Attachment 0001 - PWS 01 RFAAP Environmental.docx

RADFORD ARMY AMMUNITION PLANT

PERFORMANCE WORK STATEMENT (PWS)

PWS 1: Environmental April 2026

1. Environmental Management and Compliance

1.1 Environmental Management System (EMS): The Contractor shall implement and maintain an EMS to ensure operations eliminate or minimize the use and generation of hazardous materials and toxic waste. The Contractor shall identify major pollutants, implement source reduction strategies, and assume full responsibility for the management and disposal of all Contractor-generated solid and hazardous waste.

1.2 Regulatory Compliance: The Contractor shall comply with all current local, state, and U.S. federal environmental laws, Executive Orders, and Army Regulations, including but not limited to:

1.2.1 Resource Conservation and Recovery Act (RCRA) (42 USC § 6901)

1.2.2 Safe Drinking Water Act (42 USC § 300f) & Clean Water Act (33 USC 1251)

1.2.3 Clean Air Act (42 USC § 7401)

1.2.4 Toxic Substances Control Act (15 USC 2601)

1.2.5 Emergency Planning and Community Right to Know Act (42 USC § 1101)

1.2.6 CERCLA (42 USC § 9601) & Federal Facilities Compliance Act (42 USC § 9620)

1.2.7 Federal Insecticide, Fungicide, and Rodenticide Act (7 USC 6)

1.2.8 National Environmental Policy Act (NEPA) of 1969, DoD NEPA Implementing Procedures (Appendix A, 30 June 2025), and Army NEPA Guidance (8 August 2025)

1.2.9 Army Regulations 200-1, 200-2, and 420-1

2. Permits, NEPA, and HAZMAT Management

2.1 Permit Management: The Contractor shall apply for, obtain, and maintain all necessary environmental permits. Applications shall designate the Army as the "facility owner" and the Contractor as the "facility operator," with the Contractor signing all certifications required by operators. The Contractor shall provide primary facility permit applications (Title V, RCRA, VPDES) to the Government environmental staff for review 35 working days prior to regulatory submittal. All other permit applications require a 7-working-day Government review period.

2.2 NEPA Documtation: The Contractor shall initiate and complete environmental documentation required by NEPA and AR 200-1. While the Contractor is not required to write Environmental Assessments (EAs) or Environmental Impact Statements (EISs), they shall provide necessary supporting data to the Army. The Contractor shall author Records of Environmental Consideration (RECs), inclusive of all background data and potential impacts, for Government approval and signature.

2.3 Hazardous Materials Management: The Contractor shall develop a Hazardous Materials Management Plan and manage materials/waste IAW Army policies. The Contractor shall obtain user access for and utilize the WEBCASS-E Hazardous Material Inventory Database (HMID) Module as the system of record for HAZMAT/HAZWASTE authorization, tracking, and reporting.

3. Government Access, Audits, and Planning:

3.1 Government Data Access: The Contractor shall provide Government environmental staff unrestricted, read-only access to all environmental databases, drives, TEAMs channels, and document repositories (including blueprints, logs, and procedures) associated with RFAAP and New River Unit (NRU) operations.

3.2 Audits and Planning: The Contractor shall support Government audits (e.g., Environmental Performance Assessment System, Command Inspection Program). The contractor shall assist U.S. Army personnel and support external audit teams and provide access to contractor areas. Additionally, the Contractor shall develop and maintain a forward-looking, 12-month Annual Environmental Compliance Calendar that tracks critical regulations, permit deadlines, training, and reporting obligations. This calendar must be continuously accessible to on-site Government staff.

3.3 The contractor shall provide information and support for all environmental taskers received from the government.

4. Regulatory Inspections and Enforcement

4.1 Inspections: The Contractor shall immediately notify Government environmental staff of any regulatory communications, visits or inspections. The Contractor shall not proceed with any communications, visits or inspections with regulators without a Government representative unless a waiver is granted or Government staff fails to arrive within 30 minutes of notification. The Contractor shall submit meeting minutes/notes (CDRL A01-001) and a list of all materials provided to visitors within 48 hours of completion.

4.2 Enforcement and Liabilities: The Contractor bears primary responsibility and financial liability for all environmental matters, non-compliances, and fines resulting from Contractor (or subcontractor/tenant) actions or inactions. The Contractor shall defend, negotiate, and resolve enforcement actions (e.g., Notices of Violation, orders, citizen suits) at their own expense and reimburse the Government for any associated fines. The Contractor shall not engage in negotiations that obligate the Government without prior written agreement.

5. Incident Reporting and Site Restoration

5.1 Spill Notification and Reporting: Upon discovery of any spill, unauthorized discharge, excursion, or NOV, the Contractor shall notify Government environmental staff via text message within one (1) hour (including time, duration, estimated quantity, location, and suspected cause). For any discharge incident that is reportable to environmental and/or federal agencies, the Contractor shall submit a written pollution incident report with photographic evidence (CDRL A01-002) within 24 hours. If required, the Contractor shall also provide a formal root cause analysis and corrective action plan.

5.2 Environmental Restoration Standards: The Contractor shall clean any spills/releases caused by their operations (including tenants/subcontractors). Cleanup standards are dictated by the location's status:

5.2.1 Non-SWMU/NFA Status: Spills occurring in non-SWMU areas or Solid Waste Management Units (SWMUs) with No Further Action (NFA) status shall be remediated to residential standards to prevent future Army liabilities.

5.2.2 Active SWMUs: Spills on active SWMUs (or HWMU, AOPC, SSA) shall be remediated to industrial standards following appropriate regulatory notification.

5.3 Land Use Controls (LUC): The Contractor shall strictly comply with all LUCs for SWMUs, HWMUs, and AOCs. Prior to issuing dig permits or beginning construction, the Contractor shall review current GIS data to ensure LUCs are maintained and groundwater monitoring wells are protected.

5.4 Perform post-closure care of closed surface impoundments, permitted landfills, and land treatment facilities.

6. Integrated Active Waste Stream Management Plan Execution

6.1 General Scope and Plan Incorporation: The Contractor shall execute the Integrated Active Waste Stream Management Plan (IWSMP) incorporated from its accepted proposal at contract award. The Contractor shall manage, operate, and continuously optimize this IWSMP for all newly generated operational waste streams at RFAAP. To ensure continuous improvement and alignment with facility operations, the Contractor shall review and submit an updated IWSMP to the Government for review and acceptance on an annual basis (CDRL A01-003).

6.2 Waste Minimization and Monetization: The Contractor shall implement waste minimization processes and process optimization techniques to reduce active waste generation. The Contractor shall aggressively pursue byproduct reuse and identify commercial outlets for spent acids, solvents, and out-of-specification products. All commercial revenues and cost-savings generated from waste monetization shall be tracked, managed, and deposited into the Facility Contractor Account (FCA) in accordance with the ARMS PWS 12 program guidelines.

6.3 Hazardous and Non-Hazardous Material Storage Limits: The Contractor shall ensure that no propellant, production materials, manufacturing byproducts, chemicals, intermediates, off-specification materials, newly generated Nitrocellulose (NC) Fines, or residual hazardous materials generated during the performance of this contract are stored on-site for longer than two (2) years and disposed of in accordance with all applicable federal, state, and local regulations and permits.

6.3.1 Inventory Tracking and Aging Analysis: The Contractor shall establish and maintain an automated, software-based inventory tracking system (e.g., barcoding) that performs real-time aging analysis on all stored hazardous materials. The system must include pre-programmed "disposition-triggering" alerts that notify both the Contractor and the Government when any stored hazardous material reaches eighteen (18) months of storage age to ensure disposal occurs prior to the two-year contractual and regulatory limits. (CDRL A01-004)

7. Environmental Key Performance Indicators (KPI)

7.1 KPI Reporting: The Contractor shall track, measure, and report on the three (3) approved active waste stream KPIs established at contract award to drive continuous environmental and operational improvement. In addition, the Contractor shall track, measure, and report on a minimum of three (3) Contractor-identified KPIs that evaluate the performance, effectiveness, and efficiency of environmental efforts at RFAAP. The Contractor shall submit a monthly Environmental KPI Report (CDRL A01-005), with the initial submission due 30 days post-operational control.

7.2 KPI Management: The initial report shall define the calculation methods and establish performance targets (justified by industry standards or baseline data) for Government approval. If any KPI trends negatively or falls below the target for three consecutive months, the Contractor must submit a Corrective Action Plan detailing mitigation steps, timelines, and the personnel responsible for achieving the target.