UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLD WASTE AND EMERGENCY RESPONSE
ALJG 3 I 1990 OSWER Directive 9242.6-07
MEMORANDUM
SUBJECT: Approval of Long Term Contracting Strategy for
Superfund (Superfund Management Review:/ Recommendation
E.2)
FROM: Henry L. Longest II, Director
Office of Emergency and Remedi
TO: Don R. Clay
Assistant Administrator
PURPOSE
I have attached for your approval a paper which summarizes
the issues, findings, analysis and recommendations for the
Superfund Long-Tenn Contracting Strategy. Implementation plans
will be developed subsequent to your approval.
BACKGROUND
The issues, analysis and recommendations contained in this
paper are the products of an Agency-wide task force comprising
representatives of the Office of Emergency and Remedial Response,
the Office of Waste Programs Enforcement, the Procurement and
Contracts Management Division, as well as the ten Regions and
Headquarters project officers, contracting officers and other
affected organizational entities. The overall effort is
a 90-Day Study project scheduled for completion at the end of
August 1990.
As part of this effort a broad analysis was conducted on the
program's dependence upon contractor support. The analysis
ranked Superfund contractor work in terms of its relationship to
the decision-making process and the perception of overdependence.
The analysis indicated that the Superfund work being performed by
our contractors is legal, appropriate, and within the scope of
OMB guidance on contracting. Because of the large resource
implications, a recommendation was made to maintain the same
Pruutd on Rtcyeltd Paptr
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level of Superfund contracting while strengthening contracts
management through increased training, clear policies and proce-
dures, and increased management attention.
The attached Executive Summary outlines the recommended
strategy. In addition, the attached paper contains a discussion
of the development of the strategy, the key evaluation factors,
the five options developed by the task force and the analysis of
those options by the key subgroups. The task force subgroups
analyzed the structure, competitive aspects, roles and respon-
sibilities, legislative impact and organizational barriers posed
by the optional contracting approaches. Detailed appendices
containing documentation of the analyses are available upon
request.
The regional representatives of the task force supported
continued decentralization under the final recommended strategy.
The workload analysis developed by the task force demonstrated
that the resources needed to support the strategy are approxi-
mately the same as current levels of personnel (both program and
contract office) provided in the budget.
The recommended strategy addresses Superfund contracting by
each of the program functions. This strategy balances the key
evaluation criteria and the needs of the various program func-
tions. The Executive Summary con- *. ins a description of the
components supporting the program functions.
The Long-Term Contracting Strategy recommends that
preremedial and removal support be combined. This involves
merging the two dedicated teams the Field Investigation Team
(FIT) and the Technical Assistance Team (TAT) . These regionally
based teams will provide technical assistance to both the site
assessment and removal programs. The strategy proposes that the
site cleanup needs of the removal program will continue to be
addressed by a decentralized approach which includes
time-critical and site-specific contracts. In addition, rapid
response capabilities for the remedial program will be included
in these contracts. For the rare nontime-critical responses,
activities will be integrated into a response action contractor
function.
In evaluating the needs of the preremedial program, the
Imminent expiration of the Field Investigation Team (FIT) -con-
tract (September 1991) required the evaluation of an interim
.implementation plan, as well as long-term recommendations. The
strategy recommends using ARCS contract -capacity to support
preremedial activities for up to three years. We will work to
assure that the ARCS contracts contain administrative procedures
which minimize the burden placed on the Regions using this new
structure. The procedures will also provide for the rapid
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response capabilities to which the Regions have become accustomed
in use of the FIT.
The remedial and enforcement oversight responsibilities are
proposed to be integrated into a single response action contrac
tor structure. In addition, specialized enforcement activities
are proposed to be separated into regionally-based contracts to
provide items such as litigation support and potential respon-
sible party searches. Separate administrative and regional'
management support contracts will also be developed. :
The component of the recommendation related to analytical
support under the current Environmental Services Assistance Team
contracts, proposes decentralized regional contracts. However,
the task force deferred a final decision on decentralization of -
the Contract Laboratory Program pending additional study and the
outcome of several pilot efforts. This recommendation reflects
Regional requests by both the Waste Management and Environmental
Services Divisions.
Finally, at Regional request, a centralized transportation
and disposal broker contract is proposed to assist Regions in
locating and procuring such activities nationally. The services
that would be provided under this contract will require further
definition and evaluation prior to implementation.
OBJECTIVE
I am asking for your approval of the recommended strategy.
The final strategy is required to be completed by the end of
August 1990.
IMPLEMENTATION
This strategy is intended to be a road map for the next
decade of Superfund contracts. We will continue to evaluate the
strategy in light of changes that may occur in the program. Upon
your approval, an implementation plan will be developed to phase-
in the new contracting structures as existing contracts expire
and to avoid program disruption. The plan will be developed by
the Long-Term Contracting Strategy Task Force and will outline
our approach to initiating the new contract program.
Attachments
f
Approve
^/
Date.
Disapprove
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cc:
.Bruce Diamond, Director, OWPE -
David O'Connor, Director, PCMD
Regional Waste Management Division Directors :
Regional Environmental Services Division Directors
Office of Emergency and Remedial Response Division Directors
Mark Walker/PCMD
Elaine Stanley/OWPE
Sally Mansbach/OWPE
Tim Fields/OERR
Clem Rastatter/OERR . .., . .
Long-Term Contracting Strategy Task Force
Regional Quality Assurance Officers
ASAC Members
Stanley Laskowski, Region III, Lead Superfund Region
William Muszynski, Region II, Lead Superfund Region FY91
Superfund Branch Chiefs, Regions I - X
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LONG-TERM CONTRACTING STRATEGY FOR SUPERFUND
TASK FORCE MEMBERS
REGION 1
REGION 2
REGION 3
REGION 4
REGION 5
REGION 6
REGION 7
REGION 8
REGION 9
REGION 10
Dennis Gagne
Joshua Nemzer
Shaheer Alvi
Deborah Butler
Peter Schaul
Marie Murphy
Matt Robbins
Jane Singley
Carol Monell
Jan Rogers
Bobby Carroll
Cindy Wakat
Elissa Speizman
Carlene Chambers
Chris Peterson
Alan Wehmeyer
Larry Kalwei
Charles Mooar
Peter Orth
Kathy Davidson
D.J. Lovelady
OEKR/OPM
OERR/HSCD
OERR/ERD
OERR/HSED
OWPE
PCMD
OSBDU
Clem Rastatter
John Jaksch
Debbie Dietrich
John Comstock
Kay Waters
Linda Garczynski
Kerry Kelly
Paul Nadeau
Scott Fredericks
Robert Heffeman
Bruce Engelbert
Susan Janowiak
Lynn Beasley
Frank Biros
Mike Kosakowski
Walt DeRieux
Mark Walker
Ika Joiner
Bill Topping
Pat Patterson
Louise Senzel
Dave Stutz
Jordan Strauss
Tom O'Connell
Margie Wilson
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EXECUTIVE SUMMARY
,.i ;no "*.ป-7A.-.'_ i !
The Agency developed a Superfund Long-Term Contracting
Strategy to meet two objectives.- First,-to.-analyze the long-term
contract needs of the Superfund Program,-and second,, to design a^
portfolio of Superfund contracts.to meet those needs over the j
next ten years. '.'-'. ' '-.'.'. ;..-..:... ..- . ^-:'-.ii "
Analyzing Superfund Contracting Needs -:,.-- --.-..
ซ- le-fc-i-'. _ ..-. -_.' - j.. 1 ,..,"_.- .. J...J. iCCJ Jป '; -"-,.->.'. -l..v_ ,'j " ' . .- :."...'
In analyzing Superfund Program contracting- needs) several
assumptions were made about the future direction of the Superfund
Program. The Agency assumed program priorities and policies will
continue to change as the program matures. For example, the May
1989- Superfund Management Review, presented, new areas of program
emphasis including an integrated "One Program" approach to
enforcement and response. Reauthorization of the Superfund
legislation may also bring changes to the program. : The Agency
also recognized that effective cleanup of Superfund sites will be
a complex, long-term effort. Additionally, competition for
scarce resources and changes in program focus may lead to
fluctuations in the Superfund budget* These factors indicate
that the Agency needs to establish a contracting strategy that
will support both current and future program goals. -
Strategy Direction ' .. .-j. - : :--:';ซ-:.
The Superfund Long-Term Contracting Strategy is built on
several key principles. The strategy is designed to:
Support an integrated "One Program" approach to
enforcement and response;
Support project management from site discovery through
remedy construction; -
4
Build in flexibility to respond to changing program
priorities and budgets r ; - '
Support rapid response to immediate risks;
Decentralize contracts management to the Regions where
practicable; and
Be implemented to avoid program disruption. '
Approach,
An agency-wide task force was formed to analyze the
contracting needs of the Superfund Program and recommend a
portfolio of contracts:""The Long-Term-Contracting Strategy Task
Force comprises the Office of Emergency and Remedial Response,
Office of Waste Programs Enforcement, the Procurement and
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Contracts Management Division,.:the Office of Small and
Disadvantaged Business Utilization, and the Regions' Waste
Management, Environmental Services, and Management Divisions.
^V-.?"The-'task force developed, four contracting options in - '--..
addition-- to- the: status.: quo,~ and identified issues and, evaluation.
criteria'for their analysis~ Key issuesi examined by the task.--/-,
force included: . .V:v: '.~;..~'^"~''7eifi-svrr\-^ ";ฑ-"Tr
What contracting approach will best support an -.'"--
integrated "One Program" with flexible responses? , ;
-"'-- ป ..- what: contracting approach will, best deal with program ,
--:-: and budget changes? .^i.:;; /.; : A - : ., - .
-- - ป ; What contracting approach will promote .decentralization
- and create program, efficiencies?. r,s r::12>ii_^:_ :!_;-.-. ^
"--: 7*-. What contracting approach will, best maintain and~~^V~
-:"..: .v -^.increase competition? :_ i-^j..;^^;^i>
Various aspects of each option were evaluated including ,
structure, legislative-effects, impact on EPA resources, roles -
and responsibilitiesr organizational barriers,, .and competition
(see Chart I-Analysis of Options by Evaluation. Criteria,, page yj .
Each option's impacts on the program functions (e.g.,
preremedial, removal, and remedial) were also analyzed.- The task
force then selected elements of the options that best served each
program function while meeting the evaluation criteria. z ,
Loncr-Term Contracting Strategy
The Long-Term Contracting Strategy promotes program
integration, incorporates flexibility to meet change, and
balances the various evaluation criteria. The strategy supports
the "One Superfund Program" concept and minimizes handoffs by
integrating cleanup activities according to response needs rather
than NCP classification.. In addition,, enforcement oversight and
remedial response are consolidated to increase regional
flexibility to pursue various enforcement, options. The .following
summary presents an analysis of the strategy by program function
(also see Chart II-Long-Term Contractfng Strategy, page vi).
Preremedial
For the long-term, the strategy creates regional contracts
with dedicated teams performing both oreremedial Field
Investigation Team (TIT) activities and removal Technical
Assistance Team fTATl activities. This approach will promote
program integration and early action at Superfund sites by
coordinating site discovery, investigation, and removal
assessment"activities;^ The combined teams will-:also provide the
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Regions with flexibility to respond to changing budgets and
workloads. Finally, the approach enhances preaward competition,
opportunities for snail business participation, and
decentralization by creating smaller, regionally; based contracts.
Because ther FIT contract is ^ due" to expire In 1991,^ the- task: force
also considered interim approaches- to- facilitate transition^to^
the new contract mechanism. - The strategy ' uses ARCS' contract ''zs'S
capacity to support preremedial activities for up to> three years.
-~- - -ซ . _ .-.'. - , . ..-...,....;.- ---':-. -~>::-~:.'j ";.... v /io I :,>y^--..^--'iCฃ?'
Removal ........ ;. .....:.., ^._-^;..- , . .. .v ,-;:._ c:r; jr . .:yrฃ^^;;:^
The strategy creates regional FIT/TAT contracts. : The - -'.ป-
strategy provides flexibility for the Regional Removal Programs
by maintaining a dedicated technical assistance team for
emergency response . ; The strategy co]flfrjn^s time critical removal
cleanup activities with rapid remedial responses. -This approach
enhances flexibility and promotes program integration, by _~; "--';ir
providing all rapid response capabilities under a single regional
contract mechanism. It also reduces* the handoffs that can occur
between removal and remedial during rapid responses at Superf und
sites. Further, competition and small business participation are
enhanced through creation of smaller, regionally based cleanup
contracts. ;- - " .--'
Remedial ; - - -' - - ..-; _--' - ^-L.^^r.: ...
The strategy combines all remedial activities, enforcement
oversight, and nontime-critical removals under a single regional
contracting mechanism. This approach will reduce handoffs and
promote program integration by creating one umbrella program to
perform all remedial and enforcement oversight work. Integrating
remedial action with enforcement oversight will give the Regions
flexibility to pursue various enforcement options. Contract
management impacts will be minimized because the new contracts
can use the existing management infrastructure created for the '
ARCS contracts. Also, the numbers of contracts will be reduced
by eliminating separate TES oversight contracts. Multiple
remedial contracts, available to each Region, will provide
flexibility to respond to potential conflict of interest .
problems, and enhance postaward competition based on contractor
performance.
Enforcement support
The strategy creates small regional contracts to provide
specialized enforcement support services. The new contracts
will provide enhanced support to Superfund enforcement efforts by
supplying expertise for specialized efforts such as PRP searches
and litigation and negotiation support. This should reduce the
appearance of conflict of interest by removing this specialized
support from a response action contract.
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Regional Management,Support
" '-
.- The strategy creates small regional contracts to provide ""'
Regional management support. These contracts will provide vital
ปadministrative support to On-Scene Coordinators and-Remedial. ,^
Project. Managers, as:well~a& information management:; support^ The
task,: force: agreed ,^ however, that, the contract, scopes;! ofT work? must:
.be further defined.*>-Pre-award competition,"small business;^^'_- ;.
participation, and decentralization will be enhanced, by creating;
these small, regionally-based contracts. v. , _
Analytical support^ __ ^ . -,.. ..,, ^ .~ .. ..-. -
---.- T * >'7-"'~ ~ " " --.ป.--: - . .. ' ' ' ~. ~~ -. -""-.- .'.._" j
The strategy decentralizes the Environmental Services 'r' "".
Assistance Team fESAT^ contracts, but deferred a decision on
decentralizing the Contract Laboratory Program fCLP^ pending ~i}~^~'
further analysis .~~->:This- approach minimizes 'opportunities f orr ;;
I conflict of -.interest by maintaining' atvseparatecontract for data
review .cc. The..approach also promotes decentralization/and .__".".'
increases .opportunities for. small business-participation i
creating smaller, regional contracts'.~..~~.~~\ ~ "*" ' ""'~^" vt
Transportation & Disposal Broker
The strategy recommends evaluating the creation of a
national T & D Broker. Such a contract might assist in ~
minimizing the delays experienced with, current disposal
arrangements. -The task force agreed the Regions need enhanced .
support in tracking facility status, comparing disposal and ~;~
transportation- costs, and arranging for disposal.. The expertise
of a national broker might make the disposal process more :*,"
efficient and consistent across sites, and achieve economies of
scale not now realized at the regional level. " .^ .~1'. ""..'-7^'"'"'
Community Relations- -'"'- ' - - * -.'"'''*"'""
.~ -. j -~ .. -..._..-..;ซ
The task 'force discussed the need to enhance the consistency
and credibility of Superfund community relations. The task force
recommended .that an evaluation of integrated community relations
support within the remedial contracts, and a review of the* :'".,
advisability of bringing some community relations activities in-
house be performed.
Next Steps :
The next steps for the task force will involve developing a
strategy implementation plan. This plan will phase-in new
contract procurement as existing contracts expire, to avoid
disruption of program activities. ..";.., .. .. ;_.
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Analysis of Options by Evaluation Criteria
PTION OPTION OPI ION OPTION OPTION
Evaluation Criteria
6. Contract Program
Management Costs
7. Reduces Duplication Between
HQ&. Regions
8. Reduces Handoffs
9. Minimizes Organizational impact
10. Minimizes Programmatic Impact
11. Reduces Numbers of Contract
12. Minimizes Conflict of Interest
13. Minimizes Implementation Efforts
14. Increases Small Business
Participation
15. Minimizes Legislative Impact
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Recommended Long-Term Contracting Strategy for Superfund
Headquarters
:;tll.Natlppal|i::I
llContractill
CorrtnMH Laboratory
Program
CLP*
Each EPA
Region
Enforcement
Support Contracts
i
Time Critical/
Rapid Response
Activities
Environmental
Services Assistance
Team
(ESAT)
1
Transportation
and Disposal
"""
Regional Management)
Support Contracts
Field Investigation Team /
Technical Assistance
Team
(FnYTAT)
Response
Action
Contracts
1
Site Specific
Contracts
l'! Defers decision on decentralizing CLP pending further study.
2. *Creates concept of national broker for transportation and disposal services. Further evaluation to be conducted.
3. Creates regional contracts for PRP searches and litigation support, and separate regional contracts to provide data entry, management, and administrative support.
4, Combines removal time-critical and rapid remedial response activity.
5. Decentralizes ESAT to Regions.
6 Combines two dedicated team programs (TAT, FIT) into one program for removal and preiemcdial activities. .
7, Integrates enforcement oversight of PRP lead remedial activities into response action contracts for RI/FS, RD/RA and non-lime critical removals.
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LONG-TERM CONTRACTING STRATEGY FOR SUPERFUND
Iป IHTRODUCTION V. - V ""':..' ':i'V4
. , The Environmental. Protection Agency, developed the Long-Term
Contracting Strategy for Superfund to define the shape ~of the 7~-
portfolio of Superfund contracts over the next ten years- The f?X
Superfund Program over the years has undergone many changes in~w
emphasis as it has matured. One of the key results^ of this ---
maturation process is a recognition that flexibility to .respond
to changes, such, as fluctuating budgets,: modified regulations,. :
statutes and policies will need to be a cornerstone of the /'
defined strategy* \ . - V : ' -;:'
"""".... . . ' f-
- *,,- This paper summarizes the background of the strategy, the
program direction, key issues, and strategy objectives. Section
IX outlines-the approach'taken to develop the strategy; Section
III provides a"summary of the 'analysis of the'optional approaches
designed to meet the strategy objectives and evaluation criteria.
Finally, Section XV analyzes .the components of the recommended
structure for the strategy. '"Detailed documentationSupporting
this summary is available in appendices, as noted throughout the
text. ..-.-..'.' ' ' ' " " '":" " ' . ' ^ "-
Background . , "".. ' '.'.'.' _ '
The Superfund. Management Review issued in May 1989
emphasized the need for a long-term contracting strategy
incorporating the key objectives of the Review. These
objectives: the integration of program elements (e.g.,
enforcement, remedial, removal) into none program" to more
effectively pursue cleanup of Superfund sites, the need for
making all sites "safe" via early action to mitigate immediate
risks, the emphasis on pursuing enforcement actions prior to
committing fund money for cleanup, and the need for flexibility
in administering the .program, have defined and shaped the final
recommendation for the long-term contracting strategy.
In addition, the Superfund program recognized the need to
improve its contract management. Outside scrutiny by Congress,
the Office of the Inspector General, and the General Accounting
Office also highlighted areas of contract management which needed
improvement. In response, EPA has instituted many improvements
in the short term management of the contracts (e.g., development
of training programs for On-Scene Coordinators, Work Assignment
Managers, and Remedial Project Managers; issuance of policies on
conflict of interest; improved cost control mechanisms). These
short-term improvements will continue to be developed and
implemented as an ongoing part of the contracts management
process. However, it was also decided that resolution of some
issues would best be done in the context of the development of a
long-term contracting strategy (e.g., improved contract
management via delegation of authority to Regions).
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Program Direction
In developing the Long-Term Contracting Strategy, it was
necessary to define the future direction of the program in order
to tailor the strategy to fully support the program. Certain key
trends were determined to influence Superfund contracting- (see
Appendix 2} '-' ~. The budget process and determination-of priorities
will be affected by these .trends." ;Several important, points '
defining these trends came,to light. - 7 -=',--'- - :-.
* -- -- '- -*" - ''' ''
It. is .expected that, the .queue of sites awaiting ranking for
the'National Priorities List'"'(NPL) 'will"continue to grow*^Ixr &&"
addition, the number of sites undergoing potentially responsible
party (PRP) led remedial investigation/feasibility studies --
(RI/FS) and remedial design/remedial actions (RD/RA) will
increase, generating the.need for additional enforcement support
and oversight. ..The number .of.sites awaiting remedial action is^ '
-expected-to increase .alongrwith the number of sites requiring ^
rapid responses.^^;/^;:; >f- ^^^f}^^"^^ '
'~~ >These trends also naturally affect the -shape "and/ integration
of the Superfund contracting program. Although it is expected -
that the US Army Corps of Engineers and the Bureau of Reclamation
will continue in their currently defined roles, other trends such
as those mentioned above may generate changes in the kinds of
contract support the Superfund program will need. Additionallyr
the Comprehensive Environmental Response, Compensation and
Liability Act as amended*in 1986 expires in 1991 and the strategy
must be flexible to accommodate any changes generated during the
reauthorization process. _ . _ - "'-. - -
As these trends shape the future, it is also expected that
the EPA Regions will continue to have a growing role in contract
management and that there will be a continuing need to cultivate
expertise in these offices...
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Strategy Objectives
The analysis of program direction led to the establishment
of certain objectives for; the strategy. The strategy wouldt -
.,_-. o continue to provide capabilities to conduct: rapid response
o be flexible to "respond to changing budgets and priorities
...o emphasize integratioa of program areas (e.g. r enforcement,
'remedial, removal) into "one program" "'"~- -.' ----'-T-_,.
o phase-in implementation to avoid disruption of ongoing
program efforts '.''.."
o continue to decentralize management of contracts to the
Regional offices to the extent practicable
o maintain the role of the US Army Corps of Engineers and
the Bureau of Reclamation.
A separate evaluation of the role of Headquarters support
contractors was conducted in addition to the development of the
long-term strategy. Recommendations were made to bring certain
functions in-house and other functions were identified as
sensitive. These sensitive tasks would require scrutiny and
attention to oversight.
The analysis of contractor support to Headquarters was
expanded by assessing contractor support to all Superfund
contracts (Appendix 3). The analysis ranks Superfund contractor
work in terms of its relationship to the decision-making process
and the perception of overdependence. Data on contractor labor
hours, contractor skills, and contract funding were analyzed to
determine the number of FTEs required to do the same level of
work in-house.
The analysis indicated that the Superfund work being
performed by our contractors is legal, appropriate, and within
the scope of OMB guidance on contracting. If a decision were
made to bring all contractor work in-house, EPA would be required
to recruit and fill approximately 3,000 new positions. Because
of the tremendous resource implications, a recommendation was
made to maintain the same level of Superfund contracting while
strengthening contracts management through increased training,
clear policies and procedures, and increased management
attention.
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Kev Issues
The Agency identified key issues to examine during the
development of the strategy. These issues included the
evaluation of: 1) the contracting approach which would best ~
support: the "one program" goal of the Superfund Management
Review, 2) contracting approaches which would provide flexibility
to respond, to. fluctuating budgets and program, uncertainties, 3)
the optimal numbers of contracts which can be effectively managed.
given current trends and directions, 4) various methods or
efficiencies to reduce duplication of efforts or handoffs-. Si
contract types for effectiveness, 6) the roles of contractors in
the Superfund program and the skills and expertise needed to
serve the program, 7) the most effective means to increase
competition, and 8) the need for coordination with other agencies
and programs contracting efforts.
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XI. DEVELOPMENT OF STRATEGY
In January 1989, the Office Emergency and Remedial Response
(OERR) and the Procurement and Contracts Management Division
(PCMD) began to evaluate the need for a long-term contracting
strategy for Super fund. Subsequent to this meeting and the
issuance of the Superfund Management Review, a task force was .""
formed with representation across the ten Regional offices, the
enforcement, remedial and removal programs, the Environmental
Services Divisions and Headquarters and Regional contracting
offices. The task force was chaired by the Contract Operations,
Review and Assessment Staff (CORAS) of OERR. Multiple task force
meetings were held which evolved into the following approach.
Process/Approach
The initial evaluation performed by the task force included
the development of a summary of the evolution of the Superfund
contracting program to date (see Appendix 2) and the expectations
for future program direction as discussed earlier in this
document. With the summary of the program's evolution and its
expected direction, the task force began to focus on the key
issues to be evaluated in the strategy (see Section I).
The task force then developed options which would be
evaluated in light of the key issues identified. (The process
evolved as detailed in the attached flowchart). Five subgroups of
the task force were formed. These groups were to evaluate the
optional contracting approaches comparatively within their areas
of concentration. The five key subgroups were: structure,
competition, roles and responsibilities, organizational barriers
and legislative impacts. In conducting the comparative analyses
of Options A-E, the subgroups found fifteen evaluation criteria
which shaped the recommendations of the groups. Section III of
this document will more fully summarize the findings of these
subgroups.
As the final steps, the task force then took a fresh look at
the options by program area (e.g., removal, remedial,
enforcement) and recommended the advantageous components of each
individual option to be assembled into a final alternative. This
alternative balanced the needs of the program areas and the
evaluation criteria (see additional discussion in Section IV).
The next steps for the task force will involve development
of a plan for implementation. This plan will phase-in
procurement of new contracting structures as the existing ones
expire to avoid.disruption of any activities.
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Strategy Planning Approach
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III. ANALYSIS OF OPTIONS - * -^ - -.ii:ซ '-; ^ ;_:_ .i...-.....:, :cr
The task force developed four optional contracting
approaches in addition to the status quo (see attached charts of
Options A-E' and Appendix 4). - The options were1 compared across ~:
program .areas* ta determine commonalities and differences within..--;
those areas (see chart" on pages 16-18) v-: On the issue: of X-iif5cl?r
decentralization of the Contract Laboratory Program. (CLP) ^ it yas
determined that a separate: workgroup would fully analyze this --. '
issue and that only one option, E, would illustrate this as. a ,'-,-
possibility. Any final-determinations on the1 CLP will be married
to the long-term strategy during implementation.
The fifteen evaluation criteria evolved from the analyses
conducted by the five subgroups: structure, competition,, roles .
.and responsibilities, organizational barriers and legislative ..-
impacts. The attached matrix'illustrates'the relative ranking-.of
the options within each criterion as decided by the subgroups and
the full task force (page 15).:The criteria are arrayed in order
of relative importance the highest priority criteria are the
first five; the second group of five are medium priority; and the
last five were considered by the task force to be of lowest ~_-
priority. Values were assigned to the three categories: highest
priority items receiving a value of three per weighted point,
medium priority items receiving a value of two, and low priority
criteria receiving a value of one. Option D received the highest
total in ranking the proposed options. ~ -.
, " * * "" f
The findings of the individual subgroups are summarized in
the following sections. _- .;.--..-
gtructure '.'''
The first subgroup, structure, analyzed the types, EPA ,..
resources, program management costs, sizes and numbers of : ~-
contracts associated.with the individual options. Several key
assumptions affected these analyses. The baseline size and
numbers of contracts associated with each option were generated
on the basis of current budget assumptions for funding and
numbers of activities (e.g., removal starts, RI/FS starts).
Flexibility for changing priorities and funding would be provided
via the exercise of options to increase these baseline amounts.
Program management costs were estimated based upon historical
data (negotiated or actual amounts) for the activity types as
contracts are structured currently. The workload node! used to
generate the necessary estimates of EPA resources was based on
current budget assumptions for numbers of activities and
estimates associated with contract workload (e.g.r- numbers, of
work assignments, technical direction documents, etc.). The full
supporting documentation for these analyses are available by
requesting Appendices 5-8. It was determined that a full
analysis of decentralization of the Contract Laboratory Program
-------
would be conducted by a separate workgroup. Only Option E
presented data for illustration purposes on this issue. -
c ซ- ซ- ---... _...,.ป ^rvrl>ซ. ..;,.ซ. J
The primary conclusions of the structure subgroup were that
the fewest contracts* were- required to support. Option E because it
included: the: decentralization; of. .the Contract Laboratory Program..
Many of-' the- functions^ of .the? Sample Management Offic^ and,tbซ;.^ I
actual 'laboratory:.analyses*.(both, special analytical, services and; :
regular analytical- services).;.were integrated into., the response ;~;
action contracts structure-/ The independent.laboratory contracts-
no longerr.would be: used. % The second, lowest,number of, contracts"-
were/needed: ta support Option: D (see Appendix:5);.^*TV]^lMir%rฃ^T
Program management costs would remain relatively stable "'
across all the options because,..in the analysis, the workload
(numbers of activities, undertaken) did not change by option. This
was done only to compare scenarios across options.-.Workload may
actually, fluctuate across the years The task., force expected .that
certain-combinations;of activities (e.g., FIT "and TAT), would""!;:'I
yield program management .efficiencies. Additionally,,, flexibility
would be provided by .combining certain key.functions~and~ ~~~^J~
therefore,- responsiveness to fluctuating budgets'and program ^
uncertainties would be increased.. -
.The types of contracts .would remain, in the 'majority,. 'cost .
reimbursed with additional opportunities for fixed price.: ^~,l. .""!
contracts where specifics within the statement of work- were '. well*
defined. In the main, however, the uncertainties associated with
site work dictate that most activities must be performed on a
cost. -reimbursed. basis. Regarding EPA resources the status quo -
and Option E generated the need for the highest number of EPA .,
resources (207 FTE and 205 FTE respectively). Options C and D *
required the fewest (189 FTE and 176 FTE). However, these .
numbers vary depending upon the range in the numbers of contracts
and do not reveal _ wide .differences in the needs for resources
regardless of the option. selected. _,-.. _ : - - --- -.._'....... ..c_.
Competition . -J.--*'.^A^_- .. -^\~ -::-..--..".. -.c - ... .:.. ,r." *r*~ --*.
^ --..:;.-_,;;/.:.-- i?1->Vป .CปXJ7 >~l~ '.'i- 9^- ;i~rW "*'-:?? ''": '--?'. ' J ". ">'" -* ---- v~r- T -.'- ----- >-
The competition subgroup- analyzed the marketplace and, the. "r
effects of options on increasing competition, decentralization,'
the number of handof fs generated by the options and the effects
of the options oh the competitive environment for small
businesses and small and disadvantaged businesses (see Appendices
9-11) . The -analyses illustrated that Option B, very closely
followed by Option D was the best for the competition subgroup.
Option B presented the highest number of contracts and thus
created the most opportunities for competition and small business
participation. Option E created the fewest handof fs. .
8
-------
Organizational Barriers
The organizational barriers subgroup examined the effects
prฉgrammatically, as well as organizationally of the options. In
addition, they examined the duplication of effort between
Headquarters and the Regions presented by the options and the
policy and procedural effects of the options. With regard to *
organizational impacts, Option B presented the fewest effects by
crossing fewer organizational lines within contracting \
structures. Option E was determined to be the best with regard.
to programmatic effects (see Appendix 12). In analyzing the
effects on policies and procedures, it was determined that all
options including the status quo will require major revisions and
changes over time. Option B closely followed by Option D
presented the least duplication of effort and also was found to
effectively reduce opportunities for conflict of interest (see
Appendices 13-15).
Roles and Responsibilities. Legislative Impacts
The final two groups, roles and responsibilities and
legislative impacts also analyzed the effects of the options. As
a result, it was determined that the significant programs under
development by the Department of Energy and the Department of
Defense might affect the competitive environment for EPA
contracts. As a consequence, an interagency committee was
established to share information on contract strategies. The
legislative subgroup examined three key issues: the effects on
the options of Brooks Bill, the effects on the options of the
Davis-Bacon Act and the effects of the definitions of OMB
Circular A-120 on the options. Three of the options, E followed
closely by B and C were the least affected by these issues
(detailed analysis may be found in Appendix 16).
-------
Headquarters
National
Contracts
1
Emergency Response
Cleanup Services
Zones I & IV
1
Technical
Assistance
Teams
OPTION A
STATUS QUO
Environmental
Services Assistance
Teams
(ESAT)
1
Field
Investigation
Teams
JL
Contract Laboratory
Program
(CLP)
EPA
Regions
Alternative Remedial
Contracting Strategy
(ARCS)
Regions 1 -10
Regional
Emergency Response
Cleanup Services
Regions 2,3,4.5
Zone
Emergency Response
Cleanup Services
Regions 4 & 5
SHe-Spedflc
Regions 2,4,5,7
TES
Regions 1-10
-------
Headquarters
National
Contracts
OPTION B
CLP
Each
EPA
REGION
Regional
Management
Support
Contracts
Time-Critical
Response
Activities
Small
Respons*
Activities
Pre-Remedlal,
Analytical and
Technical
Assistance
Support
Enforcement
Support
Activities
Remedial
Investigations,
Feasibility Studies
and
RI/FS Oversight
Design,
Construction
and
RD/RA Oversight
Activities
Sltft-Speclflc
Contracts
Separates removal support Into two contracting structures (Time-Critical Response Activities and Small Response Activities).
Provides rapid response capability for remedial program (Small Response Activities).
Combines dedicated team programs (TAT, FTT.ES AT) Into one program.
Creates separate contraci(s) for litigation support, responsible party searches, and administrative record support.
Separates Rl/FS and RD/RA activities while integrating enforcement oversight into each area.
-------
.'
1
SJฃfgA^k fla^B^iMHK ^MtJr
emergency
Response
Contracts ,
1
ESAT
. I
Small/Rapid
Response
Activities
Headquarters
National
Contracts
Transportation
and
Disposal
Broker
Each
EPA
REGION
Pre-Remedlal,
Technical
Assistance
and Enforcement
Oversight Activities
OPTION C
1
CLP
Regional Management
Enforcement ft Support
Contracts
i I l
Response Action
Contracts Site-Specific
(Remedial) and Contracts
Enforcement
Oversight
Citato national broker for Transportation and Disposal Services.
Separates classic emergencies from other removal actions.
Combines removal time-critical and rapid remedial response activities.
Combines two dedicated team programs (TAT, FIT) and enforcement oversight
activities into one program for removal and pre-remedial activities.
Maintains remedial approach (ARCS) for RI/FS, RD/R A including enforcement oversight.
-------
Headquarters
National
Contracts
1
OPTION D
CLP
1
Transportation and
Disposal Broker
Each
EPA
REGION
Tlnw Critical/Rapid
Response
Activities
Pre-Remedlal,
Analytical and
Technical Assistance
Support
Regional Management
Support
Contract(s)
Enforcement
Support
Activities
Non-Time Critical
Response
Activities
Site-Specific
Contracts
Creates national broker for Transportation and Disposal services.
Combines all removal and remedial rapid response functions.
Combines dedicated learn programs (TAT, FIT, ES AT) into one program.
Creates separate contraci(s) for litigation support, responsible party searches, and administrative record support.
Non-time critical removals, remedial and enforcement oversight activities combined into one contracting program.
A variant of this option would be to keep classic emergencies as a separate contract program or to place pre-remedial
activities into non-lime critical responses.
-------
I
Headquarters
National
Contracts
I
Transportation/
Disposal Broker
OPTION E
Technical
Assistance
Each
EPA
REGION
Critical/Rapid
Response
Activities
Analytical
Support
Contracts
Response
Action
Contracts
Enforcement
Support
Contracts
Site-Specific
Contracts
Combines SMO and ES AT function* for each region.
Rapid Response Is classic emergencies, lime-critical removals and rapid remedial response.
TAT is unchanged including removal laboratories.
Response Aclkm contractors provide preremedial, RI/FS, RD/RA. enforcement oversight,
laboratories for preremedial and remedial and noniime-criiical removals.
-------
Analysis of Options by Evaluation Criteria
OPTION OPTION OPTION OPTION
Evaluation Criteria
Multiply by u factor of 3
31J 825 I 52J ซ7J
6. Contract Program Management Costs 5
7. Reduces Duplication Between
HQ & Regions
8. Reduces Handoffs
5 9. Minimizes Organizational Impact
10. Minimizes Programmatic Impact
Multiply by* factor of 2
Reduces Numbers of Contracts
ฃ412. Minimizes Conflict of Interest
13. Minimizes Implementation Efforts
14. Increases Small Business
Participation
15. Minimizes Legislative Impact
Multiply by a factor of 1
82.0 102ฃ 102 119 108.5 121.5
Ranking Totals
LMSt AdMuataly MMto Critsrien
-------
Long-Term Contracting Strategy Options
RG Managed
[~~l HQ Managed
Option A Option B Option C Option D Option E
Remedial
ARCS
JRI/F8T and
Enforcement
Oversight ;
Enforcement
v Oversight -;
RI/FS,
RD,;
^Oversight,
^.MTC
; Removals \
1&?kV HD
-------
Long-Term Contracting Strategy Options
RG Managed
I IHQ Managed
Option A OptionB Option C Option D Option E
Preremedial
FTT
Combined with
f AT and ESAT
Combined with .
TAT
Same as B
.V
Combined with
! Remedial
Removal
Technical Assistance
TAT
Combined with
FIT and ESAT
Combined with
-.:..' Fir7 : /
B
.< f",
Same us A
Classic Emergencies
(CE)
Time-Critical
Response
(TCR)
Non-Time Critical
(NTC)
,
bldfleinedlal
Resjonse
CE
Rapid Remedial
tV'> Response :
Remedial
Response }
Note: NTC combined with Remedial Response
-------
Long-Term Contracting Strategy Options
E3RGM.n.<>.d Opt|on A option B
| | HQ Managed r r
ESAT
Analytical
Support
SMO/CLI
*
Regional
Management
Support
';>. ;'
Combined with
;;TATandlFrr
>
Option C Option D Option E
' "?'-$ฃ , *>**""
_ . i " * $& - V t\ <
Same as A Same as E
">*< i'$ - <, '!-'-
Same as A
Management
t/ฃ Support.,
T & D Broker
CReglonalMgrnVl
)* Supportw/ f
'"-: Enforcement , ' ^ , ??-SfJ
Support , ;v%v"';f<-s "-^^>
Transportation
and Disposal Sa
Broker
\
. *S "%* ' " s
^- *^^halyt)eal^
f>{ |^x Support
/ .. * Xs %
Note: Sampling
Analysis done by
RAC Contractor
1 '
*
. ;.' ป
me asC
' , - y\ ' ' '. ' ' (
-------
.-
IV. PROGRAMMATIC ANALYSIS OF TEE LONG-TERM STRATEGY (LTC8) TASK
. .FORCE1 8 RECOMMENDED ALTERNATIVE . -"- r- Y ">-"--
'' ''- ' -'^ * J i5 " --
,. -, .. , . -.
* .".. The task, t force considered the findings of 'each subgroup 'ffr.
analysis ancL determined that each option should be^ evaluated-
program, area (see chart pages 16-18). The benefits -of each:^?
change were .weighed against: the status quo using the^evaluat
criteria developed for the options. Components were^chosenrby^t ;"
program 'area, and were ^selected as the balanced approach- to best i
serve that program area without creating negative effects on the
other .program areas. .These components were selected to * ' - -^
adequately meet the evaluation criteria and to effectively -:"-'
integrate responses to meet the "one program objective" as well
as to provide flexibility for- changing priorities and budgets. -
Many of the components of the highest rated options, -<-:
particularly D, have been adopted into the : recommended -~~~ I;:-~
alternative. . .The following sections explain the analysis that
was performed. by program area and the selection of the components
which compile the recommended strategy (see chart pages 24-28).
The comparative matrix on page 15 illustrates that the ^r:^
recommended strategy achieves a balance of all of the criteria.
While it does not achieve the highest ranking in each of the ^
criteria, overall it does rank highest amongst all proposed ~
options. The chart on the last page, of this document (29) ir"~1'
illustrates the final components which make up the task force's
recommended strategy.
19
-------
Preremedial
^5.': / :-"r;.?.r* , ., - ซ _
Strong support was voiced by the task, force to combine _the -
Technical Assistance Team. (TAT) functions of the removal program
with. the. preremedial. and to. decentralize this comb ination.-_tO:. the .
Regions.. -j. This recommendation,. would 'reduce the. handof f s between,
the removal, and preremedial programs-. and would promot^^^^^^
decentralization .,.-. In. addition ^these^combinations also^seryerto "
integrate the functions into a- single ^vehicle serving the "one >?rv
program^ obiectiveป^-The site-discovery ^'inspection and removal^-
assessment activities could be integrated and lead to3 &$&&&&*?''
recommendations for early actions at Super fund sites to ^mitigate
Immediate r isles. : This nay also lead to sites being fully cleaned
up before they need to be ranked for the National Priorities * j-
List. The final combination with TAT would enhance competition J-
and opportunities for! .small businesses by creating smaller "'" 2^ *
regionally-based contracts J,~ "*'- -"" v -*-:-:--:' .--.:-..- :-.-Xr*~i'*
-3 j - . ,^ .. ..... jjtii vw-".V4.'
. .,.-.^ - -o- N.-X.-, cr-...-: - . ^x ,,_,- .. . -. r ^_ .
.. r ::2>r .The . pending issue ,of _the. recbmpetition "of the Field Z^ '. * "'
Investigation ..Team (FIT) contracts led the task^ force to evaluate
interim approaches , as .well as' the , final 'structure of* the " . "*"* A "*
preremedial component . ." Several! representatives advocated merging
preremedial functions with the remedial as an interim . approach to
avoid the necessity for recompeting. the 'current FIT contracts;'*
Some Regions strongly preferred a continuation of the current FIT
approach until implementation of the long-term strategy. Because
of the desire to use existing capi'-ity of the remedial contracts
(Alternative Remedial Contracting Strategy (ARCS) contracts); a
desire to avoid duplicate payments of program management costs,
the need to save resources rather than hold a competition for a
short-term preremedial contract and the continued desire for
decentralization, the task force agreed that use of the ARCS
contracts for preremedial functions would be appropriate until an
orderly transition to the merger with the TAT could occur.
Procedures will be developed to ensure that the ARCS provide the
same capabilities as the current FIT (e.g., rapid response).
Removal . -
The TAT component determined to be the most balanced was a
structure which would create regional" contracts. The Regional
TAT contracts will be phased-in and merged with the preremedial
contract function. This component enhanced opportunities for
competition . and small business participation by creating smaller
regionally-based contracts. Zt continued to support the
Superfund Management Review initiative of mitigation of immediate
risk and rapid response at Superfund sites by the continuation of
2 4 -hour per day dedicated support for emergencies. Few
organizational effects will result and those that do will affect
less than half of the existing entities. The current contract
management infrastructure in the Regions will be easily adaptable
to managing regionally-based contracts. The primary negative
effect of this component was the increase in the number of
20
-------
contracts to be managedI ..' However, the assets such, as-enhanced
competition and decentralization were ^determined to far outweigh
the one drawbackป-. ],-, .">. :- -,--_ ~ ~ r^ ..'.". 7~ ". '*, ''2. ".l~r~~'~ . '.. 1 . ':""i--:";-
- The component-serving removal cleanup "work is ''a. continuation
of the current strategy to decentralize the Emergency Response '
Cleanup Services (ERGS) contracts* It integrates rapid remedial
response capabilities into the "contract structure promoting an'rr
integrated "one program approach" for all types of time critical. :.
activities and reduces handoffs between removal and remedial ^^'
activities., -Competition,is enhanced by. creating;.more smaller,.
regionally-based contracts and this also provides more '''--*
opportunities for small, business participation.*;; In addition";'-""=
post-award competition., is enhanced by creating multiple contracts
within the regions. This component also reduces the double layer
of management in the "current .status quo contracts; both - ^-'-
Headquarters^and Regions,'~to a.single layer of Regional "_' ~"' """'
management. --The baseline size of these contracts will be"7"-^"
structured'around the current funding levels; however, ':--.'-
flexibility will he enhanced by creating multiple options to " .
anticipate any increases in program growth. In additions, a
common component across Options A-E was site-specific
contracting. This component will meet many of the evaluation
criteria such as enhanced, competition and continued
decentralization while presenting a cost-effective means to
provide specialized services to support primarily the removal
program, with some support.to the remedial and enforcement
programs. . V ..-.- ... - . '",-.. -..",. . ' '.; ; . . . : '
Remedial .. \..".". '
The component recommended by the task force integrated
remedial, enforcement oversight and nontime-critical removal
activities into an integrated and flexible single contracting
structure. This component was common to several options and was
considered, to be highly desirable because of the flexibility,
enhanced post-award Competition and the simplification to a -
single layer of regional management.. In addition, preremedial
activities are being added to this component as a pilot effort.
The potential complex, teaming arrangements due to the very broad
scope of the contract and disincentives to small business
participation because of the large size and management
requirements were considered to be more than offset by the
advantages. The task force also determined that this component
might reduce handoffs by allowing a broader range of activities
by a single component and it would also provide incentives for
improved performance incentives through the process of post-award
competition.
Enforcement Support
The uniform consensus of the .task force across all options
was that specialized contracting support would be most effective
for certain specific enforcement support functions such as -^ ;:-
21
-------
potentially responsible party (PRP) searches and litigation
support.- More specialized, firms could be procured thereby ^ '.ex
minimizing opportunities for conflict of interest. This would"
also create opportunities for small business and 8(A) firms to^
compete for these contractsป A recommendation was made to.
separate the current. RCRA support?ofl the Technical Enforcement
Support contracts into a. new procurement at the time "of J the
Many 'taskTf or ce~ members "stated* that administrative-
support was uniformly needed across the programs. These
contracts would not be response action-type contracts but would
be more. limited in the scope of their functions. -They would -
further decentralization /.competition and small business
opportunities by their small size and regional base. -Conflict of
interest considerations "would also be minimized by the fact that
smaller, more specialized firms would be" more likely ta compete'
to perform these functions. 'i'~^T'- *"*T'~''D ~ *"" "":"':' ------
* - - -;- - --"* - ..... ป_ *. ฃ.'.-3. _. SCT;."! Sii~ :.* "' ' ' ''- -._- " '
Analytical ' Subobrt" ' ~ r'/XI2^^"--""-^ ;:-^-;- -
The task force evaluated multiple options 'to combine' the
current Environmental Assistance Team (ESAT) contracts with TAT
or TAT/FIT or with certain Sample Management Of f ice functions. '
However, the advantages presented by these approaches appeared to
be outweighed by the unique functions supplied by the ESAT --" -~
contractor. The actual work performed by the contractors did not
duplicate or overlap with functions currently being performed .by
other contract entities. However, the task force recommended tr
that there was no obstacle to continue further decentralization
of the ESAT functions. Therefore, the recommended component for
analytical support would be regionally-based. The smaller "'- '
entities would enhance competition and opportunities for small
business participation and also would be flexible to provide - -
response to specific regional needs.* Opportunities for conflict
of interest would be diminished* by maintaining a third party :ฎ
entity to provide independent data review. Despite the increase
in actual numbers of . contracts jto manage, it appeared that
regional analytical support contracts would be the most effective
components ป The considerations for combining Sample Management
Office functions will be evaluated in the independent review *
being conducted of the Contract Laboratory Program.
Transportation and Disposal Broker - . ~
This component grew out of the dissatisfaction of regional
personnel with the current prime contractors in making - - -
arrangements for transportation and disposal of hazardous .--._ --
materials and the difficulties encountered in assuring regulatory
requirements are being met. . The separation of this function from
the major prime .contractors was seen as a way to minimize delays
in making disposal arrangements. One of .the primary concerns,
' ' '
22
-------
cost of such functions, may be minimized under this component by
obtaining specialized services, making the process consistent
across the Regions and the potential for economies of scale. One
issue associated with this component is that the number of
disposal facilities is currently quite limited and they exercise ';:
a large degree of control over the market for disposal. The ;;- ^r
economic benefits and viability of this component remain less J:
well defined than in the other components of the recommended ~ -;""-;fV
alternative. Additional study and definition is required in order -:
to determine the structure and cost-effectiveness of the broker
concept. However, given the dissatisfaction with, the current- ;- ^;
system, the task force wanted continued exploration of this
structure.
Community Relations
Although the task force gave serious consideration to the
development of a separate component for supplying of community
relations support, the final recommendation remains that an
evaluation of the new contracts be conducted. Because the new
response action contract function will provide continuity of
prime contractor control, the previous problems due to handoffs
to multiple community relations subcontractors at different
phases of work may be diminished. This evaluation will determine
whether the handoff problem experienced with multiple contractors
performing site work and PRP oversight will be diminished by the
use of the response action contract concept for all remedial
activities.
Final Recommendation
The compilation of the components of the final
recommendation are contained in the attached chart. The
alternative balances the needs of the programs and the objectives
of the strategy. The CORAS staff and the task force will
develop a plan within the next few months to phase-in
implementation without serious program disruption.
23
-------
Recommended Long-Term Contracting Strategy
RG Managed
HQ Managed
Status Quo
Task Force
Recommendation
Preremedial
FIT
Recommends that the existing FIT contracts be combined with the TAT contracts as a long-term option.
These contracts would be decentralized to the Regions. In most cases, the recommended structure
would be two separate teams under each contract to ensure that priorities of each program element
(preremedial and. removal ) would be met. Zone structures would be considered depending upon
individual Regional workloads. ARCS will support FIT work in the interim.
Removal
Technical Assistance
TAT
As stated above, recommends decentralized Regional contracts combined with the FIT,
*ปป
-------
Recommended Long-Term Contracting Strategy
RG Managed
I I HQ Managed
Removal
(continued)
Status Quo
Task Force
Recommendation
Classic Emergencies
(CE)
Time-Critical Response
(TOO
NonTime-Critical
(NTC)
Zone ERCS
and
Note: NTC combined with Remedial Response
Recommends decentralized removal contracts to cover classic emergencies, time-critical response and
rapid remedial response. Nonn'me-critical response moved to the remedial contracts. Recommendation includes,
where workload permits, more than one contract per Region to promote competition and to address conflict of
interest concerns. . '
-------
Recommended Long-Term Contracting Strategy
RG Managed
Status Quo
Task Force
Recommendation
Remedial
o
1\
!&& ^?IKtill
(PRP Oversight)
ERGS
(Nontlnw-crltlcal
removals)
Note: Rapid Remedial Response
under Removal Program
Recommends continuation of the current ARCS strategy (RI/FS, RD and RA), adding all PRP oversight
and nontime-oitical removal actions. Rapid response capability for the remedial program would be
handled by the removal contracts. The recommendation continues the theory of more than one contract
per region to support competition and conflict of interest concerns. :,
-------
Recommended Long-Term Contracting Strategy
RQ Managed
HO Managed
Status Quo
Task Force
Recommendation
Enforcement
Support
PRP Oversight
TES
Note: PRP Oversight moved
to Remedial Program
Recommends smaller, decentralized enforcement contracts to support PRP searches and litigation support.
PRP oversight would be moved to the Remedial contracts. OWPE and the Task Force voiced concerns about
combining enforcement support with Regional Management Support (e.g., maintaining enforcement focus.)
Recommends separate contracts for RCRA enforcement support.
Regional
Management
Support
N/A
Recommends that separate Regional management support contracts be provided. Activities would include
items such as data entry support, systems management, data tracking, and contract management assistance.
Exact scopes of work will need to be determined by individual Regional requirements.
-------
Recommended Long-Term Contracting Strategy
K>
CO
Analytical
Support
Status Quo
Task Force
Recommendation
ESAT
SMO/CLP
Reconunendction deferred
pending further study by HSGD
Recommends continuation of the ESAT contracts, decentralized to the regions. Zone structures
will be considered in accordance with regional workloads. A recommendation on decentralizing
the CLP is deferred pending further analysis of pilot efforts currently underway.
T&D
Broker
N/A
T&D
Broker
Recommends that a Transportation and Disposal Broker be established. Further study is
required to determine the exact requirements and how such a contract might be structured.
Community
Relations
N/A
Recommends that separate community relations contracts not be created. Community
relations support would continue to be handled by the removal and remedial contracts.
-------
Recommended Long-Term Contracting Strategy for Superfund
Headquarters
National
Contracts
Certred Laboratory
1
Transportation
ปnd Disposal
'
Each EPA
Region
Enforcement
Support Contracts
I
Time Critical/
Rapid Response
Activities
Efivlrofwntrftsjl
TMm
(ESAT)
Regional Management!
Support Contracts
FtoM (nvMtlgatlon Team /
Technical Assistance
Team
(FIT/TAT)
Response
Action
Contracts
1
Site Specific
Contracts
1. *Defeซo>dskjn on decentralizing CLP pending further Mudy. .
2. 'Creates concept of nations! broker for transpoitation and disposal services. Further evaluation to be conducted.
3. Creates regional contract! for PHP Marches and litigation support, and separate regional contracts to provide data entry, management, and administrative support.
4. Combines rctnoval Ume-oftical ami rapid remedial response activity.
5. Decentralizes ES AT to Regions.
6. Combines two dedicated team programs (TAT, FIT) into one program for reinoval and preremedial activities.
7. Integrates enforcement oversight of PRP lead remedial activities into response action contracts for RI/FS, RD/RA and non-time critkal removals.
------- |