United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
EPA
DIRECTIVE NUMBER:
9242.6-09
TITLE:
Long Term Contracting Strategy for Superfund • Implementation
Framework
APPROVAL DATE:
EFFECTIVE DATE:
-07/ia/Mr
ORIGINATING OFFICE:
E FINAL
D DRAFT
LEVEL OF DRAFT
Q A — Signed by AA or DAA
n B — Signed by Office Director
Q C — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
DIRECTIVE DIRECTIVE
-------
I 9i9iC9 cnvironmcfliai rro*6clion t
Washington. DC 20460
OSWER Directive Initiation Request
Directive Numoer
9242.6-09
2. Originator Information
Name of Conuct P«*on
Superfund Document Coordinator
Mail Code
OS-245
Office
OERR
Telephone Code
(202) 260-9760
37Title
. Long Term Contracting Strategy for Superfund - Implementation Framework
4. Summary of Directive (include bnel statement of purpose)
This document reflects the consensus of the Long-Term Contracting Strategy Task Force. The strategy details the
portfolio of contracts to be used by the Superfund program over the next 10 years. The document outlines the
approach and time frame for implementation.
5. Keywords
Th£
he approach and timeframe for implementation
6«. Does This Directive Supersede Previous uirecttve(S)?
b Ones it Supplement Previous Oirective(s)?
No
No
Yes What directive (number, title)
Yes ' What directive (number, title)
7 Draft Level
A - Signed by AA/OAA I I 8 - Signed by Office Director
C - For Review & Comment
D - in Development
8.
Document
to
be distributed
to
States by Headquarters? Q Yw
No
This Request M««ta OSWER Directives System Format Standards.
9. Signature of Lead Office Directs Coordinator
^^7^^^^^-
10. Name and Title ol Approving Official j /
Henry L. Longest 11, Director/ Office of Emergency and Remedial Response
Date
FEB 2 A 19S
Date
07/12/91
2
EPA Form 1315-17 (Rev. S-«T) Previous editions are obsolete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE^
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
DEC I I33u
OSWER Directive 9242.6-09
MEMORANDUM
SUBJECT:
FROM:
TO:
Long-Term Contracting Strategy for Superfund—
Implementation Framework
Henry L. Longest II, Director
Office of Emergency and Reinedia
/fferuce M. Diamond, Director
^ Office of Waste Programs Enforcement
David J. O'Connor, Director _
Procurement and Contracts Management Di
Don R. Clay
Assistant Administrator for Solid Waste
and Emergency Response
Charles L. Grizzle
Assistant Administrator for Administration
and Resoures Management
sion
Purpose: We have attached the final Long-Term Contracting
Strategy for Superfund Implementation Framework. This document
reflects the consensus of the Long-Term Contracting Strategy Task
Force.
Backgrounds The final Long-Term Contracting Strategy was
issued on September 9, 1990. The strategy details the portfolio
of contracts to be used by the Superfund program over the next
10 years. The second important phase of the strategy is
implementation. The attached document outlines the approach and
timeframes for implementation. The Task Force anticipates that
this approach will ensure an orderly transition to a decentral-
ized contracting system without program disruption.
The implementation phase entails full planning for the
phase-in of new contracts and monitoring the award and adminis-
tration of these contracts. Several broad categories of issues
were identified by the Task Force which will require extensive
cross-programmatic and cross-organizational coordination. These
issues are discussed in the attached document.
-------
A result of the Task Force recommendations was the
development of a structure consisting of three groups with
distinct roles and responsibilities. These three groups will
constitute the framework to manage and coordinate implementation
efforts. The first group, the Advisory Committee, will coor-
dinate and oversee overall implementation. The second group, the
Designated Leads, will plan and oversee Regional administration
of each strategy component. The third group, Regional Liaisons.
will serve as the points of contact in each Region to facilitate
implementation across Regional organizations. (A more detailed
discussion of the roles and responsibilities of the three groups
is contained in the attached paper.)
Objective: The implementation framework has been developed
to ease the process of phasing-in the new contracting programs
without disruption of Superfund activities.
Implementation: The framework will provide the structure
for implementation and problem resolution of the Long-Term
Contracting Strategy as the new programs are initiated over the
next 5 years. Immediate actions are occurring to integrate site
assessment activities into the interim use of the Alternative
Remedial Contracting Strategy contracts and to integrate rapid
remedial responses with time-critical removal activities.
Attachment
cc: Elaine Stanley, OWPE
Clem Rastatter, 0PM
Larry Reed, HSED
Paul Nadeau, HSCD
Stephen Luftig, ERD
Mark Walker, PCMD
Long-Term Contracting Strategy Task Force
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OSWER Directive 9242.6-09
IMPLEMENTATION FRAMEWORK FOR LONG-TERM CONTRACTING STRATEGY
FOR
SUPERFUND
I. Introduction
The Agency developed the Superfund Long-Term Contracting Strategy to design
a portfolio of contracts to m*et the needs of the program over the next decade. In
analyzing those needs, several issues were highlighted. Among them were the needs for
the following: program integration, streamlining project management by minimizing
contractor handoffs, flexibility in responding to changing program priorities and budgets
and enhanced competition. The Superfund program has 102 contracts supplemented by
the Contract Laboratory Program. The current contracting program is a mixture of
Headquarters and Regionally-managed contracts.
This plan provides a framework for implementing the Superfund Long-Term
Contracting Strategy. Several major goals are addressed by the strategy. The majority
of Superfund contracting programs will be decentralized to the Regions. Contracts will
be smaller sized but contain options that may be exercised in response to fluctuating
needs. The smaller contracts will allow new and smaller environmental firms to
compete for Superfund work. Program activities will be integrated into the same
contract component where functions are similar (e.g., time critical/rapid remedial
response contracts.)
This implementation framework phases-in the new contracting components
without disruption of current programs. As older contract vehicles expire, new
components will gradually replace them over a 5-year period (see Table I.) This will
allow time to prepare Regional personnel to receive the contracting responsibilities
delegated in the strategy. In addition, gradual implementation provides Headquarters
time to adapt its role to one of oversight and technical assistance .
The Long-Term Contracting Strategy Task Force met to discuss and define a
framework for strategy implementation and to identify key issues the plan should
address. The task force also discussed methods for coordinating strategy implementation
including the roles and responsibilities of the entities affected by the strategy. This
implementation framework is the result of the task force's deliberations.
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TIME TO IMPLEMENT STRATEGY
COMPONENTS
CURRENT
CONTRACT
CONTRACT
EXPIRATION
1992
1993
I I I
1994
I I
REMOVAL
REG ERCS
ERCS ZONES HV
DIOXIN STORAGE BLDGS
DIOXIN EXCAVATION
02/91
02/91
09/91
09/92
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TIME TO IMPLEMdfTSTRATEGY COMPONENTS
CURRENT
CONTRACT
CONTRACT
EXPIRATION
NATIONAL
PRIORITIES LIST
12/92
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT
CONTRACT
CONTRACT
EXPIRATION
1994
i i i
1995
1996
i i i
ENFORCEMENT
PRP SEARCHES 06/91
TECH ASSIST
HAZ WASTE
SITES
TES ZONES I,
II, III, & IV
07/91
12/93
12/93
\/
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT CONTRACT
CONTRACT EXPIRATION
1991
4-4—1-
1992
4-4-4.
1993
1994
t-i-i
1995
4-Ul
FIT
W91
TECHNICA
FAT
use of ARCS
z
UJ
(0
UJ
cc
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CONTRACT
EXPIRATION
CURRENT
CONTRACT
CLP-QATECH
CLP-SMO
ESAT ZONE I
ESAT ZONE II
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II. Roles and Responsibilities
Implementation of the Long-Term Contracting Strategy will have broad, far-
reaching effects on the Superfund program and the entities that carry out its mission.
The task force believed that the key to successful strategy implementation was the
development of a team structure to manage and coordinate the implementation effort.
The task force designed an implementation team to:
Oversee the implementation process;
Include all affected organizations;
Exchange information;
Ensure consistency with the strategy goals;
Identify and resolve issues;
Plan administration of strategy components;
Facilitate Regional implementation; and
Monitor progress and measure success.
The team structure consists of three groups with distinct roles and responsibilities
(see attached Chart of Team Structure). The first group, the Advisory Committee, will
coordinate and oversee overall implementation. The second group, the Designated
Leads, will plan and oversee Regional administration of each strategy component. The
third group, the Regional Liaisons, will serve as the points of contact in each Region to
facilitate strategy implementation across Regional organizations. The roles and
responsibilities are described in more detail below.
A. Advisory Committee
The Advisory Committee will include representatives of all affected organizations
(the Emergency Response Division, the Hazardous Site Evaluation Division, the
Hazardous Site Control Division, the Office of Waste Programs Enforcement, the
Procurement and Contracts Management Division and the lead Regions for Superfund,
Management, and Environmental Services Divisions). The representatives from the lead
Regions will represent the Regions and communicate regularly with the Regional
Liaisons. The Contract Operations Review and Assessment Staff (CORAS) will lead
and facilitate the Advisory Committee (see attached Chart of Team Structure).
This broad-based membership will enable the Advisory Committee to build
consensus on the overall focus and direction of strategy implementation. It will also
enable the group to evaluate cross-programmatic issues and identify resolutions. As part
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of its problem resolution role, the Advisory Committee will define the degree of
Regional flexibility as well as define areas requiring consistency. A primary function of
the Advisory Committee will be maintaining open lines of communication with upper
management, the Designated Leads, and the Regional Liaisons. The level of long-term
involvement in overseeing the new contracts will be evaluated by the committee. They
will also oversee strategy implementation by reviewing the detailed implementation plans
for each strategy component, developing measures of success, and tracking progress.
B. Designated Leads
Headquarters program Divisions and Regions will serve as Designated Leads for
implementation activities (see attached Chart of Team Structure). The Designated
Leads will plan and coordinate implementation of each strategy component by
developing detailed implementation plans (discussed in Section IV). The Designated
Leads will oversee and guide Regional execution of plans, providing technical assistance,
monitoring progress, and recommending improvements. They will also play an
important role in maintaining communication links with the Advisory Committee and the
Regional Liaisons.
C. Regional Liaisons
Regional Liaisons will be appointed by each Region to serve as the points of
contact for strategy implementation and coordination within the Region. A liaison will
be appointed to represent the Superfund program, and an additional liaison will be
appointed to represent the Management Division, in each Region. These representatives
will be responsible for overseeing and coordinating Regional implementation to ensure
consistency with the strategy. The Regional Liaisons will serve as the Region's
communications link distributing and communicating progress to the Designated Leads
and Advisory Committee. They will also ensure that Regional input on the detailed
implementation plans is provided to the Designated Leads.
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Implementation OrgalWational Structure
Time Critical/Rapid
Response
ERD
Senior Management
Advisory Committee
CORAS, Chair
HSCD OWPE
ERD PCMD
HSED Lead Regions
Enforcement
Support
OWPE
Regional Management
Support
Region VII
Response Action
Contracts
HSCD
ESAT
HSED
Regional Liaisons
FITtfAT
ERD
Contract Laboratory
Program
HSED
Site • Specific
Region IV
!
v
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HI. Key Considerations of Implementation Efforts
The Task Force identified eight major categories of implementation issues.
These catepories encompass issues whose resolution will detail the extent of flexibility
available to the Regions and programs, and the need for consistency with the strategy
goals. Each detailed implementation plan for the new contracting components of the
strategy will address these categories of issues. As the Designated Leads identify the
issues affecting their contracting components, some may require a broad-based
resolution. The Leads are expected to analyze these issues for cross-programmatic
implications and determine when the Advisory Committee will be needed for resolution.
In addition, the Task Force identified issues within the eight major categories
which would be best resolved at the Advisory Committee level. The broad-based
membership of the Advisory Committee is expected to yield cross-fertilization and
consensus building. These issues will require extensive cross-programmatic and cross-
divisional coordination and cooperation and quality assurance in their resolution. The
Task Force anticipates that the Advisory Committee, Designated Leads and Regional
Liaisons, as discussed in the previous section will become the framework for discussion
and resolution of these issues during planning and implementation. In light of the
strategy's objective of program integration, an unprecedented level of coordination will
be required to ensure successful implementation of the strategy's final components.
This section discusses the topics identified as the eight major categories of issues
which must be evaluated by the Designated Leads and the Advisory Committee.
Category 1 - Communications
One of the key issues identified by the Task Force which affects ill components
of the strategy was communications. Each strategy component must be concerned that
communications are effective and that deliberations and decisions by the Designated
Leads represent consensus of affected entities. The links between Headquarters and the
Regions in both procuring and overseeing these contracts must be clearly established -
and regularly used. The methods of communication and information sharing must be
defined in the detailed implementation plans. Progress should be regularly reported by
Designated Leads and Regional Liaisons to the Advisory Committee.
The Advisory Committee's membership will promote free and open
communications among affected organizations. Communications on overall strategy
implementation direction and progress will be a key topic considered by the Advisory
Committee. In addition, information transfer will be a theme of the Advisory
Committee efforts.
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Category 2 - Organizational Roles and Responsibilities
The shifting of the Headquarters roles to oversight and monitoring will require
analyses and recommendations from the Advisory Committee. The role of Headquarters
during the transition period will require careful definition. Initially assistance will be
provided to the Regions by both the contracts offices and program offices to ensure that
activities are carefully coordinated and that Regions are well prepared to accept their
new responsibilities. Well-managed and interactive control mechanisms will need to be
developed so that the transition can be accomplished smoothly. For example, efforts
should be made to provide model Statements of Work, assistance on technical
evaluation criteria, fee plans, etc. to ensure consistency and ease of transition. Program
offices will need to coordinate closely with contracts personnel on the types, kinds and
numbers of contracts to support their needs. In addition, extensive cross-programmatic,
cross-divisional coordination efforts will be required to develop integrated contracting
components (e.g. FTT/TAT.) Designated Leads of contracting components will
undertake responsibility to elicit participation of other divisions and programs involved
in these components. Provisions also should be evaluated regarding Regional access to
one another's contracts for crossover in cases of conflict of interest, poor performance
and insufficient capacity.
Category 3 • Individual Roles and Responsibilities
The Task Force also raised the issue of individual roles and responsibilities.
With the transfer of contract management responsibility from headquarters to Regions,
many areas of coordination must be addressed (e.g., finance, legal, systems). Cross-
cutting issues concerning roles and responsibilities involved the definition of contracting
officer (CO) and project officer (PO) roles and authorities. Some questions for
consideration include: Will contracts be procured in the Regions initially or at
Headquarters? How will Regional COs and POs interact? How will administrative,
legal and financial monitoring support be provided to POs and COs? The Advisory
Committee will review the general transition of contracting and project officer
responsibilities to the Regions. In addition, the Designated Leads will need to consider
program-specific issues on roles and responsibilities such as issuance of technical
direction documents and work assignments, fee determinations, performance evaluations,
subcontracting consent and warrant authorities. The Designated Leads will inform the
Advisory Committee of their recommendations on these issues and use the Advisory
Committee mechanism to ensure coordination and consistency on their resolutions.
Category 4 - Timing of Transition and Delegation of Responsibilities
A primary goal of strategy implementation is to avoid program disruption by
phasing in new contract mechanisms as the old expire. Preliminary timelines for
implementation of the new contract mechanisms are discussed in Section IV-Individual
Strategy Components. The detailed implementation plans will ensure that a smooth
transition of responsibilities occurs. They will also address the timing and delegation of
placement and administration responsibilities to the Regions. These recommendations
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will be carefully coordinated with the Advisory Committee who will oversee the general
issues of delegation timing so that Regions will be prepared to assume the
responsibilities.
Category 5 • Training
A key issue to be addressed for each strategy component will be the preparation
of the Regions to receive technical PO and contracting responsibilities. Cross-
programmatic training issues (e.g., RPM access to Time Critical/Rapid Response
Contracts) will be addressed through recommendations relating to OSC and RPM
training. These recommendations will be considered by the Advisory Committee.
Category 6 • Budget/FTE
A key issue of implementation will be the evaluation of the budget and personnel
resources. The Designated Leads will recommend budget allocation scenarios to fund
new Regional contracts for each strategy component. The Advisory Committee will
provide oversight on general budget issues to ensure consistency with the analysis
performed in the Long-Term Strategy on personnel resources and funding of contracts.
In addition, the Advisory Committee will coordinate personnel and resource issues with
the affected budget offices.
Category 7 • Policy. Guidance and Procedures
The Designated Leads will be responsible for identifying needed policy, guidance
and procedures modifications resulting from the new contracting mechanisms. Types of
procedural issues to be considered by the Designated Leads will likely include: model
statements of work, fee determinations, performance evaluations, contractor monitoring
requirements, etc. The Advisory Committee will provide recommendations on cross-
programmatic and broad policy issues involving extent of Regional flexibility and
national consistency requirements (e.g., consistency of award fee process).
Category 8 - Automated Information & Reporting Systems
A key cross-cutting issue identified by the task force will be the development of
consistent information and reporting systems for all the strategy components. The
Designated Leads for each individual contracting component will address the needs for
information systems within their detailed implementation plans. The Advisory
Committee will evaluate the individual component's needs and identify the means to
address those needs in a coordinated and systematic way. The Advisory Committee will
need to evaluate a number of associated issues: 1) identifying the types of information
Headquarters will need to fulfill its oversight role; 2) identifying information needs
within and across Regions; 3) establishing common data elements; 4) linking new and
existing data systems. The Advisory Committee will also have to coordinate this effort
with PCMD's planned Integrated Contracting Management System.
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IV. Individual Strategy Components
The Designated Leads will be responsible for developing detailed plans and
coordinating the implementation of each strategy component. The Advisory Committee
will provide general guidance to the Designated Leads in preparing their plans and in
considering cross-cutting issues. Each of the detailed implementation plans will address
the eight major categories of issues identified in Section HI. Some key elements of
detailed implementation plans may include:
1) Methods for obtaining input from all affected organizations;
2) Resources to be committed to the implementation process;
3) Key milestones such as preparation of procurement packages, model
statements of work, issuance of RFPs, and methods for technical
evaluation, etc.;
4) A timeline for implementation outlining dates for major milestones;
5) Methods for monitoring implementation and reporting accomplishments
and problems to the Advisory Committee.
Inclusion of additional elements may also be necessary depending on the
requirements of the individual contracting program. This section describes the current
state, strategy goal, potential implementation issues, plan due date and designated lead
for each of the strategy components.
lie
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Time Critical/Rapid Response
Designated Lead
The Emergency Response Division is the Designated Lead for this component.
Current State
Currently all removal cleanups services and emergency response services are
provided by the Emergency Response Cleanup Services Contracts (ERCS). Four zone
ERCS contracts provide emergency response and cleanup services, nationwide, within 2
to 24 hours. Additionally, Regions n, ffl, IV, and V have Regional ERCS contracts that
provide cleanup services within 24 to 48 hours. Cleanup services for rapid remedial
actions are only available through the U.S. Army Corps of Engineers Rapid Response
and Preplaced contracts.
Strategy Goal
The strategy integrates rapid response cleanup services for the removal and
remedial programs by creating one contract mechanisms, in each Region, that can be
accessed by both programs. These new contract mechanisms enhance flexibility to be
completed under the remedial program without handoffs among various contractors.
Implementation Timeline
The first contracts to be affected by the strategy will be the ERCS contracts for
Zones 2 and 1. Which expire in June and July 1991 respectively. The Zone 3 ERCS
contract expires in September 1991. The Zone 4 ERCS has recently been recompeted
as two contracts to be awarded prior to February 1991. Zone 4A and 4B will not
include rapid remedial response. It will be phased-in at a later date. Coordination on
these issues must begin immediately.
Potential Implementation Issues to be Considered
o Statement of work for the new contract mechanisms to include rapid response'
cleanup services for both the remedial and removal programs
o A modification of the current ERCS statements of work
o On-Scene Coordinators have limited contracting officer authority to issue delivery
orders for cleanup services up to $250,000 and provide on-scene supervision of
the contractor
o Remedial Project Managers (RPMs) do not have authority to issue delivery
orders, nor are they trained to do on-scene supervision
8
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o New contract mechanisms to incorporate procedures for RPMs to access the new
contracts
o Time Critical/Rapid Response the first to be implemented because of the near
term expiration dates for the current ERCS Zones 1 and 2 contracts
Detailed Plans
Due Date for Detailed Implementation Plan: January 1991
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT .-%,«•«. -nrNn
CONTRACT EXP.RATION
REMOVAL, (ERCS)
ZONE IV 12/94
ZONE" 06/91
ZONE I 07/91
ZONE III 09/91
1
PRESENT
1991
I I I
1
•
1992
I I I
1993
i
& 4B
1994
I
-------
TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT
CONTRACT
CONTRACT
EXPIRATION
1993
1994
I I
lEMQVAL (REGIONAL ERCS1
REGION II
REGION II
REGION III
REGION III
REGION III
REGION IV
09/91
02/92
02/91
03/92
04/92
08/91
V
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT
CONTRACT
CONTRACT
EXPIRATION
1991
I I I
1992
1993
I I I
1994
I I
REMOVAL
DIOXIN STORAGE BLDGS.
09/91
UJ
DC
EL
DIOXIN EXCAVATION
09/92
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Environmental Services Assistance Team
Designated Lead
The Analytical Operations Branch of the Hazardous Site Evaluation Division is the
Designated Lead for this component.
Current State
Currently, analytical support and data review services are provided by dedicated
team contracts in two zones. These Environmental Services Assistance Teams (ESAT)
contracts are managed by EPA Headquarters.
Strategy Goal
The strategy continues the dedicated team concept but individual ESAT contracts
will managed by each Region. Creation of smaller, regionally-based contracts will
enhance competition.
Implementation Timeline
The current ESAT contracts expire in July and September 1991 and are
undergoing recompetition. The Regional ESATs are expected to be phased in within 4
years of the new contract expiration dates.
Potential Implementation Issues to be Considered
o Procedures for allocating funds to compete and manage the Region ESATs.
o Plan to manage the procurement process (e.g., model SOW, fee plans, etc.)
o Capacity issues linked to CLP issues
o Infrastructure and award fee issues including personnel resources
Detailed Plans
Due Date for detailed Implementation Plan: February 1991
10
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT
CONTRACT
EXPIRATION
1991
1992
I I
1993
1994
1995
I I I
1996
ANALYTICAL SUPPORT
ESAT ZONE I
ESAT ZONE II
09/95
09/95
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Field Investigation Team/Technical Assistance Team (FIT/TAT)
Designated Lead
The Hazardous Site Evaluation Division is the Designated Lead for the ARCS/FIT
portion and ERD is the lead for the FIT/TAT portion of the component.
Current State
Currently, preremedial support services are provided by dedicated team contracts
in two Headquarters managed zones. Removal technical assistance is also provided by
dedicated team contracts in two Headquarters managed zones.
Strategy Goal
The strategy will combine the FIT and TAT services into small, regionallv-
managed, dedicated team contracts. Until an orderly transition can occur, the ARCS
contracts will be used to provide preremedial support.
Implementation Timeline
The FIT zone contracts expire in October 1991. Preremedial support must be
fully phased into the ARCS contract mechanisms by that date. Coordination on these
issues must be immediately initiated.
The current TAT zone contracts expire October 1994. The FTT/TAT Regional
Contracts must be implemented by that date.
Potential Implementation Issues to be Considered
Procedural changes to be implemented to provide preremedial support through
the ARCS contracts
o Process to evaluate preremedial support within the existing ARCS evaluation
process
o Administrative procedures associated with the FIT contracts to be adapted to the
ARCS processes (e.g., program management costs, site-specific invoicing)
o Regional team structures for the combined FTT/TAT contracts
o Model SOWs and other elements of the procurement packages.
o Procedures for allocating funds to the Regions for competing and managing the
FTT/TAT contracts
11
-------
Detailed Plan
Due Date for Detailed Implementation Plan:
Interim FIT/ARCS: submitted
Long-term FIT/TAT: April 1991
12
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT CONTRACT
CONTRACT EXPIRATION
1991
I I I
1992
1993
I I I
1994
I I I
1995
J 1 1
PREREMEDIAL
FIT
09/91
use
of ARCS
UJ
(/)
UJ
DC
Q.
ECHNICAL ASSISTANCE
ATZONE 1
10/94
V
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Response Action Contractors
Designated Lead
The Hazardous Site Control Division is the designated lead for this component.
The Office of Waste Programs Enforcement and the Emergency Response Division will
serve as leads for their programmatic issues arising under this component.
Current State
Currently, 45 Regionally-managed Alternative Remedial Contracting Strategy
(ARCS) contracts provide support for federal-lead remedial activities except remedial
actions. ARCS contracts also support selected enforcement oversight activities.
Strategy Goal
The strategy integrates all enforcement oversight activities into the current ARCS
contracts, and adds support for nontime-critical removals to the scope of contract
activities. Integration of remedial and all enforcement oversight activities will reduce
handoffs among contractors when actions change from fund-lead to responsible party-
lead. Inclusion of all enforcement oversight activities will increase use of existing ARCS
capacity. Until an orderly transition to a combined FIT/TAT contract program occurs,
preremedial support will be provided through the ARCS contracts (see FIT/TAT
discussion.)
Implementation Timeline
The ARCS contracts begin to expire in 1998. The transfer of all enforcement
oversight activities to the ARCS contracts will occur in December 1993 with expiration
of the Technical Enforcement support (TES) zone contracts. Integration of nontime-
critical removal actions with ARCS will begin in June 1991 as the ERCS Contracts
expire.
Potential Implementation Issues to be Considered
o Procedures for short-term integration of preremedial support with ARCS (see
FIT/TAT discussion - Hazardous Site Evaluation Division will serve as the
Designated Lead.)
o Resolve the issues of switching between fund and enforcement-lead, potential
conflicts of interest, phase-in of enforcement oversight
o Issue of removal program access to ARCS contracts for nontime-critical removals
13
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Detailed Plans
Due Date for Detailed Implementation Plan: February 1991 for removal
programmatic issues (ERD). Hazardous Site Control Division must
develop procedures for accessing for nontime-critical removals by May of
1991 due to the first expiration date of ERGS in June of 1991.
April 1991 for enforcement oversight programmatic issues (OWPE).
Hazardous Site Control Division must develop procedures for all oversight
functions based on the OWPE plan.
The Hazardous Site Control Division has the main responsibility for
coordinating these efforts under the response action contracts (ARCS).
14
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT
CONTRACT
CONTRACT
EXPIRATION
REMEfflAL f ARCSI 1 OF a
REGION!
' REGION I
REGION I
REGION I
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT
CONTRACT
CONTRACT
EXPIRATION
RFUFRUI /ARCS* 9 OF 3
REGION IV
REGION IV
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT - CONTRACT
CONTRACT EXPIRATION
RFUFDUL f ARCS) 3 OF 3
REGIONS VI-VII 09/08
REGIONS VI-VII 10/9 S
REGIONS VI-VII 12/98
REGIONS VI-VII 03/99
REGIONS VI-VII 06/99
REGIONS IX-X
REGIONS IX-X
REGIONS IX-X
REGIONS IX-X
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Site Specific Contracts
Designated Lead
Region IV is the designated lead for this component.
Current State
Currently, site specific contracts are relatively short-term contracts providing
tailored site support. Regions ffl, IV, V and VII have awarded site specific contracts.
The types of services supplied by these contracts varies dramatically from provision of
bottled water to excavation of contaminated soil at 27 dioxin sites.
Strategy Goal
The strategy promotes increased use of site specific contracting to maximize cost
efficiencies. Decentralizing contracts management to the Regions should encourage
increased use of these contract mechanisms.
Implementation Timeline
Use of site specific contracts is ongoing. The Regions are expected to continue
evaluating opportunities to use these contracts.
Potential Implementation Issues to be Considered
o Methods to share information and experience on site specific contracting across
Regions
o Guidelines for developing site specific statements of work and accompanying
procurement packages
Detailed Plans
Due Date for Detailed Implementation Plan: February 1991.
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CURRENT
CONTRACT
CONTRACT
EXPIRATION
1991
I I I
1992
I I I
1993
I I
1994
ECHNICAL ASSISTANCE
TAT ZONE 1
10/94
TAT ZONE II
10/94
U)
U
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Enforcement Support Contracts
Designated Lead
The Office of Waste Programs Enforcement, CERCLA Enforcement Division is
the Designated Lead for this component.
Current State
Currently, there are 8 zone Technical Enforcement Support (TES) contracts;
three recently expired. These contracts provide support for selected enforcement
oversight activities, PRP searches, negotiations support and litigation support.
Strategy Goal
The strategy integrates all enforcement oversight activities into the ARCS
contracts (see Response Action Contracts discussion.) Specialized enforcement support
activities (e.g. PRP searches) will be supplied by small Regionally-based contracts.
RCRA enforcement support will be supplied through separate contracts. The smaller
Enforcement Support contracts will enhance competition and encourage small business
participation. Potential responsible party oversight for removal actions will continue to •
be performed by the removal program Technical Assistance Team.
Implementation Timeline
The Regional Enforcement Support contracts must be implemented by December
1993 when the majority of the TES contracts expire.
Potential Implementation Issues to be Considered
A strategy for creating separate contracts for RCRA enforcement support.
o A statement of work will define the functions of the new Enforcement Support
contracts and other elements of the procurement packages in view of tasks to be
moved to the Response Action Contracts
o Procedures for allocating funds to compete and administer enforcement support
contracts
o Procedures for allocating funds to response action contracts for oversight (see
response action contracts section)
o Linking regional contracts to CERCLIS/WasteLAN
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Detailed Plans
Due Date for Detailed Implementation Plan: February 1991.
Programmatic issues for response action contracts: April 1991
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TIME TO IMPLEMEIVTSTRATEGY COMPONENTS
CURRENT CONTRACT
CONTRACT EXPIRATION
ENFORCEMENT
TES ZONE I
TES ZONE II
TES ZONE III
TES ZONE IV
PRP
SEARCHES
TECH ASSIST
HAZ WASTE
SITES
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Regional Management Support Contracts
Designated Lead
Region VII is the Designated lead for this component.
Current State
No systematic contracting support exists for Regional administrative and
information management tasks.
Strategy Goal
The strategy creates small, Regionally-based contracts providing administrative
and information management support. The contracts should encourage more erncient
use of EPA OSCs1, SAMS', RPMs', RPOs' and Information Management Coordinators'
time by supporting their administrative duties. The small contracts should also enhance
competition and encourage participation by small business.
Implementation Timeline
Implementation of the Regional Management Support contracts is not contingent
on any existing contract timeframes or on the other strategy components.
Implementation can occur as Regional needs dictate.
Potential Implementation Issues to be Considered
o A new statement of work to define the functions of the new Regional
Management support contracts.
o The procurement process (e.g., model SOW, award responsibility)
o Allocation of funds for procurement and administration of Regional Management
Support contracts
Detailed Plans
Due Date for Detailed Implementation Plan: February 1991.
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37
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Transportation and Disposal Broker
Designated Lead
The Designated Lead will be determined by the Advisory Committee.
Current State
Prime ERCS and ARCS are responsible for subcontracting transportation and
disposal. In addition, most treatment and recycling is performed by the cleanup
contractors. The program has experienced delays in arranging for transportation and
disposal due to regulatory complexities. The determination of availability of facilities
meeting all regulatory requirements and competitive procurement requirements has
proven to be confusing and logistically difficult.
Strategy Goal
The strategy must further define functions of a transportation and disposal
broker. Two options have been considered. One option is to establish a broker as an
information clearinghouse and central point of contact on disposal. The second option
would entail the broker not only serving the information function but also conducting
actual subcontracting for disposal. Additional analysis of the problems encountered and
selection of the appropriate option will be required.
Implementation Timeline
The evaluation of options and analysis of problems should be completed in fiscal
year 1991.
Potential Implementation Issues to be Considered
o RCRA off-site contacts in each Region must be contacted individually regarding
facility compliance and inspection issues
o Each state must be contacted to determine the capacity assurance arrangements
o Each OSC/RPM must determine whether waste requires treatment prior to
disposal
o Identification of cost-effective alternatives to disposal
o Coordination of disposal/treatment of materials from sites which may be similar
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Detailed Plans
This is a cross-programmatic issue requiring coordination between removal,
remedial, and enforcement programs. The Long-Term Strategy Implementation
Advisory committee will determine lead responsibility and due date for a detailed
implementation plan.
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Contract Laboratory Program
Designated Lead
The Analytical Operations Branch of the Hazardous Site Evaluation Division is the
Designated Lead.
Current State
The Contract Laboratory Program consists of a contract for the Sample Management
Office and multiple contracts with individual laboratories to perform analysis of the
majority of samples taken for Superfund sites. This is a Headquarters managed effort.
Strategy Goal
The strategy deferred any decision regarding the decentralization of the Contract
Laboratory Program. A separate analysis of this issue is being performed by HSED.
Implementation Timeline
Early in fiscal year 1991 a briefing of upper management will occur on this issue.
Potential Implementation Issues to be Considered
o Delegation to Regions before or after award
o Program contractors subcontracting for analytical services
o _J Expansion of ESAT
Detailed Plans
A detailed implementation plan will be submitted upon decisions made by upper
management
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TIME TO IMPLEMENT STRATEGY COMPONENTS
CLE
CLP-QA TECH
CURRENT
ONTRACT
CONTRACT
EXPIRATION
CLP-SMO
09/94
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V. Next Steps
Several key steps will need to occur within the next two quarters of the fiscal year
(1991). Dates include:
1. Coordination on ARCS/FIT and ERCS issues 12/90
2. Memo to Regions calling for participation 12/90
3. Meeting of the Advisory Committee 1/91
4. Submission of ERCS implementation plan 1/91
5. Submission of all other implementation plans 2/91 - 4/91
6. Advisory committee review of all plans 3/91 - 5/91
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