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APPENDIX H: Technical Direction Document Preparation and Processing OSWER Directive 9360.0-16a Guidance for Conducting Federal-Lead Underground Storage Tank Corrective Actions July 25, 1988

OSWER DIRECTIVE 9360.0-16A

When the need arises for technical services during a Federal-lead UST corrective action, a Technical Direction Document (TTD) should be issued to activate the Technical Assistance Team (TAT) contractor. This appendix presents a detailed description of the process, including an explanation of the TDD form used to document the initiation of services and a description of EPA and contractor roles and responsibilities in managing and implementing the process. The following are addressed:

The procedures described in this appendix apply to both TAT zone contracts; however, the specific instructions on completing the TDD form directly relate to the sample TDD forms used in TAT zone 1 (EPA Regions I-V) and in TAT zone 2 (EPA Regions VI-X).

A. TDD Completion and Processing Instructions

When a need for TAT contractor services arises, the Headquarters Project Officer (PO), or Regional Deputy Project Officer (DPO) with PO concurrence, prepares and issues a written TDD, which serves as the principal mechanism for initiating these services. Where practicable, the DPO should confer with the Regional UST Coordinator prior to issuance of the TDD. An oral TDD may be issued, but must always be followed by a written TDD within five (5) calendar days. Thee TDD includes background data, the scope of work to be performed, a schedule of deliverables, and estimate of time and costs required to perform the work, and other related information.

Only the DPO or PO is authorized to prepare and issue TDDs to the contractor TAT leader. The TAT may not act on an UST corrective action without the specific concurrence of the PO. Each DPO can issue TDDs only to the TAT leader assigned to that particular DPO's Region. For example, the Region I DPO can issue TDDs only to the TAT leader assigned to Region I. TDDs can also be issued by the PO to the appropriate TAT contractor Zone Program Manager (ZPM) for special ZPM efforts within the contract Statement of Work (SOW).

1. TDD Completion.

A sample TDD form that has been used in TAT zone 1 is shown in Exhibit H-1; Exhibit H-2 shows a TDD form used in TAT zone 2. Each of the elements on the TDD should be completed by the DPO as explained below.

The DPO should keep in mind three important points while preparing a TDD. First, the DPO must be as specific as possible in descending the scope of work to be performed by the TAT. Second, the DPO must clearly indicate contractor reporting requirements. And, finally, it is extremely important that the DPO include in the TDD estimates for technical hours and costs needed to accomplish the assignment.

Although exact tasks and response activities, particularly those involving emergency situations, may be somewhat difficult to define, it is very important to the extent possible to provide specific guidance to the contractor on the expected work scope (see Exhibit H-q, Boxes 4A and 10 -13). The task description should be as detailed as available information permits so that there is a clear understanding by the TAT contractor of the activity objective, yet allow some flexibility for alternative and innovative actions by the contractor as conditions warrant. Examples of candidate tasks which could be performed for different types of response, corrective action, or prevention work can be extracted directly from the TAT contract Statement of Work (SOW).

Care must be taken by the DPO and TAT Leader to ensure that all tasks requested and performed are within the bounds of the TAT contract SOW. Particular attention must be given to ensure that TAT TDDs do not involve personal services. For example, the DPO must not direct the TAT to provide clerical support, travel arrangements, or other personal services for EPA staff. The DPO is also forbidden from specifying an individual TAT member to perform a task. Specific TAT staffing decisions are the responsibility of the TAT contractor.

The tasks include in any one activity will depend upon the project-specific conditions. It may prove useful for the Region to develop standardized work scopes for an activity and to use this scope (modified as necessary for a specific situation) as an attachment to the TDD.

In addition, the TDD reporting requirements (Box 11) must be spelled out such that the work product provides the degree of detail desired by the DPO and therefore facilitates accomplishment of the activity objectives. The DPO may wish to develop standard report outlines for various types of activities (i.e., facility inspection reports) and to attach these to the TDD as appropriate.

Finally, the DPO is responsible for ensuring that an estimate of technical hours and costs needed to accomplish the TDD assignment is included in the TDD. These estimates may be used in three important ways to ensure that the TAT performs efficiently. First, these estimates can serve as the basis for individual TDDs. The actual hours and costs can then be compared with the estimates. Any large differences between the figures may be indicative of problems and should be reviewed by the DPO. Second, the estimated hours, used in combination with the estimated completion date, can help to identify the need for overtime to complete the task. Since the contract limits the overtime which may be charged, overtime must be monitored.The third use for the estimate of technical hours is to provide the basis for comparison of total estimated hours for all active TDDs with the total technical hours available. Total technical hours available can be computed from the information in the contract. The difference between the two figures will tell the DPO to what extent available contractor resources are being utilized. The TAT contractor can also provide this information on a regular basis (e.g., biweekly).

2. TDD processing.

After the TDD is completed, it is signed by the DPO or the DPO's designee and forwarded to the contractor TAT Leader. (When the DPO plans to be out of the office and unavailable to perform contract management functions, the DPO must submit a written request, or telephone the PO and CO, for approval to appoint a temporary assistant DPO; this request must be for a discrete period of time.) The PO must also be notified by the DPO for concurrence with the TDD. The PO will convey concurrence to the ZPM, who will communicate this concurrence to the TAT leader as soon as possible. The contractor TAT Leader can take one of three actions on the TDD:

When the TDD is acceptable to both the TAT Leader and the DPO, it should be signed and dated. Appropriate copies should be placed in the contractor's and EPA's central TDD files. The DPO should then send copies of the TDD to the PO, CO, and the Regional UST Coordinator.

B. TDD Amendments

In the event that an issued TDD needs revision, the DPO must issue a TDD amendment containing the appropriate changes. Events that require TDD amendments may include, for example, an original underestimation of a project's magnitude or an acceleration of a project's period of performance. The original TDD's number will be used, with a check in the "Amendment" blank (Box 2). The revised TDD should include the material contained in the original TDD and the revised information so as to be capable of standing alone. Amendments are to be processed in the same manner as described above.

C. Special Project TDDs

Funding has been obligated for the performance of special projects under the TAT contracts. All TAT Special Projects TDDs for Federal-lead UST corrective actions must be signed and issued by the appropriate PO, after conferring with the Regional UST Coordinator. If a special project is required, the PO may request that the ZPM prepare and submit a work plan and cost estimate for completing the TDD. The TAT contractor's work plan should include a detailed technical approach, schedule for completion, and cost breakdown. It should be sufficiently detailed to provide a base for guiding work, measuring progress, and controlling budgets. The contractor work plan should address the elements specified below:

Upon review of the plan, the PO will approve and issue the TDD.

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