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:
- TDD completion and processing;
- TDD amendments; and
- Special Project TDDs.
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).
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.
- Cost Center (Box 1A) : Enter the number of the TAT Region that is being issued the TDD; in the sample, 07 is entered to indicate Region VII.
- Account Number (Box 1B) : Leave blank; to be filled in by the TAT contractor.
- TDD Number (Box 2) : Enter this serial number which identifies the TAT Region in which the TDD is issued, the calendar year and month, and the sequence number of the TDD issued that month. For example, the number 07-8701-03 is interpreted as follows: 07 refers to the TAT location in Region VII; 87 refers to the calendar year in which the TDD is issued; 01 is the month the TDD is issued; and 03 indicates that this is the third TDD issued in the month of January. If the TDD amends an earlier TDD, check the "Amendment" blank.
- Priority (Box 3A) : Check the box corresponding to the priority of the request. The priority should reflect whether an immediate action is required (high priority), an action is to be taken within a definite time period (medium priority), or an action is to be taken within a flexible time period (low priority).
- Key EPA Contact (Box 3B) : Enter the name and telephone number of the EPA person directly involved with overseeing and managing contractor performance of the task. This will typically be the OSC.
- Estimate of Total Hours (Box 4A) : Enter an estimate of the technical labor hours needed to accomplish the TDD assignment. The estimate should be based on best engineering judgment considering knowledge of the project or task requirements, data needs, and previous experience on similar project.
- Estimate of Total Costs (Box 4A) : Enter an estimate of the total cost including direct labor, travel, expenses, and subcontracting.
- Overtime Approved (Box 4B) : The DPO must specify whether overtime hours are allowable for the task outlined in the TDD by checking the appropriate box.
- EPA Site Name (Box 5A) : Self-explanatory; if not applicable enter N/A.
- SSID No. (Box 5B) : UST sites must be numbered to allow cost recovery; see page 2 of Attachment I to the Comptroller's Policy Announcement No. 87-13 (Appendix I of this guidance). Contact the Regional Financial Management Officer and ERD Regional Coordinator for more information on assigning a site-specific ID number.
- City/Count/State (Box 5C) : Enter the location of the UST site; if not known, this can be entered by the contractor. If not applicable enter N/A.
- Source of Funds (Box 6) : Check the UST box.
- Complete Date (Box 7) : Enter the date specified by the DPO for the TAT contractor submittal of the completed TDD assignment. Completion dates must not be left open.
- Reference Info (Box 8) : This item allows the DPO to provide the TAT contractor with any reference materials or supplemental information necessary to expedite TDD completion. At the same time, accountable control of such information is maintained. Check the most applicable box.
- Type of Activity (Box 9) : Check the UST box.
- General Task Description (Box 10) : In this
section, enter a description of the task requirements
that indicates the following:
- The type of support desired;
- The level of intensity required (the depth to which certain issues should be pursued); and
- Any other pertinent information.
The task description must clearly delineate the goals and objectives of the activity and the desired products and/or deliverables. Ambiguous phrases such as "assist OSC" are not sufficient. Where no interim task objectives are present, continuation of the general task description can be made into Box 12. Where interim task objectives are present, continuation of the general task description should be made on a separate sheet of paper that can be attached to the TDD.
- Desired Report Form (Box 111) : The DPO should indicate the type of end product desired for the TDD assignment. Additional information can be provided in Box 12 or by attaching additional sheets to the TDD.
- Specific Elements (Box 12) : In this section, elaborate on the general task description and define interim task objectives. This section should provide the TAT Leader with a clear understanding of the objectives, expected results, and required deliverables and/or reports. If more space is needed, the continuation of the description of specific task elements should be made on a separate sheet of paper that can be attached to the TDD.
- Interim Deadlines (Box 13( : Denote completion dates, where applicable, for the interim task objectives that are specified on corresponding lines in Box 12.
- Signatures and Dates (Boxes 14 - 17) : These sections are self-explanatory. The TDDs are to be issued and signed by the PO (or DPO with PO concurrence) and received and signed by the contractor TAT Leader. If the TAT :Leader judges the TDD to be our of scope, or for other reasons unacceptable, the appropriate box must be checked to show the action. This is necessary to bring the matter to the attention of the DPO, PO, Regional UST Coordinator, and Headquarters Contracting Officer (CO). An appropriate explanation can be noted on the right-hand margin of the form.
- Distribution: copies of the TDD should be distributed as specified on the bottom of the form, plus an additional copy to the Regional UST Coordinator.
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).
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:
- If the TDD is acceptable to the contractor TAT Leader as issued by the DPO, the TAT Leader signs the TDD and proceeds with performance of the assigned activities. In general, the TAT contractor should be willing to accept any assignment within the bounds of the TAT contract SOW. However, as stated earlier, conducting personal services for EPA staff is not allowed.
- The TAT leader can accept the TDD with exceptions. In this case, the exceptions are to be noted on the form and a copy is returned to the DPO. The DPO and TAT Leader are to resolve these exceptions prior to the contractor commencing work. If necessary, a revised TDD should be issued reflecting resolution of any exceptions. If the issue cannot be resolved on this level, the DPO should consult with the PO in Headquarters for guidance. If necessary, the PO will consult with the contractor ZPM to try to resolve the situation. If it is resolved, the DPO may issue a revised TDD reflecting the issue resolution and the contractor will proceed with task performance. If the PO and contractor ZPM cannot resolve the issue, the matter is referred to the CO for final resolution. Where possible, and with concurrence of the DPO, the contractor should begin work on the acceptable work elements of the TDD, pending resolution of the points at issue.
- If the contractor TAT Leader rejects the TDD, it is returned to the DPO with an explanation of the reasons for rejection. The DPO and TAT Leader are to confer to resolve the situation. If a resolution is reached, a revised TDD can be issued, if necessary, and the contractor proceeds with the task. If the DPO and the TAT Leader cannot resolve the problem, the DPO should contact the PO for guidance as explained above.
When the TDD is acceptable to both the TAT Leader and the DPO, it should be signed and dated. Appropriate copies should be placed in the contractor's and EPA's central TDD files. The DPO should then send copies of the TDD to the 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:
- Objectives and scope of the proposed activity and its relationship to other ongoing or planned activities.
- Technical approach for the activity, anticipated problems, and proposed solutions.
- Detailed breakdown of tasks to be performed.
- Description of work to be performed under each task, including objectives and scope, information sources, and methods to be used.
- Analysis of resources (level) expected for each task.
- Anticipated total labor cost for each task.
- Identification and tabulation of total direct costs for each major work element.
- Schedule, including critical path and milestones.
- Listing and schedule of deliverables.
- Safety and contingency measures.
- Safety and contingency measures.
Upon review of the plan, the PO will approve and issue the TDD.