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H-GAC 2019 Webinar/Workshop Series

Preparedness for Debris Operations

WEBINAR DATE:MAY 15, 2019

TIME:10:00 A.M. TO 11:30 A.M.

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H-GAC 2019 Webinar/Workshop Series

Date Event TopicsMay 15, 2019 Webinar Debris Management Preparedness.July 30, 2019 Webinar Wildfire, Tornadoes, Terrorism and

Other Debris Generating Incidents.August 16. 2019 Workshop Disaster debris affects on landfills.

Recommendations from the Governor's Commission to Rebuild Texas.Lessons learned and trends.Changes to regulations and guidance.

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Agenda

• Identification and evaluation of debris management sites

• Identification of priority facilities and roads for road clearing

• Establishment of prepositioned contracts for debris hauling and monitoring services

• Development and maintenance of disaster debris management plans

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Part 1: Identification and Evaluation of Temporary Debris Management Sites (DMS)

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• Temporarily store, process, and reduce debris before it is transported to a final disposal facility.

DMS Purpose

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• Publicly owned versus privately owned property• 5+ acres • Proximity to high population density• Ease of ingress and egress• Reduction method to be used• Proximity to natural running water or water

wells• Adherence to local, state, and federal

regulations

Considerations in Selecting a DMS

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• Must send request for approval form to the Texas Commission on Environmental Quality (TCEQ) Regional Office prior to use of a site as a TDMS.

State Approval of DMS

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• Prepare DMS based on concentration of debris:If necessary, get any

needed property use agreements.Get TCEQ approval.Photograph the site.Record physical features.Conduct a historical

evaluation.If necessary, collect soil

and water samples.

Preparation of a DMS

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Reduction Methods

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Reduction via Open Burning

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Reduction via Air-Curtain Incineration

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Reduction via Grinding

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Removal of Refrigerants from White Goods Prior to Recycling

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Construction and Demolition Storing and Reduction

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Site Organization

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DMS Operations

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Debris Diverted from Waste Stream

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Restore Site to Condition Prior to Use as a DMS

• Haul out reduced and processed debris.• Remove processing equipment, storage tanks,

protection berms, and other structures built on the site.

• Take samples at the same locations as those of the initial assessment.

• Remediate any contamination that may have taken place during TDMS operations.

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DMS Prep and Site Restoration Costs

• Understand who is responsible for the costs of DMS prep and restoration.

• Costs are reimbursable to the jurisdiction.• FEMA may not reimburse the jurisdiction if the

debris hauler contract states the debris hauler is responsible for the costs of the prep and restoration of the DMS.

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Part 2: Creation of a Priority Facilities and Roads List

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Purpose for the Priority Facilities and Roads List

• Serves as a tool to aid in prioritizing roads for emergency road clearing and debris collection activities following a debris-generating incident.

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Priority Roads• Priority roads are deemed as such based on

many considerations, including:Size Proximity to adjacent citizen populations Critical facility locations Ingress/egress capabilities for the community

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Potential Critical Facilities• Hospitals• EMS, Fire, and Police Stations• Nursing Facilities• Emergency Operations Centers• Water/Wastewater Treatment

Facilities• Electrical Utility Facilities• Communications Facilities• Public Works Facilities• Shelters

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Maintaining the List

• Verify the list annually.• Provide the list to jurisdiction staff responsible

for road clearing and/or to the debris contractor.

• Back up the list, along with jurisdictional boundaries, to a USB drive or other portable device to ensure it will be available in the event of a disaster.

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Part 3: Prepositioned Contracts For Debris Hauling and Monitoring Services

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The Value of Prepositioned Contracts

• Identifying prequalified contractors and contracting needs in advance can save time and money during disaster response efforts.

• After a major disaster, multiple communities may be competing for the same resources, which may be limited.

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Available resources

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• FEMA Established the Procurement Disaster Assistance Team (PDAT) to provide assistance to grantees and subgrantees after disasters

• Training is available• Review of contracts may be

requested– CMAR– Cooperative Purchasing– Single Source

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Getting Started• Applicants must comply with Federal

procurement standards as a condition of receiving Public Assistance (PA) funding for contract costs for eligible work.

• Procurement standards can be found in 2 CFR 200.

• Solicit a request for proposals for disaster debris services for specific contract provisions.

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Solicitation for Prequalified Contractors Should Include:

• Adequately defined scope of work

• All potential debris types• Anticipated haul distances• Potential size of debris events • Hourly labor, equipment, and

material price schedule• Performance bond

requirements

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Qualify Bidders • Licenses• Financial stability• Proof of insurance• Bonding capability• Description of related experience and capabilities,

including total verified cubic yards removed and processed

• References, including jurisdiction name, point of contact, email address, and phone number

• Description of health and safety plan, including operation plan at debris management site(s)

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• Primary types of compensation• Unit pricing• Time & Materials• Lump Sum

• Scopes of work will dictate your contract• Must demonstrate you have control of costs

• Not to exceed• Reconciliation/Audit of documentation

• May request retainage

ContractorCompensation

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Check for Disbarred Contractors

• Contractors that have been declared debarred by the Office of Federal Contract Compliance Programs (OFCCP) should not be considered.

• A complete list of federally disbarred contractors can be found in the System for Award Management (SAM) dataset at www.sam.gov.

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Contracting Procedures

• Ensure compliance with the jurisdiction’s procurement procedures.

• Ensure compliance with applicable state and local procurement laws and regulations.

• Ensure compliance with federal procurement laws and standards identified in 2 CFR 200.

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Contracting Procedures

• Ensure competition.• Provide a clear and definitive scope of work.• Develop a cost analysis to demonstrate cost

reasonableness for any contract or contract modification where price competition is lacking.

• For mileage based contracts evaluate contracts based on mileage categories.

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Contracting Procedures• Ensure opportunities for minority-owned and

women-owned businesses and firms whenever possible.

• Document the process and rationale the jurisdiction followed in making procurement decisions.

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Review and Document the Process

• Conduct a review of the procurement process and any potential contracts to be awarded to ensure compliance with all federal, state, and local requirements.

• Establish procedures to address protests and disputes related to contract awards.

• Compile all documentation related to the procurement and file in a secure location that can be accessed for future review.

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Major Compliance Issues

• No cost or price analysis• Inadequate (or no) competition• Failure to pursue efforts re socioeconomic

contracting• Ineligible contract type• Inadequate documentation and/or contracting

documents• Missing mandatory clauses• Missing information on pricing

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Part 4: Development and Maintenance of Disaster Debris Management Plans

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• Provide the organizational structure, guidance, and standardized procedures for the clearance, removal, and disposal of debris caused by a major debris-generating event.

Objectives of a DDMP

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Objectives of a DDMP

• Provide debris estimates for key hazards to aid in planning.

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• Outline roles and responsibilities of city, county, state, federal, volunteer, and private agencies with a role in debris management operations.

Objectives of a DDMP

• Public Works• Transportation• Code Enforcement• Finance• Animal Control• Emergency

Management• Public Health

• Public Information• Parks • Administration• Debris Contractors• Debris Monitors• TDEM• TCEQ• TxDOT

• FEMA• Federal Highway

Administration• Office of

Inspector General• U.S. Army Corps

of Engineers• Natural Resources

Conservation Service

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• Provide strategies for public information.

Objectives of a DDMP

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• Identify health and safety processes.

Objectives of a DDMP

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• Identify local resources that can be used in debris management operations.

Objectives of a DDMP

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• Provide guidance for special operations, such as private property debris removal and dangerous trees, to ensure compliance with PA requirements.

Objectives of a DDMP

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• Identify environmental and other regulations that must be considered in conducting debris management operations.

Objectives of a DDMP

• Local Regulations• National Environmental

Policy Act • Resource Conservation

and Recovery Act• National Historic

Preservation Act• Executive Order 12898,

Environmental Justice

• Endangered Species Act• Clean Water Act• Clean Air Act• National Emission Standard

for Hazardous Air Pollutants

• Executive Order 11990, Protection of Wetlands

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• Provide direction in documenting labor hours, activities, equipment use, and expenses so the affected jurisdiction can receive the maximum reimbursement to which they are allowed. Failure to properly document costs can result in the jurisdiction being denied reimbursed for those expenses.

Objectives of a DDMP

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• Having an approved DDMP and a pre-qualified debris removal contractor will allow for an additional 2% increase in the Federal share of debris-related recovery costs for the first 90-days of a debris removal operation following a disaster event.

Benefit of a DDMP

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12 Key Elements of a DDMP

1. Debris Management Plan Overview2. Events and Assumptions3. Debris Collection and Removal4. Temporary Debris Management

Sites and Disposal Locations5. Debris Removal on Private Property6. Use and Procurement of Contracted

Services

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12 Key Elements of a DDMP

7. Use of Force Account Labor8. Monitoring of Debris Operations9. Health and Safety Requirements10.Environmental Considerations and Other

Regulatory Requirements11.Public Information12.Identification of Debris Removal Contractors

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Planning Processes• Form a planning team consisting

of departments and stakeholders with a role in debris operations.

• Assume worst-case scenario.• Identify key resources.• Examine regulatory issues and

considerations.• Review existing emergency plans.• Develop a process for maintaining

and updating the DDMP.

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Case Study• Neither Puerto Rico nor the U.S. Virgin Islands

had comprehensive debris management plans in place before Hurricanes Irma and Maria. As a result:• Illegal dumping sites were created.• Debris accumulated in sensitive areas, such as

floodplains. • Issues with FEMA reimbursement for debris

management costs occurred.

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Conduct Regular Reviews and Updates of the DDMP

• Update capacity information for waste management facilities, including recycling facilities.

• Verify the continued viability of pre-determined temporary debris management sites.

• Add new reuse, recycling, and composting opportunities.

• Update contact information for state, local, and federal officials and waste management facilities.

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Conduct Regular Reviews and Updates of the DDMP

• Incorporate new contracts or agreements. • Document changes in available equipment and

other resources. • Incorporate new residential and commercial

developments. • Change debris types and quantities to

correspond to changes in the community’s character and building stock.

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QUESTIONS?

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Thank You!• Next Webinar – July 30th

Wildfire, Tornadoes, Terrorism and Other Debris Generating Incidents.