency Response Cleanup Services
(ERCS), or Emergency and Rapid Response Services
(ERRS)), the RPM should consider use of USAGE to
serve in a "technical assistance" capacity. Such
external agencies have excellent technical resources
and can be called upon to provide a wide variety of
engineering and project management services that are
not available from EPA. You may obtain services
from USAGE by preparing an interagency agreement
(IAG) that will explain and authorize the services
needed.
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Developing a Plan
Developing the Project Management Plan
A successful project begins with the "owner" (i.e.,
EPA). The RPM, acting on EPA's behalf, is
responsible for the quality of the project by virtue of
establishing the project requirements and by
communicating these requirements to the other team
members (including the designer and the constructor).
To summarize the requirements of the project fully,
carefully consider all aspects of the project, make key
decisions, and relay this information to those parties
who are performing the work. To prepare for meeting
this basic owner obligation, first develop a Project
Management Plan, which is an analysis of the
project's managerial goals and which includes the
constraints of the remedy. The purpose of preparing
the Plan is to devise a strategy for successfully
delivering the project on time and within budget.
Exhibit 2-1 is an outline of the major managerial
decisions to be addressed in the development of the
Plan, The content, of course, will be modified
depending on the complexity of the remedial design
and remedial action. For simple projects, many of the
requirements need not be addressed~the content and
level of detail are left for you and the technical review
team to determine. Some questions probably cannot be
addressed until the design is under way. Therefore, it
is important to continue to revisit the Project
Management Plan and to revise it as necessary. It is
advised that you seek technical assistance from
experienced Regional staff or USAGE when
developing the Project Management Plan.
1. Specifying Organization
and Communications
1.1 Determining Roles and
Responsibilities
Establishing the Lead
Negotiations with viable PRPs always occur first after
issuance of the ROD. If negotiations fail, the project
then becomes Fund-lead and you will select the
appropriate means of performing RD/RA. Regional
policy may dictate when the State, USAGE, or an
EPA contractor will conduct RD/RA, For Fund-lead
projects, the Office of Solid Waste and Emergency
Response (OSWER) Directive 9242.3-08, dated
December 10, 1991, mandated a maximum RA
threshold of up to $15 million for issuing RA
assignments to an EPA contractor; RAs estimated to
exceed $15 million were to be assigned to USAGE for
construction management. RD assignments, however,
could be made to either USAGE or an EPA contractor
at the Regions' discretion, regardless of estimated
cost. The RPM should check the current policy. If an
EPA contractor is selected, then you, with assistance
from the Project Officer, will evaluate the success that
a particular contractor has had on other projects.
Although it may seem, on the surface, to be desirable
to maintain continuity from the Remedial
Investigation/Feasibility Study (RI/FS) through the RA
by using the same EPA contractor, you are expected
to carefully consider the available options. Base your
final selection on the requirements of the project.
It is also possible for an EPA contractor to design the
remedy, while USAGE contracts for and manages the
RA. In this case, USAGE should be tasked to serve as
technical advisors during the design and should be
allowed to participate fully from post-ROD planning to
SOW development to the development of the plans
and specifications.
Assembling the Technical Review Team
Refer to the earlier section beginning on page 2-1 for
discussion of the makeup of a technical review team.
1.2 Establishing a Communications
Matrix
Effective communication is essential to the success of
a project. Prepare and use a communications matrix
that identifies the key team members and how
information (including submittals, memoranda,
documents, and approvals) flows among the members
to ensure successful communication. Since this matrix
may change upon discussion with the various team
members, make sure all parties agree on the
procedures before the remedial design commences.
You will need to strike a balance so that the team
members do not become inundated with too much
information, thereby creating an unnecessary
expenditure of effort in evaluating the information's
significance to the project. It is usually advisable,
however, to designate all parties to receive copies of
trarismittals, letters, project notes, records of telephone
conversations, etc., to keep everyone abreast of
project activities.
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Chapter 2
Exhibit 2-1
Developing the Project Management Plan: Key Decisions
1. Specify the Organizational and Communications Structure
• Determine roles and responsibilities
Establish the lead
Assemble the technical review team
• Establish a communications matrix
2. Determine Project Constraints
• Funding constraints
• Schedule constraints
• Other constraints
(e.g., equipment/process availability, long-lead procurement, health and safety, predictable seasonal
climate variations)
3. Develop a Contracting Strategy for RD/RA
• Identify opportunities to accelerate the schedule
Phasing
Fast tracking
Use of preplaced contracts and prequalified contracts
• Select the design approach*
Design specifications
Performance-based specifications
• Identify the RA contract type*
Fixed price
Cost plus
Time and materials
Service versus construction contracts
• effects on labor rates
• bonding concerns
• Develop the RA procurement strategy*
Competitive procurement
Sole-source procurement
*If project is Fund-lead
2. Determining Project Constraints 2.1 Funding Constraints
You will face a number of constraints that can You must identify all known funding constraints in
jeopardize timely project completion. By careful order to adequately scope the project. You are
planning, you can minimize disruptions to the schedule. responsible for understanding and ascertaining
In this section, we offer you a list of the more common
issues that can affect the schedule (and costs). • Availability of funds for RD, RA, and
operation and maintenance
• State cost share and obligations during future
years
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Developing a Plan
A shortage of RA funds for the project may result in
the need to phase certain portions. (See section 3.1 of
this chapter for an explanation of phasing and
fast-tracking.) Additionally, for Fund-lead projects, a
State's inability to fund operation and maintenance
may affect design decisions. A cost-benefit analysis of
capital versus operation and maintenance alternatives
is always advisable. It is important to know in advance
if low maintenance features should be clearly specified
in order to prevent costly redesign efforts.
2.2 Schedule Constraints
Develop a schedule that contains the major milestones
through RA completion. If available, use project
management scheduling software to create the
schedule. At this point in the process, the schedule will
be in a preliminary form; it must be continually refined
as the project develops. You must be aware of all
schedule commitments that have been made so that
you can factor them into the contracting
decisionmaking process, Decisions made during the
development of the Project Management Plan will also
affect the schedule. In addition, several of the
constraints listed below (section 2.3) could be seen as
schedule constraints.
2.3 Other Constraints
The possible constraints to timely project completion
are numerous. At this point, you need to identify as
many roadblocks as possible that will affect the project
schedule or the way the project is managed. Several
issues are the most common and therefore worth
highlighting for consideration. By carefully considering
site-specific conditions, you can plan ahead to avoid
later disruptions.
Regulations and Permits
Evaluate the logistical elements involving agencies that
have jurisdiction over the site. The involvement of
other agencies who are typically outside the Superfund
realm can cause schedule delays. It is important to
consider all possible players who may affect the
RD/RA or threaten its timely completion. Other
possible agencies may include
• Federal agencies (e.g., National Oceanic and
Atmospheric Administration (NOAA), natural
resource trustees, Housing and Urban
Development (HUD))
• Local planning commissions
• Zoning authorities
• County or city building and safety departments
• Local water and wastewater authorities
• Local emergency planning and response units
• Public utilities
• Traffic and highway authorities
• State environmental offices
Health and Safety
The management of the health and safety program will
affect completion of the project. The use of Level A
or B Personal Protective Equipment (PPE) can affect
productivity and, subsequently, the schedule.
Furthermore, there may be periods during the year
when factors such as harmful air emissions or
stormwater runoff contamination make construction
more difficult.
Equipment
The ROD may specify a process or remedy that
requires special equipment or a sole-source
procurement. For Fund-lead projects, it is important to
evaluate the delivery schedule for the equipment. If
you expect the procurement process to take a long
time, consider purchasing the equipment under a
separate contract to ensure timely delivery.
Access Needs
Identify access requirements as early as possible to
evaluate or prevent possible delays in performing RD
fieldwork.
Community Involvement*
It is generally EPA's responsibility to ensure that
community involvement activities are carefully
planned. Significant delays can result from inadequate
consideration of community concerns.
*Throughout this document, "community involvement"
is used synonymously for "community relations."
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Weather
When considering weather, it is necessary to evaluate
not only the time of the year when the work will occur,
but also the geographic location of the work site.
Extreme temperatures, excessive rainfall, or high
winds may make execution of an RA difficult. In the
northern sections of the country, winter construction
shutdowns are common.
Change in RPMs
Because some projects take a long time to complete, it
is not uncommon to see a change in RPMs during the
life of a project. To minimize disruption to the project,
records (including the Project Management Plan)
should be kept up to date in the event that the RPM is
changed on short notice. Please use the modified
Golden Rule: Document your actions for your
successor as you would want your predecessor to
have done for you.
3. Developing a Contracting Strategy for
RDandRA
3.1 Opportunities To Accelerate the
Schedule
EPA is committed to expediting cleanups at Superfund
sites. Therefore, every project must be evaluated for
opportunities to accelerate the schedule. In addition,
any constraints identified in section 2 may require you
to review and adjust the schedule accordingly. There
are several methods of developing an optimum
schedule to ensure an accelerated RA: phasing,
fast-tracking, and the use of preplaced or prequalified
contracts.
Phasing
The division of a project into meaningful work
elements that can be implemented on different
schedules usually results in acceleration of the RD and
RA. This strategy, called phasing, allows certain
elements of a project to be started ahead of others to
lessen the hazards present at the site and to complete
simple prerequisite work elements ahead of more
complex and hazardous work elements. All elements
are worked in unison, but each individual element has
its own schedule and moves at its own rate through the
process. Phasing is advantageous because the start of
initial RA is always accelerated.
Use the following criteria to group RD/RA activities
into discrete work elements:
• Existing Information. Certain aspects of the
design such as road installation, utilities
installation, and building demolition and
removal can proceed while data on other
aspects of the design are gathered.
• Phasing by Type of Waste. Segregation of
nonhazardous and hazardous work elements
may be a simple criterion for project phasing.
The engineering required for the nonhazardous
components of a project is frequently more
conventional and may lend itself readily to
accelerated schedules in RD and RA.
Examples are access roads, fences, and
utilities. In addition, these types of work
elements are frequently prerequisites for more
complex elements. It makes sense to begin
their design and construction as early as
possible in the project to ensure that
completion does not delay subsequent work.
• Phasing by Funding Availability. As stated
in section 2.1, funding constraints may create
the need to phase an RA by using the
concepts presented above. An example would
be funding mobilization and construction of an
incinerator as phase one, and incinerator
operation as phase two.
Fast-Tracking
Phasing breaks down large, complex projects into
smaller, more manageable work elements; fast-
tracking accelerates the implementation of those
individual work elements. Fast-tracking techniques
manipulate the internal steps required to complete each
phased element, thereby reducing the overall schedule.
You may choose among several techniques by which
RD/RA can be fast-tracked:
• Expediting RD. Eliminate or shorten steps in
the RD process. However, short-cutting
involves the assumption of risk. The detail in
an RD can be reduced, particularly for simple
engineering efforts such as soil excavation or
tank dismantling. The use of standard
specifications can also expedite the RD.
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Developing a Plan
• Optimizing the RD Schedule.
Optimization is the rearrangement of the
sequence of RD elements to enhance the
overall schedule. For example:
- The site preparation portion of a design
(and other simple construction activities)
can be completed and construction initiated
while the rest of the design activities are
ongoing.
- All design reviews are scheduled in
parallel with ongoing design work so they
are not on the critical path.
- The designer is required to submit design
documents as completed in a
process-logical order instead of retaining
significant schematic or ROD
interpretation documents until the
"preliminary design" or "30-percent" phase
is complete.
• Fast-Track Construction. Some projects
can be divided into separate stages for
construction purposes. This is generally
accomplished by letting out each stage of
work for construction as soon as the design is
completed (e.g., site preparation, procurement
of long-lead equipment, utilities installation).
Use ofPreplaced or Prequalified Contracts
Using preplaced or prequalified contracts will eliminate
the solicitation and audit requirements necessary for
contract award, allowing construction activities to
begin in only 30 to 60 days. Additionally, long delays
because of bid protests or bonding difficulties are
eliminated. The type of contract is heavily influenced
by the amount of uncertainty in the work to be
performed and should be selected to coincide with the
amount of detail incorporated into the design. The
major disadvantage of preplaced or prequalified
contracts is the lack of competition.
3.2 Design Approach
Included in the RD documents are specifications that
describe the technical requirements to be met by the
RA contractor and the criteria for determining whether
these requirements have been met. The two types of
design specifications typically used within Superfund
are Design and Performance-Based Specifications.
Design Specifications
Use design specifications in solicitations when the
Government's technical requirements are definite and
can be clearly communicated to bidders. Under design
specifications, the Contracting Party is responsible for
design and any related omissions, errors, and
deficiencies in the specifications and drawings.
Remedial actions that lend themselves to design
specifications include landfill covers and traditional
ground-water treatment systems. Detailed designs
permit award solely on price and may result in a lower
cost. Also, use of a detailed design specification is
advantageous in that a firm without design capabilities
can bid on the project, thereby expanding competition.
Performance-Based Specifications
Performance-based specifications set forth the
operational requirements for item(s) being procured.
They advise the RA contractor of what the final
product must be capable of performing. If the RA
contractor has undertaken an impossible task, meets
technological problems, or cannot complete
performance because of its lack of experience, the
contractor bears the risk of loss. Performance-based
specifications are typically used where a more
complex treatment technology will be employed. The
performance specification is generally more easily
prepared and can result in a reduction in the time
required to prepare the RD. However, additional time
is usually required for evaluating the proposals
submitted, and the additional risks assumed by the RA
contractor usually result in higher construction costs.
3.3 The RA Contract
(for Fund-lead projects)
The Federal Acquisition Regulation (FAR) defines
the system that the United States Government must
use to obtain contractual services. There are four
general types of contracts available under FAR: fixed
price, cost reimbursement, time and materials, and
indefinite quantity. The two types of contracts most
commonly used are fixed price and cost
reimbursement. The use of fixed-price contracts
forces the Government to do a thorough investigation
and design before solicitation. The benefit of this work
is twofold: it results in a contract that minimizes risk to
the Government and
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Chapter 2
that has the lowest price at the time of award for
comparable technical quality. In contrast, the use of
cost-reimbursement contracts allows for expedited
solicitation while placing greater demands on the
Government in terms of contract administration, risk
allocation, and potential cost.
Fixed-Price Contracts
Fixed-price contracts (lump sum, unit price, or a
combination of the two) establish a firm price for the
supplies, services, equipment, or construction being
acquired. In fixed-price contracts, the ceiling or target
price is adjusted only when an event occurs or a
contingency arises that can cause a modification, as
stated in the contract. Public agencies use only
fixed-price contracts in acquisitions made by selecting
from sealed bids.
Lump sum. A lump-sum (firm-fixed-price) contract is
an agreement to pay the contractor a specified price in
return for certain specified performance. The price
paid is not subject to adjustment as a result of the cost
history developed during performance of the contract.
The contractor's profit or loss is related entirely to its
ability to control costs. Since this type of contract
places the maximum risk and cost responsibility upon
the contractor, it provides the contractor with the
maximum incentive for effective performance. The
resultant benefit is increased profits. Because the
contractor's cost experience is not a factor in
determining compensation under the contract, the
administrative costs to both the contractor and the
public agency are kept to a minimum.
The lump-sum (firm-fixed-price) contract is used when
reasonably definite specifications are available and
whenever fair and reasonable prices can be
established at the outset. This type of contract is
especially suited to the acquisition of supplies, services,
equipment, and construction where realistic cost
estimates can be made. However, if the contractor has
to place a significant contingency factor in its contract
price to cover fluctuations in labor or material costs, or
to protect itself from its inability to estimate the costs,
then the use of a lump-sum (firm-fixed-price) contract
is not appropriate.
Unit price. In a unit-price contract, the selection of
the offerer of the lowest bid is based on estimated
quantities, whereas payments to the successful offerer
are based on actual quantities. That is, the sum to be
paid is the aggregate total determined by the quantity
of work actually performed, calculated according to
the unit price set out in the offer. If the estimated
quantities are faulty, an offer may be mathematically
unbalanced by an offerer who recognizes the real
situation and who, consequently, may attempt to gain
an evaluation advantage by offering high on the
underestimated units and low on the overestimated
units. The solicitation should state that if there is
reasonable doubt that an award would result in the
lowest cost to the agency (materially unbalanced), then
the offer may be considered nonresponsive. Also, a
clause should be included in the contract that would
permit the negotiation of any unit price when the
following changes occur: (1) changes in quantities
exceed 15 percent of the estimated quantity, and (2)
the change in price for that item is significant.
The unit-price contract shifts some of the cost risk
away from the contractor. Therefore, the burden is on
the agency to ensure that the estimated quantities are
a reasonably accurate representation of the actual
anticipated needs in light of relevant factors and past
experience. The estimated quantities should offer a
reasonable probability that award to the offerer of the
lowest bid will, in fact, result in the lowest ultimate cost
to the agency.
Cost-Reimbursement Contracts
The cost-reimbursement contract provides for
payment to the contractor of all (or sometimes a
portion of) its allowable costs. In addition to costs,
these contracts provide for the payment of a fee to the
contractor. Cost-reimbursement contracts establish an
estimate of total cost for the purpose of obligating
funds and establishing a cost ceiling. The contractor
must notify the public agency when costs approach the
ceiling, for the contractor may not exceed the ceiling
(except at its expense) without the prior approval or
subsequent ratification by the public agency. When the
contractor's costs reach the cost ceiling, it must stop
and await further instructions from the agency. A
cost-reimbursement contract may allow a project to be
fast-tracked from the ROD into RA; however, its use
requires enhanced oversight to more closely monitor
contract costs. Cost-reimbursement contracts are
suitable for use when the costs of performance cannot
be estimated with the accuracy necessary for a fixed-
price contract. The cost risk falls on the public agency.
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Developing a Plan
Time and Materials Contracts
Time and materials contracts may be obtained by using
either sealed bids or negotiated procurements. The
Government selects this type of contract when it is not
possible at the time of contract preparation to
accurately estimate the scope (extent or duration) of
work required. The contract calls for the provision of
direct labor hours at an hourly rate and the provision of
materials at a designated cost. The proposal
documents contain estimated quantities for bid
evaluation purposes. Time and materials contracts
require the use of time and cost standards applicable to
the particular work items and require appropriate
surveillance by Government personnel.
Indefinite Quantity Contracts
Indefinite quantity contracts are like time and materials
contracts in that they may be obtained using either
sealed bids or negotiated procurements. The
Government uses this type of contract when it is
impossible to determine in advance the precise
quantities of supplies or services that will be needed
for designated activities during a definite contract
performance period. The method of ordering work
must be stated, as well as minimum/maximum orders
allowable during a specific time period. In order to
provide a basis of cost for items to be ordered,
regulations require the development of a
fixed-unit-price schedule (SOW) before award. The
bid proposal contains estimated quantities for bid
evaluation purposes.
Separation of Construction and Service Activities
For Fund-lead projects, whether a remedial action is
determined to be construction (construction, alteration,
or repair, including dredging, excavating, and painting)
or service (operating a treatment unit) will affect the
labor wage rates and bonding concerns. The plans and
specifications should distinguish between the two types
of activities so that appropriate labor wage rates
(Davis-Bacon rates for construction and Service
Wage rates for service) can be applied. For
construction work funded in whole or in part under
Section 104(g)(l) of the Comprehensive
Environmental Response, Compensation and Liability
Act (CERCLA), the law requires that all laborers and
mechanics employed by contractors be paid wages at
rates not less than those prevailing on projects of a
similar character within the same locality as
determined by the Secretary of Labor in accordance
with the Davis-Bacon Act.
Federal construction projects require RA constructors
to post performance and payment bonds. Historically,
bonds have been difficult to obtain when the remedial
action exceeded $20 million. Separating the remedial
action into service and construction activities results in
lower overall cost of the construction and increases
the chances for the potential RA constructors to obtain
bonds.
3.4 RA Procurement Strategies
Competitive Procurement
EPA's Guidance on Expediting Remedial Design
and Remedial Actions (EPA/540/G-90/006, August
1990) states that
The strategy for expediting procurement methods
is to match the appropriate procurement method to
the type of work being procured. For example, the
fastest procurement is when sealed bidding is used
to procure work for which standard specifications
are available. The time required to put together the
invitation for bids is short because it simply
involves joining standard contract documents to
standard specifications along with a description of
the work. Standard specifications are available for
a broad variety of work including such items as
water mains, wells, pumping systems, some
treatment processes, and various types of earth
work. If these items are part of a project, then the
expediting strategy should include the possibility of
separating them out and procuring them through
sealed bidding.
On the other hand, sealed bidding can be a slow
method of procurement if used for complex work
for which standard specifications do not exist. The
slowness is caused by the need to develop detailed
design specifications. Under these circumstances,
it may be faster to use the negotiated procurement
method with performance specifications, which
require less technical detail. The contractor then
submits within his proposal a plan for the
development of detailed specifications after the
award of the contract. Therefore, the award of the
contract for complex work will usually occur
sooner if the negotiated procurement method is
used. Another procurement method discussed
below, two-step sealed bidding, is similar to
negotiated in this respect; that is, it is suitable for
complex work for which no standard specifications
exist.
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Chapter 2
Considering the above discussion, one time-
saving procurement method is to look for
significant work elements which can be
procured early by way of sealed bidding with
standard specifications. This can be done at
the same time that requests for proposals are
being developed for the more complex portions
of the project, In this manner, the appropriate
procurement method is matched to specific
type of work with the result that each work
element is awarded in the shortest possible
time. This process assumes that the various
elements of work are large enough to warrant
separate procurement actions, and that
construction schedule issues are taken into
consideration.
Descriptions of the essential features of each
procurement method can be found on pp. 32-39 of the
Guidance on Expediting Remedial Design and
Remedial Actions. Recommended procurement
strategies for the various categories of remediation are
provided as Exhibit 2-2.
Sole-Source Procurement
The use of sole-source or noncompetitive procurement
is the least favored method of obtaining an item or
service. Thus, the use of sole-source procurement is
prohibited except in the following four cases:
(1) The item is available from only a single
source.
(2) A public exigency or emergency exists,
justifying its use.
(3) Competition is inadequate.
(4) The EPA award official authorizes it.
To use sole-source procurement, the RPM must
adequately justify the need for it. Brand name and
performance specifications sometimes disguise what is
really a sole-source procurement. If only one brand of
equipment can meet the specification, this results in a
disguised sole source.
FAR requirements for sole-source procurement are
found in FAR Subpart 6.3. The FAR has specific
procedures that must be met, including obtaining the
approval of the EPA's "Competition Advocate" (FAR
6.5) before procurement.
Updating Budget and Schedule
First you must establish a preliminary budget and
schedule for the project. This information must be
incorporated into CERCLIS by the Region to ensure
that funding is available when the design process
begins and to facilitate other planning and project
management activities. These estimated costs and
dates are intended to serve merely as benchmarks;
however, they should be periodically refined and
updated in CERCLIS as they become more detailed
and accurate. Failure to update CERCLIS will hinder
efforts to properly fund and schedule the project,
possibly resulting in work stoppages, scheduling delays,
cost overruns, and a general reduction in project
quality.
Once the ROD is signed, review the budget and
schedule for both remedial design and remedial action
for accuracy. Budget considerations for a PRP-lead
site might include ensuring sufficient funding for
oversight activities and community involvement needs.
Consult with the Independent Government Cost
Estimate (IGCE) Coordinator, the Information
Management Coordinator, or other experienced staff
in the Region to ensure consistency with similar
ongoing projects and available historical cost data.
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Developing a Plan
Exhibit 2-2
Recommended Procurement Strategies for Hazardous Waste Remediation
Remediation Schedule
Ground-Water
Treatment — Complex
Ground-Water
Treatment — Simple
Treatment of
Soils and
Sludge — Complex
Treatment of
Soils and Sludge — Simple
Civil
Engineering — Complex
Civil
Engineering — Simple
On-Site Thermal
Destruction
Specification
• Design
• Performance
• Design
• Design
• Performance
• Functional
• Design
• Design
• Performance
• Design
• Performance
• Functional
Procurement
• Two-Step Bid
• Request for Proposal
• Invitation for Bid
• Two-Step Bid
• Request for Proposal
• Invitation for Bid
• Two-Step Bid
• Request for Proposal
• Invitation for Bid
• Request for Proposal
Contact
• Fixed Price
• Indefinite Quantity
• Time and Materials
• Cost Reimbursement
• Fixed Price
• Fixed Price
• Indefinite Quantity
• Time and Materials
• Cost Reimbursement
• Fixed Price
• Fixed Price
• Indefinite Quantity
• Cost Reimbursement
• Fixed Price
• Fixed Price
• Indefinite Quantity
• Time and Materials
• Cost Reimbursement
Adapted from the technical paper titled "Acquisition Selection for Hazardous Waste Remediation" by William
R Zobel, PE.
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CHAPTERS
INFORMATION COLLECTION
CHAPTER OVERVIEW
As Remedial Project Manager, you should compile
existing predesign information to facilitate a smooth
transition from the Record of Decision (ROD) to the
remedial design (RD) process and to provide the
remedial designer with a clear understanding of the
technical objectives of the RD. The information will
serve as the initial building block for developing the RD
Statement of Work (SOW) for both Fund-lead and
Enforcement-lead projects.
The listing of collected data will serve as an up-to-date
inventory of any information pertinent to the RD.
Provide the list to the designer as an appendix to the
SOW. This will make it possible for both you and the
designer to identify additional predesign information
needs and will enable them to plan for the budgeting
and scheduling requirements.
It is your responsibility to be as thorough as possible in
providing all relevant information. It remains the
responsibility of the designer, however, to verify the
completeness of the information provided to ensure
that the data will yield a design that when implemented
will meet all Applicable or Relevant and Appropriate
Requirements (ARARs). Exhibit 3-1 lists the nine
major categories of information that should be
collected.
DATA COMPILATION
Relevant data are needed by the designer in order to
understand the objectives of the RD. The data will be
collected by means of the following activities:
• Define current site conditions.
• Describe the selected remedy.
• Identify applicable regulatory requirements.
• Summarize available data and identify possible
additional data needs (or treatability studies not
performed for the Feasibility Study (FS)).
• State all known, unresolved issues.
The primary information sources include the Remedial
Investigation/Feasibility Study (RI/FS) and the ROD,
along with any other relevant documents available to
you. Document the information sources that you use.
For Fund-lead sites, you may obtain much of the
information you need through a predesign discussion
session. This meeting, which should be held soon after
the ROD is signed, will involve you, in-house technical
experts, the RI/FS contractor, and other Regional
personnel with prior experience in design and
construction activities. It may also include
representatives from other Government agencies, the
State, and the designer. Discussion topics should
include design-limiting site conditions, the availability
and need for additional data, the need to define
treatment schemes or processes, the need for
treatability studies, the selected design approach and
milestone dates, and the existence of any unresolved
issues.
Exhibit 3-1
RD Information Collection Categories
Site Conditions
Performance Standards
Availability of Data
Technology and Design Approach
Materials
ARARs/Permits/State Involvement
Unresolved Issues
Health and Safety Concerns
Miscellaneous Concerns
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Information Collection
In listing sources of technical information, consider the
following points:
• Keep the narrative brief.
• Use bulleted points whenever possible.
• Provide references to sources of information
(title and description of document, document
number, revision number, date).
• Present pertinent data in logically organized
tables.
• Provide flow diagrams to describe treatment
schemes or processes for the selected remedy.
• Provide supporting information either as
attachments or as a list of references.
We discuss the potential data items to be collected in
the pages that follow. It is left to your discretion and
that of the review team to determine the content and
level of detail for the information provided under each
topical heading. For simple design projects, many of
the items need not be addressed. Whenever this is the
case, headings for unused sections should be retained
for consistency and followed by the words "NOT
USED."
Site Conditions
1. Site Description
Provide a brief description of the site and past and
present site activities, including reference to any
previous or ongoing removal or remedial activities.
There is no need to rewrite this information if it can be
referenced in the ROD.
1.1 Site History and Current Status
Provide a summary of background information that
would be useful to the designer. Include a brief
description of the dimensions, location, and history of
the site; the level of contamination found in each
medium; and other pertinent facts about the site in
general. Also identify the time period for which the
description applies. The designer will know whether
there has been sufficient delay between the
assembling of predesign technical information and the
start of the design to require an update the site status.
Mention any individuals who have useful knowledge of
the site.
1.2 Chemical, Physical, and Geological
Characteristics of Site
Provide a brief description of the general topography
(rolling, flat, steep slopes), types of soil, vegetation,
geologic characteristics (depth to bedrock), depth to
ground water, areas of contamination, and any unusual
features known about the site. These features need to
be described only if they are not satisfactorily
described in the RI, FS, or ROD.
1.3 Proximity to Homes and Schools,
and Land and Ground-Water Use
Surrounding Site
Provide a description of the distances to the nearest
residences, schools, or businesses. Possible or
preferred access routes should also be described. Also
include a brief description of the surrounding land and
ground-water usage.
The designer will use this information (1) to estimate
the extent to which contingency planning will be
necessary during the RD and remedial action (RA)
phases, and (2) to evaluate the need for perimeter
monitoring, noise reduction controls, siting
arrangements, or temporary relocation of affected
residents.
1.4 Basis for Property Lines on
Drawings
Indicate, whenever possible, whether property lines
shown on existing topographic (topo) maps, drawings,
or sketches of the site are based on an actual site
survey or merely scaled from existing drawings, field
sketches, or topo maps. (Scaled measurements are
less reliable, since they can be in error by 25 feet or
more.)
Indicate whether the site has been mapped for the
project and whether field notes are available.
Alternatively, to indicate the level of accuracy of site
drawings, note any existing topographical data obtained
by others (e.g., U.S. Geological Survey) that have
been used for the RI/FS.
1.5 Likely Future Use of Site
Provide a description, if known, of the proposed future
use of the site. This information makes it
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easier for the designer to tailor the design to future
needs.
2. Real Estate Issues
2.1 Real Estate Requirements
Assessment
Obtain an assessment of real estate issues in the form
of a Real Estate Planning Report (REPR). The REPR
will provide information on real estate properties or
easements that must be acquired or from which
residents must be relocated before RA proceeds. Real
estate information includes data on estimated acreage,
number of owners and their names, property value,
problems, and the need for temporary relocation of
affected residents or businesses. Make arrangements
for completion of the REPR before preparing the
preliminary design (submitted when approximately 30
percent of the design is complete) by either the
designer or the U.S. Army Corps of Engineers
(USAGE) under an interagency agreement (IAG).
2.2
Real Estate and Access Issues
Point out any restrictions or special agreements made
with State or local officials or property owners. Special
agreements might include requirements such as the
following:
• Limiting the use of a primary access road to
certain times of the day to minimize the
disruption to local traffic
• Limiting excessive noise and traffic congestion
by using alternative transportation routes for
equipment and materials
• Strengthening a bridge so that it may provide
an access route for heavy construction
vehicles
• Using or acquiring property that could affect
the design or restrict the construction
3. Availability of Utilities
3.1 Location and Availability
Describe the location, if known, of any utilities (gas,
electric, water, sewer, Publicly Owned Treatment
Works (POTW), and telephone) available for use at
the site. When known, include information on the
maximum capacity of each utility and the name and
telephone number of a contact person. This
information probably can be obtained from the
preparer of the RI/FS.
3.2 Existing Agreements or Conditions
Describe any discussions or agreements made with a
utility or local boards. Include the date of the
discussion and the name of the representative(s) who
attended the meeting.
Performance Standards
For each medium to be addressed (e.g., soil, ground
water, air) include, if appropriate, the following
information on the ROD's remediation standards,
goals, requirements, or objectives:
• Clearly defined treatment or performance
standards
• Applicable point(s) of compliance (e.g., 5 ppm
trichloroethylene (TCE) in ground water at the
discharge point to the stream)
• Percentage or order of magnitude reduction
expected from treatment
• Best Demonstrated Available Treatments
(BDATs)
• Maximum discharge levels to be attained
throughout the plume/soil matrix, at property
boundaries, or at the point of release into
surface water or air
• Specific types of analyses (Toxicity
Characteristic Leaching Procedure (TCLP),
total waste analyses) that will be used to
document achievement of required reductions
• Criteria for disposal of treated materials
S delisting of residual ash
S demonstrating that treated wastes do not
exhibit Resource Conservation and
Recovery Act (RCRA) characteristics
S meeting notification and certification
requirements
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S shipping to an off-site RCRA Treatment,
Storage, and Disposal (TSD) facility
• A description of the level of closure or capping
that is required (RCRA Subtitle C or D)
Information that is already clearly presented in the
ROD or FS, and that is appropriately referenced, need
not have lists provided concerning target cleanup goals
and objectives.
Availability of Data
1. Physical and Chemical Data Collected to
Date
Identify all available data and documents that may be
pertinent to design activities, providing information on
the date of collection and the physical location of each
round of data. Include all of the following:
• "Available for review" analytical data collected
to date
• Survey notes (including the location of
monuments and benchmarks) and engineering
or physical data (soil strength and
compressibility)
• Soil boring logs
• Treatability studies
Note, for design purposes, any known data gaps or
areas of significant data variability and the relative
accuracy of the data. You may find it useful to request
the RI/FS contractor to identify data items and possible
data gaps for the design. Such data could be included
in either the FS or a post-ROD design planning
submittal.
A listing of physical and chemical data collections will
aid in developing the design SOW. It will also enable
you and the designer to determine the availability of
required data. Emphasize two facts: that this data
listing does not necessarily constitute a complete
catalog of all data that will be needed, and that it
remains the responsibility of the designer to identify all
data needs for the appropriate design of the remedy.
2. Data Retrieval
Make provisions for clear labeling and proper storage
of all site data. This will make it possible for the data
to be readily identified and retrieved by the designer if
the remedial design will not begin immediately after the
ROD is signed.
Technology and Design Approach
1. Waste Characterization
Review the site data on wastes and develop a general
description of the wastes to be treated. Whenever
appropriate, prepare a table or chart to provide
information on the type, location, condition, uniformity,
volume, and any unusual features (e.g., high toxicity,
high oil and grease content) of the waste. If this
information is listed in the ROD or FS, it can be
referenced and a new list does not need to be created.
2. Treatment Scheme
List any description of the selected treatment process
including any pertinent design criteria or parameters
from the ROD, if present.
2.1 Schematic Diagram
When you have enough information, give the designer
a schematic diagram that indicates the basic features
of the selected treatment process. The RI/FS and
treatability studies may provide additional schematics
as well. Be careful to avoid giving the designer
schematics that have more detail about the treatment
process than is provided in the ROD or that would lock
the designer into an illconceived equipment
configuration.
2.2 Pretreatment Requirements
If pretreatment requirements are specified in the
ROD, describe (to the extent possible) the type,
purpose, and level of treatment to be achieved.
Reference the ARARs or other mechanisms from
which the performance criteria have been derived.
2.3 Treatment Design Criteria
List or describe any treatment performance criteria
identified in the ROD. These may include the
following:
• Input and output rates
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• Maximum and minimum flow rates
• Extraction rates
• Influent or effluent quality
• Sampling frequency and test methods
For the RD to proceed smoothly, these criteria must be
established before the design is begun.
Describe any unusual operating or site conditions that
could affect the specified technology. For instance,
you may know from the RI/FS that an existing landfill,
which is slated to be capped, has unusually steep
slopes. Providing this information to the designer will
allow her or him to anticipate the need for a special
cover design to provide long-term stability on the
slopes. Likewise, the designer should be made aware
of any unusual bedrock formations before designing a
diversion trench because this information could affect
construction phasing, cost, and design.
3. Long-Term Monitoring and Maintenance
Requirements
Review the remedy specified in the ROD and predict
the kinds of long-term activities that will have to be
performed. Long-term activities involve monitoring and
maintaining cleanup equipment that might be used for
extended periods. Examples include maintenance of
ground-water extraction and treatment equipment,
periodic maintenance of mechanical and electrical
parts, and continual exchange of carbon filters for air
stripping or chemicals for a metal precipitation
process. For each type of long-term activity, include
information on the frequency of sampling and
inspections, the parameters of the analysis to be
performed, and the timeframe for these activities.
Longer term (30-year) programs may be required to
meet certain RCRA postclosure requirements for
capped areas containing hazardous wastes. Activities
for these programs could consist of regular inspection
for erosion and subsidence, periodic maintenance of
the leachate collection and treatment system, the
vegetative cover, and the ground-water monitoring
system.
Estimate the basic requirements for monitoring: include
regulatory requirements, performance requirements,
and reevaluation periods. Explain that the designer is
responsible for verifying the completeness of this
estimate and for determining the frequency and type of
sampling or monitoring needed to meet the
performance requirements.
Provide information on who (State or Potentially
Responsible Parties) will be responsible for the
monitoring and maintenance of the site. Explain that
the responsible party may have input on design
considerations that need to be established at the
beginning of the design, such as the complexity of
monitoring systems and the automation of systems.
Explain that when the design calls for engineering
solutions that leave contaminants on-site, a compliance
monitoring program should also be developed or
required from the contractor. This program should be
designed to provide sufficient information to allow you
to determine whether the protectiveness of the remedy
has been maintained. These plans will aid in the
performance of the 5-year review of the remedy (see
Office of Solid Waste and Emergency Response
(OSWER) Directive 9355.7-02, dated May 23, 1991).
4. Sole Source or First-Time Use of a
Technology or Innovative Technology
Point out any potential requirements for specialized or
patented equipment that is likely to be required to meet
the goals of the ROD. Also, describe specialized
equipment that has been used in predesign activities
(bench-scale treatability pilot studies) that also will be
required for the RA. This information can prevent
delays in completing and implementing the RA by
alerting the designer to the need to make provisions for
early procurement or installation of the equipment. The
procurement of equipment may require a significant
lead time, and RA time may increase significantly if
the RA contractor has to make major adjustments to
calibrate the equipment before treatment.
If noncompetitive (sole-source) procurement is
anticipated for a Fund-lead project, include or
reference information that the designer can use to
justify the procurement. Providing justification for a
noncompetitive procurement will place additional
requirements on the procuring agent.
5. Treatability Study
Tell the designer if it will be necessary to perform a
treatability study (bench or pilot scale) during the
design. The primary purpose of the treatability study
should be to obtain scale-up information, and
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not to determine whether a treatment technology will
be effective. Do not automatically require treatability
studies if a detailed database already exists for the
contaminants of concern. Treatability studies may not
be required when adequate treatability data are
available from the RI/FS, or when information already
exists about the performance of the treatment process
because it has been used elsewhere on wastes like
those found at the site. Consult with the technical
review team, technical advisors employed by the
RI/FS contractor, equipment vendors, and the Office
of Research and Development's (ORD's) Superfund
Technical Assistance Response Team (START) to
confirm the appropriate design approach. Also, give
the designer some flexibility in determining the
necessity of these studies or tests.
When treatability studies are required, they should
follow accepted protocols. When using certain
remedies, such as innovative technologies for
difficult-to-treat wastes, the use of scaled-up versions
during design should be considered. This method
allows better assessment of, for example, separation
techniques or volatilization rates, or estimated changes
in heat transfer rates.
6. Special Design Conditions
Describe any special conditions required of the
technologies being used and, if known, state why these
conditions were established. Special conditions may be
associated with an ARAR or an agreement with State
or local officials. For example, normally, it may be
acceptable to operate an incinerator as long as stack
emissions fall within a certain range for the various
particulates or gases involved. However, for a given
site, the federally established range of emissions may
not be acceptable to State or local officials; as a result,
higher efficiencies may be required. Other conditions
could include specific requirements for a trial burn or
off-site disposal, or restrictions on the operating hours
because of the noise levels produced by treatment
equipment operated adjacent to a residential
neighborhood.
7. Flexibility in Design
When the ROD allows flexibility in design, do not
attempt to restrict the designer to the use of a specific
technology or material. Instead, point out the flexibility
allowed, and encourage a review of
available alternatives and consultation with appropriate
technical advisors, as previously indicated for pilot
studies.
Explain that the designer should include a comparison
of life-cycle costs (capital, operating, replacement) in
the evaluation of treatment processes. This
comparison of life-cycle costs should not be confused
with the value engineering study that must also be
conducted.
8. Schedule Constraints That Could Affect
the Rate of Treatment or Unit Size
Point out any target date that must be met (because of
court mandate, permit requirements), since this date
could affect the rate at which treatment must be
performed. Knowledge of this date will enable the
designer to make better decisions concerning
treatment unit sizes or numbers and the scheduling of
construction activities.
9. Confirmation Monitoring (Achievement of
Performance Standards)
Confirmation monitoring is the sampling and analysis
program that is performed during and after the
removal of wastes or contaminated soils, or
ground-water remediation, and prior to project
closeout. Its purpose is to determine whether the final
cleanup levels have been met for the hazardous
constituents of concern. The monitoring is done by
acquiring sufficient environmental media sampling data
to confirm that no residual contamination in excess of
the approved levels remains as a threat to human
health and the environment and that the remedy is,
therefore, complete.
Explain that a confirmation monitoring activity may be
a necessary element of the project design
requirements, if not already specified in the ROD.
Under these circumstances, the designer would need
to supply information on specific aspects of monitoring,
such as the number of samples and the degree of
statistical accuracy that would be required.
Guidance on confirmation monitoring can be found in
Methods for Evaluating the Attainment of Cleanup
Standards: Volume 1—Soils and Solid Media
(February 1989, EPA 230/02-89-042) and Volume
2—Ground Water (July 1992).
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Similarly, the designer must call for or develop
requirements for a shakedown or testing program to
demonstrate that equipment installed by the RA
contractor performed as the designer intended.
Materials
1. Volume Estimation and Basis of
Calculations
Describe the degree of accuracy of existing RI/FS
data for the following items:
• Volume estimates
• Delineations of contaminated areas
• Chemical and physical descriptions of all
contaminated materials to be stored, treated,
or disposed of
• Estimates of off-site disposal needs (drums,
ash, sludge)
You and the technical review team should review
these items closely, as the accuracy of these values is
vital to the validity of cost estimates and to the proper
design and implementation of the RA. For example, an
on-site RCRA disposal unit built to handle an original
volume that was inaccurately estimated may not have
the capacity to contain the actual increased volume.
Knowledge of relevant volume uncertainties will
enable the designer to gather more data or to
incorporate conservative design estimates for
processes such as on-site excavation, treatment, and
disposal.
2. Spatial Requirements, Staging, Logistics
You and the technical review team should evaluate
and advise the designer of the possible need for large
areas to stage materials and to construct or operate
the project. For example, incineration, solidification or
stabilization, and other soil or sludge treatment
remedies often require space for the following
activities:
• Dewatering
• Source separation
• Dredging
• Ash, sludge, and materials treatment and
storage
• Tank containment
• Stockpiling
• Staging of equipment or materials
• Decontamination
• Treating
• Locating access roads, trailers, and buildings
Explain that the designer must consider carefully aad
determine whether project components should be
located on-site or off-site and whether in a
contaminated or uncontaminated zone. For certain
projects, the acquisition of easements or the outright
purchase of properties may be an efficient means for
implementing the remedy (using an underground
discharge line to connect with a sewage treatment
plant intercepting sewer for purposes of groundwater
treatment). In addition, depending on remedy
uncertainties, you and the technical review team may
want to provide a flexible design. This design would
allow for expansion by including provisions for
additional unit processes, pumps, and various other
items or materials needed to accommodate increased
flow capacities or additional treatment processes that
might arise during remedial action.
3. Durability of Materials
Explain that testing the durability of materials with
regard to physical and chemical characteristics may be
warranted for certain design components. For
example, process system integrity can be affected by
wet and dry or freeze and thaw cycling, inadequate
design-life assumptions, or corrosion from contact with
chemically contaminated media.
If the total volume of materials processed or the length
of operation for a treatment facility is tentative,
conservative estimates may be warranted, and more
durable materials may be appropriate (e.g., using
stainless steel instead of carbon steel piping).
4. Materials and Equipment Availability
Alert the designer to review the project and advise you
whenever the selected remedy requires locating a
source for large quantities of a particular material.
Certain materials or equipment needed during the
remedial action may require long-lead procurement,
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significant distances or size limitations for
transportation, or extensive off-site involvement. As an
example of off-site involvement, you may need to alert
the designer to give early attention to determining the
availability of off-site borrow sources or treatment or
disposal facilities if the remedy calls for any of the
following:
• Placement of an extensive clay cap
• UseofaPOTW
• Placement of riprap on embankments,
requiring large quantities of 6-inch stone
• Disposal of on-site treatment plant sludge or
spent carbon
5. Mixed Materials
List any ROD requirements for the handling of
contaminated materials, particularly if the requirements
relate to heterogeneous materials. For example, for
certain remedies such as soil washing, it is often
necessary to separate out large particles (so that the
fine ones can be treated). For such remedies, the level
of separation and treatment required for the materials
should be described to the extent known. Also include
a description of the waste to be handled when it
contains materials such as the following:
• Organic matter (roots, bushes, trees)
• Large cobbles or boulders
• Debris (tires, batteries, autos, machinery,
drums, tanks)
• Difficult-to-treat materials (creosoted piles,
oily sediments)
State, if known, whether any permit waivers or
treatability variances, such as soil and debris variances
under the RCRA land disposal restrictions, should be
pursued.
ARARs/Permits/State Involvement
1. ARARs List
OSWER Directive 9355.7-03, Permits and Permit
"Equivalency" Processes for CERCLA On-Site
Response Actions (February 19, 1992), states that
Remedial actions must comply with those
requirements that are determined to be ARARs at
the time of ROD signature. [The proposed and
final 1982 National Oil and Hazardous Substances
Pollution Contingency Plan (NCP)] [S]ection
300.430(f)(l)(ii)(B), in effect, "freezes" ARARs
when the ROD is signed unless compliance with
newly promulgated or modified requirements is
necessary to ensure the protectiveness of the
remedy. If ARARs were not frozen at this point,
promulgation of a new or modified requirement
could result in a reconsideration of the remedy and
a restart of the lengthy design process, even if
protectiveness was not compromised. This lack of
certainty would adversely affect the operation of
the [Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)]
program, would be inconsistent with Congress'
mandate to expeditiously clean up sites, and could
adversely affect negotiations with potentially
responsible parties.
List or reference the ARARs that were in effect on
the date that the ROD was signed and therefore are
required as part of the remedy. This list will be useful
in preparing the design SOW, and in establishing an
initial agreement between EPA and the designer as to
which ARARs must be met in the design.
Explain that the designer must ensure the accounting
of all appropriate ARARs, off-site permits, and TBCs
(nonpromulgated or enforceable Federal or State "To
Be Considered" criteria, advisories, guidance, or
proposed standards) that need to be followed or
attained during the RD/RA. An example of a TBC is a
requirement that all electrical codes be met when
constructing a pump station or force main. Duplicative
ARARs should not appear on this list, for they should
already have been screened out during ROD
development. Categorize the ARARs as either
chemical-specific, location-specific, or action-specific.
Also, identify TBCs that should be addressed during
the RA.
Identify for the designer (to the extent possible) any
ARARs, variances, waivers, and exemptions that have
been used or are available for use. This might include
a land ban treatability variance or a waiver of certain
Maximum Concentration Levels (MCLs) for
remediating contaminated ground water in fractured
bedrock.
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Explain that the designer is responsible for any
potential ARARs that can be established only during
design—for example, through treatability studies to be
conducted or through specific processes selected
during design to satisfy the general remedy selected.
2. On-Site Versus Off-Site Waste
Management
The Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) and the
National Contingency Plan (NCP) provide that
"on-site"* actions will be exempt from having to obtain
Federal, State, and local permits through administrative
procedures. Although on-site actions must comply with
(or waive) the substantive requirements of the permits,
these RAs will generally proceed more quickly than
off-site actions. In contrast, off-site actions must
usually meet the substantive and often lengthy
administrative permit components of these ARARs,
and comply with the requirements of the Off-Site
Policy (in accordance with CERCLA §121(d)(3).
3. Permits and Land-Use Restrictions
Provide a preliminary list of off-site permits to be
obtained. Point out situations where institutional
controls such as restrictive easements or water-use
restrictions are needed, and note all parties who have
specific responsibilities for implementing controls:
EPA, the State, the local government and/or the
designer or constructor. For example, the designer
may be required to develop a restrictive easement
prohibiting the use of certain wells as a potable water
supply.
4. Extent of State Involvement
Describe the anticipated responsibilities of the State
during the RD. Include the role of the State in
• help in applying State-developed RD/RA
ARARs
• helping to resolve and expedite permitting
issues
• gaining access to properties
Unresolved Issues
Provide a list of all known, unresolved issues; include
enough detail to enable the designer to understand the
concerns of everyone involved. For example, a local
sanitation board could be reluctant to accept
wastewater from the site for treatment at their
POTW. The board's concerns might include the
impact of the wastewater on the treatment process or
the ability of the plant to accommodate additional
volumes of water during peak flow periods. When you
resolve issues of this type with help from the designer
early in the process, substantial cost savings may
result.
Health and Safety Concerns
Alert the designer to potential health and safety
concerns (air releases, traffic) that may be posed by
the site and the planned remedial activities at the site
both for on-site workers and for the neighboring
community.
List or reference all known threats posed by the site
and the planned remedial activities. Reference and
require modification and reuse of any existing data or
Health and Safety Plan (HASP) from previous work
at the site. This list will facilitate the preparation of a
site-specific HASP for any on-site activities to be
performed by the designer or by the RA contractor, as
defined and required by 29 CFR 1910.120 and 40 CFR
300.150.
The designer should be required to delineate the
nonhazardous portions of the post-RD work, because
the efficiency of work in hazardous areas is limited in
direct proportion to the level of protective clothing
required.
Advise the designer of the following contingencies:
• Potential for off-site migration of toxic vapors
or particulates that might result from remedial
activities
• Associated controls, such as dust suppression,
that may be required to minimize health risks
to off-site receptors
* "On-site," according to the NCP, may include the areal extent of contamination (as well as reasonably close
noncontiguous facilities having wastes compatible with a selected treatment or disposal approach) and all suitable
areas, in close proximity to the contamination, involved in implementation of the response action.
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• Applicable community air emission standards
(an example of an ARAR)
• Site-specific risks from chemical, biological, or
physical hazards (such as unusual employee
exposure)
• Potential for fire or explosion
Air dispersion modeling might be recommended for
predicting potential off-site concentrations. Ambient
monitoring requirements as well as realtime air
monitoring with action levels may also be required at
the site perimeter to determine the need for
implementing control measures.
Miscellaneous Concerns
1. Community Involvement Activities
Summarize the community involvement activities that
have taken place. Highlight any special interests or
concerns that the community has expressed. Include a
preliminary list of additional community involvement
activities that should be performed as part of the
design and construction efforts.
List or reference representatives of citizen groups that
have expressed interest in the site.
2. Confidential Business Information
Identify any documents being used for the site RD that
also contain confidential business information.
Reference each document and its location in the files.
Responsibilities for safeguarding confidential business
information are explained in EPA's guidance
document entitled Contractor Requirements for the
Control and Security ofRCRA Confidential
Business Information, dated March 1984, available
from OSWER's Confidential Business Information
Office.
3. Other RD/RA Requirements
Explain that designer- or RA contractor-developed
documents should be provided for each RA and should
be called for in the project specifications. These might
include a Health and Safety Plan, an Emergency
Response Plan, a Community Involvement Plan, a
Field Sampling and Analysis Plan, a Quality Assurance
Project Plan, or an Operation and Maintenance Plan.
These plans may have been developed for an earlier
design or for the RI/FS and can be provided to the
designer for modification rather than having the
designer start from scratch.
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CHAPTER 4
DEVELOPING THE PRELIMINARY
REMEDIAL DESIGN SCHEDULE
CHAPTER OVERVIEW
Successful management of a remedial design (RD)
depends on maintaining schedules and budgets and
resolving problems quickly. Techniques for establishing
good RD management include requirements for
monthly Remedial Project Manager (RPM) and
revision of the RD schedule. The designer may not
change the RD schedule without your prior written
approval. This chapter will help you develop a
preliminary schedule to be used during negotiations.
Because you may not have all the skills, experience, or
insight to develop the schedule, you should rely on the
technical review team to help you. To develop the
schedule, first produce a comprehensive list of
activities or subtasks that, when completed, will
achieve the goals specified in the Record of Decision
(ROD). In contrast to the preliminary schedule that
you prepare, the final, established RD schedule is
prepared by the designer. The final schedule must
specify reasonable goals, contain sufficient detail to
allow monitoring of progress on key activities, and
follow the approved Work Plan.
THE PRELIMINARY RD SCHEDULE
Schedule Components
You are responsible for negotiating the preliminary RD
schedule with the State, other Government agencies,
or a remedial contractor (for Fund-lead projects) or
with the Potentially Responsible Party (PRP) (for
Enforcement-lead projects). As a starting point for
negotiation, develop a preliminary, independent RD
schedule—consistent with the draft design Statement
of Work (SOW) (see Chapter 6 and Appendix
A)—using the 11 standard RD tasks as the basis for
establishing schedule milestones. Request that the
contracting party (the State, other Government agency,
remedial contractor, or PRP) develop a schedule in a
similar manner by separating the work into tasks. This
parallel organization will provide a common basis for
evaluating differences between the two schedules.
Initially, the durations for the individual tasks can be
approximated by referring to the generic RD schedules
in Appendix B and selecting or adapting values from
the tables. (It is anticipated that CERCLIS 3 will be
used to record historic data, including the durations of
standard tasks for work assignments, from which new
data schedules can be developed.)
Generic RD Schedules and Assumptions
The generic RD schedules found in Appendix B were
developed to match the 11 standard tasks found in
ARCS (Alternative Remedial Contracting Strategy)
contracts for RD work assignments. This generic
schedule can also be used with slight modification to
establish schedule durations for the similar standard
tasks for RD found in the RACs (Response Action
Contracts) SOW and summarized in Exhibit 4-1.
The assumptions used in developing the generic RD
schedules typically apply to all the schedules
regardless of the technology applied to remedy the
site. If the design activities differ from these
assumptions, adjust the schedule accordingly. These
assumptions are listed below.
• The Feasibility Study data are sufficient to
specify the bench and pilot testing for any
treatability study.
• Design reviews are conducted in parallel with
the continuing design process rather than in
series.
• The duration of individual activities for each of
the remedy-specific schedules was selected
based on a review of ongoing RD projects and
on discussions with consultant and regulatory
personnel knowledgeable about the various
cleanup technologies, the design requirements,
and procurement and planning needs.
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Preliminary Schedule
Exhibit 4-1
RACs (Response Action Contracts) Standard Tasks for Remedial Action
TASK 1: PROJECT PLANNING AND SUPPORT
• Attend scoping meeting
• Conduct site visit
• Develop work plan and associated cost estimate
- prepare construction cost estimate
- initiate discussion regarding 6% design limitation
• Negotiate work plan and make necessary revisions
• Provide conflict-of-interest disclosure
• Evaluate existing data and documents
• Prepare the following (or reference existing) plans:
Site Management Plan
Field Sampling Plan
Quality Assurance Project Plan
- Health and Safety Plan
• Develop an EPA-approved laboratory quality assurance program
• Develop/review qualifications of the laboratory
• Accommodate external audits or review mechanisms
• Perform site-specific project management
• Manage, track, and report status of site-specific equipment
• Prepare meeting minutes
TASK 2: COMMUNITY INVOLVEMENT
• Update Community Involvement Plan
• Prepare fact sheets
• Prepare or update site mailing list
• Provide public meeting and/or open house support
• Implement other community involvement activities
• Prepare presentation materials
TASK 3: DATA ACQUISITION
• Environmental survey
• Mobilization/demobilization
• Test boring and monitoring well installation and development
• Soil boring, drilling, and testing
• Environmental sampling/monitoring, including the following:
ground water
surface soil
soil boring/permeability
air
• Physical/chemical testing
• Field-generated waste characterization and disposal in accordance with local, State, and Federal regulations
(continued on next page)
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Chapter 4
Exhibit 4-1 (continued)
TASK 4: SAMPLE ANALYSIS
• Perform environmental sample analysis
• Perform waste sample analysis
• Produce analytical data
• Task implementation mechanisms include:
field screening
Contract Laboratory Program
subpool or Team subcontracts laboratories
Regional Environmental Services Division
Environmental Response Team laboratory
regionally procured laboratories
TASK 5: ANALYTICAL SUPPORT AND DATA VALIDATION
• Collect, prepare, and ship environmental samples in accordance with the Field Sampling Plan; the following
may be required:
field screening
ground-water sampling
surface/subsurface soil sampling
surface water and sediment sampling
air monitoring and sampling
biota sampling
• Develop Data Quality Objectives
• Request, obtain, and perform oversight of analytical services
• Coordinate with the EPA Sample Management Office, the Regional Sample Control Coordinator, and/or
the Environmental Services Division
• Implement the EPA-approved laboratory quality assurance program
• Provide sample management
• Perform data validation
• Review data for useability for its intended purpose
• Provide reports on data validation and useability
TASK 6: DATA EVALUATION
• Data useability evaluation/field quality assurance/quality control
• Data reduction and tabulation
• Comparison of data acquired during design with historic data
• Data trend evaluation and/or modeling and submission of Technical Memorandum
TASK 7: TREATABILITY STUDY/PILOT TESTING
• Provide test facility and equipment
• Test and operate equipment
• Retrieve sample for testing
• Prepare Technical Memorandum
• Characterization and disposal of residuals in accordance with local, State, and Federal regulations
(continued on next page)
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Preliminary Schedule
Exhibit 4-1 (continued)
TASK 8: PRELIMINARY DESIGN
• Prepare preliminary design, including the following specific components:
recommended project delivery strategy and scheduling
preliminary construction schedule, including project phasing
specifications outline
preliminary drawings
basis of design report
preliminary cost estimate
a detailed statement of how all applicable or relevant and appropriate requirements as well as Federal
and State public health and safety environmental requirements and standards will be met
land acquisition/easement requirements
technical support to EPA/State/USACE in land acquisition
conduct and/or assist in value engineering screening
TASK 9: EQUIPMENT/SERVICES/UTILITIES
• Procure long-lead equipment, services, and/or utilities
TASK 10: INTERMEDIATE DESIGN
• Prepare intermediate design, including the following specific components:
update construction schedule
preliminary specifications
intermediate drawings
basis of design report
revised cost estimate
a revised detailed statement of how all applicable or relevant and appropriate requirements as well as
Federal and State public health and safety environmental requirements and standards will be met, if
required
an intermediate design review/briefing for EPA
Initiate VE study if VE screening identified potential project savings
TASK 11: PREFINAL/FINAL DESIGN
• Prepare the prefmal design, including the following specific components:
subcontract award document
prefmal design specifications
prefmal drawings
basis of design report/design analysis
revised cost estimate
a prefmal/final design review/briefing for EPA
biddability (offerability) and constructability reviews
revised project delivery strategy
the 100% design submittal shall include the final plans and specifications in reproducible format, a final
cost estimate, and a schedule of the overall remedial action
report results of VE study and incorporate accepted VE recommendations into final design
(continued on next page)
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Chapter 4
TASK 12:
Exhibit 4-1 (continued)
POST-REMEDIAL DESIGN SUPPORT
• Solicit the procurement
• Evaluate offers received
• Inform EPA Contracting Officer of the best qualified/cost-effective offer
• Perform prebid (presolicitation) activities, including:
duplication and distribution of contract documents
advertising/soliciting of bids
issuing addenda
prebid (presolicitation) meetings
resolution of bidder (offerer) inquiries
on-site visits
compilation of contract documents
resolicit bids/offers and repackage documents if necessary
• Perform preaward activities, including:
receipt of bids (offers)
determination of responsive, responsible bidders (offerers)
bid (offer) tabulation
bid (offer) analysis
receipt of followup items from lowest responsible bidder (offerer)
review of EEO, MBE requirements, SDB subcontracting plans, etc.
reference checks
request for consent from EPA
• Write site-specific plans before beginning Remedial Action field activities, including
Site Management Plan
Sampling and Analysis Plan
- Health and Safety Plan
Community Involvement Plan
TASK 13: WORK ASSIGNMENT CLOSE OUT
• Return documents to EPA or other document repositories
• Duplicate, distribute, and store files
• Archive files to meet Federal Records Center requirements
• Use microfiche, microfilm, or other EPA-approved data storage technology
• Prepare a Work Assignment Close Out Report
The intermediate design submittal and formal value
engineering (VE) are not required for the Simple
designs.
The pilot-scale equipment is available; i.e.,
long-lead procurement or fabrication is not
required.
Laboratory analysis is conducted similar to EPA's
data quality objectives (DQO) Level III; i.e., full
Contract Laboratory Program (CLP) validation is
not required.
Resource requirements do not restrain the duration
of an activity.
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Preliminary Schedule
Schedule Development
EPA has developed nine remediation categories (see
Exhibit 4-2, Total Design Durations for Nine
Remediation Categories/Schedules) that encompass
the universe of technologies being used to remediate
National Priorities List sites. These nine remedy-
specific, generic schedules are included as Charts B. 1
through B.9 in Appendix B. We recommend the "bar
chart" format to depict the generic RD schedules
because it provides a clear display of each task,
including the start and completion dates and the
relationship to other tasks. Other formats are also
acceptable; their usage will depend on the complexity
of the project. The generic RD schedules can be used
to develop an initial site-specific schedule; however,
when you use the schedules, consider (1) the
assumptions used in preparing the schedules, and (2)
the recommendations provided in this chapter.
You and the technical review team will have
knowledge of site data that will enable you to select
the remedy-specific, generic RD schedule appropriate
for the site. Wherever two or more remedy categories
are applicable to the same site (e.g., ground-water
treatment and on-site thermal destruction) and the
design activities for both remedy categories are to be
conducted in parallel, a base generic schedule is to be
selected.
The schedule for the remedy of longest overall
duration should be selected as the base schedule, with
the schedule for the other remedy incorporated into it.
The longest duration for each common task should be
used in the base schedule and the total duration revised
accordingly.
Such use of the generic RD schedules will result in an
approximate, first-cut schedule. This schedule can then
be used directly for simple projects, or as the basis for
refinement into more detailed, site-specific schedules
for projects that are complex or that vary from the
assumptions for the generic schedules. The
site-specific schedule may differ from the first-cut
schedule by taking into account features such as the
deletion of certain standard design activities that may
have been previously performed or the consideration
of unique technical design requirements for the site
that will cause revision of the time estimates for some
of the standard tasks.
You may also use "Timeline" software, along with a
computer module that was developed by EPA based
on the same principal remediation categories and
schedules included as Charts B.I through B.9 in
Appendix B. Additional information on this EPA-
developed system can be obtained from Regional
Local Area Network (LAN) Administrators.
Exhibit 4-2
Total Design Durations for Nine Remediation Categories/Schedules
Remedy/Schedule Total Duration*
(months)
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/or Sludge—Complex 13-19
5. Treatment of Soils and/or 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 are based on completed remedial management (REM) contract design
projects. Shorter durations could be achieved through the use of performance specifications or
"off-the-shelf "designs.
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Chapter 4
REMEDY-SPECIFIC SCHEDULES AND
ASSUMPTIONS
Nine characteristic RD categories typify the universe
of remedial actions being considered or implemented at
Superfund sites. A general definition of the nature of
each of the nine principal categories, along with the
assumptions that were made in developing the generic
schedule for each category, is described below. (See
Exhibit 4-2 above for these nine principal remediation
categories and their range of durations from RD start
to 100-percent design approval.) These schedules have
been developed using reasonable approximations for
performing the standard tasks; however, each
Superfund site must be individually analyzed to
determine whether the approximate durations apply.
It should be noted, as previously discussed, that a
site-specific design may have a combination of these
remedies as the overall project solution. It is assumed,
in that case, that the component remedies are applied
in parallel and that the more complex, time-consuming
remedy will determine the overall project duration.
Ground-Water Treatment—Complex
(Appendix B, Chart B.I)
This design category is for withdrawal of ground
water, treatment and discharge or disposal of ground
water, and surface water or leachate treatment. The
technology categories include physicochemical or
biological treatment of liquids. Specific technologies
may include air stripping, carbon adsorption, metals
precipitation, ion change, multimedia filtration, aerobic
and anaerobic biodegradation, evaporation, and
distillation. However, the aquifer, contaminants,
duration of operation and maintenance (O&M),
disposal requirements, performance monitoring
difficulties, and pumping and treatment system design
effort is a more complex, time-consuming effort than
in the Simple case. Innovative water treatment
technologies may be considered.
Scheduling assumptions
• The complexity of the aquifer system requires
extensive aquifer testing.
• The contaminants present and the processes
selected require pilot-scale testing in addition
to bench-scale testing.
• The complexity of the design effort dictates an
intermediate design submittal.
Ground-Water Treatment—Simple
(Appendix B, Chart B.2)
In the Simple case, the technologies are proven for the
contaminants of concern and are available in
"off-the-shelf package treatment units. In addition, the
aquifer characteristics are not complex, and standard
pumping systems are used.
Scheduling assumptions
• Bench-scale testing without pilot-scale
treatability testing is sufficient for design.
• The following are not required:
Extensive aquifer testing and collection of
chemical analytical data
Intermediate design submittal.
Ground-Water Treatment—Simple (Expedited)
(Appendix B, Chart B.3)
EPA has developed expedited categories for sites
where the RD is simple and straightforward and
where additional data collection is not required. Sites
where the scope is limited to minor removal actions or
administrative controls fall into these categories.
Scheduling assumptions
• A single contractor performs the Remedial
Investigation/Feasibility Study (RI/FS), the
RD, and construction management.
• The following are not required:
Additional data collection to support the
RD
Treatability studies
- VE
Intermediate design submittal.
• Client agrees at predesign meeting to initiate
some aspects of design before approval of the
Work Plan.
Treatment of Soils and Sludge—Complex
(Appendix B, Chart B.4)
This design category includes the physical, chemical,
or biological treatment or volatilization of soils and
sludges. All nonthermal destruction of solids is treated
under this category. As a result of complex
contaminants and site conditions,
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Preliminary Schedule
innovative processes requiring extensive testing and
development are required.
Scheduling assumptions
• The selected process requires extensive
bench- and pilot-scale testing.
• The design magnitude and complexity dictate
the submittal of an intermediate design
package.
Treatment of Soils and Sludge—Simple
(Appendix B, Chart B.5)
In the Simple case, the process chosen is a well-
proven technology for the contaminants of concern
and for the existing site conditions.
Scheduling assumptions
• Bench- and pilot-scale testing programs are
required; however, they are relatively short.
• The simplicity of design activity and magnitude
of the design effort allow elimination of the
intermediate design submittal.
• Formal VE is not required.
Civil Engineering—Complex
(Appendix B, Chart B.6)
This design process is principally a civil engineering
design. The Complex case may require a more
extensive data collection or design effort such as a
Resource Conservation and Recovery Act (RCRA)
cap, extensive or complicated excavation or demolition
activities, or the design of other engineered structures.
Scheduling assumptions
• The magnitude of data-gathering activities is
greater than in the Simple case, making the
durations of sampling and analysis also
greater.
• An intermediate design submittal is required.
• VE is required.
Civil Engineering—Simple
(Appendix B, Chart B.7)
As with the Complex case, this design is principally a
civil engineering design. This category will contain
such remedies as fencing, ground-water monitoring,
and minor earthwork, demolition, or removal activities.
Scheduling assumptions
• No treatability studies are required.
• Data-gathering activities include collection of
survey, geotechnical, and chemical analytical
data.
• The simplicity of the design activity and
magnitude of the design effort allow
elimination of the intermediate design
submittal.
Civil Engineering—Simple (Expedited)
(Appendix B, Chart B. 8)
Both of the expedited categories were developed for
sites where the RD is simple and straightforward and
where additional data collection is not required. Sites
where the scope is limited to minor removal actions or
administrative controls also fall into these categories.
Scheduling assumptions
• A single contractor performs the RI/FS, the
RD, and construction management.
• The following are not required:
Additional data collection to support the
RD
Treatability studies
- VE
Intermediate design submittal.
• Client agrees at predesign meeting to initiate
some aspects of design before approval of the
Work Plan.
On-Site Thermal Destruction
(Appendix B, Chart B.9)
This design category includes on-site incineration,
pyrolysis, or in situ vitrification.
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Chapter 4
Scheduling assumptions
• Performance specifications are produced in
the design of the thermal destruction unit.
• Detailed design of auxiliary systems is
required (e.g., water supply, electricity, fuel,
material handling).
• Bench-scale treatability and a pilot-scale test
burn are required. It is assumed that pilot test
burns are conducted at an existing facility.
RECOMMENDATIONS
Consider the following recommendations to further
enhance the usefulness of the concept of a generic
RD schedule:
• To maximize cost and technical efficiencies
and to become aware of and to correct
possible deficiencies, initiate the technical
reviews (biddability, constructibility,
environmental, claims prevention, and
operability) as early as possible during
intermediate design. For similar reasons,
initiate VE screening early in the project
schedule and conduct a formal VE review, if
appropriate, during intermediate design.
• The use of "standard" specifications
(specifications modeled for a particular type of
equipment or treatment process and then
modified to be site-specific) or the use of
completed plans and specifications for a
similar remedy as a starting point for design
will save time and resources. Standard
specifications are currently available from the
U.S. Army Corps of Engineers. A list of these
standard specifications can be obtained by
calling Ms. Tommian McDaniel at (202) 504-
4363.
For sites where RD will be conducted outside
the limits of the assumptions presented here,
obtain specific information about duration
requirements and current practice for
procurement, interagency agreements, owner
reviews, and other factors that may affect the
start or overall duration of an RD.
For sites where early RA starts are required
to protect the health and safety of the public or
for other reasons, you can organize the
RD/RA schedule to allow for early RD
completion and RA implementation on the
simplest operable units first. This method
allows earlier RA starts with simultaneous
design of the more complex operable units.
The standard tasks for RD services are
described in more detail in the model SOW
(Appendix A), and use of the standard tasks is
intended to provide a consistent method of
reporting design work. Use them as much as
possible.
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CHAPTER 5
DEVELOPING AN ESTIMATE
OF REMEDIAL DESIGN COSTS
CHAPTER OVERVIEW
For Fund-lead projects, EPA's Work Assignment
Manager (WAM) is required to prepare an
Independent Government Cost Estimate (IGCE)
before issuing the work assignment to the selected
remedial designer. The Federal Acquisition
Regulation (FAR) at 48 CFR 36.603 requires that an
independent estimate of the cost of design services be
prepared for each contract or contract modification
(work assignment) that is expected to exceed $25,000.
As the WAM of the contract action, it is your
responsibility as Remedial Project Manager (RPM) to
develop the IGCE during preparation of the Statement
of Work (SOW) for the remedial design (RD). 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),
which may include travel and per diem,
communications, equipment, sampling and laboratory
analysis, printing, and computer time.
This chapter provides information on the preparation of
the IGCE to be used in negotiating a reasonable price
for the design of a remedial action (RA) project.
IGCEs are important when cost reimbursement
contracts are the method of contracting because very
little risk falls to the contractor, and the Government
must be in a position to determine if the proposed costs
are fair and reasonable. You should also prepare an
estimate to establish the cost when developing either
(1) an interagency agreement with another
Government agency (the U.S. Army Corps of
Engineers), or (2) a cooperative agreement with a
State for the performance of a remedial design.
When a Potentially Responsible Party (PRP) is the
project lead, you must have a general understanding of
the PRP's design costs, although a detailed estimate is
not necessary. You will have to prepare a detailed
IGCE for RD oversight and community involvement
activities.
Guidance on the roles and responsibilities for preparing
IGCEs for work assignments was issued as OSWER
Directive 9202.1-2, dated July 29, 1993.
A copy of this Guidance is provided in Appendix C
along with OERR Directive 9355.5-01/FS, (September
1989), ARCS' Construction Contract Modification
Procedures.
IGCE COORDINATORS
A number of Regional offices have cost estimators to
help RPMs/WAMs to prepare IGCEs. In other
Regions, RPMs/WAMs can seek the assistance of the
Project Officer. The IGCE Coordinators can provide
information on labor rates, per diem, travel, and ODCs.
They may also be able to provide computer program
spreadsheets for estimating costs.
DEVELOPING THE ESTIMATE
In preparing a cost estimate for an RD project, first
divide the work into the 13 standard tasks for RD
work assignments issued under Superfund RACs
(Response Action Contracts). (See Exhibit 4-1,
Chapter 4.) The activities to be performed under each
task should then be outlined in as much detail as
possible, consistent with the draft RD SOW. (See
Chapter 6 and Appendix A.)
While many of the activities are similar for various
sites, each site will have characteristics that require an
individual evaluation of the resources necessary to
complete the RD. To determine the needed resources,
each task should be evaluated for the specific site to
estimate its complexity and to identify obstacles that
might affect its completion. 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 defining each
functional activity and product in as much detail as
possible, you can more accurately estimate the labor
hours required to accomplish the work at a given site.
Estimation of Design Labor Hours and/or Level
of Effort
Data that characterize the range of the labor hours or
level of effort (LOE) for the 11 standard tasks for RD,
found in ARCS (Alternative Remedial
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Estimate of Costs
Contracting Strategy) contracts, for the Complex,
Simple, and Simple (Expedited) versions of the nine
principal categories of RA are provided in Appendix
D, Tables D.I through D.9. (See Exhibit 5-1, List of
LOE Tables for Remediation Categories.) These
tables can also be used with slight modification to
establish an estimate of the LOE required to perform
work for the 13 standard tasks for RD found in the
RACs Sow. These LOE estimates do not include
labor hours required for program management (i.e.,
cost and schedule control and management reporting).
The data are to be used as a rough check on the more
detailed site-specific estimate of labor hours that the
RPM has prepared for the standard tasks. When a site
uses a combination of categories of RA (e.g., On-Site
Thermal Destruction and Civil Engineering-Simple),
the labor-hour range may not be completely additive
for a given task; again, evaluate the functional
activities that comprise each of the 11 standard tasks.
Then use your best professional judgment, in
conjunction with historical data from similar work
assignments, to estimate the number of labor hours
needed to complete each task.
Cost Estimation
Once you have estimated the labor hours for all
required tasks, the final step in developing the IGCE is
relatively straightforward. Obtain the total direct labor
costs by multiplying the total labor hours by an
estimated loaded hourly rate that falls somewhere
between the high and low rates listed in the specific
contract. The loaded hourly rate includes the costs of
fringe benefits and overhead.
The IGCE should also include ODCs and the cost of
subcontracts (site surveys, drilling). Other direct costs
include such items as travel or equipment and are
computed based on past experience or from
established cost parameters such as per diem and
travel costs. You can also determine these costs by
considering the individual activities that comprise each
task. Accounting records for similar projects will
provide useful data to verify your estimate. Examples
of typical ODCs and subcontractor activities for the 11
standard tasks (under ARCS) are included in the LOE
charts (D.1-D.9) provided
in Appendix D. These charts are based on early
Superfund work assignments. Use these examples as
a starting point, keeping in mind that they represent an
approximation of the LOE requirements for RD.
Appendix D also contains sample forms for use in
preparing an IGCE for RD work assignments. The
IGCE should include the information outlined on these
sample forms even though formats may vary across
Regions. Contact your Regional IGCE Coordinator to
obtain computer-based spreadsheets for cost estimate
compilation.
Design Fee Limitation
For federally funded projects, the total fee for the
preparation of designs, plans, drawings, and
specifications must not exceed 6 percent of the
estimated construction cost. The FAR at 48 CFR
15.903(d)(l)(ii) states that:
For architect-engineering services for public works
or utilities, the contract price for the estimated cost
and fee for production and delivery of designs,
plans, drawings, and specifications shall not
exceed 6 percent of the estimated cost of
construction of the public work or utility, excluding
fees.
This statutory limitation, however, applies to the
estimated cost of design only; other costs such as
travel, site surveys, sampling and analysis, and printing
are not subject to the 6-percent design cost ceiling.
The design cost estimate should, therefore, include a
calculation of the 6-percent ceiling to verify that
neither your estimated design costs nor the
contractor's proposed design costs exceed the
statutory limit for the project. A form for this purpose
is provided in Appendix D.
REMEDY-SPECIFIC COST ESTIMATES
Assumptions used to analyze the activities for each
standard task in the nine remediation categories are
presented in the following paragraphs.*
Ground-Water Treatment—Complex
(See Appendix D, Table D.I)
*The Ground-Water Treatment—Complex remediation category is presented in greater detail than the other
eight categories to serve as a template or guide for developing the other schedules.
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Chapter 5
Exhibit 5-1
List of LOE Tables (in Appendix D) for Remediation Categories
Remedy
Ground-water Treatment—Complex
Ground-water Treatment—Simple
Ground-water Treatment— Simple (Expedited)
Treatment of Soils and Sludge—Complex
Treatment of Soils and Sludge—Simple
Civil Engineering—Complex
Civil Engineering—Simple
Civil Engineering—Simple (Expedited)
On-Site Thermal Destruction
Table
D.I
D.2
D.3
D.4
D.5
D.6
D.7
D.8
D.9
1. Assumptions
1.1 Task 1. Project Planning
Three technical experts (civil engineering,
hydrogeology, and chemical process engineering) are
needed to support the Work Plan preparations. The
contracting party will consolidate comments to
maximize efficiency of review and comment
resolution.
1.2 Task 2. Community Involvement
This task builds on the community involvement
activities of the predesign Remedial Investigation/
Feasibility Study (RI/FS) phase. Level of effort is
proportional to the schedule. Activities include revision
of an existing Community Involvement Plan, one public
meeting, and continued community involvement
support through the start of construction.
1.3 Task 3. Data Acquisition
Four technical specifications are required: drilling and
well installation, laboratory analytical services,
surveying, and waste disposal. In the example, a field
data collection effort that takes 6 weeks, including a
2-week pumping test, is assumed.
1.4 Task 4.
Sample Analysis and
Validation
1.5 TaskS. Data Evaluation
Twenty samples are analyzed and validation is
conducted by using data quality objectives (DQO)
Level III.
1.6 Task 6. Treatability Study and Pilot
Tests
For contracting and evaluation, assume that one
contract modification is issued and that one person is
needed at the site periodically to oversee the pilot test
programs.
1.7 Task 7.
1.8 Task 8.
Preliminary Design
Equipment and Services
Procurement
We assume that at least five permits will be required,
including the National Pollutant Discharge Elimination
System (NPDES), air, wetlands, erosion and
sedimentation control, and local municipality. The RA
contractor will acquire the building and construction
permits.
1.9 Task 9. Intermediate Design
1.10 Task 10. Prefinal and Final Design
1.11 Task 11.
Post-Remedial Design
Support
Essentially there should be no difference in LOE
between prescriptive and performance specifications.
Most site designs will require the use of both
prescriptive specifications for site-specific
requirements, such as earthwork, and performance
specifications for many of the innovative
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technologies that have limited performance histories.
You can reduce the LOE, however, by using
"standard" specifications or by giving the designer
completed plans and specifications for a similar
remedy to use as a starting point for the new design.
The final technical design reviews (constructibility,
biddability, operability, environmental, and claims
prevention) are included here.
The Operation and Maintenance Manual is, at this
stage, a detailed "specification" to guide the
contractor. The Manual is completed by the RA
contractor during startup operations.
2. Summary
The total estimated LOE for the Ground-Water
Treatment—Complex version of the generic RD
schedule is 8,750 to 11,149 hours. With a schedule of
13 months (to approval of 100-percent design), this
loading is equivalent to 4a to 51A full-time positions.
Ground-Water Treatment—Simple
(See Appendix D, Table D.2)
1. Assumptions
Task 3, data acquisition, is set at 6 weeks with 10
samples collected and analyzed. Also, we assume that
a pumping test is not required. The design task's LOE
is estimated at one-third that of the Complex design.
The submittal of an intermediate design and formal
value engineering (VE) are not included in this design.
The LOE required to obtain permits and site access is
held constant for all cases. Permit requirements are
typically tied to specific data acquisition and reporting
formats irrespective of the complexity of the design.
1. Summary
The total estimated LOE for the Ground-Water
Treatment—Simple version of the generic RD
schedule is 3,368 to 4,691 hours. With a schedule of 10
months (to approval of 100-percent design), this
loading is equivalent to 2 to 3 full-time positions.
Ground-Water Treatment-Simple (Expedited)
(See Appendix D, Table D.3)
1. Assumptions
The expedited schedule assumes that no additional
field data collection is required to complete the design.
A portable, "off-the-shelf' treatment system will be
selected. The treatment system vendor will supply
much of the design analysis.
The product of the design tasks will be a package
consisting of 20 specifications (civil, chemical, and
mechanical) and 5 drawings (site plan, general
arrangement, piping and instrumentation diagram,
electrical diagram, and process diagram).
2. Summary
The total estimated LOE for the Ground-Water
Treatment—Simple (Expedited) version of the generic
RD schedule is 1,641 to 2,225 hours. With a 4-month
schedule (to approval of 100-percent design), this
loading is equivalent to 21A to 3l/2 full-time positions.
Treatment of Soils and Sludge-
(See Appendix D, Table D.4)
1. Assumptions
-Complex
Field data acquisition requires specifications for five
activities: drilling, surveying, analytical laboratory,
geotechnical laboratory, and waste disposal service.
The average National Priority List site is 10 acres.
Assume the field data collection requires 5 weeks and
includes the collection of 300 samples; all but 30 are
analyzed using an on-site laboratory. Assume that one
technology of a complex nature will be studied under
the treatability task.
The design criteria to be considered include civil and
process engineering, health and safety, and
environmental. The design components are estimated
using a large east coast Superfund project as a
template. This project design package included 50
specifications and 33 drawings.
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2. Summary
The total estimated LOE for the Treatment of Soils
and Sludge—Complex version of the generic RD
schedule is 10,850 to 13,463 hours. With a 17-month
schedule (to approval of 100-percent design), this
loading is equivalent to 4 to 5 full-time positions.
Treatment of Soils and Sludge-
(See Appendix D, Table D.5)
1. Assumptions
-Simple
This category is considered appropriate for a 1-acre
site. Fifty samples are taken during the field
investigation, of which 10 are sent to an off-site
analytical laboratory. Design criteria and design
activities are similar to those in the Complex category;
however, LOE is considerably reduced. As with the
other Simple categories, the intermediate design
submittal and VE are not required.
2. Summary
The total estimated LOE for the Treatment of Soils
and Sludge—Simple version of the generic RD
schedule is 4,406 to 5,860 hours. With a 9-month
schedule (to approval of 100-percent design), this
loading is equivalent to 3 to 4 full-time positions.
Civil Engineering—Complex
(See Appendix D, Table D,6)
1. Assumptions
The model for this design category was a large east
coast Superfund site that included several activities:
soil excavation, water treatment, a slurry wall, and
building decontamination. The actual LOE for this site
was reduced by removing the ground-water treatment
aspect from consideration.
The activities of field data collection are assumed to be
similar to those required in the Soils and
Sludge—Complex category. Similar design criteria are
considered. An intermediate design submittal and
formal VE are included in this category.
2. Summary
The total estimated LOE for the Civil
Engineering—Complex version of the generic RD
schedule is 10,720 to 13,605 hours. With a 12-month
schedule (to approval of 100-percent design), this
loading is equivalent to 5% to TA full-time positions.
Civil Engineering—Simple
(See Appendix D, Table D.7)
1. Assumptions
The field data acquisition consists of installing three
shallow monitoring wells and excavating several test
pits. Ten samples are analyzed at an off-site
laboratory. Four design criteria are considered in
developing the basis of design: civil, hydrogeologic,
environmental, and health and safety.
The design is straightforward, with 20 specifications
and 5 drawings required for the procurement package.
The design reviews are performed by a single person
(rather than a team) and the operability review is not
performed.
2. Summary
The total estimated LOE for the Civil
Engineering—Simple version of the generic RD
schedule is 3,106 to 4,187 hours. With a 9-month
schedule (to approval of 100-percent design), this
loading is equivalent to 21A to 3 full-time positions.
Civil Engineering—Simple (Expedited)
(See Appendix D, Table D.8)
1. Assumptions
In this generic category, there are no activities for field
data collection and no laboratory analysis. A Basis of
Design Report is issued. The design activities are
simple and uncomplicated with minimal institutional
concerns.
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Estimate of Costs
2. Summary
The total estimated LOE for the Civil
Engineering—Simple (Expedited) version of the
generic RD schedule is 1,633 to 2,210 hours. With a
4-month schedule (to approval of 100-percent design),
this loading is equivalent to 21A to 3l/2 full-time
positions.
On-Site Thermal Destruction
(See Appendix D, Table D.9)
1. Assumptions
An existing Superfund incineration project with a
required quantity of excavation close to 20,000 cubic
yards was selected as the template for the generic
design.
Some water treatment will be necessary for
incineration of sludges (treating effluent of the
dewatering effort). Treatability studies are required at
the bench scale for the water treatment and at bench
and pilot scales for the material to be incinerated. Five
specifications are needed to
conduct activities for field data collection.
The LOE to support the activities for field data
collection is assumed to be similar to that required for
the Treatment of Soils and Sludge—Simple category.
A 1-acre site with a required depth of excavation of 10
feet satisfies the area and volume assumptions
presented here and under the Soils and
Sludge—Simple category.
Four design criteria are considered: civil and process
(including electromechanical) engineering,
environmental, and health and safety.
The design activities are similar to the Complex
categories previously described and include formal VE
and an intermediate design submittal.
2. Summary
The total estimated LOE for the On-Site Thermal
Destruction version of the generic RD schedule is
9,411 to 12,939 hours. With a 12-month schedule (to
approval of 100-percent design), this loading is
equivalent to between 51A and 7 full-time positions.
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CHAPTER 6
DEVELOPING A STATEMENT OF WORK FOR
REMEDIAL DESIGN
INTRODUCTION
The purpose of this chapter is to guide you, the
Remedial Project Manager (RPM) in developing a
site-specific, project-specific Statement of Work
(SOW) for remedial design (RD). The chapter is
divided into discussions of the development of either a
Fund-lead or Enforcement-lead SOW. A model
Fund-lead SOW based on the 13 standard tasks found
in RACs (Response Action Contracts) is provided in
Appendix A.
FUND-LEAD DESIGN
Roles and Responsibilities
1. Remedial Project Manager's Role
When EPA decides to assign a design project to one
of its remedial contractors (i.e., EPA acting as the
"contracting party"), you must establish the tone and
level of the performance required. Your role is not to
be all-knowing, but to marshal the resources needed to
perform the task at hand. You will be responsible for
establishing and maintaining connection with the
technical review team, articulating particular needs,
assuring that funding is available, establishing project
requirements, making decisions affecting RD, and
providing other essential information. Failure to fulfill
these responsibilities can have serious consequences,
regardless of the talent and abilities of the other team
members.
Among your responsibilities as RPM are the following
tasks;
• Prepare a complete, detailed SOW for design.
• Communicate project objectives and critical-
need dates.
• Identify special expertise needed and form a
multidisciplinary technical review team.
• Establish reasonable and attainable design
criteria.
• Require the designer to implement programs
for quality assurance, quality control, and peer
review.
• Provide timely reviews and approvals.
• Allow freedom for innovation in design. (Do
not impose undue restraints.)
• Stress completeness, timeliness, and
professional presentation of submittals.
• Assure that value engineering (VE),
biddability, constructibility, operability, claims
prevention, and environmental reviews of the
design are conducted.
• Be prepared to coordinate, negotiate, and
resolve conflicts in a timely manner.
• Assure that both the cost and the schedule for
the RD are reasonable.
Effective communication with the technical review
team members and the remedial designer is a key
element of a successful RD effort. Clear
communication about relevant facts, schedules,
requirements, expectations, status of work, and funding
is critical in any quality project. Lack of
communication about changes and delay in sharing
new information both result in wasted time and money.
2. The Designer's Role
The designer's primary role is to conceive, plan, and
provide quality design solutions in response to the
stated requirements of the contracting party. This
effort is documented by plans and specifications and
other remedial action (RA) contract documents
(submittals) used for solicitation and award of the RA
contract. After the designer has completed these
documents, the contracting party reviews and
approves them.
The designer follows the design development criteria
and the Basis of Design approved by the contracting
party, who plans and executes the design effort. For
example, the designer is
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Developing an SOW for Remedial Design
primarily responsible for design-phase activities such
as the following.
• Planning and managing the design
• Coordinating and communicating
• Monitoring and controlling design costs and
schedules
• Providing professionally qualified staff
• Performing design-related quality control
• Designing in compliance with codes and
standards, laws and regulations, and regulatory
agency requirements
• Arranging for appropriate design reviews and
peer reviews
In addition to the responsibilities stated in the
designer's contract, the designer is responsible for
protecting the public health, safety, and welfare under
State licensing laws and for conforming to the code of
ethics of the design profession.
Designers are responsible for providing professional
quality work that meets professional standards of care,
skill, and diligence. If the designer fails to meet these
standards, or fails in any other contractual duty, the
party that contracted for the design must review the
circumstances involved, including the resulting
damages and subsequent recovery activities.
By common law, if it is found that a design defect has
been the result of either (1) the designer's lack of the
ordinary skill, knowledge, and judgment possessed by
members of the profession, or (2) the designer's
failure to apply professional knowledge and skill, then
the party that contracted for design would be entitled
to recover from the designer the amount of damages
suffered. The damages suffered will vary with the
circumstances of each case. In most instances, the
damages are considered to be the cost of the RA that
would not have been incurred had the design not been
defective because of professional negligence on the
designer's part.
Such damages might include the cost of redesign to
correct the defect during RA and damages to the RA
contractor attributed to the delay. However, proving
fault with the designer will likely be far more difficult
than using the technical review process to make sure
that the work is done correctly in the first place.
Design Reviews
It is your responsibility to assure that the technical
review team reviews and comments on the design
documents and other contractor submittals. These
activities may occur concurrently with or prior to other
design activities. In the latter case, design activities do
not begin until the review is completed, all comments
are resolved, and approval to proceed is granted.
Concurrent reviews eliminate the inefficiencies and
delays caused by stopping and restarting design at the
30- and 60-percent stages; however, in a concurrent
review, there is a risk of proceeding with the design of
a feature that could require change as a result of the
technical review. Other methods for speeding the
remedial design process are discussed in the document
entitled Guidance on Expediting Remedial Design
and Remedial Action.
You will coordinate the review process, including
collecting the review comments and providing the
designer with a concise comments package. This will
allow you to screen and respond to comments that
need not be passed on to the designer. The designer
has a professional responsibility regarding the
consequence of the comments on the design and must
communicate any adverse effects to you.
The review of the plans and specifications and other
required design submittals by the technical review
team generally is for administrative purposes only.
That is, the review should ensure that the project will
achieve its remediation goals and that its performance
and operations requirements have been correctly
identified. The structural, mechanical, and electrical
aspects of the design documents should be reviewed in
detail by a qualified member of the technical review
team. However, EPA's acceptance of the plans and
specifications does not relieve the designer of
professional liability for the adequacy of the design.
The duration of review activities for any particular
project is a function of the complexity of both the site
characteristics and the design, as well as of the
administrative requirements of the party who contracts
for design, and the design reviewers. The specific
review and approval activities, which are the
responsibility of both you and the technical review
team, should be clearly and separately identified on the
project schedule. This level of
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precision will reinforce the responsibilities of all parties
and will provide early knowledge of any consequences
of allowing these activities to move onto the critical
path of the design process.
Value Engineering During Design
It is your responsibility to ensure that VE screening
and a VE study, if appropriate, are conducted on each
Fund-lead RD. We recommend that for most designs,
either the U.S. Army Corps of Engineers (USAGE),
the Bureau of Reclamation (USER), or an independent
firm with the requisite experience be tasked to perform
the work. The designer can be tasked to conduct the
VE study if the screening performed during
preliminary design indicates the need for the study and
if an independent and objective study can be
conducted by the design firm. (See Value
Engineering Fact Sheet, Publication 9335.5-03FS,
May 1990.) The items to be reviewed in screening a
design are identified and discussed in the RD/RA
Handbook, Publication 9355.5-22 (8/93 Draft).
Developing a Fund-Lead SOW for RD
1. Background
The Fund-lead SOW describes the project-specific
professional services to be accomplished by the
designer. The SOW should be clear, concise, and
enforceable. Services are grouped by tasks that are
defined and correlated with services required, level of
effort by the designer, project time, and compensation.
The designer is expected to produce certain
documents during the development of the project.
Among these are the RD Work Plan, cost estimates
and schedule, preliminary design and outline
specifications, and final design. Each of these
documents is the result of one or more subtasks
defined in the SOW, and each is scheduled for delivery
to EPA on a mutually agreed-upon schedule.
You and the designer share the responsibility and the
obligations for on-time performance of assigned tasks
and subtasks, which may include providing existing
information on the project, arranging for additional
specialized information necessary for design,
coordinating activities with other project team
members, arranging for permits and approvals from
other agencies, making prompt decisions, and other
activities influencing the designer's ability to perform
under the terms of the agreement. EPA's commitment
to quality requires that these responsibilities be
discussed and written into the SOW.
2. RACs Standard Tasks
Included in each of the RACs is an SOW that contains
a full description of typical contractor services.
General categories of remedial response activities are
further subdivided into standard tasks. (See Exhibit
6-1, RACs Standard Tasks, on page 6-4.) You should
use the standard tasks for a given activity to develop a
detailed SOW to obtain contractor assistance for a
work assignment.
2.1 Benefits of Using Standard Tasks
We strongly recommend that you use the standard
tasks (and the model RD SOW found in Appendix A)
when you prepare a remedial design SOW for a RACs
work assignment. The standard tasks for RD provide
uniformity in the remedial process and will ultimately
benefit Superfund management functions and
objectives. Some of the benefits derived from using
standard tasks are listed on page 6-5 in Exhibit 6-2.
6-3
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Developing an SOW for Remedial Design
Exhibit 6-1
RACs Standard Tasks
Remedial Investigation/Feasibility Study (RI/FS)
Task 1 Project Planning and Support
Task 2 Community Involvement
Task 3 Field Investigation
Task 4 Sample Analysis
Task 5 Analytical Support and Data Validation
Task 6 Data Evaluation
Task 7 Assessment of Risk
Task 8 Treatability Study/Pilot Testing
Task 9 Remedial Investigational Report
Task 10 Remedial Alternatives Screening
Task 11 Remedial Alternatives Evaluation
Task 12 FS Report and RI/FS Report
Task 13 Post RI/FS Support
Task 14 Negotiation Support
Task 15 Administrative Record
Task 16 Work Assignment Close Out
Remedial Design
Task 1 Project Planning and Support
Task 2 Community Involvement
Task 3 Data Acquisition
Task 4 Sample Analysis
Task 5 Analytical Support and Data Validation
Task 6 Data Evaluation
Task 7 Treatability Study/Pilot Testing
Task 8 Preliminary Design
Task 9 Equipment/Services/Utilities
Task 10 Intermediate Design
Task 11 Prefmal/Final Design
Task 12 Post-Remedial Design Support
Task 13 Work Assignment Close Out
Remedial Action
Task 1 Project Planning and Support
Task 2 Community Involvement
Task 3 Development and Update of Site-Specific PlansData Acquisition
Task 4 Procurement of Subcontract
Task 5 Management Support
Task 6 Detailed Resident Inspection
Task 7 Cleanup Validation
Task 8 Remedial Action Implementation
Task 9 Project Performance
Task 10 Project Completion and Close Out
Task 11 Work Assignment Close Out
6-4
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Exhibit 6-2
Benefits From Using Standard Tasks
Establishes a common framework for remedial activities among the Regions, Headquarters, and
contractors
Results in cost savings because contractors can prepare Work Plans more efficiently in response
to similarly structured SOWs
Provides a checklist and Work Breakdown Structure (WBS) for work plan negotiations and
tracking activities that are included in the SOW for a work assignment
Enables the development of cost databases to help estimate the cost of future remedial activities
Facilitates the development of SOW templates and, therefore, saves time and resources.
2.2 Use of Standard Tasks in SOWs
The detailed SOW that you develop for an RD will
give the contractor the information needed to plan,
schedule, estimate the cost of, and execute the work.
The SOW must provide adequate detail on the project
requirements so that you and the contractors can
independently develop accurate budgets or cost
estimates.
The recommended approach to establishing project
requirements in the SOW for a work assignment is to
rely on the standard tasks established in the RACs, to
further define these specific activities, and to expand
on site-specific requirements.
2.3 Standard Task Categories
Exhibit 6-1 shows the standard tasks for three (RI/FS,
RD, and RA) of the five Fund-lead work areas found
in the Statement of Work in RACs. Remedial Design
includes the specific activities that occur between the
signing of the Record of Decision (ROD) and the
completion of design activities.
2.4 Using a Standard Task To
Develop a Detailed Task
The examples shown in Exhibits 6-3 and 6-4 on pages
6-6 to 6-7 illustrate the process of using a standard
task to develop the detailed task description for a work
assignment. The standard task is provided exactly as it
appears in the RACs. This task provides a starting
point for developing each detailed task of the SOW.
The standard task is expanded, broken down into
subtasks, and tailored to the specific conditions of the
site. It is important to remember that sufficient detail is
required at the subtask level to provide clear
instructions to the contractor and to facilitate
preparation of the Independent Government Cost
Estimate (IGCE).
2.5 Work Breakdown Structure
A work breakdown structure (WBS) is simply a
numbering system for tasks and subtasks. Use of a
WBS is recommended as the best approach for
organizing the SOW. This approach allows you to
organize the work assignment in the framework of the
standard tasks. From this framework, you can develop
the project schedule and the IGCE. A standard WBS
has been developed for RD SOWs (based on the
RACs standard tasks and the model RD SOW found
in Appendix A) and is used in the examples shown in
Exhibits 6-3 and 6-4.
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Explanation
This text is the standard
task reproduced
verbatim from the
RACS contract SOW.
Exhibit 6-3
Excerpt From Standard Task 1 From RACs SOW
TASK 1 PROJECT PLANNING AND SUPPORT
This task includes work efforts related to project initiation and support. Typical
activities the contractor may be tasked to perform include but are not limited to:
• Attend scoping meeting
• Conduct site visit
• Develop work plan and associated cost estimate
Prepare construction cost estimate
Initiate discussion regarding 6% design limitation
• Negotiate work plan and make necessary revisions as a result of EPA
comments and/or negotiated agreements
Exhibit 6-4
"Detailed" Task 1 From Model SOW (Appendix A)
Explanation
Provide a task overview and
objective.
Location of meetings should be
specified for budgeting
purposes.
A Health and Safety Plan
(HASP) is required for the site
visits.
The purpose of this task is to determine how the site-specific
remediation goals, as specified in the ROD, will be met. The following
activities shall be performed as part of the project planning task:
1.1.1 Attend scoping meeting. Before developing the Work Plan, the
contractor shall attend a scoping meeting to be held at the EPA
Regional Office.
1.1.2 Conduct a site visit. The contractor shall conduct a site visit with
EPA's RPM/WAM during the project planning phase to assist in
developing a conceptual understanding of the RD requirements
for the site. Information gathered during the visit shall be used to
better scope the project and to help determine the extent of
additional data necessary to implement the RD. A Health and
Safety Plan (HASP) is required for the site visit. The contractor
shall prepare a report that documents all EPA, contractor, and
site personnel present at the visit; all decisions made during the
visit; any action items assigned, including person responsible and
due date; any unusual occurrences during the visit; and any
portions of the site that were not accessible to the contractor and
the effect of this on the RD. The contractor shall prepare a trip
report and submit it to the RPM/WAM within 10 calendar days
of the site visit.
(continued on next page)
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To control expenses, limit review to
pertinent documents specific to the
site.
Define scope and schedule
requirements.
Minimize FSP preparation costs by
requiring use of the existing FSP.
Identify if audit will be performed
and specify contractor response
items.
EPA does not approve
contractor's HASP, but reviews it
to ensure that it is complete and
adequately protective.
Exhibit 6-4
"Detailed" Task 1 (Continued)
1.1.3 Evaluate existing data and documents, including the Remedial
Investigation/Feasibility Study (RI/FS), Applicable or Relevant
and Appropriate Requirements (ARARs), the Record of
Decision (ROD), and other data and documents as directed by
the EPA. This information shall be used to determine if any
additional data are needed for RD implementation. The
documents available for review are listed in Attachment 3.
1.1.4 Develop a Work Plan including a schedule and cost estimate for
the RD. Provide confirmation that there is no conflict of interest.
Attend a meeting to negotiate the Work Plan.
1.1.5 After approval of the Work Plan, prepare a Site Management
Plan (SMP) that will provide EPA with a written understanding
of how access, security, contingency procedures, management
responsibilities, and waste disposal are to be handled.
1.1.6 Prepare a Field Sampling Plan (FSP) that defines the sampling
and data collection methods that shall be used for the project. It
shall include sampling objectives, sample locations and
frequency, sampling equipment and procedures, and sample
handling and analysis. The FSP shall be written so that a field
sampling team unfamiliar with the site would be able to gather
the samples and field information required. The FSP developed
for the RI/FS should be used whenever possible in preparing the
FSP for the RD.
1.1.7 Prepare a Quality Assurance Proj ect Plan (QAPP) in
accordance with QAMS-005/80 (December 29, 1980). The
QAPP shall describe the project objectives and organization,
functional activities, and quality assurance/quality control
(QA/QC) protocols that shall be used to achieve the desired
Data Quality Objectives (DQOs). The DQOs shall, at a
minimum, reflect use of analytical methods (for identifying
contamination and addressing contamination) consistent with the
levels for remedial action objectives identified in the National
Contingency Plan.
1.1.8 Prepare a site-specific Health and Safety Plan (HASP) that
specifies employee training, protective equipment, medical
surveillance requirements, standard operating procedures, and a
contingency plan in accordance with 29 CFR 1910.120 1(1) and
(1)(2). Use the HASP developed for the RI/FS, whenever
possible, in preparing the HASP for the RD. A task-specific
HASP must also be prepared to address health and safety
requirements for site visits.
1.1.9 Perform site-specific management including monitoring of
costs, preparation of Monthly Progress Report, and
preparation and submittal of invoices.
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Developing an SOW for Remedial Design
2.6 Completing the Detailed SOW
Develop the detailed SOW for an RD work
assignment task by task from the standard tasks using
the same task numbers (i.e., WBS) as are listed for
the standard tasks. If a standard task is not needed for
a particular work assignment (e.g., if intermediate
design is not required for a given RD), the numbering
order should be kept intact and the words "omitted" or
"not used" inserted after the task number.
Expand each standard task to provide the level of
detail shown for our example. A model SOW for RD
is provided as Appendix A of this Guidance. The
purpose of this model SOW is to give you an effective
tool for ensuring development of consistent and
appropriate SOWs. Model SOWs are also available
from Project Officers in most Regional Offices. There
is an IGCE Coordinator in each Regional Office who
can confirm that the level of detail used for tasks in the
SOW is sufficient to allow preparation of the IGCE.
The IGCE Coordinator can also be called on to review
the detailed tasks for completeness.
Clear, detailed SOWs using standard tasks result in an
understanding of project requirements. Planning the
project in advance through a detailed SOW provides
benefits such as the occurrence of fewer problems
later in the project and the ability to track costs and
schedules for use in estimating future work.
ENFORCEMENT-LEAD DESIGN
Background
The purpose of this section on Enforcement-lead
design is to give you general guidance for developing a
site-specific, project-specific SOW for remedial
design. The Guidance will address only the
preparation of the SOW that is an attachment to a
Consent Decree (CD) for RD. The Guidance does not
address the preparation of a remedial design SOW for
use with either a Unilateral Administrative Order
(UAO) or an Administrative Order on Consent
(AOC).
The Consent Decree
After the ROD is signed, EPA will attempt to
negotiate a CD, an agreement with the Potentially
Responsible Parties (PRPs) for them to implement
the remedy selected in the ROD. If the negotiations
are successful, the site will be a PRP-financed site.
This scenario is often referred to as an
Enforcement-lead project. If the negotiations are not
successful, the site will be a Fund-financed site (i.e.,
EPA will manage and fund the project).
For Enforcement-lead sites, EPA enters into a CD
with the PRPs, at which time the parties become the
Settling Defendants. The CD—the primary
enforcement document for EPA—specifies the
responsibilities of the Settling Defendants for
implementing an RD project. Major components of the
CD include the ROD and the SOW. The SOW
specifies the tasks, activities, and submittals that must
be completed to fully implement the selected remedy
for the site.
Roles and Responsibilities
Key individuals who understand their corresponding
roles and responsibilities during an RD/RA project are
necessary for project success. As the EPA
representative, you are primarily responsible for
developing the SOW, for defining the necessary tasks
and submittals, and for overseeing the Settling
Defendants' activities in the implementation of an
RD/RA project. To fulfill this role, you must have a
clear understanding of EPA's role in an
Enforcement-lead RD/RA project. If State personnel
or other parties are involved, the responsibilities of
each of these parties must also be understood and
addressed.
The Settling Defendants, responsible for day-to-day
management of the RD/RA project, must have a clear
understanding of the technical and administrative
requirements for implementing an RD/RA project.
Under the terms specified in the CD, the Settling
Defendants are required to identify the names and
professional qualifications of the key individuals (such
as the Supervising Contractor) representing the
Settling Defendants, and to provide this information to
you for approval. Furthermore, the detailed Work
Plans that the Settling Defendants are required to
submit at the start of the RD and RA phases of the
project must formally document the roles and
responsibilities of all key individuals involved.
As you can see, delineating the roles and
responsibilities of the key individuals representing EPA
and the Settling Defendants is critical to ensuring
effective implementation and oversight of
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the RD/RA tasks. A more complete discussion of
these respective roles follows. Additional guidance on
roles and responsibilities in an Enforcement-lead
RD/RA project can be found in the Super fund
Guidance on EPA Oversight of Remedial Designs
and Remedial Actions Performed by Potentially
Responsible Parties (April 1990).
1. RPM's Role: Oversight
As RPM, you have the overall responsibility for
ensuring that the Settling Defendants satisfy the
requirements of the CD and the SOW. To accomplish
this, you are responsible for drafting the final SOW
and reviewing and approving submittals specified in the
SOW. EPA's approval of a submittal or activity is
intended to ensure that the RD/RA tasks are
implemented in a manner that is consistent with the
selected remedy in the ROD.
In developing an SOW, you will identify these items:
• The RD tasks that are relevant to the
specific project (not all projects will
require every task that is listed in the
model SOW)
• The major submittals (plans, drawings,
reports) associated with each of these
tasks
• A delivery schedule for all required
submittals prepared and executed by the
Settling Defendants
It is critical that you develop a clear and
comprehensive SOW that is specific to the site and to
the remedy selected in the ROD. This enables you (1)
to effectively monitor and oversee the Settling
Defendants' activities in implementing the RD project,
and (2) to enforce the requirements of the CD and the
SOW.
As mentioned previously, a clear and concise SOW
should alleviate many potential problems that could
otherwise result from misunderstandings either in
terminology or in schedule dates for submittals.
However, even the best-written SOW might not
address everything that can arise. Once the SOW is
final, it is critical that you meet with the Settling
Defendants to discuss both the SOW and details of the
RD task requirements. This meeting will ensure that all
parties clearly understand their respective roles and
responsibilities and will allow questions to be answered
immediately. Finally, the meeting also provides an
opportunity for you and the Settling Defendants'
Project Coordinator to meet and establish rapport.
You will be assisted in the oversight role by an
Oversight Official. The Oversight Official is generally
tasked by EPA to give you technical support in
reviewing submittals and monitoring on-site activities.
We recommend using other Federal agencies (e.g.,
USAGE) to help with oversight. See Chapter 7 for
more detail on oversight of RD performance by the
Settling Defendants.
You may rely on other EPA or State agency staff for
technical and administrative support, if needed. These
individuals are not considered key personnel but may
play a role in the RD project.
You will determine the precise responsibilities of key
project individuals based on the scope of the RD
project. A summary of the roles and responsibilities
and reporting relationships of key individuals are
provided in Exhibits 6-5 and 6-6, respectively.
2. Settling Defendants' Role:
Implementation
Although EPA reviews and approves submittals
throughout the RD/RA project, the ultimate
responsibility for implementation of the selected
remedy lies with the Settling Defendants. EPA review
and approval of your Work Plan or design is merely a
statement on acceptability with regard to RA goals in
accordance with the ROD and the CD; it in no way
guarantees the success of the design in meeting the
specified performance standards. The Settling
Defendants' Project Coordinator is the focal point for
project management and communication with EPA.
The Project Coordinator handles various
responsibilities: planning, budgeting, selecting
contractors, managing contracts, monitoring the
progress of project activities, and supporting EPA in
community involvement activities.
The Project Coordinator is assisted by a Supervising
Contractor who is responsible for the technical
requirements of the RD project. All other contractors
and subcontractors report to the Supervising
Contractor, including the RD professional (lead
contractor for implementing the RD).
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Developing an SOW for Remedial Design
The QA Official, designated by the Project
Coordinator, ensures that QA procedures and
requirements are established and met. In this role, the
QA Official routinely interacts with the supervising
contractor. Quality Assurance comprises plans and
actions, identified by the Project Coordinator, to ensure
that the remedy meets the project requirements.
Developing an Enforcement-Lead SOW for RD
The Enforcement-lead SOW is a written document
that you develop to define the scope of the RD project
activities that will be undertaken by the Settling
Defendants to meet the requirements of the CD.
Ultimately, the SOW will specify the scope of each
task and any associated activities required to
implement the remedy selected in the ROD.
The SOW should identify the extent of the Settling
Defendants' obligations for each task and activity. The
Settling Defendants will use the SOW to prepare the
RD Work Plan and other specified submittals
necessary to implement the selected remedy. Also,
because these submittals are critical to your evaluation
of the performance of the Settling Defendants in
meeting their obligations under the CD and SOW, the
SOW must specify the outcome of each task and all
required submittals.
The "performance standards" section includes cleanup
standards, standards of control, quality criteria, and
other substantive requirements, criteria, or limitations,
including all ARARs set forth in the ROD. To help
ensure enforceability, this section must be well written,
clear, and concise. This section should list all ARARs
from the ROD, provide all cleanup goal criteria or
standards from tables or charts in the ROD, and
provide a complete description of all RA objectives
and remediation goals provided in the ROD.
You should clearly identify performance requirements
to be met by the Settling Defendants, as well as
EPA's role in the attainment of the performance
standards (e.g., EPA shall confirm that the Settling
Defendants met the cleanup standard numbers by . .
.). The performance standards in the ROD, SOW, and
CD must be consistent.
If the ROD is well written and comprehensive, much
of the information on performance standards can be
lifted directly from the document with minimal change.
If any ARARs or performance standards in the ROD
require clarification, the SOW should resolve any
discrepancies or ambiguities in an enforceable way.
However, in all cases, the performance standards
listed in the SOW must be consistent with the ROD
(unless EPA is contemplating a ROD amendment or
Explanation of Significant Differences (BSD), in which
case the standards should be consistent with the
revised ROD).
A poorly written SOW can cause serious
communication problems between EPA and the
Settling Defendants. Ambiguity can result in
misunderstandings and the execution of activities that
do not conform to the CD and SOW. These
misunderstandings can also produce incomplete
submittals, schedule delays, and disputes—possibly
requiring resolution in court.
Enforcement-lead model SOWs have been developed
by each Regional Office; we recommend that you use
the one preferred by your management. Compare the
technical content of the preferred Regional SOW with
the model SOW for Fund-lead RD (in Appendix A) as
a check for completeness. Besides using Regional
model SOWs, canvass the Region (and possibly other
Regions) for recent SOWs written for similar
remedies.
6-10
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Chapter 6
Exhibit 6-5
Superfund RD/RA Project Roles and Responsibilities
(Enforcement-Lead)
Title
EPA Project
Coordinator/Remedial
Project Manager (RPM)
Settling Defendants'
Project Coordinator
Settling Defendants'
Alternate Project
Coordinator
Supervising Contractor
Remedial Design
Professional (Designer)
Remedial Action
Contractor
Quality Assurance
Official
Oversight Official
Designated by
EPA
Settling Defendants
Settling Defendants
Settling Defendants
Settling Defendants
Settling Defendants
Settling Defendants
EPA
Role
Oversee and monitor
compliance
Manage project
Assist Settling
Defendants Project
Coordinator
Principal Contractor
to supervise and
direct RD/RA
Implement remedial
design tasks
Implement remedial
action tasks
Implement
Construction Quality
Control Program
Monitor compliance
for RPM
Major Responsibilities
• Documents and maintains administrative
record
• Coordinates EPA review of designs and plans
prepared by Settling Defendants
• Implements Community Relations Plan
• Coordinates Implementation of remedial
design/remedial action (RD/RA) tasks
• Manages budget, schedule, and contracts
• Supports EPA's Community Relations
activities
• Prepares and reviews RD/RA plans
• Communicates with EPA on progress of
RD/RA Implementation
• As assigned by Settling Defendants' Project
Coordinator
Supervises implementation of all RD/RA tasks
Defines subtasks of RD/RA necessary to
Implement the RD/RA
Functions as the lead contractor at the site
Scopes out other contractors needed
Directs remedial design professional
Directs remedial action contractor
Supervises the implementation of all RD/RA
plans
• Conducts Value Engineering analysis
• Prepares design plans and specifications
• Implements field sampling and treatabillty
studies (as needed)
• Directs and oversees construction activities
• Maintains records
• Conducts Inspections and testing
• Examines and tests materials, procedures,
and equipment during construction
• Implements Quality Assurance programs
• Evaluates professional qualifications of
Setting Defendants' professional staff
• Reviews technical report and plans
• Monitors activities of the Quality Assurance
Official
• Reviews and approves Construction Quality
Assurance Project Plan
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Developing an SOW for Remedial Design
Exhibit 6-6
Relationships Among Parties During Enforcement-Lead RD/RA
t
t
Remedial Design
Professional
RPM
Settling
Defendants'
Project
Coordinator
Sen
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Super
Contr
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vising
actor
Quality
Assurance
Official
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Remedial
Action
Contractor
Legend: solid line = formal relationship; broken line = informal communication.
6-12
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CHAPTER 7
DEVELOPING A STATEMENT OF WORK
FOR REMEDIAL DESIGN OVERSIGHT
CHAPTER OVERVIEW
Remedial design (RD) oversight involves monitoring
remedial design activities to ensure that the Settling
Defendants comply with the Consent Decree (CD),
Statement of Work (SOW), and applicable regulations
(e.g., performance standards, permit limitations, and
regulatory requirements). The overall objective of
oversight is to focus your efforts as Remedial Project
Manager (RPM) on environmental protection,
consideration of public health concerns, overall project
quality, scheduling, major changes based on changed
field conditions, emergency actions, the preparation of
design documents, and project closeout. While you
have oversight responsibility, and ideally use the
technical review team, you may choose to task another
Federal agency or a remedial contractor to carry out
certain oversight activities to lessen the workload and
to gain the needed technical expertise of the
contractor. When developing a site-specific SOW for
RD oversight by a remedial contractor or other
Federal agency, it is your responsibility to establish the
appropriate level of oversight for the project.
ROLES AND RESPONSIBILITIES
Remedial Project Manager's Role
It is your responsibility to oversee the Settling
Defendants' activities and to monitor compliance with
all RD requirements included by incorporation or
reference within the CD.
Depending on the complexity of the RD activities, the
level of involvement in oversight varies in terms of
what you deem necessary to perform adequate
oversight. However, in most instances, you will ensure
that EPA and its representatives review RD submittals
(e.g., Work Plan, Health and Safety Plan (HASP),
Quality Assurance Project Plan (QAPP), preliminary
design package).
You should use a high level of oversight at the
beginning of the RD, determined by requirements
specified in the CD, the complexity of the RD, past
performance of the Settling Defendants, the
qualifications of the Settling Defendant's design team,
and any other relevant factors affecting the RD and
the implementation of the remedial action (RA). The
level of this oversight may then be adjusted
accordingly as implementation proceeds, based on the
performance of the Remedial Designer.
You may choose to obtain the services of an Oversight
Official to assist in carrying out some of the oversight
activities. The Oversight Official functions under some
form of contractual (in the case where work is
assigned to a remedial contractor) or interagency
agreement with EPA and reports directly to you.
During RD, you should initiate the following oversight
activities to be carried out with the help of an
Oversight Official:
• Conduct periodic progress meetings with the
Settling Defendants to address the status of
project design activities, schedule changes, test
results, observations and findings, issues of
noncompliance, and upcoming activities. The
frequency of the meetings depends on the
environmental significance of site activities
and the level of oversight desired. (Generally,
the frequency will be spelled out in the CD.)
• Verify that data collection activities are not
endangering public health and that the
Contingency Plan is implemented in the event
of an accident or emergency.
• Monitor the RD Quality Assurance (QA)
program, including review of the sampling
results and testing and inspection reports
(prepared by the QA official).
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Developing an SOW for RD Oversight
• Coordinate interaction among all Government
entities involved, including State and local
municipalities.
• Enhance community involvement by providing
RD status reports to representatives of the
public or to other agencies.
• Document all contacts with the Settling
Defendants concerning implementation of
theRD.
• Verify that RD tasks are completed.
• Verify that the Settling Defendants are in
compliance. If it is determined that the Settling
Defendants fail to comply, approach the
problem in a constructive manner:
- Identify the problem and devise corrective
actions that are consistent with the CD
- Document all contacts with the Settling
Defendants concerning the inadequacies of
the implementation
- Discuss the proposed corrective action with
Regional management to ensure that there
is a consistent Regional approach in
overseeing the Settling Defendants'
response activities
- If necessary, contact the office of Regional
counsel for advice on how to proceed in the
event that enforcement becomes necessary
Oversight Official's Role
The RD Oversight Official assists you in observing
performance of the work of the design contractor
(designer). The Oversight Official reports to you and
supports you in monitoring compliance with the CD
and the Record of Decision (ROD).
1. Duties and Responsibilities
The responsibilities of the Oversight Official during
remedial design could include the following activities:
Conferences and Meetings:
Attend meetings with the designer (e.g.,
predesign conferences, progress briefings, and
other project-related meetings) and document
all decisions that are made in meetings and
conversations with EPA.
Observation:
Make observations of RD data collection
activities (e.g., field sampling, treatability
study) proceeding in accordance with the RD
Work Plan and the QAPP.
Maintain a diary or log of observations as a
result of site visits.
Modifications:
Evaluate suggestions from the designer and/or
the contracting party for modifications to
drawings and specifications, and report
recommendations to EPA.
Report to the RPM any actions that the RD
contractor or the Settling Defendants take in
interpreting the SOW or ROD documents in a
way that may materially affect either the work
in progress or the original intent of the plans
and specifications.
Submittals:
Review RD contractor submittals including
preliminary, intermediate, and final design
drawings and specifications, and various
documents including the RD Work Plan,
Community Involvement Plan, Site Safety
Plan, Field Sampling and Analysis Plan, and
QAPP. The review should include checking
the documents for conformance with CD,
ROD, standard engineering practices, and
applicable EPA policies, guidance, and
regulations.
Review submittals prepared by the Settling
Defendants at your request.
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7-2
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Chapter 7
Schedules:
Review the progress schedule, and schedule
of submittals prepared by the designer, and
consult with EPA concerning acceptability.
Liaison:
Assist in obtaining (from EPA) additional
details or information when required for proper
execution of the work.
Consult with EPA in advance of scheduled
major tests, site visits, or start of important
phases of the work.
Inspection:
Accompany visiting inspectors representing
the public or other agencies having jurisdiction
over the project; record the results of these
inspections and report them to EPA.
Records:
Maintain orderly files for correspondence,
reports of conferences, review of drawing and
specifications, clarifications and interpretations
of the CD, ROD, progress reports, and other
project-related documents.
Reports:
Review progress reports of the RD contractor
and furnish the RPM with routine reports on
the schedule and progress of work.
Furnish EPA with weekly reports of the
progress of the work and the designer's
compliance with the work schedule and
schedule of submittals.
Safety Concerns:
Immediately notify the authorized
representative of the RD contractor or Settling
Defendants of any observed activities that
present imminent and
substantial endangerment to the public health
or welfare or environment, and follow up with
an appraisal of the situation to the RPM.
Advise EPA as promptly as possible of
discharges and releases that can affect natural
resources or any endangered or threatened
species, or that can result in destruction or
adverse modification of the habitat of such
species.
Report to EPA on the designer's and
contracting party's compliance with on-site
worker health and safety requirements.
Submit pollution reports to EPA as significant
developments occur.
Report any on-site accident immediately to
EPA.
2. Limitations of Authority
The Oversight Official is limited from performing the
following activities:
• Shall not authorize any deviation from the
project documents.
• Shall not undertake any of the responsibilities
of the designer or contracting party.
• Shall not issue directions relative to, or assume
control over, any aspect of the means,
methods, techniques, sequences, or procedures
of design.
• Shall not issue directions regarding, or assume
control over, safety precautions and programs
in connection with site visits by the designer.
• Shall not accept submittals from anyone other
than the contracting party.
• Shall not participate in specialized field or
laboratory tests or inspections conducted by
others.
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Developing an SOW for RD Oversight
DEVELOPING AN SOW FOR RD
OVERSIGHT
The SOW included in each of the RACs (Response
Action Contracts) contains a work area for RD/RA
oversight. From this work area a more detailed Model
SOW that clearly denotes the activities to be
performed by the contractor has been developed and is
included in Appendix E of this guidance. As explained
in Chapter 6, you should prepare a detailed
site-specific SOW, using the Model RD Oversight
SOW, that incorporates a work breakdown structure
(or numbering system for tasks and subtasks).
The purpose of the Model SOW is to give you an
effective tool for ensuring the development of
consistent and appropriate SOWs for RD oversight.
The Model SOW and work breakdown structure
should be used as the framework for developing a
detailed, site-specific SOW that describes the duties
and responsibilities of the Oversight Official as listed
earlier in this chapter. There is an Independent
Government Cost Estimate (IGCE) Coordinator in
each Regional office who should be asked to confirm
that the level of detail used for tasks in the SOW is
sufficient to allow preparation of the IGCE.
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