EPA Brownfields Assessment Demonstration Pilot Program Final report Close Out
Economic Development Department
City Hall - Second Floor
50 West 13th Street
Dubuque, Iowa 52001-4864
(563) 589-4393 office
(563) 589-1733 fax
5UOFB~JE
~~~
August 11, 2005
Stephanie B. Doolan
RCRA Corrective Action Officer
U.S. Environmental Protection Agency
Air, RCRA, and Toxics Division
901 N. 5th Street
Kansas City, Kansas 66101
Ref: Final Closeout documents: BP 98719701
Dear Ms. Doolan:
Enclosed you will find an original and two copies of the Final Technical
Performance Report for the above referenced program agreement. Copies of the
Final Financial Status Report and Final Federal Cash Transactions reports have
been mailed to Las Vegas Finance Center of EPA. These reports will officially
close out this program agreement.
The EPA Brownfields Assessment Demonstration Pilot Program has assisted the
City in acquiring properties in the Port of Dubuque for redevelopment purposes.
Thank you for your help as the City completed the environmental assessments
If you have any questions concerning the final report, or any supporting
documentation please contact me.
Sincerely,
~~
David J. .uia'r
Economic Development Director
cc:~ke Van Milligen, City Manager
John Brimeyer, Terracon Consultants
Service
People
Integrity
Responsibility
Innovation
Teamwork
FINAL REPORT
PORT OF DUBUQUE BROWNFIElDS PROJECT
BROWNFIElDS ASSESSMENT DEMONSTRATION PilOT PROGRAM
EPA #BP 98719701
City of Dubuque, Iowa
Date submitted: August 2,2005
Prepared by: Bill Baum, Economic Development Staff
City Hall, 50 West 13th Street
Dubuque, Iowa 52001
Prepared for: Stephanie B. Doolan, Brownfields Project Officer
EPA Region 7
901 North 5th Street
Kansas City, KS 66101
913 551-7719
REPORT NARRATIVE
1. Pilot Program Activities Final Performance Report
Task 1: Phase I Environmental Site Assessments:
The City of Dubuque completed 12 Phase I Environmental Assessments on a total of 14
properties in the Port of Dubuque during the grant period. The City's consultant conducted
all Phase I Assessments according to the current ASTM standards.
Task 2: Phase II Environmental Site Assessments
The City of Dubuque completed 7 Phase II Environmental Assessments on a total of 9
properties in the Port of Dubuque during the grant period. The City's consultant conducted
the Phase II Assessments according to the Quality Assurance Project Plan reviewed and
approved by EPA.
During the grant period, the City expended a total of $64,720 of the $200,000 grant to
Minority Business Enterprises.
Task 3: Administration
The City staff attended regional and national Brownfields training conferences in Wichita,
Kansas; Chicago, Illinois; Portland, Oregon; Cedar Rapids, Iowa; St. Louis, Missouri; and
Des Moines, Iowa. City staff administered the reporting requirements of the grant.
Task 4: Cleanup Planninq
The City's consultant, Terracon, has submitted copies of all Phase I ESAs and Phase II
ESAs to the Iowa Department of Natural Resources for review and comment in anticipation
of enrollment in the voluntary Land Recycling Program. Terracon has discussed the status
of the sites with DNR, and indications are the City may be issued comfort letters in lieu of
No Further Action certificates under the LRP program.
Other: City staff met with EPA staff at the end of the grant period to clarify the key
measures reported in the quarterly reports, and arrive at consistent accurate reporting
data. The final key measures report is attached along with a table identifying each
property assessed in the target area of the Port of Dubuque. A separate narrative is also
included that provides a detailed explanation of each key measure item.
2
Attachment t:
TABLEt
Brownfields Assessment Demonstration Pilot Key Measures
Pilot Name: Dubuque, Iowa: Port of Dubuque, Iowa CA#:BP-98719701-0
R P 'd F' D t F
F'II dOt
7/29 / 05
eportm eno : ma a e orm I e u :
Key
Measure Description Cumulative
API Number of Properties Estimated in Brownfields Pilot Jurisdiction
AP2 Number of Properties Reported to be Contained in Pilot Inventories 39
AP3 Number of Properties Reported to be Targeted by Pilot 22
AP4 Number of Properties with Brownfields Assessments Started with Pilot Funding 16
AP5 Number of Properties with Brownfields Assessment Completed with Pilot Funding 16
AP6 Number of Properties with Brownfields Assessment Completed with Other Funding 2
AP7 Number of Properties with Brownfields Assessment that Do Not require Cleanups I
AP8 Number of Properties with Brownfields Cleanup Activities Started 7
AP9 Number of Properties with Brownfields Cleanup Activities Completed 0
APIO Number of Properties with Brownfields Redevelopment Activities Underway 6
APlI Number of Cleanup/Construction Jobs Leveraged (10 Steward Construction) (40 Kramer Brothers) 50
API2 Number of Cleanup Dollars Leveraged (IDEO Grant $142,655) HUD EDI $357,660)(City $202,345) $702,660
AP13 Number of Redevelopment Jobs Leveraged
API4 Number ofredevelopmentlConstruction Dollars Leveraged (Dubuque Star Brewery renovation) $1,010,000
Additional Brownfields Showcase Community Reporting Measures
(Voluntary & Encoura2ed for Non-showcase Communities)
Key Measure Description Cumulative
SC 1 Number of Brownfields-related Partnerships with Other Organizations 8
lA Number of Partnerships with other Federal Agencies (HUD/EDAlEP A) 3
IB Number of Partnerships with State and Tribal Government Agencies(lDNR/DED) 2
IC Number of Partnerships with Local Government Agencies 0
10 Number of Partnerships with Private Entities and Non-Governmental Organizations 3
SC2 Brownfields-related Initiative Funding Received from other Sources $2,662,660
2A Funding Received from Other Federal Agencies (HUD/EDA) $2,357,660
2B Funding Received from State and Tribal Government Agencies (IDEO) $ 142,665
2C Funding Received from Local Government Agencies $ 202,345
2D Funding Received from Private Entities and Non-Governmental Organizations 0
Note: The Assessment Demonstration Pilot and Showcase Community Key Measures and the definition oj each are attached in Appendix A.
ENCLOSED IS A FINAL REPORT WITH DETAILS RELATED TO EACH KEY MEASURE
3
BROWNFIELDS PILOT PROPERTIES KEY MEASURES
AP3
Number of Properties Proposed to be targeted
1. Dubuque Water Department, 505 Adams Street
2. Adams Company
3. Dubuque Hardwoods, 205 East Sixth Street
4. Klauer Property adjacent to Dubuque Hardwoods
5. City owned Market Square adjacent to Dubuque Hardwoods
6. Peavey Salt Storage, Bell Street/4th Street
7. Bill Miller Logging, 380 East 4th Street
8. Dubuque Star Brewery — End of 4th Street
9. Stealth Race Cars on 5th Street
10. City owned Corner of 5th and Bell
11. Plastic Center on Adams Street
12. Diamond Jo lot adjacent to City lot on Bell Street
13. Diamond Jo parking lot on Bell Street
14. City owned Diamond Jo leased parking lot (East of Casino)
15. Mulgrew Oil Company on Terminal Street
16. Molo Oil Company (Apex Concrete on Jones Street
17. Dubuque River Terminal, Inc, 60 Jones Street
18. Dubuque River Terminal, Inc, SE Corner of Jones/Terminal
19. Sitco, 102 Terminal Street
20. Dodds River Terminal, Inc 20 Terminal Street
21. Sinclair/Koch Terminal — Terminal Street
22. Newt Marine complex on Jones and Terminal
22 Properties
AP4 & AP5
Assessments Completed
Phase 1
Phase 2 and Cost to
Remedy
Phase I & 2
Combined with #3
Combined with #3
Phase I & 2
Phase I & 2
Phase 2
Phase 1 & 2
Phase 1 & 2
Phase 1
Phase 1
Phase 1
Phase 1
Phase 1
Phase 1
16 Properties
AP6 AP7 AP8 AP10
No City
With Other $ CUR Started Redeye! Owned/Acquire
x x
x x
x
x x
x x
x x
x x x
2
x
x
x
7 6 12
NOTES TO KEY MEASURES: FINAL REPORT
A technical assistance meeting with EPA staff Stephanie Doolan to work out clarifications of the
key measures resulted in this final report.
A separate table is attached to the Pilot Key Measures report, identifying properties by name, and
the key measures completed or underway.
Other key measures requiring an explanation:
AP11 Number of cleanup/construction jobs leveraged: During the grant period, the City contracted
for the demolition/cleanup of 7 of the properties under City ownership and control. Two
contractors, Steward Construction (10) and Kraemer Brothers (40) employed 50 persons in the
cleanup work.
SC1 d Partnerships with Private Entities and Non-Governmental Agencies:
During the grant period, the City partnered with the Dubuque Main Street L TD, the Dubuque
County Historical Society, and the Greater Dubuque Development Corporation in the promotion of
the City's Brownfields Assessment program in the Port of Dubuque.
3. Budget Summary
Attachment 2
TABLE 2
SUMMARY OF FINAL EXPENSES BY TASK
Pilot Name: Port of Dubuque Brownfields Redevelopment Proiect
Cooperative Agreement #: BP-98719701-0
Reporting Period: Final
Approved Work Total
Budget Plan Budget Previously Expenses this Cumulative
Categories (as amended) Expended Quarter Expenses
Task 1: $ 46,600 $ 46,802.41
Phase I EA
Task 2: $ 145,700 $149,041.41
Phase II EA
Task 3: $ 4,300 $ 7,445.07
Admin
Task 4: $ 3,400 $ 1,820.83
Cleanup Planning
Task 5:
Total Cumulative $200,000 $205,109.72
Expenses
The City funded the over expenditure of $5,109.72. Attached is a spreadsheet identifying all costs
by invoice.
6
7/27/2005 BROWNFIELDS ASSESSMENT GRANT I
Balance BUDGET AND EXPENSES BY CATEGORY
DRAW #1 $ 200,000.00 PHASE 1 PHASE II ADMIN CLEANUP PLANNING
T erracon $ 9,668.98 784112 $ 5,870.73 $ 3,798.25 $ 9,668.98
Wichita T $ 876.03 11/8/2002 $ 876.03 $ 876.03
$ 10,545.01 $ 10,545.01 $ 189,454.99 $ 5,870.73 $ 3,798.25 $ 876.03 $ 10,545.01
$ -
Draw #2 DRAW #2 DENIED FOR NO SIGNATURE $ -
T erracon $ 5,649.27 784203 $ -
T erracon $ 9,079.26 784264 $ -
Chicago T $ 1,195.00 7/1/2003 $ -
$ 15,923.53 $ 10,545.01 $ 189,454.99 .... $ -
$ - $ -
Draw #3 $ - $ -
T erracon $ 5,649.27 784203 $ 2,799.85 $ 2,849.42 $ 5,649.27
Terracon $ 9,079.26 784264 $ - $ 9,053.51 $ 25.75 $ 9,079.26
Chicago T $ 1,195.00 7/1/2003 $ - $ 1,195.00 $ 1,195.00
Terracon $ 6,243.80 784316 $ - $ 6,192.30 $ 51.50 $ 6,243.80
Terracon $ 5,817.25 784378 $ - $ 5,817.25 $ 5,817.25
Portland T $ 543.00 9/19/2003 $ - $ 543.00 $ 543.00
$ 28,527.58 $ 39,072.59 $ 160,927.41 $ 23,862.91 $ 2,926.67 $ 1,738.00 $ 28,527.58
$ 29,733.64 $ 6,724.92 $ 2,614.03 $ 39,072.59
Draw #4 Portland T $ 577.17 11/17/2003 $ 577.17 $ 577.17
T erracon $ 4,061.75 784486 $ 4,061.75 $ 4,061.75
T erracon $ 5,745.50 784433 $ 4,925.00 $ 820.50 $ 5,745.50
$ 10,384.42 $ 49,457.01 $ 150,542.99 $ 4,925.00 $ 4,061.75 $ 1,397.67 $ 10,384.42
$ 34,658.64 $ 10,786.67 $ 4,011.70 $ 49,457.01
Draw #5 T erracon $ 3,846.00 784572 $ 3,846.00 $ 3,846.00
T erracon $ 614.25 784530 $ 614.25 $ 614.25
T erracon $ 415.76 784626 $ 415.76 $ 415.76
T erracon $ 2,594.11 784655 $ 2,594.11 $ 2,594.11
Error in #1 $ (19.00) $ (19.00) $ (19.00)
Pam CR $ 59.86 $ 59.86 $ 59.86
T erracon $ 15,927.00 784719 $ 15,927.00 $ 15,927.00
Total $ 23,437.98 $ 72,894.99 $ 127,105.01 $ 23,397.12 $ 40.86 $ 23,437.98
$ 34,658.64 $ 34,183.79 $ 4,052.56 $ 72,894.99
Draw #6 Terracon $ 12,944.60 784775 $ 12,944.60 $ 12,944.60
Total $ 12,944.60 $ 85,839.59 $ 114,160.41 $ -
$ -
Draw #7 T erracon $ 1,155.51 784826 $ 1,155.51 $ 1,155.51
T erracon $ 799.50 784879 $ 799.50 $ 799.50
T erracon $ 3,387.75 784922 $ 3,387.75 $ 3,387.75
A4 Scien. $ 48,700.00 16 invoices $ 48,700.00 $ 48,700.00
Total $ 54,042.76 $ 139,882.35 $ 60,117.65 0 $ 66,987.36 0 $ 66,987.36
$ 34,658.64 $ 101,171.15 $ 4,052.56 $ 139,882.35
Draw #8 T erracon $ 2,630.10 784982 $ 1,348.75 $ 1,281.35 $ 2,630.10
Portzen $ 2,005.73 4005 $ 2,005.73 $ 2,005.73
Form Approved OMB NO. 2030-0020 Approval Expires 12/3/02
&EPA
LOBBYING AND LITIGATION CERTIFICATION FOR GRANTS
AND COOPERATIVE AGREEMENTS*
INSTRUCTIONS:
*At project completion, complete this form pursuant to the 2001 Department of Veterans Affairs and Housing and Urban
Development, and Independent Appropriations Act, Public Law 106-377, Section 424 and 2000 Department of Veterans
Affairs and Housing and Urban Development, and Independent Appropriations Act, Public Law 106-74, Section 426 and
any other subsequent Appropriation Act requirements.
Please mail this form to your EP A Grant Specialist within 90 days of project completion. DO NOT send this information
to the Office of Managemt:int & Budget.
Assistance Agreement Number( s):
BP 98719701
Terrance M. Duggan. Mavor
Print Name
Burden Statement - The annual public reporting and record keeping burden for this collection of information is estimated to average 5 minutes per
respondent. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating and verifying information, processing and maintaining information, and disclosing and providing
information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to
a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the
information. An agency may not conduct or sponsor, and a person is not required to respond to , a collection of information unless it displays a
currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.
Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for
minimizing respondent burden, including through the use of automated collection techniques to the Director, Regulatory Information Division, U.S.
Environmental Protection Agency, Ariel Rios Building, 1200 Pennsylvania Avenue, N.W., Mail Code 3213A, Washington, DC 20460; and to the
Office ofInformation and Regulatory Affairs, Office of Management and Budget, 725 171hStreet, N.W., Washington, DC 20503, Attention: Desk
Officer for EPA. Include the EPA ICR number and OMB control number in any correspondence.
EP A Form 5700-53 (Rev. 7-02)
u.s. ENVIRONMENTAL PROTECTION AGENCY
MBEIWBE UTILIZATION UNDER FEDERAL GRANTS, COOPERATIVE
AGREEMENTS, AND INTERAGENCY AGREEMENTS
PART 1. (Reports are required even if no procurements are made during the reporting period.)
1A. FEDERAL FISCAL YEAR 1 B. REPORTING QUARTER (Check appropriate box) FINAL
2005_ 1st (Oct-Dee) 2nd (Jan-Mar) 3rd (Apr-Jun) 4th (Jul-Sep) Annual
1 C. REVISION HIGHLIGHT ITEMS TO BE REVISED AND PROVIDE EXPLANATION IN BLOCK No.6
Year:
Quarter:
2A. FEDERAL FINANCIAL ASSISTANCE AGENCY 3A. REPORTING RECIPIENT (Name and Address)
(EPA Office Address - ATTN: DBE Coordinator)
Environmental Protection Agency City of Dubuque Iowa 50 West 13th Street Dubuque
901 N. 5th Street
Kansas City, Kansas 66101 Iowa
2B. REPORTING CONTACT 2C. PHONE: 3B. REPORTING CONTACT (Recipient) 3C. PHONE:
(EPA DBE Coordinator) William J. Baum 563 589-4393
4A. FINANCIAL ASSISTANCE AGREEMENT ID NUMBER 4B. FEDERAL FINANCIAL ASSISTANCE PROGRAM
(SRF State Recipients, Refer to Instructions for Completion of 4A, 5A, and 5C)
BP-98719701-0 Brownfields Pilot Demonstration
Program
5A. TOTAL ASSISTANCE AGREEMENT 5B. Check and skip to Block 5C. TOTAL PROCUREMENT AMOUNT THIS REPORTING
AMOUNT No. 7 if no procurements PERIOD (ONLY include the amount not in any prior reporting
and accomplishments period and procurements made by SRF Loan Recipients and
EPA Share: were made this reporting Sub- Recipients)
$_200,000 period.
$47,004.06
Recipient Share: $
(Exclude procurement amounts reported by Prime Contractors)
5D. ACTUAL MBElWBE PROCUREMENT ACCOMPLISHED THIS 5E. ACTUAL MBEIWBE PROCUREMENT ACCOMPLISHED THIS
REPORTING PERIOD BY RECIPIENT (SRF State Recipients, Report REPORTING PERIOD BY LOAN RECIPIENTS, SUB-RECIPIENTS,
State Procurement Activities Here) AND PRIME CONTRACTORS
$MBE $WBE $MBE $WBE
Construction Construction
Equipment Equipment
Services Services _$16,020_
Supplies Supplies
TOTAL TOTAL
6. COMMENTS:
Terracon, the City's Environmental Consultant subcontracted with A4 Scientific, Inc to perform laboratory analyses on samples collected for the Dubuque
Brownfields Assessment Program
7. NAME OF AUTHORIZED REPRESENTATIVE TITLE
William J. Baum Economic Development staff
8. SI"H~S~NTATIVE DATE
8/02/05
f 7
MBE/WBE PROCUREMENTS MADE DURING REPORTING PERIOD
EPA Financial Assistance Agreement Number: _BP-98719701-0
1. Procurement Made
By
2. Business
Enterprise
3. $ Value ofDate
Procurement
4. of
Award
MM/DD/YY
5. Type of
Product ServicesAor
(Enter Code)
6. Name/Address/Phone Number of
MBE/WBE Contractor or Vendor
Recipient
Other
Minority
Women
Terracon
Yes
$16,020
06/02/2004
B
A4 Scientific Inc. 1544 Sawdust Road, Suite
505
The Woodlands, TX 77380
8
OMB APPROVAL NO. 0348-0003
FEDERAL CASH TRANSACTIONS REPORT 1. Federal sponsoring agency and organlzaUonal element 10 which 1hls ~
Is submitted
(See instructions on the back. If report is for more than one grant or U.S. Environmental Protection Agency
assistance agreement, attach completed Standard Form 272A.)
2. RECIPIENT ORGANIZATION 4. Federal grant or other ldenUflcallon 5. Recipient's 8OOOW1I number or
number Idenlifylng number
Name: City of Dubuque BP-9871970 1-0
6. Letter of credit number 7. Lest payment voucher number
Number 50 West 13th Street 7964 11
and Street:
Give total number for this period
City, State Dubuque. Iowa 52001 8. Payment Vouchers credited to 9. Treasury checks received (whether
and ZIP Code: your account 1 or not deposited)
10. PERIOD COVERED BY THIS REPORT
3. FEDERAL EMPLOYER FROM (month, day, yesr) TO (month. day, yew)
IDENTIFICATION NO. ~ 42-6004596 7/01/2005 8/02/225 FINAL
a. Cash on hand beginning of reporting period $ 0.00
b. Letter of credit withdrawls 18,112.94
11. STATUS OF c. Treasury check payments
FEDERAL d. Total receipts (Sum of lines b and c) 18,112.94
CASH e. Total cash available (Sum of lines a and d) 18,112.94
f. Gross disbursements 18,112.94
(See specific g. Federal share of program income
instructions 0.00
on the back)
h. Net disbursements (Line f minus line g) 18,112.94
i. Adjustments of prior periodS
j. Cash on hand end of period $ 0.00
12. THE AMOUNT SHOWN 13. OTHER INFORMATION
ON LINE 11), ABOVE,
REPRESENTS CASH RE- a. Interest income $
QUIREMENTS FOR THE
ENSUING b. Advances to subgrantees or subcontractors $
Days
14. REMARKS (Attach additional sheets of plain paper, if more space;s required)
THIS IS THE FINAL REPORT FOR THIS GRANT. ALL FUNDS HAVE BEEN REQUESTED AND RECEIVED. ALL
EXPENDITURES HAVE BEEN MADE.
I certify to the best of my
knowledge and belief that this
report Is true in all respects and
that all disbursements have
been made for the purpose and
conditions of the grant or
egreemenL
AUTHORIZED
CERIFICATION
15.
DATE REPORT SUBMITTED
08/0212005
CERTIFYiNG
OFFICIAL
Kenneth J. Tekippe, Finance Director
TELEPHONE (Area Code.
Number, Extension)
563 589-4133
THIS SPACE FOR AGENCY USE
NSN 7540.01.016-5434
272.103
STANDARD FORM 272 (Rev. 7-l17)
Prescribed by OMB Clrculsrs A.102 and A.110
FINANCIAL STATUS REPORT
(Short Form)
(Follow instructions on the back)
1. Federal Agency and Organizational Element 2. Federal Grant or Other Identifying Number Assigned OMB Approval Page of
to Which Report is Submitted By Federal Agency No.
U. S. Environmental Protection Agency BP-98719701-0 0348-0038 1 1
pages
3. Recipient Organization (Name and complete address, including ZIP code)
City of Dubuque, Iowa 50 West 13th Street, Dubuque, Iowa 52001
4. Employer Identification Number 5. Recipient Account Number or Identifying Number 6. Final Report 7. Basis
42-6004596 FINAL REPORT IZI Yes DNo o Cash D Accrual
8. Funding/Grant Period (See instructions) 9. Period Covered by this Report
From: (Month, Day, Year) ro: (Month, Day, Year) From: (Month, Day, Year) To: (Month, Day, Year)
10/1/2002 6/30/2005 12131/2004 6/30/2005
10. Transactions: I II III
Previously This Cumulative
Reported Period
a. Total outlays 157,477.00 47,632.72 205,109.72
b. Recipient share of outlays 0.00 5,109.72 5,109.72
c. Federal share of outlays 157,477.00 42,523.00 200,000.00
,',c' 'I, 7,.
d. Total unliquidated obligations ;
, .'.
.',> ' ," "
e. Recipient share of unliquidated obligations '. :'
"
." ',' " .
f. Federal share of unliquidated obligations ..' .
,
g. Total Federal share(Sum of lines c and f) " ,', 200,000.00
'" , " .'
, ',/ >
h. Total Federal funds authorized for this funding period 200,000.00
, .
i. Unobligated balance of Federal fund(Line h minus line g) 0.00
. .,
a. Type of Rate(Place .X. in appropriate box)
11. Indirect D Provisional D Predetermined DFinal D Fixed
Expense b. Rate c. Base I d. Total Amount e. Federal Share
12. Remarks: Attach any explanations deemed necessary or information required by Federal sponsoring agency in compliance with goveming
legislation.
ALL EXPENDITURES HAVE BEEN MADE AND ALL FUNDS HAVE BEEN REQUESTED AND RECEIVED.
13. Certification: I certify to the best of my knowledge and belief that this report is correct and complete and that all outlays and
unliquidated obligations are for the purposes set forth in the award documents.
Typed or Printed Name and Title Telephone (Area code, number and extension)
Kenneth J. Tekippe, Finance Director 563 589-4133
Signalure uthorized Certifying Official Date Report Submitted
(~J) CJ)!._~/d/1 August2,2005
NSN 7540-~'1-218-4387 V 269-202 Standard Form 269A Rev. 7-97
( )
Prescribed by OMB Circulars A-102 and A-11C