General EFS FAQs

1. What is an EFS?
2. If a CAP has not been approved for the site, only assessment activities to date have been reimbursed, and I have remaining assessment costs to submit for reimbursement, do I include these costs on the EFS?
3. Does the August 15, 2003 date apply to only sites where a CAP Modification was requested in February 2003?
4. If I have additional assessment activities after a CAP has been approved for the site, do I include these assessment costs on the EFS?
5. If reimbursement requests have been submitted to OPS and have not been approved and paid, and were not included on the EFS form or Appendix D, how will they be processed?
6. Are pilot study costs to be approved prior to installing wells and performing the test?
7. Can the consultant sign the EFS form in lieu of the Owner/Operator?
8. At what stage in the project are assessment costs (i.e. installing a monitoring well) included in the EFS?
9. What if the contractor mobilizes to install wells that were requested by OPS in the CAP request, but also wants to conduct a pilot test at the same time.  How should the costs be coded?
10. If a CAP has been approved before February 1, 2003 but a CAP Modification is needed, should the CAP Modification include an EFS?
11. If excavation activities are conducted during UST removal, prior to an SCR being submitted, do these costs go on the EFS when the CAP is finally submitted?
12. Does OPS want three remediation methods proposed and costed out within the CAP submittal as required by regulation?
13. Does OPS want to pre-approve pilot test (PWC 3A) scope and costs?
14. Should I discuss with the OPS reviewer projected labor hours for Remediation System Design (PWC 3B) and CAP Report Preparation (PWC 3C) prior to preparing the CAP?

1.       What is an EFS?

         The Economic Feasibility Summary (EFS), instituted on February 1, 2003, is a listing of the remediation costs within a Corrective Action Plan (CAP) for a release event.  The EFS Form (MSExcel) and EFS Instructions (MSWord) can be downloaded from the OPS website at http://oil.cdle.state.co.us.  The purpose of the EFS is to allow for standardized submittals, accurate coding and streamlined reviews of all costs submitted in a CAP.  This EFS format replaces all other EFS formats currently included in the OPS CAP format.  For all CAPs, an EFS for the selected remediation method(s) is required to be submitted on this format.  Each EFS will address all impacted media.  The EFS Form contains Phase of Work Codes (PWCs) and allowable Activity Codes (ACs) listed below each Phase of Work Code.  Task/Labor Codes (TLCs) are located in Appendix B of the EFS Form.   Appendix C lists the allowable TLCs for each AC.  If a specific TLC is not listed as appropriate for a particular AC, approval by the OPS reviewer must be granted for its use. 

2.       If a CAP has not been approved for the site, only assessment activities to date have been reimbursed, and I have remaining assessment costs to submit for reimbursement, do I include these costs on the EFS?

         No, do not include these assessment costs on the EFS.  The EFS must include only costs associated with corrective action.  These assessment costs should be submitted in a separate reimbursement application (RAP).

3.       Does the August 15, 2003 date apply to only sites where a CAP Modification was requested in February 2003?

          No.  Beginning August 15, 2003, all reimbursement applications will be held without OPS review if the reimbursements to date have exceeded the total approved costs and a new EFS has not been submitted and approved.

4.       If I have additional assessment activities after a CAP has been approved for the site, do I include these assessment costs on the EFS?

         Yes, these costs should be included in the EFS, although make sure to give a description of the costs on the associated line items (Task and Labor Code) within the EFS.

5.       If reimbursement requests have been submitted to OPS and have not been approved and paid, and were not included on the EFS form or Appendix D, how will they be processed?

          Reimbursement applications will continue to be processed for sites where the paid reimbursements exceed the approved costs until August 15, 2003.  If the EFS has been approved, the costs will be subtracted from the EFS total amount via an E-RAP.  If the EFS has not been approved, an EFS addendum must be submitted to account for these costs.  OPS will combine the EFS addendum with the original EFS.

6.       Are pilot study costs to be approved prior to installing wells and performing the test?

          Yes, get approval through the individual OPS reviewer.

7.       Can the consultant sign the EFS form in lieu of the Owner/Operator?

          After the EFS has been negotiated with OPS, the Owner/Operator must sign the final page(below the Phase of Work Cost Summary table) and fax or mail it to OPS.  The consultant may sign the approved EFS in lieu of the Owner/Operator if OPS has received a document from the Owner/Operator that gives signatory authority to the consultant.

8.       At what stage in the project are assessment costs (i.e. installing a monitoring well) included in the EFS?

         All assessment costs are coded with the Phase of Work (PWC) 2 until the time that a Corrective Action Plan (CAP) is received by OPS.  If a CAP is requested with the condition that additional well(s) be installed, the cost to install these wells and any associated costs should be coded as PWC 2 and submitted on a separate reimbursement package than CAP related costs.  If a CAP has been approved and a CAP Modification has been requested that includes installation of additional wells, these costs should be included in the EFS in PWC 3D, Activity Code (AC) k.  Do not submit PWC 2 and PWC 3 costs in a single RAP.  PWC 2 costs (not on EFS) and PWC 3 costs (on EFS) will only be processed as separate RAPs.

9.       What if the contractor mobilizes to install wells that were requested by OPS in the CAP request, but also wants to conduct a pilot test at the same time.  How should the costs be coded?

         Costs relating to the assessment activities (i.e. well installation) must be separated from costs relating to the pilot test.  The assessment costs will be included in a reimbursement package to be processed the old way.  The pilot test costs will be included in a reimbursement package with an attached E-RAP.

10.     If a CAP has been approved before February 1, 2003 but a CAP Modification is needed, should the CAP Modification include an EFS?

Any modification to or exceedance of costs of a CAP that was approved prior to February 1, 2003 necessitates the submittal of a CAP Modification that includes an EFS for all costs since the end-of-work date in the last reimbursement application submitted through decommissioning activities.  All future reimbursement applications must include an E-RAP that corresponds to costs within the CAP Modification EFS (approved).

11.     If excavation activities are conducted during UST removal, prior to an SCR being submitted, do these costs go on the EFS when the CAP is finally submitted?

         No, these costs would be submitted as Phase of Work 1 or 2 costs, whichever is appropriate.  Costs on the EFS would only reflect remediation activities.  Please note that any excavation activities at a UST removal must be discussed with an OPS reviewer to determine acceptable volumes of contaminated soil to be removed.

12.     Does OPS want three remediation methods proposed and costed out within the CAP submittal as required by regulation?

         The consultant and/or owner/operator should contact the OPS reviewer for the site, prior to submitting the CAP, to discuss possible remedial approaches and to come to an agreement as to which is the most technically and economically feasible approach or approaches.  Unless it is the desire of the OPS reviewer to compare EFSs of more than one technically appropriate scenario, OPS can waive the requirement (Storage Tank Regulations, Article 5-4) that three methods be evaluated and only one selected approach will be included in the CAP.

13.     Does OPS want to pre-approve pilot test (PWC 3A) scope and costs?

         Yes, the consultant and/or owner/operator must contact the OPS reviewer, prior to conducting a pilot test, to discuss the appropriateness of the pilot test.  Once it is agreed that the pilot test is warranted, a scope summary and an EFS form must be submitted with pilot test costs listed in PWC 3A and appropriate activity and task and labor codes.  Following review of the scope and PWC 3A costs, the OPS reviewer will give a verbal or email approval for commencement of the pilot test.  This approval will be also entered into the COSTIS database.

14.     Should I discuss with the OPS reviewer projected labor hours for Remediation System Design (PWC 3B) and CAP Report Preparation (PWC 3C) prior to preparing the CAP?

         Yes; following completion of approved pilot testing the consultant and/or owner/operator should contact the OPS reviewer, prior to preparing the CAP to discuss anticipated PWC 3B and 3C costs.  These costs will reflect the anticipated level-of-effort associated with the remediation method agreed upon by the consultant and OPS.