f/EPA
            United States
            Environmental Protection
            Agency
            Office of Water
            Program Operations (WH-547)
            Washington DC 20460
December 1983
Construction Management
Evaluation and
Project Management
Conference Manual

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GCNb'mJLTlON MANAGEMENT EVALUATION
                AND     	
   PROJECT MANAGEMENT CONFERENCE
              MANUAL
    Construction Grants Program
      .Municipal Wastewater
          Treatment Works
                    1983
  Municipal Construction Division
 Office of Water Program Operations
           Office of Water
  U.S.  Environmental Protection Agency
        Washington, D.C.   20460

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              CONTENTS
CHAPTER I      GENERAL

                 A.  PURPOSE
                 B.  REFERENCES
                 C.  DISCUSSION

CHAPTER II.    PROJECT MANAGEMENT CONFERENCE

                 A.  GRANT MANAGEMENT
                 B.  CONSTRUCTION MANAGEMENT

CHAPTER III.   CONVENTIONAL CME

                 A.  GRANT MANAGEMENT
                 B.  CONSTRUCTION MANAGEMENT
                 C.  GRANTEE EXIT BRIEFING

CHAPTER IV.    EXTENDED CME

                 A.  GENERAL
                 B.  GRANT MANAGEMENT
                 C.  CONSTRUCTION MANAGEMENT
                 D.  GRANTEE EXIT BRIEFING

CHAPTER V.     THE REPORT

                 A.  GENERAL
                 B.  INTRODUCTION
                 C.  GRANT MANAGEMENT
                 D.  CONSTRUCTION MANAGEMENT
                 E.  ACTION ITEMS
                 F.  CONCLUSION
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Appendix A  -  Grantee Notification Package
Appendix B  -  Typical Report Outline
Appendix C  -  Financial Management Checklist
Appendix D  -  Construction Checklist
Appendix E  -  Construction Records Checklist

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                               I.  GENERAL
A.   Purpose

          The purpose of this manual is. to .provide, .detailed iguidance on
     conduct of Project Management Conferences ..(PMC) ".-and;Construction
     Management Evaluations  (GME).  These.-.site ,visits,;ace ^intended to
     enhance EPA oversight and.improve:local..construction:grant
     management.

B.   "REFERENCE:

       1.  40 CFR.Parts 22, 23, 30, 33, 34. and 35.

       2.  EPA Handbook of Procedures  (Third Edition).

       3.  EPA Construction Grants 1984  (CG84).

       4.  ER 415-2-4, Corps Support- of r;EPA',Construetion-J@rants,- Program,
          October 1, 9183.

       5.  EPA Regional Guidance Documents.

       6.  EPA/Corps of-Engineers  InteragencyAgreement.

       7.  EPA/Corps Regional Agreements.

       8.  State Delegation Agreement.

       9.  EPA Construction Inspection.Guide  (1976, 3.volumes).

     10.  (EPA) Management of Construction Change Orders— A Guide for
          Grantees (1983).

     11.  (EPA) Accounting Guide  for-Construction Grants (October,
          1977).

     12.  EPA Operating Procedures for Monitoring Construction
          Activities (1983).

C.   DISCUSSION:

          The PMCs are conducted  after award of the construction
     contract and preferably before initiation of construction. The
     PMC is  intended to enhance the grantee's capability to complete the
     treatment works in accordance with the grant documents and
     applicable regulations.  Typically,  this conference will include
     guidance to grantees on record-keeping requirements, construction
     management techniques and overall grant management procedures.

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     The duration of the EMC should not exceed 2 or 3 days and be
conducted on virtually all Step 3 and Step 2+3 projects with the
possible exception of grantees with demonstrated competence in project
management.

     The FMC may be conducted by either the State or the Corps of
Engineers  (CoE) depending upon the capability and desires of the State.
In those cases where the CoE has been phased out of a particular State
and the State cannot conduct the PMC's, the Region will arrange for the
CoE to do so.  This conference may be conducted by one or more persons,
depending on the size and complexity of the project.

     The conventional CME is a four to five day review conducted
during construction by the Regional Offices, preferably at the 40-60
percent stage, to evaluate the grantee's  grant management procedures,
and through this process gain insight into overall program management.
The CME should be held during the 20-40 percent completion stage,  if a
PMC was not conducted.

     An extended CME is a five to ten day in-depth review conducted
on large multi-contract projects.  These reviews will generally be
initiated by the Regional Offices and fully coordinated with the  State
agencies.  Team members should be experienced in this type of review
and fully knowledgeable of EPA regulations and policies.

     Typically, the on-site CME will be conducted by three or more
members composed of Personnel from the EPA Regional Office  (team
leader), the State Agency and the CoE.  It is important that the team
leader be  familiar with all grant requirements and relevant EPA
regulations.  The team leader will be responsible for reviewing grantee
records, procurement procedures and grant management procedures in the
grantee's  office.  The other team members will concentrate on the
project field records, construction management procedures,  and physical
construction.

     Prior to the CME, the Team  leader is responsible for notification
and coordination with the State, Grantee and CoE.  He is also
responsible  for all logistic arrangements.   Following the site visit, he
is responsible for the preparation and distribution of the CME Report.
He alsohas  the responsibility to assure that all action items have been
appropriately  responded to.
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                  II. PROJECT MANAGEMENT CONFERENCE (PMC)
     The PMC is held after the pre-construction conference and
preferably prior to initiation of construction.  The purpose is to
provide detailed guidance and instructions to the grantee in overseeing.
and managing his construction grant.  If applicable,..the CoE. is .well.
suited to conduct this conference.

     The EMC begins with a briefing in the grantee.1-s office.-attended^by
the State representative and/or CoE representative--(if applicable).,.
members of the grantee's staff, representatives :of -.the*
architect-engineer organization and other appropriate.members..of -.the:-.
construction management team.

     The Team Leader will explain the statutory requirements and-
regulations, reporting and record-keeping,requirements, construction ;
management functions, overall grant management- procedures and any
special grant conditions.  These areas are discussed in detail in the
sections of this manual under CME's.  However, in order to provide a
ready reference for those who will be conducting PMC's, they are also .
listed below.  For a detailed discussion of many of these .activities,
reference should be made to the CME sections.

A.   Grant Management

     1.  Statutory and Regulatory Requirements
     2.  Grant requirements, including special grant conditions.
     3.  Procurement procedures
     4.  Property control
     5.  Resident services required during construction
     6.  Record-keeping system
         a.  Provide a clear audit trail
         b.  Subsidiary ledger for each grant
         c.  Mlowable/Uhallcwable and direct/indirect cost segregation
         d.  Force account work documentation
         e.  Small purchase documentation.
         f.  Change orders, complete documentation.
         g.  Request for payments, documentation and back-up required
         h.  Claims, complete record of all actions taken by all parties
         i. ' Correspondence control - complete, chronological
     7.  Project closeout and project performance certificate

B.   Construction Management

     1.  Grantee responsibilities and authority
     2.  A/E responsibilities and authority
     3.  Contractor responsibilities and authority
     4.  A/E resident organization
     5.  Construction conformance with Plans and Specifications
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 6.  Inspectors daily log
 7.  Material testing requirements
 8.  Construction schedule
 9.  Progress Payments
10.  Davis Bacon, Copeland,  EEO
11.  Change order procedures
12.  Claims procedures
13.  Shop drawings, procedures and documentations
14.  As built drawings, keep current
15.  Correspondence (choronological file)
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                          III. CONVENTIONAL CME


     The- CHE'begins'with an entrance briefing at the grantee's office
attended'; by,; tlte review team, grantee office and field representatives,  a
Corps of Engineers' representative (if applicable),, a representative of
the' architect-engineer organization, a contractor- representative and
others, as-desired by the grantee.  The team leader will begin the
meeting, by reviewing the reason for the evaluation and1, explaihv the;, scope'
and goals of the- evaluation.  After1 a brief introductions of• the, team.
members and a description of their functions^ a tentative schedule of
teanfc activities will be discussed1 to1- insure- that. ReE> personnel: frcmvthe
grantee1 & office and; field, staffs will, bei available* for eoordination1
withv teantmembers1 at mutually convenient times.  The team-members will
try to- work, around! the grantee1 s established- schedules^ asi much) as-
possible* to1 minimize any disruptive effects that the1 OME- might, have-.
The team leader should also schedule, the exit briefing before? adjourning;
this meeting.

     The' grantee1 representatives should briefly describe their
organizational structure, the project's status and' work schedule,, the
contractor organization, the construction oversight, and1, inspection
programs.  Work space and key personnel for contact by team members will
be designated at this tine by the grantee..

     After completion of the entrance briefing, the1 CME team, will tour
the grantee's office, locate the filing- system- and be introduced to the
individual contact for each part of  the team's review;  The team will
then be shown to their designated work area in the grantee's office.
Following this orientation, the grantee representative will accompany
the CME team on a visit to the construction site and the resident
engineer's office.  During this time, the team will have a chance to get
a brief overview of the construction in progress.   Following  this, the
team will return to their designated work area to begin their individual
tasks.

A.   GRANT MANAGEMENT

          The team leader will evaluate the grantee's compliance with
     the grant requirements,  the procurement procedures and  the
     grantee's record keeping system.

     1.   Grant Requirements

               The team leader will specifically check on  the grantee's
          compliance with two groups of grant requirements.   The first
          group is comprised  of requirements which all grantee must
          meet, such as the requirements dealing with the  Operations and
          Maintenance Manual, a sewer use ordinance, user  charges,  an
           infiltration and  inflow survey, a sewer system evaluation
           survey, staffing, plan  of operation, a pretreatment program,

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     flood insurance, and service agreements (where there is more
     than one municipality).  The second group is composed of
     special grant conditions or requirements which have been made
     a part of  individual grants.

          The team leader must carefully scrutinize the role the
     grantee plays in seeing that these requirements are met.  In
     the past,  CME's have revealed that some grantees do not have
     firsthand  knowledge of grant requirements and their
     responsibilities under the grant.  This is particularly true
     when grantees rely on  other parties to assume these
     responsibilities.   This can lead to serious problems, such as.
     withheld grant  payments when certain grant requirements are
     not met or are not met on a timely basis.

2.   Procurement Requirements

          The team leader must be knowledgeable of all EPA
     construction grant regulations and related procurement
     procedures.  He must thoroughly review all grantee
     documents pertaining to engineering and construction contracts
     to determine if all of the applicable provisions of JJOCFR
     Parts 33 and 35 are being met.   The grantee's procurement
     systems should be reviewed to determine that contracts
     with engineer and contractors are of the  proper type and that
     the required EPA regulations  have been followed for
     evaluation and selection.

3.   Accounting Systems

          The team leader will make a thorough review of the
     grantee's accounting system.   Experience shows thatthere
     are four major problem areas which a significant number of
     grantees encounter. These areas should be given special
     attention.  The four problem areas are:

      (a)  Failure to separate eligible and ineligible costs and/or
          allowable and unallowable costs.

      (b)  Failure to segregate project costs between different
          grants and/or steps.

      (c)  Failure to develop written procedures for handling
          accounting,  and

      (d)  Failure to adequately justify and record total Federal
          reimbursements.

      Other areas of concern include force account work,  poor  or
missing records,  and the lack of documentation relating to  tune and
compensation for  construction inspectors.

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B.   CONSTRUCTION MANAGEMENT

          This phase of the CME will be conducted primarily by the team
     menbers with assistance from the team leader.   The team  leader will
     help review construction records after the grant requirements and
     procurement procedures have been reviewed.  The team will spend
     most of their time evaluating construction management rather than
     the acutal construction work.  A CME is not intended to  be  a
     thorough review of construction.  Rather, it provides EPA with an
     insight into the way grantees are handling grant and construction
     management, not with  detailed knowledge as to the quality  of
     construction being performed.  The EPA interim inspectixjn program,
     performed largely by the CoE, monitors and safeguards the quality
     of construction.

          The following listed items have been identified as recurring
     problem areas in previously conducted CME's.  These areas are also
     closely related to the fiscal aspects of the project,  as well as
     the progress of construction.  They should, therefore,  be given
     close scrutiny during the review.

     1.   Change Orders

               The change order review begins with an evaluation of the
          number of change orders that have been issued and', their
          relative costs.  Most large changes plus a few small changes
          should be selected  for detailed review.  It is noted that the
          number of change orders that can be expected at the tune for
          the CME depends on  the status of construction, size of
          project, complexity of design, the quality of the contract
          plans and specifications  and the contractors performance.  The
          change orders selected for review should be checked to
          determine if they are supported by  the following:

          a.   Evidence of  the need for change

          b.   Screening process

                (1)  Change order request is documented
                (2)  Funding is properly certified and authorized
                (3)  Prior approval, if appropriate
                (4)  Description of change
                (5)  Justification for change                 .
                (6)   Change to contract price, time of completion
                (7)  Approvals

           c.    Reasonableness of the method of accomplishing the
                objective
           d.    Eligibility of the change
           e.    Allowability of costs
           f.    Specific documentation of the actual change order

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        .  (1)  An independent engineering estimate

               (a)  Prepared by the consulting engineer with
               (b)  Reasonable accurate estimated of quantities,
                   and
               (c)  Detailed cost and pricing data

          (2) . A sumnary of negotiation, including the

               (a)  Basis  for the independent estimate and the
               (b)  Basis  for the contractor's estimate, including

                    (1)  Steps taken in review
                    (2)  Explanation of differences, and'
                    (3)  Adequacy of the estimate

               (c)  Results of price negotiation
               (d)  Basis  for the method of payment

2.   Claims

          It is very important that the grantee  provide timely
     acknowledgment of claims and that all known facts concerning
     claims be well documented.  A spot check should be made to
     determine the validity of the claims. The  probability of  the
     contractor successfully pursuing tha claims, possible amounts
     of such claims,  and reasons for such claims should be
     evaluated.  The grantee's position in any claim action that is
     not well documented is weakened because memories  can fade,
     personnel can change, and facts can be more easily disputed
     than can timely, well-documented, written records.

3.   Progress payments

          Review of progress payments for larger projects is
     usually limited to an explanation of procedures by the grantee
     and a review of monthly payments to insure that these
     procedures are being followed.  The standard procedure used
     for processing progress payments begins with a submittal from
     the contractor containing an estimate of work completed during
     the previous month.  Such an estimate is usually divided into
     many line item entries for various phases of work and includes
     any invoices or other documentation that are required.  The
     inspector for the grantee who is most familiar with a certain
     line item entry will then make an independent review of work
     accomplished.  The inspector should be able to verify
     quantities of work performed or materials consumed by
     referring to the daily inspection reports.  If the
     contractor's estimate and the inspector's review agree, the
     contractor  is paid the mutually agreed upon amount for that
     particular  line item.  Any disagreement on estimates is

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    negotiated, with the burden for justifying estimates falling
    on the contractor.  When a project nears completion, the
    grantee should estimate how much money  is required to complete
    the job, and then insure that the  amount needed, plus a
    reasonable contingency, is retained to  cover future work and
    any known deficiencies.

4.  Progress Schedules

         Progress schedules and their  appropriate updating ore
    important on every project, in order  that both the contractor
    and the resident engineer are aware of  the contract status.
    In the event a project falls behind schedule, early
    recognition of this fact is essential so that the Contractor
    and Resident Engineer can plan any additional effort that may
    be required to regain the schedule.

         It would appear that the normal  provision that allows the
    grantee to assess liquidated damages  against the contractor,
    if the contractor does not complete the job on time, would
    provide the incentive for the contractor to finish on
    schedule.  Unfortunately, vjhan a project does fall behind
    schedule, there are usually many factors to consider that can
    be the result of both contractor and  grantee actions, making
    it difficult to obtain a clear determination of responsibility
    for delay.  Therefore, the resident engineer must insist on
    appropriate schedule updating and  do  all that is contractually
    possible to encourage the contractor  to maintain the schedule.
    Unless such a course is pursued, the  grantee risks nullifying
    the "time is of the essence" and liquidated damages clauses.

5.  Inspection Reports

         Inspection reports are of utmost importance on any
    construction project because they  represent the observations
    of the person closest to the work  and are timely
    documentations that do not rely on memory.  They are essential
    to the grantee in settling disputes with the contractor.
    Also, the report can be an effective  tool as a basis
    for preparing deficiency lists when the project or major
    phases of the project are nearing  completion.  A spot check
    of inspection reports should include  verification that daily
    logs are being maintained, day-to-day deficiencies and
    problems are being noted, discussions with contractor
    personnel are being recorded, and notations are being made on
    any follow-up action taken on previous comments.   The daily
    inspection reports should also contain reference to quantities
    of work performed and materials consumed.  These  reports may
    then be used to compute progress reports.  The CME team should
    determine if noted deficiencies which could be concealed by
    future work are being corrected in a timely manner and
    properly documented.

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 6.  Shop Drawings

          A spot-check of the technical adequacy of shop drawings,
     compared to contract documents, is made as a part of  the
     construction review by the team.  The team should also check
     the method of processing, filing and distribution of  drawings
     to assure that construction delays have not been caused by
     deficiencies in the system.

 7.  As-Built or Record Drawings

          An evaluation of the as-built drawing procedures should
     be made to assure that the as-builts are kept current.  This
     can be done by comparing known changes with as-builts to  see
     if the changes are, in fact, being added to the drawings.
     Particular attention should be given to those items which are
     changed and are concealed by future work, such as underground
     utilities.

 8.  Correspondence

          It is important that any correspondence from the
     contractor be answered in a timely manner and that any
     decisions by the resident engineer concerning problems,
     clarification, discussions with the contractor, etc., be
     documented.  The correspondence file and resident engineer
     logs should be spot-checked to obtain a general idea  of how*
     well the resident engineer is documenting management  of the
     contract.  Such documentation can be by letter or memo to the
     contractor or by an entry into the resident engineer1 s daily
     log.  It is suggested that any documentation that
     addresses decisions involving significant items of work be in
     the form of a letter to the contractor.  The general  filing
     system should also be reviewed to assure that a logical and
     usable system is being employed.

9.   Labor Requirements

          An inspection of the contractor's facilities should  be
     made to determine that normal requirements for posting certain
     information are being met.  Such items as the applicable  wage
     poster and wage determinations, equal employment opportunity
     notices, and OSHA regulations must be posted in such  a manner
     as to afford any employee the opportunity to review such
     material.

10.  Organizational Requirements

          The team has the responsibility of evaluating the
     adequacy of the resident engineer's organization as well  as
     that of the contractor.  The record keeping system of both

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          should be reviewed.  Other areas in which problems may occur
          are staff and organizational structure.

     11.  Material Testing & Certificates

               A check into the  resident engineer's material
          testing file should  be made  to determine if adequate testing
          records and documentation are being kept.  Special emphasis
          should be placed on  soils, concrete, pipe, rebars and
          welds.

C.   GRANTEE EXIT BRIEFING

          The CME concludes with an exit briefing at the grantee's
     office.  The briefing should be attended by the same personnel who
     were present at the entrance briefing, minus the contractor
     representative.  The team leader  begins this meeting by discussing
     the findings, recommendations, and conclusions of the CME.  After
     the team leader has finished the  CME  summary, the parties involved
     will be given an opportunity to discuss the findings,
     recommendations, and conclusions  wita the  individual CME team
     members.

          The team leader should clarify that the CME findings presented
     in this meeting will include the  significant comments to appear  in
     the written report.  However, additional details may be added to
     the final CME report as appropriate.

          The exit briefing is an opportunity  for the grantee to
     benefit from the experience and knowledge of the CME team, asking
     questions and commenting on the CME findings.   Ideally, this
     meeting should be conducted in such a manner as to promote a
     positive and open atmosphere which will stimulate  constructive
     criticism from all interested parties. All CME team members must
     be prepared for this meeting by having,  at least a rough draft of
     their  findings.  These findings need not be in final  form, but they
     must be sufficiently complete so that the final report can be
     easily prepared from them.  By discussing these findings with the
     grantee, any inconsistencies or omissions will be corrected.  The
     exit briefing will also assist the grantee by providing an
     opportunity to go into the actual details behind the findings and
     recommendations.
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                            IV.  EXTENDED CME
A.   GENERAL
          The extended CME is intended for large multiple contract
     projects designated by a Regional Office as appropriate  for an
     in-depth review of construction grant management procedures.  These
     five to ten day reviews are conducted by a four to five  mentoer team
     fully experienced in on-site review techniques and knowledgeable of
     EPA regulations and policies.  The designated team leader will be
     from the EPA Regional office.  Each team member will have specific
     assignments and the team leader will determine the amount of tine
     allocated to conplete these assignments.

          The team structure will include the Regional  Program
     Manager-Team Leader and two to three experienced Team members from
     the State and CoE, who will be assigned particular areas of
     responsibility.  The Team will further include personnel from the
     Office of Audit, either initially assigned as Team menbers or on
     call, as needed.  The Team Leader assumes conplete responsibility
     for control of the Tteam.  He shall make the assignments  and, in
     general, shall be the Team member who reviews project records in
     the grantee's office.

          The scope of Review Team's actions in the field  will include
     an entrance briefing for the grantee, a review of the grantee's
     work in place, a review of the construction management system and
     procedures in the resident engineer's field office and an exit
     conference with the grantee.  In addition to those things described
     under a conventional CME, the following will be reviewed.

B.   GRANT MANAGEMENT

          The elements of the grantee's financial management system
     shall be discussed from the viewpoint of his organization, the
     procurement system, the existing or proposed user charge system,
     the property control system, the local share funding procedures and
     accounting system and the grantee's record-keeping system.  The
     financial management system will be reviewed by the Team Leader and
     the audit representative using the "Financial Management
     Checklist11, Appendix C of this manual.

     1.   Grantee Organization description shall include the
          official name of the grantee, his address and official
          telephone number and a short description of the
          organizational structure with names of key personnel.
          The description shall also include the definition of the
          service area, the community served and the service

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     responsibilities incumbent on the grantee.  The principal
     facilities owned and operated by the grantee's  wastewater
     treatment organization shall be described including the
     capacities and locations and functions of each  major  facility.
     Principal agreements with other legal entities  shall  be
     described and their current status should be  assessed insofar
     as possible.

2.   Procurement System of the grantee for
     architect-engineering services shall be described,
     including commentary on its effectiveness.  The grantee's
     procurement system for construction contracts shall also
     be described with an analysis of the grantee's  policy
     regarding conformance to Federal procurement  procedures
     as required in EPA regulations.  The following  documents,
     as a minimum, should be reviewed.  Advertisement  for
     Bids, Bid Tabulations, Low Bid, and Notice  to proceed.

3.   User Charge programs of the grantee, either existing  or
     proposed, shall be discussed from observations  made
     during the review.  Particular elements to  receive
     attention shall include the grantee's authority for
     imposing user charges, the schedule of charges  and
     surcharges, any special service agreement with  other
     legal entities.  The sewer use ordinance used by  the
     grantee shall be reviewed for adequacy in accordance  with
     the guidelines.  Any infiltration/inflow work in progress
     shall be described and related to the schedule  for its
     applicability and for its necessity.

4.   Property Control System for the grantee's real  property
     shall be reviewed for its existence and its applicability
     to both easements and fee title property.  The  Team shall
     discuss whether the grantee has the right of eminent
     domain, whether he has the capability to make realistic
     appraisals to negotiate with landowners effectively,
     whether documentation is complete and legally filed,  as
     required, and the location of the filed documents.

5.   Local Share Funding shall be identified as being planned,
     being available, or having been obtained.  Bond issues or
     short-term financing of the local share of project costs
     shall be described.  Budgets, outlay schedules and cash
     flow projections which contain funds for local share
     obligations shall be discussed.

          Discussion of bond issues shall include the level of
     current long-term indebtedness and limits on bonding
     authority.  The handling of funds received from the sale
     of bonds or borrowed on a short-term basis for local
     share payment shall also be discussed.

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               The Report shall note the  frequency of audits and the
          basis upon which each one is performed.  Disclaimers by the
          auditors shall be particularly  mentioned and the reason for
          each shall be justified.

               The discussion of budgets  and associated financial
          planning documents shall  include reference to special funds or
          reserves for debt retirement.

     6.   Record-keeping System review shall include the project
          file for all grant agreements and other documentation
          such as advertisements, bid tabulations, proper federal
          •and state approvals, recommendation for award, executed
          contracts, valid bonds, required insurance coverage and
          other required documentation.  The review of periodic
          payment estimates and change order descriptions shall
          include completeness of documentation,  .proper format and
          compliance with EPA regulations.

               Direct purchases and other charges to the project shall
          be analyzed for their allowability and the proper
          establishment of their value.  The track of EPA payments  shall
          be reviewed through the grantee's accounting documents to
          determine if proper controls have been applied at each stage.

               The Team Leader shall have the rebponsibility to review
          the grantee's cost accounting system.  However, should an
          auditor be a member of the team, he will -be assigned this
          tasks.

               Mb effort will be made to perform a  formal fiscal audit
          of the grantee's records.  The purpose of this review is  to
          check for an audit trail and determine that a proper usable
          accounting system is in place and being properly used and
          maintained.

C.   CONSTRUCTION MANAGEMENT

          The construction records are the source documents  for the
     history of the project and all actions that have been taken during
     the course of its construction.  These records should be reviewed
     to the extent deemed unecessary by the team.  A list of typical
     construction records is contained in Appendix E.

     1.   Plan and Specifications will be reviewed so that the team
          becomes familiar with the construction aspects of the project.
          This knowledge will be used to determine that the project is
          being constructed in accordance with the approved plans and
          specifications.
                                    IV-3

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 2.    Compliance with Approved Plan - The Facility Plan should be
      reviewed to  assure that the project is in compliance with the
      plan.   If it is not, an explanation and justification must be
      provided by  the grantee.

 3.    Resident Engineer and Inspector Organization should be
      monitored from the standpoint of their demonstrated technical
      competence.

 4.    Shop Drawings delivery and storage systems shall be review.
      The Report shall content on the checking procedures including
      the system and levels of responsibility of the checkers, and
      the mechanism for informing the contractor and owner of
      approvals and disapprovals.

 5.    Construction Schedule requirements and required format shall
      be discussed.  The responsibility for creating, updating and
      using  the schedule to control construction progress shall
      emphasized.

 6.    Correspondence Control shall be evaluated from the copies
      retained in  the field office.  Mention should be made of the
      correlation  between  level of authority and the subject of each
      piece  of correspondence.  Storage facilities and a control
      system such  as a correspondence log shall litewise be
      evaluated.

 7.    Pay Estimate Documentation shall be reviewed, special
      attention should be  given to the method of preparation and the
      basis  for establishing quantities and prices by which the work
      is paid.

 8.    Inspection Reports discussions shall center on the inspector's
      daily  reports and any official diaries which may supplement
      them.   They  shall be analyzed for completeness and timeliness.
      Their  use for job control shall be described.

 9.    Change Orders and the documentation to supplement them shall
      be thoroughly reviewed,  including the methods for negotiating
      change orders. Procedures  for handling change orders over
      $100,000 shall be separately analyzed.

10.    Materials Testing Documentation shall be  reviewed including
      the types of tests,  the recored of tests, the schedule of
      quotas for materials testing, the use of  outside materials
      testing laboratories and the use of  tests to reject materials
      and work. Special  attention should be given to corrective
      action taken when tests fail.  This  action must be
      completely documented.
                              IV-4

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    11.   Davis-Bacon, Copeland, EEO requirements to be met at the
          construction site shall be reviewed and any violations shall
          be noted.

    12.   Other Topics to be mentioned in the Report include  the
          presence and requirement for an Operation and Maintenance
          Manual, copies of OSHA regulations available  on the site,
          the posting and enforcement of proper emergency procedures,
          the posting of emergency telephone numbers and  the  presence of
          the required trade permits and waterways encroachment permit
          requirements.

D.   EXIT BRIEFING

          Briefing shall be as described under Conventional CME. The
          format for the briefing is included as a part of Appendix  A.
                                   IV-5

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                              •V. .THE REPORT

A.   GENERAL

          Upon completion .of the on-site evaluation, ,a formal ^report
     will be prepared.  A final .draft should :be ready .within one -jreek
     after leaving the site.  The final .report should :be .issued within
     one month.  The report .will -be ..a .self ^contained -.(3ocument -which
     details the evaluation .and its ,results..  The ,team leader is
     responsible -for .writing and issuing -the final -report.  Based .on
     past experience,;a typical. report-will average .10 to 2JD pages.

          It is suggested the report-be divided into -five-major,parts
     and necessary .appendices..  These -five .parts are -the 'Introduction,
     Grant Management, Construction Management, Action Items and
     Conclusion.  .-Any ^backup -information needed to clarify or support
     the main body of the report should be .included in the Appendices.

B.   INTRODUCTION

          The introduction .provides .an opportunity ^ ^describe -the
     grantee organization, the purpose .of -the-.(23E 9nd the.-soope of ,the
     evaluation. A reader -.should .be ^able -.to .understand the whole CME
     program by reading the introduction .to .any .individual jCME .report.
     The description of the .grantee -must .be ..in sufficient detail  for a
     reader to compare the particular grantee being evaluated with other
     grantees. As such, the description must include .all pertinent items
     regarding the grantee, -including the :population served by the project,
     the physical layout of treatment plant, the type of management
     system utilized, the number of contracts as well as the  dollar
     value of each.and the project status at the time .of the  CME.

C.   GRANT MANAGEMENT

          This part of the report  can generally be divided into four
     sections:  project record  control, .accounting system, grant
     requirements, and recommendations.  In  some cases a  separate
     section on .procurement procedures may be desirable.

          The section on grant  requirements may be set up in a tabulated
     fashion.  All the grant requirements that are checked  should be
     discussed in the tabulation.  If the grantee failed  to meet any of
     these requirements or if there  is  a strong possibility the grantee
     will be unable to meet requirements in  the future, then this fact
     and the problem behind it  should be discussed in this portion of
     the CME report.
                                    V-l

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          The recommendations section is intended to benefit and provide
     guidance to the grantee.  The recommendations nust be specific,
     detailed, and tailored to the needs of the individual grantee.   If
     the recommendations are acted upon by the grantee, they should
     remedy problems that the grantee,may be having with grant
     management.  Recommendations will be viewed as advice while the
     ACTION ITEMS part of the CME report will be viewed as a mandate.

D.   CONSTRUCTION MANAGEMENT

          This part of the report is best separated into three sections:
     construction management, construction review, and recommendations.

          The construction management section may be divided into
     subsections such as change orders, progress payments, progress
     schedules and the like.  Each of the subsections will summarize  the
     team findings with respect to,that area and list any deficiencies
     noted.  These subsections should not be cluttered with unnecessary
     detail.  They need to be short and to the point, but still detailed
     enought to allow a reader to find the grantee's strengths or
     weaknesses in a given area.

          The construction review section should give a brief.
     description as the the quality of work being performed.  If any
     problems were observed with respect to the quality of construction
    . work, then the team engineer should note these.  When such a
     situation occurs, the team leader should include extra
     documentation in a separate appendix and provide greater detail
     than usual for this section.

          The recommendations section should be designed in the same  way
     as the grant management part of the report.

E.   ACTION ITEMS

         1 This probably is the most important part of the written  CME
     report.  It outlines actions to be taken, which if followed,  will
     correct deficiencies noted as a result of the CME.  The action
     items should be divided into three distinct sections.

          The first section will include, all action items required of
     the grantee, and will be divided into two subsections:  (1) those
     actions which the grantee must personally implement, arid (2)  those
     actions which the grantee will have consultants or contractors
     implement.  An example of the former would be a change in the
     grantee's accounting system.  An example of the latter would  be
     requiring the contractor to update or revise a construction
     schedule.
                                   V-2

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          The second section will include all Agency action items which
     must be taken by the State Environmental Agencies.  An example of
     such an item would be the same as any Regional EPA action item
     where the State had received delegation in the area.

          The third section will include all action items which need to
     be taken by the Regional EPA Office.  An example might be a
     requirement for an adjustment in progress  payments.

F.   CONCLUSION

          The conclusion is a short final statement with respect to the
     project as a whole.  It should state a conclusion as to the overall
     quality of the grantee's management.  The  team leader  should be
     given discretion in deciding what should be included in this
     section.
                                   V-3

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                              APPENDIX A
                      GRANTEE NOTIFICATION PACKAGE
                                   FOR
                   CONSTRUCTION MANAGEMENT EVALUATIONS
     The itans listed below make up the notification package to the
qrantee. Samples of these documents are included as a part of this
Ippendix.  *Key should be tailored to each individual ^antee and sent
tothe grantee at least two weeks prior to the scheduled date of the
CME.
          Sample Grantee Notification Letter                    A-2

          Schedule for Review and Briefings                     A-3

          Outline of Construction Management Evaluation Revis*
            Topics

                nts and Facilities Required from Grantee        A-5
          Outline of Entry Briefing at Grantee's Office          A-6

          Outline of Exit Briefing at Grantee's Office           A-7
                                    A-l

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                  SAMPLE GRANTEE NOTIFICATION LETTER
 (Address)

Dear —

     This is to confirm that there will be a Construction Management
Evaluation  (CME) of your construction grant project from (date) to
 (date) inclusive.

     The. following enclosures have been attached to assist in- your .
preparation for the field'visit:

          Schedule for Review and Briefings

          Outline of CME review topics

          Outline of Entry Briefing at Grantee's Office

          Docurnents and Facilities Required from Grantee

          Outline of Exit Briefing at Grantee's Office

     The primary purpose of the visit is to provide an overview of the
management of the construction phase of the construction grants program.
It should be emphasized that this project has been selected because it
is part of a sampling of projects representing a cross-section of the
construction grants program.  No suggestion of improprieties can be
inferred from its selection.

      Your assistance in providing access to project documentation and
working space for the Review Team will be appreciated.  It is
anticipated that Team Members will require consultation with your staff,
your A/E's field personnel and construction contractor
personnel.  These interviews will be scheduled during the Entry
Briefing.  Your cooperation during the field visit will be appreciated
and the Review Team has been instructed to respect your normal working
schedule insofar as possible.

     Questions should be directed to (name), Project Officer, at
 (telephone number).

                                    Sincerely,


                                     (signature)
                                   A-2

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                  SCHEDULE FOR REVIEW AND BRIEFINGS
(Day and date)
     10:00 AM -  Entry Briefing with Grantee at Grantee's Of-fiee
      1:00 EM -  Escort of Team by Grantee, Orientation Tour of
                 Gcnstructioh Sites, Storage Site(s), Work Spaces,
                 Introduction/Arrangenehts with Conferences

(Day and date)
      8:00 AM -  Team Members Begin Concentrated Effort on Assigned
                 Areas

(Day and date through Day and date)  .
      8:00 AM -  Team Members Work on Assigned Areas

(Day and date)
      8:00 AM -  Team Members final Preparation for Exit Briefing
(Day and date)
      9:00 AM -  Exit Briefing with Grantee
      PM      -  Team Travel
                                  A-3

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      OUTLINE OF CONSTRUCTION MANAGEMENT EVALUATION REVIEW TOPICS
1.  Grant Management

    a.  Grantee Organization
    b.  Procurement System
    c.  User Charge/Industrial Cost Recovery
    d.  Property Control System
    e.  Local Share Funding
    f.  Record-keeping System
    g.  Facility Plan
    h.  Claims

2.  Construction Monitoring1

    a.  Preliminary Work
    b.  Work Quality Assurance (Summary)
    c.  Resident Engineer and Inspector Organization
    d.  Contractor Organization
    e.  Work Performance

3.  Construction Records

    a.  Plans and Specifications
    b.  Shop Drawings
    c.  Construction Schedule
    d.  Correspondence Control
    e.  Pay Estimates  Documentation
    f.  Inspection Reports
    g.  Change  Orders
    h.  Material Testing Documentation
    i.  Davis-Bacon, Copeland, EEO
    j.  Other
                                    A-4

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            DOCUMENTS AND FACILITIES REQUIRED FRCM GRANTEE
1.  Documents to be Furnished by Grantee

    a.  Contract Drawings
    b.  Specifications
    c.  Change Order File
    d.  Claims File
    e.  Payment File
    f.  A/E Contract (s)
    g.  Construction Contract(s)
    h.  Grant Agreement(s)
    i.  Organization Chart with Telephone Numbers
    j.  A/E and Contractor Organization Charts with Telephone Numbers
    k.  Project Schedule
    1.  Resident Engineer (s) Reports
    m.  Shop Drawings
    n.  Correspondence File
    o.  Records of Testing
    p.  Payroll Records
    q.  Permits and Certificates
    r.  Operation and Maintenance Manual  (if prepared)
    s.  Shop Drawings

2.  Team Facilities Required

    a.  Work space in A/E site office(s) accessible to field files
    b.  Work space in Grantee's office accessible to Grantee files
                                   A-5

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                       ENTRY BRIEFING WITH

                            Grantee's Office
A.   Attendees

     Grantee     -  Chief Executive
                    Principal Staff Engineer
                    Principal Staff Financial Representatives
                    Other  (Grantee option)

     A/E         -  Project Manager
                    Project Resident Engineer
                  ' Chief  Inspector
                    Other  (Grantee option)

     Contractor -  Construction Superintendent

     R.O.        -  Project Officer  (if not delegated)

     State      -  Project Officer  (where delegated)


     CME Team


 B.   tentative Agenda

      CME Team Leader  -  Introduction /Purpose/Objective, Schedules
                       -  Team Member

      Grantee          -  Discuss the follxwing:

                           0  Description of Construction Inspection and
                             Supervision Arrangements
                           0  Briefing of Institutional Arrangements,
                             Statutory  Authority, Regional Agreements
                           «  Overview of Project Status, Financing,

                           0  Designate  Grantee Principal Contacts, Work

                             Spaces



  C.   Grantee Escort  of Team on Orientation Tour, PM

                        -  Construction Site(s)
                        -  Storage Site(s), stockpiles, and Off-site
                           Plants
                        -  Field offices
                        -  Other

                                     A-6

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                       EXIT BRIEFING WITH GRANTEE

                            Grantee's Office
A.   Attendees

     Same as Entry Briefing, Except:

          -  Minus Construction Superintendent


B.   Tentative Agenda

     CME Team leader  -  Highlights of Favorable Findings
                      -  Highlights of Unfavorable Findings
                      —  Reocnmendations
                      -  Probable Thrust of Final Report

     Grantee          -  Observation on Exit Briefing
                      -  Conments, Questions, Discussion of any findings
                         or observations of the review team
                                 A-7

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                               APPENDIX B
                         TYPICAL REPORT OUTLINE
PART I    Introduction

          A.  Purpose
          B.  Scope
          C.  Grantee
              1.  Organization
              2.  Construction Grant
              3.  Construction Project
PART II  Grant Management

          A.  Record Control
              1.  Project Filing System
              2.  Manner of Organization

          B.  Procurement Procedures

              1.  Engineering Services

                  a.  Maximum Open Technical Competition
                  b.  Types of Contracts
                      (1)  Cost of Percentage of-cost
                      (2)  Peroentage-of-construction-costs
                      (3)  Cost Reimbursement
                      (4)  Fixed Price
                      (5)  Per Diem
                  c.  Responsible Engineer Capable of Performing
                  d.  Contract Clearly Defining Scope of Service
                  e.  EPA Transition Policy - Appendix D
                      (1)  Prior to July I, 1975 - Existing contracts
                      (2)  July 1, 1975 to December 17, 1975 -
                           Negotiated on current cost and pricing data
                      (3)  After December 17, 1975 - Provision of
                           40 CFR 35-937 Subagreemsnts for A/E services
                      (4)  December 17, 1975 - February 1, 1976 - RA can
                           excuse announcement and selection procedures
                  f.  Access to Records, Appendix D, required after
                      July 1, 1975.
                                   B-l

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    2.  Construction Contracts

        a.  Competitive Bidding w/Public Notice and
              Adequate Time
        b.  Type of Contract
             (1)  Lump sum
             (2)  Unit price
             (3)  Combination
        c.  Bidding Documents
             (1)  Statement of work
             (2)  Terms and Conditions of Contract
             (3)  Explanation of Method of Bidding
             (4)  Bid Evaluation Requirement and Criteria
             (5)  Sealed Bids
        d.  Lowest Responsive, Responsible Bidder
        e.  EPA Approval
        f.  Eligible/Ineligible Items

C.  Cost Accounting Systems

D.  Grant Requirements

    1.  User Charge -35.925-11 and 35.935-13

        a.  Status
             (1)  Evidence of Timely Development - 50 percent
                Grant Payment
             (2)  System Approval - 80 percent Grant Payment

    2.  Industrial Cost Recovery (ICR) - 35.925-11 and
        35.935-15

        a.  Status
            (1)  Class deviation at 45 FR 81576,
                 December 11, 1980, eliminates all industrial
                 cost recovery requirements back to
                 December 27, 1977.

            (2)  ICR payments due to EPA prior to
                 December 27, 1977, on grants awarded after
                 March 1, 1973, are still required.

    3.  Sewer Use Ordinance 35.927-4 and 35.935-6

        a.   Status
            (1)  Ordinance Approval - 80 percent Grant Payment

    4.  Sewer System Evaluation and Rehabilitation 35.927-5
        and 35.935-16
                         B-2

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                  a.  Status
                      (1)  Compliance with Rehabilitation Program
                           80 percent Grant Payment

              5.  Operation and Maintenance Manual 35.935-12

                  a.  Status
                      (1)  Draft or Timely Development - 50 percent
                           Grant Payment
                      (2)  Manual Approval - 90 percent Grant Payment
          E.  Recommendations

              1.  Listing of Specific Recommendations
              2.  Recommendations Should be Impersonal
PART III  Construction Management

          A.  Construction Records - Overall Statement

              1.  Plans and Specifications

                  a.  Comprehensiveness of Review
                  b.  Plans - Some significant Points
                      (1)  Site layout Compared to Tour of Site
                      (2)  Wastewater & Sludge Flow Diagram
                      (3)  Hydraulic Profile
                      (4)  Structures Compared to Site Layout
                      (5)  Process Equipment
                  e.  Specifications - some Significant Points
                      (1)  Liquidated Damages
                      (2)  As-built Drawings
                      (3>  Time of Completions
                      (4)  Construction Schedule
                      (5)  Contract Price Breakdown
                      (6)  Payment estimates
                      (7)  Change Orders

              2.  Construction Schedule

                  a.  Types of Schedules
                  b.  Primary Concern - On Schedule or Not?
                  c.  Secondary Concern - Will Construction Remain on
                      Schedule?
                  d.  Indicators of Future Trouble
                      (1)  Construction Schedule Has Not been Updated
                           Recently
                                   B-3

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         (2)  Little Evidence of Contractor's Advance
             Planning
         (3)  Shop Drawing Suhmittal Is Slow
         (4)  Numerous Scheduling Conflicts
    e.  Reason for Slow Construction Progress
         (1)  Poor Bidding
         (2)  Poor Planning
         (3)  Acts of God
         (4)  Financial Expedience
    f.  Behind Schedule Actions
         (1)  Warning Notice to Contractor
         (2)  Requirement for Interim Make-up Schedule
         (3)  Liquidated Damages Reminder
    g.  Consequences of Ignoring Construction Schedule

3.  Payment Estimates

    a.  Method of Preparation
         (1)  Submitted by Contractor to Resident Engineer
         (2)  Reviewed and Adjusted by Resident Engineer
         (3)  Negotiated with Contractor
         (4)  Estimate Certified by Resident Engineer
         (5)  Estimate Submitted to Grantee
    b.  Documentation Required
         (1)  Unit Price Contract
         (2)  Lump Sum Contract
             (a)  Contractor's Breakdown
             (b)  Resident Engineer Quantity Records
             (c)  Stored Material Records

4.  Change Orders

    a.  Reviewed Individually
         (1)  Type of Change Order
             (a)  Unit Price Previously Agreed
             (b)  Unit Price Negotiated
             (c)  Agreed Lump Sum
             (d)  Cost Reimbursement
         (2)  Purpose
         (3)  Justification of Need
    b.  Management Elements
         (1)  Independent Engineering Cost Estimate
             (a)  Prepared by Consulting Engineer
             (b)  Reasonably Accurate Estimate of
                  Quantities
             (c)  Detailed Cost and Pricing Data
             (d)  Published Estimating Handbook
             (e)  Informal Local Quotations
             (f)  Advice from Experts
        (2)  Summary of Negotiations
             (a)  Basis for Independent Estimate
                     B-4

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             (b)  Basis for Contractor's Estimate
             (c)  Steps Taken to Review
             (d)  Explanation of Differences
             (e)  Adequacy of Estimate
             (f)  Results of Price Negotiation
             (g)  Basis for Method of Payment
        (3)  Time Extension
             (a)  Approvable for Extra Work Impacting
                 Critical Path
             (b)  Not Approval for Float Time Elements
             (c)  Documentation Required
                  i.    Independent Cost Estimates
                  ii.   Summary of Negotiations
                  iii.  Justification for Time Extension

5.  Shop Drawings

    a.  Process Review
        (1)  Delivery
        (2)  Control
        (3)  Checking
        (4)  Approval
    b.  Process Delays
        (1)  Submittal-Indicative of Poor Schedule
        (2)  Grantee Review - Basis for Extension of Time
             Claim

6.  As-Built Drawings

    a.  Engineering Agreement Requirements
    b.  Specification Requirements
    c.  Preparation
        (1)  What to Look For
             (a)  Currently Posted
             (b)  Sufficiently Detailed
             (c)  Contained in a Bound Set
        (2)  How to Evaluate Sufficiency
             (a)  Difficult
             (b)  Compliance with Specifications Provision
             (c)  Outside Underground Piping

7.  Inspection Reports

    a.  Form
    b.  Detail
        (1)  Weather
        (2)  Work Performed
        (3)  Material Used
        (4)  Work Crew
    c.  Remarks
    d.  Quantities for Payment Estimate Documentation

                     B-5

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              8.  Material Testing and Certificates

                 a.   Specification Requirements
                      (1)  Soils
                      (2)  Concrete
                      (3)  Reinforcing Steel
                      (4)  Pipe
                           (a)   Concrete
                           (b)   Steel
                           (c)   Cast  Iron
                      (5)  Other Material

              9.  Labor Requirements

                 a.   Davis-Bacon Act
                 b.   Ccpeland Act
                 c.   EGO
                 d.   OSHA

          B.  Construction Work - Overall Statement

              1.   Inspection Organization
              2.  Contractor's Organization
              3.  Work Performance

          C.  Recomendations

              1.   Listing of specific Reccmmendations
              2.   Recormsndation should be Impersonal
PART IV   Action Items
          A.  Grantee
          B.  State
          C.  Regional Office
                                   B-6

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                         APPENDIX C

               FINANCIAL MANAGEMENT CHECKLIST
                             for
             CONSTRUCTION MANAGEMENT EVALUATION
A.   General Project Information

     1.   Region
     2.   Grant Number
     3.   State
     4.   Review Date
     5.   Name of Grantee
     6.   Office Address
     7.   Mailing Address
     8.   Telephone
     9.   Chief Executive (Name & Title)
     10.  Designated Contact (Name & Title)
     11.  Jurisdiction
     12.  Project Location
     13.  Project Description

B.   Grantee's Management Organization

     1.   Type of Organization
     2.   Authority for Establishment
     3.   When Established
     4.   Description of Service Area; Communities Served;
            Service Responsibilities
     5.   Description of Ruling Body
     6.   Appointing Authority
     7.   Terms of Appointment
     8.   Principal Manager
          a.    Title
          b.    Name
          c.    Areas and Limit of Responsibility and
               Authority

     9.   Principal Financial Manager
          a.    Title
          b.    Name
          c.    Areas and Limit of Responsibility and
               Authority

     10.  Principal Engineering Manager
          a.    Title
          b.    Name
          c.    Areas and Limit of Responsibility and
               Authority
                             C-l

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     11.  Principal Legal Counsel
          a.   Title
          b.   Name
          c.   Areas and Limit of Responsibility and
               Authority

     12.  Organizational Chart
     13.  Principal Wastewater Facilities
     14.  Principal Regional Agreements
          a.   Community
          b.   Basis/term
          c.   Special Agreements
               (1)  Federal/State
               (2)  Industry
               (3)  Intermunicipal

     15.  Bonding of employees

C.   Procurement System

     1.   A/E Services
          a.   Procurement policies and procedures
          b.   Types of contract
          c.   Sub-contract procurement
          d.   Sub-contract advance approval
          e.   Review of contracts

     2.   Construction Contracts
          a.   Procurement policies and procedures
          b.   Standard grant clauses
          c.   Time for completion/penalties
          d.   Review of contracts
          e.   Exclusionary or Restrictive Bidding
               Requirements

D.   User Charges, Industrial Cost Recovery

     1.   Authority for Imposing Service Charges
     2.   Rate Schedules-Surcharges
     3.   Special Service Agreements
     4.   Industry Service Agreements
     5.   Cost Recovery Provisions P.L. 92-500
          a.   Current Involvement
          b.   Current Status
          c.   Agreements-Basis
          d.   Remaining Actions

     6.   Sewer Use Ordinance
          a.   Legal status/adequacy
          b.   Monitoring-Enforcement
          c.   Industry Pretreatment-Prohibitions
                             C-2

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          d.   Inflow Connections Portion
          e.   Plumbing Ordinance Compatibility

     7.   Infiltration/Inflow
          a.   Analysis
          b.   Survey
          c.   Rehabilitation

E.   Property Control System

     1.   Acquisition System
          a.   Easements
          b.   Titled Property

     2.   Right of Eminent Domain
     3.   Appraisals
     4.   Negotiations
     5.   Where Filed
     6.   Copies of Deeds Available
     7.   Property Insurance, Types, Amounts
     8.   Flood Hazard Insurance
     9.   Property Reporting to EPA R.O.

F.   Local Share Funding

     1.   Bond Issues
          a.   Bond Counsel
          b.   A/E for Engineering Report
          c.   Marketing Method-Experience
          d.   Current Issues, G.O.? Rev.?
          e.   Coverage
          f.   Trustees-Trust Agreements
          g.   Repositories
          h.   Investments
          i.   Debt Service Schedule
          j.   Special Funds

     2.    Short-term Financing
          a.    Purpose
          b.   Terms-Source
          c.    Special Funds

     3.    Synopsis of All Special Funds
          a.    Purposes
          b.    Restrictions
          c.    Transfers

     4.    Annual Budget
          a.    Operations Section
          b.    Debt Service Section
          c.    Other
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     5.   Annual Financial Report
     6.   Audit
          a.   Auditor
          b.   Frequency
          c.   Basis
          d.   Report

     7.   User Charge System/ICR
     8.   Sewer Ordinance

G.   Record Keeping System

     1.   Project Files
          a.   Grant Agreement/Amendments
                (1)  Step 1
                (2)  Step 2
                (3)  Step 3
          b.   Bidding File
                (1)  Advertisement
                (2)- Tabulations
                (3)  State/Federal Approvals
          c.   Acceptance-Notice to Proceed
          d.   Contracts-Bonds-Insurance
          e.   Construction Schedule
          f.   Construction Correspondence Control
          g.   Periodic Payment Estimates
                (1)  Ample Backup of Costs of Work
                    Accomplished
                (2)  Retentions
                (3)  Payment Records
          h.   Change Orders
                (1)  Backup of Cost Produced
                     (a)  Change Notice
                     (b)  Change Estimate
                     (c)  Authorizations
                     (d)  Regional Actions
                     (e)  Cost plus percent-of-cost
          i.   Direct Purchase
          j.   Force Account By Grantee
          k.   Other Charges to Project
          1.   Track of EPA Payment
          m.    Prompt Transmittal/Filing-shop Drawings, etc,
          n.   Wage  Rates - Furnished and Checked
          o.    EEO

     2.   Cost Accounting System
          a.   Audit Trail - cost track  to project  file
          b.    Identifiable eligible/ineligible cost
                              C-4

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c.   Identifiable allowable/unallowable cost
d..   Identifiable direct/indirect cost
e.   Payments made-Retentions-Promptness
f.   Grant Payments received
g.   Direct Purchases
h.   Controls
i.   Etc.
                   C-5

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                         APPENDIX D
                   CONSTRUCTION CHECKLIST
                             for
             CONSTRUCTION MANAGEMENT EVALUATION
A.   General Project Information

     1.   Region
     2.   Grant Number
     3.   State
     4.   Review Date
     5.   Name of Grantee
     6.   Office Address
     7.   Mailing Address
     8.   Telephone
     9.   Chief Executive (name & title)
     10.  Designated Contact (name & title)
     11.  Jurisdiction
     12.  Project Location
     13.  Project Description

B.   General Construction Information

     1.   Principal Inspection Manager
          a.   Title
          b.   Name
          c.   Areas and Limit of Responsibility and
               Authority
          d.   Telephone

     2.   Inspection Staff
          a.   Duties
          b.   Names
          c.   Areas and Limits of Responsibility and
               Authority

     3.   General  Contractor Site Representative
          a.   Title
          b.   Name
          c.   Areas and Limit  of Responsibility and
               Authority
          d.   Telephone
                             D-l

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C.   Plans Specifications and Contracts

          The engineer will first thoroughly study the plans
     and specifications to familiarize himself with the
     project and to arrive at an understanding of the
     responsibilities and duties of the contractor.

          The engineer will study the A/E contract to
     develop a clear understanding of the responsibilities
     of the owner, the A/E and the contractor.  The
     relationship and authority of the three principal
     parties must be clearly understood by the engineer.

D.   Conformance with Plans and Specifications

          The engineer shall visit the construction site  and
     physically inspect both the completed work and the work
     in progress.  The following points will be emphasized:

     1.   Does the contractor appear to be well organized
          and efficiently pursuing the work?
     2.   Does the resident inspector exhibit technical
          competency, initiative; is he well organized and
          observant?
     3.   Is stockpiling of materials adequately protected,
          properly inventoried and readily accessible?
     4.   Does the quality of materials, both stockpiled  and
          in-place meet appropriate standards?
     5.   Has the work in place been properly executed and
          is it visually acceptable?
     6.   Are health and safety measures adequate?
     7.   Is testing of materials being accomplished as
          required by the contract documents?            .3
     8.   Treatment levels maintained during construction?
     9.   Are there procedures for properly controlling
          measured quantities?
     10.  Are the batch plants and manufacturing plants
          producing products which meet the specifications
          and are there proper control procedures?
     11.  Is the overall construction in conformity with the
          plans and specifications?

E.   Resident Engineer and Inspector Organization

     1.   Name
     2.   Employer
     3.   Apparent qualifications
     4.   Staff
     5.   Procedures
     6.   Attendance at site
                             D-2

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     7.    Change  order control
     8.    Schedule  control
     9.    P.E.  opinion of contract  drawings  and
          specifications
     10.   Degree  of dedication  to project
     11.   Procedures for notifications to  contractor
     12.   Relationship with Design  Engineer
     13.   Authority (documented,  to "act for"  grantee,
          limitations, etc.)                          .
     14.   Contractor-Engineer relations (friendly,  fair,
          firm, businesslike and cooperative)
     15.   Inspector(s) personally knowledgeable,  good
          judgment, responsible)
     16.   Plans and Specifications (reference  set,
          marked-upf amendments, changes)
     17.   Progress Schedules (changes, slippages)
     18.   As-built drawings  (set kept current for record)
     19.   Inspectors guidance (formal)

F.   Contractor Organization

     1.   Name and Qualifications                    .
     2.   Equipment (appear adequate in number and size for
          schedule and/or safety)                  .
     3.   Personnel (sufficient for safe and efficient
          prosecution of the work)                   .
     4    Supervisory personnel  (organizational  ability)
     5    Field Office and Shops (well placed, without
          safety or health hazard, adequately sized)
     6.   Storage  area  (well organized, protected)

G.   Work Performance
 c
     1.   Work in  place (properly  executed)

          a.   Site
 E             (1)  Appearance
               (2)  Safety  - security
rft             (3)  Project  Sign
               (4)  Materials  Storage
               (5)  Dewatering - Drainage
          b.   Foundation Work
                (1)  Dewatering - Shoring
                (2)  Piling
                (3)  Material Consolidation
          c.   Concrete
                (1)  Appearance
                (2)  Samples
                (3) Condition  of Reinforced Steel  - Steel
                     Location
                              D-3

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           (4)  Formwork - Bracing
           (5)  Curing Procedures
           (6)  Inserts
           (7)  Expansion Joints - Waterstops
           (8)  Contiguous Pours
     d.   Structures
           (1)  Masonary
           (2)  Steel Frame
           (3)  Substitutions
           (4)  Roofing
     e.   Mechanical
           (1)  Conformance
           (2)  Condition
           (3)  Installation
           (4)  Protection
     f.   Electrical
           (1)  Conformance
           (2)  Condition
           (3)  Installation
           (4)  Protection
     g.   Pipelines
           (1)  Materials
           (2)  Installation
           (3)  Testing

2.   Safety (personnel, equipment and site)
3.   Site drainage (adequate)
4.   Dust control (maintenance of roads, stripped
     areas)
5.   Erosion protection (in place and planned).
                        D-4

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                         APPENDIX E
               CONSTRUCTION RECORDS CHECKLIST
                             for
             CONSTRUCTION MANAGEMENT EVALUATION
A.   General Project Information

     1.   Region
     2.   Grant number
     3.   State
     4.   Review date
     5.   Name of grantee
     6.   Office address
     7.   Mailing address
     8.   Telephone
     9.   Chief executive (name & title)
     10.  Designated contact  (name & title)
     11.  Jurisdiction
     12.  Project location
     13.  Project description
     14.  Reviewer

B.   General Construction Information

     1.   Principal inspection manager
          a.   Title
          b.   Name
          c.   Area and limit of responsibility and
               authority
          d.   Telephone

     2.   Inspection staff
          a.   Duties
          b.   Names
          c.   Areas and limits of responsibility and
               authority

     3.   General contractor  site representative
          a.   Title .
          b.   Name
          c.   Areas and limit of responsibility and
               authority
          d.   Telephone
                              E-l

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C.   Resident Engineer and/or Inspector Information

     1.   Employer
     2.   First arrived at project
     3.   Work hours
          a.   Normal
          b.   Authority to Work Overtime
     4.   Communications
          a.   To Employer
          b.   On-Site
     5.   Inspection equipment furnished
     6.   Office security
          a.   Method
          b.   Evidence of tampering
     7.   Inspector's library
          a.   On-site office
          b.   Manuals

D.   Working Papers

     1.   Contract drawings and specifications
          a.   Does inspector have approved set?
          b.   Is superintendent working from approved set?
          c.   Are changes being kept current by both
               parties?
          d.   Are they supported by working sketches?
               (1)  Source
               (2)  Completeness
               (3)  Admini stration
          e.   Do subcontractors have sufficient sets?
          f.   Are all contractors obligated to furnish
               as-built drawings?
               (1)  In what form?
               (2)  If not, who furnished?

     2.   Shop Drawings
          a.   Delivery procedure
          b.   Storage and filing system
          c.   Approval system
               (1)  Who has responsibility?
               (2)  Mechanism
               (3)  Turn-around time
               (4)  Substitutions
               (5)  Log
               (6)  Ahead of deliveries?

     3.   Construction Schedule
          a.   Is one required?
          b.   Who prepares?
          c.   Format
          d.   Date furnished
          e.   Conforms to specified completion?

                             E-2

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     f.    Obvious conflicts
     g.    Who updates?
     h.    Agrees with partial payment request?
     i.    Up to date?
     j.    Reaction to delays
          (1)  Inspector's actions
          (2)  Superintendent's actions
          (3)  Current status
     k.    Reflects stop orders, approved delays?

4.   Requests for Partial Payments
     a.    Frequency
     b.    Who prepares and verifies
     c.    Format
     d.    Treatment of work in process
     e.    Allowance for materials on site
          (1)  Protection requirements
          (2)  Determining value
     f.    Subtrade documentation
     h.    Treatment of specifically manufactured items

5.   Force Account Records
     a.    Force account used on what elements of
          project?
     b.    Is RA preapproval documented?
     c.    Format
     d.    How are quantities kept and verified?
          (1)  Labor
          (2)  Materials
          (3)  Overhead

6.   Correspondence                            .
     a.   What  level  of correspondence  can be  initiated
          by project  engineer  for construction?
     b.   With  grantee
     c.   With  utilities
     d.   With  general contractor
          (1)   Reasons
          (2)   Actions ordered
          (3)   Control procedures
          (4)   Stop  work  orders
          (5)   Other

7.   Current Deficiencies
     a.   Immediate  action items
     b.   Preliminary punch list
           (I)   Is one being created?
           (2)   Mechanism for adding an item
           (3)   Is it current?
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     8.   Spare Parts Inventory
          a.   Are spare parts required?
          b.   Is inventory being created?
          c.   Who prepares?
          d.   Is it current?
          e.   Does it conform to specifications?

E.   Job Records

     1.   Inspector's Daily Reports
          a.   Is set complete to date?
          b.   Do assistants have separate reports?
          c.   Format
               (1)  Complete heading
               (2)  Record of construction activity
               (3)  Record of quantities
               (4)  Special instructions
               (5)  Basis for change orders
               (6)  Remarks on progress
               (7)  On-site tests
               (8)  Demonstrate methods of quantity control
                    and measurements?
          d.   Correlates with partial payment request
          e.   Stop work orders

     2.   Diaries
          a.   Are they kept?
          b.   Can we inspect?
          c.   Do they record measured quantities?

     3.   Change Orders
          a.   Number
          b.   Total value
          c.   Is negotiation complete prior to initiation
               of change work?
          d.   Procedures for change order over $100,000
          e.   Amount by trades
               (1)   Total each trade
               (2)   Relationship to subbids
          f.   Format'
          g.    Specification basis
          h.    Completness of documentation
          i.    Procedures for creation
          j.    Appropriateness for costing method
          k.    Reflection of quality of contract drawings
               and specifications
              -(1)   Interpretation of justification for
                    each?
               (2)   Is value realistic?

                             E-4

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          (3)   Is there a contract provision for
               unilateral ordering of changes?
          (4)   Quality of A/E documents
     1.    Or-equal violations
     m.    Minor changes trade-off file
          (1)   Is there one?
          (2)   Is it formal/informal?
          (3)   Are trades consistent?
          (4)   Are trades shown on as-built drawings?

4.    Records of Tests
     a.    Requirements clauses in A/E contract and/or
          specifications?
     b.    List from specifications
     c.    Conformance to schedule
     d.    Who pays for testing?
     e.    Names of testing laboratories/certification
          procedures
          (1)   Soils
          (2)   Concrete
          (3)   Pipe
          (4)   Rebars
          (5)   Welds
          (6)   Paint
          (7)   Other
     f.    Test results indicate need to inspect
          manufacturing plants?
     g.    Authority to reject materials
          (1)   Source
          (2)   Record of actions
          (3)   Frequency of  rejections

5.   Operation and Maintenance Requirements
     a.   Do manufacturer's  manuals  arrive  at same  time
          as equipment?
     b.   Are manufacturer's respresentatives available
          during  installation?
     c.   Is a draft of O&M  Manual available  at  site
           (note percent completion of  project)?
     d.   Operator  input to  draft O&M  Manual
           (1)  Reommendations
           (2)  Inventory
           (3)  Contacts with suppliers

6.   Plant Operator Information
     a.   Has  he/she/they  been hired (note  percent
          completion  of project)?
                         E-5

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          b.   License
               (1)  State/local requirement?
               (2)  Grade
               (3)  Training in lieu of license
          c.   Does operator have conflicting duties?
          d.   Accountability for operator's time
          e.   Reporting responsibility
          f.   Staffing conform to staffing plan?

F.   Documentation

     1.   Certificates
          a.   Mill
          b.   Pipe
          c.   Guarantees register
          d.   Other

     2.   Davis-Bacon and Wage Hour Law Requirements
          a.   Secretary's determination
               (1)  Posted
               (2)  Correct rates

     3.   EEO Notice Posted?
          a.   Weekly payrolls
               (1)  Copies delivered
               (2)  Conform to inspector's reports
               (3)  Correct rates
               (4)  Complaints about wage payments

     4.   Emergency Procedures
          a.   Are signs posted?
               (1)  Electric
               (2)  Flammable
               (3)  Ventilation
               (4)  Dangerous liquids
               (5)  Emergency showers
               (6)  First aid equipment
               (7)  Firefighting equipment
               (8)  Breathing equipment
               (9)  Chlorine tank repair equipment
          b.   Telephone numbers posted?
               (1)  Fire Department
               (2)  Police
               (3)  Utilities
               (4)  Grantee
               (5)  A/E
               (6)  Contractor nights/weekends
               (7)  Other
          c.   OSHA Regulations
               (1)  Available on site
                             E-6

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               (2)   Accident records
               (3)   OSHA inspector comments

     5.    Permits
          a.    Building
          b.    Trades
               (1)   Electrical
               (2)   Plumbing
          c.    Corps of Engineers
           :    (1)   Waterways
               (2)   PL 92-500, Section 404
          d.    State requirements

     6.    Delivery Documents
          a.    Concrete truck slips
          b.    Copies of invoices
          c.    Systematic filing
          d.    Verification system
          e.    Delivery control
G.   Remarks
                              E-7

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