Attachment 11 - ORC PMP Guidance.pdf

Optimized Remediation Contract (ORC) Program Management Plan (PMP)

Guidance Version 6

December 2024

Prepared for:

Air Force Civil Engineer Center

(AFCEC/CZR)

Optimized Remediation Contract Program Management Plan Guidance

ACRONYM LIST

AF Air Force

AFI Air Force Instruction

AFCEC Air Force Civil Engineer Center

AFICC Air Force Installation Contracting Center

BCA Business Case Analysis

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CIP Community Involvement Plan

CLIN Contract Line-Item Number

CO/KO Contracting Officer

COC Contaminant of Concern

COR Contracting Officer Representative

CPSMR Contractor’s Progress, Status, and Management Report

CSM Conceptual Site Model

CZ AFCEC Environmental Management Directorate

DoD Department of Defense

DQO Data Quality Objective

EESOH-MIS Enterprise Environmental, Safety, and Occupational Health Management Information System

EISB Enhanced in Situ Bioremediation

EQS Environmental Quality System

ERPIMS Environmental Restoration Program Information Management System

FFP Firm Fixed Price

FS Feasibility Study

FTA Fire Training Area

IMS Integrated Master Schedule

ISCO In Situ Chemical Oxidation

ITRC Interstate Technology and Regulatory Council

LCC Life Cycle Cost

LTM Long-Term Management

MCL Maximum Contaminant Level

MNA Monitored Natural Attenuation

MPS Milestone Payment Schedule

ORC Optimized Remediation Contract

PM Program Manager

PMBOK Project Management Body of Knowledge

PMP Program Management Plan

PO Performance Objective

POC Point of Contact

POP Period of Performance

PP Proposed Plan

PWS Performance Work Statement

QA Quality Assurance

QAPP Quality Assurance Program Plan

QASP Quality Assurance Surveillance Plan

QC Quality Control

QP Quality Process

QPP Quality Program Plan

RAB Restoration Advisory Board

RA-C Remedial Action Construction

RACR Remedial Action Completion Report

RA-O Remedial Action Operation

RAWP Remedial Action Work Plan

RC Response Complete

RCRA Resource Conservation and Recovery Act

RI Remedial Investigation

RL Remediation Level

ROD Record of Decision

RPM Remedial Project Manager

RRM Remediation Risk Management

RTC Response to Comments

SC Site Closeout

TCE Trichloroethylene

TO Task Order

UFP Uniform Federal Policy µg/L Micrograms per Liter

USACE United States Army Corps of Engineers

UST Underground Storage Tank

UU/UE Unlimited Use/Unrestricted Exposure

772 ESS AFICC 772d Enterprise Sourcing Squadron

INTRODUCTION

This Program Management Plan (PMP) guidance is designed to aid Contractors in document development required to maintain compliance with the Optimized Remediation Contract (ORC) Performance Work Statement (PWS). The Guidance includes the following four sections:

• PMP instructions with two related attachments

• Performance model instructions with one related attachment

• Document quality guidance

• Instructions for Development of Integrated Master Schedules (IMSs) and Milestone Payment

Schedules (MPSs)

Each section contains guidance developed as an expansion of the PWS language to aid the Contractor in developing acceptable documents, including examples and templates.

1 PROGRAM MANAGEMENT PLAN INSTRUCTIONS

1.1 Overview

The Contractor is responsible for complying with all requirements stated in the Air Force Civil Engineer Center (AFCEC) ORC PMP Guidance. The PMP is the basis for confirming that the Contractor understands and complies with the requirements in the PWS. It also provides the Air Force (AF) with the basis for developing oversight activities and Quality Assurance Surveillance Plans (QASPs). Each Contractor shall refer to the applicable sections of the PWS for contract-specific requirements.

At a minimum, the PMP shall include the following sections: a table summarizing the Performance Objective (PO) of each site, technical approach for achieving the POs in accordance with the PWS, draft performance models for sites requiring one, organization and integration of the project team, schedule management and project controls, transitional activities, risk management, quality management, health and safety management, procurement management, and security management.

The PMP shall be maintained throughout the duration of the contract utilizing dated page changes and additions as practicable. PMP updates during the life of the ORC will be necessary based on the accumulation of small incremental changes or significant changes (e.g., contract requirements, technical approaches, risk and issue management, or key personnel). Updates to the PMP shall be coordinated with the Contracting Officer (CO/KO), Contracting Officer Representative (COR), and AF POCs

1.2 Program Management Plan Guidance

The PMP provides information necessary to ensure successful achievement of the POs by the performance period (PP) specified for each site in Table 1 of the ORC PWS, for the contracted cost. The PMP also forms the basis for the QASP.

A large portion of the PMP can be incorporated from the proposal without substantial rework and be modified to include plans based on new information, negotiated terms, or lessons learned since the proposal was prepared. A suggested table of contents is provided in Attachment 1-1. ORC award indicates AF selection of the aggregated package of POs and approaches and does not indicate AF agreement with every aspect of the proposal. Components of individual site approaches needing refinement following ORC award can be reconciled during the process of creating a baseline PMP, IMS, and MPS.

The Contractor shall address the technical approach at each site to include a description of the remedy, risk management, how resources will be organized, and communications with the team will be maintained to accomplish the stated objective. Contractors shall include descriptions of economies of scale and consecutive and concurrent processes that will be implemented to achieve the awarded POs. (Example:

“There will be two teams removing underground storage tanks (USTs) for the first 6 months, then the excavation team at Site 1 will join the team at Site 2 until all the USTs are removed.”)

The technical approach must include a performance model for all sites listed in Table 1 of the PWS that do not have a PO of long-term management (LTM) and have a remedy planned and/or in place. A draft performance model is required in the baseline PMP, and a final, approved performance model is required in the work plan. See Section 2 of this document for performance model guidance. The technical approach shall identify any potential risks that can occur and associated mitigation and contingency actions. In addition, AF approval must be obtained before implementing contingency actions.

Rationale for changes in the technical approach for any site must be put forward to show how the change will meet or exceed the PO compared to the proposed technical approach. In addition, changes to the technical approach must be justified using a Business Case Analysis (BCA) of alternatives to minimize future AF liability and approved by the AF prior to implementation. All alternatives identified for evaluation shall be compared against the currently implemented remedy. An example BCA is presented in Attachment 1-2. The BCA shall include:

• A focused analysis of alternative approaches, to include conceptual designs and engineering cost estimates. The analysis shall identify the total cost of executing the optimized remedy (including the plan and reports).

• An estimate of the reduction of life cycle cost (LCC) due to the alternatives selected to optimize the remedy.

• Any risk inherent in implementing the alternative optimized remedy.

• A summary comparison of the LCC and risk of each alternative in a BCA and a clear statement of the recommended optimized approach.

Information in the PMP technical approach must be consistent with the progression of activities and the dates provided in the IMS/ MPS.

1.3 Program Management Plan Frequently Asked Questions

Q: What is the AF really looking for in a PMP?

A: The PMP is the basis for confirming that the Contractor understands and complies with the requirements in the PWS. The PMP is the “baseline plan” for the specific remedial approaches to achieve the PO at each site. It also provides the AF with the basis for developing oversight activities and QASPs.

Q: What is the connection between the PMP and the QASP?

A: The QASP will identify selected project components and will be used to schedule surveillance activities at appropriate times. Therefore, it is essential that the QASP and Contractor PMP (including the IMS and MPS) remain in lockstep synchronization such that surveillance activities are planned, scheduled, and timed appropriately.

Q: How will the AF and Contracting Agent conduct surveillance for this contract?

A: Using the QASP in conjunction with the PMP, IMS/MPS, and performance models, the AF and Contracting Agent will conduct 100% reviews of all project deliverables. The COR oversees all surveillance activities, with AF point of contact (POC) concurrence.

Q: Can we just screen our proposal for sensitive and proprietary information and submit it as the

PMP?

A: No. It is expected that some of the information in the PMP will come from the Contractor’s proposal;

however, the PMP must stand alone (without the proposal) as a management planning and decision support tool. While portions of the proposal may be used, the PMP is expected to contain more detail on the way the overall project will be conducted, integrating all site-specific approaches and addressing resource limitations, scheduling conflicts, economies of scale, describing how access restrictions will be mitigated, and any other issues that help to understand and support the Contractor’s performance.

Q: Do we need to outline decision logic for determining alternative pathways if risks are realized?

A: Yes. Contingency actions (i.e., remedy) may be necessary if the selected remedy fails to consistently meet performance goals as described in the performance model. Selection of a contingency action must follow a prescribed process to ensure selection of the most effective contingent remedy. Refer to Section

2.1 of this Guidance and Section 8.1.3.1 of the PWS for information on evaluation of performance and implementation of corrective action or contingencies. Descriptions of decision logic and processes, including consideration of contingency actions, are required parts of risk management in PMPs. The decision logic and process shall also include a description of how a BCA of alternatives for each site would be implemented to determine alternative pathways. The BCA must show how future AF liability and LCC will be minimized by the implementation of the selected alternative.

Q: How detailed does the personnel organization management need to be (to what level)?

A: Personnel organization management shall show key personnel and subcontractor roles.

Q: How does the AF make use of the organizational chart?

A: The COR and AF POCs have a primary Contractor POC identified as the Contractor’s Project Manager. Other roles and responsibilities described in the personnel organization management and organizational chart are intended to demonstrate the adequacy of planning and functional relationships among key personnel.

Q: What needs to remain constant from the proposal to the PMP and what is allowed to change?

A: Table 1 of the PWS is binding upon contract award. POs/PPs for each site cannot be changed without modification of the contract. Likewise, the dollar value of each site cannot change without a modification of the contract. These aspects of the contract—the PO/PP/cost for each site—specify what the AF is buying and the Contractor is obligated to deliver. (There may also be other miscellaneous, schedule, and mission-related requirements that must be satisfied.) The technical approach and milestone payments can be changed without modification in response to changes needed to achieve the POs. However, any restructuring of the milestone payments in response to the need to employ contingent actions must be coordinated and approved by the COR and AF.

Q: What is the ORC Transition Plan?

A: The ORC Transition Plan is a strategic document that is initiated by the ORC Contractor two years prior to PoP end date and is delivered at least 90 days prior to the PoP end date. The ORC Transition Plan should include but not be limited to: information regarding site statuses, the status of all operating treatments systems, contractor-owned materials that will be removed and may be needed by the incoming contractor, and documents that may be in review with the regulators at the end of the PoP. The purpose of this plan is to support a seamless transition for the incoming ORC Contractor upon the award of a follow-on ORC. This plan serves as a critical reference for the incoming Contractor when detailing transitional activities within their Project Management Plan (PMP).

1.4 Program Management Plan Checklist

Item No. PMP Checklist Items

1 Include a technical approach for achieving the POs for each site in accordance with the

PWS.

2 Present an organized strategy for coordinating the various tasks.

3 Ensure that POs are identical to those awarded or approved by the AF subsequent to award and meet POs noted in the final PWS Performance Table (Table 1). The PMP must include a Table including the Installation (if a multi-installation ORC), Enterprise Environmental, Safety, and Occupational Health Management Information System (EESOH-MIS) site id, PO, and PP.

Verify that milestone values and schedule may change, with AF approval. The total cost of the Sub-Contract Line-Item Number (CLIN) may not change without contract modification. The final payment milestone must be a minimum of 20 percent of the total Sub-CLIN cost.

5 Verify that although milestones may change during development of the PMP with AF approval, the technical approach is at least as aggressive as presented in the proposal or where different, thoroughly described and supported by a BCA.

6 Verify that the technical approach in the PMP is consistent with achieving the PO in Table This must be supported by a draft performance model for sites with a remedy planned or in place. Subsequent changes to the technical approach must be approved by AF before including in revised PMP.

7 Specify the resources and procedures for the planning, scheduling, execution, controlling, and completion of the POs.

8 Include the project organization, integration, personnel management, resources, and tasks corresponding to each milestone.

9 Include an organization chart identifying the names of key personnel and their roles, including subcontractors, and a description of how the project team will be organized and integrated.

Include a communication plan and stakeholders, a risk management plan, a quality management plan, a health and safety management plan, a procurement management plan, and a security management plan.

11 Describe provisions for adapting the PMP to accommodate revised project plans and schedules.

Describes the quality assurance processes to ensure report submittals include performance data that satisfy Data Quality Objectives (DQOs) and Quality Assurance Program Plan (QAPP) requirements, and demonstrates performance is achieving the goals established in the performance model.

Verify performance models, schedule management and project controls, document quality, and a QASP are provided that allow the measurement and demonstration of progress towards the awarded POs. Note that assessments of these components are described in other sections of this PMP guidance.

14 Include a strategy for risk analysis, management, and mitigation.

15 For sites with a PO of Remedial Action Operation (RA-O) with optimization, an annual performance goal must be specified for each year of remedy operation.

ATTACHMENTS:

1-1: Suggested PMP Table of Contents

1-2: Example BCA

ATTACHMENT 1-1: SUGGESTED PROGRAM MANAGEMENT

PLAN TABLE OF CONTENTS

Below is an example table of contents that can serve as a general outline of the PMP. The indicated sections address the primary PMP components and are considered a starting point in developing the overall structure of the PMP. The structure for any given PMP needs to consider the specifics of the Installation’s remedial program and the details of the negotiated ORC. As such, the example table of contents does not list all possible headings and subheadings and does not prescribe the preferred organization for all PMPs.

PROGRAM MANAGEMENT PLAN

for the

Optimized Remediation Contract at [insert Installation(s) name(s)]

SUGGESTED TABLE OF CONTENTS

(The following topics are suggested to be addressed in the PMP.)

• INTRODUCTION (Present the context of the Task Order [TO], such as Contract Number, Contracting Agent (United States Army Corps of Engineers [USACE] or Air Force Installation Contracting Center [AFICC]/772 Enterprise Sourcing Squadron [772 ESS]) and AFCEC/CZ POCs, TO Number, Scope, etc. Include a table of original and revised POs by site, a list of regulatory objectives, and a regulatory framework detailing regulatory agencies.)

• PROJECT ORGANIZATION, RESOURCES, COMMUNICATIONS (Describe how project team resources will be managed, coordinated, and integrated to achieve project POs.)

Project Team Organization and Responsibilities Organizational Chart Management Approach (Include overall as well as subcontractor management procedures, plans to manage work at multiple installations, and plans to manage multiple and concurrent unforeseen events.)

Communication Plan (Include Project Team and Stakeholders. Address all project communication, including internal, AF POC and Restoration Program Manager, Contracting Agent, regulatory agencies, and public.)

Transitional Activities (Describe how the transition from the previous existing Contractor responsibilities will be managed such that the AF is protected from an absence, delay, or gap in performance.)

• SITE-SPECIFIC TECHNICAL APPROACHES

Details (This includes the anticipated technical approaches, funding, schedule, and deliverables for the sites included in the PWS. This can be taken largely from the proposal but shall also include discussion of efficiencies and economies of scale that the AF can help support to improve productivity. This can be addressed on a site-by-site basis but shall include a discussion of the overall approach for completing the entire TO scope. The technical approach shall include a summary of the general remedial strategy, a site background, current site status, execution, performance, and exit strategy. The technical approach must include Performance Indicators and a performance model. The technical approach must also include potential revised remedial actions that would be implemented, with AF approval, if the Performance Indicators show the need for process improvement/minor corrective actions or process failure/contingency actions.

Contingency actions must include triggers and timing for implementation.)

Risk Management (This may be incorporated into the technical approach discussion for each site or presented as a separate discussion. Resources include Project Management Body of Knowledge [PMBOK] and Interstate Technology and Regulatory Council [ITRC] Remediation Risk Management [RRM] Technical Regulatory Guide.)

• Methodology (Describe how project risks will be identified and evaluated, as well as how revised remedial actions will be triggered, assessed, implemented, and communicated in the context of the AF surveillance requirements.)

• RISK REGISTER (Include general project risks and site-specific risks).

• SITE-SPECIFIC RISK MANAGEMENT MEASURES

• PROJECT PLANS, REPORTS, AND MEETINGS

Project Planning (Discuss how systematic planning will be conducted and documented in the execution of this TO.)

Quality Control (QC) Documents (State when the QC documents required by the PWS will be prepared and submitted, what guidance their preparation will follow, and how the QC documents will be used.)

Monthly/Quarterly Reporting (Describe what will be contained in monthly Contractor’s Progress, Status, and Management Reports [CPSMRs]. Distinguish from what quarterly reports will focus on.)

Meetings (Describe how planned meetings will be communicated and coordinated with the AF and stakeholders.)

Master Document List Sub-CLIN Management (Describe how Sub- CLINs will be managed and integrated into project planning, execution, and reporting.)

• SCHEDULE MANAGEMENT AND PROJECT CONTROLS (Address how project changes and progress will be managed, tracked, and reported.)

Schedule Project Milestones Project Reports

• QUALITY MANAGEMENT

Basic Practices (Describe the Contractor corporate Quality Assurance and Quality

Control (QA/QC) Program and resolution procedures.)

Meeting PWS requirements (Describe how the project management procedures will demonstrate and document achievements integral and necessary for completing the awarded POs.)

Document Control (Describe how document versioning, retention, and archival will be maintained.)

Data and Document Management Problem Resolution

• HEALTH AND SAFETY MANAGEMENT (Resources include 29 CFR 1910.120) Preparation and implementation of site safety and health plans and procedures Training

Medical surveillance Suppliers and subcontractors

• PROCUREMENT MANAGEMENT (Describe how materials, equipment, services, and subcontracts will be procured such that the Contractor and the AF are protected from delays and quality failures. Include competition and best value approach for all procurements.)

• SECURITY MANAGEMENT (Describe how Contractor access to secure areas [like flight lines and research facilities] will be achieved and managed to complete the awarded POs with minimal effects on AF mission.)

• (Suggested) LIST OF TABLES Key Features of Approach Authorities of Personnel to Effectively Perform the Contract Transition Approach General Risks, Risk Impact, and Risk Management Site-Specific Risk Management Points of Contacts and Stakeholders

• (Suggested) LIST OF FIGURES Team Organization Chart Communication Flowchart

• (Suggested) LIST OF ATTACHMENTS Performance Work Statement Technical approach to each site Performance indicators and scientifically based models for each remedial action (include process improvement and corrective action ranges, and process failure and contingency action ranges.)

IMS (Include: Installation name, EESOH-MIS Site ID, CLIN/Sub-CLIN, task description, start and finish dates, milestone payment amount, percent complete, and predecessor and successor. Recommend IMS Microsoft Project file that contains all IMS and MPS information, from which the MPS can be exported.)

MPS (Include: Installation name, EESOH-MIS Site ID, CLIN/Sub-CLIN, milestone payment identification number, milestone payment description, milestone payment amount, milestone payment percentage, completion date, percent complete, and invoice number. Recommend one integrated IMS and MPS within one Microsoft Project file, which can then be extracted to create the two documents.)

ATTACHMENT 1-2: EXAMPLE BUSINESS CASE ANALYSIS

This Attachment provides an example BCA for a hypothetical former fire training site called FT-23 Site.

The example includes a brief site background, description of risks, description of alternatives, cost estimate, and alternative selection rationale. Depending on the nature and complexity of a site, not all aspects of the BCA example may be necessary, but sufficient information must be provided to the AF to enable review and potential approval of the proposed alternative.

Example: FT-23 Site Site Description

Site FT-23 consists of a trichloroethylene (TCE) plume 1000-feet-long in shallow alluvium currently moving slowly beneath an abandoned on-base rail yard but eventually will reach an off-base neighborhood. Minimal biodegradation is naturally occurring, but previous pilot testing showed it can be stimulated. Modeling shows that contaminants of concern (COCs) reach the base fence line at concentrations at Maximum Contaminant Levels (MCLs) in 30 years under current conditions. There are no current plans to develop the on-base area.

Current Project State Description (Current Status)

Remedial Investigation (RI)/Feasibility Study (FS) complete.

Problem Statement

Site cannot be left in current condition for regulatory reasons due to a future off-site risk. Remedial options considered are: (1) Site Closeout (SC) (unlimited use/unrestricted exposure [UU/UE], aggressive in-situ chemical oxidation [ISCO] at highest concentrations of plume), (2) Response Complete (RC) (enhanced bioremediation plus LTM for 9 years, SC in 12 years), (3) Remedial Action Operation (RA-O) Recirculation System (cutoff wells with re-injection using existing wells with 15 years RA-O, SC in 18 years), (4) Monitored natural attenuation (MNA)/LTM for 30 years. Options 2 and 3 require three years of monitoring after RC to prove effectiveness prior to SC.

Objective

The objective of a PO BCA is to select the PO that provides the best value for the AF, balancing cost, risk, land use schedule, and land use scenario (function).

Future Project State Description (Endpoint)

This land is considered industrial but is in an unused portion of the base property. There are no known uses currently listed for this land in the Base Master Plan. There is an off-base residential community at the property line.

Assumptions

It is assumed that characterization is complete and accurate. Contamination in the form of dissolved TCE exists in the groundwater plume in the shallow alluvium. Depth to groundwater is amenable to direct push techniques, pilot studies for ISCO and enhanced in situ bioremediation (EISB) are positive, and there is an existing groundwater monitoring well network.

There is no apparent use of this land that could benefit the AF at this time; however, future liabilities exist if the on-base land were to be developed or if the plume were to reach the community.

Alternatives

Description

• SC: Achieve UU/UE, petition regulators for site closure, and achieve SC.

• RC: Achieve RC within the Period of Performance (POP), achieve SC within next POP.

• RA-O: Achieve RA-O within POP, continue RA-O and achieve SC within next POP.

• LTM/MNA during POP: Continue LTM within POP, SC not achieved for the foreseeable future.

Alternative-Specific Assumptions

• SC: Conduct ISCO injections in areas of plume exceeding MCLs over one-year period, monitor for performance for three years, achieve SC.

• RC: Conduct EISB injections over nine-year period, monitor for performance for three years after injections cease, achieve SC in next POP.

• RA-O: Achieve remedial action construction (RA-C) and RA-O during POP, achieve RC during next POP.

• LTM: Utilize MNA and LTM during POP, manage site minimally and perpetually.

Cost Estimates

See Table 1-1.

Table 1-1. Cost Estimate for FT-23 Site

EESOH-MIS Site Name: FT-23 site Current Status: Former Fire Training Area (FTA) Site plume (CERCLA). RI/FS complete. TCE plume 1000-feet-long in shallow alluvium moving slowly beneath abandoned rail yard but eventually toward off-base neighborhood. Minimal biodegradation naturally occurring but it can be stimulated. Modeling shows that COCs reach fence line at MCLs in 30 years. Area is in industrial portion of base, unused overgrown area. Alternatives: (1) SC (UU/UE, aggressive ISCO at highest concentrations of plume); (2) RC (enhanced bioremediation plus LTM for 9 years, SC in 12 years); (3) RA-O Recirculation System (cutoff wells with re-injection using existing wells with 15 years RA-O, SC in 18 years); (4) MNA/LTM for 30 years.

PO 1: RI/FS to SC PO 2: RI/FS to RC PO 3: RI/FS to RA-O PO 4: RI/FS to MNA/LTM Scope Cost ($K) Present

Worth ($K) Scope Cost ($K) Present

Worth ($K) Scope Cost ($K) Present

Worth ($K) Scope Cost ($K) Present

Worth ($K)

UFP-QAPP $15 $15 UFP-QAPP $15 $15 UFP-QAPP $15 $15 UFP-QAPP $15 $15

Pilot Test $35 $35 Pilot Test $35 $35 Pilot Test $15 $15 Pilot Test $0 $0

PP/ROD $10 $10 PP/ROD $10 $10 PP/ROD $10 $10 PP/ROD $10 $10

RD/RAWP $15 $15 RD/RAWP $15 $15 RD/RAWP $15 $15 RD/RAWP $0 $0

RA $950 $950 RA $500 $430 RA $150 $150 RA $0 $0

RACR $15 $15 RACR $15 $12 RA-O $150 $75 RA-O $0 $0

LTM1 $30 $30 LTM1 $30 $28 LTM1 $30 $28 LTM2 $100 $50

PoP TOTAL $1,070 $620 $385 $125 Present Worth PoP Total ($K) $1,070 $545 $308 $75 Post Closure Care Scope Cost ($K) Present

Worth ($K) Post PoP Cost ($K) Present

Worth ($K) Post PoP Cost ($K) Present

Worth ($K) Post PoP Cost ($K) Present

Worth ($K)

N/A 0 5YR 2015 $5 $3.10 5YR 2015 $5 $3.10 5YR 2015 $5 $3.10

N/A 0 5YR 2020 $7 $2.70 5YR 2020 $7 $2.70 5YR 2020 $7 $2.70

N/A 0 5YR 2025 $9 $2.15 5YR 2025 $14 $3.35

N/A 0 5YR 2030 $16 $2.38

N/A 0 5YR 2035 $18 $1.66

N/A 0 5YR 2040 $20 $1.15

Post Closure TOTAL $0 $0 $7 $3 $21 $8 $80 $14 Present Worth TOTAL $1,070 Present Worth TOTAL $548 Present Worth TOTAL $316 Present Worth TOTAL $89

Notes: 1 - LTM to prove site closure assumes 1 sampling round per year for 3 years after RC; 2 - Includes LTM costs only for 10-year ORC POP, thereafter, included in 5YR costs

Acronyms: CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act; PP/ROD – Proposed Plan/Record of Decision;

RACR – Remedial Action Completion Report; RAWP – Remedial Action Work Plan

Non-Financial Considerations

Although this location is currently an unused industrial part of the installation, there is potential for future construction on base, including housing units, and a potential risk if the plume migrates past the installation boundary.

Analysis

Table 1-2. PO BCA Summary Table for FTA-23 Site

Date of PO BCA Day, Month, Year Base and Site ID Installation and Site ID Site Description FTA-23: Former FTA Site plume Project Status Currently being managed under contract XX. RI/FS complete.

Problem Statement TCE plume 1000-feet long in shallow alluvium moving slowly beneath abandoned rail yard but eventually toward off-base neighborhood.

Minimal biodegradation naturally occurring but it can be stimulated.

Modeling shows that COCs reach fence line at MCLs in 30 years. Area is in industrial portion of installation, unused overgrown area.

Objective Select the PO that represents the best value for the AF, balancing cost, risk, land use schedule, and land use scenario.

Assumptions General Most probable future project state endpoint is industrial land use; base is active. Installation is fenced and guarded with no public access. Private housing off base near fence line.

Alternatives SC during POP with UU/UE in 3 years

RC during POP, SC with UU/UE in 12 years

RA-O during POP, SC in 15 Years

IC/LTM during

POP, SC 30+

years

Alternative-Specific Assumptions

PO 1: ISCO

injections and

SC (UU/UE)

PO 2: EISB

injections and RC

PO 3:

Groundwater recirculation system to RA-O

PO 4: MNA to ICs/LTM

Cost to Achieve PO within PoP ($K)

$1,070 $548 $316 $89

Non-Financial Factors

No residual risk, short duration

No residual risk, moderate duration

No residual risk, slightly longer duration

Potential residual risk, longest duration

Cost/Benefit Analysis Comparison of PO 1 has PO 2 has PO 3 has less PO 4 has Alternatives highest short- moderate cost, cost, more minimal cost to term cost but no residual risk infrastructure implement, no residual risk, but longer to intensive, only probable no LTM implement, no slightly longer to residual risk, LTM implement than longest duration, PO 2, no residual LTM, no SC risk, no LTM

Results • Remedial action objective of SC can be achieved but with increased expenditures during POP

• Current site conditions are protective of human health and the environment but do not preclude plume movement or daughter products

• Potential benefits that may be gained by increased expenditures to reach SC during initial 10-year POP cannot be justified by current site conditions, modeling results or project requirements

• PO 3 uses existing wells, allows for modification of existing systems or injections if needed to speed results, and will reach SC

Best Value Decision Balance Decision Summary Cost ($K) Risk Land Use

Schedule Land Use Scenario

$316 Low Site Risk, Higher Off-Site Risk

No planned change

Industrial to Residential (off-site)

Recommendations Recommended PO: Alternative 3, RA-O The selected PO is RA-O.

Summary Statement of Recommended PO

Because this site is currently low risk, with no receptors, and aggressive remediation methods are costly, it would make sense to select MNA with LTM for this site for the PoP; however, because the plume will migrate off-base in the future, the Best Value Decision is to achieve RA-O for this site during the POP.

This is a lower-cost option than Alternatives 1 and 2 but still maintains control and reduces risk at lower cost. If land use changes, the existing RA-O remedy can be augmented with more aggressive in-situ methods.

2 PERFORMANCE MODEL INSTRUCTIONS

2.1 Overview

In accordance with the PWS, Contractors shall develop performance models that describe how site conditions are expected to change over time, using appropriate performance indicators, from the current baseline state through PO achievement. Performance models are required for all sites listed in Table 1 of the PWS that do not have a PO of LTM and have a remedy planned and/or in place. Actual performance must be evaluated against performance predicted by the performance model at least annually, and this activity must be identified in the IMS.

In general terms, performance will be measured against meeting and demonstrating value-added (remedial) services as described by the PO. Under an ORC, the Contractor determines the method(s) to meet the POs with a larger goal of reaching the POs rapidly and efficiently. Specifically, as part of each site technical approach, the Contractor develops performance model(s) that define the performance indicators and standards to be used in assessing the performance of their remedial actions and monitoring programs. Those performance indicators (measurable parameters that can be used to represent most directly remedial mechanisms) may be presented as primary or secondary goals that include reduction of contaminants in impacted media (decay curves, mass flux, etc.), maintaining capture of an existing groundwater contaminant plume, reaching or maintaining regulatory compliance, and reducing site LCCs.

The performance model facilitates communication between the AF and Contractor and provides a framework that incentivizes the Contractor to develop exit strategies aiming to close sites as efficiently as possible and reduce the AF’s overall environmental liability.

Summarizing from the PWS, performance models shall:

• Be based in the understanding of the current Conceptual Site Model (CSM) and represent the extent of contamination being addressed for a given COC.

• Be scientifically based.

• Define the baseline state for a given COC.

• Include a documented approach to quantifiably determine remedial progress relative to the defined performance indicators, to apply decision criteria associated with performance indicator results, and to demonstrate achievement of annual and final goals consistent with the projection of expected performance in the performance model.

• Differentiate indications of successful demonstration of contaminant reduction, process improvement and corrective action, and process failure and contingency action that reconcile underperforming remedies when combined with the decision criteria.

The performance model must also contain supporting information explaining the development approach and justification. Sufficient detail includes, but is not limited to, identification of baseline conditions specific to the proposed performance indicator; the sample data used (e.g., monitoring wells and dataset range) and methods employed (e.g., statistical approaches for summarizing sample data) in developing the baseline and future performance indicator data; the methods employed to project expected performance (e.g., best-fit model); how performance indicator data is evaluated against expected performance; and decision logic used to conclude successful remedial performance and achievement of proposed performance milestones, when to implement corrective or contingency actions, and what the corrective/contingency options might be. An individual site/COC may have more than one performance model (e.g., different parts of the site that are addressed by separate remedies and represented by different sets of monitoring wells). In addition, multiple performance models may be needed to reflect variability in site attenuation rates at different locations of the site (e.g., aquifer zones, source area versus dilute plume).

Each Contractor shall refer to the applicable sections of the PWS for contract-specific requirements.

Performance model development incorporates two primary components: (1) determining the performance model baseline and (2) projecting the expected course of site performance from the baseline through PO achievement, or simply, model performance.

2.2 Performance Model Guidance

This guidance focuses on developing a performance model that uses COC concentration as the performance indicator. Certain site POs and remedies may require different types of performance models and indicators, and site-specific factors may influence the inputs to the models (e.g., use of certain wells and data ranges) that cannot be fully addressed in this general guidance. Therefore, an acceptable performance model is not limited to the approaches described in this guidance and may include other mathematical approaches based on professional judgement.

Determine Performance Model Baseline

A fundamental component of the performance model is the baseline – the starting point of the performance model. The baseline state is determined by using select monitoring wells that are representative of the site and have sufficient data to develop statistics-based historic concentration trends for site COCs. A scientific approach that uses a line of best-fit (e.g., first order decay rate) is appropriate for estimating the baseline attenuation rate. The baseline attenuation rate, in turn, can be used to extrapolate a baseline concentration and measures of future performance. Supporting information for the baseline concentrations must include the rationale for the well selection and the time period used to develop the trends, justification for the selected line of best-fit, actual values used to define the trend, and extension of the line of best-fit to predict values for future years independent of future remedy implementation plans. Other statistical approaches can be used to calculate a baseline concentration, such as calculating a mean concentration value for the site COC. If multiple methods are used to calculate a baseline concentration, then the most conservative value (i.e., lowest concentration) shall be used.

An approach for generating a performance model baseline, with an example, that uses two methods for determining the baseline concentration and selects the more conservative value is described in Attachment 2-1.

Modeling Performance

A performance model is used to compare actual performance indicator data gathered as the remedial action progresses with projected performance. This comparison is expected to facilitate optimization decisions and demonstrate achievement of identified interim goals, and ultimately, the PO. The initial performance model(s) shall include projected values of performance indicators that are based on all available data provided in the Government Furnished Information and account for any proposed enhancements to the baseline conditions (e.g., acceleration of the baseline attenuation rate). These projections serve as a starting point for defining milestones that demonstrate value-added progress (e.g., concentration reduction) toward the PO, which may be defined as payment milestones in the MPS. As data become available warranting updates to the CSM understanding and remedial exit strategy, performance models shall be further refined in the development of site-specific work plans. Contractors shall devise and prepare performance models that provide sufficient detail for the AF to transparently evaluate actual performance data against projected performance indicator values. Performance indicator projections must be scientifically based, employing statistical approaches where possible, and are typically consistent with methods used to define the performance model baseline. Because performance models are to reflect the proposed site exit strategy, performance projections shall be extrapolated through the performance period and achievement of site remedial goals or remediation levels (RLs). The applied area of the performance model during the performance period may only be a portion of the overall exit strategy.

Outline decision logic capable of identifying performance issues that would preclude achieving the POs as soon as the data indicate unacceptable performance, triggering corrective action and/or contingencies as soon as possible. Such decision logic is aided by using performance thresholds that signify acceptable performance, the need for process improvement and corrective action, and process failure and need for contingency action. Thresholds shall be developed taking both rates of contaminant reduction and inherent data variability into consideration and must also be protective of achieving the PO. Options for corrective or contingency actions shall be identified as part of the decision logic.

Demonstrated progress that is not on target through comparison against the expected performance is valuable for indicating re-evaluation of a given approach. The Contractor must continually review progress and present annual reports at a minimum, or whenever new monitoring data that feed into the performance model is reported, with actual data values and explanations, as necessary. Consistent with established decision logic, missing a performance threshold during a certain period will trigger an evaluation of why actual performance is not as expected. Remedial performance outside of expected threshold ranges may show the need for process improvement and trigger corrective actions or show process failure and require contingency actions. It also may indicate CSM inadequacies that have not been accounted for in the performance model, which can dictate performance model refinement consistent with an updated CSM and exit strategy. Any proposed changes in the technical approach must be scoped with the AF, planned, documented, and justified to show how the change will meet or improve the endpoint the Contractor set in their original technical approach. Proposed changes to the technical approach must be approved by the AF.

An approach for generating a performance model, with an example, consists of projecting expected performance, establishing performance thresholds, and identifying decision logic through use of performance indicator data, is described in Attachment 2-1.

2.3 Performance Model Frequently Asked Questions

Q: What is a performance model?

A: A performance model is typically a technically based predictive model that describes and graphically shows (using an illustration, plot, graph, or rarely a text description) the expected changes in a performance indicator over time throughout the performance period and until RLs are achieved. An example of a performance model is a plot showing groundwater concentrations following an exponential decay curve. The performance indicator in this example is the groundwater concentration of the COC (micrograms per liter [µg/L]) and the model is the plot showing the sequence of values that indicator is expected to take over time (each year). As with all environmental data, error and variation about the expected value will be typical, and interpretation of data will be required to determine compliance or substantial deviation from the expected values in the model. The performance model shall include depiction of successful contaminant concentration reduction, process improvement and corrective action level thresholds, and process failure and contingency action level thresholds, that when combined with the decision criteria shall reconcile underperforming remedies.

Q: Why is a performance model for each COC required?

A: A performance model is required for each COC to assure the AF that the remedial actions are effective for each COC and not causing buildup of intermediate contaminants. For example, biodegradation of TCE can produce vinyl chloride, which is more toxic than the TCE parent.

Q: What is a performance indicator?

A: A performance indicator is a measured or calculated parameter that represents a specific mechanism or benefit resulting from a specific remedial action. For example, in the context of a groundwater extraction system with an objective to remove mass as efficiently and effectively as possible, contaminant concentrations in groundwater would NOT be an appropriate performance indicator since reductions in concentration would not discern between the mass removed by extraction and other possible mechanisms responsible for those reductions (e.g., natural attenuation). Mass of contaminant extracted per unit time

(e.g., month) could be used as a performance indicator for the groundwater extraction system. Remedial approaches may have more than one performance indicator that is useful for demonstrating their effectiveness and efficiency. A performance indicator is presented in a performance model as the measure of value-added remedial progress towards contract POs and overall site objectives.

Q: When is a performance model developed and submitted to the AF?

A: A performance model is an excellent tool to demonstrate integral and necessary accomplishments for any site with remedial or removal actions. Performance models fit well into documents that are required to comply with the Interagency Data Quality Task Force Uniform Federal Policy on Environmental Quality System (UFP-EQS) and UFP-QAPP policies, as are all documents that plan the collection of environmental data. Therefore, performance models can appropriately be components of the PMP, work plans, monitoring plans (especially performance monitoring plans), technical reports, optimized exit strategies, and other documents that predict and report changes to environmental conditions resulting from remedial efforts. Final Performance Models, subject to be modified as needed during the life of the contract, shall be submitted along with the Work Plan required under PWS Section 6.1.2

Q: Sites with Sub-CLINs for RA-O with Optimization include performance Sub-CLINs for “Achieving performance goals per the performance model” and compliance Sub-CLINs for “Conducting RA-O.”

Why are there two kinds of Sub-CLINs for these sites?

A: The performance Sub-CLINs are specifically for reporting progress in achieving the performance goal identified in the performance model. This requires a separate report for each year evaluating the result for the performance indicator(s), usually a COC concentration, and how it compares with the projected value of the performance indicator in the performance model. Compliance Sub-CLINs are specifically for operating the remedy and reporting all required results, such as COC concentrations, geochemical, groundwater elevations, etc.

2.4 Performance Model Checklist

Item No. Performance Model Checklist Items

1 Provide a detailed explanation of the methods, with technical rationale, for generating the performance model baseline and projected expected performance.

2 Graphically illustrate expected performance throughout the performance period and to the site end point (i.e., achievement of RL).

3 Clearly define projected performance indicator values for annual and final performance goals that are consistent with payment milestones in the MPS.

Define performance thresholds that differentiate success, process improvement, and process failure with decision logic that specifies the course of action relative to each performance threshold.

ATTACHMENTS:

2-1: Detailed Performance Model Approach and Example

ATTACHMENT 2-1: DETAILED PERFORMANCE MODEL

APPROACH AND EXAMPLE

Approach

Determine Performance Model Baseline

1. Determine site-specific primary COCs and performance monitoring wells by using one of the following approaches:

a. Conferring with the Installation Remedial Project Manager (RPM) and Program Manager (PM); or

b. Identifying monitoring wells with contaminant concentrations exceeding RLs or remedial action objectives within the past five years.

• Query the Environmental Restoration Program Information Management System (ERPIMS) to determine wells exceeding RLs within the past five years.

• Identify primary COCs per a PP/Decision Document or other recent document identifying

COCs based on occurrence within the past five years.

• Provide justification for exclusion of wells exceeding RLs that are not used as performance monitoring wells.

• Select performance monitoring wells that are representative of the extent of contamination being addressed by a given remedy. Multiple performance models shall be developed if there are separate remedies addressing different parts of the site that are represented by different monitoring wells. In addition, multiple performance models may be needed to reflect variability in site attenuation rates at different locations of the site (e.g., aquifer zones, source area versus. dilute plume).

2. Gather relevant analytical data associated with the selected performance monitoring wells and the selected COCs within the past ten years, or other available data range that represents the current site conditions, from ERPIMS and/or available documents.

• Assume one-half of the method detection limits for any non-detect values.

• Justify any exclusion of specific data points (outliers, etc.).

3. Determine the baseline concentration value as the more conservative (i.e., lower) value calculated using the following two methods:

a. METHOD A: Determine the median value from a set of geometric mean values of the annual average concentration for a given COC for the dataset defined in #2.

• Calculate annual average concentration for a given well:

a. Cw = ΣCi / n

b. where Cw…