United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington DC 20460
Superfund
ARCS Contracts
Users' Manual
EPA540G-89'008
August 1989
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EPA 540/G-89/008
August 1989
ARCS Contracts Users' Manual
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
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Disclaimer
The policies and procedures set forth here are intended as guidance to Agency and other government
employees. They do not constitute rulemaking by the Agency, and may not be relied on to create a
substantive or procedural right enforceable by any other person. The Government may take action that
is at variance with the policies and procedures in this manual.
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TABLE OF CONTENTS
Topic Page
1.0 Background and Structure of the ARCS Contracts 1-1
1.1 Background 1-1
1.2 Purpose 1-1
1.3 Structure of ARCS Contracts 1-1
1.3.1 ARCS Contract Scope 1-1
1.3.2 ARCS Contract Type and Administrative
Arrangements 1-3
1.4 ARCS Contract Management Roles and
Responsibilities 1-7
1.4.1 EPA Contract Management Structure 1-7
1.4.2 Contractor Management Structure 1-10
2.0 ARCS Contractor Start-up 2-1
2.1 Background 2-1
2.2 Management Plan 2-1
3.0 Operational Functions 3-1
3.1 Background 3-1
3.2 Award Fee Plan 3-1
3.2.1 ARCS Contract Fee Arrangement 3-1
3.2.2 Award Fee Roles and Responsibilities 3-2
3.2.3 Performance Evaluation Categories
and Criteria 3-4
3.2.4 Coordination of the Award Fee
Determination Process 3-5
3.3 Distributing Work and Exercising Contract
Options 3-24
3.3.1 Distribution of Work at Contract
Start-up 3-25
3.3.2 Distribution of New Work Assignments
Throughout the Contract 3-25
3.3.3 Distribution of Continuation Work
Assignments 3-31
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TABLE OF CONTENTS
(continued)
Topic Page
3.3.4 Exercising Contract Options 3-33
3.3.5 Exercising Program Management Options 3-35
3.4 Work Assignment Procedures 3-36
3.4.1 Work Assignment Roles and
Responsibilities 3-36
3.4.2 The Work Assignment Form 3-37
3.4.3 Issuance of the Work Assignment 3-37
3.4.4 Work Assignment Initiation and
Development of the Work Plan 3-41
3.4.5 Amending the Approved Work Plan and
Increasing Funding 3-43
4.0 Management Plan for Multi-Regional ARCS Contracts 4-1
4.1 Background 4-1
4.2 General Contract Administration 4-1
4.3 Managing Work Assignments 4-3
4.4 Award Fee Determination Meeting 4-4
4.5 Work Assignment Distribution Meeting 4-4
Appendix I EPA Directives 1-1
Appendix II Program Management Award Fee Allocation II-l
Appendix III Work Plan Evaluation Checklist III-l
Appendix IV List of Acronyms V-l
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LIST OF EXHIBITS
Exhibit Page
1.3-1 ARCS Contract Sizes 1-4
1.3-2 Program Management Support Allocation 1-6
3.2-1 ARCS Contract EPA Summary Evaluation Report 3-7
3.2-2 Award Fee Performance Event Report 3-8
3.2-3 EPA Work Assignment Completion Report 3-11
3.2-4 ARCS Regional Evaluation Summary 3-15
3.2-5 Performance Index Rating Score 3-18
3.2-6 Year-End PIRS 3-19
3.2-7 Phase I Award Fee Allocation Matrix 3-20
3.2-8 Phase II Award Fee Allocation Matrix 3-21
3.3-1 LOE Usage for ARCS Contractor "A" 3-28
3.3-2 Project-Specific Contractor Selection 3-32
3.3-3 Example Options Determination 3-34
3.4-1 Work Assignment Form 3-38
3.4-2 Action/Execution Summary 3-45
3.4-3 Technical Direction Memorandum Form 3-46
4.1-1 Organizational Plan for Multi-Regional ARCS 4-2
Contract Management
II-l Award Fee Pool Allocation II-2
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LISTOFTABLES
Table Page
1 Work Assignment Distribution 3-27
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1.0 BACKGROUND AND STRUCTURE OF THE ARCS CONTRACTS
1.1 BACKGROUND
The Alternative Remedial Contract Strategy (ARCS) is EPA's
approach to obtaining project management and technical services to
support remedial response activities at National Priorities List
(NPL) sites. This approach to contracting for remedial response
services is intended to optimize quality, timeliness and cost
efficiency by:
Promoting continuity in site project management and
execution, from remedial planning through construction
Decentralizing contract management responsibilities,
thereby placing authority and responsibility for
management decisions within the Regional offices
Implementing performance incentives to the maximum extent
possible, by awarding multiple contracts in each Region
or Zone, and using triannual ratings of contractor
performance to determine the amount of work assigned to
a given contractor.
The ARCS program represents a significant departure from other
Superfund contracting programs in its management and incentive
approach.
1.2 PURPOSE
ARCS places substantial responsibility on EPA Regional offices
for managing remedial response support contracts. Unlike the
Remedial Planning (REM) contracts, Regional personnel will be
responsible for all basic contract management and administrative
functions under ARCS. The purpose of this handbook is to provide
guidance for EPA Regional personnel with responsibility for
management and administration of ARCS contracts.
1.3 STRUCTURE OF ARCS CONTRACTS
This section briefly describes the basic structure and scope
of ARCS contracts. Individual ARCS contracts will vary,
particularly with regard to prices, and should be reviewed by
Regional personnel for specific information.
1.3.1. ARCS Contract Scope
ARCS contracts include two main categories of support:
site-specific technical support and overall program management
(PM). Site-specific technical support is divided into five broad
functional areas as described below:
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Site-specific Project Management - Provide project
planning, monitoring, and control in performing work
assigned to accomplish the overall remedial response
Remedial Planning - Conduct remedial
investigation/feasibility studies (RI/FSs), analyzing
site conditions and developing alternatives for remedies
Remedial Design - Evaluate necessary field and laboratory
studies, address permit and regulatory requirements,
coordinate with State officials, participate in community
relations activities, review design criteria and
rationale, and confirm cost estimates and proposed
project schedule
Remedial Implementation - Support the procurement and
management of construction services for remedy
implementation
Other Technical and Management Assistance - Support EPA
in oversight of remedial responses being conducted by
other parties, and provide support in enforcement,
community relations, quality assurance, data management
and analysis, and other related technical activities.
Each of these functional areas includes several specific tasks
or activities that are defined in the contract Statement of Work
(SOW). The precise tasks or activities that will be performed at
any given site will be defined in the SOW that will accompany each
work assignment (WA). While EPA is free to tailor individual WA
SOWs to a particular site, the scope of the WA SOW must be within
the scope of the basic ARCS contract.
Program management constitutes technical, management,
administrative and clerical activities performed by the contractor
in order to ensure:
Quality control/quality assurance of all work performed
under the contract including data management
Efficient personnel management including staffing,
recruiting, training, and mobilization
Adherence to standard Agency and other Federal procedures
and guidelines (e.g., security, health and safety, and
enforcement/legal)
Effective contract management (e.g., schedule and cost
control, reporting, and non-project specific problem
solving)
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Adherence to the requirements and objectives of the
approved subcontracting plan (e.g., ability to meet
Minority Business Enterprise subcontracting goals,
subcontracting agreement turnaround times, contractual
vehicles used).
The Project Officer (PO) does not have to issue WAs to define
or start PM activities. PM is provided on an as needed basis by
the contractor as long as base or optional PM dollars (see Section
1.3.2.2 below) are available in the contract.
1.3.2. ARCS Contract Type and Administrative Arrangements
ARCS contracts will be awarded on a Cost Plus Award Fee (CPAF)
basis. Under this contract type, vendors costs are reimbursed each
month as they are incurred. The fee consists of a base amount
fixed at contract award and an award fee pool that may be earned
in whole or in part based on the Government's evaluation of
performance.
1.3.2.1 Site-Specific Technical Support
Site-specific technical support is provided under a
level-of-effort (LOE) contracting structure. Contractors are
required to provide professional staff who meet specified
experience and education requirements for labor categories
identified in the contract. When the PO issues a WA to perform
remedial response activities at a particular site (see Section
3.4) , the contractor will draw from this pool of professional staff
to perform the WA.
EPA will award ARCS contracts in five discrete sizes. All
five contract sizes, however, are not available for award in all
EPA Regions. The range of contract sizes are depicted in Exhibit
1.3-1. As the exhibit shows, base awards range from 25,000 hours
to 70,000 hours and contract maximum capacities from 145,000 hours
to 780,000 hours over the allotted ten-year period of performance.
Exhibit 1.3-1 illustrates the base award, available yearly
LOE options, and yearly ceilings for ARCS contracts. As the
exhibit depicts, a base LOE allocation will be made at the start
of contract performance. LOE options also are provided in all
contract years. Options are broken into increments of 5,000 hours
that can be awarded singly or in multiple groups. For example, the
yearly option allocation for large contracts is broken into 20
increments of 5,000 hours each (100,000 hours). EPA may award
these options in any combination up to the maximum allowed hours
or option increments. LOE hours, either base or optional, that are
awarded in any given year will carry over into subsequent years
until they are fully utilized. However, options, allocated for a
given year, may be awarded only in the year they are allocated.
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EXHIBIT 1.3-1
ARCS LOE BREAKDOWN
CONTRACT SIZE
LARGE
560,000 Hour Max.
MEDIUM
300,000 Hour Max.
SMALL
145,000 Hour Max.
BASE AWARD
LOE
30,000 Hours 1st Year
20,000 Hours 2nd Year
No Base Award in Years 3-10
30,000 Hours 1st Year
20,000 Hours 2nd Year
No Base Award in Years 3-10
15,000 Hours 1st Year
10,000 Hours 2nd Year
No Base Award in Years 3-10
OPTIONAL
LOE
100,000 Hours per Year in 20
Blocks of 5,000 Hours Each
50,000 Hours per Year in 10
Blocks of 5,000 Hours Each
25,000 Hours per Year in 5
Blocks of 5,000 Hours Each
YEARLY
CEILING
100,000 Hours*
50,000 Hours
25,000 Hours
* Yearly Ceilings May Be Exceeded by Executing Bilateral Contract Modifications.
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The sum of the potential maximum base and optional hours
exceeds the maximum LOE limits. This gives EPA the flexibility to
provide a high LOE during peak periods of activity. However, the
maximum LOE limits cannot be exceeded during the life of the
contract. The contracts also include limits on yearly expenditures
of LOE for each contract, which are shown in Exhibit 1.3-1. These
yearly ceilings may be exceeded with a bilateral contract
modification. If the contracts are so modified, options in excess
of the yearly ceilings will be exercised at the prices specified
for that year. Exceeding the ceiling for a particular contract
year does not allow the contractor to exceed the overall contract
ceiling.
1.3.2.2 ARCS Program Management
The ARCS contractors are required to provide a PM organization
that will manage all non-site specific administration of the
contract. This organization will include a single Project Manager
and necessary support staff. PM is a separate line item under ARCS
contracts with base amounts in years one and two and multiple
options in each year that provide the PO with the ability to
control costs by awarding PM options as they are needed.
The contract provisions for PM are substantially different
from the LOE provisions described above for site-specific technical
support. PM will be structured on a CPAF completion basis instead
of the LOE basis used for site-specific ARCS tasks. The contract
does not include a LOE figure for PM. By exercising a PM option,
EPA authorizes the contractor to make reasonable expenditures up
to the cost figure in the option or base award for PM support,
without requiring the provision of a given LOE in specified labor
categories. The PM base and option allocations also include fixed
amounts for other direct costs (ODCs) such as travel and special
equipment.
The PM base and option allocations are priced according to
increments of site-specific LOE to be delivered during a given
period. For example, for a medium-size ARCS contract, the first
year base PM allocation is intended to support 30,000 hours of
site-specific LOE. Each of the base and optional PM allocations
is intended to support a given site-specific LOE increment.
Exhibit 1.3-2 illustrates the PM allocation available in each
ARCS contract year for an ARCS contract with a base award of 50,000
LOE hours (see Exhibit 1.3-1 for a complete illustration of ARCS
contract sizes). As the exhibit shows, a base PM allocation will
be made at the beginning of the first and second year of contract
performance. These allocations are intended to support 30,000
site-specific LOE hours in year one and 20,000 site-specific LOE
hours in year two. PM options also are provided in these years to
increase PM allocations when necessary. There is no base PM
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EXHIBIT 1.3-2
PROGRAM MANAGEMENT SUPPORT ALLOCATION
BASE PM
ALLOCATION
NUMBER OF
AVAILABLE
OPTIONS
OPTION
SIZE
CONTINGENCY
EQUIPMENT
OPTION
CONTRACT YEAR
1
PM
SUPPORT
FOR 30,000
LOE HOURS
5
SUPPORT
FOR 6,000
LOE HOURS
TBD
2
PM
SUPPORT
FOR 20,000
LOE HOURS
10
SUPPORT
FOR 9,000
LOE HOURS
TBD
3
NONE
15
SUPPORT
FOR 9,500
LOE HOURS
TBD
4
NONE
15
SUPPORT
FOR 9,500
LOE HOURS
TBD
5
NONE
15
SUPPORT
FOR 9,000
LOE HOURS
TBD
6
NONE
15
SUPPORT
FOR 7,000
LOE HOURS
TBD
7
NONE
15
SUPPORT
FOR 4,500
LOE HOURS
TBD
8
NONE
15
SUPPORT
FOR 3,000
LOE HOURS
TBD
9
NONE
15
SUPPORT
FOR 2,000
LOE HOURS
TBD
10
NONE
15
SUPPORT
FOR 2,000
LOE HOURS
TBD
NOTE:
THE ARCS CONTRACTS MAY INCLUDE CONTINGENCY OPTIONS FOR EQUIPMENT THAT IS NOT INCLUDED IN THE PM BASE ALLOCATIONS OR OPTIONS.
THESE OPTIONS WILL BE SEPARATE FROM PM AND WILL BE AVAILABLE IN EACH CONTRACT YEAR. OPTIONS THAT ARE NOT AWARDED WILL NOT
CARRY OVER TO SUBSEQUENT YEARS.
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allocation in years three through ten. However, PM options are
provided in each of these years as shown in Exhibit 1.3-2. The PM
base and option allocations for small and medium-size ARCS
contracts will be reduced proportionately to reflect the size of
those contracts.
Funds awarded for PM in a given year, either base or optional,
will carry over into subsequent years until they are fully
expended. However, options allocated for a given year may be
awarded only in the year they are allocated. For example, in year
one there are five available PM options that may be awarded. If
the PO exercises three of those options, the funds for the three
options may be used at any time, but the remaining two options may
not be exercised after the end of the first year.
1.4 ARCS CONTRACT MANAGEMENT ROLES AND RESPONSIBILITIES
The internal organization of both ARCS contractors and EPA
Regional offices is a critical element contributing to the
successful implementation of ARCS. This section focuses on the
roles and responsibilities of EPA and contractor management.
1.4.1 EPA Contract Management Structure
Administrative and management responsibilities of ARCS
contracts will be primarily with the Regions; although when
necessary, Headquarters may intervene. Regional offices will be
entirely responsible for assigning and overseeing work.
Regions I-V will act as independent management entities.
Regions VI, VII, VIII, and Regions IX and X will combine to form
two zones, referred to as Multi-Regional Zones. Management of ARCS
contracts in the two Multi-Regional Zones will require
modifications to the management procedures and responsibilities
established for single Region ARCS programs; these modifications
are discussed in Section 4.0.
1.4.1.1 ARCS Contracting Officer (CO)
The ARCS CO will be responsible for verifying that contracting
activities are performed as authorized by laws, regulations, and
the terms and conditions of the contract. Specific responsi-
bilities include:
Approving Contract Documents - The CO reviews and signs
the initial WA issuance and any subsequent action that
affects overall scope or budget of the basic contract.
Award Fee Determination - The CO prepares the Award Fee
Allocation Matrices for the Performance Evaluation Board
(PEB) and issues the Final Award Fee Determination to
ARCS contractors.
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Dispute Resolutions - The CO is responsible for resolving
disputes regarding performance or costs.
1.4.1.2 ARCS Project Officer
The PO will have overall responsibility for managing and
directing activities performed under the contract. Many of the
PO's management functions are listed below; however, this is not
an all inclusive list because each project will give rise to
further management needs.
Contract Surveillance - The PO is responsible for
assuring compliance with contract terms and conditions.
This includes monitoring:
Regional Project Manager (RPM) technical directions
for consistency and contract compliance
Contract capacity to assure that actual assignments
are in line with annual allocations
Progress toward meeting contract guarantees.
Recordkeeping - The PO maintains all administrative
records and reports for ARCS contractors. Project
specific documentation including Work Assignments, work
plans, written technical direction, and performance
reports will be forwarded to the PO by the RPMs.
Work Assignment Distribution - The PO compiles and/or
prepares all information necessary to assign work among
ARCS contractors. This information may include Regional
workload data, project-specific information, contractor
performance records, data regarding contractor special
expertise, and conflict of interest and other information
as appropriate." Procedures for distributing WAs are
provided in Section 3.3.
Contract Option Determination - The PO participates in
determining the number of contract options to be
exercised to maintain contractor support. Procedures
for distributing contract options are discussed in
Section 3.3.
Award Fee Determination - The PO is responsible for
coordinating the determination and allocation of award
fees for ARCS contractors assigned to him/her for general
contract administration. Specific responsibilities
include:
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Preparing performance evaluation forms for each
rating period
Compiling and reviewing all performance evaluation
documentation into a performance evaluation package
for the Performance Evaluation Board (PEB)
Invoice Approval - The PO reviews and approves all
invoices and forwards the invoices to finance for
payment.
The PO may delegate one or more Deputy Project Officer(s)
(DPO) to assist in the aforementioned responsibilities. For
example, if the PO manages three ARCS contractors he may designate
three DPOs, one to assist in the management of each contractor.
In single Region ARCS the PO may delegate responsibilities to DPOs
in any reasonable manner. The PO may delegate full authority to
DPOs or opt not to designate any DPOs. This flexibility is not
permitted in the Multi-Regional Zones; there DPOs are a required
entity in the management structure (Section 4.2).
1.4.1.3 ARCS Remedial Project Managers
The RPM is the EPA official responsible for monitoring and
directing all ARCS contractor activities conducted at project
sites. The basic duties and functions of an RPM include the
following:
Assist in technical review and approval of work plans.
Review contractor cost reports
Monitor project status
Monitor contractor performance
Maintain project documentation files (cost recovery and
performance evaluation documentation)
Control site access
Participate in community relations activities
Ensure site safety
Coordinate with Federal and State agencies.
The RPM will report directly to the PO on matters related to ARCS
contract management and will assist the PO in general contract
management activities.
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1.4.2 CONTRACTOR MANAGEMENT STRUCTURE
ARCS contractors will be required to designate a single
Program Manager to manage the contract, and a Site Manager for each
project site. The roles and responsibilities of each are
highlighted below.
1.4.2.1 ARCS Contractor Program Manager
The Program Manager will be the single point of contact for
coordination with the PO. He will be responsible for the planning
and execution of all activities performed under the contract.
Specific responsibilities of the Program Manager include the
following:
Provide overall supervision and administrative support
to Site Managers
Provide assistance to the Site Managers in the
procurement of needed staff
Monitor costs and expenditures of funds throughout the
duration of the contract
Prepare and submit reports as specified in the contract
schedule and establish procedures for the preparation
and submission of reports required of the Site Manager
Discuss contract status with the EPA PO on a regular
basis.
In order to accomplish the tasks listed above, the Program
Manager must maintain open lines of communication with both the
Site Managers and the EPA PO.
1.4.2.2 ARCS Contractor Site Manager
The Site Manager will plan, monitor, and control the assigned
work, and will be responsible for ensuring progress that is in
accordance with approved work plans and the SOW. Specific
responsibilities of the Site Managers include the following:
Maintain open and regular communication with the Program
Manager and EPA RPM
Prepare and submit project-specific monthly progress
reports
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Prepare and submit performance evaluation forms required
for award fee determination
Monitor and document costs and expenditures.
The Contractor Site Manager will report directly to the
Contractor Program Manager.
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2.0 ARCS CONTRACTOR START-UP
2.1 BACKGROUND
Prior to initiating ARCS work assignments, both ARCS
contractor and EPA personnel must be sufficiently familiar with the
Superfund remedial program to begin contract activities in a
logical and orderly way. Personnel involved with the management
of ARCS contracts must familiarize themselves not only with this
manual, but also with existing EPA guidance related to hazardous
waste site work and Superfund programs. Appendix I contains an
extensive list of relevant guidance documents which may be obtained
through EPA's Docket Room.
2.2 MANAGEMENT PLAN
The first activity ARCS contractors must undertake following
contract award will be the preparation of a Management Plan. The
submittal of this Management Plan will ensure that a well
thought-out and comprehensive project approach has been developed
by each contractor. The Management Plan will delineate the
management strategy and cost plan for implementing ARCS projects.
It will provide general financial and procedural guidance for all
remedial response work to be performed. If necessary, the plan
will address special planning and management needs within the
Region/Zone in which the contractor will work.
ARCS contractors will submit a draft version of the Management
Plan within 30 days after award of the contract. This version will
reflect the management concept presented in the contractor's
successful proposal as revised and augmented through negotiations
and post-award consultations.
After a brief period of review, EPA officials will return the
draft version with EPA's comments to the contractor. The final
plan, modified according to EPA's comments, will be submitted
within 15 days of receipt of those comments.
The Management Plan will include but will not necessarily be
limited to the following elements:
Introduction
Purpose and scope of the program
Objectives and organization of the plan
Project Organization
Functional organizational structure
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Key personnel assignments
Staffing plans showing flow of authority and
responsibility
Management Process
- Work assignment initiation and progress controls
Program and performance review procedures
Administrative procedures
Scheduling controls
Accounting and cost control procedures
Management information system(s)
Reporting requirements
- Document production and distribution procedures
Subcontracting
Subcontracting decision process
Procurement process
Flow of authority and reporting relationships
Performance review and quality assurance procedures
Accounting and cost control procedures
Property Management
Existing in-house inventory procedures
- Acquisition and disposition procedures
- Maintenance and calibration controls and procedures
Technical Approach (Technical policies and Standard
Operating Procedures (SOPs) to be incorporated during
life of project)
Planning activities
- Design and implementation activities
- Management support plan
Quality Assurance Program Plan*
Community Relations Plan*
Health and Safety Plan*
If at any time the contractor's management approach or
structure substantially deviates from that outlined in the
Management Plan, they are required to notify EPA in writing.
Significant deviations may include changes in the following:
* Detailed versions of these plans also will be included in
site-specific work plans.
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Key personnel assignments
Accounting and cost control procedures
Subcontractor procurement and management procedures
Quality assurance program.
Less significant deviations in the management approach may be
verbally communicated to EPA's PO.
The Management Plan will reflect a generic approach to be
implemented by the contractor at each site. ARCS contractors will
also prepare a more detailed and site-specific work plan subsequent
to the receipt of each work assignment. The development of these
work plans is discussed in Section 3.4.
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3.0 OPERATIONAL FUNCTIONS
3.1 BACKGROUND
This section provides instructions for performing the basic
administration and management functions required of EPA personnel
responsible for operating ARCS contracts. Three functional
responsibilities are described:
Award fee policies and procedures
Procedures for distribution of site assignments and award
of contract options
Work assignment (WA) procedures.
This section provides a how-to guide for performing these
functions. It applies to all Regions/Zones that are operating ARCS
contracts, and is therefore generic in nature. EPA personnel
responsible for ARCS contract operations must be thoroughly
familiar with individual contracts in order to implement these
instructions.
3.2 AWARD FEE PLAN
As stated in the introduction to this handbook, one of the
primary goals of ARCS is to provide the maximum incentive for good
contract performance through the use of financial incentives.
Financial incentives are provided through the Award Fee Plan that
is used to allocate fees and distribute WAs based on contractors'
performance. This section of the manual provides guidance to
personnel responsible for implementing the ARCS award fee plan.
3.2.1 ARCS Contract Fee Arrangement
ARCS contracts are awarded under a cost-plus-award-fee (CPAF)
contracting arrangement. This contract type includes two basic
fee components described below:
Base or "fixed" fee - The base fee compensates the
contractor for risk. The base fee amount does not vary
with performance, but rather is a fixed amount that will
be paid to the contractor as costs are incurred. The
contractor will include amounts for base fee on monthly
vouchers based upon costs incurred during the month.
Award fee - The award fee is an award amount in addition
to the base fee that may be earned in whole or in part,
based upon an evaluation of the contractor's performance.
The award fee seeks to motivate the contractor's
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performance with respect to technical quality, ingenuity,
and budget and schedule control.
The award fee is divided into separate categories for
site-specific technical support and program management (PM) .
Site-specific award fee is allocated in two phases; Phase I which
is based on an overall evaluation of the contractor's performance
on all WAs (in progress and completed) during the triannual rating
periods, and Phase II which is based on an evaluation of
performance on WAs completed during a given rating period. The
ratio of fee allocated between Phase I and Phase II award fee is
specified in each contract.
The PM award fee is based on a separate evaluation of overall
(Region or Zone-wide) PM performance during each rating period.
PM award fee amounts are specified in the contract.
3.2.2 Award Fee Roles and Responsibilities
This section describes the responsibilities of personnel
involved in the award fee determination process.
3.2.2.1 Performance Monitors
Contractor performance is evaluated and reported by EPA
Performance Monitors. Performance Monitors are defined as being
any Government employee in a position to observe, assess, and
report the performance of a contractor.
3.2.2.2 Remedial Project Manager (RPM)
The RPM has site-specific responsibility for directing and
monitoring contractors' technical performance on individual WAs.
The RPM also is a designated Performance Monitor in the award fee
process. At the close of each performance evaluation period, and
in conformance with the contract Award Fee Plan, the RPM is
responsible for reporting his/her evaluation of contractor
performance on the forms described in Section 3.2.4. The RPM
submits all site-specific evaluation documentation to the Project
Officer (PO).
3.2.2.3 Pro-iect Officer (PO)
The PO has general responsibility for ensuring that contractor
WA performance meets program and contract requirements. The PO is
responsible for evaluating contractors' performance on WAs across
sites that may have different RPMs and is solely responsible for
evaluating PM performance. At the close of each performance
evaluation period, the PO assesses the contractor's overall
performance during that evaluation period and documents those
assessments in the Summary Evaluation Report (SER) and the Regional
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Evaluation Summary (RES) (see Section 3.2.4.1). The PO integrates
all EPA and contractor performance reports and supporting
documentation into a single package for the consideration by the
Performance Evaluation Board (PEB). The PO also is responsible for
developing the Performance Index Rating Score (PIRS) which is used
to determine annual work distribution.
3.2.2.4 Contracting Officer (CO)
The CO has two basic functions in the Award Fee Process:
The CO serves as a designated Performance Monitor because
of his/her unique perspective in observing contractor
performance. In this role, the CO functions exactly as
any other Performance Monitor.
The CO implements the fee decisions made by the Fee
Determination Official (FDO) by issuing the appropriate
contract modifications.
3.2.2.5 Performance Evaluation Board (PEB)
The purpose of the PEB is to advise and assist the FDO in
evaluating contractor performance. The PEB provides the necessary
discussion and interaction among Agency managers to ensure that all
matters relevant to a contractor's performance evaluation are
brought to their attention for decision. The PEB consists of
managers not involved in day-to-day management of ARCS contracts
who are appointed by the appropriate Regional Division Director.
Each PEB will have a chairman who will lead PEB meetings and
document PEB recommendations in the Fee Decision and Rationale
Report. This report will be forwarded to the FDO for review.
The PEB also reviews the Performance Index Rating Scores
(PIRS) developed by the PO for determining WA distribution.
Approval of the PIRS, by the PEB, is required before the PIRS can
be used for WA allocation.
3.2.2.6 Fee Determination Official (FDO)
The FDO is responsible for the ultimate fee decision. The FDO
will determine whether the PEB's fee recommendation is
substantiated by the Fee Decision and Rationale Reports. The FDO
may overrule the PEB recommendations for reasons such as: bias,
arbitrariness, inconsistencies, procedural irregularities, false
data, incomplete data, or other issues which are contrary to the
terms and conditions of the contract. The decision of the FDO is
both independent and final. Final fee determinations may not be
appealed within EPA or by the contractor.
3-3
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3.2.2.7 Contractor
ARCS contractors participate in the award fee process by
providing assessments of their performance. These self-evaluations
may include descriptions of superior performance as well as
explanations in mitigation of any performance problems,
deficiencies, or delays. Contractor self-evaluations are submitted
to the appropriate PO/RPM at the close of each performance
evaluation period. The contractor also may be asked to meet with
the FDD, RPM, PO, CO and other Agency officials to review the
results of the evaluation process, and to discuss, develop, and
implement improvements to programs, procedures, and performance.
3.2.3 Performance Evaluation Categories and Criteria
ARCS contractors' performance will be evaluated on the basis
of their ability to provide the necessary personnel, services,
equipment, and materials to support the remedial program in various
performance categories that correspond to the organization of
contract resources.
3.2.3.1 Performance Evaluation Categories
As stated in Section 3.2.1 the evaluation categories cover the
two main organizational components of the contract:
Program management
Site-specific technical support.
These categories are assigned separate award fee pools and
evaluated separately.
3.2.3.2 Performance Evaluation Criteria
Award fee performance evaluation criteria are included in each
ARCS contract. The evaluation criteria were developed to provide
a uniform basis to evaluate work performed by all contractors;
thus, the criteria are generic in nature. Because there are basic
differences between PM and site-specific activities, however, the
application of the evaluation criteria will vary between the two
categories.
For example, ARCS contracts include an evaluation element for
"project planning." This element can be applied in a
straight-forward manner to work performed in the site-specific
technical support category (i.e., contractors' ability to develop
a well thought-out plan in response to a WA). On the other hand,
for work performed in the PM category, the project planning
criteria would apply to contractors' ability to develop Regional
Management Plans or the coordination of work among the various
contractor management offices.
3-4
-------
Similar examples can be cited for each of the criteria with
respect to the different types of work that must be performed under
the contract. The primary distinction in the application of the
criteria depends on whether the work involves a discrete task or
overall management of various organizational components of the
contract. The application of the criteria is the responsibility
of the individual Performance Monitors and must be reviewed by the
PO responsible for coordinating the performance evaluation process.
3.2.4 Coordination of the Award Fee Determination Process
ARCS award fee determinations will take place every four
months during the life of the contract. This section details the
procedures for evaluating and documenting contractor performance
and allocating award fee based on the performance evaluations. In
addition, contractor performance, as evaluated in the award fee
process and expressed in the PIRS, will be the primary tool used
to determine annual work distribution.
3.2.4.1 Reporting Contractor Performance
EPA Performance Monitors (i.e., POs and RPMs) are responsible
for reviewing projects performed by the ARCS contractors. The
reviews of contractor performance will be documented through the
following:
EPA Summary Evaluation Report (SER) is used to evaluate
the contractors' overall Region-wide performance on PM
and site-specific technical support.
EPA Performance Event Report (PER) documents less than
satisfactory performance on particular WAs.
EPA Work Assignment Completion Report (WACR) documents
overall performance on individual WAs that are completed
during a given rating period.
ARCS Regional Evaluation Summary (RES) provides a summary
rating of performance on each active WA.
Performance Index Rating Score (PIRS) rates contractors'
overall technical performance over a given contract year
to determine the allocation of new WAs.
The forms listed above are prepared separately by the responsible
EPA Performance Monitor and the ARCS contractor. The PO will
assemble these reports into a package to be presented to the PEB
for award fee determination, at the end of each award fee rating
period.
3-5
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EPA Summary Evaluation Report
The SER (see Exhibit 3.2-1) is used by ARCS POs to
evaluate contractors7 overall performance in both PM and
technical performance. At the end of each performance
evaluation period, the PO will complete a separate SER for PM
and overall technical performance. The ARCS PO should check
the appropriate box under the block labeled "Performance
Evaluation Category" to indicate the category of contractor
performance being evaluated in the report.
The SER is self-explanatory in terms of the information
required for completing each block. The purpose of the SER
is to obtain the PC's overall evaluation of contractor
performance in each category from a broad perspective. The
PO should use the descriptions of the evaluation categories
and criteria and rating guidelines outlined in the ARCS
contract to formulate his/her evaluation. The evaluation
should be concise and provide only information which
highlights significant events, and strengths and weaknesses
observed during , the period that support the overall
evaluation. As such, the SER should be useful in identifying
recurring difficulties or trends which need to be discussed
with the contractor. Accompanying the SER should be a list
of the individual WAs or projects that have been considered
for the evaluation.
The contractor may submit self-evaluation SERs to the PO,
who will include the SERs in the Performance Evaluation
Package that is sent to the PEB. The title and signature
blocks of contractor-prepared SERs should be appropriately
altered to indicate their source.
To assist in completing the SERs, each office should
develop its own internal mechanism for periodic tracking and
reporting of contractor performance on WAs during the rating
period. This will provide the PO with documentation necessary
to support the ratings on the SER.
EPA Performance Event Report
The PO/RPM is required to complete a PER (see Exhibit
3.2-2) for each WA or area of performance in which the
contractor's performance has been less than satisfactory. The
PER is a prerequisite for withholding or deferring Phase I
award fee. The PER serves as the Region's primary vehicle for
affecting the fee awarded for ongoing projects that are not
proceeding satisfactorily, and provides a valuable input to
the PEB in its determination of the amount of the Phase II
award fee to be allotted to the contractor. If the PO/RPM
plans to submit a PER, the contractor Site Manager must be
informed of the deficiencies in performance so that the
3-6
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EXHIBIT 3.2-1
•DNTF
ARCS CONTRACT
EPA SUMMARY EVALUATION REPORT (SER)
NTRACTOR/SUBCONTRACTOR(S)
CONTRACT NO.
EPA REGION
CONTRACTOR REGIONAL MANAGER (Name and Phone No.)
PERFORMANCE EVALUATION CATEGORY:
n OVERALL TECHNICAL PERFORMANCE
D PROGRAM MANAGEMENT
PO (Name and Phone No.)
PERFORMANCE EVALUATION PERIOD
FROM: TO:
CONTRACTOR PERFORMANCE EVALUATION:
n OUTSTANDING Q EXCEEDED EXPECTATIONS
5 4
SATISFACTORY
3
MARGINAL
2
UNSATISFACTORY
1
DESCRIPTION OF ACTIVITIES AND PERFORMANCE:
(List on a separate page if necessary, Work Assignments covered by this report.)
STRENGTHS/WEAKNESSES/NEEDED IMPROVEMENTS:
W
PO SIGNATURE
DATE
3-7
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EXHIBIT 3.2-2
AWARD FEE PERFORMANCE EVENT REPORT 1
PART 1: EVENT DESCRIPTION AND OVERALL EVALUATION J
CONTRACT NO. CONTRACTOR WA NO. 1
DATES OF REPORTED EVENT: NO. OF HOURS THIS PERIOD
FROM: TO:
COSTS THIS PERIOD
CONTRACTOR CONTACT PHONE NO. RPM PHONE NO.
DESCRIPTION OF PERFORMANCE EVENT
OVERALL PERFORMANCE EVALUATION
/
PROJECT
PLANNING
TECHNICAL
COMPETENCE
& INNOVATION
SCHEDULE &
COST CONTROI
REPORTING
RESOURCE
UTII I7ATION
EFFORT
DATE RPM SIGNATURE OVERALL RATING
PO ASSESSMENT & CERTIFICATION
DATE PO SIGNATURE RATING
(
00 ™
-------
EXHIBIT 3.2-2 (CONTINUED)
AWARD FEE PERFORMANCE EVENT REPORT
PART II: EVALUATION CRITERIA SCORE SHEET
CONTRACT NO.
CONTRACTOR
WA NO.
PERFORMANCE CRITERIA
RATING
SUPPORTING COMMENTS
PROJECT PLANNING
ORGANIZING (E.G., WORK PLAN
DEVELOPMENT, DATA REVIEW)
SCHEDULING
BUDGETING
.5
.4
3
2
.1
TECHNICAL COMPETENCE & INNOVATION
EFFECTIVENESS OF ANALYSES
MEET PLAN GOALS
SUPPORT COE, STATE, ENFORC.
ADHERE TO REGS. & PROCEDURES
APPROACH CREATIVITY/INGENUITY
EXPERT TESTIMONY
SCHEDULE & COST CONTROL
BUDGET (HOURS & COST) MAINT.
PRIORITY/SCHEDULE ADJUSTMENTS
COST MINIMIZATION
5
4
3
2
1
REPORTING
TIMELINESS OF DELIVERABLES
CLARITY
THOROUGHNESS
.5
.4
.3
.2
.1
RESOURCE UTILIZATION
STAFFING
SUBCONTRACTING
EQUIPMENT, TRAVEL, ETC.
5
4
3
2
1
EFFORT
<
RESPONSIVENESS
MOBILIZATION
DAY-TO-DAY
SPECIAL SITUATIONS (E.G., ADVERSE/
DANGEROUS CONDITIONS)
3-9
-------
contractor has the opportunity to explain any extenuating
circumstances which may be relevant to the subject evaluation.
Additionally, this will allow the contractor to take
appropriate corrective actions. PERs should be completed
promptly after a performance deficiency is noted and should
not be held until the end of the rating period. This will
provide the contractor with sufficient time to prepare a
response or explanation for the FEB.
The PER also can be used as a convenient means to
document satisfactory or above satisfactory performance. The
form includes space to describe and rate the contractor's
overall performance, as well as a space for the description
of a specific event. When the PER is used to document any
level of contractor performance, it should be included in the
Performance Evaluation Package that is forwarded to the PEB.
EPA Work Assignment Completion Report
As stated earlier the Phase II award fee is allocated to
ARCS contractors only at the completion of a WA. The WACR
(see Exhibit 3.2-3) is used to provide a concise review of the
contractor's project performance on individual WAs, and to
recommend the Phase II award fee amount.
A WACR will be prepared for every WA upon completion of
the project(s) specified in the Statement of Work (SOW). The
WACR is a three-page form. Page 1 encompasses the body of
the performance report and will be presented to the PEB. Page
2 provides a worksheet for summarizing the costs and schedule
information associated with completion of the WA. Page 3
provides an additional worksheet to assist the performance
monitor in developing his/her review and evaluation, drawing
on the category descriptions, evaluation criteria, and rating
guidelines contained in the award fee plan included in the
contract.
A WA will be considered "complete" upon approval of the
final deliverable by the RPM and receipt of the final invoice
for the WA (a final invoice and WA close-out form will usually
be received by the RPM within 60 days of project completion).
WACRs will be prepared by EPA RPMs or other appropriate EPA
personnel (e.g., enforcement or community relations staff) who
were responsible for monitoring the activities performed by
the contractor and will be forwarded to the PO for review and
approval. All WACRs received by the PO prior to the end of
the evaluation period will be included with the Performance
Evaluation Package. The ARCS contractors also will complete
WACRs (appropriately altering the title and signature blocks
of the form) and submit these to the PO.
3-10
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EXHIBIT 3.2-3
PAGE 1 of 3
EPA WORK ASSIGNMENT COMPLETION REPORT (WACR)
I
PONTRACT NO. WORK ASSIGNMENT NO.
NTRACTOR/SUBCONTRACTOR(S)
BRIEFLY DESCRIBE SCOPE OF WORK:
EPA REGION
CONTRACTOR SITE MANAGER (Name and Phone No.)
RPM (Name and Phone No.)
WORK LOCATION (Site Name & State)
DESCRIBE CONTRACTOR'S PERFORMANCE:
UNUSUAL PROBLEMS/OCCURRENCES AFFECTING CONTRACTOR'S PERFORMANCE:
PHASE I AVAILABLE
PHASE I PAID
PHASE II AVAILABLE
PHASE II AWARD RECOMMENDED?
n YES RECOMMENDED SIZE:. %
D NO
(0-100%)
STATE SPECIFIC REASONS FOR RECOMMENDATION FOR PHASE II AWARD:
(Additional pages may be attached if necessary)
iPM
Signature & Date
PO
Signature & Date
3-11
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EXHIBIT 3.2-3 (CONTINUED)
PAGE 2 of 3
EPA WORK ASSIGNMENT COMPLETION REPORT (WACR)
PART II: PROJECT SCHEDULE AND COST INFORMATION WORKSHEET
CONTRACT NO.
APPROVED WORK PLAN
ANDWAAMENDEMENT
DATES
WORK PLAN APPROVAL DATE
Amendment 1
Amendment 2
Amendment 3
TOTAL PLANNED COST
TOTAL ACTUAL COST
VARIANCE
WORK ASSIGNMENT NO. EPA REGION
LOE&
EXPENSE
COST
SUBCON-
TRACTING
POOL COST
TOTAL
PLANNED
COST
PLANNED
COMPLETION
DATE
WMfr,
'mm.
w//////<
ACTUAL
COMPLETION
DATE
'mm,
'4Mb
W/M,
3-12
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EXHIBIT 3.2-3 (CONTINUED)
PAGE 3 of 3
EPA WORK ASSIGNMENT COMPLETION REPORT (WACR)
PART III: PERFORMANCE CRITERIA RATING WORKSHEET
CONTRACT NO.
WORK ASSIGNMENT NO.
EPA REGION
PERFORMANCE CRITERIA
RATING
SUPPORTING COMMENTS
PROJECT PLANNING
• ORGANIZING (E.G., WORK PLAN
DEVELOPMENT, DATA REVIEW)
• SCHEDULING
• BUDGETING
TECHNICAL COMPETENCE & INNOVATION
• EFFECTIVENESS OF ANALYSES
• MEET PLAN GOALS
• SUPPORT COE, STATE, ENFORC.
• ADHERE TO REGS. & PROCEDURES
• APPROACH CREATIVITY/INGENUITY
• EXPERT TESTIMONY
SCHEDULE & COST CONTROL
• BUDGET (HOURS & COST) MAINT.
• PRIORITY/SCHEDULE ADJUSTMENTS
• COST MINIMIZATION
REPORTING
« TIMELINESS OF DELIVERABLES
• CLARITY
• THOROUGHNESS
RESOURCE UTILIZATION
• STAFFING
• SUBCONTRACTING
• EQUIPMENT, TRAVEL, ETC.
EFFORT
RESPONSIVENESS
MOBILIZATION
DAY-TO-DAY
SPECIAL SITUATIONS (E.G., ADVERSE/
DANGEROUS CONDITIONS)
3-13
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Completion of the form is generally self-explanatory,
with the label for each block specifying the required
information. In describing and evaluating the contractor's
performance on Page 1 of the WACR, the RPM should refer to the
cost and schedule information worksheet (Page 2 of the WACR)
and describe any deviations in performance from the approved
work plan. More specifically, the RPM's description and
evaluation of the contractor's performance should highlight
the evaluation criteria included in each ARCS contract.
Phase II award fee recommendations are made by RPMs and
POs by completing the "Phase II Award Recommended" block on
page 1 of the WACR. All projects, upon completion, should be
recommended for a Phase II award fee provided work has been
performed in at least a satisfactory manner. EPA personnel
responsible for management of the ARCS contract should
recommend Phase II award amounts that are consistent with the
quality of the contractor's performance and the guidelines for
Phase II award fee allocation (Section 3.2.4.3).
All recommendations must be clearly supported, and should
cite specific examples where the contractor's performance was
above satisfactory or unsatisfactory. Additional support
documents may be attached as appropriate.
Each Region should implement procedures to track and
record performance on WAs to ensure an equitable evaluation
on the WACR. This is particularly important to ensure
continuity on long term projects or when the RPM is changed
during the course of the project. The PER and RES are
particularly useful in tracking WA performance and records of
all PERs and RESs should be maintained to provide input for
the WACR.
Regional Evaluation Summary
The RES (see Exhibit 3.2-4) provides a summary rating of
performance on each active WA. It will be the primary
mechanism for documenting satisfactory or above satisfactory
performance and will be used as the basis for the PIRS. In
addition, the RES is intended to provide a more complete
historical record of project performance that will facilitate
the completion of WACRs and the determination of Phase II
award fee for completed WAs. The RES will be especially
useful for determining Phase II award fee on long-term WAs and
WAs where the RPM or PO has changed during the course of the
assignment.
An RES entry must be completed for each WA by the RPM and
the Project Manager of the affected ARCS contractors. Where
space permits, a single RES can be used for multiple WAs.
3-14
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EXHIBIT 3.2-4
ARCS REGIONAL EVALUATION SUMMARY
CONTRACTOR: CONTRACT NO.:
EPA REGION:
CONTRACTOR PM: PERFORMANCE EVALUATION PERIOD
FROM:
RPO: T0.
PERFORMANCE EVALUATION KEY:
100-80 OUTSTANDING 80-60 EXCEEDS EXPECTATIONS 60-40 SATISFACTORY 40-20 MARGINAL 20-0 UNSATISFACTORY
SITE
NAME
WORK
ASSIGNMENT
NUMBER
NUMERIC
RATING
COMMENTS
SIGNATURE DATE
u>
I
H
Ul
-------
The general information required at the top of the form
and the identification of site name and WA number is
self-explanatory and will be completed on each RES entry. The
PO and the RPM will then complete the numeric rating for each
WA based on the performance evaluation key at the top of the
form. This rating is intended to be an overall rating of a
contractor's performance on each WA. It should not be broken
down into the subcategories of the award fee performance
evaluation criteria such as project planning or schedule and
cost control.
The comment column on the far right of the form should
be used to support the numeric rating. Comments are not
necessary for WAs that are rated satisfactory (3), but they
must be included for any other rating. The comments should
focus on the following issues:
Specific events that indicate either substandard or
exceptional performance
Overall progress on work in relation to established
schedules
Technical quality of work performed
The comments may reference other performance reports
where appropriate. For example, the PO could refer to
information in a PER to support a rating of marginal or
unsatisfactory on a given WA. While raters are encouraged to
be brief and concise, the comments must be clear, complete and
sufficient to support the numeric rating.
Both the PM and the PO must sign the RES. The PM will
forward the completed RES to the PO who will incorporate it
into the other information being forwarded to the PEB at the
end of each rating period.
Performance Index Rating Score
The PIRS is a numerical score designed to provide a
composite rating of an ARCS contractor's performance on all
active work assignments. The PIRS results from a calculation
involving separate evaluation scores for site-specific
performance on technical work assignments and will be used by
the PO to rate an individual contractor's performance for the
purpose of allocating new work.
The PIRS is derived from the ratings of contractor
performance that are included on the RES. The RES includes
a numeric rating of performance on each WA that is based on
the evaluation key at the top of the form (for example
outstanding performance receives a rating in the range of 80
3-16
-------
to 100). The PIRS is a weighted average of the RES ratings
for each WA, that is based on the level-of-effort (LOE) used
on the WAs during the rating period.
Exhibit 3.2-5 depicts a hypothetical example of PIRS
development during a given rating period. As shown the RES
score for a given WA is multiplied by the total LOE used for
a WA during the rating period to determine the PIRS Raw Score.
For example for WA 1 on Exhibit 3.2-5 the total LOE of 5,000
hours is multiplied by the RES score of 68% to derive a PIRS
Raw Score of 3,400. A PIRS Raw Score is developed for each
WA. The sum of the Raw Score is then divided by the total
hours worked on all tasks to derive the PIRS for a rating
period. In the hypothetical example shown in Exhibit 3.2-5
a total Raw Score of 21,100 is divided by the total LOE of
30,000 to derive a PIRS for the rating period of 70%.
Because the distribution of WAs occurs annually, a single
PIRS that covers all three award fee rating periods in a given
year must be developed. Exhibit 3.2-6 depicts a hypothetical
example of the development of the year-end PIRS that will be
used to determine WA allocations. Like the individual rating
period PIRS, the year-end PIRS is a weighted average. As
Exhibit 3.2-6 shows, the PIRS Raw Score from each rating
period is summed and divided by the total LOE used in a given
year to derive the year-end PIRS. In the hypothetical example
in Exhibit 3.2-6, a total Raw Score of 76,400 is divided by
the total LOE used (100,000 hours) to derive a year-end PIRS
for technical WAs of 76%.
3.2.4.2 Preparing the Performance Evaluation Package
The PO will assemble the information on the forms described
in 3.2.4.1 into a Performance Evaluation Package that is forwarded
to the PEB at the end of each rating period. In assembling this
package, the PO must review each document submitted by performance
monitors, the CO, or contractors to assure that they are complete
and correct and that they clearly document any performance
observations or fee recommendations.
The PO also will submit a summary of available award fees for
each contractor in the affected rating period. The site-specific
(Phase I and Phase II) award fee allocation will be submitted on
the Phase I and Phase II Award Fee Allocation Matrices that are
shown as Exhibit 3.2-7 and 3.2-8.
The Phase I Award Fee Allocation matrix will be prepared for
all active WAs by the contractor and forwarded to the PO for
inclusion in the Performance Evaluation Package. The CO will
verify the contractor-prepared Phase I matrix before the final
award fee determination is made by the FDO. The Phase II Award
Fee Allocation Matrix will be prepared by the CO for WAs completed
3-17
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EXHIBIT 3.2-5
Performance Index Rating Scores
Developing the Rating Period PIRS
Work Assignment
1
2
3
4
5
RES Percent
68 %
54 %
82 %
100 %
36 %
Totals
PIRS: 21,100-r30,C
Rating Period
LOE Use
5,000
7,000
12,000
3,000
3,000
30,000
PIRS
Raw Total
3,400
3,780
9,840
3,000
1,080
21,100
)00 x 1 00% = 70%
H
00
-------
EXHIBIT 3.2-6
Year-End PIRS
ID
Developing The Year-End PIRS
Rating
Period
1
2
3
PIRS
68%
84%
76%
Totals
LOE
30,000
35,000
35,000
100,000
PIRS
Raw Total
20,400
29,400
26,600
76,400
Year-End PIRS: 76,400-^ 100,000 x 100% = 76%
-------
EXHIBIT 3.2-7
PHASE I AWARD FEE ALLOCATION MATRIX
(In Thousands)
WORK
ASSIGNMENT
NUMBER
SITE NAME AND ACTIVITY
WORK ASSIGNMENT BUDGET
APPROVED
WA
COST1
PHASE I
AWARD
FEE
PHASE II
AWARD
FEE
CUMULATIVE
COST
PHASE I
AVAILABLE
PHASE I
AWARDED
AWARD FEE AVAILABLE
FOR PERIOD
COSTS
FOR
PERIOD
PHASE I
AWARD FEE
w
ro
o
1 AN ASTERISK (*) NEXT TO A COST FIGURE INDICATES THAT THE APPROVED WORK PLAN COST HAS
BEEN MODIFIED THROUGH AN APPROVED AMENDMENT TO THE WORK ASSIGNMENT
-------
EXHIBIT 3.2-8
PHASE II AWARD FEE ALLOCATION MATRIX
(In Thousands)
u>
1
to
H
WORK
ASSIGNMENT
NUMBER
SITE NAME AND ACTIVITY
PHASE II
POOL
AVAILABLE
SIZE OF RECOMMENDED PHASE II
AWARD (0-100%)
CONTRAC-
TOR
RPM
PEB
COMMENTS
-------
during the rating period. The CO will forward the completed Award
Fee Allocation Matrices to the PO for inclusion in the Performance
Evaluation Package.The amount of Phase I award fee that is
available in any given rating period is based on the LOE used by
the contractor during the period. Phase II award fee pools for
each rating period will be calculated only for WAs that are
completed during the period. Phase II award fee will be
accumulated for specific WAs, and the entire amount of Phase II
award fee that is accumulated for a given WA will then be available
for allocation to the contractor at the end of the rating period
in which the WA is completed.
Instructions for determining PM award fee allocations for a
rating period are included as Appendix II to this handbook.
The entire Performance Evaluation Package must be sent to each
member of the PEB at least five working days prior to the PEB
meeting.
3.2.4.3 Award Fee Determination
The PEB will meet at the end of each rating period to review
contractor performance and recommend Phase I, Phase II, and PM
awards fees for each ARCS contractor.
The PEB recommendations will be based on a review and analysis
of the Performance Evaluation Package that is submitted for each
ARCS contractor. The members of the PEB must assure themselves
that the information contained in the Performance Evaluation
Package is consistent, complete, and sufficient to support an
equitable and reasonable recommendation. If the PEB believes that
the package submitted by the PO is deficient in any way, they must
clarify or supplement the package through questions or requests for
additional documentation to the PO.
The PEB has broad discretion to recommend an award fee amount
provided that the recommendation is supported by the information
in the Performance Evaluation Package and consistent with the
contract Award Fee Plan. Specific considerations for determining
award fee allocations are contained below:
Phase I Allocation
The entire amount of Phase I award fee available for a
rating period will be allocated to contractors performing
satisfactory work. Phase I fee only can be deferred or
withheld if a PER has been filed documenting unsatisfactory
performance. When the information contained in the
Performance Evaluation Package indicates that performance is
less than satisfactory, the PEB must determine what allocation
will be made based on the severity of the problems that are
noted.
3-22
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The PEB also has the option to defer some portion of the
Phase I award fee for consideration in a subsequent rating
period. This may be necessary if the PO has filed a PER at
the end of a rating period and the contractor has not had
sufficient time to file its account of the problem, or if
there is some question about the severity and/or validity of
the problem noted in a given PER, and the PEB wishes to
monitor the performance problem during the subsequent rating
period. Phase I fee also may be deferred if work on a
specific WA has just started and performance data that is
sufficient to form a judgement is not available. A PER does
not need to be completed if Phase I fee is deferred due to
insufficient performance data but the PO must notify the PEB
of the amount of award fee that will be deferred and must
insure that the deferred amount is made available in the
following rating period. A PER must be completed by the PO
and included in the Performance Evaluation Package in order
for the PEB to withhold or defer Phase I award fee due to
unsatisfactory performance.
Phase II Allocation
Phase II award fee allocations may be made for an amount
ranging from 0-100 percent of the total Phase II award fee
available. The PEB should use the following guidelines to
determine the amount of available Phase II award fee that will
be allocated for completed WAs:
Less than satisfactory performance: 0 percent
Satisfactory performance: 1-30 percent
Exceeded expectations: 31-65 percent
Outstanding performance: 66-100 percent
The PEB is not bound by the Phase II award fee
recommendation that is included on the WACR, but must make
his/her judgment based on the information in the Performance
Evaluation Package.
Program Management Allocation
Unlike the site-specific award fee which is broken into
two categories (Phase I and Phase II), the PM award fee has
only a single category where Region-wide PM performance is
evaluated as a whole in each rating period. As a result,
satisfactory performance is not sufficient to earn the entire
amount of PM award fee, as is the case with site-specific
Phase I award fee. Rather, the PEB must determine a ratio of
the available PM fee pool that will be allocated to the
3-23
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contractor based on an analysis of the information contained
in the Performance Evaluation Package.
The PEB should use the following guidelines to determine
the amount of available PM award fee that will be allocated:
Less than satisfactory performance: 0-30 percent
Satisfactory performance: 31-60 percent
Exceeds expectations: 61-80 percent
Outstanding: 81-100 percent
Program management award fee allocation is discussed in
further detail in Appendix II.
Fee Decision and Rationale Report
Following the PEB meeting at which the award fee
recommendation is rea'ched, the PO will prepare a Fee Decision
and Rationale Report, which will be the official record of the
PEB meeting, and forward this to the CO. The CO will prepare
a letter for signature by the FDO informing the contractor's
general management of the amount and basis of the award fee.
The FDO will review the performance evaluation and the fee
recommendation made by the PEB and make a final determination
of fee. Following approval by the FDO, the fee will be
awarded to the contractor by the CO.
3.2.4.4 PIRS Determination
The PEB must review and approve the PIRS developed by the PO.
The PEB review should focus on the accuracy and fairness of the RES
ratings used to generate the PIRS and the PEB should ensure that
the PIRS accurately reflects his/her assessment of a given
contractor's overall performance. The PEB may accept the PIRS
developed by the PO or may modify the ratings as appropriate. If
the PEB does modify the ratings assigned by the PO, the PEB
chairman must develop a narrative rationale for the changes. The
approved and/or revised PIRS are forwarded to the personnel
responsible for determining new work allocations. They are not
included in the Fee Determination and Rationale Report that is sent
to the FDO.
3.3 DISTRIBUTING WORK AND EXERCISING CONTRACT OPTIONS
EPA will issue Work Assignments to ARCS contractors based on
past contract performance and the Regions'/Zones' workload for the
coming year. Work Assignments will be distributed to the ARCS
contractors when the contracts are awarded and annually when
assignments are made for new projects. In addition, work may be
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assigned to enable contractors to continue their efforts through
subsequent phases of the remedial process at sites where they have
begun work. The procedures applied in each of these circumstances
vary slightly in criteria.
The process of initiating WAs, for both new and continuation
work, will follow the procedures and forms described in Section
3.4.
3.3.1 Distribution of Work at Contract Start-Up
Initial WAs will be distributed soon after contract awards.
The process for making contract start-up assignments differs
significantly from subsequent assignments because performance
records are not available, and all ARCS contractors are considered
to be equally capable of performing remedial response activities.
To make contract start-up WAs, EPA POs will consider the size of
the contract awarded, the location of the contractors7 offices
within the Region/Zone, potential conflict of interest, and any
unique experience or capability possessed by a given contractor or
Site Manager. These criteria are discussed in further detail in
Section 3.3.2.2. To the extent practical, EPA will assign initial
WAs to contractors in proportion to the size of their contracts.
3.3.2 Distribution of New Work Assignments Throughout the
Contract
New WAs (excluding contract start-up assignments) refer to
those that assign contractors to a site where they have not worked
previously under this contract.
The distribution of new work is a two-phase process. The
first phase is designed to determine the number of WAs distributed
to each contractor; the second phase entails assigning specific
projects. In the first phase, EPA considers only contractor
performance and contract capacity in order to determine the number
of new WAs to be allotted annually to each contractor. The second
phase is designed to equitably assign specific projects to the
contractors based on the allocations developed in the first phase.
3.3.2.1 Annual Distribution of Work
To initiate the annual distribution of WAs, each Region or
Multi-Regional Zone must assess its needs for contractor support
for the coming year. This will occur prior to the beginning of
each fiscal year, and will begin with the development of the
Superfund Comprehensive Accomplishments Plan (SCAP).
The PO(s) will determine the number of new WAs to be awarded
to each contractor in the upcoming fiscal year. The P0(s) will
gather all the necessary data (i.e., anticipated resource
requirements, contract capacity information, and performance
3-25
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evaluation data) to assign new work among the pool of ARCS
contractors.
The number of new WAs given to ARCS contractors should be
based on their relative technical and PM performance. The PIRS is
developed to provide relative ratings of technical performance and
is the primary measure used to determine annual work distribution.
PM performance is considered to be less important than technical
performance in determining WA distribution, but should be
considered. The relative PM performance of different contractors
can be determined by reviewing the percentage of PM award fee
allocated to each contractor by the PEB. The PO is free to use any
reasonable method to include PM performance ratings in the work
distribution process, provided it is consistently and fairly
applied to all contractors.
Under the performance-based work distribution process, it is
possible for a contractor that is performing unsatisfactorily to
receive no new WAs for the year under consideration, and to be
considered for new WAs in subsequent years only if their
performance on existing work improves. Conversely, contractors
that perform work that exceeds satisfactory will receive a
proportionately larger share of new WAs for a given year.
When assigning new work, the PO cannot exceed maximum contract
ceilings or maximum yearly usage rates established in the
contracts. Contract ceilings and usage rates are extremely
important considerations because the contractor must have
sufficient hours, both total and yearly, to complete existing
projects. For example, a contractor that is performing
successfully in the early stages of WAs may not receive new
assignments in a given year if the PO believes the contractor's
full capacity will be needed to complete existing assignments
through remedial design and implementation oversight.
In order to make a valid determination of available contract
capacity, POs must keep a running total of both obligated hours
and the estimated number of hours necessary to complete assigned
projects for each contractor. For example, if a contractor is
performing well during the remedial investigation/feasibility study
(RI/FS) phase and the PO feels that the contractor should continue
with that site through remedial design and implementation
oversight, then the hours necessary to complete the site should be
considered in determining that contractor's available capacity.
This would be true even if the hours required or tasking to
complete work on the site have not yet been assigned to the
contractor.
Exhibit 3.3-1 gives a hypothetical example of the type of
running total that should be kept by the PO to determine contract
capacity. The exhibit shows an estimate of hour requirements for
WAs issued to the same contractor. The WAs are for work at three
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different sites in the RI/FS stage. The column titled "Expected
Follow-On" indicates the PO's intention to have contractor "A"
complete assigned sites through remedial design and implementation
at sites A and C. As the exhibit indicates, the PO must track
assigned and expected hours on both yearly and total contract basis
because ARCS contracts include both yearly and total hour ceilings.
Exhibit 3.3-1 is provided as an example of a possible methodology
for monitoring contract capacity. While the use of this form is
not required, POs must devise some mechanism to consistently track
available contract capacity for ARCS contractors.
Table 1 depicts a hypothetical example of WA distribution.
In the example, the Region has eight new WAs to distribute among
five ARCS contractors that have sufficient capacity to complete new
assignments within the yearly and overall contract ceilings. The
PIRS (center column) are assigned to each contractor by the EPA PEB
on a triannual basis, and are used to allocate work to contractors
for the following year. The number of new WAs allocated to each
ARCS contractor (right-hand column) is determined by their
respective year-end PIRS. Contractors B, C and E have each
received two Work Assignments because their respective average PIRS
are higher than those of Contractors A and D.
TABLE 1
CONTRACTOR
A
B
C
D
E
AVERAGE OF PAST THREE
PERFORMANCE INDEX RATING SCORES
75
89
87
79
91
NUMBER OF NEW
WORK ASSIGNMENTS
1
2
2
1
2
3.3.2.2 Project-Specific Distribution of Work
The second phase of the distribution process can take place
only after project-specific information is available.
Regions/Zones should attempt to gather this information immediately
after, if not before, the number of WAs to be distributed has been
determined. Once the majority of sites to be assigned are known,
the PO(s) will make specific assignments based on the criteria
discussed below. For those projects not identified prior to this
determination, the P0(s) will assign the remaining projects as the
necessary information arises.
The P0(s) must thoroughly document all decisions.
Documentation should consist of a narrative record of the decision
process, describing the basis for making specific project
assignments. The P0(s) also must track the number of WAs actually
given to a contractor to verify compliance with the allocations
made during the annual distribution of new work.
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EXHIBIT 3.3-1
LOE USAGE FOR ARCS CONTRACTOR "Af
SITE
A
B
C
WA
#
1
2
3
ASSIGNED
HOURS
20,000
15,000
15,000
EXPECTED
FOLLOW-ON
YES
NO
YES
ESTIMATE
TO
COMPLETE
20,000
- 0 -
30,000
TOTAL
40,000
15,000
45,000
BREAKDOWN BY YEAR
1
5,000
2
15,000
10,000
15,000
3
15,000
5,000
15,000
4
5,000
15,000
5
6
7
8
9
10
I
M
03
-------
Several criteria must be carefully considered when
distributing WAs. Some criteria lend themselves to quantifiable
measures, while others are more qualitative. The manner in which
each Region applies these criteria may vary slightly, but within
a Region, or Multi-Regional Zone, they must be applied
consistently. The applicable criteria are discussed below.
Demonstrated Performance - Demonstrated performance is
used in the annual distribution procedure to determine
the number of new WAs given to a contractor, and again
to make project-specific WAs. Although two contractors
may both be assigned the same number of new WAs during
the annual distribution of work, the better performer of
the two would be considered better qualified to receive
an especially difficult project or one that would require
a higher LOE. For example, using the hypothetical
situation shown in Table 1 above, contractor E should be
considered for the largest or most difficult Work
Assignments because its year-end Performance Index Rating
Score (91) was the highest of those firms receiving two
new WAs.
In addition, the contractors PM performance, as evaluated
for the purpose of allocating PM award fee (see Section
3.2.4.3), may be used in the project-specific allocation
of WAs. While PM performance is considered less
important than site-specific technical performance it may
be used to differentiate between contractors with
substantially equal PIRS ratings. The percentage of PM
award fee allocated to a given contractor by the PEB, in
accordance with Section 3.2.4.3, should be used as the
PM performance rating for the purpose of allocating WAs.
Conflict of Interest (COI) - ARCS contractors will be
required to notify the Government of potential conflicts
of interest prior to award .of the contracts. However,
due to the ten year term of the ARCS contracts and the
uncertainty about which projects will be assigned to a
given contractor, the pre-award notification of potential
conflicts may not be sufficient to allow EPA to determine
real or perceived conflicts of interest. The P0(s)
should therefore circulate a list of proposed projects
to each ARCS contractor and require them to inform the
Agency, prior to specific WA distribution, of any
conflicts. Contractors will not be considered for
projects where the CO determines that a conflict exists.
It should be emphasized that this pre-selection
disclosure of COI will not affect the number of WAs
allocated to an ARCS contractor, but will simply dictate
which projects can be assigned to fill the contractor's
yearly work allocation. ARCS contractors should be
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cautioned that this pre-selection notification will be
considered a certification that no conflict exists at
those sites/projects indicated. If the existence of a
real or perceived conflict is discovered after work is
assigned at a particular site, and the ARCS contractor
knowingly failed to give EPA pre-selection notification,
the contractor may be subject to termination for default,
or penalized in the award fee determination for that
rating period.
Location - Geographic location of a contractor's
office(s) is an important consideration in terms of the
expense associated with the costs of travel to and from
a site. The objective of this criterion is to minimize
charges due to the movement of contractor and
subcontractor personnel and equipment. Regions may use
distance bands (e.g., 0 - 100 miles, 100 - 250 miles) or
any other method they devise to evaluate this criterion.
Contract Capacity - The purpose of considering contract
capacity in determining new WAs is to ensure that
contractors are assigned workloads within the maximum
contract ceiling and the yearly usage rates specified in
their contracts.
The Regions/Zones should attempt to distribute work
equitably among satisfactory and above satisfactory
performers. If two contractors are performing equally
well, the Region/Zone should attempt to use an equal
percentage of their respective contract capacities. The
overriding contracting capacity considerations include:
Do the contractors' WAs exceed the maximum yearly
usage rate or total contract ceiling?
Will the contractors have sufficient capacity,
within both the yearly and total contract ceilings,
to complete assignments through the remedial
implementation if necessary and continue on projects
where they are performing satisfactorily?
Specific Technical Expertise - This final criterion is
used to distinguish among two or more equally deserving
ARCS contractors. Although all ARCS contractors are
capable of performing any task within the contract SOW,
the Region/Zone may observe that certain contractors
and/or site managers exhibit specific technical expertise
or strengths. EPA should take advantage of contractor
skills by matching demonstrated expertise to projects
requiring these skills or abilities. For example, a
particular contractor may be very experienced in projects
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involving wetlands, and therefore, should be assigned to
the site requiring that knowledge.
To assess a contractor's specific technical
expertise, the Region/Zone should rely primarily on
first-hand experience, derived from observing the
contractor's performance on ARCS WAs. Because it is
likely that the contractors' personnel and associated
capabilities will change over the ten year period of
performance, ARCS contractors may voluntarily submit an
annual statement of qualifications to the PO (25 page
limit). The annual qualifications statement should
include information about changes or improvements in the
contractors' personnel, capabilities, and corporate
experience. In particular it should focus on the
availability of specific site managers and other key
personnel. This will assist POs in matching the
particular strength or expertise of a contractor to
specific sites. EPA will not reimburse the contractors
for this voluntary submission.
The criteria discussed above must be applied accurately and
consistently to ensure that WAs are distributed equitably. Exhibit
3.3-2 shows how the criteria might be applied to a specific WA for
a hypothetical ARCS contract.
3.3.3. Distribution of Continuation Work Assignments
One of the stated goals of ARCS is to allow remedial response
contractors to provide continuous project management and execution
at a site from remedial planning through implementation
(construction management).* By providing continuous service at a
site, project "handoffs" are avoided and the quality, schedule,
and cost effectiveness of the remedial response are maximized.
Actual implementation/construction must be competitively
contracted or subcontracted. The Federal Acquisition
Regulations (48 CFR Part 36) preclude Government contractors
from designing and implementing projects (in this case,
remedial actions) except with the approval of the head of the
Agency or an authorized representative. A contractor's
efforts at a site may be discontinued for reasons other than
poor performance; the project-lead organization for the site
may change (i.e., from Federal to State) or responsible
parties may agree to conduct the Remedial Design/Remedial
Action (RD/RA) . EPA also may assign the RD/RA to the U.S.
Army Corps of Engineers. In these cases, the ARCS contractor
may be assigned to oversee activities on behalf of EPA or
provide other technical assistance.
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EXHIBIT 3.3-2
PROJECT-SPECIFIC CONTRACTOR SELECTION
(RI/FS AT SITE X, ANYWHERE, USA)
CONTRACTOR
A
B*
C
D
E
CRITERIA
CONFLICT
OF
INTEREST
No Conflict
PASS
No Conflict
PASS
No Conflict
PASS
Represents
PRP of site
FAIL
No Conflict
PASS
PERFORMANCE
(AVERAGE OF PAST
THREE PIR SCORES)
75
89
87
91
LOCATION
75 miles
(usual drilling subcontractor
in next town)
50 miles from satellite
office
30 miles from main office
150 miles
EXPERTISE
35% of total contract cap-
acity used, yearly capacity
available; has already
received allotment of new
work for the year
25% of total contract cap-
acity used, yearly capacity
available; due for a new
work assignment
30% of total contract cap-
acity used, yearly capacity
available; due for a new
work assignment
40% of total contract cap-
acity used, maximum yearly
usage rate assigned
CAPACITY
Annual qualification package
indicated experience with
similar projects; EPA has no
first-hand knowledge
of experience
Successfully completed
similar project last year
Little experience with this
type of site - better
suited for another project
u>
I
W
to
CONTRACTOR B WAS DETERMINED TO BE BEST-SUITED FOR THIS PROJECT
-------
Continuation WAs result when EPA decides to retain an ARCS
contractor at a site to continue work on the next phase of the
cleanup. This will occur most commonly when EPA decides to assign
the remedial design (RD) to the ARCS contractor who satisfactorily
completed the remedial investigation/feasibility study (RI/FS) at
the site.
The Region/Zone must determine, at logical break points in the
remedial process, whether the contractor is performing
satisfactorily at the site and whether the project would benefit
from assigning the contractor follow-on work. Logical break points
occur at the end of major remedial response activities (RI/FS and
RD) , however, the Region/Zone may break the project into smaller
activities, if desirable.
Continuation WAs will be made as needed during the course of
a project. If the contractor's performance at the site in question
has not been satisfactory, and the responsible EPA RPM recommends
continuation, then the RPM must document on what basis he/she
suggests the continuation. The PO, along with appropriate Regional
managers, will consider additional factors (e.g., enforcement
status of site, contract capacity) before forwarding the
continuation WA to the EPA CO for approval.
3.3.4 Exercising Contract Options
EPA may elect to exercise contract options when a contractor's
base award has been fully ordered. Contract options may be awarded
incrementally, over the performance period of ten years up to the
maximum yearly and total LOE ceilings (see Section 1.3.2). As
mentioned previously, a bilateral agreement may be used to exercise
options in excess of the yearly ceilings.
EPA will exercise options in 5,000 hour increments. The number
of options exercised will be based on EPA's projections of the LOE
necessary for a given contractor to continue existing WAs (based
on predicted schedule and projected expenditure) and to begin new
WAs. The number of options to be awarded can be calculated only
after the number of new WAs to be issued to a contractor is known
and the associated LOEs can be estimated. Better LOE estimates can
be made if site-specific projects are allotted to each contractor
prior to the option determination. To avoid the allotment of
excessive hours, the LOE remaining from the previous year will be
subtracted from the LOE required for the year under consideration.
The LOE necessary to carry out assigned work will determine the
number of 5,000 hour option blocks exercised.
Following the annual WA determination, the PO assesses the
number of options to be awarded. The PO submits his recommendation
to the CO for approval. The determined LOE must be rounded off to
the next highest 5,000 hour increment. An example determination
is shown in Exhibit 3.3-3.
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EXHIBIT 3.3-3
EXAMPLE OPTIONS DETERMINATION
The number of options awarded is based on the LOE required to continue existing work,
plus the LOE required to begin new work, less the LOE remaining in the contract.
CONTINUATION
ASSIGNMENTS
CONTRACTOR (ESTIMATED HOURS)
A 10,000
B 4,000
C 6,000
D 20,000
E 8,000
NEW WORK
ASSIGNMENTS
(ESTIMATED HOURS)
5,000
17,000
13,000
8,000
19,000
LOE
REMAINING
(HOURS)
6,000
2,000
6,000
9,000
1,000
LOE
REQUIRED
(HOURS)
9,000
19,000
13,000
19,000
16,000
76,000
# OF OPTIONS
AWARDED
2
4
3
4
4
1 7 Options
85,000 Hours
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3.3.5 Exercising Program Management Options
The CO, based on the PO's recommendation, has the unilateral
right to exercise PM options within stated yearly limits whenever
needed. Because PM is a support function for site-specific
remedial activities that are in process, the PO is not required to
adhere to the procedures for exercising site-specific LOE options
that were described in Section 3.3.4 above.
As stated in Section 1.3.2, base and optional PM allocations
are priced on the basis of assigned site-specific LOE. This gives
the PO the flexibility to increase PM support as the ARCS
contractor's site-specific workload increases either through
additional site assignments or increased testing beyond the initial
stages of sites that have already been assigned. While the PO can
anticipate that a contractor's PM responsibilities will increase
as site-specific LOE is increased, there is no requirement to
exercise PM options in a precise ratio to LOE hours awarded or
used. In some situations, the existing PM allocation may be
adequate to support an increase in LOE.
The award of PM options will be based on the PO's assessment
of the need for additional PM support. The ARCS contracts require
the contractor to identify PM expenses separately on each monthly
invoice. The PO must use the information on the monthly invoices
to monitor PM expenditures versus the pool of PM dollars currently
available in the contract and to determine whether the charges are
allowable and reasonable. This review of invoices is vital to the
PO's ability to exercise management control over PM costs.
Unallowable expenses, or allowable expenditures that exceed
expected levels, should trigger an assessment of the contractor's
PM support by the PO. This assessment should focus on possible
inefficiencies in the contractor's operations and/or conditions
that have caused the PO to underestimate the need for PM support,
and should help the PO to determine the need for additional PM
options, or other corrective action.
In all cases, the PO should use the following criteria to
determine an appropriate PM option award:
Number of active WAs
Progress and percent of completion on active WAs
Specific PM needs
Probability that additional WAs will be awarded to the
vendor in the foreseeable future
Historical trend regarding relationship between LOE and
PM.
3-35
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POs are reminded that because PM base and option amounts are
priced on a completion basis, the entire base and award fee pools
for any PM allocation must be made available to the contractor even
if the entire PM cost allocation is not used. Therefore POs should
use the flexibility allowed by the contracts to award options in
reasonable increments that have a high probability of being fully
used.
3.4 WORK ASSIGNMENT PROCEDURES
This section describes the contract administration procedures
that apply to the initiation, management and completion of WAs.
The four key steps that are involved in the WA process are:
Development and issuance of the WA
Completion of the interim WA tasks and approval of the
contractor work plan
Amending the approved contractor work plan and increasing
funding
Completion of the WA and close-out procedures
3.4.1 Work Assignment Roles and Responsibilities
This section describes the responsibilities of the personnel
involved in the WA process.
3.4.1.1 RPM/PO Responsibilities
The RPM/PO is responsible for generating the basic technical
documents related to the WAs, and review and approval of contractor
submissions. Specific responsibilities include:
Developing the WA Package
Developing the Technical Direction Memorandum (TDM) when
necessary
Setting Expenditure Limits when necessary
Reviewing contractor work plans and proposed amendments
and recommending approval to the CO
Processing WA amendments and funding increases when
necessary.
3.4.1.2 CO Responsibilities
The CO has a wide range of responsibilities; specific
responsibilities are listed below:
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Reviewing, approving, and issuing WAs
Authorizing funding
Transmitting signed initial WAs to the RPM/PO and the
contractor
Reviewing and approving work plans.
Issuing necessary contract modifications to accompany WAs
Approving changes to the total funding or overall scope
of a WA.
3.4.2 The Work Assignment Form
The Work Assignment Form (WAF) is a one-page form developed to
manage and coordinate the various activities needed to initiate,
approve, change, and complete a WA. The form allows for efficient
WA tracking and provides an up-to-date WA status at any given time.
A new WAF is completed for each contractual action related to a WA.
Each successive WAF supersedes the previous form and therefore ALL
required information must be provided on each form. A copy of the
WAF is provided in Exhibit 3.4-1. The form is to be used whenever
one of the following activities is to be conducted:
A new WA is issued by EPA
The contractor requests an amendment to the WA or work
plan
Incremental funding is providefflhe work plan receives
full or partial approval
An assignment is completed.
The WAF is a versatile form used in all of the situations outlined
above. The use of the WAF for specific administrative action is
discussed in further detail below.
3.4.3 Issuance of the Work Assignment ;
The initial step in issuance of the WA is development of a Work
Assignment Package. The initial package consists of the following
elements:
Work Assignment Form
Complete SOW for the total WA
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EXHIBIT 3.4-1
USEPA
WORK ASSIGNMENT FORM
1. WORK ASSIGNMENT INFORMATION
PROJECT NAME: CONTRACTOR:
ACTIVITY:
DATE:
EPA CONTRACT
NO.:
CONTRACTOR CONTROL NO.:
WORK ASSIGNMENT NO.:
REVISION NO.:
MODIFICATION NO.:
(Contracting Officer Use Only)
2. DESCRIPTION OF ACTION
i-i NEW WORK n
LJ ASSIGNMENT u
• Interim SOW, schedule, •
and LOE
• Complete SOW,
estimated budget and
schedule
RECURRED ,-,
APPROVAL LJ
EPA REGION/
HEADQUARTERS
3. BUDGET INFORMATION
TOTAL FUNDING
RECEIVED (SI-
CURRENT
THIS ACTION
TOTAL
' Option - dollar estimate may be track
regionally in expenditure limit block EP
estimated LOE hours ot entire WA
4. WA COMPLETION DATE
CURR
INTERIM
AMENDMENT
Change in LOE, Scope by
task
Add additional tasks or
funds
INCREMENTAL
FUNDING
EPA REGION/
HEADQUARTERS
1-1 PARTIAL WORK
"-1 PLAN APPROVAL
D FINAL WORK
PLAN APPROVAL
• Approval of work plan
• Add funds
i-i AMENDMENT TO FINAL
LJ WORK PLAN APPROVAL
• Change in LOE, scope or budget by task
• Add additional tasks or funds (include
OF 60 or SF 1411)
EPA REGION/
HEADQUARTERS
INTERIM BUDGET
(TECHNICAL ($)'
LOE)
ed
* ' Includ
ENT
ssfees
r-i TECHNICAL DIRECTION
"-1 MEMORANDUM
• Detailed scope, budget
and schedule
• Revise expenditure level
• Minor shift within SOW
(All changes must be within
overall scope, budget, and
LOE approved by EPA CO)
EPA REGION
APPROVED
WORK PLAN BUDGET
(TECHNICAL ($)'
LOE)
' Includes fees
REVISED
WORK ASSIGNMENT
.-, COMPLETION
LJ NOTIFICATION .
(NO ATTACHMENTS)
• Contractor originates
• Regional determination
• When signed by CO, this
constitutes a stop work
order
CONTRACTOR
EXPENDITURE LIMIT (EL)*
(TECHNICAL ($)'
LOE)
' Established by RPM/RPO
5. EPA COMMENTS
6. APPROVALS
CONTRACTOR SIGNATURES:
SITE MANAGER /FIRM
REGIONAL MANAGER /FIRM
D APPROVED AS
PHONE
SUBMITTED
DATE
DATE
EPA SIGNATURES:
REMEDIAL PROJECT MANAGER
PROJECT OFFICER
D APPROVED WITH CHANGES
DATE
PHONE
DATE
D NOT APPROVED
SIGNATURE OF CONTRACTING OFFICER
DATE APPROVED
CC EPA Project Officer
PO/RPM
Contractor
EPA Contracting Officer (when only expenditure limit column is used)
UPDATE 11/13/86
3-38
ATTACH STATEMENT OF WORK
(PER DESCRIPTION OF ACTION)
-------
Procurement request (PR)
Expenditure limits.
3.4.3.1 Completing the Work Assignment
The RPM/PO is responsible for preparing the WAF and submitting
the completed form to the CO. In the initial WA package, the
RPM/PO will be responsible for completing the following elements
in Item 1, "Work Assignment Information":
Date
Project Name
EPA Contract Number
Activity
Contractor Name
Revision Number (which will be "initial" for new WAs and
then sequentially numbered for each subsequent action)
Work Assignment Number (of which the last four digits
correspond to the site-specific accounting information
for the site, allowing room for sequential numbering by
the CO).
Under Item 2, the RPM/PO will check the box marked "New Work
Assignment." Under Item 3, the RPM/PO will fill the "Interim
Budget" column by showing the current LOE for the particular
activities addressed by the WAF and the EPA estimated hours for
the entire WA. (Note: The LOE hours for the entire assignment
should be estimated based on historical data when available.) For
a new WA, the dollar amount of the initial PR should be shown in
the "This Action" and "Total" lines of the "Total Funding Received"
column. The RPM/PO also may provide a dollar estimate for some set
of interim work tasks (see 3.4.3.1 below) and show this estimate
in the Expenditure Limit block (use of the expenditure limit is
discussed in Section 3.4.3.3). Under Item 4, the RPM/PO will fill
in the WA completion date for the entire WA in the space marked
"Current." The RPM/PO will sign on the appropriate spaces in'the
Approvals Section (6) of the form.
3.4.3.2 The Statement of Work
The EPA RPM/PO is responsible for developing the complete WA
SOW. The complete SOW defines the tasks the contractor will be
expected to perform to complete the entire WA. The SOW also may
identify some interim work tasks that can be performed by the
contractor prior to approval of the contractor's work plan for the
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WA. These interim work tasks are a subset of the total SOW and
normally consist of basic and routine activities that can be
performed by the contractor immediately after the WA is received.
They may include:
Literature reviews
Data file services
Development of a Sampling and Analysis Plan
Limited fieldwork.
SOW development is an extremely important part of the PO's/RPM's
responsibilities because the SOW is the basis for all activities
performed under a WA. The ARCS Work Assignment Management Field
Guide and the Work Assignment Management Training for RPMs both
contain detailed guidance for developing clear and complete SOWs.
3.4.3.3 Procurement Request
The procurement request (PR: EPA Form 1900-8) is used to
commit funds to the WA. The procurement request sets an overall
ceiling on expenditures on the WA that may not be exceeded without
subsequent additions to WA funding. Additional funding for WAs can
be provided at any time, and is accomplished with a new PR and the
issuance of an amended WAF that is signed by the CO (see Section
3.4.5.3). The PR for initial WAs may not include sufficient
funding to complete the entire WA but it should include enough
funding to complete all SOW tasks that can be reasonably estimated
at that time. Additional funding may be allocated as needed. The
RPM is responsible for requesting a PR and planning sufficient
funding for the project. Each EPA Regional office has designated
personnel to prepare PRs and obtain approvals.
3.4.3.4 Expenditure Limits
The RPM/PO may choose to set an expenditure limit for WAs.
This limit provides a mechanism for the Region to manage the
phasing and execution of the WA. An expenditure limit cannot
exceed the total funding available on a WA.
Expenditure limits can be used to:
Limit execution of work to distinct tasks or activities
Provide control over the execution of individual tasks
within an approved work plan
Provide control over interim work tasks that are started
prior to work plan development and approval.
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Expenditure limits can be increased or lifted by the PO at any time
through the issuance of an amended WAF (see Section 3.4.5.5).
3.4.3.5 Issuance of the Work Assignment Package
The Work Assignment Package, when completed, is transmitted to
the EPA CO. The CO assigns the WA number, signs the WAF in the
appropriate section, and prepares a contract modification that
reflects the necessary change to contract funding. The CO forwards
the original to the contractor with a copy to the RPM and the PO.
The contractor acknowledges acceptance of the WA by signing the
contract modification and returning the original modification to
the CO.
Upon acceptance of the WA, the contractor will identify the
Site Manager, and begin work on the Work Plan Memorandum and other
interim tasks.
3.4.4 Work Assignment Initiation and Development of the Work
Plan
This section describes the activities related to developing
the work plan and beginning approved tasks under the WA SOW. Three
basic activities are described:
Development of the work plan memorandum (WPM)
Performance of interim work tasks
Development and approval of the work plan.
3.4.4.1 The Work Plan Memorandum
The WPM is developed by the contractor immediately after
receipt of the WA. It describes the contractor's approach to
developing the overall work plan for the WA and the approach to
any interim work tasks (see Section 3.4.3.1) that are identified
in the SOW. The WPM is normally used for large and/or complete
WAs. The WPM is intended to save time by providing the PO with
interim authorization to allow the contractor to begin work, and
therefore incur costs, prior to approval of the overall work plan.
The content of the WPM should be similar to the content of the
overall work plan, and should include at least the following
information:
Proposed LOE
Proposed total cost
Schedule
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Staffing
Technical approach.
The PO reviews the WPM for sufficiency but is not required to
formally approve it, and any PO response to a WPM should be on an
exception basis only. For example, the PO may respond if the
proposed staffing or costs in the WPM appear unreasonable for the
tasks to be performed. If the PO accepts the WPM as submitted,
the contractor is authorized to begin work to develop the overall
work plan, as well as other interim work tasks.
3.4.4.2 Performance of Interim Work Tasks
The contractor is authorized to begin work on interim work
tasks identified in the SOW and described in the WPM upon
acceptance of the WPM by the PO. The contractor may perform
interim work tasks up to authorized expenditure limits or task
budgets.
3.4.4.3 Work Plan Development and Approval
The work plan describes the contractor's technical approach to
accomplish the complete SOW under the WA.
The contractor begins work on the work plan after acceptance
of the WPM by the PO. The work plan must include a complete
description of the contractor's proposed budget, LOE, staffing and
methodology for completing all tasks in the SOW in sufficient
detail to allow the PO to determine whether the contractor's
proposed technical approach and costs are realistic and reasonable.
The contractor must complete an Optional Form 60 (OF-60) or a
Standard Form 1411 (SF-1411) as part of the work plan, and a
partially completed WAF for final work plan approval. The
contractor should complete Item 1 of the WAF and should mark the
"Final Work Plan Approval" box under Item 2. The contractor also
can fill in the Approved Work Plan Budget in the "This Action" and
"Total" columns in Item 3 reflecting the technical LOE hours and
total cost budget supported in the final work plan text. If the
final approved work plan revises the completion date for the entire
WA then the contractor should reflect this new date in the revised
line of Item 4. The contractor's Program Manager and Site Manager
must sign the appropriate spaces under Item 6 prior to transmittal
of the form to the PO.
In some cases the contractor may not be able to develop a
detailed approach for all tasks in the SOW when the initial work
plan is developed. For example, the approach to some of the later
tasks in an SOW may be dependent on work completed during the early
stages of a WA when a thorough examination of the conditions at a
given site are performed. In cases where the initial work plan
3-42
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does not include a detailed approach to all tasks in the SOW, the
contractor will be required to submit a preliminary approach and
budget and staffing estimates for the tasks that require further
definition and investigation with the initial work plan. As soon
as sufficient information is collected to complete a detailed work
plan for these tasks, the contractor should prepare and submit a
work plan amendment which will complete the description of the
approach for the complete SOW.
Upon receipt of the work plan, the PO will review the budget,
schedule and approach for technical sufficiency, and the cost for
reasonable and realistic estimates. Appendix III - Work Plan
Evaluation Checklist is a detailed list of technical and cost
issues which the PO must consider in evaluating work plans. This
checklist must be completed and signed by the PO and forwarded to
the CO with the approved work plan.
POs are responsible for resolving any questions or
disagreements they have with the work plan. This should be
accomplished through a dialogue with the contractor aimed at
producing a plan that is mutually agreeable to both parties. The
PO will signify acceptance of the work plan by signing on the
bottom of the contractor-prepared WAF that accompanies the work
plan, and returning it to the contractor. A copy of the approved
work plan also is forwarded to the CO.
If the approved work plan calls for expenditures that exceed
the funds obligated for the WA, the PO must process a new
procurement request that will increase funding up to the level
identified in the work plan. This increase must be approved by
the CO and will be accomplished by the issuance of a WAF and
contract modification.
3.4.5 Amending the Approved Work Plan and Increasing Funding
Upon completion and approval of the work plan, the contractor
will proceed with performance of all approved tasks in the SOW (see
Section 3.4.4.3 for discussion of phased approval of work plans).
During this period, the PO is responsible for monitoring the
technical performance of the contractor and the costs incurred on
the WA to ensure that the contractor meets the technical objectives
of the WA within the approved schedule and budget.
During the execution of the approved tasks in the work plan,
changes sometimes occur or site conditions are encountered that
are different than originally projected. These changes in site
execution may affect the approved scope, LOE or dollar values
described in the work plan and the work plan and/or the WA SOW may
have to be revised.
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There are two methods for modifying the approved work plan for
any WA:
Technical direction memorandum (TDM)
Formal work plan amendments
Both the TDM and the formal amendment are normally initiated
by the contractor and must be approved by EPA. Exhibit 3.4-2
provides summary guidance for the appropriate use of the TDM and
WA amendment, and procedures for processing these actions follow
in Sections 3.4.5.1 and 3.4.5.2.
As stated in Section 3.4.3, the PO provides WA funding with the
PR and may set expenditure limits. When the initial funding is
insufficient to complete the entire WA, or when expenditure limits
must be lifted or raised to allow the contractor to continue work,
the PO will be responsible for initiating the necessary changes to
the WA. Procedures for processing these actions are detailed below
in sections 3.4.5.3 and 3.4.5.4.
3.4.5.1 Technical Direction Memorandum
A TDM is used to make changes to tasks under an approved WPM
or work plan that do not involve changes in the basic scope or
budget of the WA. A TDM cannot be used to document major changes
in scope which would clearly exceed the overall approved budget or
LOE levels for the assignment. Changes of this nature must be
documented and approved through an amendment.
The contractor first completes a detailed description of the
scope, schedule and budget for a proposed TDM. If it is determined
that the proposed TDM is within the scope, budget and schedule of
the approved SOW and work plan, the contractor will prepare a WAF
and attach this to the TDM. The contractor will be responsible for
checking the TDM box on the WAF and submitting this information to
the RPM/PO for approval. Proper completion of the TDM will insure
that the required data will be submitted to the RPM/PO in a format
designed to expedite the Regional approval process.
Exhibit 3.4-3 presents a completed sample TDM. Item 1.0
contains the general WA information and serves as a tracking device
for the overall site activity. Item 2.0 presents the objective and
the approach of the modifications being carried out. Item 3.0
(page 2 of the form) explains subcontractor requirements, if any,
and Item 4.0 presents schedule and deliverable changes. Item 5.0
contains the budget information, providing a task breakdown of
costs and hours with the totals. Item 6.0 summarizes the impact
of the current proposed TDM action on the overall assignment LOE
and cost. Item 7.0 of the TDM is the final approval signatures by
the contractor and Regional personnel.
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EXHIBIT 3.4.2
ACTION / EXECUTION SUMMARY
ACTION
EXECUTION
Add new task or phase
Modification to task which affects overall approved
LOE, dollars, and schedule end date
Modify execution of task or phase within approved
LOE dollar limits of assignment prior to actual execution
Document changes made to execution of task or
phase which did not affect overall approved LOE
or dollar limits
WA Amendment
WA Amendment
TDM
TDM
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EXHIBIT 3.4-3
PAGE 1 OF 2
USEPA TECHNICAL DIRECTION MEMORANDUM
1.0 WORK ASSIGNMENT INFORMATION
DATE: 10/15/84 PROJECT NAME: ABC CO..TX
EPA CONTRACT NO.: 68-01-6939 WORK ASSIGNMENT NO.: 1-6L51
CONTRACTOR: CDM INC. SITE MANAGER/FIRM: JOHNNY SAMPLE - COM
REVISION NO.: 3 CONTRACTOR CONTROL NO.: 999-PM1-RT-CDHG
2.0 TECHNICAL DIRECTION SCOPE OF WORK
OBJECTIVE- To conduct 'ield activities at the site. Field activities that are
being conducted during Phase I include first round well drilling,
soil sampling, sediment sampling, and air sampling.
APPROACH: (Present description of Task and Sub-Task basis)
Tasks affected by this TDM are as follows:
Task 2A-1 Well Drilling - Phase I
Task 2B-2 Soil Sampling - Phase I
Task 2C-1 Sediment Sampling - Phase I
Minor changes in the scope of the above listed sub-tasks occurred
during the conduct of the work assignment. The detail of the scope
changes are attached. (ATTACHMENT NOT INCLUDED IN THIS GUIDANCE
DOCUMENT). While the individual task budgets have changed, there is
no impact on the overall budget or LOE ceilings for this assignment.
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EXHIBIT 3.4-3 (continued)
PAGE 2 OF 2
USEPA
TECHNICAL DIRECTION MEMORANDUM
3.0 SUBCONTRACTOR REQUIREMENTS (Description of Services):
Not Applicable
4.0 SCHEDULE AND DELIVERABLE:
TASK NO. START DATE
A-1 3/8/85
B-1
C-1
4/16/85
4/1 6/85
: COMPLETION DATE: DELIVERABLE:
6/25/85
5/2/85
5/1 2/85
(Task Nos. Per Technical Direction Scope of Work)
5.0 BUDGET
TASK NO.
A-1
B-1
C-1
TOTAL
COMMITTED
TO DATE
APPROVED
BUDGET
VARIANCE
INFORMATION:
PROFESSIONAL
HOURS COST
1,170 27,000
608 13,500
608 13,500
2,386 54,000
3,100 100,000
2,500 60,000
(114) (6,000)
6.0 TOTAL ORIGINAL
WA BUDGET:
7.0 APPROVALS: L0
CONTRACTOR SIGNATURES
SITE MANAGER FIRM
REGIONAL MANAGER FIRM
SUPPORT
HOURS COST
130 3,000
67 1 ,500
67 1 ,500
264 6,000
310 25,000
280 7,000
(16) (1,000)
EQUIP.
1,000
1,500
1,500
4,000
5,000
4,500
(500)
TRAVEL
500
700
500
1,700
3,000
2,100
(400)
ODCs
1,200
1,700
2,000
4,900
7,000
5,200
(300)
SUB POOL
47,300
22,600
21,000
90,900
225,000
104,000
(13,100)
TOTAL REVISED WA BUDGET
$ 550,000 $ 550,000
E 7,050 LOE 7.050
FEES
5,635
3,020
2,950
1 1 ,605
25,250
13,080
(1,475)
TASK
TOTALS
85,635
44,520
42,950
173,015
390,250
195,880
(22,775)
VARIANCE
$
LOE
DATE REMEDIAL PROJECT MANAGER DATE
DATE REMEDIAL PROJECT OFFICER DATE
If there is a significant positive variance, an amended request should be
processed by the manager after discussions with the RPO.
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The RPM/PO will be responsible for approving the TDM by
completing the appropriate sections of the WAF and returning a copy
of the completed WAF to the contractor, the EPA PO and CO.
3.4.5.2 Amendment to Approved Final Work Plan
If it is determined that additional funds are needed, a major
change in overall scope or an individual task is required, or an
overall WA completion date change is necessary, the final work plan
must be amended to implement the changes. The contractor will
normally initiate a work plan amendment by submitting the detailed
scope, budget and schedule for the changes to the assignment to the
RPM/PO with an appropriately completed WAF. The contractor will
check the box labeled Amendment to Final Work Plan Approval on the
WAF and will include an OF-60 or SF-1411 as part of this
submission.
The contractor should include appropriate back-up information
with the amendment package. The additional information required
includes the following:
A detailed scope of work to be performed or a detailed
description of the changes that take place in the
assignment;
Schedule update, including task completion dates
(milestones), and critical path schedule (optional);
Staffing of each task affected; and
A detailed LOE and cost estimate for each task being
covered by the amendment.
The RPM/PO must evaluate and approve the amendments to the
Final Work Plan. The RPM/PO indicates approval by completing and
submitting the WAF and signing in the appropriate box. In
addition, the RPM/PO will need to check the funding level of the
project to determine if a procurement request will be required as
well. When the Amendment requires a change to the overall scope
or funding of the WA, the PO will forward the WAF to the CO for
approval. The CO will then forward copies of the approved
amendment to the contractor and PO.
3.4.5.3 Increasing Total Work Assignment Funding
In order to increase total WA funding, the PO must prepare a
PR and an amended WAF. The WAF must indicate the appropriate
information in Item 3, "Budget Information", by placing the
appropriate dollar figures in the This Action and Total rows.
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Increasing total funding on a WA requires the approval of the
CO. The PO must forward the amended WAF with the PR to the CO for
processing.
3.4.5.4 Increasing the Expenditure Limit
Increasing or lifting expenditure limits also requires the
preparation of an amended WAF. Item 3 on the form must be revised
to show the correct information in the "Expenditure Limit" column.
Increasing or lifting the expenditure limit requires CO approval
only if the action increases total WA funding. If the action to
increase or lift expenditure limits does not increase total
funding, the PO can approve the action, and will forward copies of
the amended WAF to the contractor and the CO.
3.4.5.5 Completion of the Project
Upon completion of the project, a WAF stating that the project
is complete (with appropriate detailed budget information) is
prepared by the contractor and submitted to the RPM. The RPM will
then sign the WAF and forward it to the CO with a copy to the PO.
Upon receipt of the WAF, the CO issues a Stop Work Order (SWO)
to the contractor and submits copies of the SWO to the RPM and PO.
The SWO will cover major technical activities only. Administrative
activities relating to close-out will proceed as needed.
With the SWO in-place, the contractor will begin the physical
project close-out. The physical close-out of a WA will include
the following activities at a minimum:
Compiling of project files;
Turning over all requested files (either in hard copy or
microfiche format) to EPA;
Turning over any Government-owned equipment to the project
inventory or to the EPA Equipment Coordinator (if
equipment was purchased with WA funds); and
Verifying that all appropriate site charges are being
processed for inclusion in the final invoice.
All other close-out procedures and subsequent processing guidelines
will be in accordance with the contractor's Management Plan.
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4.0 MANAGEMENT PLAN FOR MULTI-REGIONAL ARCS CONTRACTS
4.1 BACKGROUND
Management of ARCS contracts in the two Multi-Regional Zones
will require some modification to the management procedures and
responsibilities designed for the single Region ARCS programs.
This section describes procedures for managing ARCS contracts in
the Multi-Regional Zones, by addressing how this situation differs
from ARCS contract management in a single Region. Specifically,
this section addresses the required coordination between Regions
for Award Fee determination, work assignment selection, and
maintenance of contract records.
These instructions focus on activities of Project Officers
(POs) in the Multi-Regional Zones. As in single Region ARCS, a PO
must be appointed in each Region. However, this individual will
perform two separate functions:
He will be the PO for selected ARCS contractors within
the Zone based on the contractors' proximity to the EPA
Regional Headquarters and will perform general contract
administration functions for that contract in accordance
with the guidance in this document.
He will serve as Deputy Project Officer (DPO) for all
other contracts within the Zone and will have direct
project management responsibility for all remedial
projects within the Region.
The duties of other EPA personnel such as Regional Contracting
Officer (CO) and the Remedial Project Manager (RPM) will remain
essentially unchanged from those in single Region ARCS.
A graphic representation of the organizational plan for
Multi-Regional ARCS contract management is depicted in Exhibit
4.1-1.
4.2 GENERAL CONTRACT ADMINISTRATION
While it is vital to the ARCS program that EPA Regional offices
retain management authority for remedial projects within their
Region, the ARCS contractors must have a single point of contact
for general contract management and administration. In the
Multi-Regional Zones, a single PO will be assigned for general
contract administration of each contractor. The PO will conduct
the administrative and recordkeeping functions that are not
project-specific and will provide necessary coordination for
functions such as award fee determination and new work assignment
distribution that require input and/or participation from more than
one Region.
4-1
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EXHIBIT 4.1-1
Organizational Plan
For Multi-Regional ARCS Contract Management
Region VI
Project Officer for
Contractor A
(located in Reg. VI)
Deputy Project
Officer for
Contractors B, C
(working in Reg. VI)
Contracting
Officer
(For All Contracts)
;Region VII
Project Officer for
Contractor B
(located in Reg. VII)
Deputy Project
Officer for
Contractors A, C
(working in Reg. VII)
Region VIII
Project Officer for
Contractor C
(located in Reg. VIII)
Deputy Project
Officer for
Contractors A, B
(working in Reg. VIII)
Remedial
Project
Managers
Remedial
Project
Managers
Remedial
Project
Managers
Deputy Project Officers have full authority to manage Work Assignments within their
Region. DPOs must forward copies of all relevant contract documentation to
the assigned PO for central filing.
4-2
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The PO assignments will be based on the proximity of the EPA
Regional office to the management and administrative offices or
Headquarters of the ARCS contractor. For example, an ARCS
contractor with Headquarters in Colorado Springs, Colorado, would
be assigned to a PO in Region VIII. If an ARCS contractor does not
have Headquarters or administrative offices within the Zone, or
has several offices in different Regions within the Zone, the PO
assignment will be designed to maximize administrative convenience
for EPA and the vendor, and to control travel costs. EPA has
complete discretion in assigning POs to ARCS contractors, and there
is no requirement to formally justify the selection. Regions,
however, should make PO assignments that will facilitate timely and
cost-effective administration of the contracts. Where a question
arises regarding the appropriate assignment, the ARCS contractor
may be queried as to his preference during final negotiations.
4.3 MANAGING WORK ASSIGNMENTS
Each PO in a Multi-Regional Zone will serve as DPO for ARCS
contractors that are assigned to other Regions within the Zone for
general contract administration. For example, a contractor with
Headquarters in Dallas will have its PO in Region VI and will have
DPOs in Regions VII and VIII. POs in each Region within a Zone
will therefore have full authority to manage all work assignments
within their Region.
When applicable, DPOs will coordinate activities with the PO
to assure compliance with basic contract terms and conditions and
will forward copies of all work assignment documentation to the PO
to allow maintenance of a single, complete contract file. Also,
the DPO and PO must coordinate activities with the CO and obtain
CO signature and/or approval whenever necessary. PO/DPO
responsibilities for work assignment management include:
Pronect Management - The PO/DPO will have full authority
to issue and manage work assignments within the Region.
Specific activities include:
Issue and amend work assignments
Approve work plans
- Provide technical direction
Monitor contractor performance
Direct activities of the RPMs within their Region
Prepare Award Fee Performance Event Reports and Work
Assignment Completion Reports for use by the
Performance Evaluation Board (PEB).
4-3
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Project Coordination - In cases where a DPO is managing
a work assignment performed by an ARCS contractor which
reports to a different Region for general contract
administration, the DPO will be responsible for
coordinating activities with the PO where necessary and
for forwarding all project-specific documentation to the
PO for the central contract file. Records that must be
forwarded to the PO include:
Work assignments and amendments
Final work plans
Written technical direction
Records of disputes or performance problems
Copies of approved invoices
Any written reports on contractor performance
Copies of all subcontracts
Any documentation regarding conflict of interest.
The above list is not intended to be comprehensive. The
DPOs are responsible for forwarding to the PO any
information that relates to the general contract
administration responsibilities described above.
4.4 AWARD FEE DETERMINATION MEETING
The PEB in Multi-Regional Zones should be made up of
representatives of each Region and will be convened on a rotating
basis in each Regional office. It is suggested that the Division
Director in the host Region act as PEB Chairman. The PO in the
host Region will coordinate PEB meetings by setting schedules and
agenda, arranging for conference or meeting facilities, collecting
and distributing the individual contractor performance information
packages, and providing an Executive Secretary for the PEB who will
prepare the Performance Evaluation Report. The award fee
determination process is discussed in Section 3.2.
4.5 WORK ASSIGNMENT DISTRIBUTION MEETING
Project-specific work assignment distribution for
Multi-Regional Zones will be performed annually. Meetings
involving representatives from each Region should be rotated among
the Regions and chaired by the PO in the host Region. Any
reasonable and consistent procedures that comply with the
4-4
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requirements for distributing work and exercising contract options
under ARCS (Section 3.3) are acceptable.
4-5
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APPENDIX I
EPA Directives
DIRECTIVE #
9230.0-02
9230.0-03a
9230.0-05
9234.0-02
9234.0-04
9234.0-05
9240.0-01
9240.0-02
9242.3-07
9260.2-00
9272.0-05
9280.0-01
9283.1-01
9283.1-02
EFFECTIVE DATE
11/85
10/83
02/84
08/86
07/87
10/84
08/86
03/86
08/85
09/84
08/85
03/86
TITLE
Super fund Community Relations Policy
Community Relations Activities at
Superfund Enforcement Sites:
Interim Guidance
Community Relations Requirements for
Operable Units
CERCLA Compliance with Other
Environmental Statutes
Applicability of RCRA Requirements
to CERCLA
Interim Guidance on Compliance with
Applicable or Relevant and
Appropriate Requirements
User's Guide to the
Laboratory Program
Contract
Analytical Support for Superfund
Draft - Implementation of the
Decentralized Contractor Performance
Evaluation and Award Fee Process for
Remedial Program Contracts
CERCLA Delegations of Authority (Set
of all current delegations)
Responsibilities
Facilities
for
Federal
Flood Plain Requirements
Recommendations for Ground Water
Remediation at the Millcreek,
Pennsylvania Site
Draft - Guidance on Remedial Actions
for Contaminated Groundwater at
Superfund Sites
1-1
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DIRECTIVE #
9285.1-01B
9285.2-01
9285.2-02
9285.2-03
9285.2-04
9285.2-05
9285.3-02
9285.4-01
9285.5-01
9285.6-01
9295.1-01
9295.2-03
9295.5-01
9318.0-02
9318.0-03
EFFECTIVE DATE TITLE
11/84
01/85
01/85
01/85
04/85
03/84
07/87
10/86
12/86
06/83
08/83
05/81
08/81
Standard Operating Safety Guide
Manual
Field Standard Operating Procedures
Manual S: FSOP #4 Site Entry
Field Standard Operating Procedures
Manual S: FSOP #7 - Decontamination
of Response Personnel
Field Standard Operating Procedures
Manual S: FSOP #8 - Air
Surveillance
Field Standard Operating Procedures
Manual S: FSOP #6 - Work Zones
Field Standard Operating Procedures
Manual S: FSOP #9 - Site Safety
Plan
Employee Occupational Health and
Safety
Superfund Public Health Evaluation
Manual
Draft - Superfund Exposure
Assessment Manual
Superfund Risk Assessment
Information Directory
MOU Between the ATSDR and EPA
Interagency Agreement Between the
Corps of Engineers & EPA in
Executing PL 96-510 (CERCLA)
MOU Between FEMA and EPA for the
Implementation of CERCLA Relocation
Activities Under PL 96-51
Guidance on Superfund NEPA Policy:
Areas of Responsibility
CERCLA Remedial Actions and NEPA/EIS
Functional Equivalency
1-2
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DIRECTIVE #
9318.0-04
9320.2-03
9330.1-02
EFFECTIVE DATE
08/84
04/86
01/83
9330.2-04
9347.0-01
9355.0-04A
9355.0-05C
9355.0-06B
9355.0-07A
9355.0-07B
9355.0-10
9355.0-14
9355.0-19
9355.1-01
05/85
01/86
06/86
06/86
06/85
06/85
04/85
11/85
08/86
12/86
TITLE
Coordination Between Regional
Superfund Staffs and OFA Regional
Counterparts on CERCLA Actions
Draft - Guidance on Deletion of
Sites from the National Priorities
List (NPL)
Evaluation of Program and
Enforcement Lead RODs for
Consistency with RCRA Land Disposal
Restrictions
Discharge of Wastewater from CERCLA
Sites into POTWs
Interim RCRA/CERCLA Guidance on
Non-Contiguous Sites and On-Site
Management of Waste Residue
Superfund Remedial Design
REmedial Action Guidance
and
Guidance on Feasibility Studies
Under CERCLA
Guidance on Remedial Investigations
Under CERCLA
Draft - Data Quality Objectives
Development Guidance for Remedial
Response Actions
Data Quality Objectives for Remedial
Response Activities (2-volume set)
Remedial Action Costing Procedures
Manual
A Compendium of Superfund Field
Operations Methods (2-Volumes)
[Formerly: Draft - Quality
Assurance/Field Operations Methods
Manual]
Interim Guidance on Superfund
Selection of Remedy
Federal-Lead Remedial Project
Management Manual
1-3
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DIRECTIVE #
9355.3-01
9360.0-10
9360.0-13
9360.0-15
9375.1-04
9375.1-05
9375.1-09
EFFECTIVE DATE
12/86
12/85
04/87
02/87
05/84
03/86
02/87
9380.0-02
9380.0-03
9380.0-04
9380.0-05
9380.0-06
03/84
02/84
05/85
10/85
11/85
9380.2-03
11/85
TITLE
Guidance Document for Providing
Alternative Water Supplies
Expedited Response Actions
Guidance on Implementation of the
"Contribute to Remedial Performance"
Provision
The Role of Expedited Response
Actions Under SARA
State Participation in the Superfund
Program, Volume 1
State Participation in the Superfund
Program, Volume 2
Interim Guidance on State
Participation in Pre-Remedial and
Remedial Response
Slurry Trench Construction for
Pollution Migration Control
Guidance Document for Cleanup of
Surface Tank and Drum Sites
Remedial Action at Waste Disposal
Sites Handbook (Revised)
Leachate Plume Management
Guidance Document for Cleanup of
Surface Impoundment Sites
Superfund Innovative Technology
' Evaluation (Site) Program Strategy
and Program Plan
1-4
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APPENDIX II
Program Management Award Fee Allocation
The available award fee pool for any program management (PM)
base or option award will be allocated evenly over three rating
periods. Because PM options may be exercised at any time, the
additional award fee, made available with the exercise of an
option, will be added to the pool already available in the rating
periods affected. If the PM option is awarded prior to the
mid-point of a given rating period the award fee pool allocation
will begin with that rating period. If the option is exercised
after the mid-point of a given rating period the award fee pool
allocation will begin with the next rating period.
Exhibit II-l illustrates the PM award fee allocation
methodology by showing the available award fee pool for the
hypothetical ARCS contract described below:
Contract Award Date - January 1, 1988
Award fee rating periods - Four months each, beginning January
1988
First year base PM award fee pool - $30,0(1)0
First year option PM award fee pools - $15,000 each
Second year base PM award fee pool - $24,000
First PM option award - May 30, 1988
Second PM option award - November 15, 1988
The base award fee pool in this situation is allotted evenly
between the first three rating periods with $10,000 allocated to
each. With the award of the first PM option on May 30, the award
fee pool allocation of $5,000 for each of three rating periods
begins in the second rating period (May 1, 1988 to September 1,
1988) , because the award date falls in the first half of that
rating period. The award fee pool allocation for the second PM
option award begins in the fourth rating period (January 1, 1989
to May 1, 1989), because the option award date falls in the second
half of the third rating period. The second year base PM award fee
pool allocation begins with the fourth rating period.
In each case, the award fee pool allocation is added to the
pool already available for a given rating period. Thus the award
of a PM option during the second rating period adds $5,000 in award
fee to the pool of $10,000 that was allocated in the base award to
the second and third rating periods, and the award fee pool in
II-l
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EXHIBIT II -1
AWARD FEE POOL ALLOCATION
AWARD FEE
POOL AVAILABLE
FROM AWARD
1/1/88
AWARD FEE
POOL AVAILABLE
FROM PM OPTION
EXERCISE 5/30/88
AWARD FEE
POOL AVAILABLE
FROM PM OPTION
EXERCISE 11/1 5/88
AWARD FEE
POOL AVAILABLE
FROM 2ND YEAR
BASE PM
ALLOCATED 1/1/89
TOTAL AWARD FEE
AVAILABLE AT END
OF RATING PERIOD
RATING PERIOD |
JAN. 1 -
APR. 30,
1988
10,000
10,000
MAY1-
AUG.31,
1988
10,000
5,000
15,000
SEPT. 1 -
DEC. 31,
1988
10,000
5,000
15,000
JAN. 1 -
APR. 30,
1988
5,000
5,000
8,000
18,000
MAY1-
AUG.31,
1989
5,000
8,000
13,000
SEPT. 1 - 1
DEC. 31, 1
1989 i
i
1
1
I
5,000 1
I
II-2
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subsequent rating periods increases with each option or base award.
The column at the bottom of Exhibit II-l shows the total available
award fee at the conclusion of each rating period.
The PO is responsible for reporting the available PM award fee
pool for each ARCS contractor to the FEB. This computation should
take place after the mid-point of any rating period to ensure that
all PM options that would apply to that rating period are included
in the award fee pool allocation.
II-3
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APPENDIX III
WORK PLAN EVALUATION CHECKLIST
Addressing the Work Assignment (WA)
A. Does the contractor address all WA requirements?
YES
(Describe what requirements must be addressed)
NO
B. Does the contractor include any work that is not required?
NO
(Describe extraneous work included by contractor)
YES
C. Is the schedule, including critical path and interim
milestones, acceptable?
YES
(Describe a realistic schedule)
NO
D. Is the management structure sound? Does it include appropriate
quality assurance procedures?
YES
(Describe problems with management structures)
NO
Skill Levels/Hours
A. Is the caliber of personnel proposed appropriate for the work
involved?
YES
(Describe the professional and technical levels
NO suitable for the WA)
III-l
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B. Comment on the number of hours proposed in each labor category.
(Discuss the make-up of the labor spread including
amounts of supervisory, professional, technical, and
clerical effort)
C. Are there concerns that key personnel will not be available as
proposed?
NO
(Identify possible problems with availability
YES of key personnel)
Material and Equipment
A. Evaluate the reasonableness of the types of material and
equipment proposed.
B. Indicate the reasonableness of proposed prices for material
and equipment.
(Include pertinent catalogue information in explanation)
C. May Government furnished property/material be used?
NO
(Describe GFP/GFM that may be used, and
YES availability)
III-2
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Travel
A. Is the number of trips reasonable?
YES
(Describe the trips that should be taken and the
NO recommended number of trips)
B. Should the length of stay and number of travelers be adjusted?
NO
(Discuss the need for certain parties to attend
YES meetings and how long visits should be)
Consulting and Subcontracting Effort
A. Evaluate the reasonableness of consultant effort proposed.
B. May other consultants be considered?
NO
(Explain)
YES
C. Evaluate the proposed subcontracting effort and costs.
D. Are the subcontractors cited in the WP on the list of approved
subcontractors?
YES
NO
III-3
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Computer Effort and Printing
A. Evaluate the need for the computer effort proposed.
B. Has OIRM reviewed for use of Government computer sources?
YES
NO
C. Comment on the proposed costs associated with printing and
preparing reports.
SAFETY AND CONTINGENCY MEASURES
A. Are the proposed safety and contingency measures adequate?
YES
(If no, explain problems and possible remedies)
NO
III-4
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SUMMARY
The aforementioned aspects of the submitted WP are recommended for
approval, approval with changes, and/or disapproval, as appropriate.
If no changes to the WP submission are recommended, the AGO may approve
the final WP. However, if changes are recommended, the AGO may use
this memo to justify negotiation of additions or subtractions to WP
skill levels/hours, consultant efforts, types of material and
equipment, travel, computer effort, printing, etc.
APPROVED
APPROVED W/CHANGES DISAPPROVED
1. Addressing the WA
2. Statement of Work
3. Skill Levels/Hours
4. Material and Equipment
5. Travel
6. Consulting and
Subcontracting Effort
7. Computer Effort and
Printing
8. Safety and Contingency
9. Other
RPM/RPO SIGNATURE DATE
III-5
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APPENDIX IV
LIST OF ACRONYMS
ARCS Alternative Remedial Contracting Strategy
CO Contracting Officer
COI Conflict of Interest
CPAF Cost-Plus-Award-Fee
DPO Deputy Project Officer
FDO Fee Determination Official
LOE Level-of-Effort
NPL National Priorities List
ODC Other Direct Charges
PEB Performance Evaluation Board
PER Performance Evaluation Report
PIRS Performance Index Rating Score
PM Program Management
PO Project Officer
PR Procurement Request
RA Remedial Action
RD Remedial Design
REM Remedial Planning Contractors
RES Regional Evaluation Summary
RI/FS Remedial Investigation/Feasibility Study
RPM Remedial Program Manager
SCAP Superfund Comprehensive Accomplishments Plan
SER Summary Evaluation Report
SOP Standard Operating Procedure
SOW Statement of Work
SWO Stop Work Order
TDM Technical Direction Memorandum
WA Work Assignment
WACR Work Assignment Completion Report
WAF Work Assignment Form
WPM Work Plan Memorandum
IV-1
, US GOVERNMENT PRINTING OFFICE: 1M9 . 648-163/00320
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