2-Wood_BPM003359_Method_of_Approach_Attachment_3_A.pdf

Attachment 3-A Method Proposal (Method of Approach)

The Offeror shall provide a narrative response to each question that demonstrates their understanding of the Scope of Work requirements and describes your company’s overall method of approach for providing the service stated in this solicitation. If there is a question that is not applicable to the services required by the Scope of Work, you may mark it N/A. Responses shall be limited to one (1) page per question.

Do not include marketing materials.

Wood has experience and is qualified to provide services for all disciplines listed in Section 5.1 of the Scope Summary for Assessment and Remediation of Hazardous or Regulated Substances or Materials. Therefore, Wood intends to provide services for the following disciplines listed:

• Legacy Mining

• Phase I ESAs

• Phase II ESAs

• Remedial Investigation / Feasibility Study and EECAs

• Risk assessment

• Consulting Services

• Removal, Transportation and Disposal of Hazardous Substances or Materials

• Recognized Environmental Concerns (RECs)

• Well Abandonment

Question 1: Describe how your company selects a Project Manager for a project.

Offeror Response:

Wood’s Project Managers will be assigned on a Task Order basis such that their skill sets, experience, training, professional qualifications, and available bandwidth all align with the TO requirements, including but not limited to price and schedule. Prior experience managing similar ADEQ and other non-ADEQ projects that are similar in budget and scope will also be highly considered. Wood maintains a rigorous Project Management Program. During 2020, Wood implemented a Project Manager Certification program that included re-certification of previous Project Managers and certification of new Project Managers. Training included six sessions of Project Management Training, Health and Safety Training, and vendor/subcontractor procurement training. It was mandatory for all prospective PMs to complete this training and apply for certification as a PM.

In some cases, the prospective PM was interviewed by Wood management. All PMs that will be assigned to manage TOs have been through this certification process.

Question 2: Describe how your company ensures that a project is delivered on-time, on-budget, and completed correctly the first time.

Offeror Response:

Wood’s Quality Management Program (QMP) is designed to provide reliable, high-quality deliverables and exemplary service to our clients. Based on the ISO 9000 principles, our program integrates our entire project delivery system, including procurement, systems management, subcontractor performance, and all technical execution of our work product.

Our Project Manager has primary responsibility for successful delivery to our customer; specifically, that is the high-quality delivery of the scope of work and fulfillment of all client objectives on-time and on-budget.

Working within our QMP, our Project Managers plan for critical procedures that assure our customers of an accurate and complete work product as they deliver against schedule commitments.

Critical to delivering a project on-time, on-budget, and completed correctly the first time is understanding the client’s expectations. This requires communication with the client representatives and other stakeholders. In some cases, the expectations are too high and unrealistic to achieve. Therefore, this needs to be identified at the beginning of a project and discussed.

Question 3: Describe your quality assurance/quality control procedures for the review and delivery of technical documents.

Offeror Response:

Wood’s Quality Assurance/Quality Control (QA/QC) program provides a systematic approach for increasing the quality of our work activities and effectively integrates planning, assessment, enforcement, training, and lessons learned to exceed contract requirements. This program provides the framework for establishing quality measures, monitoring performance, enforcing quality processes, and achieving continuous improvement. The foundation of our QA/AC program is our corporate Quality Management Plan (QMP) and quality organization.

The QMP establishes standard procedures and accountability, while the organization implements the plan to achieve project objectives.

Technical Review is a critical procedure in Wood’s QMP process. All of Wood’s designs, plans, reports, and other work products undergo a Technical Review where results and calculations are verified, conclusions are independently confirmed, and the work product is compared against project scope of work and our company procedures for compliance. For this on-call contract Wood will assign duly qualified Final Technical Reviewers who will be completely independent from the development of work products. Our Technical Review process of work products is a required procedure that provides our clients with the consistent, high quality work products they expect. Said reviews are recorded on a Wood “Green Sheet” which memorializes and archives the names and dates of all technical reviews.

Following Wood’s QMP processes and procedures, the using agencies will receive quality services that are timely, reliable, and cost effective.

Question 4: Describe your approach to developing a remedial design for a legacy mine site which has been determined to be degrading surface water quality under storm conditions.

Provide a project summary that exemplifies the success of your approach.

How was the success measured or quantified?

The project is the Klondyke WQARF site located in Klondyke, Arizona, which is an unincorporated area of Graham County. Wood has been providing remediation services to ADEQ for this site since November 24, 2016 under the Arizona Superfund Response Action Contract (ASRAC). Klondyke is located approximately 45 miles west of the City of Safford, Arizona, and approximately 150 miles southeast of Phoenix, Arizona. Access to Klondyke is principally via Klondyke Road, a maintained dirt road located 12 miles northwest of Safford, Arizona, extending along U.S. Route 70. According to ADEQ, lead, zinc, copper, silver, and gold mining were conducted in the Klondyke area of the Aravaipa Mining District from the 1870s through the 1950s. In 1948, the Athletic Mining Company constructed a flotation-processing mill next to Aravaipa Creek that operated until about 1958. During the time of operation, lead, zinc, and copper concentrates were produced, along with two mine waste piles, the Lower Tailings Pile (LTP) and the Upper Tailings Pile (UTP). The LTP contained approximately 36,000 cubic yards of tailings and the UTP contained approximately 34,000 cubic yards of tailings. In 1993 during a flood on Aravaipa Creek and the tributary Laurel Canyon Wash, eroded tailings from the UTP had entered into Aravaipa Creek, impacting the water with lead above surface water quality standards.

A RI conducted by others found that not only were the UTP and LTP impacted with lead, surface soils throughout the area were also impacted with lead. There was also a smaller mill operation and associated tailings pile found on a residential property. The UTP was consolidated and capped by others under contract to ADEQ as an early response action.

Utilizing soil data collected by the RI, Wood prepared plans and designs to remove lead contaminated soils from around five existing residences, from areas between the LTP and UTP, and from a portion of Klondyke Road. These were intended to not only remove a health risk to area residents, but to remove a source of lead to surface water. The impacted soils were excavated and placed on the uncapped LTP. The excavations were backfilled with clean, non-impacted fill soil. In the FS, Wood selected consolidation and capping of the LTP and the smaller tailings pile as a portion of the remedy to eliminate the tailings piles as a source of surface contamination and a risk to area residences. A low permeable cap was only required. An economically available source of cap materials was required. Therefore, materials obtained from Aravaipa Creek without the need for a Section 404 permit were processed to 1.5-inch minus for cap materials, 2-4 inch gravel for erosion control, and 4-8 inch rock for rip-rap erosion control. A pre-design aerial survey was performed to obtain the pre-construction surface. The cap design assumed a 1,000-year flood event of Aravaipa Creek and Laurel Canyon Wash. Therefore, the sides of the capped LTP were designed to be armored with the gravel and rock placed in gabion mattresses. The slope was also designed to minimize erosion. Utilizing the surface, the design was prepared and construction specifications along with survey data were provided to the construction contractor qualified for installation of mine tailings caps. Construction was performed during the Spring of 2018. During construction, periodic inspections were conducted by the Wood engineer to assure that the design and construction specifications were achieved. The cap on the LTP was successfully constructed on-time and within budget. A cap was also placed on the smaller tailings pile. A post construction aerial survey was used to develop the as-built drawings.

Declarations of Environmental Use Restrictions (DEURs) with Engineering Controls were filed by ADEQ for the capped tailings piles. Engineering Control Plans (ECPs) were prepared for the capped tailings piles that include annual cap inspections and an O&M plan. The cap inspections were completed in March 2019, March 2020, and March 2021. The caps on the tailings piles were found to be performing as designed. A small erosion channel found along the road to the small tailings pile in March 2019 was repaired and a diversion channel was designed and installed. The March 2020 and 2021 inspections found that the drainage channel was performing as designed.

Question 5: How many legacy mine site remediation or reclamation projects has your firm led?

Describe the most challenging obstacle that your firm has encountered during the implementation of a mining remediation or reclamation project and how you resolved it.

Offeror Response:

In Arizona, Wood has managed mine and mill site remediation or reclamation at 12 sites. These projects have been performed for ADEQ, the City of Tucson, the United States Forest Service, Bureau of Land Management, and on active mining properties. Additionally, we have managed remediation of mining mill related materials that have been placed in two landfills. Wood is also currently performing remedial investigation for coal combustion residual (CCR) deposits at two coal-fired power plants in Arizona. Nationwide, Wood has managed mine and mill site remediation/reclamation at more that 42 sites, primarily located in the Western United States.

Challenging obstacles were encountered during the implementation of mine reclamation/remediation at the Klondyke WQARF site located in Graham County, Arizona. The scope of work involved removing lead contaminated soils from around five existing residences, from areas between the lower tailings pile (LTP) and upper tailings pile (UTP), and from a portion of Klondyke Road. After soil removal was completed, the LTP and a smaller tailings pile were to be capped. One challenging obstacle was obtaining an economically available supply of clean fill and cap materials. The UTP had been capped by another contractor using imported materials obtained more than 30 miles away. This required additional transport permits required by Graham County and improvements to Klondyke Road costing more than $250,000. Total cost to cap the UTP was reportedly more than $5 million. Wood identified that the required materials were present in Aravaipa Creek.

Wood had to work with area residents to remove impacted soils from around their houses, which was successfully done. A portion of Aravaipa Creek crosses the property where the mill site was located and ADEQ had an established access agreement with the property owner. Next, Wood contacted the US Army Corps of Engineers (USACE) to determine possible Section 404 Permit requirements for obtaining fill materials from Aravaipa Creek. The USACE informed Wood that obtaining the materials from Aravaipa Creek would not require a Section 404 permit as long as clean excavation was implemented, specifically the materials were removed from the streambed, transferred directly to a dump truck and the materials processed outside the jurisdiction area of the streambed. The primary requirement was that the excavated area must not be backfilled. A plan was provided to USACE, which issued a determination that the process met the definition of clean excavation. Two excavations were successfully implemented to supplement material left over from the capping of the UTP. Clean excavated material was processed to 1.5-inch minus for backfill and tailings cap materials, 2-4 inch gravel for erosion control, and 4-8 inch rock for rip-rap erosion control. After each excavation was completed, seasonal runoff in Aravaipa Creek naturally filled the excavations. Wood estimates this process saved ADEQ more than $2 million in material purchase and transport costs.

Another challenge involved Klondyke Road. Anecdotal information obtained from area residents indicated that an approximate half-mile portion of Klondyke Road (dirt road) had been surfaced by Graham County with lead and arsenic impacted mill tailings. Subsequent collection of soil samples from the road surface confirmed that lead and arsenic were present above residential soil remediation levels (RSRLs). Klondyke Road is used by area residents and for visitors to the Aravaipa Canyon Wilderness Area. Risk assessment conducted in support of the Feasibility Study indicated that dust from the road surface represented a lead exposure health risk to residents; however, replacing the road surface would significantly decrease the risk. The road is owned and maintained by Graham County. Wood designed a plan to remove the lead impacted surface of the road to a depth of approximately 2-feet and replace it with clean fill material. Meetings were held between ADEQ, Graham County and Wood to determine the process. Graham County decided to prepare the road design at no cost and waived permit fees. Wood and their subcontractor DalMolin Excavating, excavated the impacted materials, placed them on the LTP, and replaced the excavation materials with clean backfill. Dust control was implemented during construction activities. Testing completed by Wood and as-built surveying demonstrated construction specifications were met. The area residents were very satisfied with the final product because the remediated portion of the road produced less dust than other portions of the road and a low spot that pooled stormwater had been eliminated.

Question 6: Discharging adits are often technically challenging and expensive to plug.

Describe successful alternative approaches that your firm has implemented to address these types of discharges.

Because Wood has a strong underground mining group, we understand how to manage water at a high level.

Our mining clients typically need to manage water often, and they come to us to provide successful technical approaches to water management. Our firm has significant experience with the following types of water management techniques:

• We have designed and implemented significant grouting programs using bentonite, cement and even polymer grouts to reduce or eliminate poor quality water flows.

• We have designed installed bulkheads successfully on projects as oxygen is the culprit that causes acid water development from high sulfide materials. Creating anerobic environments reduces the acid development from sulfide minerals.

• We often look for ways to reduce meteoric water that finds its way into a mine adit by first understanding the extent and nature of the mine workings through our mining engineering team members and techniques like 3-D underground mine modeling.

• Other techniques for managing poor water quality from an adit includes passive water treatment techniques such as sulfate reducing bioreactors, evaporation and only if no other options are not economical, active water treatment.

Our team has worked for industry and State and Federal Agencies on a large number of the above types of mine water management projects.

Question 7: During a Phase II ESA the field team comes across material not identified in the SAP, explain next steps.

Offeror Response:

This may involve finding stained soil that was not identified in the SAP, piles of soil that were placed on the site after the Phase I ESA and SAP were completed, or chemicals leaking from containers. The first step is to stay away from the material and not come into contact with the material until it is known what the material is. The property owner or using agency should be immediately notified of the situation and an inquiry made regarding the nature of the material. If the material is potentially hazardous or is unknown, the area should be secured and an emergency response team equipped with proper personal protection equipment brought in to assess the situation, including collection of samples to characterize the nature of the material. The SAP will then need to be revised to include the additional material.

Question 8: Provide an example of performing work for one state agency but dealing with other state or local agencies that have regulatory oversight. If applicable, include the method of approach.

Wood managed a project for the Arizona Department of Transportation (ADOT) that included Phase II Environmental Site Assessment and removal of approximately 9,150 tons of cathode ray tube (CRT) glass on a portion of an ADOT parcel located in Phoenix, Arizona. The CRT glass was disposed on the parcel in a large pile by the adjacent CRT glass recycling company. The CRT glass contained concentrations of lead, which classified the material as hazardous waste.

The waste was originally discovered by the Arizona Department of Environmental Quality Hazardous Waste Unit during a hazardous waste field inspection. ADOT was notified of the issue and contacted Wood for consultation services. Wood worked closely with representatives from ADOT and ADEQ to develop an assessment plan to determine the appropriate waste disposal methods for the large CRT glass pile. Wood developed a CRT Glass Removal Work Plan (Work Plan) and submitted the plan to ADEQ for approval.

Following approval of the Work Plan, ADOT contracted Wood to manage the removal of the CRT glass pile.

Wood developed weekly summary reports for ADOT that were compiled and submitted to ADEQ in a monthly summary report. Wood conducted frequent on-site inspections during the project with ADOT and ADEQ staff.

Following removal of all CRT glass, Wood prepared a removal report that was reviewed by ADOT and ADEQ.

After the removal report was approved, ADEQ issued a letter to ADOT stating that the remedial objectives had been met for the ADOT parcel. By closely working with ADEQ and ADOT, Wood developed a unique remediation plan, successfully managed the removal of all CRT glass from the site and saved the State of Arizona approximately $2M in remediation costs.

Question 9: Requesting Agencies may request that you to perform construction activity oversite, monitor risk & exposure to the general public during a hazardous waste remedial operation at an excavation site where the soil is contaminated with above threshold limits for various Semi-Volatile Organic Compounds (SVOCs) or other Polycyclic Aromatic Hydrocarbons (PAHs).

1) What information would you need from the requesting Agency to monitor exposure to the general public?

Offeror Response:

To guide our development of methods for monitoring, and establishing action level criteria to protect public health, Wood would request site contaminant data for the area to be excavated, the timing and nature of activities likely to release airborne hazardous emissions, and the duration of the expected remedial construction operation. Based on the above, we assume the requesting Agency has contracted with a licensed and certified hazardous waste excavation contractor and that all necessary permits such as dust control and stormwater has been obtained. Therefore, Wood will require copies of the plans and permits.

2) What are your means and methods of approach taken to mitigate the levels of risk and exposure?

Assuming that the remedial site emissions are mainly associated with fugitive dust emissions (because the contaminants are SVOCs and PAHs), Wood would use the site contaminant data or an existing summary to establish the upper confidence limit on the arithmetic mean of lognormally-distributed contaminants.

Assuming that the concentrations in the soil will represent the relative concentrations in fugitive soil dust made airborne, Wood would use these values for each contaminant in an additive cumulative cancer risk/hazard index model to estimate the downwind perimeter concentration that will protect sensitive receptors from adverse health effects. If a site-specific risk assessment is not needed, the Regional Screening Levels from USEPA provide suitable cumulative risk and hazard quotient criteria, and with the assumption above Wood will calculate a site perimeter action level (in terms of micrograms of total suspended particulate per cubic meter of air) that should adequately protect public health (e.g., a cumulative cancer risk of < 1E-06 and noncancer Hazard Index below 1.0).

Occurring in the context of a site air monitoring plan, site-specific meteorological data (e.g., a MetOne Automet system) will be necessary to quantify when monitoring is up or downwind of the site, and the proportion of time that realtime monitoring or integrated samples were up- or down-wind of the exclusion zone on the site. The air monitoring plan will rely on using a nephelometer for TSP dust monitoring by Wood site HSSE personnel (such as a DustTrak II). Our typical approach is to periodically monitor up and downwind dust levels and compare the 5-minute average results from the nephelometer against the perimeter action level. Exceedances are cause for our site superintendent to alert the remedial construction contractor when fugitive dust controls appear inadequate. The contractor would be required to improve dust controls until compliance with the action level is achieved, such as through water application, covering exposed soils, reducing the rate of excavation, etc.

To verify the effectiveness of our controls, Wood would operate high-volume air monitoring stations for TSP at one upwind and up to three downwind locations, each preestablished with line power. The HiVol air samplers would likely have binderless quartz filters with solvent-washed PUF backup to sample for SVOCs and PAHs in accordance with USEPA Method TO-13A, or alternatives (such as TO-4A or TO-9A) depending on the specific SVOCs of concern. Depending on the duration of the remedial action, the reference method TSP results could be plotted versus collocated nephelometer measurements to calculate a site-specific factor for more-accurate estimates of airborne dust than would likely occur with factory calibration data. In any case, the HiVol perimeter air monitoring TSP and SVOC/PAH results would provide objective evidence of the actual downwind fenceline concentrations of the chemicals of potential concern, when paired with the meteorological data over each measurement period. Regular review and communication of these results with the project team provide the best means to ensure successful protection of public health from the proposed remedial action.

Question 10: What is your firms’ approach to a Risk Assessment?

Does this approach vary depending on the hazardous substance and/or media?

How?

Wood’s approach to risk assessment is to evaluate each Site according to both Federal and State level guidance.

Risk assessment begins at the planning stage where risk assessors assist in the development of the sampling and analysis plan for a site. Once the impacted environmental media (e.g., soil, groundwater, surface water, soil gas, etc.) are identified, then the risk assessor evaluates the human receptors that have the potential to come into contact with impacted environmental media. This information is used to develop a conceptual exposure model (CEM). The CEM identifies the source of contamination, how it is transported through the environment, potential receptors, and the exposure pathways by which human receptors may come into contact with impacted environmental media.

The maximum concentrations of the analytes detected in the environmental media with complete exposure pathways are compared to conservative and applicable screening levels. The screening levels are selected based on the type of environmental media being screened as well as the receptor population of interest. There is a potential for multiple screening levels to be utilized, for example, in the case of groundwater, where data may be compared to screening levels based on direct contact with groundwater, as well as vapor intrusion (USEPA VISLs). In addition to risk-based screening levels other criteria, such as state-based criteria, are also considered in the screening process. Those chemicals with detected concentrations in excess of their respective screening levels are considered chemicals of potential concern (COPC) and are carried forward in the risk process.

The next step of the risk assessment process is the calculation of exposure point concentrations (EPCs). The methodology for calculating EPCs are chemical- and media/pathway-specific. For volatile compounds in subsurface media (i.e., soil gas and groundwater) the maximum detected concentration is used as the EPC when evaluating vapor intrusion to indoor air. For other chemical types/media the EPC is defined as the lower of the maximum detected concentration or the 95th percentile upper confidence limit (UCL) on the mean. The 95% UCL is calculated using site-specific data and USEPA’s ProUCL software. The exception to this is lead which uses an average concentration as the EPC consistent with USEPA guidance.

For each identified receptor at the site, exposure factors are selected based on the media of exposure (e.g., soil, air, groundwater), exposure pathway (e.g., ingestion, dermal contact, inhalation), type of receptor (e.g., resident, worker, trespasser), and age of receptor (i.e., adult, adolescent, child). Furthermore, some exposure factors may differ based on chemical type (i.e., carcinogenic vs. noncarcinogenic) and mode-of-action (mutagenic). Default exposure factors are obtained from USEPA and ADEQ guidance documents. If no default exposure factor is available, receptor-specific factors are selected based on other guidance documents and/or best professional judgment.

For each identified COPC toxicity factors are identified. Toxicity factors are based on a hierarchy of USEPA sources of toxicity factors. Toxicity factors are dependent on the route of exposure (i.e., ingestion, dermal, and inhalation), type of toxicity (carcinogenic vs noncarcinogenic), and duration of exposure (chronic vs subchronic). For those COPCs that do not have applicable toxicity factors the toxicity factors from related surrogate compounds may be selected.

Risk is characterized using the identified COPCs, EPCs, exposure factors, and toxicity factors previously identified in conjunction with the risk equations obtained from USEPA and/or ADEQ guidance. These equations are media-, receptor, and exposure pathway-specific. For the inhalation of volatiles exposure pathway, risk is only characterized for those COPCs identified as volatile. In addition, where indoor air data are not available, the vapor intrusion pathway risk associated with exposure to volatiles in indoor air that have migrated from the subsurface is calculated using USEPA’s Johnson & Ettinger model for vapor intrusion. This model incorporates site-specific and chemical-specific information to model indoor air concentrations based on concentrations of volatiles in subsurface media (i.e., subsurface soil gas and groundwater).

Risk is further characterized by summing the estimated carcinogenic risk and noncarcinogenic hazards for each receptor/media/exposure pathway. The cumulative risks are compared to the USEPA and ADEQ acceptable target carcinogenic risk/non-carcinogenic hazard target levels. Those COPCs associated with carcinogenic risk/non-carcinogenic hazard above target levels are considered chemicals of concern that may require further evaluation and/or remediation. The assumption of dose additivity for noncarcinogenic compounds is appropriate only if they affect the same target organ. Where the total hazard index is greater than 1 for any receptor, a more detailed evaluation of potential non-carcinogenic effects based on specific health or target endpoints (e.g., liver effects, neurotoxicity) is performed.

Based on the results of the risk assessment various evaluations may be undertaken to better understand the extent and magnitude of the potential risk. These evaluations can include, but are not limited to, hot-spot analysis, trend analysis, and groundwater plume analysis such as flux to surface water.

Question 11: What approach does your firm take to understand a site before evaluating a potential risk?

Offeror Response:

Generally, a potential risk is initially identified during a Phase I Environmental Site Assessment (ESA), a release of hazardous chemicals/wastes has been reported for a property, a tank system has leaked, or samples from a nearby receptor such as a water well have been detected with concentrations of hazardous compounds.

The Phase I ESA or a Preliminary Assessment will identify hazardous chemicals/wastes at the site and potential features that could cause a release of hazardous compounds to the environment. These are identified as recognized environmental conditions (RECs). This provides an initial list of hazardous chemicals/compounds that will be the subject of a future investigation, referred to as either Phase II ESA or a Site Investigation (SI).

Additionally, geologic conditions such as lithology and depth-to-groundwater are identified. A Sampling and Analysis Plan (SAP) is prepared to identify the media to be sampled and the analytical requirements based on the results of the Phase I ESA/PA. The Phase II ESA and/or SI confirms if a release has occurred to the environment and further evaluates geologic and hydrogeologic conditions. Analytical results are compared to published regulatory levels such as Regional Screening Levels (RSLs), Soil Remediation Levels (SRLs), Aquifer Water Quality Standards (AWQSs), and Maximum Contaminant levels (MCLs). These are referred to as Tier 1 levels and are considered the minimum risk-based cleanup levels for hazardous chemicals/compounds.

However, the Phase II ESA and/or SI does not necessarily define the extent of contamination. Further investigation such as site characterization or remedial investigation is used to define the extent of the contamination. Once a release of hazardous chemicals/compounds is confirmed, a conceptual exposure model (CEM) is developed as described in the response to Question 10. The CEM identifies the source of contamination, how it is transported through the environment, potential receptors, and the exposure pathways by which human receptors may come into contact with impacted environmental media. This is a particular concern with volatile organic compounds (VOCs) such as tetrachloroethene (PCE), trichloroethene (TCE), and benzene. Not only do VOCs result in ingestion, dermal contact, and inhalation exposure pathways due to contact with contaminated media such as water and soil, they can also migrate into buildings from contaminated media, referred to as vapor intrusion. Therefore, identifying the use of VOCs at a site is key to identifying a potential risk. Our approach to understanding a site before evaluating a risk as described in our response to Question 10 is as follows:

• Identify if there is a potential risk at a site by identifying chemical use/hazardous waste management and presence of RECs;

• Review available resources for area-specific geologic and hydrogeologic information;

• Conduct initial investigation to evaluate if a release of hazardous substances has occurred;

• Compare concentrations to published Tier 1 levels;

• Characterize the extent of contamination resulting from the release and media that are impacted; and,

• Develop a CEM

End of Attachment 3-A