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DIRECTIVE NUMBER:
9242.2-03
             TITLE: Administrative Guidance for the FIT to ARCS
                  (FIT/ARCS) Transition


             APPROVAL DATE:  11/29/91

             EFFECTIVE DATE:  11/29/91

             ORIGINATING OFFICE:OERR

             D FINAL

             D DRAFT
                AC       (  1  A~ Pending OMB approval
              STATUS:      f  j  B- Pending AA-OSWER approval
                           I  1  C- For review &/or comment
                           [  ]  D- In development or circulating

             REFERENCE (other documents):        headquarters
  DIRECTIVE    DIRECTIVE    D

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oEPA OSWER Direcfivelnitlation Request 9242.2-03
2. Orlcjfnator Information
Name of Contact Person .Mail Code Office
SF Document Center Coordinator • OS-245
;Teiepnone Code
OERR 202-260-9760
3'Title Administrative Guidance for the FIT to ARCS (FIT/ARCS) Transistion
4. Summary of Directive 'jr.ciuce bnef statement of purpose)
Describes the final administrative guidance for managing pre-remedial, site
assessment work under the Alternative Remedial Contracting Strategy (ARCS)
contracts.
5. Keywords
Pre-remedial and site assessment
6a. Goes This Directive ouperseoe Previous uirective(S) ? > N
L-'"' No

b. Does It Sucplement Previous Oirectwe(S)' :" "1
; • ' ' ; NO


Yes What directive (number, title)

Yes What directive (number, title)

7 2 ran _evei
j i A - Signed S-/AA.CAA i j 3 •- Signea ;y Office Director

C •- For Review 4 Comment i i 0 - in Development

          8. Document to be distributed to States by Headquarters?
 Yes
        No
     This Bequest Meats OSWEf^QIrectlvea System Format Standards.
     9. Signature of Leaa C.fice p/fectives Coordinator
Date
     10. Name ana Title of Approving Crfjbal/
       Henry L. Longest II,  Director
       Office of Emergency and Remedial Response
Date
     November 29, 1991
    EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
  OSWER          Of'VER             OSWER            O
VE    DIRECTIVE        DIRECTIVE       DIRECTIVE

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             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C. 20460
  MOW 2 9 199!
            	  .._: Building
         Headquarters Repository
       1301 Constitution Avenue N.W.
       Room 3340 - Maifcode 3404J
         Washington, DC 20004  °'
         OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE


 DIRECTIVE #9242.2-03
MEMORANDUM

SUBJECT:  Administrative Guidance  for  the  FIT to ARCS (FIT/ARCS)
          Transition

FROM:     David J. O'Connor, Director
          Procurement and Contracts Management division (PCMD)
TO:
          Henry Longest, Director
          Office of Emergency and Rem<
                                    sponse (OERR)
Waste Management Division Directors
Environmental Services Division Directors
Assistant Regional Administrators
Regions I - X
Purpose;  Attached is the final administrative guidance for
managing pre-remedial, site assessment work  under the Alternative
Remedial Contracting Strategy  (ARCS)  contracts.

Background:  As directed by the Long  Term  Contracting Strategy
(LTCS) for Superfund (OSWER Directive #9242.6-07),  the site
assessment work performed under the Field  Investigation Team
(FIT) contracts is currently being re-assigned to the ARCS
contracts.  Implementation of this transition process began in
1991 under guidelines provided in Interim  Administrative Guidance
for the FIT to ARCS (FIT/ARCS) Transition  (January 29,  1991).
The original document provided administrative guidelines for the
ARCS Contracting Officers (COs), ARCS Project Officers (POs),  FIT
Regional POs (RPOs), and site assessment staff to follow while
implementing the FIT/ARCS transition.  This  final guidance
updates and supersedes the original guidance document.

     Note that the following sections of the attached document
contain significant changes from the  Interim Administrative
Guidance previously issued:

   • Tracking and Reporting (in the standard reporting table)
   • Equipment Management
   •> Invoicing
                                                        Printed o/~ ^eored Paper

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Ob-1 active:  This document provides administrative guidelines for
assigning site assessment work (i.e., work previously done by the
FIT contractors) to the ARCS contractors.  In accordance with
these guidelines, ARCS COs, ARCS POs and site assessment staff
can continue managing FIT/ARCS work assignments in a consistent
manner.

Implementation:  Regional staff should immediately begin to
incorporate this guidance into their ongoing efforts.  The ARCS
POs should issue this guidance to every ARCS contractor receiving
site assessment work.  If you have any questions regarding this
guidance document, contact John Hollister at FTS 260-8106 (HQ -
site assessment program); Barbara McDonough at FTS 308-8347 (HQ -
ARCS program management, phone number will change to 678-8347 on
11/15/91); and Ann Hamann at FTS 260-9252 (HQ - ARCS contracts
management, PCMD).

Attachment

cc:  Superfund Branch Chiefs, Regions I - X
     FIT/ARCS Transition Workgroup,
     LTCS Advisory Committee
     LTCS Regional Liaisons
     LTCS Designated Leads

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     Administrative Guidelines  for Conducting
Site Assessment Work Under the Alternative Remedial
       Contracting Strategy  (ARCS) Contracts

                   November  1991

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                        TABLE OF CONTENTS


INDEX                                                        PAGE


I.    Background  	  1

II.   FIT/ARCS Implementation  	  2

III. Contractor Selection/Work Assignment Negotiation   	•-. 3
     A.  Work Distribution	  3
     B.  WA Negotiations  	  4

IV.   Program Management  	  5

V.    Tracking and Reporting  	  7
     A.  Cost Reporting	  7
     B.  Progress Reporting  	 	  8

VI.   Equipment  	  8
     A.  Non-interference Loan Agreement  	  9
          1.   Purpose  	  9
          2.   Applicability  	  9
          3.   Concerns to be Addressed  	  10
     B.  Equipment Loans and Transfers between Regions   	  12
     C.  Equipment Pools  	  12
     D.  Performance and Cost Information  	  12

VII.  Invoicing  	  13
      A.  Funding,  Task Structure and Cost Reporting  	  13
      B.  Invoice Review Process  	  14
      C.  Initiating Site/Spill Identifiers (S/S IDs)   	  15
      D.  Documentation of Pre S/S ID Costs for Cost Recovery  16

VIII.  Award Fee Plan  	  17
      A.  Background:  ARCS Award Fee  	  17
      B.  Background:  FIT Award Fee  	  18
      C.  Implementation under ARCS  	  18
      D.  Performance Evaluation Board  	  19

 IX.  Miscellaneous Issues  	  19
      A.  Conflict of Interest (COI)  	  19
      B.  LOE Utilization on the ARCS Contracts  	  20
      C.  Training of ARCS Contractors  	  20

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Summary of Attachments!

A.  FIT/ARCS Workgroups
B.  Professional/Technical and Skill Mixes for Site Assessment
    work
C.  Standard Semi-annual Reports for Site Assessment Work
    Assignments
D.  Standard 7-point Justification for Equipment Transfers
E.  A Summary of Regional Approaches for Managing FIT Equipment
F.  Sample Equipment Loan Agreements
G.  Equipment Costing more than $10,000
H.  Financial Management Division - Cost Re-allocation Guidelines
    (September 1991)
I.  Sample Site-Specific Invoice Attachment
J.  Elements of Superfund Account Numbers
K.  Flowchart:  Processing Superfund Invoices
L.  Flowchart:  Process for Assigning S/S ID Numbers
M.  Sample Summary of All Site Specific Costs
N.  Site Assessment Training Program for Fiscal Year 1992

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             Administrative Guidelines for Conducting
       site Assessment Work Under the Alternative Remedial
              contracting Strategy  (ARCS) Contracts


I.  Background

     A transfer of the site assessment contract support to the
ARCS contracts will occur as a part of the overall Superfund Long
Term Contracting Strategy  (OSWER Directive #9242.6-09).  EPA will
implement this transfer at the completion of the current FIT
contract and continue until EPA awards Regional Field
Investigation Team/Technical Assistance Team (FIT/TAT) contracts
as outlined in the Long Term Contracting Strategy.  In
preparation for the FIT/ARCS transition, the Hazardous Site
Evaluation Division (HSED), Hazardous Site Control Division
(HSCD), and Procurement and Contracts Management Division (PCMD)
planned to gradually issue site assessment work to the ARCS
contractors in fiscal year  (FY) 1991.  The final transfer will
occur in FY '92.

     In preparation for this gradual startup, workgroups
consisting of ARCS Contracting Officers (COs); ARCS Project
Officers (POs); FIT Regional POs (RPOs); Contract Operations,
Review and Assessment Staff (CORAS)  personnel; PCMD staff and
Superfund accounting staff produced this guidance (see Attachment
A).   These workgroups evaluated the major areas of concern in the
conversion from FIT to ARCS.  The following sections of this
document present the workgroups' findings on these areas of
concern.  While reading these sections, you should note the
following new aspects that have been introduced by the FIT/ARCS
transition:

1)  accommodation for multi-site work assignments - see pages:
     2 & 3 (assigning work),
     7 (track by task and subtask),
     13 (funding),
     18 (performance evaluation);

2)  consideration for assigning a new type of work - see pages:
     2 (scope of work for work assignments),
     4 (different professional-technical mix to phase in);

3)  use of a 'project planning* task - see pages:
     6 (definition of project planning),
     13 (invoicing);
     15 (cost reallocation),

4)  new semi-annual reporting requirement - see page 7;

5)  routine use of equipment pools and non-interference agreements
     see pages 8,  9, 10, 11 and 12;

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6)  new requirement for a site-specific invoice attachment -
     see pages.14 & 15;

7)  new requirement of site-specific cost summaries - see pages
     16 & 17;

8)  site assessment subcontracts use LOH pool - see page 20.

     If you require clarification on additional or Region
specific issues, you may contact Ann Hamann (PCMD) at FTS 260-
9252, John Hollister  (HSED) at FTS 260-8106, or Barbara McDonough
(HSCD) at FTS 308-8347 (use FTS 678-8347 after 11/15/91).

II.  FIT/ARCS Implementation

     The site assessment program has made arrangements for
funding and developing site assessment work assignments (WAs).
ARCS COs should continue to work with the ARCS PO and the site
assessment staff to issue or modify work assignments so that ARCS
can fully support all the site assessment activities in FY  '92.

     The site assessment program has developed model statements
of work  (SOWs) for their major activities.  These SOWs now  cover
work for preliminary  assessments (PAs) and site inspections
(Sis), expanded site  inspections (ESIs), SI prioritization  (SIP),
Hazard Ranking System  (MRS) package preparation and special
studies.  You have the flexibility to tailor each WA so that they
best meet your Region's needs.  The site assessment program plans
on releasing new guidance for conducting the site assessment
activities mentioned  above.  The EPA site managers will be
responsible to instruct the work assignment managers (WAMs) to
incorporate new guidance into on-going ARCS work assignments in
an orderly fashion.

     EPA's management of this work should not create significant
changes to the ARCS contractor's current management system.  The
work assignment scope would be approached as a single project
that  includes many sites and deliverables.  A single WAM would
oversee each work assignment.  This WAM would coordinate with the
EPA site managers responsible for the  investigations on sites
assigned.

      For reasons associated with cost  tracking and performance
evaluation, the workgroup recommends  issuing similar
site-specific work for multiple sites  within a single work
assignment,  i.e., one work assignment  for PAs, another WA  for
HRS,  etc.  If different site assessment work is combined onto one
work  assignment, the  Contractor must  be able to track and  report
by work  category  (e.g. PA, SI, etc) as well as by site.

      Due to  the  large number of sites  that  require evaluation by
the  site assessment program, it would  be  impractical to issue a

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work assignment for each site.  An example work assignment might
be:

     Conduct Sis on 40 sites based on a list of 20 known sites
     and 20 unknown sites.  EPA will then identify the unknown
     sites ,_a a Technical Direction Memorandum (TDM) or by work
     assignment form (WAF) at a future date.

     The contractor would then submit a work plan to perform the
     40 Sis.   If the contractor anticipates that additional LOE
     or dollars would be necessary to complete the assigned work
     or if the Agency increases the total number of sites to be
     completed under the SOW for the work assignment, the
     contractor will be required to submit a Work Plan Revision
     addressing the additional LOE and/or dollars necessary to
     complete the assigned activities.

     At the time of the FIT/ARCS transition (10/30/91),  the
workgroup recommended that each Region establish a balance
between administrative efficiencies (using 2 year work
assignments)  and promoting greater competition amongst the
contractors (with shorter work assignments).  In the interest of
promoting competition, you may want to consider using shorter
term work assignments.  On the other hand, issuing the longer
work assignments will allow the contractor to maintain the
appropriate staffing level and mix and improve continuity and
performance.   The work assignment might be issued for an
estimated workload for the period of performance as agreed upon
by the ARCS PO and the WAM.

     The sections below indicate special considerations required
to efficiently accommodate the site assessment work.

III.  Contractor Selection/Work Assignment Negotiation

     Assigning the site assessment work to the ARCS contractors
will introduce a large amount of work not routinely assigned to
ARCS contractors in the past.  You may periodically re-evaluate
the issues of work distribution and work assignment  (WA)
negotiations once we have had more experience with contractor
costs and performance in conducting site assessment activities.

Work Distribution

     EPA will assign site assessment work to at least two ARCS
contractors in each Region.  This approach promotes competition
(in staying with the original idea of competition between ARCS
contractors) and minimizes the effects of conflict of interest.
Concerns relating to available contract capacity and options, or
balancing regional workload evenly may require the use of more
than two contractors.  Consequently, the decision to use more
than two ARCS contractors is  left up to the Region's discretion.

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     The ARCS POs will work with the site assessment staff and
ARCS COs to decide which contractors will be issued site
assessment WAs.  This decision should be based on sound business
judgement and must be thoroughly documented for future reference.
The current decision criteria such as past performance, quality
of work, current workload, etc., will still apply for ARCS
contracts that have not reached their base LOE.  On contracts
where the base has been exceeded, the contractor's performance
index rating score (PIRS) will provide additional information for
your decision.  The Regions will retain the same flexibility you
now have in choosing a contractor in accordance with the ARCS
Contracts' Users Manual.

WA Negotiations

     WA negotiations will involve special attention given to
several cost items that will require more in-depth negotiations.
Items of primary concern include labor costs, travel, and other
direct costs (ODCs).

     One of the most important issues concerning site assessment
costs is the composition within the Professional and Technical
skill levels and labor rates associated with these levels.  The
technical requirements of the site assessment work are not as
high as those for remedial work currently being performed by the
ARCS contractors.  For example, PAs or Sis do not require a staff
of engineers that would be needed to conduct a remedial design.
Consequently, a different mix of professions, e.g., geologist,
hydrogeologist, chemist, etc., may affect the labor rate
associated with each category.  The workgroup recommends that a
composite labor skill mix be negotiated for each category.  You
can also use the most recent actual labor rates when developing
cost estimates.

     Attachment B summarizes the professional/technical (P/T)
distribution that has produced successful results on the current
FIT contracts.  You will note that the categories utilized most
under the FIT contract are T-2, P-l, and P-2.  This attachment
also shows the composition of the FIT Zone I staff for contract
years (CY) 1 and 2.  A range of labor skill mixes, T-levels and
P-levels should be negotiated based on the skill requirements
appropriate for the task assigned.

     Travel will be a part of each WA and may be estimated
according to task  (e.g., PA, SI).  Travel estimates are based on
the projected cost of a typical trip.  These estimates will
differ significantly depending on the size of the Region and the
task at hand.  Realizing the peculiarities of each site, the
Contractor needs enough flexibility in this area to accomplish
the task.  The goal is to establish estimates and guidelines.

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     The ARCS PO should assist the WANs when reviewing the
proposed and actual ODCs charged to the site assessment work
assignments.  This assistance will help the WAMs to become more
familiar with the types of ODCs acceptable under the ARCS
contracts.

     Other negotiating points for the SI WAs include subcontract
costs which may be proposed by the contractor.  As a guideline,
the SI SOW should provide the typical range and type of samples
per site.  The contractor may propose a subcontract for acquiring
samples and other data.  The workgroup recommends that the
Regions manage these costs in accordance with specifications
developed in the work assignment's SOW.  Again, enough
flexibility should be given to allow the Contractor to submit
quality technical deliverables.

     Region specific requirements such as reporting and tracking
formats and costs may enter into the negotiations.  You should
discuss these items in accordance with the guidelines provided in
the program's SOW as well as the program management, reporting
and tracking sections of this guidance.

IV.  Program Management (PM)

This section addresses the following issues:

  1) definition of program management support required for site
     assessment work;

  2) advantages/disadvantages of utilizing existing ARCS program
     management funding mechanism;

  3) determine if special studies should or should not be charged
     to program management.

     A comparison of current FIT and ARCS program management
activities indicates that the following FIT program management
activities could be conducted under ARCS program management:

     -ensuring successful technical and administrative
      performance;
     -preparing annual program plans and reports;
     -projecting obligation rates and outlays;
     -standardizing technical and programmatic procedures;
     -developing acceptable health and safety plan;
     -preparing summary reports and fact sheets;
     -maintaining equipment;
     -training;
     -maintaining files;
     -ensuring contractor specific QA/QC;
     -making Conflict of interest (COI) determinations;
     -managing a subcontracts procurement system.

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     Under program management, ARCS contractors need to report
site specific cost data as addressed in the invoicing and
reporting sections.  In addition, medical monitoring may need to
be reviewed depending upon how each ARCS contract was negotiated.
At this time, several PM duties previously conducted under the
FIT contracts will not translate into ARCS PM.  The management of
the Field Analytical Support Project (FASP) has been deleted
since this activity will be transferred to the Environmental
Services Divisions (ESDs).  Production of supplemental cost
summaries for monthly invoices and data collection for FOIA
responses are also deleted as a program management activity.  The
management of investigation derived waste should be included as a
site-specific task in each work assignment as appropriate.

     It is important to make a distinction between ARCS PM
activities and "project planning" activities directly related to
managing a group of sites on a WA since they will be funded
differently.  The "project planning" costs will be charged
directly to a WA and will consume ARCS LOE.  Task 1 of each work
assignment will cover all "project planning" costs.  These costs
involve activities associated with development and management of
the overall work plan, cost estimates, and amendments for a WA.
Additional activities under this task include costs for
specialized training required by the site assessment work (i.e.,
revised Hazard Ranking System (rHRS) and support of any region
specific tracking requirements for monitoring progress of the
work at each site on the WA (see tracking and reporting
section)).

     HSCD has an existing mechanism for funding all ARCS PM
costs.  Consistent with the overall approach of minimizing
changes caused by the FIT/ARCS transition, this process will
continue,  and the transition will not require an administrative
change in funding for ARCS PM.

     To provide quick turnaround of special field studies, the
FIT/ARCS workgroup evaluated several alternatives for conducting
this type of work under a separate "special studies" work
assignment or under a program management WA.  A program
management WA will not be used for special studies.  It is
recommended that a "special studies"  (or technical assistance)
work assignment provide the capability rapid response studies as
the need arises.  Funding such a work assignment would not be
considered "banking funds" since this approach solely provides
the capability to conduct a set of well defined, short term,
quick turnaround activities allowed under the ARCS scope of work.

     In summary, ARCS will use the following approach for
managing PM on site assessment work:

   1) The necessary program management activities provided under
     the FIT contracts are included in ARCS program management.

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     Project planning associated with site assessment work will
     be included in the individual work assignments.

  2) All program management activities associated with site
     assessment work assignments shall be included in the
     existing ARCS program management.

  3) If special studies or general technical assistance
     activities are to be conducted, a separate work assignment
     is recommended.  The statement of work will be based on past
     special study activities, with the statement of work revised
     as needed.  The special studies work assignment approach
     will be further refined by the WAMs (with the ARCS PO's and
     CD's input) during development of a special studies
     statement of work.

v.  Tracking and Reporting

     The transition of site assessment work into ARCS contracts
will require considerations in two areas of ARCS reporting:
costs and progress reporting.   In both cases,  ARCS should
accommodate these requirements with relative ease.

Cost Reporting

     The current ARCS monthly cost and site activity reporting
system will stay the same.  The ARCS contractors' capability to
track by task or subtask will support tracking and reporting for
multi-site work assignments.

     The transfer of site assessment work to ARCS will produce
one additional reporting requirement.  A semi-annual report
outlined in Attachment C provides a data summary on site specific
activity.  The WAM has to ensure that each site assessment work
assignment requires the Contractor to track the data summarized
in Attachment C.  If a Contractor routinely charges management
information system  (MIS) support hours to WAs, then the
contractor may conduct this activity under the appropriate work
assignments.  Otherwise, the work will be done under the program
management function.

     The WAM will forward this report to both the Regional Site
Assessment Section Chief and to Steve Caldwell (Field Operations
Section Chief in HQ) by December 1 and June 1 of each year.  Each
site assessment work assignment should have a report that
summarizes work completed over the preceding 6 month period
(i.e., Novemb.-.r 1 to April 30, and May 1 to October 31).
Headquarters needs these reports to develop annual budgets and to
account for program expenditures.  As the site assessment program
further evaluates the results of the FIT/ARCS transition, the
reporting table in Attachment C may change (note that this
guidance updates the original tabl*>) .  The ARCS contractors

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should plan on implementing tracking revisions in the first full
reporting period following the date of issuance.

Progress Reporting

     The site assessment prograir needs to work with the ARCS PO
to define the requirements and frequency for progress reporting
on site assessment work.  In the past, FIT contractors have
developed milestone tracking systems that provide feedback to the
Regions on the status  (both in LOE use and percentage to
completion) of sites.  In some cases, the level of detail of past
FIT reports may exceed that of the ARCS remedial assignments.  If
individual Regions continue to require these reports, the site
assessment program should provide the ARCS contractor with a
documented program and/or data file  (collected from FIT) to
support report generation.  This reporting requirement should be
outlined in Task 1 (i.e. project planning) of each WA.

vi.  Equipment

     The FIT RPOs and ARCS POs will continue to coordinate the
transfer and distribution of FIT equipment based on the
anticipated workload and equipment needs for each ARCS
contractor.  For future consideration in managing ARCS equipment,
the following items have arisen out of this transition effort:

  l) Attachment D contains a standard 7 point justification for
     transferring equipment.  Contractors receiving equipment
     need this type of justification to get transferred equipment
     assigned to their contracts (via contract modification).
     Note that if equipment is to be transferred to EPA, a 7-
     point justification is not required.

  2) Approaches for managing the FIT equipment through the
     FIT/ARCS transition period have varied from Region to
     Region.  For your reference, Attachment E briefly summarizes
     each approach employed in the Regions.  The issue of
     centralized equipment management will require further
     attention and coordination under the Superfund Longterm
     Contracting Strategy  (LTCS).  If you would like to locate or
     obtain Regional guidelines for managing equipment pools,
     contact the appropriate FIT RPO listed in Attachment A.

  3) The workgroup recommends that EPA distribute health and
     safety equipment  and a portion of other non-reportable, non-
     expendable equipment among ARCS contractors based on
     equipment needs.  All equipment purchases made under ARCS
     will be done in accordance with current procedures.

     While undertaking a variety of Regional approaches for
managing special field equipment (geoprobes, X--mets, vehicles,
etc.), we would like to generate information that could be used

                                 8

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in future evaluations of Superfund equipment management issues.
Past experience with expensive analytical and field equipment has
indicated a need for improved coordination for the acquisition,
technical oversight and utilization of certain types of
equipment.

     Several Regions will either manage certain pieces of FIT
equipment in a central pool or routinely loan equipment between
ARCS contractors.  The experience gained through each approach
may provide the information with which we can evaluate the merits
of Superfund equipment pools as well as current equipment
acquisition and management practices.  Due to the impending
nature of the FIT/ARCS transition, the implementation process
cannot address the longterm issues associated with equipment
management.  However, we request that the Regions continue to
increase the degree of coordination on equipment issues, document
their experience and participate in any future evaluations.

     While implementing your Region's approach to equipment
management, you may need to consider some of the following items:

NON-INTERFERENCE LOAN AGREEMENT:

PURPOSE:  The non-interference loan agreement is intended to
simplify the temporary loan of equipment between contractors,
protect all parties involved and define each party's
responsibility.  The use of these loan agreements will save EPA
money by preventing the unnecessary purchase or lease of
equipment when equipment is sitting idle either within EPA or at
one of its contractors.  As the name suggests, the loan of the
equipment should not interfere with the loaning program's
operation.  Therefore, it can be canceled if a need arises in the
loaning area.

APPLICABILITY:  A loan agreement has uses for short term
transfers only.  Longterm equipment transfers between contractors
will require a contract modification.  Loans of field equipment
from EPA to the contractors would have to follow the same
procedures and controls that we would expect our contractors to
maintain.

These agreements are generally for loans of nonexpendable
property for up to six months.  If the items are required for a
longer period, the items should be transferred (with a contract
modification) to the contractor requiring the item.  Until a
clause is developed that will allow for the authorization of
equipment on multiple contracts, the loan of accountable
equipment  (nonexpendable items $1000 or above) for more than 60
days will require a seven point justification and a modification
to the contract to authorize the use of the property.  Non-
accountable  items may be transferred with the approvz.1 of both
project officers and the completion of a 1700-7 form or other

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appropriate hand receipt.  For your reference, Attachment F
contains examples of non-interference loan agreements used on a
FIT contract.

CONCERNS TO BE ADDRESSED:

     SHIPMENT:  The cost of shipment to and from the receiving
     contractor is normally the responsibility of the receiver.
     If this is not the case, the agreement should specify which
     program will be responsible.  Special packing requirements
     should be detailed in the agreement.  Normally the loaning
     area is responsible for the item until it is received by the
     receiving contractor, and the receiver is not relieved of
     responsibility until returned to the leaner.  It may be
     advisable to select a method of shipment that requires a
     signature of receipt.

     ENHANCEMENTS OR REFURBISHING:  Often the item to be loaned
     will be improved by the addition of components or even a
     general overhaul.  The costs of these enhancements are
     generally considered a type of user fee and are borne by the
     receiving area.  However, if the costs are so extensive that
     this would be unreasonable, all or part of the costs can be
     paid by the lender.  For example, the lender may pay for all
     or part of the costs when the enhancement increases the
     capability of a system twofold or significantly extends the
     useful life of the property.  The POs responsible for the
     contractors involved will negotiate the reasonableness of
     any payments.

     MAINTENANCE AND CALIBRATION:  An item should be returned in
     the same condition as when it was lent, minus normal wear
     and tear.  The receiving area should pay for maintenance and
     calibrations and should follow the maintenance schedule set
     up by the loaning area.  A summary of the recent maintenance
     and calibration records should accompany the equipment when
     shipped to the receiving contractor, and copies of
     maintenance and calibration records should be returned with
     the equipment at the end of the loan.

     If major repairs are required, a determination of the
     economic feasibility of the repair should be made by the EPA
     Property Administrator  in conjunction with the Project
     Officers involved.

     DECONTAMINATION:  Each  contractor is required as part of
     their health and safety plan to establish procedures for the
     decontamination of  equipment removed from toxic areas.
     Depending on the nature of the equipment and the sites
     involved, site specific workplans should always specify
     decontamination requirements to eliminate duplicate efforts


                                10

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REPORTING PROCEDURES - INVENTORY:  The lending organization
will setup and maintain a tracking and reporting system for
all equipment under their responsibility.  The system should
accommodate tracking of loaned equipment and encompass the
following items:

- Utilization records
- Maintenance & calibration records
- Loss, stolen or damage (see relief from
responsibility section)

RELIEF OF RESPONSIBILITY:  Normally the loaning area is
relieved of responsibility for property upon shipment to the
receiving contractor.  However, for a loan, this relief will
only apply to the liability for the item and not the
accounting (i.e. reporting) for the item.  The determination
of liability will be made by the contracting officer for the
receiving contract.

For property accounting and reporting purposes, the
receiving area will report through the loaning program.  For
the loaning program's annual inventory, the receiving area
will certify that they have the property if it is on loan
when the loaning area's inventory is due.

Copies of lost, damaged or stolen reports to the receiving
contractor's Government Property Administrator should be
sent to the loaning area.  Upon relief of responsibility,
the receiving contractor will forward a copy to the lender.

REIMBURSEMENT:  Since the Government is self-insured,
reimbursement for lost, damaged or stolen items is not
normally required.  Exceptions to this principle must be
identified in the receiving contract such as when additional
insurance is required for vehicles.  However, reimbursement
may be required if the loss is so great that it will
significantly impact the loaning program.

Fair market value (FMV) reimbursement is required if a
Superfund item in the possession of a non-Superfund program
is lost, damaged or stolen.

If reimbursement is required for items that are lost, stolen
or damaged beyond repair, the agreement should specify
whether the basis for reimbursement will be fair market
value, depreciation or replacement.

MOTOR VEHICLES:  When motor vehicles are loaned, the
receiving program should certify that they have sufficient
liability coverage to meet the requirements of 48 CFR
28.307-2(c).  State vehicle registration is not required.
                           11

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     At this time, it is not anticipated that there will be an
     administrative problem with loaning vehicles between ARCS
     contractors or between EPA and an ARCS contractor.   However,
     there are some legal aspects under consideration that may
     affect future loans.

     EQUIPMENT POOLS:  Whether the equipment pool is maintained .
     by a contractor or by EPA personnel, the overall guidelines
     for the control of property are in the Federal Property
     Management Regulations (FPMR),  the Facilities and Support
     Services Manual 4830 series, The Federal Acquisition
     Regulations  (FAR) and the Contracts Management Manual.

EQUIPMENT LOANS OR TRANSFERS BETWEEN REGIONS;  To streamline
equipment tracking, inter-regional transfers will require either
the appropriate contract modification for equipment loans over 60
days or follow the appropriate procedures for the transfer of
Government equipment.

EQUIPMENT POOLS;  For your reference, Attachment G contains a
list of equipment with costs greater than $10,000.  You may
identify equipment to include in a Regional pool from this list.
In addition to pooling expensive equipment, you should also
consider pooling backups for field certain field equipment (e.g.
HNUs, etc.) that would assist with short term equipment
shortages.

PERFORMANCE AND COST INFORMATION ON THE VARIOUS APPROACHES
EMPLOYED:  In this effort, we eventually hope to test the
hypothesis that equipment pools will save on equipment
acquisition, storage and maintenance costs.  You should be aware
that in the future, we would like to collect data for evaluating
the efficiencies provided by equipment pools.  When such an
effort has been organized in conjunction with the LTCS,  you
should plan on providing the .following data to the designated
lead addressing equipment issues:

   • a summary of management issues  (problems, successes,
     failures and tracking and reporting systems) to gain a
     subjective indication of the manageability of each approach.

   • a summary of costs  for storing and maintaining (in FTE) the
     equipment pool.  Cost items to be tracked include rent,
     associated contractor fees and maintenance hours.  As a
     comparison,  it would be helpful to hold cost records on both
     the contractors that contributed equipment to the pool and
     the contractor managing the equipment pool.

   • Property Administration will keep records of the utilization
     ratings developed  in their Regional reviews to evaluate the
     aspect of equipment utilization.  As guidance becomes
     available for conducting desk reviews and reports on

                                12

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     equipment utilization or as Regional tracking systems are
     developed, we may have other information sources.

vn.  Invoicing

     Based on Regional and Headquarters recommendations for
funding site assessment work and approving invoice payments, the
following procedures should apply to all site assessment work
assignments.  In all cases, the current invoice structure and
processing procedures will not change.  The reporting of site
specific costs to the National Contracts Payment Division at
Research Triangle Park (NCPD-RTP) for sites with a Site/Spill
Identifier  (S/S ID) number should be maintained.  The contractor
must maintain records of all site specific costs for all sites,
regardless of whether the site has or does not have an S/S ID.

Funding. Task Structure and Cost Reporting

     Each multi-site work assignment will be incrementally funded
under a non-site specific  (00) account or a pre-SSID site (ZZ)
account.  The dollars obligated will be based on the number of
sites to be processed or the LOE to be delivered.  All costs
incurred on a multi-site work assignment should be included in a
contractor's regular monthly invoice.

     The task structure for all site assessment work assignments
should be similar.  For cost accounting purposes, task 1, as
described in the project planning section, will include all non-
site specific costs on a WA (note that special studies work
assignments may be an exception to this rule) and will be charged
to the non-site account (00).   Task 1 costs will be redistributed
to all tasks on the same WA in accordance with the Financial
Management Division's (FMD's)  guidelines for annual allocations.
Attachment H provides these guidelines for your review.

     For tasks 2 through "N",  the contractor will track all costs
and labor hours for individual sites.  The redistribution sheets
will summarize these site-specific costs for redistribution into
either S/S ID accounts or into a single ZZ account for sites
without S/S IDs (IFMS only has site accounts set up by S/S ID).

     Labor hours by tasks shall be outlined in the monthly
progress report for review by the EPA site managers (with the
WAM's assistance).  Site specific financial information must be
maintained by the contractor for cost recovery purposes and will
be submitted to the Project Officer on a basis specified in the
following sections.
                                13

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Invoice Review Process

     ARCS POs must assume responsibility for communicating the
following new reporting requirements to ARCS contractor
personnel:

  1) Capture by site, all site-specific costs incurred on multi-
     site work assignments.

  2) Report site-specific costs to the ARCS PO using the:

     - Superfund Site-Specific Invoice Attachment and
     - the cumulative summaries for site specific costs.

      Beginning immediately, every ARCS contractor that has an
active site assessment work assignment will submit a Superfund
site-Specific Invoice Attachment, or redistribution sheet, with
every invoice.  Attachment I provides an example of a
redistribution sheet.  The Contractor should be able to provide
all this information with the exception of the document control
number (DCN), which the ARCS PO will provide.  In order to help
NCPD-RTP process ARCS invoices, each contractor having an active
site assessment work assignment must submit a monthly invoice
attachment, regardless if they do or do not have site assessment
costs in a given month.

     The redistribution sheet will allow NCPD-RTP to distribute
site-specific costs to the appropriate site-specific Superfund
account number in their Integrated Financial Management System
(IFMS).  Costs listed on the invoicing attachment should include
all site-specific contract costs (i.e. labor, overhead, G&A,
travel, etc.) directly associated with site activities.

     As a reference, Attachment J shows the elements that make up
Superfund site account numbers and illustrates how to convert
generic account numbers to site specific accounts.  The
Contractor shall construct these account numbers when producing
the redistribution sheets as shown in Attachment I.  One should
note that NCPD-RTP will also use the account numbers to identify
pre-remedial work assignments  (by noting the 'J1 entered in the
field for the activity code).  Therefore all accounts containing
obligations for pre-remedial work should have a 'J' as an
activity code.  NCPD-RTP will  look for site-specific invoice
attachments when they see an account with a  'J1 activity code
listed under a Contractor's obligations.

     Attachment K depicts the process by which EPA captures
monthly site-specific costs in the IFMS through the invoicing
process.  The IFMS maintains these records for cost recovery
purposes.
                                14

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     The Contractor must reallocate certain costs to sites on an
annual basis.  These costs include base and award fees, non-site
specific ODCs, .and other allocable costs for non-site specific
activities.  These costs shall be reported on the monthly
invoicing attachments as illustrated in Attachment I and
reallocated annually according to the process guidelines provided
by FMD.

     Due to the structure of the multi-site work assignment, cost
re-allocation will have to occur in two steps.  In accordance
with FMD's allocation guidelines (Attachment H),  the contractor
first reallocates project planning costs (i.e. task 1 of each
work assignment) to other tasks on the same work assignment.
Secondly for the remaining allocable costs (i.e.  fees, etc.),
FMD's guidelines will then apply equally to all ARCS work
assignments.

     The invoice submitted to NCPD-RTP for payment will include
prior, current, and cumulative costs, and the total dollars being
invoiced for the work assignment.  The ARCS PO is responsible for
approving site assessment invoices, providing the site specific
invoice attachments and verifying the accuracy of any accounting
information submitted to NCPD-RTP for payment.

     The PO should also provide a copy of the invoice and the
site-specific costs for the WAM's and EPA site manager's review.
With the site manager's input, the WAM will determine whether or
not the costs invoiced are reasonable for the technical progress
achieved.  (The CORAS Bulletin, Financial Management
Responsibilities of EPA Program Staff;  Review and Certification
of Contractor Invoices (OSWER Publication 9200.5-401-4), provides
guidelines for this review.)  With the WAM's input, the ARCS PO
will then recommend payment, request additional information, or
recommend that payment be denied.


Initiating Site/Spill Identifiers

     EPA's process for assigning S/S IDs, as it relates to
accounting for site costs, is presented in Attachment L.  The
accuracy of site names and locations in S/S ID accounts is
critical to this process.  Consistency of site information
between the IFMS, CERCLIS and the Office of Program Management's
(0PM's) S/S ID data base will assist both the ARCS contractors
and POs in tracking, invoicing, and reporting site-specific
costs.

     To ensure accurate and consistent site names and locations
in the Superfund data bases, the procedures listed below must be
followed:
                                15

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  1)  The EPA site managers will work with the ARCS PO and
     Regional Finance Officer to decide when sites should receive
     an S/S ID.  From the site assessment perspective,  a site
     should receive an S/S ID when it appears likely that the
     site will go on to the National Priorities List (NPL)  and
     undergo future enforcement activities.   The S/S IDs will be
     entered into the IFMS according to Regional procedures.   The
     Resource Management Directive System 2550-D provides agency
     guidelines for entering S/S IDs into the IFMS.

  2)  In accordance with Regional procedures, the EPA site manager
     must always inform the ARCS PO and the Regional Finance
     Officer of changes in the site name and/or location.  This
     is necessary to maintain consistency in the case where the
     same CERCLIS site has S/S ID information maintained in the
     IFMS.

  3)  The Contractors will continue to use 0PM1s S/S ID site
     listing when producing the site-specific invoice attachment
     for the ARCS PO.  For the purpose of NCPD-RTP's processing
     invoices, the total monthly sum of all costs for sites not
     having S/S IDs  (i.e. pre-S/S ID) can be reported to a single
     Regional ZZ account.

Documentation of Pre-S/S ID Costs for Cost Recovery

     When contractors conduct site-specific tasks for sites
without S/S IDs, the ARCS contractor and the ARCS PO will be
responsible to maintain the records of site-specific charges in
the Region.  Costs for sites without S/S IDs cannot be entered
into separate IFMS accounts in the monthly  invoice process.  Once
EPA assigned an S/S  ID to the site, the contractor can then
report all subsequent cost on the monthly redistribution sheets.
Previous costs incurred on the site receiving a new S/S ID should
be documented as follows:

     The Agency is currently developing a formal process for
     reassigning pre-S/S ID costs through invoicing attachments.
     If the PO wishes to make corrections for pre-S/S ID costs
     (by site-specific invoicing attachment)  in advance of this
     guidance, the accounting and format requirements should be
     cleared through FMD and RTP-NCPD.

     Until the guidance  is released, the WAM  shall require the
     contractor to submit a summary  of the  cumulative site
     specific  costs  (by  invoice).  Attachment M provides a
     recommended format  used by  FIT  at contract close-out.  The
     WAM  shall work  with the site assessment  Section Chiefs to
     determine when  the  Contractor will submit these reports and
     how  EPA will  store  any completed reports.  Each WAM should
     instruct  the  ARCS Contractor to compile  this  information
     into  a  single,  cumulative  cost  summary covering all work

                                16

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     assignments.  A comprehensive summary will facilitate data
     collection for cost recovery.

     There may be many sites that will not receive an S/S ID
number during the FIT/ARCS transition period; others will never
receive an S/S ID.  However, the ARCS PO must document all site
costs for future reference.  You can use the same report in
Attachment M to summarizes these costs (as indicated on the lines
having ZZ entered for an S/S ID #) .

     If the cumulative cost summary has an S/S ID number
referenced with a site, then pre-S/S ID costs may exists.  The
cost recovery staff or contractor will have to cross-check the
cost listing with the IFMS data to identify if all costs were
captured in the IFMS.  The cost summary tables refers to a site
assessment site file (either by site name or by task order
number) where detailed information can be found and verified.

     In summary, the ARCS PO must:

  1) Ensure that each ARCS multi-site invoice has a site-specific
     invoicing attachment before going to NCPD-RTP.

  2) Work with the WAM and the Regional Financial Officer to
     develop a strategy for assigning S/S IDs to sites for
     capturing site costs in the IFMS.

  3) Arrange to produce and maintain cumulative cost summaries
     covering every site assigned to the contractor.

VIII.  Award Fee Plan

     Both the ARCS and FIT contracts are Cost-Plus-Award-Fee
(CPAF) contracts.  These contracts consist of: (a) the "base" fee
which was negotiated as a percentage of the estimated cost of the
contract that does not vary with performance, but, rather
compensates the contractor for risk; and (b) the "award" fee
amount, which is a financial incentive earned in part or in
whole, based on an evaluation of the contractor's performance.
The following sections give a brief overview of how the award fee
process has been managed for both the FIT and ARCS contracts in
the past.  The implementation section relates how we will manage
the award fee for ARCS site assessment work.

Background;  ARCS Award Fee

     The ARCS contractor's performance is evaluated twice a year,
on a six months  (semester) basis.  Under the ARCS contract, the
award fee is divided into several categories for site specific
technical support and program management.  The site specific
award fee is allocated in two phases:


                                17

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     Phase I Award Fee - Based on the overall evaluation of
     contractor's performance on all work assignments during the
     rating period.

     Phase II Award Fee - Based on the evaluation of performance
     for work assignments completed during the evaluation period.

     The ratio of available award fee allocated to Phase I and
Phase II is specified in each contract.  The program management
available award fee is based on a separate evaluation of overall
PM performance during each rating period.

Background:  FIT Award Fee

     Under the FIT contract, performance evaluations differed
from the ARCS because of the large number of sites involved and
the relatively short duration of each site activity.  The FIT
evaluation covers a combination of both on-going and completed
assignments and is not split into Phase I and II.  The evaluation
is categorized by the type of investigation being conducted
instead of by site.  It is based on the' quality of work completed
for a group of sites for which a similar task was performed.  For
instance, one evaluation is conducted on all Sis.

Implementation Under the ARCS

     The FIT/ARCS Contractor Evaluation workgroup has developed
the following recommended approach to evaluate site assessment
work under the ARCS contracts.

     The Phase I and Phase II award fee plan of the current ARCS
contract can be used for the site assessment work assignments.
Since the ARCS contractors often expect long term work
assignments, the introduction of the Phase II award fee to site
assessment work should not present a significant problem.

     In the ARCS contracts, an assessment of contractor
performance against six evaluation criteria is made for each work
assignment and an allocation of the award fees for both Phases I
and II are then based on those performance evaluation
recommendations.  The performance evaluation criteria were
developed to provide a uniform basis to evaluate work performed
by all contractors, thus, the criteria are generic in nature.
These criteria are very similar to those used in the FIT
contract.  The performance criteria are:

  o  Project Planning - organizing (e.g. work plan development,
     data review), scheduling, and budgeting;

  o  Technical Competence and Innovation - effectiveness of
     analyses, meet plan goals, support COE/State/enforcement

                                18

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     actions, adhere to regulations and procedures, approach
     creativity/ingenuity, expert testimony;

  o  Schedule and Cost Control - budget (hours & cost)
     maintenance, priority/schedule adjustments, cost minimizing;

  o  Reportl..j - timeliness of deliverables, clarity,
     thoroughness;

  o  Resource utilization - staffing, subcontracting, equipment,
     travel; and

  o  Effort - responsiveness,  mobilization, day-to-day, special
     situations (e.g. adverse/dangerous conditions).

     These performance evaluation criteria will be used by the
WAM when evaluating contractor performance each semester and at
the end of the work assignment for Phase II award fee
determinations.

     Since numerous deliverables are anticipated for each work
assignment, it is recommended that each Region devise a mechanism
for tracking the quality of all deliverables as they are
submitted.  This will provide support documentation for the
evaluation recommendations.

Performance Evaluation Board (PEB)

     Due to the significant size of the site assessment work
assignments, it is recommended that PEBs have a voting member who
is knowledgeable in the site assessment program for the periods
that the site assessment work is evaluated.  (note a formal
change to the PEB may be required.)  A site assessment staff
person should be invited to the PEB at the first meeting to
assist the ARCS POs in their presentations.  However, the ARCS PO
will retain overall PO authority for the entire contract,
including those work assignments issued for site assessment work.

     It has been noted that, as with PRP oversight work, site
assessment work assignments may be somewhat routine in nature and
may not allow the contractor an opportunity to show innovation or
other characteristics that merit "outstanding" ratings.  The PEB
members, POs, and site assessment staff should work together to
give the contractor a fair rating.

     The site assessment work assignments should be included in
the PIRS score for award of future work once the base LOE hours
are achieved on the contract.
                                19

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IX.  Miscellaneous Issues

Conflict of Interest (coi) - Initial feedback from the ARCS
contractors has focused on two primary concerns with COI.  The
first concern centers on the requirement for EPA approval to
accept EPA-initiated remedial work on a site where the contractor
previously conducted site assessment work for EPA.  Because of
the unique controls existing between Superfund's pre-remedial and
remedial work, EPA does not believe it would be a conflict of
interest for a contractor to perform both EPA initiated pre-
remedial and remedial work.  However, because of the sensitivity
of COI issues, EPA reserves the right to review each situation on
a case by case basis.

     The second case involves the requirement for EPA approval to
pursue private work on a site where site assessment work has been
conducted for EPA.  EPA expects the ARCS to follow the COI
clauses included in the ARCS contract.

LOE Utilization on the ARCS Contracts - The ARCS contractors
expressed concern over the site assessment work draining the pool
of available LOE hours before contract expiration.  Options exist
for addressing this issue should it eventually limit EPA's
ability to find remedial or site assessment support in a Region.
However, WAs will continue to be issued under current contracting
methods and Headquarters, with the assistance from Regions, will
monitor use of LOE hours.

     An ARCS contractor may propose the use of a subcontractor to
conduct site assessment work.  Obviously, this is the
contractor's decision.  However, this approach will still use LOE
hours in the ARCS contract.  This option does not affect the
guidelines presented in the Contract Selection section of this
document and EPA must in no way, have the appearance that this
option or the use of a specific subcontractor would be preferred
by EPA.

Training of ARCS Contractors - The ARCS contractors should be
expected to conduct field investigations with the SOW provided in
a site assessment WA.  However, special training may be needed to
become familiar with the new Hazard Ranking System (HRS) used as
a relative risk model by the site assessment program.  We
recommend you allocate hours for some training under one work
assignment for this purpose.  The Program's current plans for HRS
training are attached in Attachment N.  The site assessment staff
will inform you of changes in these plans.
                                20

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   Attachment A





FIT/ARCS Workgroups

-------
                            FIT/ARCS  Administration Workgroup
.'lar.cy Barrr.akian
-en Smith
3en Conr.etta
Amy 3rochu
Charles Swan
Keith Mills
Steve Nathan
Gail Nabasny
Pat Bamford
Karen Flcurr.oy
-oug Frazer
Joanne Labaw
Ann Hamann
Tom Sharpe
John Hollister  (chair)
Barbara McDonough
John Comstoctc
Joseph Sefadi
Charlie Young
Oebbie Morrey
Sydney Ozer
Tina Van Pelt
Anthony Borda
Greg Ham
Linda  Martin  (chair)
Barbara Driscoll
Gerry  Snyder
John Hollister
 Name

 Sharon Hayes
 Ben Conneta
 Mario Villamarzo
 Bill Messenger (co-chr)5
 Paul LaCourreye
 Debbie Flood (co-ch
 John Hollister

Rea ion
1 (ARCS ?0)
1 (FIT RPO)
2 (SAM)
2 (FIT RPO)
4 (FIT RPO)
4 'ARCS ?O)
5 (ARCS PO)
5 (FIT RPO)
5 (ARCS CO)
7 (S.A. Chief)
9 (FIT RPO)
10 (ARCS PO)
HQ (PCMD ARCS)
HQ (PCMD FIT)
FTS
Phone $
333-1797
333-1643
264-6696
340-6302
257-2930
257-7297
886-5496
353-1056
386-2400
276-7782
484-2338
399-2594
. 260-9252
332-6289
HQ (desig. lead) 260-8106
HQ (ARCS Mgt. )
HQ (CORAS)
RTF
HQ ( FMD )
7 (ARCS PO)
3 (ARCS CO) •
HQ ( FMD )
HQ (Prop. Admin
PA Work
Region
3 (FIT RPO)
5 (SAM)
6 (SAM)
8 (FIT RPO)
HQ (FIT PO)
SI Work
Region
1 (SAM)
2 (SAM)
4 (SAM)
)5 (SAM)
9 (SAM)
)10 (SAM)
HQ (SA)
303-8347
260-4026
629-3777
260-5143
276-7782

260-6167
) 260-7712
FTS
FAX #
333-1662
333-1662
264-6192
340-6622
257-4464
257-5206
353-6775
353-6775
353-1879
276-7063
434-1916
399-0124
260-1830
260-1880
252-0854
308-8389
260-7265
629-3159
260-6543
276-7063

260-6543

Assignment Workgroup
Phone #
597-8229
353-9486
255-6740
330-7504
475-8106
FAX t
597-9890
(312) 886-7160
655-6460
330-1647
252-0854
Assignment Workgroup
Phone #
833-1709
264-6696
257-5065'
353-1057
434-2345
399-2722
475-3106
FAX *
833-1662
264-6192
257-3035
886-7160
348-1078
3990175
252-0854
Email *

EPA917Q
EPA 9543
EPA 5033
                                                                       Emai.L_£
                                                                       Email

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                          FIT/ARCS  Administration Subworkgroups
Equipment

:,'a.-r,e
Gail Mabasr.y
Karen Flournoy
Doug Frazer
Jchn Hollister
Anthony Borda
Ann Harr.ann
Invoicing

Name
N'ancy Barmakian
Ann Hamann
John Hoilister
Barbara McDcnough
Joseph Sefadi
Charlie Young
Tina Van Pelt
Program Management

Name
Don Smith
Gail Nabasny
Karen Flournoy
Joanne Labaw
Ann Hamann
Award Fee Plan

Name
Keith Mills
Steve Nathan
Pat Bamford
Doug Frazer
John Comstoclc
Tracking and Reporting
Name
John Hoilister
Work Distribution
Name
Nancy Barmakian
Charles Swan
Doug Frazer
Ann Hamann
Barbara McDonough

Region
5 (FIT RPO)
7 '(S.A. Chief)
9 (FIT RPO)
-:Q (FIT ?O)
-:<2 (Prop. Admin)
•iQ (PCMD ARCS)


Region
1 (ARCS ?O)
HQ (PCMD ARCS)
HQ (FIT PO)
HQ (ARCS Mgt. )
RTP
HQ (FMD)
HQ ( FMD )


Region
1 (FIT RPO)
5 (FIT RPO)
7 (S.A. Chief)
10 (ARCS PO)
HQ (PCMD ARCS)


Region
4 (ARCS PO)
5 (ARCS PO)
5 (ARCS CO)
9 (FIT RPO)
HQ (CORAS)

Region
HQ (FIT PO)

Region
1 (ARCS PO)
4 (FIT RPO)
9 (FIT RPO)
HQ (PCMD ARCS)
HQ ( ARCS Mgt . )
FTS
Phone #
353-1055
275-7782
484-2333
260-3105
260-7712
269-9252

FTS
Phone #
833-1797
260-9252
260-8106
308-8347
529-3777
260-3209
260-6167

FTS
Phone if
833-1648
353-1056
276-7782
399-2594
260-9252

FTS
Phone if
257-7297
886-5496
886-2400
484-2338
220-4026
FTS
Phone if
260-8106
FTS
Phone if
833-1797
257-2930
484-2338
260-9252
308-8347
                                                     260-1880
                                                     FTS
                                                     FAX If
                                                     833-1662
                                                     260-1880
                                                     260-0854
                                                     308-3389
                                                     529-3159
                                                     260-6543
                                                     260-6543
                                                     FTS
                                                     FAX if
                                                     833-1662
                                                     353-6775
                                                     276-7063
                                                     399-0124
                                                     260-1880
                                                     FTS
                                                     FAX If
                                                     257-5206
                                                     353-6775
                                                     353-1879
                                                     484-1917
                                                     260-3847

                                                     FTS
                                                     FAX #
                                                     260-0854

                                                     FTS
                                                     FAX If
                                                     833-1662
                                                     257-4464
                                                     484-1917
                                                     260-1880
                                                     308-8389
                                                                        -.T.aii  *
                                                                        EPA  5033
Email *
EPA 9170

EPA 5033
Email if
Email
EPA 9543
Email f
EPA 5083
Email t
EPA 9170

-------
Name

Jane Anderson
Amy 3rochu
Greg Ham
Lonnie Ross
Jeanne Griffith
John HoLlister
Expanded Site Inspection (ESI) Work Assignment Workgroup

       Region            Phone *     FAX *             Email
Name

Linda Martin
Greg Oberly
Dave Bennett
John Hollister
Name

Sharon Hayes
Walter Schoepf
John McCuen
Paul LaCourreye
John Hollister
1 - (SAM)
2 (FIT RPO)
3 (SAM)
6 (SAM)
5 (SAM - lead)
HQ (FIT/ARCS)
Hazard Ranking System
Region
5 (SAM)
3 (SAM)
10 (SAM)
HQ (FIT/ARCS)
Site Prioritization
Region
1 (SAM)
2 (SAM)
4 (SAM)
9 (SAM)
HQ (FIT/ARCS)
335-9698 833-1662
340-6802 340-6622
597-3229 597-9890
255-6740 655-6460
886-3007 886-7160
260-3106 260-0854
(HRS) Work Assignment Workgroup
Phone J* FAX t
353-9486 (312) 886-7150
330-7598 330-1647
399-2103 399-0175
260-8106 260-0854
(SP) Work Assignment Workgroup
Phone # FAX #
333-1709 833-1662
264-0221 264-6192
257-5065 . 257-4862
484-2345 848-1078
26.0-8106 260-0854
Special Studies (SS) Work Assignment Workgroup
Region Phone if FAX /
HQ (FIT/ARCS) 260-8106 260-0854
L HQ (ARCS Mgt.) 308-8347 208-8389
HQ (PCMD ARCS) 260-9252 260-1880
EPA5033
Email #
EPA5083
Email #
EPA5083
Email £
EPA5083
 Name

 John  Hollister
 Barbara McDonough
 Ann Hamann

 Note:   In developing a special studies  SOW,  HQ  will develop a draft SOW with the input
 of the Regional site assessment staff.   HQ  will distribute the draft SOW through the
 Regional site assessment section chiefs for review SOW by the ARCS POs and ARCS cos.

-------
              PIT Regional Project Officers  (RPOs)
Region
1
2
3
4
5
6
7
3
9
10
FIT RPO
Don Smith
Amy Brochu
Greg Ham
Charles Swann
Gail Nabasny
Ed Sierra
Pete Culver
Gerry Snyder
Doug Frazer
John Osborn
FTS Phone #
833-1648
340-6802
597-8229
257-2930
353-1056
255-6740
276-7707
330-7504 *
484-2338
399-0837
* after 10/31/91,  contact Paul Arell at FTS 330-7658

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               Attachment B

Professional/Technical and Skill Mixes for
           Site Assessment Work

-------
     ZONE I FIT STAFFING
                            ZONE I FIT TECHNICAL STAFF
                       PERCENT DISTRIBUTION BY DISCIPLINE
Region
ZPMO
HST
FIT1
RT2
FIT 3
FIT 4
ToUl
Program
Planned
Staff
17**
9
46
72
76
90
310—
Actual
Staff
ii**
7
37
67
73
79
279
•  Asof October 1988
•* For ZPMO only, this number includes
   profefHonal arid support suff.
   Does not include 6 'reserve* LOE
                                                            Other
                                                            2094
                                                   Geochenrmts
                                                   Geophysicists
                                                   Earth Scientists
                                                   Environmental Technicians
                                                   Draftspersons
                                          Biologists
                                             9H
                                         Toxicologists
                                             S%
 Hyd
Hydro
Hydrologists/
 irogeoTog
    4H
lists
                                               Engineers
                                           (Civil. Chem.. Envir.)
                                                  5%
                                                   Environmental
                                                   ,   Scientists
                                                        20%
                                                            Geologisti
                                                              23*  '
                              Chemists
                                14%
           pUubttl
                                 Exhibit 2

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                                17
                  P-T Mix for PIT LOE Delivery
           (distributions given as percentage of each
                P-T category to total LOE pool) *
                           5-year                 (5/90 to 10/90)
                         Budgeted  %                Actual  %
                         Distribution             Distribution
P4                               2.5                     2.0
P3                              16.4                    15.5
P2                              26.9                    23.7
PI                              25.4                    30.5

T2                         .     16.7                    18.4
Tl                              12.1                     9.9

Total Dist.                    100.0                   100.0

Clerical                        16.1                    14.4
   * These are based on the total FIT regional hours (Zone
     Program Management hours are not included).   The regional
     FIT hours do include a portion of what will be considered
     ARCS PM hours (approx. 15 to 20% of total regional FIT
     hours).   Therefore, P-4 and P-3 distributions should be
     considered to be on the high side of what should be expected
     on a site assessment work assignment.

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            Attachment C
    Standard Semi-annual Reports
for Site Assessment Work Assignments

-------
Contractor:
Reg ion:
WA Name:
Reporting Period:
Total  LOE for  Period:
                        Total Costs:
Page  1

Date:

WA No.:
•iiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiijgi
III 1 II
LOE Total
Spent in Period
# of Final Site
Deliverables (1)
Average LOE/Site
w/ Final Deliv. (2)
Average Site Spec.
Costs/Site (2,3)
Project Planning
LOE Spent
Project Planning
Costs ($)
Average Drilling
Costs/Site (2)
PA




N/A
N/A
N/A
SI




N/A
N/A

SIP




N/A
N/A

ESI




N/A
N/A

MRS




N/A
N/A

EPI PA




N/A
N/A
N/A
FF
REVIEW




N/A
N/A

Specii 1
Studies




N/A
N/A

SUBTOTAL







      1.   Sites with final report submitted to EPA in Period of Performance.
      2.  Jflksites with  final report only;  subtotal is sum of^^^ hours/costs on completed  sites.
      3-  ^^Bate using  the fully loaded rate ($/LOE) on the ^^Bassignmeiit in the period.

-------
                                        Page 2
                                        Period:
                                        WA #
                  Breakout of LOE by P/T Level


     Level          Hours          % of total

      P4

      P3

      P2

      PI

      T2

      Tl


Total LOE


* Clerical


*the "% of total" for clerical will equal  the ratio of  clerical
hours to total LOE delivered on the work assignment in  a  given
period.

-------
         Attachment 0

Standard 7-point Justification
    for  Equipment Transfers

-------
SEVEN POINT JUSTIFICATION FOR TRANSFER OF RESIDUAL PROPERTY


 CONTRACT NAME:     	

 CONTRACT NUMBER:	•
       1,     It is requested that the Government property described in the attached
 listing be transferred to the subject ARCS contract for use under the contract.  This
 contract has been tasked by the EPA with the responsibility of performing pre-remedial
 activities previously held by the FIT program at uncontrolled hazardous  substance
 disposal sites under the Superfund program.  Activities that are performed and will
 continue  to  be performed by  the contractor include preliminary  assessment, site
 investigation,  site-specific  project  management,   remedial  planning,  remedial
 investigation, remedial design, remedial construction management, and other technical
 and management assistance.

       2.     The equipment to be transferred is described in the attached listing.

       3.     This equipment is essential to the performance of the  contract because
       4.     It is in the best interest of the Government to transfer this equipment to
 the contract because it will maximize utilization of the property and result in a cost
 savings to the Government by not purchasing new equipment.

       5.     The property will be utilized for purposes under the contract and when not
 in use will be located at	
 The person and telephone number of the person who would be responsible for the
 property is	


       6.    This item is not applicable) since the items are being supplied from excess.

       7.    A lease vs. purchase is not applicable in this case, as no new expenditure
 is involved.

-------
          Attachment E

A Summary of Regional Approaches
    for Managing FIT Equipment

-------
                                                  5/31/91
                                         (revised 9/18/91)
Note to John Comstock  (CORAS):

     At the FIT RPO's meetings held on 5/29-30, we discussed
several property "administration issues with the EPA Property
Administrator for NUS contracts, Anthony Borda.  The points below
summarize some of the FIT/ARCS transfer  issues as well as other
issues relating to establishing centralized equipment pools in
the Regions.

1) Summary of Regional Plans  for Managing FIT  equipment under
   FIT/ARCS:

   Region 1:  Will split equipment between ARCS contractors, the
   geoprobe unit will go to one ARCS contractor, another ARCS
   contractor will plan to buy a second unit.

   Region 2:  Wants to centrally manage equipment in ESD but has
   problems finding FTE to do so.  The Region will look into
   options for having ESAT provide personnel for maintenance and
   daily management of the equipment.

   Region 3:  Will split equipment between ARCS contractors

   Region 4:  Plans on assigning all equipment to one ARCS
   contractor.  If needed, the equipment will  be loaned to other
   ARCS contractors using a "non-interference  agreement".  The
   idea to hand equipment over to ESD failed to be a viable
   option at this time (I think due to space and FTE concerns)
   and the ARCS pooling idea  failed due to contracting concerns.

   Region 5;  Will centrally  manage much of the FIT equipment out
   of their Superfund technical support section.  The Region
   plans on assigning 2 FTE to manage the equipment.  All
   Superfund contractors will have access to the equipment on a
   first come, first served basis.

   Region 6;  Will split between ARCS contractors

   Region 7;  Will manage all FIT equipment in ESD with the
   support of 2 ESAT staff.

   Region 8;  At this time, plans on splitting between ARCS
   contractors.  The RPO will reconsider this  plan in light of
   some of other options considered  in the other Regions.

   Region 9:  Will assign all FIT equipment to one ARCS
   contractor for the  interim FIT/ARCS period.  The ARCS
   contractor will  loan equipment only to other ARCS contractors
   as the need arises.

   Region  10; Will manage all FIT equipment in ESD with the
    support  of 2  ESAT staff.

-------
                        farm
               EQUIPMENT LOAN AGftfiMENT
                                      wt« on
    o«tt:
        Tlmt:
ivM by.

-------
          Attachment F
Sample Equipment Loan Agreements
(Used by the FIT Zone I Contract)

-------
                                                          REVISION:           03
                                                          DATE:         October !, 1939
                                                          PAGE:            35 of 41
                                          Exhibit E

                                        (Page 2 of 2)

Loan Period:            Fill in the dam th« property is approved for lain.

Delivery Date and Time:  Fill in the datt and time the property is loaned to the Government agency.

Method and Payment of  Describe tht property transfer  arrangements for  transporting the
Transportation:          Gov«rnm»nt property to th« r«pcnsibl« Govtrnmt nt ag«ncy.

Conditions of Us*:        Ot«rib« th« ip*dfic project the Govarnmtnt property will b« us«d for and
                       any special conditions rtquirtd in the prop«rty u*4.
condition of th«         0«tcrib« in full th« rtquirtd property condition upon return, i.«., prop«ry on
return:                 dtcontaminattd, calibrated, «tc.

Impact i on              Pill in tht  n»p«
-------
                                                          NUUJE3:
                                                       •2
                                                      CJ
                                                          OAT!;
                                                          PAGE:
                                                        :. '935
                                          Exhibit!
               INSTRUCTIONS FOR COMPUT10N OF EQUIPMENT LOAN AGREEMENT
                                          Form #5

Purpose:                For projtct staff ailignid to Government projtcti to lend Govenmert
                       property to a Government agency regional office.

UM:                   To b« completed after approved In writing by the Contracting Offictr and
                       prior to landing any  Govtrnmant prop«fty fo< which NUS Corporation is or
                       will b« li«bl« for int UM, rapain, or any oth«r stipulated conditions.

Th« Rtqional Manager will ensure the Equipment Loan Agreement is accurately completed, filed in th<
regional office, and forwarded to  the  Property Administrator as an attachment to the regionji
inventory. Any other pertinent information should be  attached to the Equipment Loan Agreement
form.
Contract Number
Government Agency:

Oe
-------
         GPS  PATHFINDER  PERFORMANCE  CHECK  RECORD
 Unit (TNI. 12019- 15) Seriil^umber
TANS GPS Receiver (TNL 12017-15) Serial Number J
Fl« GPS Antenna (TNL 12960-00) Serial Number  3 U'4 AC' I >4vf2.
POLYCORDER (TNL 12915-13) Serial Number   Ob"!
 1. Visually inspect all instruments for workmanship defects                Done _^/_
 2. Check parts against the paclcng list                                Done_^_
 3. Place the GPS antenna in a clear space with an unobstructed view of sky.   Done y
 4. Connect the GPS Antenna to the TANS Receiver with the couiiJ cable.    Done _i/L
 5. Connect the POLYCORDER to the TANS Receiver with the wiring harness. Done _j/.
 6. Connect the DC battery connector on the wiring harneia to the btcrery pack. Or aroch
 the optional DC 10-15 voli supply to the vehicle power adapter and connect  the vehicje
 power adapter to the wiring hameia,                                   Done _^_.
 7. Turn on the POLYCORDER.  Read memory size and operating software version.
  Record from the fir* idefitificaaon screen:
  Merrory size   ^t> *.    (typical Is 448K)
  Version   1 -o^       (typical ia 2.05)
  Record from the second identification screen:
  Application software version    1-4 7.     (typical ia 120)
 8. Select main menu item 6, sub-menu 2 to record the NP and SP numbers.

NP JJd_ (typical is 3.02)           SP  i O°|  (tvoical it 2.07)

-------
                             EQUIPMENT LOAN AGREEMENT      i \ \ "   ^r •"  '    ''   -'
                                                             N-M->   ."^-•--'     "         ^=


                                                                        ~  : T - ^.;.-  • - 1
NUS Corporation agr*«s to Itnd th« following tquipmtnt for t)".f usa> on



contract *      63-01-7346                  bvUS. Er.viror.r.er.cal
     NO.
S«nal No.  A X    A "".'Ac  /-»L L) _



Prop«rty C«xnption/Manuf*cturtr  Six  (6) Trible Global ..Positioning Survey Units








Acquisition Date:    A~ / /•;
               ^^^^^^^^•^w
Ejtimated Cost:   6 units 3  fiSQ^.  /4. j <^. CO



Condition Codt: _ I _
LoanPtriod:  ** Mer.tha  or aa assreved by  EPA-CO (D. 2«ni)



0«rivtry Oattand Timt:  I'.'K- ^'   ^_'  ^ •' /';\V  '  '.<- '  ^ '



MtthodandPaymtntof Tran»po^ation:  S/A £OT sayraant  U.S.  EPA Vehicle used  for
  pick-u?
Conditions of Us»:  Nor.-lneerfarar.ce  -se  baaia in perforganea of U.S. E?A  Cor.eract



 Nuaber  68-01-7346	








Rf sponn bill tin for condition of tht property on return:  Robart  Jubach, FITOM






                                                               it

lntp«
-------
 X-Mets
 :
-------
           Attachment G



Equipment Costing more than $10,000

-------
                 Attachment H

       Financial Management Division -
Cost Re-allocation Guidelines (September 1991)

-------
     INSTRUCTIONS FOR
        PERFORMING
 THE ANNUAL ALLOCATION
OF NON-SITE-SPECIFIC COSTS
       Superfund Accounting Branch
       Financial Management Division
         Office of the Comptroller

-------
  SECTION I
INTRODUCTION

-------
                         TABLE OF CONTENTS
             INSTRUCTIONS FOR THE ANNUAL ALLOCATION
                      OF NON-SITE-SPECIFIC COSTS

SECTION I • INTRODUCTION	   1
     OVERVIEW  	   2
     DEFINITIONS OF TERMS	   3
     GENERAL REQUIREMENTS 	   5
SECTION II - ANNUAL ALLOCATION OF NON-SITE COSTS 	   7
     ANNUAL ALLOCATION PROCESS  	   8
           Step 1 - Reconciliation of Amount Paid	   9
           Step 2 • Identification of Site-Specific Costs	   11
           Step 3 - Reassignment of Pre-SSID Costs	   13
           Step 4 - Identification of Non-Site Costs  	   14
           Step 5 • Program Management Costs	   16
           Step 6 - Start-Up Costs  	   17
           Step 7 - Equipment	   19
           Step 8 - Non-Site Activities  	   22
           Step 9 - Non-Superfund Costs  	   23
           Step 10  - Summary of Amounts	   24
           Step 11  - Allocation  of Program Management Costs	   25
           Step 12  - Allocation  of Start-up Costs  	   28
           Step 13  - Allocation  of Capital Equipment Costs 	   29
           Step 14  - Allocation  of Site-Support Costs	   30
           Step 15  - Completion of Master Allocation Schedule 	   31
           Step 16  - Summary of Allocated Amounts 	   32
SECTION III - EXAMPLES OF ANNUAL ALLOCATION SCHEDULES	   33
     SUMMARY OF  ALLOCATION  	   34
     MASTER ALLOCATION SCHEDULE  	   35
     SCHEDULE OF START-UP COSTS  	   36
     SCHEDULE OF CAPITAL EQUIPMENT DEPRECIATION	   37
     SCHEDULE OF NON-SITE AcnvmEs	   38

-------
DEFINITIONS OF TERMS

Capital Equipment • equipment with a unit cost of $5,000.00 or more and with a useful
life greater than 1 year.

Direct Site Costs • costs which are attributable to a specific site.

End of Contract costs - costs incurred to shut down a contract - usually occur at the end
of the  contract.  End of contract costs may include such items as equipment removal
costs and maintenance.

Program management -  contract specific costs and fees incurred for the management of
the specific EPA contract as a whole.

Non-site activities  - costs incurred for activities not charged to specific sites.  Examples
include training of state personnel, calibrating EPA-owned equipment, and participating
in general meetings and/or conferences.  Non-site activities are broken down  into two
broad categories:  program-wide and site-support. (See definitions below.)

Pre-SSID costs - costs incurred in connection with particular locations at which a
Site/Spill Identifier (SSID) has not been assigned.  Also known as Sites without SSIDs or
'ZZ* costs.

Program-wide non-site activities • costs incurred for activities which support the overall
Superfund program.  The costs are global in nature and purpose and are not eligible for
distribution to sites.  Examples of program-wide activities include training given by the
contractor for EPA employees, training to first responders, training of state personnel,
and attendance at  conferences held to discuss general Superfund issues.

Site-support non-site activities - costs incurred for those activities other  than program
management and fees which relate to, support, and/or benefit the sites worked on by the
contractor in the aggregate, but which cannot be accounted for readily on a site-specific
basis.  Examples include training for  contractor employees working on sites, equipment
maintenance, calibrating EPA-owned equipment, tracking and inventory, and a
conference or meeting held to discuss issues related to  sites the contractor worked on.

SSID - Site/Spill Site Identifier  • specific two character alpha-numeric designation for
each site within  a  region.  The SSID  number is the last two digits in the EPA accounting
system's 10 digit account number used to track all costs incurred on the site.

Start-up Cosjs •  cost of efforts and activities incurred early in the contract term whose
benefits extend for the entire contract period.  Examples may include recruitment and
relocation of staff, preparation of the contract work plan, establishment of a quality
assurance program and  certain equipment purchases.

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OVERVIEW

       CERCLA, as amended by SARA, authorizes EPA to recover all response costs
associated with cleaning up hazardous waste sites.  A large portion of EPA's response
costs consists of payments to response action contractors.  In order for these costs to  be
adequately supp^i .ed in cost recovery Irigation against the potentially responsible party,
a defendabi:, logical and supportable accounting methodology must be in place that can
assign  costs to specific sites.

       The site-specific portion of the contract costs are accounted for by EPA on a site-
specific basis.  However, contractors' non-site-specific costs are accounted for in a
general account and must be allocated to the sites in order to be recovered.  This
guidance provides a logical and equitable methodology for the distribution of these non-
site-specific costs to specific sites. This effort is called Annual Allocation.  Completion
of Annual Allocation reports by the response action contractors will result in the
inclusion of all appropriate costs in the cost recovery effort.

       This document has been prepared by the Superfund Accounting Branch (SAB) of
the Financial Management Division. It provides instructions to contractors on how to
perform the annual allocation. EPA recognizes that each contract may feature unique
situations which may not necessarily be addressed in these instructions. In such cases,
the contractor should contact SAB for guidance.

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"00" CoSts - synonymous with "non-site-specific" costs. These are costs which are
attributable to more than one site or the program .  Examples include program
management and fees, equipment, start-up costs, end-of-contract costs and all non-site
activities  The "00" represents the last two digits in the EPA 10 digit account number.

-------
GENERAL REQUIREMENTS

      The Annual Allocation process results in the contractor allocating ail program
management costs; fixed, base and award fees;  and some non-site activity costs to sites
and activities the contractor worked on dining the fiscal year.  The contractor submits an
allocation report, along with supporting attachments, to the Supertund Accounting
Branch (SAB) of the Financial Management Division (FMD).  The amount included in
the annual allocation report is the sum of the invoices paid for work performed during
the Federal fiscal year, i.e., October 1 - September 30.

      SAB will provide to  the contractor within 90 days after the end of the fiscal year
the total  amount of all invoices paid for the annual allocation period.  The contractor
should provide two copies of the draft report within 60 days after the invoice amounts
are provided to the  contractor. The contractor may elect to combine all costs for FY
1986-FY  1991 on one allocation report.  Otherwise, each fiscal year's costs should be
allocated separately.

      When the contract performance period ends at other than the  end of the FY,
EPA will provide the amount to be allocated 90 days  after submission of the last invoice
following contract expiration.

Draft and Final Reports

      The contractor should first submit the draft reports to SAB. SAB will review the
drafts, notify the contractor in writing of any necessary corrections and request
submission of a final report. Two copies of the final report are due to SAB 30 days after
receipt of written notice from EPA.  The contractor shall provide, as  pan of the final
report, a signed statement certifying that the final report data accurately reflects the
costs distributed to each site and is supported by the contractor's accounting records.
Additionally, the contractor shall submit a Summary of Allocation report on a 5 Vi inch
or a 3 V6 inch DOS computer disk in a Lotus 1-2-3 or ASCII format.

      The annual  allocation report  submission includes the following:

Required Reports:

             Summary of Allocation
             Master Allocation Schedule (Attachment A)
             Statement of Allocation Methodology
             Listing of all  invoices paid during the Federal fiscal year (with invoice
             numbers and amounts)
             Certification of Contractor's report - (final report only)

-------
Required- if applicable:

             Schedule of Start-up Costs (Attachment B)
             Schedule of Capital Equipment Depreciation (Attachment C)
             Schedule of Non-Site Activities (Attachment D)

Allocation Methodology

      Annual Allocation is a multi-step process that distributes the costs of program
management, regional management, base and award fees  and other non-site specific
expenses to sites and program-wide activities on a pro-rata basis. The distribution of
costs is based upon benefits received or support provided  by the activities.

      The preferred allocation method is the distribution of non-site costs based on a
percentage of total costs. However, the contractor may request an alternative method,
subject to approval by the Financial Management Division.

      In preparing each year's  annual allocation report, the concractor should determine
whether any amounts received from EPA during the year  relate to prior fiscal years, e.g.,
indirect cost adjustments.  If the amount of such payments are  material, the contractor
should prepare a separate allocation schedule for those amounts.

-------
      SECTION H

ANNUAL ALLOCATION OF
    NON-SITE COSTS

-------
ANNUAL ALLOCATION PROCESS

      This section describes EPA's preferred annual allocation method. The examples
included are designed to incorporate most situations.  Certain contracts may not have all
types of costs, or activities listed.  If so, enter "N/A" on the schedule and proceed to the
next step.

      The allocation package submitted by the contractor should provide the
information shown on the Summary of Allocation Schedule along with the information in
Attachments A, B, C, and D.  Attachment A is the master schedule and summarizes
information from the other attachments.  In a sense, Attachment A is similar to Internal
Revenue Service Form  1040, and  the other attachments equate to Schedules A, B, etc.

      The information  provided on the Summary of Allocation should be triple spaced
to allow for the addition of account codes by EPA.  Sufficient supporting documentation
enabling EPA to verify  the accuracy of the allocation must be submitted as required by
the contract clause.  Attachments  A, B, C, and D of the instruction package provide
examples of adequate supporting documentation.

      The instructions  provided below follow a format which flows from Attachment A
to each of the supporting attachments B, C, and D.
                                        8

-------
Step 1 - Reconciliation of Amount Paid
      The first step in the annual allocation process is the determination of the amount
paid for work performed during the government fiscal year.  EPA will provide the
amounts paid for work performed during the fiscal year.  The amount paid represents
Superfund monies only."  Non-Superfund monies are not considered in this allocation.
The contractor should reconcile EPA-provided paid amounts with their  records. For this
step, assume EPA provides a paid amount of $270,000. An example of the reconciliation
is shown below:
EPA PROVIDED AMOUNTS:
Invoice

  4
  5
  6
  7
  8
  9
Period of Performance
  10/1/88 -
  12/1/88 -
  2/1/89 -
  4/1/89 -
  6/1/89 -
  8/1/89 -
11/30/88
 1/31/89
3/31/89
5/31/89
7/31/89
9/30/89
                             Paid
                            Amount

                            $30,000
                             40,000
                             40,000
                             50,000
                             60,000
                             50.000
                           $270,000
                    Date
                    Paid

                    1/15/89
                    3/15/89
                    5/15/89
                    7/15/89
                    9/15/89
                   11/15/89
CONTRACTOR AMOU
 Invoice

  4
  5
  6
  7
  8
  9
Period of Performance
10/1/88 -
12/1/88 -
 2/1/89 -
 4/1/89 -
 6/1/89 -
 8/1/89 -
           11/30/88
            1/31/89
           3/31/89
           5/31/89
           7/31/89
           9/30/89
 Billed
 Amount

 $30,000
  42,000
  40,000
  50,000
  60,000
  50.000
$272,000
  Paid
 Amount

 $30,000
 40,000
 40,000
 50,000
 60,000
 SQ.QQQ
$270,000
                                      Difference

                                       $ -0-
                                        2,000
                                         0
                                         0
                                         0
                                         0
                                     $270,000
       There are three important pieces of information in the above example. The first
 important piece of information is the period of performance.  It is the government fiscal
 year - October 1 through September 30. Note that the invoices provided represent work
 performed during the government fiscal year.  When the phrase 'amount paid for
 performed" is used, the government fiscal year is the period of work performed.

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      The second important piece of information is the paid amount. EPA has paid
$270,000. The contractor amounts show $272,000 billed to EPA, but only $270,000 paid.
There is a difference of $2,000, which could represent fee holdbacks, suspensions, or
disallowed payments. The annual allocation process uses the amount paid for work only
performed, not the amount billed.

      The third important piece of information is the date paid.  Some of the payments
occurred after the end of the government fiscal year. The annual allocation process uses
th* amount paid for the work performed during the government fiscal year.
                                       10

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Step 2 - Identification of Site-Specific Costs

      The next step in the annual allocation process is the identification of the site-
specific costs paid for work performed during the fiscal year.  The site-specific costs
include those sites with EPA SSIDs and those without EPA SSEDs. This information will
be entered on Attachment A, Master Allocation Schedule.

Sites with EPA SSIDs

      For sites assigned an EPA SSID, enter the following information by region and by
site number on Attachment A, line 1, Description:

      Q      EPA SSID - the unique site/spill identifier number consisting of a two-digit
             region code (representing EPA regions 01 - 10), and a two-digit site/spill
             number assigned by EPA.

      n      Site Name - the first twelve letters of the site name as it appears on EPA's
             SSID  list.

      a      State  - the two-letter State abbreviation.

      a      Amount Paid - under Column A, the sum of the amounts directly reported
             for each site on each  invoice or site-specific attachment submitted and paid
             for the annual allocation period. This includes any pre-SSID costs
             redistributed to the site during the year.

Sites without EPA SSIDs

       For sites not assigned an EPA SSID, enter the following information by region
and by Site on Attachment A, Line 2, Description:

       Q     Sites without SSIDs - the pre site/spill identifier number consisting of a
             two-digit region code (representing EPA regions 01 - 10), and a two-digit
             pre-SSID number (ZZ) assigned by EPA.

       Q     Amount Paid - under Column A, the sum of the amounts reported for each
             pre-SSID site on each invoice or site-specific attachment submitted and
             paid for the annual allocation period. Pre-SSID costs are summarized by
             region.

       The Attachment A example illustrates the procedures for entry of cost
 information for Sites with EPA SSIDs and Sites  without EPA SSIDs. For example.
 Region 1 Sites with EPA SSIDs, show $15,000 identified as costs for the Picillo site
 (0101) and $25,000 for the Fletchers Paint Mill site (01A2).  For Region 1 Sites without

                                         11

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EPA SSIDs, there is an $8,000 amount reported under the SSID "01ZZ." The costs for
sites reported under the "ZZ" identifier shall not include any pre-SSED costs which were
previously redistributed to the sites during the year.

Subtotal Superfund Site Costs

      In Column A, subtotal the amounts from Column A, Line  1 for Sites with EPA
SSIDs and subtotal the amounts from Column A, Line 2 for Sites without EPA SSIDs.
                                       12

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Step 3 - Reassignment of Pre-SSID Costs

Note: if the contractor does not have this category of costs, note this on Attachment A
and proceed to the next step.

      The purpose of (his step is to reassign any pre-SSID costs paid for work
performed during the fiscal year that are not reflected in the Sites with EPA SSEDs costs
identified in the previous step.  For these costs, the redistribution will be identified on
Attachment A, Column B.

      During the year, the contractor may have performed effort at sites which had not
been assigned an EPA SSID. The costs for this effort were charged to  the pre-SSID
account during the year.  In many instances, a unique SSID is subsequently assigned to
these sites, and the cost of work initially performed and billed is properly reassignable to
a specific site.

      In the Attachment A example, $2,000 is being reassigned from the Region 1 pre-
SSID amounts to two Region 1 sites. Based upon contractor records, $1,000 was
incurred and paid at each of these two sites before an EPA SSID was established. These
amounts are not reflected in the Sites with EPA SSIDs totals from the previous step.  In
order to reflect the total site specific amount for these two sites, the $1,000 per site
needs to be reassigned from the pre-SSID amounts to the site amounts.

      On Attachment A, Line 2,  Column B, a credit of $2,000 is entered for that line
item. The reassigned amounts of $1,000 for each site are then entered  on the
appropriate lines in Line 1, Column B.  After all reassignments  are made, sum the totals
of Column A and Column B for each site and pre-SSID item and enter the sum on
Attachment A, Column C for the  respective site and pre-SSID amount.
                                        13

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Step 4 - Identification of Non-Site Costs

      The purpose of this step is to identify the non-site costs and the types of activities
they represent.  The non-site costs can be classified into one of five major categories:

      1)     Program Management • contract activities associated with the management
             and administration of the contract as a whole.  For region specific
             contracts, there will be one category of Program Management.  For Zone
             or National contracts, Program Management may be broken down into two
             subcategories - Regional Program Management and National Program
             Management. Program Management costs will be entered onto
             Attachment A in Step 5.

      2)     Start-up Costs - activities incurred generally  in the first year and associated
             with efforts benefiting the entire contract term, e.g., quality assurance
             plans. Start-up costs will be entered onto Attachment A in Step 6.

      3)     Capital Equipment - equipment with a unit cost of $5,000.00 and greater
             and a useful life of greater than one year. Capital equipment costs will be
             entered onto Attachment A in Step 7.

      4)     Non-Site Activities - activities under the contract, other than program
             management, start-up, or end-of contract, which are not site-specific.
             These activities can be broken down into two sub categories:

        •    Site-Support Non-Site Activities - payments for activities which relate to,
             support, and/or benefit the sites worked on by the contractor; or

        •    Program-Wide Non-Site Activities - payments for activities which support
             the overall Superfund program  beyond the sites worked on under this
             contract; they are global in nature and purpose.  These costs will not  be
             allocated to sites in the annual  allocation process.

             For further information on non-site activities, refer to the next page.  Non-
             site activities will be entered on Attachment A in Step 8.

      5)     Non-Superfund Costs • costs for contract tasks funded from EPA
             appropriations other than Superfund; e.g., Abatement, Control, and
             Compliance, Research and Development, or Lust monies.  Non-Superfund
             costs are not included in this allocation.

      The contractor should evaluate the types of non-site costs that were billed and
paid for work performed during the fiscal year and place them in one of the five
categories identified above. In the next five steps, these amounts will be identified on

                                        14

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supporting schedules and entered on Attachment A as applicable.  Once the costs have
been entered onto Attachment A, the appropriate non-site costs will be allocated to sites
and activities.

Description of Non-Site Activities

      There is no comprehensive list of site-support non-site activities and program-wide
non-site activities. The determination of a site-support activity or a program-wide
activity is based upon the purpose of the activity itself.  A general definition with some
examples will provide sufficient guidance for the contractor to identify which of the non-
site activities represent site-support activities and program-wide activities.

      Site-Support Activities - Activities undertaken for the purpose of specifically
assisting  in, or supporting the contractor's site response actions, are considered site-
support activities.  Listed below are some activities which are generally considered to be
site-support activities:

      - Project  planning costs for a multi-site work assignment
      - OSHA safety training for site employees
      - Site equipment training
      - Development of CERCLA site standard operating procedures (SOPs)
      - Development of CERCLA site quality assurance plans
      - Review CERCLA site  sampling procedures

      Program-Wide Activities - Activities which are general in nature and are
performed for reasons other than supporting site response actions are considered
program-wide activities.  If the activity benefits the Superfund, or EPA as a whole, it
should be considered a program-wide activity.  A few examples of program-wide
activities are provided below:

      - Review of EPA sampling procedures
      - Preparation of SOPs for CERCLA and Clean Water sites
      - Preparation of the Annual Allocation Report
      - Attendance at a General Superfund Environmental Conference
      - CERCLA Title III evaluations
      - End of contract activities

      The examples given above are certainly not an exhaustive  list  However, to
summarize the general guidelines and concepts of the examples listed above:  if the
activity  supports or benefits the site response actions worked on under the contract, the
activity should be considered a site-support activity; if the activity benefits the Superfund
or EPA  as a whole, the activity should be considered a program-wide activity.
                                         15

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Step 5 - Program Management Costs

      The purpose of this step is to enter program management costs onto Attachment
A, Master.Elocution Schedule.  In step 4, the amount of program management costs was
identified. Depending on the area of coverage of the contract, there may only be one
category of program management. For Zone or National contracts, there may be two
categories - regional and national program management. Enter the amount of national
program management, or contract program management, identified in Step 4 on
Attachment A, Line 3, Columns A and C  If the contractor has regional program
management, enter the amount of regional program management, by region, on
Attachment A, Line 4, Columns A and C.

      In the Attachment A example, $25,000 has been identified as national program
management as indicated in Line 3, Columns A and C. Attachment A also shows
regional program management of $10,000 and $7,000 for Regions 1 and 2,  respectively,
in Line 4, Columns A and C.
                                      16

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Step 6 • Start-Up Costs

      Note: If there are no start-up costs associated with this contract, note this on
Attachment A and proceed to the next step.

      Start-up costs consist of the cost of efforts and activities incurred and paid for
whose purposes and benefits extend for tne entire contract period. Examples may
include the recruitment and relocation of staff, preparation of the contract work  plan,
establishment of a contract quality assurance program, and calibration of equipment.
Start-up costs typically will have been charged to the contract as program management.

      Any start-up costs incurred during this annual allocation period were identified  in
Step 4.  In Step 6, the total start-up costs applicable to this period will be identified and
incorporated  into the annual allocation process.

      Attachment B, Schedule of Start-Up Costs, is the schedule used to determine
start-up costs applicable for this annual allocation period. The information on this
schedule will be  used for all annual allocation periods. The following information should
be entered on the schedule:

      A)    Schedule Heading - complete the heading for this schedule by entering the
             fiscal year of the annual allocation, contractor name, and  contract number.

      B)    Fiscal Year Incurred - enter the Federal fiscal year for this annual
             allocation period.

      C)    Start-Up Costs - enter the amount of start-up costs incurred and paid by
             each annual allocation period (fiscal year) of the contract. Also enter the
             amount of start-up costs incurred and paid  this annual allocation period on
             Attachment A, Line 5, Column A.

      D)    Number of Years  Allocated - enter the  number of  years over which the
             start up costs will  be allocated (amortized).  Generally, this represents the
             number of years remaining on the contract.  The amortization should be
             based upon a straight-line  or percentage of level-of-effort basis. In this
             example, a straight-line amortization of five years (the life of the contract)
             is used for illustrating the amortization.

       E)    Amount Amortized Each Year - the amount of start-up costs amortized in
             this annual allocation period, by fiscal year. This fiscal year amount
             (straight-line method) is determined by  dividing the amount identified in
             the Start-Up Costs column by the amount in the Number of Years
              Allocated column.
                                        17

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      F)     Total Amount to be Allocated This Annual Allocation Report - the total of
             all costs in the column. Amount Amortized Each Year. Enter this amount
             on Attachment A, Line 5, Column C.

      In the Attachment B example, the contract began in FY 1987. During FY 1987
the contractor incurred 'and was paid for $25,000 of start-up costs. These start-up costs
will be amortized over the five-year life of the contract on a straight-line basis. To
complete this schedule, the FY 1987 start-up costs of $25,000 are entered on the first
line of the schedule in accordance with Steps B-E above. For FY 1988, no start-up costs
were incurred or paid. A zero is entered in the start-up  costs column. In the current
year, FY 1989, there were no start-up costs incurred or paid. A zero is entered in the
start-up costs column.  For this annual allocation period, $5,000 of start-up costs is being
amortized and included in the annual allocation. The $5,000 represents the amortized
portion  of the start-up costs incurred and paid in FY 1987. This amortized portion  is
entered on Attachment A, Line 5, Column C.
                                        18

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Step 7 - Equipment

      Note: If there are no equipment costs, please note this in Attachment A and
proceed to the next step.

      Cost-reimbursed equipment represents capital equipment with a unit price of
S5.000.00 or greater and a greater than 1 year useful life.  The cost of this capital
equipment should not be allocated to sites during a one-year period, but rather,
depreciated over its useful life.  The preferred depreciation basis is an actual usage basis
or straight-line method.  If the contractor has another accepted accounting method of
equipment depreciation, that procedure may be substituted for the straight-line or actual
usage basis.

      This schedule applies only to  non-site-specific capital equipment.  Expendable
equipment or capital equipment purchased and consumed at a site (and paid as a site-
specific cost by EPA to the contractor) should not be included on this schedule.

      Any new capital equipment costs incurred during this annual allocation period
were identified in Step 4.  In this step, the capital equipment costs purchased during this
annual allocation period will be entered on Schedule C, Schedule of Capital Equipment
Depreciation, and the total capital equipment depreciation applicable to this period will
be identified.  The total capital equipment depreciation applicable to this period includes
the depreciable amount of capital equipment purchased this annual allocation period
plus the applicable depreciation of capital equipment purchased in previous annual
allocation periods.

      Attachment C, Schedule of Capital Equipment Depreciation, is the schedule  used
to determine capital equipment costs applicable for this period. The information on this
schedule will be  used for all annual allocation periods.  The following information should
be entered on the schedule:

      A)    Schedule Heading - complete the heading for this schedule by entering the
             fiscal year of the annual allocation, contractor name, and contract number.

      B)    Date Charged to Contract - enter the month and year the equipment was
             charged to the contract for all equipment items depreciated this  annual
             allocation period.

      C)    Capital Equipment - enter the name of each capital equipment item.

      D)    Purchase Price - enter the amount charged to the contract for each capital
             equipment item. For equipment items purchased this annual allocation
             period, compute and enter the total amount billed and paid and enter that
             amount on Attachment A, Line 6, Column A.

                                         19

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      E)     Useful Life - enter the useful life of the equipment. If the straight-Line
             depreciation method is used, enter the useful life in number of years. If an
             actual usage basis is used, enter the actual usage unit;  i.e., number of
             hours, number of days, etc.  The useful life may extend beyond the term of
             the contract.

      F)     Beginning Balance - enter the amount of undepreciated equipment costs.
             For equipment purchased in previous fiscal years, this  amount will be the
             Ending Balance (See H) in the previous year's  annual  allocation report.
             For equipment purchased this fiscal year, the amount will be  the purchase
             price.

      G)     Depreciation Amount  - the depreciation amount to be allocated this
             annual allocation period.  This amount represents the purchase price (D)
             divided by the useful life (E). For this report, assume  no residual or
             salvage  value.

      H)     Ending  Balance - enter the amount of undepreciated equipment cost. This
             amount represents Beginning Balance  (F) less Depreciation Amount  (G).
             This amount is carried over to the next annual  allocation report.

      I)     Total Amount to be Allocated in this Annual Allocation Report • sum the
             amounts entered into the Depreciation Amount Column (G).  Enter  that
             sum on Attachment A, Lane 6, Column C.

      In the  Attachment C example, the straight-line depreciation method  was used for
all equipment items.  In the example, there are three capital  equipment items, each
purchased in  a separate fiscal year and initially reported in a separate annual allocation
period.

      Entries for Items A - D are self-explanatory.  In this example, Step D results in
the entry of equipment purchased during this annual allocation period on Attachment A,
Line 6, Column A.

      The entry for Useful Life (E), may be somewhat difficult to determine. The
contractor's own experience should be used in setting the useful life.  However, the
contractor may rely on manufacturer estimates or specifications.  If the manufacturer
does not publish useful life figures, or a standard industry useful life  has not been
established, use the standard IRS depreciation tables for useful life.

         The entries for the Beginning Balance (F) represent the remaining balance of
depreciation at the beginning of the annual allocation  period. The Gas Chromatograph
has a purchase price  of $80,000 and a beginning balance of $48,000.  The gas
chromatograph was purchased in FY 1987. The current  annual allocation period is for

                                       20

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FY 1989.  There have been two annual allocation reports prior to this year.  The
difference between the purchase price and the beginning balance of $32,000 represents
the depreciation included in the two prior years' annual allocation reports.  The same
holds true for the mobile lab. The mobile lab was purchased in the prior annual
allocation period. Therefore, the beginning balance represents the purchase price less
one year's depreciation amount. The third item shown, Tractor, was purchased in this
annual allocation period. The purchase price and the beginning balance  are the same.

      The Depreciation Amount (G) represents the Purchase Price (D) divided by the
Useful Life (E). In this example, number of years were used. Also in this example,
there is no proration of the depreciation  amount for purchases made during the fiscal
year.  As an example, the Tractor was purchased in November 1988. It was used for
eleven months of this annual allocation period. The depreciation for this annual
allocation period is one-third of the total purchase price, or one of the three years' useful
life, not 11/36 of the purchase price.  If the contractor choose,, to depreciate the
equipment based upon the number of months available during the fiscal year, that is an
acceptable practice.  However, this example uses the full year basis.

      The Ending Balance (H)  represents the Beginning Balance (F) less Depreciation
Amount (G). For the FY 1990  annual allocation report, this amount would  be entered
into the Beginning Balance column (F) for all  equipment items depreciated during the
FY 1990 annual allocation period.

      Attachment C provides the  total amount to be allocated for this annual allocation
period in Step I. The amount is the sum of the amounts entered into the Depreciation
Amount (G) column.  Total the  amounts entered in this column and enter the amount
on Attachment  A, Line 6, Column C.

      This example shows the straight-line depreciation method for equipment
depreciation. If the contractor has another acceptable accounting procedure for
depreciation, that procedure can be used. The resulting schedule may appear in a
different format than presented  in the example.  However, the basic information should
still be presented.
                                        21

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Step 8 - Non-Site Activities

      Note: If there are no non-site activities, please note this in Attachment A and
proceed to the next step.

      Non-site activities represent efforts and activities which either support contractor
site response actions or support the Superfund program as a whole.  The non-site
activities can be efforts generated  by separate contractual instruments  (Work
Assignments, Technical Directive Documents, Delivery Orders, etc.) or general
components of the general non-site portion of the contract.

      Attachment D, Schedule of Non-Site Activities, is the schedule  used to identify
and list the activities by site-support activities or program-wide activities.  In Step 4,
these activities were identified. Activities should be grouped and listed by alienability
type and area of applicability.

      A)    Schedule Heading - complete the heading for this schedule by entering the
             fiscal year of the annual allocation, contractor name, and contract number.

      B)    Determination of Allocability - enter the allocability determination for
             each identified activity as either site-support or program-wide.

      C)    Area of Applicability - enter the sites, or grouping of sites, over which the
             costs will be allocated; i.e., Region  1 sites, all sites, or  not allocable.   For
             region specific contracts, all sites would be entered for site-support costs.

      D)    Description of Activity - enter the description of the non-site activity.  The
             description should provide  for a complete description of  the activity.

      E)    Amount of Activity - enter the  amount of the non-site  activity.

      F)    Amount to be Allocated This Annual Allocation Report  - Sum the non-site
             activities by Area of Applicability (C) and by Determination of Allocability
             (B). For site-support activities, enter the amount on Attachment A, Line 7,
             Column A and Column C.  For program-wide activities,  enter the  amount
             on Attachment A, Line 8, Column A and Column C.

       In the Attachment D example, there are examples of the two types of non-site
activities.  First, there is $55,000 of site-support costs.  These site-support costs are
further broken down into regional activities,  $25,000 of Region 1 site-support activity and
$30,000 of Region 2 site-support activity.  These amounts are entered onto Attachment
A, Line 7, Columns A and C, for each respective region. Second, there is a total of
$22,000 of program-wide activities and these costs are identified as not allocable. This
amount is entered onto Attachment A, Line  8, Columns A and C.

                                         22

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Step 9 - Non-Superfund Costs

      Certain Superfund response action contractors may perform efforts other than
Superfund activities.  These efforts are paid from other than the Superfund
appropriation. The annual allocation process deals with Superfund monies only. Do not
include non-Superfund monies in this annual allocation report.
                                        23

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Step 10 - Summary of Amounts

      Sum all of Attachment A, Column A and enter that total on Attachment A, Line
9, Column A.  This amount should equal the amount identified in Step 1. If it does not,
please re-check your figures.  In the Attachment A example, this amount equals
$270,000.

      Sum Attachment A, Column C and enter that total on Attachment A, line 9,
Column C. This is the universe of costs used in this  annual allocation period, including
site specific amounts, Pre-SSID amounts, and amounts eligible for allocation.  In the
Attachment A example, this amount equals $268,000

      With these  final entries, the annual allocation process can begm. The next four
steps provide  an illustration of the annual allocation  process  for each of the  allocable
costs:  program management, start-up costs, equipment, and site-support activities.
                                       24

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Step 11 - Allocation of Program Management Costs

      Program management costs are allocated to all sites with and without EPA SSIDs,
non-site activities, and other non-Superfund efforts.  The allocation should be based
upon a method which equitably reflects the benefits provided by the program
management.

      In this example, a modified cost base is used for the allocation of program
management costs. Also, two types of Program Management costs are included in this
example - National Program Management and Regional Program Management. All
contracts may not have both types of program management, but this instruction
document is designed for all types of contracts and may have examples or illustrations
which do not apply.

      Program management is allocated to the sites and activities based upon the
percentage of the particular site or activity's costs to the total cost of all sites and
activities.  Please note that equipment is not included in the allocation base. Generally,
equipment does not receive the same level of support that sites and other activities
receive. Because the support provided would not reflect the causal/beneficial
relationship, equipment is excluded.

      An example is provided below on the allocation to an EPA SSID site.  The
allocation to other sites and activities is performed in the  same manner.

      Program Management Allocation

      Formula:

                                    Site  or Activity
     Program  Management x	Amount	  _ Allocable
           Amount               Allocation  Cost  Base  ~    Share
      Allocation of Costs:
                      $25'°°°   *  $VoV,°oQo°o   *  $1'951
       In the example shown above, the Program Management amount of $25,000 is
 identified on Attachment A, Line 3, Column C.  This is trie amount to be allocated.
                                       25

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      The site or activity amount, in this example the SSID amount for the Picillo Site
(0101), equals S.6,000 - the amount shown in Attachment A, Line 1, Column C. This
amount includes the S 15,000 of site costs plus the $1,000 of pre-SSED costs reassigned to
the site in Step 3.

      The allocation cost base of $205,000 (the total shown in Column C of $268,000
less the $25,000 of Program Management Costs and the $38,000 of Equipment Costs)
represents the sites and activities which receive a portion of allocated program
management.  The allocable share of $1,951  is entered on Attachment A, Line 1,
Column D for this site.  Repeat this calculation for all other sites and activities. The
allocable  share for each site or activity is entered on Attachment A, Column D on the
corresponding line.  Enter a credit to the Program Management amount in the amount
of $25,000 on Attachment A, Line 3, Column D.

Allocation of Regional  Program Management Costs

      The allocation of regional program  management costs is similar to the allocation
of program management costs shown above,  except it is on a regional level.  The
regional program management costs are allocated to all sites and activities in that region.

      Regional Program Management Allocation

      Formula-

   Regional  Program    ..   Site  or   Activity  Amount   _  Allocable
   Management  Amount  A   Total  Regional  Cost Base  ~     Share
      Allocation of Costs:
                      $11'22°  *  $8^903   =  $2'459
      In the example shown above, the Region 1 Program Management amount of
$11,220 represents the sum of the Regional Program Management identified on
Attachment A, Line 4, Column C of $10,000 plus the $1,220 allocable share of Program
Management costs identified in Column D.
                                      26

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       The site or activity amount, in this case the SSID amount for the Picillo Site
(0101), equals $17,951.  The SSID amount includes the  $16,000 shown on Attachment A,
Column C plus the allocable share of Program Management costs of $1,951.

       The total regional cost base of $81,903 represents all sites and  activities in Region
1. This amount includes the total amount of site costs both with SSIDs  ($17,951 for
Picillo and S29.171 for Fletchers Paint Mill) and pre-SSIDs ($6,732) and the Region 1
site-support costs ($25,049), including any previous allocations of costs (Program
Management Costs).  If there were regional start-up costs, these amounts would also be
included in the total regional cost base.  In this example, start-up costs are considered
contract-wide costs.  Regional program management costs are allocated  to region-specific
costs only. From the calculation above, the allocable share for Site 0101 is $2,459 and is
entered on Attachment A, Line 1, Column E for this site. Repeat this calculation for all
other sites and activities.  The allocable share for each site or activity  is entered on
Attachment A, Column E on the  corresponding line.
                                         27

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Step 12 - Allocation of Start-up Costs

      The allocation of start-up costs proceeds in the same manner as program
management costs.  The start-up costs are allocated to all sites and activities which
receive a benefit from the start-up costs.

      In this example, start-up  costs are allocated to all sites and activities, excluding
equipment.  The contractor may be able to identify start-up costs to specific sites,
regions, equipment, or activities. If the contractor has kept records in such a manner,
the start-up costs should be allocated in accordance with the benefits provided by the
start-up costs.  The example below provides the basis for allocating the start-up costs to
all sites and activities, excluding equipment:

      Start-up Cost Allocation

      Formula:


      Start-up  Cost  x  Site  or  Activity  Amount  _  Allocable
          Amount              Allocation   Cost  Base    ~     Share
      Allocation of Costs:

      In the example shown above, the start-up cost amount of $5,610 represents the
sum of Columns C, D, and E, of Line 5 ($5,000, $610, and 0, respectively).  The site or
activity amount, in this example the SSID amount for the Picillo Site (0101), equals
$20,410 - the sum of the amounts shown in Columns C, D, and E, of Line 1 ($16,000,
$1,951, and $2,459, respectively). The Total Cost Base is $224390 which represents all
costs from Column C of $268,000 (because start-up costs are allocated to all sites and
activities, excluding equipment) less the start-up cost amount of $5,610 and equipment of
$38,000.  The allocable share of $510 for site 0101 is entered on Attachment A, Line 1,
Column F for this  site. Repeat this calculation for all other sites and activities. The
allocable share for all sites and activities is entered on Attachment A, Column F on the
corresponding line.
                                        28

-------
Step 13 - Allocation of Capital Equipment Costs

      Capital equipment costs are allocated to those sites and activities which receive a
beneQt from the equipment. The preferred method of allocating capital equipment costs
to sites and activities is on a direct usage basis; i.e., as capital equipment is used on each
site or activity, those costs are captured and identified with that specific site or activity.
This method would result in the most equitable cost accounting treatment  of capital
equipment costs.  However, other allocation procedures may be used if they provide  a
sound cost accounting treatment of capital equipment costs. The allocation of capital
equipment costs should be based upon a procedure which results in the equitable
allocation of costs and is based upon information from the  contractor's accounting
system.  For this example, the straight-line depreciation method is used.
      Capital Equipment Cost Allocation

      Formula:
    Capital  Equipment  ,.   Site  or  Activity Amount  _  Allocable
        Cost  Amount      *        Total  Cost  Base       ~     Share
      Allocation of Costs:


                      $38,000
       In the example shown above, the capital equipment cost amount of $38,000
 represents  the sum of the Capital Equipment line item, Columns C, D, E, and F
 (538,000, SO, SO, and SO, respectively, because capital equipment does not receive any
 allocations). The site or activity amount, in this example the SSID amount for the Picillo
 Site (0101), equals $20,920 • the sum of the amounts shown  in Columns C, D, E,  and F
 ($16,000, $1,951, $2,459, and $510, respectively). The Total  Cost Base amount equals
 $230,000 and represents all costs of $268,000 (because in this example capital equipment
 costs are allocated to all sites and activities) less the capital  equipment cost amount of
 $38,000. The allocable share of $3,456 for site 0101 is entered on Attachment  A, Line 1,
 Column G for this site.  Repeat this calculation for all other sites and activities.  The
 allocable share for all sites and activities is  entered on Attachment A, Column G on the
 corresponding line.

                                         29

-------
Step 14 - Allocation of Site-Support Costs

      Site-support costs represent those activities which support site response actions in
the aggregate, but by their nature cannot be accounted for on a site-specific basis. In
this example, all site-support costs are region specific costs. Site-support costs may also
be contract-wide costs, i.e., allocated to  all sites on the contract.  The allocation of site-
support  costs is shown below:

      Site-Support Cost Allocation

      Formula:

      Site  Support x     Regional  Site  Amount     _  Allocable
      Cost  Amount   *   Total  Regional  Cost  Base  ~     Share
      Allocation of Costs:


                      $38,089  X
                                    v ' «* i -L J U
      In the example shown above, the Region 1 site-support cost amount of $38,089
represents the sum of the Site-Support line item. Columns C, D, E, F, and G ($25,000,
S3.049, $3,842, $797, and $5,401 respectively).

      The Regional Site Amount, in this example the SSID amount for the Picillo Site,
0101, equals $24,376 - the sum of the amounts shown in Columns C, D, E, F, and G
($16,000, $1,951, $2,459, $510, and $3,456, respectively).

      The Total Regional Cost Amount is $73,130 and represents all Region 1 site costs
- sites with EPA SSIDs ($24,376 for Picillo and $39,613 for Fletchers Paint Mill) and
Pre-SSID costs ($9,141), including any allocations incorporated in Columns D, E, F, and
G. The allocable share of $12,696 for site  0101 is entered on Attachment A, Line  1,
Column H for this site.  Repeat this calculation for all Region 1 sites and activities. The
allocable share for other sites is entered on Attachment A, Column H on the
corresponding line. Repeat these same calculations for Region 2 until all site-support
costs are allocated to sites.
                                        30

-------
Step 15 - Completion of Master Allocation Schedule

      The purpose of this step is to complete Attachment A, Master Allocation
Schedule by summarizing the allocation. Attachment A is completed by adding the
amounts entered in Columns D, E, F, G, "nd H for each site and activity and entering
the sum in Column I.  These amounts represent each site's and activity's total share of
allocated costs.  The Column I site totals are then forwarded to the Summary Allocation
Schedule.

      All amounts shown on Attachment A, Master Allocation Schedule, are whole
dollars.  EPA prefers the amounts shown in this format.  Because the amounts are shown
in whole dollars and there are numerous calculations, some rounding differences will
occur.  The rounding difference can be shown as a separate line item, or, as in this
example, is simply incorporated into the schedule.
                                        31

-------
Step 16 - Summary of Allocated Amounts

      The purpose of this step is to summarize the amounts allocated to site response
effort (Sites with EPA SSIDs and Pre-SSID Costs) on the Summary of Allocation. The
allocated amounts represent the entries in Columns D through H on the Master
Allocation Schedule.

      The Summary of Allocation should be completed as follows:

1)    Identify sites by region

      •     SSID - the unique site/spill identifier number consisting of a two-digit
            region code  (representing EPA regions 01 - 10), and a two-digit site/spill
            number which is assigned by EPA.
      •     Site Name - the first twelve letters of the site name as it appears on EPA's
            SSID list.
      •     State - the two-letter State abbreviation.

2)    Within the region, list the Sites with EPA SSIDs - numbers first, then letters

3)    After the identification of the Sites with EPA SSIDs, enter the Pre-SSID 'ZZ' line
      item

4)    Enter the  summary amount of allocated dollars by site from Column I on the
      Master Allocation Schedule onto the Summary of Allocation

      The contractor shall submit the Summary of Allocation report on a 5 !/« inch or a
3 V* inch DOS computer disk in a Lotus 1-2-3 or ASCII format. The Allocation Schedule
should be triple spaced. Two hard copies of the report should accompany the diskette
submission.
                                       32

-------
         SECTION m

        EXAMPLES OF
ANNUAL ALLOCATION SCHEDULES
             33

-------
                                                Summary of Allocation
                                                   Fiscal Year 1989
                                                    Clean-up, Inc.
                                                Contract No. 68-01-xxxx
Description
Amount
Allocated DCN
Account
Numl>cr
To
Account
Number
From
Allocalion tp Sites with EPA SSIPs
SSID Site Name Slate
   0101 P1CILLOFARM
   01A2 FLETCHERS PAJ
Rl
Nil
21,073     |  TO  BE  COMPLETED BY  EPA |
34.245
   02B3 CALDWELLTRUC
NJ
39.430
   02C4 SAYREVILLELD
NJ
26,286
SITES WITH SSID SUBTOTAL
Allocalion lo Pre-SSID Sites
           121,034
   01ZZ
   02ZZ
SITES WITH SSID SUBTOTAL
TOTAL ALLOCATED TO SITES
             7,902

             3,584
            11.4K6
           132,520

-------
CJ
en
                                                                                      Master Allocation Schedule
                                                                                           l-ucal Year 1989
                                                                                            ("lean-up, Inc.
                                                                                        Contract No. 68-OI-uux
                                                                                                                                                                       Attachment A




1






2




3
4


5
6
7


8
•/Column


Dcicriplion
Sites with EPA SSI IX
SSID Site N«mc
oioi PICIU.O FARM
01A2 FLETCklERS PAI
02B3 CALDWELLTRUC
02C4 SAYREVILLELD
SITES WITH SSID SUBTOTAL
Situ without EPA SSID*
OIZZ
02ZZ
SITES WITHOUT SSID SUBTOTAL

SITE TOTAL
Program Management
Regional Program Management
Region 1
Region!
Sun-up Costs
EquipcDcol
Silt-Support CotU
Region 1
Region 2
Program Widc-Aciivilicc
A 11

Amount Pre-SSIl)
ft lit Adiuitmcnu

SUit
R| 15.000 1.000
NH 25.000 1.000
NJ 33.000
NJ 22,000
95,000 2,000

8.000 -2.0UU
3,000
11,000 -2,000

106,000 0
25.000

10.000
7,000
0
45,000

25,000
30,000
22.000
<:

Allocation
Amounts


16,000
26.000
33.000
22,000
97,000

6,000
3,000
9,000

106.000
25.000

10,000
7,000
5.000
38.000

25.000
30.000
22.000
D

Program
Mananement


1.951
3.171
4.024
2,683
11,829

732
366
1,098

12,927
-25.000

1,220
854
610


3,049
3.659
2,683
|j

Regional Program
Management


2,459
3,9%
2,945
1,963
11,364

922
268
1,190

12,553


-11.220
-7,854



3,842
2,677

F
Allocation of
Start-up
Costs


510
829
999
666
3,005

191
91
282

3,287




-5.610


797
908
617
(i

Equipment
Costs


3.456
5,617
6.769
4,513
20,355

1.2%
615
1,911

22.266





-38.000

5.401
6,153
4.180
II

Site-Support
(t*!!,


12.6%
20.632
24.692
16,461
74,481

4.761
2,245
7,006

81,487







-38.089
-43.398

1
Total
Allocated
Amounts


21.073
34 .MS
39,430
26.2H6
121,033

7.9U2
3,584
11,487

132,520
0

0
0
0
0

0
()
7,4«0
        9 TOTAL
270.000
268,000
                                                                                                                                                                            I40.1MKI

-------
                                                              Attachment B
B
                    Schedule of Start-up Costs
                         Fiscal Year  1989
                          Clean-up. Inc.
                     Contract No. 68-Ql-xxxx
FY Incurred
FY 1987
FY 1988
FY 1989


Start-up Costs
$25,000
-0-
-0-


Number of Years
Allocated
5
0
0


Amount
Amortized Each
Year
$5,000
-0-
-0-


          Total Amount to be Allocated
          This Annual Allocation Report
$5,000
                                                 Enter this amount on Attachment A.
                                                 Line 5, Column C
                                36

-------
                             Schedule of Capital Equipment Depreciation
                                          Fiscal Year 1989
                            —*            Clean-up. Inc.
                                       Contract No. 68-01-xxxx
                                                                                              Attachment C
B
                                    D
                       H
Date Charged
to Contract
January 1987
October 1987
November 1988
Capital
Equipment
Gas
Chromatograph
Mobile Lab
Tractor
Purchase
Price
$80,000
49,000
45,000
Useful Life
5 years
7 years
3 years
Beginning
Balance
$48,000
42,000
45,000
Depreciation
Amount
$ 16,000
7,000
15,000
Ending
Balance
$32,000
35,000
30,000
                                         Total Amount to be Allocated
                                         This Annual Allocation Report
   $38,000
                                                        I
Enter this amount on Attachment A. Line 6,
Column C

-------
                                                    Schedule of Non-Site Activilies
                                                           Fiscal  Year 1989
                                                             Clean-up. Inc.
                                                        Contract No. 68-OI-xxxx
                                                                                                                   Attachment D
              B
                                                                             D
                      E
Determination
of Allocabiliry
Site-Support

Site-Support
Site-Support

Program- Wide
Program-Wide

Area of
Applicability
Region 1 Sites

Region 2 Sites
Region 2 Sites

Not Allocable
Not Allocable

Description of Activity
Worker safety training for regional personnel
SUBTOTAL REGION 1 SITES
Worker safety training for regional personnel
NPL Training
SUBTOTAL REGION 2 SITES
Training of First Responders
Review State Agency Safety Requirements
SUBTOTAL NOT ALLOCABLE
Amount of H
Activity 1
$ 25,000
$25,000
28,000
2,000
$30,000
•••••M^MB
10,000
12.000
$22,000
CJ
09
                                                        Total Amount to be Allocated This Annual
                                                                      Allocation Report
                     $55,000
                                                      linlcr I he Site-Support or Program-Wide amounts on:
Attachment A, I me 7, ( olumn (.' or
Attachment A, Ijnc H, (k>lunm (', a*

-------
            Attachment I
Sample Site-Specific Invoice Attachment

-------
4TRACTOR NAME ABC. INC
4TRACT 6101 1234
                                          SIH'I HhUNO Sill- SPECIHC INVOICE ATTACHMENT  HLUION I
                                                                •» oi 05/25/90
INVUICh NUMBI.M 6V
HUN DATE
ACCOUNT ACCOUNT
TRANS UOCUMEN BLIOATIN NUMBER NUMBER
srrE ACTION CONTROL OCUMEN TO BE OF INITIAL CLASS
10 NO SITE NAME SFO DATE CODE i/C 1 NUMBER NUMBER HAROED OBLIGATION CODE
TS FOR SITES WITH EPA S/S ID
41 FORESTDALE
n OAKLAND AVENUE
»3 NOWELL STREET
M RUSSELL AVENUE
H6 INDUST BOX LUMBER
HI OREEN STREET
HI VAN BUREN MADA
H9 MACNA1R
12 TURCHIN PREP
11 ACTION LAND MGMT
SUBTOTAL
TS FOR SITES W/O SS ID
ZZ SITES W/O SS ID
SUBTOTAL:
TOTAL INVOICB AMOUNT
BRIEFINO/PER 10
CONTAINERS
SSI COMPUTER
SSI PLANNU40/IO
^ FIT TRA1NINO

TOTAL REOION
BASE HE
AWARD Hi
101 Al. H:tJ

FBOIM 6141 1234 OTFA72IM* OTFA72F700 25)5
FBOIM 6141 12)4 OTFA72II92 OTFAT2F700 25)5
FBOIM 614)1 1234 OTFA72II93 OTFA72F700 2S15
FBOIM 614)1 1234 OTFA72IJ94 OTFA72F700 2S15
FBOIM 614)1 1234 OTFA72IIH6 OTFA72F700 2SJS
FBOIM a 01 1234 OTFA72IJH7 OTFA72F700 2M5
FBOIM 614)1 1234 OTFA72IIHI OTFA72F700 25)S
FBOIM 614)1 1234 OTFA72IIH9 OTFA72F700 2SJS
FBOIM 614)1 1234 OTFA72III2 OTFA72F700 2SJS
FBOIM 614)1 1234 OTFA72III3 OTFA72F700 263)


FBOIM 614)1 1234 OTFA72IIZZ OTFA72F700 2J3i


253S
2J3S
25JJ
253S
2535

/
25)S
2535

THtASUMY
CUKHLNT SCHEDULE
AMOUNT NUMBER

6S7 16
76)55
3)762
61 70
9)9 15
SS5747
:!SI6 19
77227
•5072
2190 10
"1 227<72S

25)29 05
2532905
37605.30
•1673
17104
762 U
661522
••5762
1722349
5412179
•46(44
000
MU44
INVOICt (UMUI AllVb
NIIMBIR AMOUNT

•219 61
2372 87
I33172
6170
939 15
555747
3639 IS
77227
219)1 5)
2190 10
47106 57

)62I)5 75
362135 75
409942 32
3)2« 14
5>73 21
IM709
24)22 76
42)91 21
77*02 41
417744 *0
Jt43«V 1)
4MII700
11)416 15
f/U- INVOICL AMi
                                                                                                      6)297 2)
                                                                                                                                     1)71230

-------
           Attachment J





Elements of Superfund Account Numbers

-------
              CONVERSION OF SUPERFUND ACCOUNT NUMBER
                  FROM GENERIC TO SITE-SPECIFIC
GENERIC ACCOUNT NUMBER:
               0
TFA
 01  I  JZZ
                     TV*
                            •I
                                    AC
                                          *•
                                       . 1

                                       n

                                       I
SITE-SPECIFIC ACCOUNT NUMBER:
               0
TFA
O/  1TV5

-------
             Attachment K





Flowchart:  Processing Superfund Invoices

-------
       EPA
                                                ATTACHMENT
                                 CAPTURING SITE-SPECIFIC COSTS IN THE
                        INTEGRATED FINANCIAL MANAGEMENT SYSTEM (IFMS)
  Assign Site/Spill
     Identifiers
                                     Process lor payment
                                     Update II MS lor payments
                                                       II MS (hi., lor
t
Contractor
Original Invoice including Sunerfund
Site Specific Invoice Aitachmeni "~
and site costs
NCPD
(RIP)
^—

cost document
IMD
Invoice includes
breakout of:
• Cost by S/S
 ID Number
 lor redistribution
• Total site costs
 to /Z account
 (where no S/S
  ID exists)
• Non-site costs
 (perlusk)
• PM costs, fees
\
 Advance Copy
   of Invoice
 OngiD.il Invoice
plus Project Officer
  Approval l;i
       EPA Regional
       Projecl Office
      • Route invoice for
       WAM review
I-PA Regional
Project Officer
   Review
                  1 Review costs and
                   expenditure rales
                   for appropriateness
                      WAM
                     Review
                               EPA Regional
                               Project Officer
                                 Approval
                                                    Review invoice for
                                                    reasonableness of costs
                                                    • Evaluate costs
                                                    - SAM/RPM input on
                                                     appropriateness of hours
                                                     for task
                                                financial/accounting
                                                review for final approval,
                                                including:
                                                • Identify DCN
                                                • Create new site
                                                 account numlxrrs
                                                • Verily accuracy of site
                                                 specific accounts and
                                                 charges
                                                                            KEY:
                                                                            DCN - Document Control Nuinlxrr
                                                                            EMI) - Einancia! Management Division
                                                                            NCPD -  National Contracts Payment Division
                                                                            RTP  Research Triangle Park

-------
                 Attachment L





Flowchart:  Process for Assigning S/S ID Numbers

-------
                                                       ATTACHMENT
                                    SITE/SPILL IDENTIFIER ASSIGNMENT PROCESS
                     Region
                                                     I    I
                                                                I leadquancrs
       Site
     Managers
Forms
1 Initiate request for
 creation of S/S ID
> Determine site name
 (Consult both CERCLIS
 and II MS)

• If a removal proceeds
 a PA or SI, a S/S ID
  could exist
• Site managers must
 verify consistency of
 both S/S ID and CERCLIS
 site name; if consistent,
 no action is required
    Regional
   Accounting
     Office
(Budget Division)
Prior Year
                              Requests
          1 Assign account numbers
          > Set up new accounts in
           II-MS
          1 Call in entries for prior
           year activities
Stiperlund Accounting
     IIQ  FMD
 (Snp|)ori Contractor)
 Financial Reports &
   Analysis Branch
Updated Master
                                  List of S/S ID
                                     Fntrics
                               • Manage II MS
                               • Call Regions with inquiries
                               • Enter account numbers
                                and obligations into IFMS
                                for prior year accounts and
                                for HQs
  Si.,)crUuul (OI'M)
Funds Control Center
1'iograin Development
   & liudget Stall
                                                • Make new entries into
                                                 S/S ID data base
                                                • Distribute sue lists on a
                                                 monthly/quarterly basis
                                                 to EPA Regional contacts
                                                 and contractors
                                                • Refer list inquiries to
                                                 Regional contacts

-------
             Attachment M





Sample Summary of All Site Specific Costs

-------
  NUS
                    *1 *V I
                    Psj
August 13, 1991

•Vir Tim Forta^e
F!~ Pro;ect Officer
Hazardous Site Evaluation Division
U.S. Environmental Protection Agency
Room 2635
401 VI Street. 5.W.
Wasr-rgton, D.C. 20^60

Subject:     Revised S/S ID and ZZ Account Reconciliation Oraf- Resort
'En-rosed -s  revved G'aft version 3.1  of :.-e reciSf b-t'on  o; costs  for S'tei v,-->.h and w.tn.out S/S  10
n-j — oers. T'--,s  '.ers;on has been revised <~ accc'dance with your  specifications.  Because of -data
o-'ocessi'-g costs, only cost data  for :-e ;i's; f,-«e vouche-'s have oee'n used.  S/S 10 and Site description.
ca:a are also mcoTplete for the sa.Tie reason A br:e; -description of the draft report :s as follows:
      Ve--sion 3 '      The primary sorL 15 by region; a secondary sort is on site description, state, a^:
                      S/S 10 or ZZ account "umber; subsequent sorts are  on TOO nurnoer  an-
                      activity.  Each record  a'so includes the voucher number and the totai  costs ;?'
                      the voucher nun-be1'  A subtotal of the costs appears for each. Site cescr p: o"
                      and for each reg;o", j:ong with a grand totai of a-ll costs.
31 ease don'; -e sit ate to call me with any questions or comments regarding the draft report.  I -.v:i also
attemot to make any further changes you fee1 necessary.  We will advise you  of the feas:bi:'ty an~
costs associated with any further modifications

Very truly yours,
iV'S Vanager

CC:  Paul C'ay, Z?M

-------
                                           DKAII  -  VtKSION  3. 1
                                            HI IMSIKIBU1 ION  01
                             COSTS FOR SIUS WITH AND  WITHOUT  S/S ID NUMBERS
CON IKAC 1 Oh NAME: NUS CORPORATION
CONTRACI NUMBER: 68-01-73*46
REPORTING DATE: 06/13/91
PAGl  NUMBER:
VOUCHER
REGION SITE DESCRIPTION STATE SSIL) TDD NUMBlh AC 1 NUMBLR
FIT 1 FLETCHERS PAINT WORKS, MILL ST. MILTORD NH 1A2 f 1861132 SI 1
2
3
«
FORE RIVER TRANS. PARK ME 22 11870326 PA 5
FRENETTE DRIVE AREA NH 22 F 1870335 PA 5
FT DEVENS SUDBURY TRC ANNEX MAD980520670 MA IF 2 F 186 1107 SI 1
2
3
14
5
(1861138 SS 1
2
3
14
*
CALARY PROPERTY MA 22 F 186 1121 HR 1
2
3
*
GALLUPS QUARRY, PLAINFlELD CT 1B7 F 1861 109 SI 1
2
3
14
5
*
GENERAL ELECTRIC, CLARENDON VT 22 F 1870137 PA *4
5
*
GRACE PROPERTY ASSOCIATES NH 22 F 1861209 SS 2
3
*4
5
( 1U70336 PA 5
TOIAl. COSTS
5*48.96
1,056.33
»4l6.81
2,022.10
306.02
9 . 62
*437 .87
296.55
171 .8*4
527.99
36.*42
*t!9.59
362. 17
190.02
67*4.73
3,117.18
27.*49
77.32
712.68
817. *49
1,380.66
2,55*4.92
1 , 169.08
617.75
738.13
6,*460.5*4
*487.21
255.82
7*43.03
3*49.82
1,391.71
1 ,*465. 13
8*49.86
57 .014

-------
                                           OKA! I  -  VERSION 3.1
                                             Kl I) IS IK I BUI ION 01
                             COSIS fOR SITES WIIH AND WITHOUI  S/S IU NUMBERS
CON1RACIOK NAME:  NUS CORPORA!ION
CON1RACT NUMBER:  68-01-73*46
REPORTING DATE: 08/13/91
PAGl  NUMBER:
VOUCHl K
REGION SITE DESCRIPTION STATE SSIO 100 NUMBER AC 1 NUMBER
«
FIT 1 GRACELAWN LANDFILL ME ZZ 1 1861117 SI 1
2
3
(4
5
*
GRODEL MFC. INC. CT 22 f 1870 116 PA 3
14
5
*
HAMPSHIRE PAPER COMPANY NH 22 f 186 11 33 SI 2
3
14
*
HINRY LEAIHER MA 22 f 1870302 PA 5
HICCANUM MFG. CO. CT 22 f 186 1 1 18 S 1 1
2
3
«4
5
«
HICHMOOR FARM ME 22 f 186 1205 PA 2
3
<4
•
HOLT ON CIRCLE, LONDONDERRY Nil 1A*4 F 18701 31 El 3
>4
5
«
HOMIIOWN PROPERTIES K 1 ZZ 110/0207 PA *4
b
1 OT Al. COS T S

•4.113.
l40^>.
1 ,220.
877.
525>.
658.
3,68t).
89.
390.
220.
700.
27.
1 ,1 1«4.
85.
1,227.
33»4.
93.
18»4.
610.
3,107.
1,267.
5,263.
258.
321
123.
703.
46.
2148.
762.
1 ,057.
2H3 .
«407 .

56
59
15
1 1
08
05
98
30
85
75
90
83
08
91
82
11
»48
86
3*4
62
l>ti
78
83
1<4
8*4
81
73
1 1
7«4
58
56
99

-------
                                           DKAK1 - VIRSION 3.1
                                            HIUISIHIBUIION OF
                             cosrs FOK SITES WITH AND WIIHOUI s/s ID NUMBERS
CON IHACIOH NAME: NUS CORPORATION
CON1RAC1 NUMBER: 68-01-73*46
REPORTING DATE: 08/13/91
REGION
          SITE DESCRIPTION
                                                                                   VOUCHER
                                                    SKATE  SSID  TOD NUMBER  ACT   NUMBER
PAGl NUMblH:     9


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*
FIT 1 HUBBARD HALL CHEM. INC. CT ZZ M870117 PA 3
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F 18703147 PA 5
*
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5
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JOHNSON AND DIX VI ZZ ( 1870330 PA 5
JOHNSON CONIROLS VT ZZ F 1861123 MR 1
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JUDGE DEVELOPMENT VT ZZ F 1870331 PA 5
KALADISH WASTE DISP. CT ZZ F 1870109 SI 3
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KALART VICTOR CORPORATION CT ZZ F 1861 131 HR 1
KEEFE ENVIRONMENTAL, EPPINC NH 106 F 1861 11*2 SS 1
2
3
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50.86
101.72
1141.58
239.50
381.08
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8.59
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579.03
871.82
310.148
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                                                           //
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          Attachment M

Site Assessment Training Program
      for Fiscal Year 1992

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                          SE?  • 5 i99!
MEMORANDUM    .                                    ..-.•.---•-.:

SUBJECT:  Site Assessment Training Program

FROM:     Janet Grubbs, Acting Chief
          Site Assessment Branch

TO:       Site Assessment Section Chiefs
          Regions I - X


Purpose

     The purpose of this memo is to  transmit our proposed training
schedule for  FY92 and to request names of participants  for  train-
the-trainer courses that will be developed for HRS and PA&SI  and to
verify the Regional Training  Coordinators.

Background

     As discussed at the last Section Chief's meeting,  we want  to
finalize the schedule for the  FY92 Site Assessment Training Program
and  meet  the  demands  for  HRS  and  PA&SI  training.   The  survey
results distributed at  the  meeting  show a large number of  people
needing both HRS and PA&SI training.  Without your help we will not
be able to  train everyone who needs training.   In order to meet
these  demands,  all  of you  supported development  of  train-the-
trainer courses  and  providing Regional support for HRS and PA&SI
training.

     The  attached   proposed  schedule  involves   the  following
assumptions:  1) Supplementing the FY92 schedule with  the offering
of both  HRS and PA&SI  train-the-trainer  courses.   These courses
will be  scheduled in the first quarter of  the  fiscal year.  The
individuals  you select  for  the train-the-trainer  sessions will
eventually  provide  HRS and  PA&SI   training to  site  assessment
personnel  that  did  not attend  any  of  the  scheduled sessions.
Please  keep  in mind  that  preparation for  presenting a training
course requires  time  and commitment.  2)   Coordinating logistics
with SAB  for both courses.    This will include  room arrangements,
copying training materials and coordinating registration.  We will
provide appropriate  specifications  and contractor  support  to the
Regional Training Coordinator.  3)   Having Regional staff serve  as
the  EPA  representative at  the appropriate course offerings.  EPA
representation  is required  at  all  site  assessment training and
Headquarter  staff will not be able to attend all course offerings.

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                               -2-

Therefore, senior Regional staff will attend the courses, give an
introduction,  and  answer  policy  questions.    We will  provide
materials and support to these individuals.

     As we agreed at the Section Chief meeting,  the  October session
of the HRS course will be open to all Regions and  you need to set
priorities  for  who  needs  training  for  that  session.    We  have
allocated 5 spaces to each Region.   If you  do not fill any of your
5  spaces,  we  will open  these slots up  to  the  Regions  within
geographical proximity  of the  training  location.    The attached
schedule designates Regions to  the  session we  have delineated to
be within their geographic proximity.  Registration  procedures will
follow as soon as we receive the names.

     Additionally,  we will  hold the  one day training  seminar on
PREScore  in every  Regional office  beginning   in  October.    Art
Johnson is working with your staff on this schedule.

     We will continue to update you regarding availability of the
OERR Work Assignment Manager training.   At this time,  the Office
of Program  Management who  offer  this training does not have  a
schedule, but will notify us of the next course offering.

Implementation

     Before we finalize the FY92 schedule,  we request you fill out
the attached form.  The form requests the names of your staff who
will participate in the train-the trainer course; the names and/or
affiliation  of  the trainees for the October session of  the HRS
course, the status of your Regional Training Coordinator; and any
comments you have on the FY92 HRS and PA&SI training schedule.

     For  your  information,  attached is  a list  of the  current
Regional Training  Coordinators.  Please  indicate on the form any
changes to  that  list.   The Regional Training Coordinator will be
the  contact  for   schedules  and  logistical  support  for  site
assessment training.

     Please send or FAX your forms to Tina Maragousis by September
30.   The FAX number is FTS-260-0854.  Your prompt response will
enable us to finalize  and make appropriate arrangements for FY92
training.

     If you have any questions, please do not hesitate to contact
Tina at FTS-260-7393.
Attachments

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FY92 SCHEDULES FOR HRS AND PA&SI TRAINING
 FY92 QUARTERLY SCHEDULEFQR HRS TrainineCourse
Session
1
2
3
4
Date
October 28-31
mid January
mid April
mid July
Location
Washington, DC
Dallas, TX
Kansas City, KS
Seattle, WA
Regions with
Geographical
Preference
1,2,3
4,6
5,7, 8
9, 10

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            FY92 SCHEDULE FORJ>A&SI Training Course
SESSION
1
2
3
4
5
6
7
8
9
10
DATE *










LOCATION
Dallas, TX
Boston, MA
New York, NY
Chicago, IL
Atlanta, GA
Kansas City, KS
Philadelphia, PA
Denver, CO
San Francisco, CA
Seattle, WA
REGION
6
1
2
5
4
7
3
8
9
10
* See your Regional  training coordinator for a final schedule.

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                 SITE ASSESSMENT
     LIST OF REGIONAL TRAINING COORDINATORS
Region    Coordinator    Telephone It
         Nancy Smith   FTS-833-1697
         Ben Conetta    FTS-264-6696
         Peter Ucker    FTS-264-6324
         Jim McCreary  FTS-597-1105
         Dorothy
         Rayfield       FTS-257-5065
         Bill Messenger  FTS-353-1057
         Rita Gardner    FTS-886-2440
 6       Ladonna Walker FTS-255-6740


 7       Karen Flounroy FTS-276-7782


 8       Greg Oberly    FTS-330-7598


 9       Lisa Nelson    F"S-484-2347
  10      David Bennett  FTS-399-2103
          Monica Rolluda FTS-399-2136

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                         Site Assessment Training Form
I.     Name:
           Site Assessment Section Chief, Region	
II.
      Participants for the MRS                        Participants for the PA&SI
      Train-the-Trainer Course:                       Train-the-Trainer Course:
III.   Participants for the HRS Training Course on 10/28-10/31 in Washington. D.C.

             Name. Affiliation (i.e. ARCS. State. EPA). Address, and Telephone it


      1.     	

      2.     	;	

      3.     	,	

      4.     	

      5.     	'	
IV.   The Regional Training Coordinator for FY92 will remain the same?
      	yes  	no  	Name of new coordinators)
V.     Comments:

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              -UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON. D.C. 20460
                              .331
MEMORANDUM
                            /
SUBJECT:  PR'Escore  status  and  Draining  Schedule

FROM:     Janet Grubbs,  Acting Chief
          Site Assessment  Branch  (OS-230)

TO:       Site Assessment  Section Chiefs
          Regions I  -  X

The  purpose  of  this memorandum is to inform everybody as to  the
current status of PREscore and to transmit  the recently  finalized
PREscore  training  schedule.    PREscore  is  almost  ready  to  be
distributed.  Testing  of the algorithm  was  completed July  31,  and
since then efforts  have focussed  on  finalizing the Help Screens,
the Users Manual and the print function.  The Help Screens  and the
Users Manual  have  been completed.  Unfortunately, finalizing  the
print  function  has taken longer than  originally  anticipated.
However, the  developer is  currently making  the final revisions to
the  PREscore  printout  and  the  complete  software package  (PREscore
and  PREprint programs and the Users Manual)  is  scheduled to  be
delivered to  EPA HQ September  30.

Art  Johnson   of my  staff  has  been coordinating  with  all  of  the
Regional Computer Contacts to compile Regional distribution lists.
PREscore software will be distributed to site assessment  personnel
identified on the  Regional  lists as soon  as possible after  the
final version is  received at HQ.    In addition, we have  scheduled
one-day  PREscore  training  sessions  in  each Region beginning  the
first week of October  (See the attached schedule)  . The purpose of
these  training sessions is  to provide sits  assessment  personnel
with a hands-on introduction to the functions and capabilities of
PREscore.   Ws have  intentionally limited the number  of training
participants for  each  session  to  approximately 20 so that  each of
the  participants  can  have  access to  a computer  work  station  for
working  through the PREscore  program (it is expected that  there
will be  two  persons per work station).

Each  training  session  will  include   a   general   introduce;on
presenting  a brief  history of PREscore  development,  its  general
structure and format, and discussion of  the specific functions cr.at

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PREscore performs to assist the scorer (e.g.,  lookup of  substance-
specific factors  and numerous table  values).   Participants will
then be instructed in the specific keystrokes necessary for gaining
access to  the program and  for moving through  the many screens.
Participants will also be instructed in the recommended methodology
for organizing and  entering  data.   The remainder of  the training
session  will involve actually working  through some source and
pathway  evaluations in  which  the  participants will  be asked to
enter site data  into PREscore to calculate  scores.   During this
portion of the training the  instructor will circulate around room
providing assistance and guidance where necessary.

The training  sessions are  scheduled  to start at 9:30 in order to
allow the  instructor time  to load the software  onto each  of the
work stations.  There will be  a  one-hour break for lunch and the
training will be concluded  at 5:00.   Please contact Art Johnson at
FTS-260-9749, if you have any questions or comments.


Attachment

cc:  Agnes Ortiz, HQ
     Nancy Smith, Region I
     Ben Conetta, Region II
     Jim McCreary, Region III
     Craig Benedict, Region  IV
     Jeanne Griffin, Region V
     Bartolome Canellas,  Region VI
     Karla Asberry, Region VII
     Luke Chavez, Region VIII
     Lisa Nelson, Region IX
     Dave Bennett, Region X

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                   PREscore Training Schedule
Date
        •*
October^ (Wed.)
October >£(Thurs.)

October 7 (Mon.)
October 9 (Wed.)
October 10 (Thurs.)

October 15 (Tues.)
October 16 (Wed.)
October 16 (Wed.)
October 17 (Thurs.)
October 18 (Fri.)
Region

Region III
Region IV

Region V
Region VI
Region VII

Region VIII
Region X'
Region II"
Region I
Region IX
Instructor

Ross Peebles (Halliburton NUS)
Ross Peebles

Art Johnson/Ross Peebles
Ross Peebles
Ross Peebles

Ross Peebles
Ross Peebles
Art Johnson
Art Johnson
Ross Peebles
' Half day training session due to availability of computer facilities.
" Tentative date subject to change.
                                        USEPA  West MMng
                                       ^f*0*=&***' .—A	 "»•
                                                            ..
                                   fcoorn 3340 - Maifcode 3404?
                                      Washington, DC 20004

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