Attachment_1_-_Performance_Work_Statement.pdf

Performance Work Statement For (2) Long Term Performance Monitoring Plans

& a site specific SAP/QAPP for Animas Forks/Gold Prince Mill Site

BLM GFO - Bonita Peak Mining District, Silverton, Colorado

1. INTRODUCTION

The National Contingency Plan (NCP) (40 CFR 300.435) and CERCLA (40 CFR 121) require performance monitoring and evaluation of remedial actions to ensure that a CERCLA remedy is, and continues to be, protective of human health and the environment. Based upon this requirement, the U.S.

Bureau of Land Management (BLM) requires post removal performance evaluations at Sites where a remedy has been constructed pursuant to BLM’s authority under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).

The EPA developed guidance regarding “5-year Reviews”. The EPA notes that such reviews are specific to remedial actions; however, leeway is allowed for (Policy) and applications towards removal actions are possible on a site-by-site basis. The BLM-Colorado AML program considers the overall objective of 5-year reviews as applicable to removal actions, but with some noted exceptions. The scope of any individual plan is contingent upon a Site’s overall complexity, elements of the response action and the potential consequences of a failure.

The contractor will be required to establish 2 performance monitoring plans that meet the EPA’s 5-year review requirements and align the Sites with the EPA’s processes for partial deletion of sites from the NPL. The BLM drafted several performance evaluation plans in 2015, prior to Bonita Peak Mining District NPL listing but now since the sites are included in the NPL the BLM would like one of the existing plans updated and will require a new evaluation plan to be developed for a site where construction has recently been completed (Elk Tunnel, and Lewis Lake). Where there is an existing plan attention should be on updating and establishing site specific annual monitoring requirements. In addition, the BLM requires a Sampling and Analysis Plan and Quality Assurance Project Plan to support data collecting efforts at the Gold Prince Mill site located in Animas Forks, Colorado.

Important elements of the performance evaluation plans or 5-year reviews will include an update to the existing plan (if applicable), a site inspection plan and accompanying SAP/QAPP for the sampling for the recommended sampling interval and any remaining items needed to ensure that the sites are on track for deletion from the NPL.

2. BACKGROUND

The BLM has performed many CERLCA removal actions within the Bonita Peak Mining District prior to the superfund designation in September 2017. To fulfill the BLM’s responsibilities under CERCLA, the BLM developed several performance monitoring plans in 2015 with a focus on ensuring long term performance of remedies constructed by the BLM. With the addition of the superfund listing, the BLM is realizing the need to update these plans with an eye on partially deleting these sites from the NPL.

3. TASKS

TASK 3.1 RECORDS REVIEW

As the first step in the process, the contractor will review the existing administrative record and any other applicable documents available in the casefiles including existing Performance Evaluation documents and reports completed for the areas and any applicable EPA guidance documents. This research will be documented in the updated Performance Evaluation plans.

The contractor will also perform a data gaps analysis for the Animas Forks/Gold Prince Mill area in preparation for development of a combined SAP/QAPP for the Animas Forks/Gold Prince Mill Site.

TASK 3.2 PERFORMANCE EVALUATION PLANS

The contractor will use data from Tasks 3.1 to compile and synthesize two Performance Evaluation plans and SAP/QAPP for the Animas Forks/Gold Prince Mill area. Also, during this Task, any data gaps should be identified that could be deemed necessary for this project work.

TASK 3.3 PLAN AND IMPLEMENT FIELD WORK EFFORT

The contractor will prepare a Work Plan that includes a Schedule, Management Plan, and Sampling and Analysis Plan with Data Quality Objectives. The Work Plan would be used to support environmental sample collection. EPA has developed a site-wide quality assurance plan for the Bonita Peak Mining District which should be utilized for any required sampling.

TASK 3.4 REPORTING

The contractor shall summarize all results and findings. Drafts of the performance evaluation plans and a draft SAP/QAPP for Animas Forks Site will be provided to the BLM for review and comment.

Comments will be resolved to the BLM’s satisfaction before a final document will be accepted.

4. PROJECT MANAGEMENT

The contractor will submit to BLM monthly progress reports that describe work completed since the previous report, work currently underway, and work anticipated. These reports will detail the schedule and any deviations.

Monthly, or more frequently if requested, the contractor will meet with BLM in person or via conference call, to discuss the upcoming project activities and anticipated support, project or contract issues, and budget.

5. CONTRACTOR REQUIREMENTS

The contractor will be required to maintain Professional Level 1 avalanche certification due to the unpredictable avalanche conditions encountered within Bonita Peak during winter sampling events.

Hazardous Waste Operations and Emergency Response (HAZWOPER) 40-hour certification is also required.

6. DELIVERABLES

The following deliverables will be required for each of the three gulches in both draft and final form in electronic format (after all comments on draft versions are sufficiently addressed). All final reports will be provided in Word on flash drives:

- Work Plan (proposed work, approach, and schedule)

- Draft and Final Performance Evaluation Plans (2)

- Draft and Final Field Sampling Plan (with Health and Safety Plan, Quality Assurance Plan, Sampling and Analysis Plan, and Schedule)

- Monthly Progress Reports