Fort Gordon Environmental Cleanup Features Performance-Based Contract

[CPEO Moderator <cpeo@cpeo.org>]

The following can be viewed online at:
http://aec.army.mil/usaec/publicaffairs/update/win04/win0401.html
__________________________________________________
Fort Gordon Environmental Cleanup Features Performance-Based Contract

By Neal Snyder
Update Editor

Photo by Neal Snyder
A water sample is carefully capped to avoid air contamination.
Brian Maillet carefully unreels a length of yellow measuring tape and
slides the end down a narrow well. The reel bleeps and Maillet, a staff
scientist for Arcadis G&M, peers at the tape, noting the exact depth at
which the tip contacted the water column in the well.

He removes the measure and just as carefully replaces it with a device
resembling a chrome flashlight attached to the end of two white plastic
hoses. This low-flow pump lifts water from the well at the rate of about
a gallon per hour ? slow enough, he hopes, to gather a clean sample from
a well where suspended particles might have skewed the chromium readings
for the groundwater.

Here in a warm, shady clearing on Fort Gordon, Ga., the process of
environmental remediation moves along methodically, as it has since the
Army began cleaning up the remains of a less aware age.

But from Fort Gordon's perspective, cleanup is happening at a rocket's
pace. In 2001, the Army hitched the installation's environmental
restoration program to a performance-based contracting method called
Guaranteed Fixed Price Remediation (GFPR). Though unfamiliarity caused
some delays at launch, cleanup on Fort Gordon caught up with its
schedule in October, and some involved are predicting completion ahead
of schedule.

GFPR is part of a government-wide shift to-ward environmental
performance-based contracting. Simply put, instead of detailing how a
contractor will reach each milestone in a cleanup project, the
government states the objectives and leaves it to the contractor to find
the way to achieve them.

Performance-based contracting makes the contractor "part of the
solution, rather than just an employee," said Steve Willard, chief of
the Fort Gordon Environmental and Natural Resources Management Office.

The Army first tried GFPR as a convenient method of taking care of sites
to be transferred under the Base Realignment and Closure program. Fort
Gordon and Fort Leavenworth, Kan., were added in 2001 as pilot GFPR
programs on active installations.

By mid-2002, the Army was observing at least a 14 percent overall
savings at the BRAC sites and pilot active installations, according to
Maj. Paul Olsen, the Army's GFPR action officer at the time. In
September, the Army awarded seven more performance-based contracts,
worth approximately $110 million.

Then, in October, Maj. Gen. Larry J. Lust, the Army assistant chief of
staff for installation management, made performance-based contracting,
including GFPR, the Army's preferred model for writing cleanup
contracts. The Army plans to use performance-based approaches to write
at least half of its cleanup contracts by the end of fiscal 2005.

Until the September awards, the Army had committed only $80 million to
performance-based contracts. "We are seeing better schedule performance,
and the icing on top of the cake is cost savings by using this
contracting mechanism," said Randy Cerar, chief of the U.S. Army
Environmental Center cleanup division. "And the Army is reinvesting
those savings to clean up other installations. This allows us to
increase the buying power of our annual cleanup budget, which in turn
accelerates the overall cleanup program. In effect, we are able to
fulfill our responsibilities sooner."

Under GFPR, the contractor agrees to bring an installation's sites in
compliance with state and federal requirements by a set date, for a set
cost, and buys insurance to cover cost overruns. In exchange, the
contractor receives increased flexibility in approaches, technology and
timelines.

In practice, the installation carefully constructs the objectives in
consultation with regulators, so all understand what must be done to
earn a certificate of completion. The installation monitors what the
contractor is doing and the contractor completes all documents required
by the regulators.

Fort Gordon's $19.5 million arrangement with Arcadis G&M, the U.S.
division of a 115-year-old Dutch firm, extends through fiscal 2008, when
the Army expects site closure.

Long-Term Partnership

"There are really four partners involved," said Willard. "The
regulators, the GFPR contractor, the installation and higher
headquarters, including USAEC."

Installations with Restoration Advisory Boards ? bodies allowing local
citizens to see and comment on Army cleanup plans ? make the public a
fifth partner in the process, said Army officials. Fort Gordon
periodically solicits the Augusta, Ga., community for interest, but a
board has not yet formed, according to Lange.

Performance-based contracting brings a new stability to that
partnership. For Fort Gordon, continuity has been a key benefit, said
Kathy Riley, environmental protection specialist and government overseer
of Fort Gordon's Installation Restoration Program and GFPR contract.
"The people who are actually doing the field work are the same people
who were doing work from the beginning," she said.

Before GFPR, cleanup on Fort Gordon moved forward, as it does on most
other installations, as money came in to pay for each step, explains
Frederick Lange, Fort Gordon's Installation Restoration Program manager.
There was no guarantee the same firm would be awarded the fieldwork
contract at every step. And cleanup would only progress as far as that
year's funds would allow.

Greater control over the pace and the expectation of multi-year funding
allowed Arcadis to begin work on projects scheduled for fiscal 2004
before the end of September, according to John Hollar, Arcadis program
manager overseeing the company's activities on Fort Gordon. All work
could be finished before the contract's scheduled completion in 2008.

The long-term nature of the contract makes coordinating with the state
easier, as well. "Not only do we have a better working relationship with
the restoration team, but regulators at the state get more familiar with
the contractors," Riley said.

Conference calls among Arcadis, Fort Gordon, Georgia Environmental
Protection Division (EPD) and, occasionally, USAEC helped move things
forward, Hollar said.

The level of communication "gives the ability for us to get into the
nitty gritty details of what is required of the RCRA [Resource
Conservation and Recovery Act] requirements, perceive what is important
to the state and drive the process to closure," Hollar said.

Another advantage of close relationship and single contractor is that
the state and the installation are confident enough to use "interim
measures" to begin cleanup of contamination before the RCRA facility
investigation delineation process is complete.

Photo by Neal Snyder
Geologist Bill Ware examines a water sample for air bubbles.

"There is an expectation of an accelerated process," said Christopher
Hurst of Georgia EPD. Hurst serves as project manager for the state's
oversight of cleanup on Fort Gordon. "The potential is there when the
consultant stays there for the whole lifetime of the process."

Flexible Schedule

The expectation is not unfounded. A 2002 study reported by Olsen of 40
private sector GFPRs found they closed 45 percent earlier than they
would have under more conventional methods. One reason: Basing the
contract on performance gives the company an incentive both to remain
focused on a schedule and to use innovative technologies.

The flexibility extends to scheduling cleanup more efficiently. "We have
the flexibility within the contract to rearrange the work. We can shift
to another site," Riley said. "We're still tied somewhat to multi-year
funding, but overall the contract is funded."

The Arcadis contract covers 26 of the installation's 35 active Solid
Waste Management Units, including seven former industrial areas, five
closed landfills and two sites where munitions were burned in the open.
The work ranges from polychlorinated biphenyl (PCB) contamination to
heavy metals to closed landfills.

"We've had a couple of NFAs [letters from the state saying a site
requires no further action]," said Arcadis' Hollar, "and we're probably
very close to seeing closure on five or six more."

Once Fort Gordon gets NFAs from the Georgia Environmental Protection
Division on those sites, "we are right on track in relation to the
schedule," Hollar said.

Georgia was initially concerned about being overwhelmed by the volume
that could be generated, according to Bruce Khaleghi, coordinator of the
Government Facilities Unit within the Hazardous Waste Management Branch
of the Georgia EPD.

The state didn't object to or discourage the plan, he explained. "We
only cautioned them, ?Do not overwhelm us with documents,' because we
want to do things in a timely fashion, but have time to do the review
and time to respond." In return, Georgia expected Fort Gordon to
continue to do a good job, complete the same documents and do what the
state required, he said.

As Arcadis began its work on Fort Gordon, Georgia was setting up a unit
within its EPD to take advantage of a Defense Department program
designed to keep states from being overwhelmed by cleanup-related
paperwork. Called the Defense-State Memorandum of Agreement (DSMOA), it
pays the state to hire staff to review documents for Defense-related
cleanup actions. Hurst was hired to oversee Fort Gordon as the Georgia
EPD opened its DSMOA-funded DoD remediation unit.

The state significantly reduced its turnaround time on document review
by establishing the DoD restoration unit, Lange said.

The Ultimate Responsibility

All parties at Fort Gordon say the chief danger of working in close
partnership is the possibility of blurred roles. However, the
installation remains firmly in charge of the process, says Riley. "At
face-to-face meetings we are always present," Riley said. "We frequently
have conference calls with everyone involved participating. But we are
the regulated installation and have the ultimate responsibility."

Using any kind of performance-based contracting, including GFPR, doesn't
absolve the Army or its installations of overall liability for
contamination. "Fort Gordon is the permit holder -- that is the bottom
line," Riley said.

State regulators agree. "We've always tried to be very clear that the
RCRA permits must be represented by facility staff no matter who is
hired to do the physical work," said Brent Rabon, coordinator of the
Georgia EPD DoD remediation unit. "The same is true with all
documentation requirements. They hold the permit. Environmental
consultants can't be handling this work and be told to run with it, in
my opinion. Facility representatives need to be the responsible parties;
we interact with the consultants through the facility representatives."

At the very beginning, "It's important to the contractor and the state
that everybody understand what is expected. We let them know the process
will follow a strictly CERCLA [Comprehensive Environmental Response,
Compensation, and Liability Act], strictly RCRA pathway," Hurst said.
(Fort Gordon deals only with RCRA.)

Ground Zero to Finished Closure

As a member of the relatively new DoD remediation unit, Hurst has only
had a year-and-a-half experience with GFPR. However, "I wouldn't have
any reason to recommend [a state] not to support it. It's beneficial to
have a single contractor involved in the process," Hurst said.

A GFPR contract would be less effective on installations where the
cleanup action is mature and remedies are already in place, Rabon said.
"It would be most effective where there are greater unknowns and where
investigations are in their early stages," he said.

_From Fort Gordon's perspective, GFPR has been a positive experience. "If
an installation has several cleanup sites, it's well worth looking at,"
Willard said. "A lot depends on the installation's staff size."

"You're going to use a contract anyway. So much [of cleanup] is so labor
intensive, no matter which way you go it's going to be costly. If you
need to go from ground zero to finished closure, GFPR will take you
there," Willard said.

However the contract is written, there is one bottom line, according to
Lange. "The name of the game in restoration is closing sites ? the
regulatory closure of sites," Lange said. The faster sites are closed,
"the more advantageous it is to protecting human health and the
environment."

.
For more information, contact USAEC at 1-800-USA-3845
or at EnvironmentalHotline@aecapgea.army.mil.

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
CPEO: A DECADE OF SUCCESS.  Your generous support will ensure that our
important work on military and environmental issues will continue.
Please consider one of our donation options.  Thank you.
http://www.groundspring.org/donate/index.cfm?ID=2086-0|721-0