EP 1110-3-8
9 Apr 04
(2) Litigation or underwriting legal actions such as paying attorney fees or paying for a
technical assistance provider to assist an attorney in preparing a legal action or preparing for and
serving as an expert witness at any legal proceeding regarding or affecting the FUDS property.
(3) Political activity and lobbying as defined by OMB Circular A-122, "Cost Principles for
Non-Profit Organizations."
(4) Other activities inconsistent with the cost principles stated in OMB Circular A-122.
(5) Generation of new primary sampling data, such as well drilling and split sampling.
(Note: USACE, in coordination with the regulatory agencies, is responsible for developing
investigation strategies to ensure that potential contaminants and explosives safety hazards are
adequately characterized. If the RAB or TRC members identify a circumstance where they feel
that additional data collection may be necessary, these concerns should be communicated to the
USACE Co-Chair of the RAB or TRC or to the appropriate regulatory agency for evaluation.)
(6) Disputes with USACE over remedy selection or any other aspects of the restoration
program, or to reopen final Army CERCLA decisions, such as RODs, or conducting disputes
with USACE.
(7) Epidemiological or health studies, such as blood or urine testing.
(8) Community outreach efforts, such as reproducing reports, conducting FUDS property
tours, renting meeting rooms, and distributing newsletters.
d. TAPP Process.
(1) Step One - Identification of Need. When RAB/TRC community members initially
determine a desire for independent technical assistance, they must demonstrate that the technical
expertise necessary for the proposed project is not available through the Federal, state, or local
agencies responsible for overseeing environmental restoration at the FUDS property or that the
selection of an alternate provider will contribute to the environmental restoration activities and
the community acceptance of these activities. In determining if the technical assistance may
already be available, the RAB/TRC community members must first consider the following
sources of assistance:
(a) Federal and state environmental regulatory agency personnel responsible for
overseeing the environmental restoration program at the FUDS property (e.g., EPA Technical
Assistance Grant (TAG) or Technical Outreach Services to Communities(TOSC) support). (If
the FUDS property has been listed on the NPL, the public will be informed of the availability of
TAGs, which are awarded and managed by EPA regional offices. If the FUDS property has not
been listed on the NPL, the public will be made aware of the availability of TOSC support.)
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