2022 Draft PWS for ECO3 Procurement.pdf

National Aeronautics and Space Administration (NASA)

Johnson Space Center (JSC) White Sands Test Facility (WSTF)

Environmental Compliance and Operations 3 (ECO3) Performance Work Statement (PWS)

Draft

ECO3 Draft PWS

Table of Contents

1.0 Program management requirements

1.1 Management and supervisory team

1.2 Financial and project data reporting

1.3 Safety, health, and quality assurance program

1.4 Quality and environmental management systems

1.5 Records management and deliverables

1.6 Information technology (IT) requirements

1.7 Supplies and services

1.8 Training coordination

1.9 Property and facilities

2.0 Environmental restoration requirements

2.1 Remediation system operation and maintenance

2.2 Groundwater monitoring program

2.3 Schedule of compliance restoration projects

2.4 Hazardous waste management units

2.5 Solid waste management units

2.6 Landfill closure and post-closure requirements

2.7 Corrective action program support

2.7.1 Groundwater modeling

2.7.2 Hydrogeological characterization

2.7.3 Investigation derived waste management

2.7.4 Data presentations, plume contouring, andgraphics

2.7.5 Third party interface and support

2.7.6 Natural Resource Damage Assessment (NRDA)

2.7.7 Restoration program briefings, meetings, and conferences

2.7.8 Groundwater reporting requirements

2.7.9 Notice of Intent (NOI) process

2.7.10 Discharge plan DP-1255

2.7.11 NASA Environmental Tracking System (NETS) data calls

2.7.12 Agency fee requests

2.7.13 Restoration program pressure vessels and pressurized systems (PVS)

2.7.14 Inspections and audits

2.7.15 Restoration program training

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3.0 Environmental compliance requirements

3.1 Waste management

3.1.1 Satellite accumulation areas

3.1.2 90-day accumulation areas

3.1.3 Container Storage Unit (CSU)

3.1.4 Point of generation waste characterization

3.1.5 Waste moves and transfers

3.1.6 Universal waste program

3.1.7 Waste characterization shipping packages

3.1.8 Manifests, LDR notices, and exception reporting

3.1.9 Container management

3.1.10 Waste transportation and final disposal

3.1.11 Facility audits

3.1.12 Used oil program

3.1.13 Electronic recycling program

3.1.14 Small arms firing range lead and brass management

3.1.15 Polychlorinated biphenyl waste management

3.1.16 Asbestos waste management

3.2 Hazardous waste permit

3.2.1 Propellant Waste Central Accumulation Area (PWCAA)

3.2.2 Permit modifications, fee submittals, and public notices

3.2.3 Hazardous waste permit

3.2.4 Manage RCRA requirements until completion of Permit transition

3.2.5 Contingency plan

3.3 Air quality program

3.3.1 Air permit compliance

3.3.2 Notice of exemption and no permit required submittals

3.3.3 Title V permit strategy

3.3.4 Risk Management Plan (RMP)

3.4 Wastewater compliance program

3.4.1 Discharge plan DP-1170

3.4.2 Discharge plan DP-697

3.4.3 Discharge plan closure requirements

3.4.4 NOI documents for new discharges

3.4.5 Discharge plan renewal and closure documentation packages ii

3.4.6 Sewer system compliance requirements

3.4.7 Storm Water Pollution Prevention Plan (SWPPP)

3.4.8 Oil and water separator systems

3.5 National Environmental Policy Act (NEPA) and GIS program

3.5.1 Records of Environmental Consideration (ROEC)

3.5.2 Permit to excavate program

3.5.3 Environmental Assessment (EA)

3.5.4 Night-blooming cereus cacti

3.5.5 Cultural resources

3.5.6 Environmental GIS

3.5.7 Environmental Resources Document (ERD)

3.5.8 Integrated Cultural and Natural Resource Management Plans

3.6 Petroleum storage tank program

3.6.1 Petroleum tank regulatory compliance

3.7 Drinking water system compliance

3.7.1 Drinking water system management, sampling, analyses, and reporting

3.7.2 Drinking water compliance records and metrics

3.7.3 Drinking water presentations

3.8 WSC support

3.9 Regulatory compliance deliverables

3.9.1 Community right to know reporting

3.9.2 NETS data calls

3.9.3 Biennial hazardous waste report

3.9.4 Agency fee requests

3.9.5 Multi-media compliance reporting

3.9.6 Waste minimization plan

3.10 Sustainability program

3.10.1 WSTF Sustainability Initiative Team (WSIT)

3.10.2 Site-wide sustainability working group

3.10.3 Recycling center

3.10.4 Recycling and sustainability partnerships

3.10.5 Recycling and waste minimization tracking

3.10.6 Affirmative procurement awareness training and assistance

3.10.7 Environmental awareness and communication activities

3.10.8 Environmental improvement and recognition program

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3.11 Renewable energy program

3.11.1 Renewable energy program assistance

3.11.2 Renewable energy data

3.12 Regulatory reviews, compliance strategies, and technical support

3.12.1 Regulatory review

3.12.2 Applicability and strategy documentation

3.12.3 Technical assistance

3.13 Provide compliance program support activities

3.13.1 Compliance program briefings, conferences, and meetings

3.13.2 Compliance program pressure vessels and pressurized systems (PVS)

3.13.3 Spills and unauthorized releases

3.13.4 Regulatory inspections and audits

3.13.5 Compliance program training

Section 4.0 – Performance Standards Section 5.0 – Acronyms and Abbreviations iv

1.0 Program management requirements

The contractor shall perform all the ECO3 requirements as described in Section 1.0.

1.1 Management and supervisory team

Provide all program management and supervisory team staff to oversee and manage the contract requirements. This program management team includes all senior management personnel, first-line supervisors, and administrative support staff members.

This program management and supervisory team directs a flexible, competent, and qualified support staff to fully accomplish and maintain all contract requirements. The Program Manager is the single point of contact fully responsible for all environmental services, acting as primary interface between the contractor and the NASA WSTF Environmental Office Chief, Contracting Officer (CO), and Contracting Officer’s Representative (COR). Sub-contractors and/or teaming arrangements, if applicable, will be fully integrated into the contractor’s management structure.

1.2 Financial and project data reporting

Provide an accounting system that discretely tracks labor, materials, New Mexico (NM) gross receipts tax, overhead, and other direct and indirect costs per Federal Acquisition Regulation (FAR) 16.301-3(a)(1) by unique project source (task order) and contract Work Breakdown Structure (WBS). Support the Government’s budget process and any special requests for budget impacts. Per Data Requirements Description (DRD-TBD), provide a defined schedule, milestones, estimated cost, and resource loaded task plan(s) for project planning and IDIQ task order estimating that are readily accessible and easily evaluated (Microsoft™ Project, or equivalent). Additionally, assist with short-range (1-year) and longer-range (5-year) budget estimating and forecasting for restoration program funds on an annual, or as requested, basis.

The 1-year and 5-year restoration program planning will be used to evaluate actual work progress against planned work. The contractor will manage, track, and report project cost performance, as well as overall costs (533 Reporting) in accordance with DRD-To Be Determined (TBD) (Project Cost Reporting) and DRD-TBD (NF533 Cost and Data Reporting).

The contractor will also provide a semi-evaluation of contract performance as described in DRD-

TBD.

1.3 Safety, health, and quality assurance program

Perform all tasks to ensure the protection of personnel, property, equipment, and the environment in contractor products and activities generated in support of institutional and environmental program objectives. To ensure compliance with pertinent NASA policies, requirements, federal, state, and local regulations for safety, health, environmental protection, and fire protection, the contractor will develop and implement a safety and health program per a NASA-approved Safety and Health Plan. The “JPR 1700.1, JSC Safety and Health Handbook” provides detailed requirements and instructions regarding safety and health procedures and policies at WSTF and is incorporated by reference into all JSC contracts when performance is at WSTF. Develop and submit a Safety and Health Plan in accordance with DRD-TBD (Safety and Health Plan).

Maintain a comprehensive program of safety, health, and quality assurance by providing general internal safety and quality support and oversight while interfacing directly with the primary WSTF operations contractor (the lead for administering the WSTF site-wide safety and quality programs). The ECO3 contractor coordinates the safety and quality programs for environmental operations through direct interface and support from the primary WSTF operations contractor. However, the ECO3 contractor always complies with all JSC and WSTF safety program requirements and is responsible for all ECO3 safety requirements.

Comply with the software safety requirements resulting from NASA Standard (STD)-8719.3, “Software Safety Standard” and software quality requirements resulting from NASA STD- 8739.8, “Software Assurance Standard” as summarized for WSTF applications in WSTF Standard Instruction (WSI) 21-SW- 0001, “Software Lifecycle Process Control Plan”.

In coordination with the primary WSTF operations contractor’s safety program (the WSTF lead for overall safety program requirements), provide general safety surveillance and compliance oversight and recommendations (including Occupational Safety and Health Administration (OSHA) and NASA institutional safety and industrial hygiene requirements), integrated reporting of injury/lost time per OSHA, workplace surveys, hazard communication (including Safety Data Sheets (SDSs)), visitor and sub- contractor safety training, process safety analyses, emergency preparedness planning, environmental Safety Working Team activities, Fire Warden support for occupied buildings, and investigation, reporting, analysis, and completion of mishaps and close calls when necessary. Additionally, maintain the appropriate written, and annually updated, Job Hazard Analyses (JHAs) for all applicable environmental program activities and provide a Health, Safety, and Environmental (HSE) representative for each government facility where the contractor is the predominant occupant or operator. Perform HSE duties, in coordination with a government counterpart, including quarterly HSE safety inspections (as defined in Section 1.9) at all contractor-occupied facilities. This PWS section has an applicable performance standard, see Section 4.0 for details.

1.4 Quality and environmental management systems

Maintain an effective and timely quality program that includes quality assurance and quality control, reliability, and maintainability of systems, programs, and equipment. Quality assurance (QA) support requirements will be coordinated with the NASA Safety and Mission Assurance personnel.

Provide conformance to all requirements of the WSTF management system and WSTF Document System (WDS), maintain up-to-date documentation, coordinate with QA representatives for document management, assist with internal/external audits, evaluate impacts/aspects, manage objectives and targets, oversee Environmental Management Plans (EMPs), respond to deficiencies using the corrective/preventive action process, and maintain WSTF registration to International Organization for Standardization (ISO) 14001 (a third-party Registrar currently certifies WSTF to ISO 14001 and 9001) and ISO 9001. This certification is a site certification inclusive of a joint contractor-government effort and supports integration of WSTF management and work processes. This PWS section has an applicable performance standard, see Section 4.0 for details.

WSTF has established, documented, and maintained a management system to ensure that products conform to specified requirements. This system is fully documented, providing a detailed description of conformance to ISO 9001 and ISO 14001 requirements. The management system defines the top level management system policies and outlines the structure of the documentation used in the management system. It contains the WSTF Mission Statement and a description of the scope of registration for both ISO 9001 and 14001, which includes all WSTF contractors.

The WDS contains the procedures and instructions consistent with WSTF's stated management policy and are used to carry out WSTF operations. The WDS consists of Product Processes, Infrastructure Processes, WSTF Standard Procedures (WSPs), WSIs, WSTF Job Instructions (WJIs), and WSTF Manuals (WMs). The Product and Infrastructure Processes are process diagrams that map the required activities necessary to satisfy WSTF policies and achieve product quality. Major portions of the WDS have migrated to a WM process, including the

Product and Infrastructure Processes, which will significantly reduce formal document requirements and organize and streamline operational guidance documents.

1.5 Records management and deliverables

Support the environmental deliverable preparation process and the records management system. This system includes electronic versions of all documentation, hard copy filing systems, operating record maintenance, and the associated databases, or equivalent, for tracking deliverables, reports, data, and compliance requirements. Additionally, provide regulatory report deliverables and correspondence support that includes formatting of enclosures, compact disk (CD) preparation, correspondence cover letter drafts, and deliverable tracking and management. Perform a quarterly update to both the internal and external web pages and provide a monthly review and update of the publicly accessible Information Repository.

As part of the deliverable preparation process, ensure that final deliverables prepared during all environmental activities are signature-ready for NASA review, approval, and final submittal. The term signature-ready indicates that the cover letter, enclosures, and all supporting documentation are provided to the Government for final review in a timely manner as a single complete package. The documents will be technically complete, free of typos and grammatical errors, formatted in a consistent and professional manner, and only require minor changes/corrections prior to submittal. Provide a signed certification cover sheet with each document package that states the contractor management and supervisor team has performed a detailed review of all documentation and certifies that the information is ready for release to regulatory agency personnel.

1.6 Information technology (IT) requirements

Adhere to all NASA policies for the management of IT resources, including IT security, software engineering, capital planning and investment, and records/data management. Manage all IT resources in accordance with DRD-TBD (IT Management Plan and IT Capital Planning and Investment Control (CPIC)).

Provide lifecycle management of all government-owned IT assets. Design, develop, procure, install, secure, administer, maintain, and upgrade all approved government-owned IT hardware and software in accordance with NASA standards. Manage and administer systems that are in support of the contract requirements in accordance with NASA IT Security Handbooks. Manage all hardware and software in accordance with NASA IT Security requirements (e.g., inventory, patch, update, and vulnerability tracking and management).

Maintain, operate, manage, populate, and back up numerous government-owned environmental compliance and restoration program database systems. Manage all aspects of the Environmental Information Management System (EIMS), including all operations, compliance, and restoration modules and the current set of EIMS tools. Build new tools and database systems to support project requirements, as needed. Database systems, EIMS modules, and associated tools are currently used for numerous program activities including, but not limited to, records management, project management, deliverables tracking, groundwater data management, compliance requirement tracking, sustainability requirements, corrective action resolution, QA/QC procedures, hydrogeological data collection, waste profiling, remediation system performance, and aquifer capture analyses. Manage all NASA-owned/contractor-held records in accordance with all Federal regulations. This PWS section has an applicable performance standard, see Section 4.0 for details.

1.7 Supplies and services

Provide procurement services for all ECO3 materials, services, travel, and fee payments except for store stock supply materials that are procured by the WSTF operations contractor and obtained through the WSTF warehouse. Procurement services also include invoice management and payments. The procurement system will conform to all Federal procurement rules, regulations, and requirements including considerations for affirmative procurement and bio-based products as applicable.

In accordance with NASA Procedural Requirement (NPR) 4300, NASA Personal Property Disposal Procedural Requirements and WSI 15-SW-0018, Disposal of Government Property, conduct prescreening for purchases of supply and equipment to determine if excess/surplus property is available to offset the cost for new acquisitions. Screening support may be coordinated by utilizing the primary WSTF operations contractor’s Logistics Supply and Property Offices to document the screening efforts for ECO3 acquisitions.

1.8 Training coordination

Ensure all training and qualifications is coordinated, tracked, conducted (for environmental training categories), and properly documented. Coordination includes monitoring the site-wide training database, interacting with the primary WSTF operations contractor’s Training Coordinator to update the database for ECO3 training requirements, and scheduling employees for training classes. Tracking and documentation of training includes monitoring attendance, maintaining sign-in sheets, updating the environmental Operating Record, and scheduling make-up sessions when necessary to maintain up-to-date categories.

Actual attendance at training courses, and trainer requirements for the various categories, will be provided for separately on individual task orders for the compliance and restoration project activities (Sections 2.0 and 3.0). This training includes the annual Resource Conservation and Recovery Act (RCRA) permit training plan requirements, restoration system operator and technician requirements, standard WSTF employee training, Department of Transportation (DOT) required training (where applicable), and site-specific safety training.

Training may require on-site courses, web-based requirements, off-site training courses, and NASA- specific System for Administration, Training, and Educational Resources for NASA (SATERN) requirements. Training categories can include, but are not limited to, 90-day area management, management system awareness, training coordinator refresher, air permit record keeper, affirmative procurement, and WSTF-specific training (e.g., cargo security, hydrazine monitor training, and safety training). This PWS section has an applicable performance standard, see Section 4.0 for details.

1.9 Property and facilities

Conform to all NASA property and equipment control requirements and delegate in writing to the NASA WSTF Property Officer and the CO a property custodian(s) who will be responsible for maintaining accurate inventories, conducting scheduled and unscheduled inventories as required, and submission of property reporting in accordance with DRD-ECO3-TBD (Equipment and Supply Reporting). Losses of Government property will be reported to WSTF Protective Services, documented on NASA Form 598, and forwarded to the Supply Equipment Management Officer (SEMO) and the Property Survey Board Chairperson in accordance with WSI 15-SW-0024, WSTF Property Survey Board and WSI 15-SW-0003, Lost, Damage, Destruction of Government Property. For clarification purposes, the primary WSTF operations contractor is responsible for accounting, reporting, inventory, and reconciliation of all installation-accountable equipment. The ECO3 contractor is only responsible for assigning property custodians that are responsible for maintaining the accountability of ECO3 assigned installation- accountable property, support audits, inventories, and custodian training.

Assigned property custodian(s) will perform a 100% inventory at contract start with the responsible primary WSTF operations contractor Property Officer. In addition, property custodians will perform annual scheduled property audits of items held within their custodial accounts. The property custodians also support periodic external and internal audits or reviews as prescribed by the NASA Property Administrator.

Administer controls of ECO3 satellite storage and bench stock storage areas in accordance with WSI-15- SW-0004, maintain inventories for bench stocks, administer proper storage practices to minimize deterioration of assets and ensure storage areas are approved for use by the NASA SEMO. Also, manage and oversee facilities using HSE representatives from the ECO3 contract to address and correct any facility deficiencies and track facility changes, repairs, and minor upgrades that provide for the health and safety of the facility occupants.

2.0 Environmental restoration requirements

The contractor shall perform all ECO3 requirements as described in Section 2.0.

2.1 Remediation system operation and maintenance

Manage, operate, and maintain the Plume-front Treatment System (PFTS) and the Mid-plume Interception and Treatment System (MPITS). Specific requirements include general day-to-day operations, inspections, routine maintenance, upgrades and repairs, injection well back flushing, infiltration basin maintenance, ground water monitoring, influent/effluent sampling requirements, electrical and control system management (alarms, programmable logic controllers, human/machine interfaces), flow meter tracking, power consumption tracking, reporting, and recordkeeping. Prepare and submit the annual Remediation System Monitoring Plan update in accordance with standard compliance documentation and task order requirements. This PWS section has applicable performance standards, see Section 4.0 for details.

2.2 Groundwater monitoring program

Manage and oversee the facility-wide groundwater monitoring program. The groundwater monitoring program consists of more than 200 wells/zones throughout the site, including conventional wells, WestbayTM and FLUTeTM multi-port wells, piezometers, and soil vapor wells.

Requirements include preparing and tracking sampling schedules (both on-site wells and off-site wells, if required), well sampling field work, mobile treatment system management, procurement and coordination of analytical services, sample shipments, plume capture evaluations, system performance evaluations, data analyses and reviews, QA/QC oversight, report preparation, internal QA audits with associated reports, documentation management, recordkeeping, technician oversight, geological and hydrogeological data collection, down- hole camera logging, water level measurements, pump tests, investigation derived waste management, pump-and-treat project sampling support, and drilling program sampling assistance. Prepare and submit the Periodic Monitoring Report, Monthly Activity Report, and Groundwater Monitoring Plan in accordance with compliance documentation and task order requirements. This PWS section has an applicable performance standard, see Section 4.0 for details.

2.3 Schedule of compliance restoration projects

Prepare detailed Work Plans for investigation and evaluation of corrective measure alternatives at closed hazardous waste management units (HWMUs) and solid waste management units (SWMUs). Requirements for Work Plans include describing field work recommendations (drilling, soil gas, and monitoring wells), project goals and objectives, fate and transport evaluations, historical use summary reports, data collection procedures, data quality objectives, data management operations, analytical requirements, and QA/QC procedures.

Prepare all Work Plans within the due dates specified by the Permit’s Schedule of Compliance, manage the Work Plan process in coordination with the regulatory agency including responding to requests for information and paying review fees, implement all HWMU and SWMU investigation field work as specified by agency-approved Work Plans, oversee all field work requirements in compliance with the agency- approved documentation, request approvals for any deviations, evaluate data, and report the results of all field work. These results will be prepared in the form of formal corrective measures evaluation and implementation reports as described by various hazardous waste permit attachments. This PWS section has an applicable performance standard, see Section 4.0 for details.

2.4 Hazardous waste management units

Evaluate, inspect, track, complete, and document all compliance requirements at the five closed HWMUs. Compliance requirements include routine inspections, documentation of unit condition, maintenance and upkeep, reporting, and recordkeeping.

2.5 Solid waste management units

Evaluate, inspect, track, complete, and document all compliance requirements at approximately 30 closed SWMUs. These compliance requirements include as-needed documentation of unit condition, maintenance, reporting, and recordkeeping. Additionally, for the active small arms firing range, sample the soil annually to provide data on lead concentrations over time.

Maintain the lead concentration data in the SWMU Operating Record.

2.6 Landfill closure and post-closure requirements

Manage the 700 Area landfill closure and post-closure requirements. Requirements include ground water monitoring, data evaluation, detailed recordkeeping, regulatory reporting, methane gas monitoring, and maintenance and upkeep of closure cover materials as needed to prevent deep-rooted vegetation and landfill cell subsidence. Prepare the standard landfill compliance reports in accordance with compliance documentation and task order requirements.

2.7 Corrective action program support

2.7.1 Groundwater modeling

Perform groundwater modeling and mass flux analysis to support corrective action activities.

Groundwater modeling may be used during plume capture evaluations, aquifer characteristics studies, evaluation of HWMU and SWMU corrective action decisions, presentations, and report generation. Update the site conceptual model and groundwater flow and transport model as needed based on the collection of any appropriate and relevant data obtained as part of Section 2.7.2 activities.

2.7.2 Hydrogeological characterization

Perform hydrogeological characterization of the alluvial and fractured bedrock aquifers, to determine hydrogeological properties, identify geological structures, identify groundwater flow paths, and characterize contaminant transport. This can include performing surface geophysics, borehole geophysics, groundwater tracer tests, discreet fracture network (DFN) analysis, characterization of bedrock and clay properties, and characterization of microbiological degradation of contaminants.

2.7.3 Investigation derived waste management

Manage all investigation derived waste generated during restoration fieldwork in a compliant and cost effective manner. Investigation derived waste can include drill cuttings, groundwater purge fluids, and contaminated debris such as sampling equipment and personal protective equipment.

2.7.4 Data presentations, plume contouring, andgraphics

Prepare restoration program reports, presentations, and other documents with specialized graphical representations, as needed. These graphics can include plume contouring, site maps and drawings with boundaries and aerial views, geologic cross-sections and fence diagrams, lithologic logs, 3-dimensional plume maps, large volume data presentations, integration of hydrogeological data with Geographic Information System (GIS), and tabular presentations via database inputs.

2.7.5 Third party interface and support

Support third party requests for general restoration program information, analytical data, on-site and off- site meetings, and compliance data. Examples of third party stakeholders include the NM State Land Office (SLO), the Bureau of Land Management (BLM), the City of Las Cruces, Dona Ana County, the NM Office of the State Engineer (OSE), and the public. Support can include local area offsite meetings, offsite meetings with travel, and preparation of briefings with plume maps, project status information, analytical data tables, and well information.

2.7.6 Natural Resource Damage Assessment (NRDA)

Support all site-specific requirements related to Natural Resource Damage Assessment (NRDA) activities. Activities can include documentation requests, formal data calls, escorting site visitors, split sampling, documentation reviews, and associated meetings or teleconferences. This requirement can include travel, as needed, to address issues with the ONRT or assist with JSC or Department of Justice (DOJ) activities.

2.7.7 Restoration program briefings, meetings, and conferences Conduct, facilitate, and participate in scheduled briefings, teleconferences, video conferences, and meetings on issues within the scope of environmental restoration activities. Identify schedules, meeting locations, and meeting participants and prepare, coordinate, and distribute agendas, minutes, and materials. Additionally, support for off-site meetings with regulatory agencies, the public, and other stakeholders, can occasionally be necessary. These off-site meetings can include travel.

2.7.8 Groundwater reporting requirements

Prepare and submit the quarterly SLO Groundwater Report and the OSE Flow Meter Report in accordance with compliance documentation and task order requirements.

2.7.9 Notice of Intent (NOI) process

Prepare and submit Notice of Intent (NOI) documentation for any new, proposed, or modified restoration program discharges to grade. Additionally, prepare National Pollutant Discharge Elimination System (NPDES) general stormwater permit applications for restoration projects that meet the regulatory criteria.

2.7.10 Discharge plan DP-1255

Manage a Discharge Plan renewal package, as required, by permit-specific requirements of DP-1255. Renewal packages for each Discharge Plan are required every five years. Prepare and submit semi- annual DP-1255 compliance reports in accordance with compliance documentation and task order requirements.

2.7.11 NASA Environmental Tracking System (NETS) data calls

Complete and submit all restoration program NETS data calls as required by NASA Headquarters directives. The due dates for each data call can vary but are routinely posted by NASA Headquarters on the NETS home page.

2.7.12 Agency fee requests

Complete and submit all restoration program agency fee payments in accordance with regulatory requirements and received invoices. Ensure all fee payments are submitted prior to the invoice due dates. Fee payments are paid from the associated restoration project funding.

However, the preparation and handling of the fee payments through the standard procurement process is accomplished as described in Section 1.7.

2.7.13 Restoration program pressure vessels and pressurized systems (PVS) Manage all WSTF restoration program PVS requirements. Environmental support for specific pressure systems will be included on individual restoration program task orders. General engineering and code support for PVS reviews, updates, and approvals are acquired from the primary WSTF operations contractor via the ordered services process.

2.7.14 Inspections and audits

Support all restoration program regulatory inspections from agency personnel (State or Federal), the NASA Headquarters Environmental and Energy Functional Review (EEFR), and internal self-assessment, compliance, and quality program audits.

2.7.15 Restoration program training

Attend all restoration program specific training requirements. The training may include on-site courses, web-based requirements, off-site training courses, and NASA- specific SATERN requirements. Record all training in the WSTF Training Database.

3.0 Environmental compliance requirements

The contractor shall perform all ECO3 requirements as described in Section 3.0.

3.1 Waste management

Manage all solid and hazardous waste requirements. For waste management activities described in Sections 3.1.1, 3.1.2, 3.1.6, and 3.1.12, the end-user (e.g., primary WSTF operations contractor) of the waste accumulation areas (waste generator) will also have specific roles and responsibilities for maintaining the areas on a day-to-day basis, ensuring compliant operations, and communicating any deficiencies or other issues to the ECO3 contractor in a timely manner. The major constraints to the waste generation/management processes are the total quantities generated, the complexity of waste streams (and waste codes) throughout the facility, extensive documentation requirements, shipping and disposal requirements, and the additional costs and management requirements associated with acute hazardous waste. The roles and responsibilities between the ECO3 contractor and the waste generator will be described in the Associate Contractor Agreements (ACAs).

3.1.1 Satellite accumulation areas

Manage the satellite accumulation areas (SAAs) located throughout the facility. Specific requirements include container management, weekly inspections, proper labeling, logbook oversight, and waste moves/transfers. This PWS section has an applicable performance standard, see Section 4.0 for details.

3.1.2 90-day accumulation areas Manage the remote 90-day hazardous waste accumulation areas located throughout the facility.

Specific requirements include container management, accumulation start date tracking, proper labeling, weekly inspections, logbook oversight, waste moves/transfers, training, and implementation of applicable emergency preparedness and spill response requirements. This PWS section has an applicable performance standard, see Section 4.0 for details.

3.1.3 Container Storage Unit (CSU)

Operate and manage the centralized 90-day CSU. Specific requirements include container management, accumulation start date tracking, labeling, weekly inspections, logbook oversight, transport/disposal preparations, lab packing procedures, incompatible material management, facility maintenance, training, empty container/equipment storage requirements, and implementation of applicable emergency preparedness and spill response requirements. This PWS section has an applicable performance standard, see Section 4.0 for details.

3.1.4 Point of generation waste characterization

Characterize and profile each waste stream at the point of generation. Provide WSTF Individual Waste Profile Sheets (WIWPS) to the waste generator, assist with completing the paperwork, evaluate and complete acceptable knowledge or analytical requirements, identify underlying hazardous constituents (UHCs), and fully document all characterization processes.

Characterization is required for hazardous waste, non-hazardous waste, universal waste, used oil, Toxic Substances Control Act (TSCA) waste, and any special waste as defined by State of NM regulations (e.g., asbestos, infectious waste, petroleum contaminated soil, and sludge).

Review and update, if necessary, all active waste stream profiles on an annual basis, or more frequently if the process, quantities, or characteristics have changed.

3.1.5 Waste moves and transfers

Perform routine waste transfers/moves throughout the facility in a safe and environmentally compliant manner that minimizes the potential for spills. Containers that are routinely transferred to the 90-day CSU or the currently RCRA-permitted treatment unit include SAA drums, aspirators, sample Hoke bottles, 90- day tankers, accumulated flush and decontamination trailers, vacuum trailers, and investigation derived waste tank trailers from field operations.

3.1.6 Universal waste program

Oversee and manage the universal waste program. Requirements include collection area management, inspections, container management, accumulation date tracking, and proper documentation, training, shipment, and final disposal. This PWS section has an applicable performance standard, see Section 4.0 for details.

3.1.7 Waste characterization shipping packages

Prepare a written waste characterization package for each off-site waste shipment. Shipping packages are generally required monthly and include all supporting documentation for the characterization of each waste stream being shipped for disposal. Supporting documentation includes, at a minimum, WSTF Individual Waste Profile Sheets, analytical data results, Land Disposal Restriction (LDR) notices and manifest copies prepared as directed in Section 3.1.8, documentation of acceptable knowledge determinations, applicable regulatory documentation (e.g., RCRA Faxbacks), lab packing information such as container contents sheets, logbook copies, and SDS documentation. Waste characterization shipping packages will be provided for NASA review and approval at least 2 working days prior to the shipment date.

3.1.8 Manifests, LDR notices, and exception reporting

Generate compliant manifests and LDR paperwork for hazardous waste and universal waste shipments. Provide the manifests and LDRs to the Government for review, approval, and signature at least 2 working days prior to the shipment date. Manifests must correctly identify proper shipping names, hazard class, packing group, and all other DOT requirements. Track all manifests sent off-site for return within regulatory timeframes to ensure exception reports, if required, are completed and submitted in a timely and compliant manner.

3.1.9 Container management

Containerize, label, and mark all containers of waste prior to shipment in compliance with all Federal and State of NM regulatory requirements, including DOT Code of Federal Regulations

(Title 49) requirements for hazardous material shipments.

3.1.10 Waste transportation and final disposal

Procure, schedule, and arrange all off-site waste transportation and disposal activities using compliant off-site transportation vendors and fully permitted Treatment, Storage, and Disposal (TSD) facilities, where required. Track required shipment dates for all containers to ensure containerized waste does not exceed any accumulation time limits (e.g., 90-day storage for hazardous waste and 1-year storage for universal waste).

3.1.11 Facility audits

Perform an annual TSD audit for the facilities where waste is shipped for final disposal. The TSD audits can be shared between WSTF and JSC to minimize off-site travel and associated costs. Additionally, HQ has implemented an Agency-wide audit program that can also provide audit reports for certain TSD facilities. Telephone and document audits may be utilized in lieu of a site visit for larger, well-known, and previously visited facilities. For any new TSD facilities, or specialized disposals, that do not have a JSC or WSTF audit in the previous calendar year, perform a site visit and complete a TSD audit report. These audits can require local and out-of-state travel.

3.1.12 Used oil program

Oversee and manage the used oil program. Requirements include collection area management, container management, analyses (if necessary), documentation preparation, labeling, shipment scheduling, and disposal (recycle) procedures. This PWS section has an applicable performance standard, see Section 4.0 for details.

3.1.13 Electronic recycling program

Manage the WSTF electronics (e-scrap) evaluation process by conducting inspections of e-scrap accumulation areas to ensure proper storage practices are administered and conduct reviews of all e- scrap proposed for disposal to identify and remove potential hazardous materials, verify waste characterization, and provide authorization to the WSTF Operations Disposal Office to accept e-scrap for disposal/recycling. The WSTF Operations Disposal Office manages e-scrap accumulation areas and has specific roles and responsibilities for maintaining the areas on a day-to-day basis, ensuring compliant operations, and communicating any deficiencies or other issues to the ECO3 contractor in a timely manner.

The roles and responsibilities between the ECO3 contractor and the e-scrap management area personnel will be clearly documented in the contractor ACA(s). The e-scrap management program also includes assistance to White Sands Complex (WSC) personnel, on an as-requested basis.

3.1.14 Small arms firing range lead and brass management

Manage the lead accumulation systems at the small arms firing range including the bullet collection containers and the lead dust bag house system. Requirements include system inspection, lead removal procedures, containerization, storage, and final shipment and disposal (recycling). Additionally, accumulate, containerize, and ship for recycling spent brass from firing range training exercises. Sample and analyze the small arms range as a best management practice for soil contamination on an annual basis, with samples along the front of the capture system at the zero to 6 inch depth.

3.1.15 Polychlorinated biphenyl waste management

Manage all polychlorinated biphenyl (PCB) wastes in compliance with applicable TSCA laws and regulations. PCB wastes are generally limited to small quantities of fluorescent lighting ballasts and capacitors.

3.1.16 Asbestos waste management

For the asbestos program requirements, prepare notifications and annual reporting and assist with final disposal procedures and related documentation. The primary WSTF operations contractor and the Industrial Hygiene Office manage the overall WSTF asbestos program, and the ECO3 contractor only supports the asbestos program with limited project notifications, annual activity reports, waste characterization documentation, and disposal activities. Disposal activities are generally limited to smaller-scale quantities of asbestos waste; larger-scale asbestos activities are completed by trained, and fully certified, asbestos subcontractors procured through the primary WSTF operations contract facilities and engineering programs.

3.2 Hazardous waste permit

3.2.1 Propellant Waste Central Accumulation Area (PWCAA)

Oversee, operate, and maintain the Propellant Waste Central Accumulation Area (PWCAA).

The PWCAA is a large-scale 90-day facility that stores and manages hypergolic propellant contaminated wastewater prior to off-site shipment for incineration. The PWCAA is a large container storage area that allows management of propellant waste streams in both small quantities, standard drums, and bulk containers. Equipment and infrastructure are available at the PWCAA to facilitate transfers and container management in a safe and effective manner.

Requirements include inspections, sampling, analyses, training, recordkeeping, and reporting.

The PWCAA is a closed hazardous waste treatment facility, operating as a 90-day unit;

however, the Permit is still in the renewal process and has not been officially transitioned to a corrective action only Permit. This PWS section has an applicable performance standard, see Section 4.0 for details.

3.2.2 Permit modifications, fee submittals, and public notices Manage regulatory, unit, and operational changes and prepare Class I, II, and III permit modification requests, as needed, to maintain the RCRA hazardous waste permit up-to-date and compliant at all times. Provide permit modification fees and initiate, manage, and complete the public notice process.

3.2.3 Hazardous waste permit

Manage the RCRA hazardous waste permit that is currently in the renewal process. The expectation after NMED approval is that the new Permit will be a corrective action only permit.

3.2.4 Manage RCRA requirements until completion of Permit transition Manage all regulatory and compliance requirements that are required in the interim while the current RCRA permit renewal process is finalized and transitioned to a corrective action only Permit.

3.2.5 Contingency plan

Manage any contingency plan requirements to ensure compliance with the hazardous waste regulatory requirements. Contingency plan work can include routine reviews, updates related to personnel and response equipment, and any major changes to response procedures. Complete any permit modification procedures, including public notice, to maintain a current and updated contingency plan. Manage all requirements specific to the Hazardous Waste Generator Improvement rule.

3.3 Air quality program

Manage the site-wide air quality program. For the air permit requirements described in Sections 3.3.1, note that the organization that is conducting tests or operating facilities or equipment with an in-place environmental permit (primary WSTF operations contractor, or other contractor) will have specific roles and responsibilities for maintaining required compliance data, updating tracking paperwork, ensuring operations are compliant with permit conditions, and communicating any deficiencies or other issues to the ECO3 contractor in a timely manner. The roles and responsibilities between the ECO3 contractor and a test, facility, or equipment operator with an in-place environmental permit will be clearly documented in the contractor ACA(s).

3.3.1 Air permit compliance

Manage the site-wide air permit requirements in compliance with all permit-specific requirements, WSTF procedures, and applicable State and Federal regulatory requirements.

Prepare the air permit compliance reports, including annual inventory requirements, in accordance with compliance documentation and task order requirements. Ensure that that training is provided to any WSTF operations contractor personnel that provide data and documentation to the ECO3 contractor for compliance purposes.

3.3.2 Notice of exemption and no permit required submittals

Prepare notice of exemption and no permit required submittals, as needed by project requirements, for new and modified emission sources. The notice of exemption and no permit required documentation and submittal process is defined in the State of NM air quality regulations.

3.3.3 Title V permit strategy

Develop and maintain internal metrics on emission sources and specific criteria/toxic pollutants to provide a compliance strategy for Title V permit applicability, including maintaining synthetic minor source status. Maintain the regularly updated metrics in the operating record. Update the metrics on an annual basis, at a minimum. Update the metrics more frequently if major test programs change and significant increases in criteria or toxic emissions are expected. These metrics will identify and report when permitted emissions are approaching allowable permit-specific limitations. The metrics will document compliance status for permit requirements and clearly identify emission trends.

3.3.4 Risk Management Plan (RMP)

Oversee and manage the preparation of the RMP which is due every 5 years or when major processes have significant changes. Submit the final RMP to the regulatory agency 15 calendar days prior to the regulatory due date. Note that the primary WSTF operations contractor, with support from the ECO3 contractor and Safety and Mission Assurance personnel, will prepare the RMP.

3.4 Wastewater compliance program

Manage all aspects of the wastewater compliance program. For the discharge plans described in Sections 3.4.1-3.4.2, note that the organization that is operating facilities with an in-place environmental discharge plan (primary WSTF operations contractor, or other contractor) will have specific roles and responsibilities for maintaining required compliance data, updating tracking paperwork, ensuring operations are compliant with permit conditions, and communicating any deficiencies or other issues to the ECO3 contractor in a timely manner. The roles and responsibilities between the ECO3 contractor and the facility operator with an in-place environmental discharge plan will be clearly documented in the contractor ACA(s).

3.4.1 Discharge plan DP-1170

Oversee and manage discharge plan DP-1170. Requirements include sampling, analyses, inspections, recordkeeping, and reporting. Prepare the DP-1170 compliance reports in accordance with compliance documentation and task order requirements.

3.4.2 Discharge plan DP-697

Oversee and manage discharge plan DP-697. Requirements include sampling, analyses, inspections, recordkeeping, and reporting. Prepare the DP-697 compliance reports in accordance with compliance documentation and task order requirements.

3.4.3 Discharge plan closure requirements

Manage miscellaneous discharge plan requirements from DP-392 and DP-584 that are still applicable, if any, during the final closure process as described in permit and closure provisions. Manage all applicable requirements until such time the Discharge Plan is formally terminated by the State of NM.

3.4.4 NOI documents for new discharges

Prepare and submit NOI documentation for any new, proposed, or modified compliance program wastewater discharges to grade.

3.4.5 Discharge plan renewal and closure documentation packages Prepare discharge plan renewal packages as required by permit-specific requirements for all wastewater discharge plans. Renewal packages for each discharge plan are required every five years. Additionally, for discharge plans that are permanently closing due to connection with the City of Las Cruces sewer system ensure that all compliance documentation related to final closure is prepared and submitted in a timely and complete manner.

3.4.6 Sewer system compliance requirements

Provide compliance oversight and support for the sewer system connection. Support requirements include monthly sampling for permit constituents, data analyses, reporting, and recordkeeping. Additionally, perform point of generation wastewater evaluations to ensure discharges meet City of Las Cruces permit requirements.