&EPA
United States
Army Corps of Engineers
September 1983
United States
Environmental Protection
Agency
Office of Water
Program Operations (WH-547)
Washington DC 20460
Operating Procedures for
"Monitoring Construction
Activities"--
at Projects Funded under the
Environmental Protection
Agency's Construction
Grants Program
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OPERATING PROCEDURES FOR MONITORING CONSTRUCTION ACTIVITIES
AT PROJECTS FUNDED UNDER THE ENVIRONMENTAL PROTECTION AGENCY'S
CONSTRUCTION GRANT PROGRAM
U.S. Army Corps of Engineers/
U.S. Environmental Protection Agency
September 1983
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TABLE OF CONTENTS
Page
1. Purpose 1
2. References 1
3. General 2
4. Interim Inspection 2
5. Frequency of Inspections 2
6. Related Activities 3
7. Preconstruction Conference 3
8. Documentation and Preparation 4
9. Interim Inspection Procedures 5
10. Scope of Interim Inspections 6
11. Grant Management and Record Keeping 7
12. Construction Management 9
a. Progress Charts and Schedules
b. Payment Requests
c. Change Orders
d. Claims
13. Construction 13
a. Quantity
b. Quality
14. Final Construction Inspection 15
15. Reporting 15
16. Follow-up 17
Appendix A - Inspection Related Functions I
Appendix B - Grantee Files II
Appendix C - Guide to Grantee's Cost Accounting
and Internal Control System IV
Appendix D - Contract Administration Checklist VI
Appendix E - Construction Management Evaluations (CMEs)
and Project Management Conferences (PMCs) VIII
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1. PURPOSE: The primary purpose of this document is to provide
general operating guidance to "Agencies" (Corps/States/EPA)
performing construction inspections and related activities on
projects funded under the Environmental Protection Agency's
Construction Grants Program.
The Corps, State or EPA representative ("Inspector") is the
person(s) responsible for conducting official project
inspections to determine grantee compliance with program
requirements during the construction phase of a Step 3 grant.
2. REFERENCES:
a. 40 CFR Parts 30, 33 and 35.
b. EPA Handbook of Procedures (Second Edition).
c. EPA Construction Grants 1982 (CG-82)
d. ER 415-2-4, Corps Support for EPA Construction Grants
Program, October 1, 1983.
e. EPA Regional Guidance Documents.
f. EPA/Corps of Engineers Interagency Agreement.
g. EPA/Corps Regional Interagency Agreements.
h. State Delegation Agreements.
i. EPA Construction Inspection Guide (1976, 3 volumes).
j. (EPA) Management of Construction Change Orders -- A Guide
for Grantees (1983).
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k. EPA Construction Management Evaluation (CME) Manual
(1983).
1. (EPA) Accounting Guide for Construction Grants (October,
1977).
3. GENERAL; The Agency role in the EPA Construction Grants
Program will vary according to the status of the delegation of
grant management functions in individual States. The re-
commendations contained herein should be considered as
guidance and modified as necessary in view of the specific
responsibilities and procedures outlined in State Delegation
Agreements and EPA/Corps Regional Interagency Agreements. It
is expected that these Agreements, as appropriate, will be
revised or supplemented to reflect this guidance.
4. INTERIM INSPECTION; The purpose of the interim inspection is
to determine if the grantee is effectively managing
its construction grant by: (a) meeting all standard and
special grant conditions, (b) maintaining adequate record
keeping and accounting systems, and (c) providing adequate
construction and contract management, including maintenance of
project schedules and construction quality control. Also, as
appropriate and in keeping with the limits of his
responsibility, the Inspector will provide the grantee with
needed grants management advice and assistance.
5. FREQUENCY OF INSPECTIONS; The frequency with which projects
are inspected should be determined by the rate of progress
being achieved and the nature of problems or issues arising
during construction. Generally, each project should be
inspected monthly. Where the project is found to be
progressing well and the grantee has demonstrated a high
level of project management capability, bi-monthly or even
quarterly visits may suffice.
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6. RELATED ACTIVITIES; Appendix A lists related grant
management functions, some of which may be evaluated during
an interim inspection. While this guidance document does not
attempt to cover all aspects of these functions, some
peripheral discussion is included where the function has a
direct relationship to the interim inspection.
7. PRECONSTRUCTION CONFERENCE: The preconstruction conference
is the first meeting which will be attended by all parties
involved in construction of the project. (The preconstruc-
tion conference should be followed or preceeded by a Project
Management Conference (PMC); see Appendix E). The Inspector
should use the preconstruction conference to advise the
participants of the Agency role in the grants program and to
establish procedures and responsibilities for the interim
inspection process. The following are typical points that
should be clarified during this meeting:
a. Points of contact with the grantee and grantee's
management staff. Determine from the grantee who
should be contacted on interim inspection matters.
The grantee's "Authorized Representative" should be
notified of formal actions. A list of contacts
should also include the State/EPA project officers
and the resident engineer/inspectors(s). An
understanding should be developed regarding clear cut
lines of authority and responsibility.
b. Grantee/State/Corps/EPA interrelationships.
c. Access to the work will be provided to representa-
tives of the Corps, EPA and State whenever it is in
progress, and the contractor will provide proper
facilities as required by the Inspector.
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d. Schedules and notification procedures.
e. Flow of documents, e.g., payment requests,
change orders, inspection reports.
f. Change order review and approval process.
g. Payment review process, including development of
payment schedules.
h. Where appropriate, distinctions between
Corps/State/EPA roles in construction monitoring
and O&M activities.
i. Use of an EPA approved form or format for formal
inspection reports submitted by the Corps.
Since the Agency's tie to the project is with the grantee
(through the construction grant), and the contract is between
the grantee and the contractor, Agency contacts with or
influence on the project must be made with or exercised
through the grantee or his authorized representative. Direct
contact with the contractor by the Inspector or any other
Agency representative should be limited to the minimum
necessary to gain a full understanding of contract
matters.
8. DOCUMENTATION AND PREPARATION: The Inspector will need copies
of various grant and contract documents in order to prepare
for and conduct interim inspections. Arrangements should
be made to obtain, as needed, the following:
a. Copies of the grant award documents with all
standard and special conditions and amendments.
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b. Copies of approved contract plans and specifications
and all addenda.
c. Copies of engineering services contracts.
d. Copies of executed construction contracts with com-
pleted bid schedule, notice to proceed, and approved
change orders.
e. Access to all payment requests, including backup
documentation.
f. Copies of all milestone approval letters and other
pertinent grant and contract correspondence.
g. Copies of construction permits.
9. INTERIM INSPECTION PROCEDURES; The Inspector should become
thoroughly familiar with the project by examining the plans
and specifications, the construction grant agreement(s), and
other available documents. Due to limited resources, it may
not be possible to thoroughly review every aspect of grant
and contract management at each interim inspection. On
larger projects the Inspector may have to select areas to
review at each inspection such that, over the life of a
project, all significant aspects of grant and construction
management, and construction quality, quantity and initial
operability will be covered. However, every effort should be
made to look over the entire construction site at each visit.
On smaller projects only a total inspection should be
considered a complete inspection.
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The nature of the program also requires that the Inspector
become familiar with various engineering disciplines in
order to inspect the civil, mechanical and electrical portions
of a project. On some larger or more complex projects, it may
be necessary to draw on the expertise of specialists within
the Agency to assure adequate inspection coverage.
Inspections should be coordinated in a timely manner with all
interested parties; however, the number of participants should
be limited to those having direct responsibility for grant
and/or contract management. Keep in mind that the grantee has
the ultimate responsibility for the project and all
coordination should be through its designated representatives.
All inspection activities should be conducted in a courteous
and professional manner. In addition to pointing out
deficiencies, the inspection should be used to provide
assistance (as appropriate) to the grantee in grant related
matters.
Where the Corps is performing inspections, the State should be
notified as provided for in procedures set forth in the
Regional Interagency Agreement. Generally, written notice is
given to the State at least two weeks in advance of the
specific inspection.
Provision should also be made for inspections which are not
announced to the grantee. The frequency of unannounced
inspections will be determined by the Inspector's findings
or information brought to his attention.
10. SCOPE OF INTERIM INSPECTIONS; There are three major areas of
project management that must be covered during the course of
interim inspections. These include: (a) grant management
and record keeping, (b) contract administration and (c) con-
struction quantity and quality. These items are discussed in
detail in Pars. 11-13, below.
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11. GRANT MANAGEMENT AND RECORD KEEPING; The grantee has the
ultimate responsibility for management of its construction
grant. Some grantees handle the entire grant management
process with their own forces, while others may utilize the
services of their consulting engineer or private accountants
and attorneys. The Inspector must first determine the
responsibilities and authorities of the various grantee
representatives and the location of all files. Generally,
grant management files are maintained in the grantee's office
and the consulting engineer's office. Construction records
will normally be located at the job site. The inspection
should ascertain:
a. Are authorities and responsibilities for managing the
grant adequately defined, and are all aspects of
grant management appropriately assigned?
b. Are payment requests and funds being properly
managed (timely requests and disbursements)?
c. Are grant standard and special conditions being met?
Milestone activities which are conditions of EPA pay-
ments should especially be monitored in advance of
the milestone date and the grantee advised accord-
ingly. The requirements for most milestone activi-
ties vary as the Federal laws and regulations have
changed over the years. The Inspector should always
check the grant requirements of the particular
project being inspected. Typical milestone
submittals include:
(1) Final plan of operation.
(2) Final operation and maintenance manual.
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(3) Compliance dates for special grant conditions.
(4) NPDES compliance schedules dates.
(5) Budget/project period (dates).
(6) Initiation of operation date.
(7) Performance certification date.
(8) MBE/WBE compliance documentation: submittal
dates.
d. Are grant records complete, segregated, orderly and
up-to-date? A review of the grantee's record keeping
system should be made during the first interim
inspection and may be repeated during later
inspections. The purpose of this review is
not to audit the contents of the files, but to
evaluate the results of advice given during the
PMC on the content, methods, and procedures and thus
assure that the grantee's filing system will
facilitate the final payment, EPA audits and grant
closeout. Appendix B contains further discussion of
this item and a checklist for review of files.
(Provide the grantee with a copy of EPA's Accounting
Guide for Construction Grants, 1977).
Generally, the requirements of 40 CFR 30.800 and 30.805
include maintaining records which provide an accurate,
current, and complete disclosure of the financial transactions
of the grant. These records should show the amount, receipt,
and disposition of all grant related funds, and the total
costs (both direct and indirect) of the project. These
records must be maintained in a manner that separates allow-
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able and unallowable project costs. The Inspector should
check to see that the grantee's records fulfill these require-
ments. (On large grants, he may wish to enlist assistance
from an auditor.) See Appendix C.
12. CONSTRUCTION MANAGEMENT; Resident services and contract
management are normally furnished under a service contract by
a consulting engineer. Some grantees may perform inspections
using their own forces. Appendix D is a checklist of typical
items that should be monitored by the Inspector. This is not
meant to be all inclusive, and the Inspector should review the
requirements of the construction contract documents and the
engineering services contract to determine other points of
interest. The following items should receive special emphasis
during an inspection, since they could significantly impact
the overall progress and fiscal status of the grant:
a. Progress Charts and Schedules - The contractor is
normally required to submit a progress chart to the
grantee and keep it current. The Inspector should
determine that a progress chart has been prepared for
each contract and that it reasonably reflects
proposed and actual progress. If it appears that
the contrator is behind schedule, the grantee should
be notified and advised to take appropriate action to
require the contractor to outline his plan to meet
the schedule and to require timely completion. All
such actions should be carefully documented. (40 CFR
35.2204 (b) (3) requires a formal grant amendment for
significant changes to the project schedule.) The
grantee should be cautioned not to take any action
that could result in a claim for acceleration or for
delay of the progress of work. If it appears that
the contractor will not complete the work within the
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required completion date, the grantee should be
advised that assessment of liquidated damages as a
contract requirement is an option which may be
exercised only by the grantee. It should also be
stressed that it is in the grantee's interest to
assess liquidated damages. EPA will not participate
in inspection costs beyond the EPA approved contract
completion date unless the time extension is
authorized by an approved change order. If the
project completion date is delayed, a grant amendment
will be required if costs incurred after the initial
completion date are to be considered for EPA
participation.
b. Payment Requests - The grantee's payment requests to
EPA should include only that backup documentation
required by EPA. Documentation which should be
available for review includes the contractor's
periodic partial payment request, engineer's
invoices, and miscellaneous costs. The Inspector
should review the contractor's payment request and
compare it to conditions at the job site to assure
that the quantities for which payment is being
requested generally conform to visual observations of
actual progress. This should not be done in minute
detail, although the Inspector should develop a
tracking system to satisfy himself that the amounts
claimed by the contractor on payment requests are
reasonably accurate. This would also include
verification of any stored materials and change order
work claimed on the request. (Change orders must be
properly executed and approved by all agencies having
authority before EPA reimbursement can be made.)
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EPA normally permits retainage to be withheld on the
contractor's partial payment requests. The Inspector
should review the terms of the contract to assure
that the specified retainage clause is being properly
administered, and, near the end of project, that the
grantee is retaining only an amount sufficient to
protect its interests in completing the project.
The Inspector's review of the grantee's payment
request should be coordinated with the overall EPA
grant payment review and approval process.
Change Orders - Change orders represent a major area
of concern in the grants program (Ref.j). The
Inspector should be alert to conditions that might
give rise to the need for change orders, so he can
advise the grantee on how best to proceed, manage
costs and facilitate approval. During interim
inspections the following areas should be emphasized,
particularly with small grantees.
(1) Provide advice to the grantee on the need for
the proposed change/ as appropriate.
(2) Assure that the grantee is processing change
orders in a timely fashion, including those for
time extensions.
(3) Advise the grantee on what is required during
the review process on such matters as prior
approval, proper format, justification, working
estimates, records of negotiation, reasonable
pricing, etc.
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(4) Assure that the resident inspector or engineer
has copies of all executed change orders.
(5) Become knowledgeable of the facts regarding the
change order to assist later in the review pro-
cess .
(6) If other than a State, the Agency should
coordinate with the State.
(7) Inspect the completed change order work.
d. Claims - A claim is any written demand by the
contractor for additional costs or time. Most claims
are settled prior to extensive litigation or arbitra-
tion and are treated as routine change orders. It is
the occasional claim that is not settled that is of
special concern to EPA. As in the case of change
orders, the Inspector should advise the grantee on
matters concerning all claims. The same factors
listed in Par. 12.c, above, must be addressed
in the processing of claims, with special emphasis on
timely and accurate documentation by the grantee.
However, when it appears that the contracting parties
cannot agree on a mutual settlement, the Inspector
should immediately advise the project manager
(EPA/State/Corps) that the claim may result in
litigation or arbitration. Costs associated with
litigating claims may be allowable if the work is
determined to be otherwise allowable and the costs
were not incurred as a result of grantee
mismanagement or errors by its consultant(s).
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(See Appendix A to Subpart I (40 CFR).) Prior
approval and, in some cases, a grant amendment are
required for EPA participation in litigation costs
associated with claims. A grantee should be advised
to contact the project officer for complete details
on allowable costs and procedures for handling
formal claims.
The Inspector should not attempt to engage in
negotiations or manage the situation for the grantee.
The grantee should be encouraged to perform an
independent analysis of the issues and negotiate
settlement of those issues which have merit.
13. CONSTRUCTION:
Quantity - An important purpose of the interim in-
spection is to assure that the project is constructed
in accordance with the approved plans and specifica-
tions. The Inspector must review the contract
documents and develop a system for documenting
completed activities. Each interim inspection
should address work added since the last inspection
and address prior deficiencies. The cumulative
effect should be to greatly reduce the total effort
on the final construction inspection. Over the life
of the project, all significant aspects of the pro-
ject should have been covered. The Inspector should
keep in mind that much of the work accomplished
between inspections will be concealed as the
construction progresses and thus not be accessible
for inspection. His efforts should be directed more
toward the overall project and on major structures,
major equipment and operating systems rather than on
minor components or details.
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b. Quality - Responsibility for quality control (QC) may
rest with the contractor, the resident engineer, or,
as in most cases, a combination of the two. The
Inspector should determine from the contract
documents the extent of QC responsibility that each
party has. Following are items that should be given
special attention during the interim inspection:
(1) Review the resident inspector's daily reports or
diary. Check the reports prepared since the
last interim inspection to see what deficiencies
may have been noted and what actions were taken
(and recorded in the daily log) to correct
the deficiencies.
(2) Review contractor certified submittals of shop
drawings on a selective basis to assure that
they meet the requirements of the contract
documents. The submittals should be processed
by the grantee's engineer* in a timely manner
and copies furnished to the resident engineer.
(3) Review concrete, soil compaction and other QC
tests required by the contract. If any tests
failed, determine what action was taken by the
resident engineer.
(4) Review documentation on performance tests to
assure compliance with contract documents.
* Engineer accepts, accepts with reservations or requests
resubmittal.
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(5) Make selective field observations, in addition
to the overall field inspection, to determine
that QC requirements are being carried out.
(6) Any deficiencies noted should be reported to the
grantee or its representative and included in
the trip report. Hazards to public health,
safety and welfare should be corrected as soon
as possible.
14. FINAL CONSTRUCTION INSPECTION; Although the final construc-
tion inspection is considered to be a separately delegable
activity by EPA, it is so interrelated with interim inspec-
tions that it needs to be addressed in this guidance
document. As discussed above, each interim inspection is
simply one step toward the final construction inspection. If
interim inspections are properly conducted and documented,
the final construction inspection should be simply a
formality to wrap up loose ends and address any uncorrected
construction deficiencies. The Inspector should use his
judgment on the necessity for follow-up inspections on
construction deficiencies. Major deficiencies may require
one or more follow-up inspections, while minor ones should be
left for the consulting engineer to certify prior to the
construction closeout. Commitments on the time required to
correct deficiencies should be obtained.
15. REPORTING; Every interim inspection should be documented with
a written report. Formats and procedures may vary according
to Regional agreements and Agency policy. As a minimum, each
report should address the following:
a. Basic grant information.
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b. Basic contract information.
c. Status of grant.
d. Status of each contract.
e. List of attendees.
f. List of deficiencies noted since last report
with recommended actions for resolution.
g. Comments on status of any previous deficiencies.
h. List of known disputes, claims or potential
claims or change orders.
Any deficiencies that are to be noted on the report are to be
discussed with the grantee and engineer during the interim
inspection to assure that there is a clear understanding of
the matter and what should be done to correct the problem.
Grant management procedures for resolution of deficiencies
will depend on the status of delegation in each State.
Distribution of interim inspection reports will also be
subject to Regional agreements. Generally, the State, the
grantee and its consulting engineer should be furnished
copies. The contractor should not be furnished copies of
inspection reports, since it could mistakenly interpret
comments as directives that would prejudice the grantee's
contracting authority. Reports should be transmitted by
letter, the content of which should identify significant
findings and/or construction deficiencies. The transmittal
letter should be short, concise and able to stand on its
own merit.
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16. FOLLOW-UP; The Inspector should determine who is responsible
for taking various corrective actions and have a system for
assuring that the responsibile official(s) is advised and
does, in fact, act.
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APPENDIX A - INSPECTION RELATED FUNCTIONS
The following are separately delegable functions that may be per-
formed by the Corps, the State, EPA or a combination. Each is
closely related to functions performed during interim inspections.
The Inspector should review the Regional and State delegation
agreements and be familiar with the activities, responsibilities,
and authorities (if any) that distinguish each of these functions
from those of the related portions of the interim inspection. Some
may be accomplished during the interim inspection.
1. Overall grant management.
2. Approval of contract documents and authority to award.
3. Preconstruction conferences.
4. Project Management Conference (PMC).
5. Review and approval of progress payments.
6. Review and approval of change orders.
7. Conventional/extended Construction Management Evaluation
(CME).
8. WBE/MBE tracking.
9. Claims resolution assistance.
10. Outlay management.
11. Review and approval of O&M manual and final Plan of
Operation.
12. Final project inspection.
APPENDIX A
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APPENDIX B - GRANTEE FILES
A well organized and properly maintained filing system is essential
to the proper administration of an EPA construction grant. It
will also prove to be invaluable during the final audit and
closeout of a project. This list of recommendations is not meant
to be all inclusive, but serves to point out the typical problem
areas experienced by EPA reviewers on past projects.
1. All files for each Step 3 EPA grant should be maintained
separately from any other Step 1, Step 2 or Step 2+3
EPA grant.
2. All EPA files should be maintained separately from
any other agency files (FmHA, HUD, etc.).
3. All files should clearly distinguish between EPA allowable
and unallowable items.
4. All files should be neatly organized by subject matter in
separate folders and located in a file cabinet or drawer.
5. Contents of individual folders should be filed in a timely
manner and in chronological order.
APPENDIX B
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APPENDIX B - GRANTEE PROJECT FILE TOPICAL SUBJECT LISTING (SAMPLE)
Grant
Administration
Documents
Construction
Management
Records
Accounting
Source
Documents
0 USEPA Grant Offer
& Conditions
0 Grant Amendments
0 State NPDES Permit
0 Auth, to Award
0 Interagency Agree-
ments
0 Plan of Operation
0 User Charge System
0 Contracts & Sub-
agreements
0 Flood Disaster
Protection Act
0 Sewer Use Ordinance
0 O&M Manual
0 Davis-Bacon Act
Compliance
0 Force Account
Approvals
0 EEO, MBE/WBE
Requirements
0 Real Property
Acquisition
Documents
0 Pretreatment
Systems
0 Emergency Pre-
paredness Plans
0 Maintenance
Management Systems
0 Copeland Act
0 As-Bid Construction
Contracts
0 Bid Tabs
0 Executed Contract
Agreements & Sup-
porting Documents
Schedule
0 Progress Payments
0 Change Orders
0 Claims
0 Inspection Reports
0 Materials Test
Reports
0 Meeting Minutes
0 Correspondence
0 SubmittaIs Logs
0 As-Built Drawings
0 Equipment War-
ranties
0 Payment Schedule
0 Outlay Reports
0 Force Account
Payroll Records
0 Invoices
0 Property Control
Fixed Assets
Records
0 Cash Income Re-
ceipts
0 Cash Disburse-
ments (Cancelled
Checks)
0 Construction Dis-
bursements
0 Transaction Appro-
val Records
0 Bank Statements
APPENDIX B
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APPENDIX C - GUIDE TO GRANTEE'S COST ACCOUNTING
AND INTERNAL CONTROL SYSTEM
1. Does the grantee1s organization provide for separation of
responsibilities for operations review from control over
financial transactions?
2. Has the grantee established project accounting records to
record, on a current basis, all incurred costs applicable to
EPA work?
3. Are books and records used to document and control construc-
tion fund receipts and cash disbursements?
4. Do the grantee's books and records conform to a uniform
accounting system? Are accounting procedures documented?
a. Is a general ledger with control accounts used?
b. Are subsidiary cost accounts established to segregate
project costs?
c. Are grant unallowable costs segregated in the
grantee's accounting system?
d. Does the accounting system differentiate between
unallowable and allowable, and direct and indirect
costs?
5. Are project costs summarized and reconciled with control
accounts contained in the grantee's general ledger?
APPENDIX C
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APPENDIX C
6. Are written approvals given for each step of the disbursements
review process?
7. Is appropriate documentation maintained to support all direct
charges to the project?
8. Is change order work separately identified in the respective
project cost records?
9. Are the project cost records used as the basis for:
a. The grantee's "Outlay Report and Request for
Reimbursement"?
b. The consultant's request for reimbursement?
10. Are the grantee's accounting records subjected to an indepen-
dent audit at least once every two years?
11. Are cost and price analyses of contractor proposals carried
out in accordance with EPA grant regulations?
APPENDIX C
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APPENDIX D - CONTRACT ADMINISTRATION CHECKLIST
1. Limits of inspection service provided.
2. Daily inspection report is prepared and adequate; follow-up
actions on deficiencies are properly noted.
3. Approved plans and specifications on site.
4. As-built drawings are maintained.
5. Shop drawing register is established and maintained.
6. Progress schedule is posted and current.
7. Contractor's progress is monitored.
8. Stored materials register is established and maintained.
9. Delays are documented and action taken to improve progress.
10. Copies of all executed change orders on site.
11. Project sign located in prominent position.
12. Wage rates and EEO notice posted by contractor.
13. Continuous operation of existing plant assured; bypassing
during construction (if applicable) is justified and approved
by State Agency.
14. Construction (quality and quantity) conforms to plans and
specifications and latest payment request.
APPENDIX D
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APPENDIX D
15. Materials properly stored and protected.
16. Materials testing is being performed and documented.
17. Performance testing is being performed and documented.
18. Payrolls are submitted weekly and reviewed.
19. Environmental effects mitigation implemented.
20. Required submittals identified, scheduled, coordinated.
21. Claims file established; claims investigations documented.
22. Materials acceptances/rejections documented.
23. Contractor notified of required retesting and/or replacement?
24. Materials testing/replacement documented?
APPENDIX D
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APPENDIX E - CONSTRUCTION MANAGEMENT EVALUATIONS (CMEs)
AND PROJECT MANAGEMENT CONFERENCES (PMCs)
A CME is a thorough evaluation (on-site) of all aspects of project
management and is generally conducted when construction is 40% -
60% complete. The CME should be held earlier (20% - 40% stage)
if a PMC has not been conducted.
The objective of CMEs is to evaluate grantees' management of
construction grant projects and, through this process, gain
insight into the overall management of the construction grant
program as well as into practices which bring about the reduction
of waste, fraud and mismanagement of Federal funds.
Typically, the on-site CME should be conducted by a three or more
member team composed of staff from the EPA Regional Office (who
will generally serve as team leader), the State Agency and the
Corps. The team leader would be responsible for reviewing grantee
records, procurement procedures and grant management procedures in
the grantee's office. Reviews by the other team members would be
concentrated on the project field records, construction management
procedures, and physical construction.
A conventional CME is expected to take four or five days to
complete. Where larger, more complex projects are involved, an
extended CME — with a five to ten day review period — would be
required.
APPENDIX E
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APPENDIX E
The Program Management Conference (PMC) is conducted to provide
guidance to grantees on record-keeping requirements, construction
management techniques and overall grant project management
procedures. It is generally one to three days in duration,
depending on the capabilities of the individual grantee, and should
be conducted before the start of construction on virtually all Step
3 and Step 2+3 projects.
The conduct of the PMC is an appropriate function for the Corps or
State agency. Normally, it should be held immediately after the
preconstruction conference and concentrate on the detailed
requirements of construction grant project management. However, in
certain cases it may be beneficial to conduct portions of the PMC
(records system, accounting system, grant conditions review, etc.)
prior to the preconstruction conference.
A PMC is not required for projects already under construction.
Procedures for conducting CMEs and PMCs are described in the CME
manual (REF.K).
APPENDIX E
Page 2 of 2
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