Support Documentation

Conclusion:  On second appeal, Nashville-Davidson County (Applicant) provided adequate documentation to support reimbursement of costs associated with resident engineering services.

Summary Paragraph: Between April 30, 2010 and May 18, 2010, severe rainstorms, tornados, and straight-line winds, impacted Nashville-Davidson County (Applicant).  The rain-storms caused the Cumberland River to overflow and submerge portions of the fats, oils, and greases (FOG) building and the regenerative thermal oxidizer (RTO), both located at Applicant’s Metropolitan Water Services Biosolids Facility.  To document needed repairs, FEMA prepared PW 5567 for the FOG building and PW 5575 for the RTO system.  FEMA combined these two appeals because they share the same substantive issue—whether Nashville-Davidson County (Applicant) provided adequate documentation of resident engineering costs. In letters dated June 3, 2011, the Applicant filed two first appeals.  Regarding PW 5567, the Applicant requested $38,736.14 for direct administrative costs (DAC), additional contract labor costs, construction management costs, and resident engineering services.   Regarding PW 5575, the Applicant requested $113,820.22 for RTO repair costs, construction management costs and resident engineering costs.  In letters dated May 11, 2012, the FEMA Region IV Regional Administrator (RA) partially approved the appeals, approving reimbursement for facility repairs, contract management costs, and contract labor costs but denying reimbursement of DAC and resident engineering costs.  The RA based the denial of resident engineering costs on a lack of adequate documentation.  On July 24, 2012, the Applicant submitted two second appeals based solely on resident engineering costs—$16,172.00 regarding PW 5567 and $15,369.00 regarding PW 5575.  Upon FEMA’s request for additional information, the Applicant provided additional documents describing resident engineer’s services.