ML20125D014

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Forwards Source Evaluation Panel Rept on 840711,17-18 & 20 Meetings to Evaluate Bids Received in Response to ASB-84-352.Cost of Travel Should Be Included in Pricing of Contract
ML20125D014
Person / Time
Issue date: 07/20/1984
From:
Atomic Safety and Licensing Board Panel
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20125C863 List:
References
FOIA-84-734 NUDOCS 8506120223
Download: ML20125D014 (22)
v • d • e


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NUCLEAR MEGULATORY COMMISSION t ATOMIC stJtTY AND LICENslNG DOARD PANEL  !

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July 20, 1984 MEMORANDUM:

E r,6 ,

l FROM: Chairman  !

Source Evaluation Panel '

SUBJECT:

REPORT OF THE SOURCE EVALUATION PANEL -- A58-84-352 r

On July 11, 17, 18 and 20, 1984, the Source Evaluation Panel met to evaluate the bids received in response to A58 84 352. This contract, unlike the Tayloe Contract which expired, requires the cost of travel be included in the pricing of the contract. l There were two bids, one from Ace Federal Reporters, Inc., the other from Tayloe Associates. The Ace bid totaled $850,189.75, the Tayloe bid totaled $583.727.20, both for one year. Bidders were required, under the solicitation, to post a bid guarantee with their

, bid. Ace posted the required bond. Tayloe did not.

Because Tayloe did not submit a bid guarantee as required by Part 11.8.23, IFB Number A58 84 352 the Panel was required to first determine if the Ace bid was re,asonable. If the Panel determined the ,

Ace bid was reasonable, the Tayloe bid could not be considered because it was non responsive.

Notwithstanding the obvious difference in the bids -- $266.462.55  !

- but, in view of the fact that Ace had met the requirement of posting a bid varantee, the Panel proceeded to perform a careful analysis of the Ac bid.

The Panel felt it should be able to identify two elements in ,

analyzing the Ace Federal Reporters, Inc. submission. They ares (1) travel costs, and (2 services such as NRC requ) ires.a current rate for stenographic reporting 9

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Inordertoapsreciatethetravelcostsinthepricingkigurewhich' Ace had submitted tae Panel took a representative sample of travel i costs '

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based on 109 days of hearing claims made by Tayloe from August 20, 1983 l

- February 29, 1984, for which next-day, or daily, transcript delivery was requested. From this sample the Panel calculated the travel cost l

, per page for daily copy averaged $2.91 (see CHART A). -

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I In order to establish a base rate the Panel used six bids submitted I

by vendors forMarch (SECY-84-327, the recently) 9,1984 forawarded Metropolitan stenographic Washington, reporting D.C. The contract i

  • Panel considered these data current and responsive to the requirements I of the NRC in its court reporting requirements. In establishing this base rate the Panel also focused on the next-day requirements figures. I which represent the bulk of the contracts requirements (see CHART 8).

O From these data (CHART B) the Panel established the following

, in-town daily rates per page:

TA8LE I - DAILY RATES

_ Low Average High

$3.50 $4.63 $6.00 These figures, as in town requiremonts, do not include travel.

The figures' wore then corrected to include the average travel costs i which were developed from the data on the most recent reporting contract with Tayloe:

TABLE !! -- DAILY RATES WITH ADJUSTED TRAVEL FROM CHART A low Average Bh,  !

In Town Bids: $3.50, $4.63 $6,00 Travel Adjustment 2.91 2.91 2.9)

Total Adjusted Cost Per Page $6.41 $7.54 $8.91 s

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ThePanelthencomparedtheadjustedrateswiththe8thsubmftted by Ace:

TABLE !!! -- ADJUSTED COST COMPARISDN Low Average Ace Bid g

$6.41 $7.54 $8,00 $8.91 In comparison Ace was:

$1.59/page above the lowest

.46/page above the average

.91/page less than the h' ghost I

+

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e TABLE IV -- DAILY RATES WITH ADJUSTto TRAVEL FROM CHART C

_ Low Averase g In Town tids $3.50 $4.63 Travel Adjustment $6.00 Total Adjusted Cost M g g Per Page $6.08 $7.21 $8.58 The Panel then com mined for the Ace bid. pared the total adjusted cost with that deter-TABLE V --

M Averase Ace Old M

$6.08 $7.21 $8.00 $8.58

- \ - -. _

In comparison Ace was:

$1.92/page above the lowest

.79/page above the average

.58/page less than the highest Based on the less than 15% difference between these two travel cost factors the Panel concluded that with either factor the Ace bid was reasonable.

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Ex. 6 The fact that Ace was the only bidder to comply with the bid ouarantee requirement and was between the average and high on the scale

{see Tables III and V), the Panel concluded the Ace bid is reasonable.

Were NRC to have used the Tayloe option year daily rate from the .

recently completed contract the figures would have been:

TABLE VI --

l From From Chart A Chart C Daily Cost /Page $5.88 or $5.88 Travel Cost 2.91 2.58 l Rate /Page Daily Copy $8.79 $8.46 These figures are 79c and 46(, respectively, per page over the price per page submitted by Ace. Therefore, the Panel concludes the Ace bid'is reasonable and represents a saving to the Government over the

. Tayloe option year contract.

1 The Panel recomends subject to a favorable finding in the pre-award survey, the contract be awarded to Ace Federal Reporters, Inc.

PANEL RECOMMENDATION APPROVED:

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CHART A: TRAVEL COSTS 109 DAYS REPRESENTATIVE SAMPLE TRAVEL COST FACTOR AUGUST 20, 1983 - FEBRUARY 29, 1984 TAYLOE CONTRACT NRC-17-83-399 Hearing No. No. Total location Pages Days Travel Cost

1. Dover, NH 466 5 $ 1,046.93
2. Fulton, MO 160 1 1,533.49
3. Midland, MI 708 4 1,867.61
4. Rock Hill, SC 845 4 2,231.19
5. Beaver Valley, PA 146 1 329.46
6. Los Angeles, CA 697 4 3,489.36
7. Phoenixville, PA 521 2 1,525.66
8. Rock Hill, SC 1,065 5 2.262.21
9. Harrisburg, PA 180 1 130.70
10. Fort Worth TX 380 2 2,482.25
11. Rock Hill, SC 806 3 1,981.20
12. Petoskey, MI 2,490 10 5,806.66
13. Midland, MI 1,357 8 3,530.58
14. Rock Hill, SC 1,072 4 2,741.69
15. Rock Hill, SC 1,231 4 2,834.00
16. Rock Hill, SC 1,059 4 2,288.40
17. Houston, TX 114 1 2,245.27
18. Rock Hill, SC 358 5 2,556.18
19. Charlotte, NC 1.428 5 1,956.46
20. Cincinnati, OH 92 1 442.90
21. Philadelphia, PA 866 5 1,935.31
22. Riverhead, NY 662 4 2,345.70 -
23. Burlington. . KS 1,821 9 5,030.56
24. Charlotte, NC 614 2 2,088.14
25. Chicago, IL 219 1 1,605.08
26. Hartsville, SC 426 3 2.452.52
27. Emporia, KS 403 3 2,181.45
28. Fort Worth, TX 1,029 5 2.495.60
29. Homestead, FL 84 1 1,011.50
30. Philadelphia, PA 83 1 239.25
31. Vicksburg, MS 95 1 666.61 Totals 22,477 109 $ 65,333.92 Total Travel Cost , $65,333.92 Average Travel Cost Total No. Pgs. for 22,477 = $2.91 per page for daily 109 days of Original Original Transcript.

Tr.anscripts.

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CHART B: SECY-84-327

_ ORIGINAL TRANSCRIPT RATES -- REGULAR HOURS ..

-t (BIDS RECEIVED: MARCH 9,1984)  ;- .

INTOWN -- NO TRAVEL REQUIREMENT Posi- Five- Two- Five Page tion Day D_ay Daily Hour

,High 6 B-5.50 B-5.75 B-6.00 B-9.50 5 T-4.90 T-5.10 T-5.45 T-6.75 4 C-4.10 C-4.40 C-4.90 6.13 5 ' Average 3.73 4.21 - 4.63 C-6.10 3 Y-3.05 Y-3.55 S-4.15 F-6.00 2 S-2.95 S-3.55 Y-3.75 S-4.40 i Low 1 F-1.90 F-2.90 F-3.50 Y-4.05

/,

Withdrawn bid too low to be viable SK-1.79 SK-2.78 SK-2.88 SK-3.38 Averages not in-cluding 22.40 27.75 withdrawn 6

- 3.73 25.25-6 4.21 - 4.63 36.80_ 6.13 6 6 bid ,

LEGEND

) = Bossard C = Court Reporting Service .

F = Freestate S = SCI Management Resource SK = SKS Group Limited T = Tayloe Associates Y =

York Steno .

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CHART C:

INDEPENDENT TRAVEL COST DETERMINATION Estimated travel costs based on Attachment 10 of Amendment 2, dated

, June 1, 1984, IFB-ASB-84-352. Attachment 10 lists projected estimates for location, type of hearing, number of trips, and number of days per tri.p.

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, CHART C:

INDEPENDENT TRAVEL COST DETERMINATION

[ continued)

Attachment 10 Subtotals Page Total Total Total No. Air fare Per Diem Rent-A-Car 1 $ 29,682 $ 19,240 $ 780 2 19,327 22,620 240 3 17,444 17,940 960 4 20,098 39,390 -

5,100 5 5,794 24,440 8,520 6 17,590 20.540 1,200 7

2,604 1,950 5112,539 5146,120 516,800 Total Travel:

$112,539 + $146,120 + $16,800 =

$275.459

$275,45,9 x .57*/ = $157,012

$157,012 - Total travel cost / daily original transcript 3 60,775 = Total pages/ daily original transcript

$2.58 travel cost per page for daily original transcript

  • / See CHART D for representative sample percentage.

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CHART D:

- DAILY ORIGINAL TRANSCRIPT ..

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AS REPRESENTATIVE SAMPLE 1)

ACE FEDERAL REPORTER Five-Day Two-Day Dail Five-Hour Total 520,268 + 568,313 + $4 , O + 5500 = $375,781 Total Contract = $850,189.75

.. Percentage of Total Contract Costs t Presented by Original Transcripts

$575,281.00 5850,189.75 = M%

Percentage of Total Contract Costs By Original Transcript Categories Five-Day Two-Day Daily Five-Hour 120,268 168,313 $486,200 $500

$850,190 = 2.3% $850,190*O! 5850,190 = 57% $83ET90= .06%

! Daily = 57%

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SUMMARY

OF ponrnorMrNT i

A. General Information

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1. Contractor (Name, Address,andTelephoneNem$er):

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WY W . 6-M .N A V / / ' /

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2. Contract Number: ##c - p /- Pt/ - SS-A.

Solicitation Number: /256-PY-SSA 1

Modification Number:

RFPA Number: ASo-rY .ISS

3. Type of Organization:.

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/ / educational / / profit / / non-profit (not fo

- profit)

/ / small business (X/ large business /-/ government

4. Negotiation Authority (reference F&D, if applicable): -

p)g B. Type of Contract: (reference FAD, if applicable)

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- rMa Project Title and Description of Work: M s

,am/4 3Au.54u .fesu$

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& .sur, & f - ~ ~ 6 h f.J Cest - 1,2 L A & R

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Period of Performance: /fou Pw

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Place of Performance: MM zwog Nd, #t. h Contract Amount: lfs~() /ff 7f - Ww*etis

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Amount of this Action: 854 /ff. 75' Cumulative Total: _

  1. 9So /ff. 75-F61A-84-13Y .

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. . C. Compliances (if not applicable, mark "N/A"):

1.

Deteminatiornand Findings - Negotiation Authority gpproved on ,

W)A by E..

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2. Deteminations and Findings - Cost Type Contract approved on N/A _

by .

3. Determinations and Findings - Privacy Act approved on
  • WlA by .
4. Determinations and Findings - Personal Services or other as specified approved on .7 /&[fV by "ht . Q.ha22Z4. .
5. ~ Procurement Planning Schedule showing major Milestones / A is

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/ / is not attached (explain if not attached).

6. Synopsis of this procurement 8/ was / ~/ was not released to the Comerce Business Daily on /[f/TV (if not, why).

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7. Source Evaluation Documentation (if applicable):
a. Justification for noncompetitive procurement or sole source

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based upon N/A -)

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,and

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approved on by .

(Reference PCM' Report found at side in file folder.)

b. Competitive Range Determination and Approval dated N/A see side of file folder.
c. Approval.of Final Evaluation Report dated M/6 o- '

see side of file folder.

d. Letters to offerors in competitive range dated M/#

see side of file folder.

e. Letters to unsuccessful offerors dated f//0/fY '

. See side lo of file folder.

f. Memorandum of debriefings with M/A See side of file folder.

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The Contractor les submitted a Certificate of Current Cost or

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Pricing Data dated (FPR l-3.807-4;.see side .

I offilefolder). 8/ Not applicable ffPR l-3.807-3)

9. Date List o Dgbarred, Ineligible and Suspended Contractors was 2 &/ Y 4-checked 7 4 .
10. Funds availabil'ity documentation dated  ?///N (Reference RFPA and any amendments thereto.).
11. Pre-Award Survey /R/was / / was not performed. Date of 1 A $$ 9_#" ,
n. 'nnnt 4 om wu wse y fS - K g?y C

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. 12. Narrative of Procurement Action and Reasonableness of Price:

~ IFB No. ASB-84-352 entitled " Stenographic Reporting Services Throughout the Contiguous United States Excluding the Washington.,4,C. -

Metropolitan Area" was issued February 6, 1984. The IFR covered NRC's i requirements for stenographic reporting services outside-i.he D.C. area for a one-year period with an option to extend the tenn of the contract

one additional year. Services were to be a follow-on to Contract No.

NRC-17-83-399 with Tayloe Associates which was to expire on March 15, ,

  • 1984. The solicitation was issued on an unrestricted basis. The size I standard determined for the requirement was average annual receipts for the preceding three fiscal years must not- exceed $2 million to be classified as a small business.
The IF8 was issued to 28 firms. Bids were scheduled to be opened March 7,1984. Following initial contact by Mr. Verle Zanders, SBA Procurement Center Representative, SBA by letter dated January 30, 1984 formally recommended that the procurement be set aside for small i

business. The recomendation was rejected by the NRC Contracting Officer on February 10, 1984. SBA appealed the rejection to the HPA

, o (Director, Division of Contracts), NRC: Amendment One to the IFB was i issued February 17, 1984 suspending procurement action pending further review of the decision to issue the solicitation on an unrestricted basis. The SBA recommendation ultimately went through the entire

! review / appeals procedure prescribed by FPR 1-1.706-2. The EDO, responding as Head of the Agency, made the final decision on May 25, i 1984 that the procurement would not be set aside for small business but

} would continue on an unrestricted basis. Amendment Two to the IFB was i

issued June 1,1984 notifying bidders that the procurement was no longer suspended and reestablished bid opening date as June 29, 1984.

i To provide continuing service during the suspension and until award

] could be made under this IFB, Contract No. NRC-17-83-399 was extended through May 15, 1984. A limited competitive solicitation, RFP

RS-ASB-84-353, was issued April 27, 1984 to provide services for a
2-month period beginning May 16, 1984 with an option to extend the tenn j one additional month, or through August 15, 1984. Award under this i solicitation was made to Tayloe Associates, Ltd., Contract No.

NRC-21-84-353, on May 15, 1984.

As indicated above, Amendment Two to the IFB was issued June 1, 1984.

Among other changes, Part II.B. was amended to add a requirement for I submission of a bid guarantee in the amount of 20 percent of the bid i price, and if the successful bidder,,a requirement for the submission

] of a Performance Bond in the amount of $100,000. The bidders were j

notified that failure to submit the bid guarantee with their bids may j be cause for rejection of the bid.

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6 Bids were opened June 29, 1984. Two bids, sumarized below, were received:

Bidder Total Estimated Amount - First Year Ace-Federal Reporters. Inc. $850,189.75 Tayloe Associates, Ltd. $583,727.20 Tayloe did not submit the required bid guarantee with their bid. They did submit a letter which stated that because of their past exemplary perfomance they elected not to incur the expense of providing a perfomance bond. Tayloe requested the Contracting Officer to exercise his discretion by not requiring the performance bond and stated that if no perfomance bond is required, then a bid guarantee is unnecessary.

FPR 1-10.103-4 and FAR 28.101-4 provide that when noncompliance with a solicitation requirement for a bid guarantee occurs the bid shall be >

rejected except in specific situations none of which are present-in -

this case. The Comptroller General has held that a bid guarantee requirement is a material part of an IFB, and that, except as provided in applicable regulations, a procuring activity must reject as nonresponsive a bid that does not confom with that requirement (B-198095, June 27, 1980, 80-1 CPD 446; B-188978, August 29, 1977, 77-2,CPD155). Accordingly Tayloe's bid was rejected as nonresponsive and was not considered for award. Since Tayloe's prices were not guaranteed and could not be considered, comparison of Ace-Federal's prices for purposes of detemining reasonability of price was not made.

The Source Evaluation Panel (SEP) met, beginning July 11, 1984, to review prices submitted by Ace-Federal. As is shown in the Report of

! the Source Evaluation Panel - ASB-84-352, dated July 20, 1984 (Attachment 1), prices were determined to be reasonable for services to be provided under the contract. The SEP recomended award be made to Ace-Federal Reporters, Inc.(subject to a favorable finding in_the pre-award survey) which was subsequently approved by, the D. f Designating Official on July 23, 1984.

As is shown in the SEP Report, reasonability of price was determined, using as a base, the prices bid for NRC work in D.C. (IF8 SECY-84-327) without travel, adding travel costs, and then comparing Ace-Federal's  !

prices. Travel costs were calculated in two ways; one, actual costs incurred by Tayloe under Contract No. NRC-17-83-399 for 109 hearing days requiring daily delivery, and also by calculating estimated travel costs for hearing sites and duration projected in Attachment No.10 of the IFB. In both cases, Ace was between the average and high calculations. An independent calculation of travel costs per page for original transcripts delivered under the Tayloe contract was done by the Contract Negotiator. Time span covered was four months, July 17, 1983 through November 17, 1983. Data was extracted from contract

_ _ - _ _ _- . . _ . _. . .. __. ._ . -\

7 vouchers actually paid. Of 23 hearings held requiring daily delivery of 19,805 pages, travel costs averaged $2.80 per paDe. For hearings j

requiring 5-day delivery, the average travel cost for 2.449 pages was

$4.24 per page. Combining the two, average per page trhel cost was l $2.%. These averages are substantially the same as thon developed by .

! the SEP and lend further support to the Panel's findings. As shown on '

! Attachment 2, comparison of Ace's prices with Tayloe's prices for the l option year factoring in travel and adjustment for use of i

subcontractors shows an estimated savings of $28,445 by award to '

Ace-Federal . '

} Attachment 3 is a spread sheet showing (1) prices bid by Tayloe and Ace-Federal on the present IFB, (2) the government estimate, i (3) prices offered under RFP RS-ASB-84-353, the 2-month interim l procurement,(4) prices used in the determination made by NRC not to

! exercise the option under the Tayloe contract, and (5) Tayloe's option '

! year prices and first year prices (NRC-17-83-399) and the prior j contract prices with Alderson Reporting Co.

  • Prices in Item 1 cannot be compared since the bid guarantee was not submitted by Tayloe and the bid could not be considered for award. The I SEP did, however, review the prices using the same travel costs as j

those used to determine reasonability of Ace's prices. The Panel determined that if a formal evaluation of the bid had been made, the 1

{ bid would not have been viable. See Memorandum for the File,

Subject:

Report of the Chairman, SEP, AS8-84-352, dated July 23, 1984, l Attachment 4.

I'

] As noted in the SEP Report, the initial government estimate of $6.50

per page was based on prices in the Alderson contract (May 1980 - March 1983) for which bids were submitted in late 1979. Adjustment of the

) esti.T. ate using Tayloe's first year price of $5.47 as a base plus 23 j percent for travel and 4.7 percent inflation changes the per page price

{ to $7.05. With inclusion of the estimate for duplicated copies of $.45 l per page and $1.25 per page for magnetic tape, the corrected government

! estimate is $770,069. The Ace-Federal price of $850,190 is within 10

percent of the government estimate.

l Examination of prices in Item 3 show a wide range for the'same services. This was a short term procurement (two months with a j one-month option) to provide services pending award under this IF8.

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The award was made to Tayloe Associates.

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Their prices were lower than they bid on the NRC j in-town IFB in March 1984 which did not involve travel costs.

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g ex. 4 Interstate failed to submit a technical proposal, therefore, knowledge as tp pow they i

proposed to do the work was not available. ,

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The determination that the option in the Tayloe contract would not be ,

exercised was, of necessity, made within five months following award, i

The $1.32 per page travel cost was based on the limited infonnation available at that time. Actual travel costs experienced, which were retreursable, were more than double this estimate as evidenced by the

, SEP Report and independent DC/ACB calculation of travel costs. The l projected market price of $6.59 did not materialize for this j requirement. The lack of competition is directly attributable to the j complexity of the NRC requirements and stringent delivery provisions.

1 i Item 5 shows prices for the two prior NRC contracts. The Alderson

{ prices include travel; Tayloe's do not. It is noted that Tayloe's original transcript prices are higher than those bid under this IFB

which include travel costs. ,

The following prices are those paid by the indicated agency for

! out-of-town service, daily delivery:

1 1 Agency Price Contractor i ,

i FERC $ Ace-Federal i FTC $ 5.62 Alderson FCC $ 6.49 SKS Group, Ltd.

J NLR8 $8.25(RegionalOfficeCity) Acme Reporting i l NLR8 $ 9.25 (Outside Regional Office Acme Reporting l City) original per page price for three major House Committees range from

$4.22 to $4.80, daily delivery - D.C. only (no travel), depending on the Comittee.

As can be seen from the above range, prices vary significaretly and only  !

through comparison of prices for the same requirement can valid comparisons be made. Causes for the variances in prices are types of i

proceedings (administrative or technical; if technical, the level of difficulty), delivery requirements (daily vs.10 days), validity /

stability of projected hearing sitesi extent of subcontracting, and public sales. The end effect of subcontracting on prices in the formal advertising mode cannot be determined; e.g., does use of

} subcontractors offset to some degree travel costs.

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, Public sales affect prices as can be seen by the - 0 ,. pice for FERC's work. In actuality FERC received two bids, one f' rom l '

Ace-Federal, the other from Acme. Past NRC contracts had not required the contractor to maintain or submit data on public sales of NRC transcripts. There are no data available to evaluate impact of public

, sales on our contract price, therefore, reasonability of price was of i necessity detemined without consideration of sales. ,

j Prices bid by Ace of $.50 per page for duplicate copies, daily delivery

, (bulk of the requirement) are the same as those in the GSA Schedule '

Contract (March 1,1984 - February 28,1985);NLR8hasestablished$.97 as a reasonable price per page for additional copies. The price bid by '

Ace for magnetic tape of $1.25 is considered reasonable. Prices under i

FERC's prior contract (September 30, 1981 - September 30,1983)were

) $1.25 per page and the government returned the tapes, after transfer of l the transcripts, back to the contractor. Under Modification One, Contract NRC-17-83-399 August 17, 1983 Tayloe furnished magnetic tape of Indian Point hearings at $1.25 per page. <

Ace-Federal, as a large business concern, was required and did submit a l l

subcontracting plan within the time prescribed by the IF8. Their plan dated July 20, 1984, as revised July 31, 1984, is very responsive to the requirements of Public Law 95-507 and is acceptable. OSDBU(Von  :

Deloatch) has also reviewed and approved the plan. The plan '

anticipates subcontracting 75 percent of the reporting work of which 60 percent or $350,058 will be subcontracted to small business. Of this

{ small business goal, 20 percent or $116,686 will be subcontracted to i

small disadvanted business concerns.

j The NRC contract work is highly technical with demanding delivery 'l>

1 requirements which require the maximum skills and managerial j capabilities ~to produce quality transcripts on a timely basis. The j

hearing sites projected in Attachment No.10 are best estimates,

! subject to change. In many cases, hearing sites are located in remote areas with limited facilities and services. The contractor must respond to NRC requirements upon 2-days notice.

l The prices submitted by Ace-Federal Reporters, Inc. are reasonable for the contract effort required and acceptance of their bid is in the best

! interest of the government.

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. . SL??.ARY OF PROCUREMENT (C:ntin::ad) l' contract .Nu.cer A T C , ?/. F Y .T ( JL. .

, , , 5upp ie. en$ 1 / gres. ent jio.

e Oir.ER 701:4i5 (incluotng any necessary afapititcations of itams c:vereo in Contrac-Checklist)

CiaTIFicATicN To the best of any knowle$ge, the infor=aticn set f:rth above is c:= pieta and ac: urate. /. ward is ree .::e.:ded.

Signature of Contract Specialist Cate N'Ad L D. M #

AEVIEhED Atl0 AFFROVED a

~ % 4 3,1994 5ignacre * 'en- n - r u r. . Cate AtM- P6 CAREON COPiE5 TO: i soec- tr e ///

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.e Cant ac. specia1is:

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