A02- SOW OB-OD-CDC_Permit Support_FEB2024.docx

SCOPE OF WORK February 6, 2024 OB/OD/CDC Permit support

SCOPE OF WORK

OB/OD/CDC Permit Support

February 6, 2024

Task 1 – Project Management and Reporting This Task 1 shall include Contractor efforts for project management to include support staff, participation in routine project calls with BGAD, and other project management activities, such as, monthly progress reports, invoicing, and administrative functions during the period of performance of the contract. Anticipated deliverables are shown below. This task assumes no travel.

Deliverables

· Meeting Summaries

· Monthly Progress Reports and Invoices

Task 2 – Updates to Subpart X Permit Application for Controlled Destruction Chamber

Contractor will support BGAD to update the current CDC Subpart X permit application, to include, but not limited to the inclusion of stack testing results and/or treatability study data as provided by BGAD and revisions to incorporate information resulting from regulatory or public comments or stakeholder meetings. Anticipated deliverables are shown below. All deliverables are assumed as electronic deliverables (e.g., Word, PDF submitted via email, DoD SAFE, etc.). This task may include activities, such as participation in project meetings at BGAD or virtually, regulatory meeting attendance at KDEP office or virtually, and some travel on-site (up to 40 hours). Any requirement to attend such meetings in other tasks is assumed to be included in this task.

Deliverables

· Draft revised permit application (for BGAD review), Draft Final revised permit application (for KDEP review), and Final revised permit application (incorporating KDEP comments)

· Response to comments table, as needed.

Task 3 – Semi-Annual Reporting of Groundwater Sampling for the OD Unit BGAD will provide the relevant field sampling data, access to receiving the data from the analytical laboratory. Contractor shall evaluate the data provided by BGAD and complete groundwater monitoring letter reports for the OD unit (to include 7 downgradient groundwater monitoring wells and one upgradient seep location that serves as background). Specifically, the Contractor will receive, download, tabulate, integrate results into the existing Access database (to be provided by BGAD), perform data validation, and evaluate the results in accordance with the Groundwater Monitoring Plan for the OD Unit included in Part E of the most current BGAD Subpart X permit application and the most current KDEP approved permit and any modifications. This evaluation includes a discussion and graphs of historic trends, tabulation of results and screening against permit screening Levels, reporting groundwater flow rate and direction in the underlying aquifer(s) annually (i.e., in one of two semi-annual reports), and completing a statistical evaluation. The analyses of the following parameters are required based on the current permit and any revisions made based on KDEP reviews:

· Volatile Organic Compounds (VOCs) by SW-846 8260B, specifically benzene and trichloroethylene (trichloroethene)

· 1,4-Dioxane by SW-846 8270D SIM

· Semi-volatile Organic Compounds (SVOCs) by SW-846 8270C and 8270D, specifically p-dimethylaminoazobenzene and 2,4-dinitrophenol

· Target Analyte List (TAL) Metals (Total) by SW-846 6010C, 6020A, and 7470

· TAL Metals (Dissolved) by SW-846 6010C, 6020A and 7470

· Explosives by SW-846 8330B

· Cyanide by SW-846 9012

· Nitrate and nitrite by EPA 353.2

· Perchlorate by SW-846 6850 Statistical procedures shall be in accordance with Section P.III.F.(2)(e) of the BGAD Hazardous Waste Facility Permit, as described in Section E-1b(6) of the Open Burning (OB)/Open Detonation (OD) permit application, and 40 CFR 264.97 as established in 401 KAR 39:090. Section 1. KDEP approved OB/OD permit application (Part E-1b(6) ) shall be used as the basis for using seep SP-19-3b as the background sampling location for performing statistical analysis and comparison of the groundwater data collected from individual downgradient wells. The baseline environmental quality for naturally occurring constituents and statistically significant evidence of contamination shall be determined from the data. The report shall identify any errors or inaccuracies related to sample identification, documentation and packaging requirements, shipping coolers, chain-of-custody, and laboratory procedure for analyses and data evaluation. Contractor shall perform data validation using EPA approved methods to ensure project compliance with specified data quality and reporting requirements, and the precision, accuracy, and data completeness criteria. Reports shall be prepared and provided to BGAD at least one week prior to the submittal date to KDEP for each sampling event in accordance with the permit.

BGAD will perform sampling and procure/subcontract for analytical services and provide the Contractor with field notes, Chains of Custody, and the complete laboratory analytical report. Contractor shall maintain the BGAD OB/OD unit groundwater database (Access) and provide BGAD with the most current version when latest results from both OB and OD wells along with the seep data are integrated.

Anticipated deliverables are as follows: Draft versions of deliverables will be submitted electronically. Contractor shall address BGAD comments on the draft versions and prepare the final versions for submittal to KDEP. The deliverables can be separate letter reports for the OD and OB units. A combined report can be prepared for efficiency, if approved by KDEP.

Deliverables

Task 4 – Semi-Annual Reporting of Groundwater Sampling for the OB Unit Contractor shall receive and evaluate analytical results provided by BGAD and complete groundwater monitoring well reports for the OB unit similar in format to the OD unit and using the same seep data as the upgradient location.

Specifically, Contractor receive, download, tabulate, initiate and integrate results into an Access database, perform data validation, and evaluate the results in accordance with the Groundwater Monitoring Plan included in Part E of the most current BGAD Subpart X permit application and the most current KDEP approved permit and any modifications. This evaluation includes screening against permit screening levels and completing a statistical evaluation. The analyses of the following parameters are required based on the current permit and any revisions made based on KDEP reviews:

· VOCs by SW-846 8260B, specifically benzene and trichloroethylene (trichloroethene)

· 1,4-Dioxane by SW-846 8270D SIM

· SVOCs by SW-846 8270C and 8270D, specifically p-dimethylaminoazobenzene and 2,4-dinitrophenol

· TAL Metals (Total) by SW-846 6010C, 6020A, and 7470

· TAL Metals (Dissolved) by SW-846 6010C, 6020A and 7470

· Explosives by SW-846 8330B

· Cyanide by SW-846 9012

· Nitrate and nitrite by EPA 353.2

· Perchlorate by SW-846 6850 Statistical procedures will be in accordance with Section P.III.F.(2)(e) of the BGAD Hazardous Waste Facility Permit, as described in Section E-1b(6) of the OBOD permit application, and 40 CFR 264.97 as established in 401 KAR 39:090. Section 1. Part E-1b(6) of the KDEP approved OBOD permit application identifies seep SP-19-3b as the background sampling location and requires statistical analysis of the groundwater data collected from individual wells and comparing them with the background well data to determine baseline environmental quality information, where applicable for naturally occurring constituents. The groundwater monitoring report will include any errors or inaccuracies related to sample identification, documentation and packaging requirements, shipping coolers, chain-of-custody, and laboratory procedure for analyses and data evaluation. Data packages will be validated to ensure project compliance with specified analytical, quality analysis, data reporting requirements, and required accuracy, precision, and completeness criteria. Reports shall be prepared and provided to BGAD at least one week prior to the submittal date to KDEP for each sampling event in accordance with the permit.

BGAD will perform sampling and procure/subcontract for analytical services and provide the Contractor with field notes, Chains of Custody, and the complete laboratory analytical report. Contractor shall maintain the BGAD OB/OD unit groundwater database (Access) and provide BGAD with the most current version when latest results from both OB and OD wells along with the seep data are integrated.

Anticipated deliverables are as follows: Draft versions of deliverables will be submitted electronically. Contractor shall address BGAD comments on the draft versions and prepare the final versions for submittal to KDEP. The deliverables can be separate letter reports for the OD and OB units. A combined report can be prepared for efficiency, if approved by KDEP.

Deliverables

· Semi-annual letter reports (Draft for BGAD review and Final incorporating BGAD comments) inclusive of statistical evaluation.

· Updated Access database incorporating latest sampling results.

Task 5 - Miscellaneous Technical Support CONTRACTOR will provide up to 40 hours of miscellaneous technical support as requested by BGAD and approved by Contracting Officer’s Representative (COR) to comply with RCRA and Clean Air Act, Title V regulations, to maintain regulatory compliance with changing requirements of the operations.

Contractor may assume attending up to one (1) day meeting annually at BGAD or KDEP offices to provide support for any regulator negotiations. The deliverables under this task shall be submitted electronically in draft and final versions.

Task 6 - Re-evaluation of Alternative Technologies Contractor shall re-evaluate available alternative technologies to OB and OD and update the Alternative Technologies Evaluation based on new and emerging developments in the alt-techs. This revised evaluation shall also incorporate responses to any KDEP comments on previous submittals and provide a revised report to BGAD for submittal to KDEP.

Deliverables

· Draft, Draft Final, and Final Alternative Technologies Evaluation Reports

· Response to Comments Table

Task 7 - Open Detonation Unit Soil Sampling and Reporting Contractor shall implement the KDEP-approved Soil Sampling and Analysis Plan for the OD Unit (Compliance Schedule item 5). Specifically, the Contractor shall coordinate with BGAD to schedule and collect soil samples within the boundaries of the OD unit in accordance with the approved plan. Contractor shall provide for UXO avoidance for contractor personnel; subcontract for geotechnical analytical services to also include Bulk Density and Particle Size Distribution; receive, tabulate, and evaluate analytical results, perform data validation, and evaluate the results against KDEP-approved screening levels.

Deliverables

· OD Unit soil sampling report (Draft, Draft Final, and Final iterations). Draft versions of deliverables will be submitted electronically. Contractor shall address BGAD comments on the draft version to prepare the draft final version, and address KDEP comments on the draft final version to prepare the final.

Task 8 - Evaluation of Risk and Hazard Due to Arsenic at the Open Detonation Unit Contractor shall evaluate the Arsenic analytical results obtained from this task in accordance with KDEP-approved risk assessment guidance. Specifically, contractor shall estimate risk and hazard posed to human receptors by air inhalation of soil-bound arsenic that is dispersed by OD. The evaluation shall be based on site-specific parameters, including particle size distribution, soil-bound arsenic concentration, and exposure frequency.

Deliverables

· Arsenic Risk Assessment report (Draft, Draft Final, and Final iterations) and electronic modeling files. Draft versions of deliverables will be submitted electronically. Contractor shall address BGAD comments on the draft version to prepare the draft final version, and address KDEP comments on the draft final version to prepare the final.

Task 9 - Modeling Revisions Based on Alt-Tech and OB/OD/CDC Permit Modifications Contractor shall support BGAD with responding to various notices of deficiencies and other comments received from KDEP and USEPA pertaining to the above tasks, which would result in making revisions to the air dispersion modeling and human health risk assessments and the associated modifications to the OB/OD/CDC permits.

Deliverables Draft, Draft Final, and Final Modeling Reports and Permit Modification Applications for supporting the OB/OD and CDC Operations.

Note: Tasks will be ordered as needed for any permit updates needed to support operational changes to BGAD mission and for any assistance needed for responses to Kentucky Division for Air Quality (KDAQ) requests. The government shall be obligated only to the extent of authorized purchases made via a properly executed BPA Delivery Order

**********************END SCOPE OF WORK (TECHNICAL)**************************