&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9200.5-4011
March 1990
CORAS Bulletin
Office of Emergency and Remedial Response
Office of Program Management OS - 240
USEPA West Building
Headquarters Repository
1301 Constitution Avenue N.W.
Room 3340 - Mailcode 3404T
Washington, DC 20004
Intermittent Bulletin
Volume 1 Number 7
IG Completes Audit Report on Superfund
Cost Plus Award Fee Contracts
The Office of the Inspector General has completed an audit on Superfund's Cost Plus Award Fee contracts and has issued
Audit Report Number E1SFFP-03-0144-0100222 dated March 28, 1990. The draft of this report generated considerable
discussion within PCMD and OSWER. Numerous meetings were held between the offices affected to clarify issues and to
communicate our concerns.
The following article provides a brief summary of 1) major findings, 2) recommendations and 3) OARM and OSWER
responses to the draft report. It should be noted that OARM and OSWER will be providing a formal response within 90 days.
Finding No. 1 -
Award Fees Often Fail to Achieve Excellence.
Based upon review of the TES, ESAT and FIT contractors,
the OIG concluded that award fees were not used to effec-
tively motivate the contractors. A major criticism cited was
the payment of award fees for less than satisfactory perform-
ance and payment of base fees for seriously deficient per-
formance.
Recommendations to OARM:
• Restrict the payment of base fees in accordance with the
FAR if services performed under any Agency contract fail to
conform with contract requirements.
Response:
OARM feels the need to consider such withholdings on
a selective basis after examination of the facts and cir-
cumstances surrounding each instance of poor perform-
ance. Payment would be denied in situations
where the contractor did not provide diligent efforts.
• Restructure all Agency CPAF contracts to preclude pay-
ment of any award fees for less than satisfactory work, and
allow reduced amounts for work that is considered no higher
than satisfactory.
Response:
OARM does not agree that all CPAF contracts need re-
structuring. They generally agree to preclude payment
of award fees, but only when the overall performance
for an evaluation category is determined to be unsatis-
factory. PCMD will be working to coordinate and im-
plement such a policy.
• Monitor future ESAT Zone I award fee evaluations, and
terminate the contract if future evaluations indicate any
widespread return to the deficient performance situations
that the Agency experienced in the first three performance
periods.
Response:
OARM generally agreed with this recommendation and
pointed out that a proactive position taken in October
1988 has resulted in improved performance.
• Determine and recoup the actual costs and base fees
inappropriately charged against the FTTZone n contract for
- The Management Information System.
- FIT staff excess to authorized Region VI levels.
- E&E corporate staff.
Response:
Although OARM is exploring FIT charges for the MIS,
it appears the costs incurred are legitimate expenses.
With regard to excess FIT staff in RegionVI, OARM
maintains that overstaffing is permissible and within
the zone program management office purview when a
short-fall in level of effort hours has occurred. OARM
believes the recommendation on FIT corporate staff
charges may have merit and is reviewing these costs.
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• Determine and recoup any costs and base fees charged
against the TAT contract for Weston corporate staff in Re-
gion vn.
Response:
OARM maintains that charges for TAT corporate staff
were appropriate, necessary and reasonable.
Finding No. 2 -
EPA Performance Evaluation Procedures Varied
by Contract
The OIG found that because evaluation procedures for
various contracts differed, the Agency does not provide
award fees in a uniform manner. Moreover, the administra-
tive effort used for evaluations was not always justified and
consistent with the amount of award fees provided.
Recommendations to OARM:
• Require PCMD to establish consistent procedures for cost-
plus-award-fee contracts to provide award fees in a uniform
manner. To accomplish this, each contract should have the
same number of rating categories and the percentage of the
award fees available for each category should be consistent.
Response:
OARM pointed out that each class of contracts (i.e.,
ARCS) has virtually identical award fee plans. They do
not agree that all Superfund award fee contracts should
contain identical award fee plans. Each class of con-
tracts supports a different program and needs an award
fee plan independentally tailored to the evluation
of that program.
• Modify future contracts to eliminate the award fee aspect
when the contract value is small or when expenditures do
not materialize.
Response:
OARM indicated that award fee amounts are proposed
by successful contractors, and that, clearly, no firm
would voluntarily propose or negotiate a fee structure
which they find unacceptable. Accordingly, OARM
concluded that these contracts do motivate contractor
performance. In addition, OARM has found that the
award fee process mandates an ever vigilant contract
management initiative that would be continued in the
Superfund program.
Finding No. 3-
Late Appraisals Hinder the Award Fee Process
The OIG found that the Agency did not effectively use
award fee performance evaluations to provide the contrac-
tors timely feedback on their performance. In some cases,
the contractor did not receive feedback concerning their
performance for more than a year.
Recommendations to OSWER:
• Emphasize to all personnel involved with the award fee
evaluation process that completing evaluations in a timely
manner is essential.
Response:
OSWER agrees that timely completion of award fee
evaluations is important. However, they did note that
the OlG's statement that delays nullify the purpose of
the award fee process may be based on incorrect infor-
mation. It was also pointed out that regular feedback is
provided in routine meetings, and copies of award fee
evaluations are provided immediately or even before
the Performance Evaluation Board convenes.
• Require that performance agreements, for all EPA em-
ployees participating in the award fee evaluation process,
include the requirement to complete award fee evaluations
in a timely manner.
Response:
OSWER agrees with this recommendation and will
develop a work plan to ensure implementation of
OSWER Directives to that effect.
• Require that appropriate personnel not process any work
assignments for managers who are late in completing their
award fee evaluations.
Response:
OSWER agreed with the objective of improving time-
liness but did not agree with the specific recommenda-
tion. Instead, they proposed the establishment of an
OSWER/OARM workgroup to study contracting
issues including evaluation timeliness.
We would like to emphasize that OARM and OSWER
will be preparing formal responses within 90 days. The re-
sponses provided in this article reflect comments on the
draft report Complete copies of the audit report can be ob-
tained by contacting the OIG at 382-4175.
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CONTRACT RELATED MEETINGS, CONFERENCES AND TRAINING
Title
Date
Location
Contact
Removal Managers
OSC Meeting
ARCs/ERCS Project
Officer/ Contract Officer
Meeting
May 22-25,1990
June 11-14,1990
Avalon, NJ
Washington, DC
Bruce Engelbert, FTS 382-2188
Lisa Guarneiri, FTS 475-8110
Sue Anderson, FTS 475-8243
Scott Fredericks, FTS 382-2348
Dca Joiner, FTS 382-7966
Doretha Vaughn, FTS 475-8233
CORAS BULLETIN BOARD
Procurement and Contracts Management Division
ARCS CONTRACT TRACKING SYSTEM
Pre-implementation of the ARCS Contract Tracking
(ACT) System has begun in Regions I, II, and in. Dennis
Cunningham (PCMD) and Glenda Cherry (Network Man-
agement, Inc.) met with personnel in each of these regions to
discuss system requirements and to review the data gather-
ing process which must occur prior to implementation. The
regions also received a demonstration of the system. Pre-
implementation visits to Regions VII and X took place in
April.
Though the schedule for system installation in each
region remains flexible, ACT will be running in each of the
regions prior to the end of FY 1990. Concurrent with re-
gional implementation, PCMD will also run a requirements
analysis for installing ACT at Headquarters.
Any questions concerning the system's capabilities
or the implementation process should be directed to Dennis
Cunningham at FTS 475-9479.
JOINT SUPERFUND CONTRACT / PROGRAM
MEETING
The next trimester meeting of Alternative Remedial Con-
tracting Strategy (ARCS) and Emergency Response
Cleanup Services (ERCS) is planned for the week of June
11, at the Crowne Holiday Inn at Crystal City, VA (300
Army-Navy Drive). Attendees will include Project Offi-
cers, Contracting Officers and HQ personnel for both pro-
grams. On June 12 and 13, separate ARCS and ERCS ses-
sions will be held specific to the two contracting programs.
|>n June 14, a joint ARCS/ERCS discussion will be held to
exchange information on common issues.
Hazardous Site Control Division
INTEGRATION OF ACTs SYSTEM WITH ARCS RPOs
Members of the Design and Construction Manage-
ment Branch (DCMB), HSCD, met with Dennis Cunning-
ham of PCMD in early April to discuss the use of PCMD's
ARCS Cost Tracking System (ACT) by Regional Project
Officers (POs) as well as the Contracting Officers (COs).
Although the system is set up in such a manner that the COs
are responsible for the data input. This system was intended
to fulfill the PO needs for tracking program management
and remedial costs. We are recommending that the ARCS
POs attend PCMD's ACTs demonstrations. We are inter-
ested in your feedback and opinions of the ACT system (e.g.,
will it gather information pertinent to your needs?, do you
have a similar tracking system and how will the ACT system
affect your tracking efforts?, etc.). Please contact Chris
Watling of DCMB at FTS 382-3901.
BID TAB COMPILATION FOR POST-SARA
RA START SITES
The DCMB is compiling all available bid tabulations
(bid tabs) from post-SARA Remedial Action (RA) fund-lead
sites. The purpose of this compilation is to provide EPA's
Regional and Headquarter's Superfund staffs a tool with
which to determine the validity of future RA bids. We have
compiled about half of the available bid tabs (35 of 70) and
plan to have the project done by May 1990. We would
greatly appreciate your input concerning the final format of
the compilation, any analyses of the data you would find
useful, and any general comments you have about mis
project. Please contact Chris Watling of DCMB at FTS 382-
3901.
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Hazardous Site Evaluation Division
AUDIT SURVEY OF THE ZONE H FIT CONTRACT
During February, following an initial audit survey of
the Zone n FIT contract, it was announced that the Office of
Inspector General (OIG) was indefinitely postponing an
audit of the EPA's utilization of the Zone n FIT. Thisdecision
was reached by the OIG primarily because of the Agency's
follow up actions in Zone n which address the recommen-
dations of the OIG'S audit of the management of the Zone I
FIT contract Since 1988, many new contract management
procedures have been implemented in both Zones which
ensure more closely managed FIT contracts. Actions taken
to enhance FIT contract management include:
• Revising the FIT Zone Contracts Management Guide.
• Headquarters program office biannually conducts
regional FIT contracts management reviews of FIT contract
operations.
• Quarterly Regional Project Officer meetings are held to
discuss relevant issues and to increase nationally consistent
use of the FIT by the regions.
INVESTIGATION DERIVED WASTES
The Site Assessment Branch plans on distributing for
review, a Field Investigation Team (FIT) guidance for IDW
management. Anyone interested in commenting on this
document should contact John Hollister, FTS 475-9748.
PROCUREMENT REQUEST (PR) TRACKING
The Analytical Operations Branch (AOB) has devel-
oped a PR tracking system that helps manage the large
volume of PRs associated with the CLP and ESAT contracts
(over 150 per quarter). A data base that supports the system
requires only a contract number and incremental funding
dollars to generate a PR. The system subsequently updates
the Branch's budget file and tracks the PR through the
approval chain.
tmergency Response Division
ZONE I AND H TECHNICAL ASSISTANCE TEAM
(TAT) CONTRACTS
The Zone I and Zone n TAT Contracts are scheduled
to expire on September 30,1990. The Emergency Response
Division is in the process of recompeting both contracts.
Zone I TAT will be comprised of Regions I though IV. Zone
n TAT will be comprised of Regions V through X. The
Request for Proposals was issued on January 19,1990. The
Zone I and n TAT Technical Evaluation Panels (TEP) con-
vened on March 1, 1990 to evaluate the proposals. The
contracts are scheduled to be awarded in August, 1990.
ZONE I AND H TECHNICAL ASSISTANCE TEAM
(TAT) 8(a) CONTRACTS
As a result of a request from the Office of Small and
Disadvantaged Business Utilization, the Emergency Re-
sponse Division will be procuring the services of 8(a) firms
for technical assistance. The Zone I TAT 8(a) contract will
be comprised of Regions I through IV. The Zone II TAT 8(a)
contract will be comprised of Regions V through X The
scope of work for these contracts will include such tasks as
SPCC inspections, contingency planning, training, and
chemical safety audits. These contracts will supplement the
main TAT contracts. A pre-solicitation conference was held
in Dallas, TX on February 14,1990.
If you have questions on the TAT or TAT 8(a)
contracts, please call Pat Hawkins on FTS 382-2458 or
Susan Janowiak on FTS 382-7732.
Attached to this month's CORAS Bulletin is an article
prepared by the Office of Ha/.ardous Site Control Divi-
sion atHeadquarters. Thearlide isentitled/'Debarment
and Suspension". If you have questions regarding De-
barment and Suspension, please refer to the "Add itional
Information" section of the article for a listing of
contacts.
If you are interested in receiving back issues of the bulletin, please contact Jalania Ellis/
FTS 475-8533, '-
For any changes to the "Key Regional Personnel in Superfund Contract Management**
thart, please notify Jalania Ellis, FTS 475-8533.
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Key Regional Personnel in Superfund Contract Management
Contract
REM
ARCS
ERCS
«*
FIT
••-'•
, - s i I\5'Y-:
Headquarters
(PO. DPO if possible)
REM II - Benjamin Hamm
REM III - Bob Heffeman
REM 1 - Tracy Loy
REM V- Scott Fredericks
REM VI - Scott Fredericks
N/A
Zone 1 - David Lopez
Zone 2 - Reg. 4 is PO
Zone 3 - David Ouderklrk
Zone 4 - Lisa Guarneiri
Zone 1 - Pat Hawkins
Zone 2 - Susan Janowiak
Zone 1 • John Holllster
Zone 2 - Dave Cook
Zone 1 -Jack Jojoklan
Zone 2 -Jean Wright
Zone 3- Billy Perry
Zone 4 - Nancy Deck
Lynn Beastey
Region 1
Nancy Barmakian
U.S. EPA - HCP - CAN7
JFK Federal Building
Boston, MA 02203
8-833-5797
Nancy Barmakian
U.S. EPA - HCP - CAN7
JFK Federal Building
Boston, MA 02203
833-1797
John Carlson
U.S. EPA
60 Westview Street
Lexington, MA 021 73
(617)860-4513
John Carlson
U.S. EPA
60 Westview Street
Lexington, MA 02173
(617)860-4613
Don Smith
U.S. EPA - HSS - CAN7
JFK Federal Bulling
Boston, MA 02203
833-1648
Rick Leighton
U.S. EPA - CAN7
JFK Federal Building
Boston, MA 02203
833-1654
Scott Clifford
U.S. EPA
60 Westview Street
Lexington, Ma 02173
(617)860-4631
Region 2
ShaheerAlvi
U.S. EPA
26 Federal Plaza
New York, NY 10278
8-264-2221
Shaheer Alvi
U.S. EPA
26 Federal Plaza
New York, NY 10278
264-2221
Mike Polito
U.S. EPA
Woodbridge Avenue
Edison, NJ 08837
340-6652
Mike Polito
U.S. EPA
Woodbridge Avenue
Edison, NJ 08837
340-6652
Amy Brochu
U.S. EPA
Woodbridge Avenue
Edison, NJ 08837
340-6802
Cathy Moyik
U.S. EPA
26 Federal Plaza
New York. NY 10278
264-8123
Joseph Hudek
U.S. EPA
Woodbridge Avenue
Edison, NJ 08837
340-6713
Region 3
James McKenzie
U.S. EPA
841 Chestnut Street
Philadelphia, PA 191 07
597-3229
Jerome Curtin
U.S. EPA
841 Chestnut Street
Philadelphia, PA 191 07
597-4779
Rich Fetzer
U.S. EPA
841 Chestnut Street
Philadelphia, PA 191 07
597-
Rfch Fetzer
U.S. EPA
841 Chestnut Street
Philadelphia, PA 19107
597-
Greg Hamm
U.S. EPA
841 Chestnut Street
Philadelphia, PA 191 07
597-8229
Elaine Spiewak /
Nancy Cippola
U.S. EPA
841 Chestnut Street
Philadelphia, PA 19107
597-8183
Terry Simpson
U.S. EPA
839 Bestgate Road
Annapolis, MD 21 401
(301)266-9180
Region 4
Ken Myer
U.S. EPA
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-2930
Doug Thompson
U.S. EPA
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-2930
Fred Stroud
U.S. EPA
345 Courtland Street, NE
Atlanta, GA 30365
257-3931
Carol Monell
U.S. EPA
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-2930
Al Hanke
U.S. EPA
345 Courtland Street, NE
Atlanta, GA 30365
257-5065
Ken Myer
U.S. EPA
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-2930
Bobby Carroll
U.S. EPA, College
Station Road, ASB
Athens. GA 3061 3
250-3309
Region 5
Gail Nabasny
U.S. EPA
230 South Dearborn St.
Chicago, IL 60604
353-1056
Steven Nathan
U.S. EPA
230 South Dearborn St.
Chicago, IL 60604
886-5496
Duane Heaton
U.S. EPA
230 South Dearborn St.
Chicago, IL 60604
353-1788
Duane Heaton
U.S. EPA
230 South Dearborn St.
Chicago, IL 60604
353-1788
Gail Nabasny
U.S. EPA
230 South Dearborn St.
Chicago, IL 60604
353-1056
Lorraine Kosik
U.S. EPA
230 South Dearborn St.
Chicago, IL 60604
353-6431
Jay Thakkar
U.S. EPA
536 S.Clark St.
Chicago, IL 60605
886-1972
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MAR
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Key Regional Personnel in Superfund Conl
Contract
RBI
'«
ARCS
ERCS
TAT
HT
TES
ESAT
Regton 6
Helen Newman
U.S. EPA
1445 ROM Avenue
Dallas, TX 75270
8-255-6720
Cariene Chambers
U.S. EPA
1445 Ross Avenue
Dallas. TX 75270
255-6720
Chris Peterson
U.S. EPA
1445 Ross Avenue
Dallas, TX 75270
255-2270
Chris Peterson
U.S. EPA
1445 Ross Avenue
Dallas. TX 75270
255-6720
Ed Sierra
U.S. EPA
1445 Ross Avenue
Dallas, TX 75270
255-6491
Karen Witten
U.S. EPA
1445 Ross Avenue
Dallas, TX 75270
255-6720
Michael Daggett
U.S. EPA
6608
Houston. TX 77074
526-9430
Region?
Karen Flournoy
U.S. EPA
726 Minnesota Avenue
Kansas City. KS 661 01
(913)551-7782
Rebecca Thomas
U.S. EPA
726 Minnesota Avenue
Kansas City, KS 661 01
(913)551-7593
Ron McCutcheon
U.S. EPA
726 Minnesota Avenue
Kansas City, KS 661 01
(913)551-3881
Paul Doherty
U.S. EPA
726 Minnesota Avenue
Kansas City. KS 661 01
(913)551-3881
Peter Culver
U.S. EPA
726 Minnesota Avenue
Kansas City, KS 661 01
(913)551-7707
Maureen Hunt
U.S. EPA
726 Minnesota Avenue
Kansas City, KS 661 01
(913)551-7722
Harold Brown
U.S. EPA
726 Minnesota Avenue
Kansas City, KS 661 01
(913)551-3881
tract Managem
**
Region 8
Lisa Beasley
U.S. EPA
999 18th Street
Denver, CO 80202
8-330-1282
Lisa Beasley
U.S. EPA
999 18th Street
Denver, CO 80202
330-1282
Mike Zimmerman
U.S. EPA
999 18th Street
Denver. CO 80202
330-7134
Jim Knoy
U.S. EPA
999 18th Street
Denver, CO 80202
330-7162
Gerry Snyder
U.S. EPA
999 18th Street
Denver, CO 80202
330-7505
Sam Marquez
U.S. EPA
999 18th Street
Denver, CO 80202
330-7151
Eva Hoffman
U.S. EPA
999 18th Street
Denver, CO 80202
330-7509
icnt - i^i; *
"" "" *<&K\.. % '
Region 9
Rob Stern . ' >
U.S. EPA ;
21 5 Fremont Street
San Francisco 041 05
454-7408 - ?:, j
Man Mitgaard
U.S. EPA
215 Fremont Street
San Francisco 941 05
454-0307
Chris Weden
U.S. EPA - (T-4-9)
21 5 Fremont Street
San Francisco 94105
454-8132
William Lewis
U.S. EPA - (T-4-8)
21 5 Fremont Street
San Francisco 94105
454-7464
Doug Frazer
U.S. EPA - (T-4-8)
21 5 Fremont Street
San Francisco 941 05
454-7305
Judy Walker
U.S. EPA - (T-4-8)
21 5 Fremont Street
San Francisco 94105
454-8550
Terry Stumph
U.S. EPA - (P-3)
21 5 Fremont Street
San Francisco 941 05
454-7483
Region 10
Joanna LaBaw
U.S.EPA*
1200 6th Street
Seattl0,WA98101
8-399-2594
.!>
Joanne LaBaw
U.S. EPA
1200 6th Street
Seattle, WA 981 01
399-2594
William Longston
U.S. EPA
1200 6th Street
Seattle, WA 981 01
399-1196
CarlKitz
U.S. EPA
1200 6th Street
Seattle, WA 981 01
399-1263
John Osborn
U.S. EPA
1200 6th Street
Seattle, WA 981 01
399-0837
Mike Slater
U.S. EPA
1200 6th Street
Seattle, WA 981 01
399-0455
Gerald Muth
U.S. EPA
P.O. Box 549
Manchester, WA 09353
399-0370
-6-
MAR I990
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