Attachment 6 505 Environmental Compliance Svs NS FY21 10Oct19 r4 9Apr20.....docx
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This document provides an overview of environmental compliance services required under a federal contract to support the U.S. Army Garrison at Redstone Arsenal. The contractor will be responsible for core environmental compliance including sampling, analysis, permitting, and reporting in accordance with EPA and state regulations. Specific services involve laboratory operations and quality control, hazardous and regulated waste management, pollution prevention initiatives like waste recycling, and responding to spills. The contractor must maintain certifications and participate in evaluation programs to ensure standards are met. The opportunity also requires subject matter expertise and management of historic sites in compliance with preservation laws.
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CLS 505 Environmental Compliance Services
Attachment 6
Environmental Compliance Services
10 October 2019
REVISION-4 9April 2020
Table of Contents
| 1.0 General Information. | 1 |
| 1.1 Overview. | 1 |
| 1.2 Summary of Expectations. | 1 |
| 1.3 Historic Property or Archaeological Site. | 1 |
| 1.4 Environmental Requirements. | 1 |
| 2.0 Description of Services | 2 |
| 2.1 Contractor’s Responsibility for Environmental Protection. | 2 |
| 2.2 Contractor’s Responsibility for Reporting Pollution or Potential Pollution. | 2 |
| 2.3 Lab Operations. | 2 |
| 2.4 Core Environmental Compliance Services and Subject Matter Expertise. | 4 |
| 2.5 Recurring Hazardous and Other Regulated Waste Management Services. | 4 |
| 2.6 Pollution Prevention. | 5 |
| 2.7 Hazardous/Spill Plan. | 6 |
| 2.8 Data Input to Landfill Information Management System. | 7 |
| 2.9 Inspection of Storage Containers. | 7 |
| 2.10 Clean-Up of Contractor Spills or Releases. | 7 |
CLS 505 Environmental Compliance Services i
General Information.
Overview.
Sustain Program Compliance. Compliance Programs provide development, implementation, and maintenance of installation policies, plans, and programs related to environmental issues. The program also includes compliance inspections, Environmental Protection Agency (EPA) compliance, and pollution abatement and environmental engineering studies.
Summary of Expectations.
The Contractor shall perform operations and work requirements ensuring compliance with environmental regulations. Contractor personnel shall keep abreast of changing and/or new environmental regulations, procedures and technology to ensure compliance and maintain the most cost-effective operations. The Contractor shall reduce/eliminate environmental risks to ensure sustainability of installation facilities.
There is a certified lab located at building 3338. The Contractor shall staff, maintain, and provide lab operations to conduct required testing for compliance and other Common Levels of Support (CLS) defined in this Performance Work Statement (PWS) requirements.
The contractor shall provide hazardous material tracking and monitoring in support of other CLS defined PWS requirements and the hazardous material tracking for tenants on Redstone Arsenal (RSA).
The contractor shall operate a recycling center to maximize recycling/reuse of asphalt, soil, concrete, wood, and trees when cost effective.
Historic Property or Archaeological Site.
Historic properties and archaeological sites are subject to the provisions of the National Historic Preservation Act (NHPA). The Contractor shall maintain the historic properties on the installation IAW the NHPA, 54 United States Code (U.S.C) § 300101, National Preservation; 36 Code of Federal Regulations (CFR) Part 800, Advisory Council on Historic Preservation; and United Facilities Guide Specifications (UFGS). The Contractor shall comply with all applicable Federal historical structure and archeological laws. In the event of damage to or disturbance of any historical structure or archeological site, the Contractor shall report such damage or disturbance to the Contracting Officer’s representative (COR) within 24 hours. TE 09 provides more detail on historic properties at Redstone Arsenal. Location maps can be found at the DPW. All maintenance and repairs to historic structures shall be IAW approved policies.
Environmental Requirements.
Executive Order (EO) 13834, Efficient Federal Operations. The Contractor shall comply with tenants of the EO and when practicable, shall use:
a. Products with post-consumer recycled content
b. Products that are recyclable
c. Low toxicity or non-toxic products
d. Low-maintenance products
Green Procurement. Section 6002 of the Resource Conservation and Recovery Act of 1976 (RCRA) requires the use of recycled and recovered products identified in the Environmental Protection Agency’s Comprehensive Procurement Guidelines. The Contractor shall use these recycled or recovered products unless they cannot be procured within a reasonable period of time not to exceed seven (7) calendar days; at prices not to exceed five (5) percent of prevailing rates; or the product(s) does not meet technical or performance standards. EPA Guidelines are the minimum requirement. The use of other materials and products not listed but commonly used in industry is acceptable. The Contractor shall maintain records and submit an annual report to the COR, along with the annual certification required by 48 CFR 52.223-9 Certification and Estimate of Percentage of Recovered Material Content for EPA Designated Items, upon completion of the base year and each option year.
Environmental Compliance. The Contractor shall comply with all federal, state, local and installation environmental laws, rules and plans. The Contractor shall use and store all materials, chemicals, and equipment used in the performance of services on the installation in accordance with industry standards, local, federal and state laws, and according to manufactures' recommendations. IAW DI-SAFT-82112 , CDRL/Deliverable #13, the Contractor shall submit Material Safety Data Sheets (MSDS) for approval on all materials, five (5) days before delivery of the material, to the COR. IAW DI-MGMT-82052, CDRL/Deliverable #14, the Contractor shall make all environmental and hazardous material records available at the beginning of the next duty day after the Government’s request to view the records.
Description of Services
Contractor’s Responsibility for Environmental Protection.
The Contractor shall perform the contract requirements in such a manner as to protect the environment, prevent environmental pollution and preserve historical sites. All work performed for this contract shall be consistent with Department of the Army (DA) policy and Federal, state or local environmental laws and regulations, and Garrison policies, rules, regulations, and permit requirements. All environmental protection matters shall be coordinated with the Environmental Management Division (EMD) COR.
Contractor’s Responsibility for Reporting Pollution or Potential Pollution.
During routine operations, the Contractor shall survey all areas of RSA and verbally report any environmental pollution problems or potential problems to the Contracting Officer (KO) KO/COR within four (4) hours of detection. The Contractor shall report significant non-compliance issues to the KO/COR.
Lab Operations.
The Contractor shall prepare and update their Sampling and Analysis Plan (SAP) for the Laboratory Operations per current EPA and Corp of Engineers guidance documents IAW DI-ADMN-80925A, CDRL/Deliverable #54, Collection, Sampling, and Analysis of Surface Drinking Water. The plan shall address the processes and methodologies for accomplishing collection, sampling, and analysis for surface water (i.e., NPDES) and drinking water. The contractor shall support the Water Utility contractor by providing sampling and analysis services for compliance with the Clean Water Act including RSA’s National Pollutant Discharge Elimination System (NPDES) Permit No. AL0000019 and the Safe Drinking Water Act (SDWA) including investigating drinking water complaints. The Contractor shall report treated water samples testing positive for bacteria or other health-threatening organisms to the EMD within one (1) hour following the positive determination. All sampling shall be conducted IAW the SDWA, RCRA, the Clean Water Act (CWA), storm water, the Water Quality Act of 1987, and the Redstone Arsenal Bacteriological Monitoring Sampling Sitting Plan. The NPDES permit is renewable every five (5) years and monitoring requirements can be expected to change to some unknown degree. The next renewal date for the NPDES permit is 1 October 2018. The Contractor shall report, within four (4) hours to the KO/COR and to the EMD, any non-compliance problems or actions associated with the NPDES Permit.
The Contractor shall prepare and provide a Laboratory Workload Report to document the samples taken, analyses performed per analytical method, and type of sample/analysis (routine/emergency) IAW DI-MISC-80508B, CDRL/Deliverable #65.
The Contractor shall prepare an updated plan for Quality Control of Laboratory Operations per current EPA and Corp of Engineers guidance documents IAW DI-ADMN-80925A, CDRL/Deliverable #66 including setting up a program to internally monitor quality control of laboratory personnel. The Contractor shall report the number of tests per EPA method and turnaround times. The laboratory shall participate successfully in EPA’s Water Supply/Water Pollution (WSWP) laboratory sample evaluation program. The laboratory shall comply with ADEM’s drinking water certification program.
The Contractor shall prepare a Five (5) Year Laboratory Equipment Management Plan IAW DI-MISC-80508B, CDRL/Deliverable #67 that projects replacement and/or purchase of laboratory equipment required for execution of the environmental requirements of the PWS. The plan shall include laboratory equipment to be replaced (using PWS contract funds) in order to maintain existing capabilities and also include a “wish list” of equipment to be purchased to enhance laboratory operations. The Contractor shall update the plan annually and submit it to the Government not later than 1 August of each year. Those items specified as Government-furnished property can be found in Technical Exhibit #50.
The Contractor shall provide the Environmental Program Management Report IAW DI-FNCL-80912A, CDRL/Deliverable #68. This report shall contain information about environmental expenditures to date and differences from planned expenditures identified in the annual work plan, along with a reason for the difference and a correction plan. The report should also include identification of environmental performance metrics measured, performance metric variances from target, and reasons for all performance variances and planned actions to remedy . Environmental performance metrics are measured numerically and by other means, such as quality, punctuality, dependability, and productivity. Any circumstance that prevents the Contractor from performing an action, causes the actual to deviate from what was originally planned, causes a violation, or has a measurable environmental impact is considered a performance metric variance. This report shall contain information about environmental expenditures, variances from planned expenditures, performance metrics, performance metric variances, reasons for all environmental cost and performance variances and planned actions to remedy variances. The report shall also include a graphical chart with the annual planned expenditures, to-date expenditures, and remaining planned expenditures for the contract year. The report shall also include a detail listing of applicable cost center, CLIN/Subcontract Line Item Number (SLIN), AMS code, Account Processing Code (APC), PWS paragraph number, G&A, fee. The report shall include a summary of all Contractor costs representing laboratory (collection and analyses), recycling, hazardous waste management, environmental management, and spill response. Comment by Howard, Timothy W Mr CIV USA: Addition and changes from AD document as a result of IMCOM comment, Core Environmental Compliance Services and Subject Matter Expertise.
The Contractor shall provide a variety of sampling and analysis services to include unknown chemicals, solids, liquids, gases, bulk and air samples, asbestos, mold, and hazardous waste. These services shall be conducted by an accredited laboratory using approved EPA laboratory and sampling methods. Permit sampling and analysis services shall conform to the requirements of all applicable laws, regulations and RSA’s current RCRA Part B Permit.
Routine samples shall be taken within 48 hours of notification of sampling need unless specified otherwise in permit requirements and completed within six (6) working days. Toxicity Characteristic Leaching Procedure (TCLP) analyses shall be completed within 14 working days. Emergency samples shall be drawn within two (2) hours of a reported need. The first party that becomes aware of the need to take or test a sample makes the determination as to whether it should be classified as an emergency. TCLP analyses on emergency samples shall be completed within three (3) working days. Analyses of all other emergency samples shall be completed within one (1) working day or as dictated by the prescribed analytical method. Sub-contracted analyses shall be completed in 21 working days.
The Contractor shall use industry standards for analytical and sampling procedures, and reagent and standards preparation. Method Detection Limits (MDLs) and other control limits shall be statistically established and appropriately documented when using performance-based methods.
The Contractor shall meet the sampling, operational, testing and reporting requirements of the USAG-R drinking water, wastewater, hazardous waste, landfill and storm water permits. This may include laboratory personnel uploading data electronically into ADEM databases. The Contractor shall maintain this information and provide to the Government on an as-requested basis.
Recurring Hazardous and Other Regulated Waste Management Services.
The Contractor as a receiver, user and generator of hazardous materials/hazardous waste shall abide by the Garrison regulations.
The Contractor shall manage used oil collection on the installation to include routine collection, oil spills, containment, and clean-ups. The Contractor shall report cause and agency responsible for spill to DPW.
The Contractor shall follow the procedures established in 40 CFR 260-270, USAG Reg 200-6, the Installation RCRA Part B Permit and EMD for the turn-in, storage, disposal and tracking of hazardous wastes. Absolutely no hazardous wastes shall be brought on RSA from off-post sites. Absolutely no hazardous wastes shall be introduced to storm/rainwater or sewer systems. The Contractor shall operate a ninety day hazardous waste storage area per 40 CFR 260-270 and USAG Reg 200-6.
The Contractor shall manage hazardous materials in accordance with the Redstone Arsenals Hazardous Material Management Plan, AR 200-1 and referenced DA PAM 710-7.
Regulated Waste Management Services. The Contractor shall ensure that all areas located within the footprint of what has historically been considered the RSA Solid Waste Disposal Facility and designated as closed disposal sites are maintained IAW ADEM Administrative Code, Solid Waste Division 13, and amendments thereto; and EPA regulations in their entirety. The closed sites include the waste oil pits, the dichlorodiphenyltrichloroethane (DDT) landfill area, and the closed municipal solid waste landfill. Routine maintenance is expected to consist of periodic grading and filling activities to alleviate settlement, eliminate ponding, and activities to minimize erosion and washing.
Pollution Prevention.
Pollution Prevention Programs includes programs to reduce the impact on the environment through the reduction or elimination of wastes, more efficient use of raw materials or energy, and/or reduced emissions of toxic and other undesirable materials to the environment.
The Contractor shall reduce or minimize waste, and maximize re-use of RSA waste streams.
Summary of Expectations. The Contractor shall support pollution prevention initiatives and maintain a proactive program for elimination of pollution generation and prevention of pollution entering into the environment through 1) identifying new and alternative processes and materials, 2) reusing of existing materials, and 3) recycling of generated pollutants where practical. The Contractor is expected to research market trends, new technologies, and industry standards that support the reduction of pollution and associated environmental risk.
The Contractor shall prepare a Monthly Recycle Collection Summary Report IAW DI-MISC-80508B, CDRL/Deliverable #69. The report shall include the Commodity Received, Count, Accumulative Total and Weight. The report shall also include the Contractor’s assessment of the recycle program status, Contractor’s observed shortcomings of the recycle program, and the Contractor’s proposed improvements to the program (e.g., relocation/redistribution of recycle bins).
Core Pollution Prevention Services, Subject Matter Expertise. The Contractor shall perform and maximize cost-effective recycling initiatives. The Contractor shall operate a Redstone Arsenal Recycle Center in support of the Garrison Qualified Recycling Program IAW Garrison Policy 200-5 and Garrison SOP 200-5.
The Contractor, at a minimum, shall perform recycling/disposal of:
a. Aerosol Cans
b. Cardboard
c. Fluorescent Lamps and Tubes
d. Mixed Paper, Shredded
e. Paint (enamel and latex)
f. Toner Cartridges
g. Used Oil
h. White Office Ledger Paper, Shredded
i. Used Antifreeze
In addition, the Contractor shall maximize recycling/reuse of asphalt, soil, concrete, wood, and trees when cost effective.
The Contractor shall recycle concrete staged at the Redstone Arsenal Construction/Demolition Landfill from demolition activities on Redstone Arsenal for future use. The crushing of concrete process shall be done to maximize the use of salvaged concrete into usable sizes. This minimizes the amount of disposal concrete being disposed of in the RSARedstone Arsenal Construction/Demolition Landfill. This work will be performed as a PWO, by a subcontract, on a periodic basis as needed.
The Contractor shall recycle suitable petroleum contaminated soil staged at the RSARedstone Arsenal Construction/Demolition Landfill generated from spill incidents. Treated soils containing Total Petroleum Hydrocarbons (TPHs) of less than 100 ppm will be use as landfill cover or other purposes as needed. All soils must be tested to confirm that the presence of heavy metals (D004-D011) are below regulatory levels prior to treatment for TPH reduction. No soils originating from an Installation Restoration (IR) site will be accepted or treated without prior approval from the Environmental Management Division. This process shall be done to maximize the amount of soil treated and minimize the volume of petroleum contaminated soil otherwise disposed of as hazardous waste. This work will be performed as a PWO on a periodic basis as needed.
Hazardous/Spill Plan.
IAW DI-MISC-81397C, CDRL/Deliverable #15, the Contractor shall submit a hazardous/spill plan to the KO within 30 days of contract award. IAW DI-MISC-80508B, CDRL/Deliverable #16; and the Spill Prevention, Control, and Countermeasure Plan; if the Contractor spills or releases any hazardous substances, i.e. substances listed in 40 CFR 302, Designation, Reportable Quantities, and Notification, the Contractor shall immediately notify the KO and COR, followed by written notification within one (1) hour.
Spill Response/Coordination.
The Contractor shall provide a responsible individual to serve as the Contractor Spill Coordinator with the authority to act on behalf of the Contractor.
The Spill Coordinator shall report to the Installation Operations Support Center (IOSC) during oil and hazardous substance spills as outlined in the Redstone Arsenal Spill Prevention Control and Countermeasures (SPCC) Plan and Installation Spill Contingency Plan (ISCP). This individual shall have the authority to provide necessary resources to mitigate and abate spill incidents on the installation as directed by the IOSC with verbal follow-up to the KO/COR.
The Contractor will be responsible for providing assistance to the U.S. Army Garrison-Redstone (USAG-R), Directorate of Operations (DoO), Fire and Emergency Services Division in petroleum spill response activities. The contractor is responsible for the containment and cleanup of petroleum spills through close coordination with the USAG-R, DoO Fire and Emergency Services Division. Containment operations shall begin immediately or upon notification, whichever comes first. Cleanup operations shall be initiated within 24 hours or when deemed safe to do so. Cleanup efforts for contaminated substances other than petroleum will be addressed in a separate contract.
Data Input to Landfill Information Management System.
The Contractor shall ensure up-to-date data is input into the Landfill Information Management System. The Contractor shall submit any waste manifest and waste information documentation received at the landfill to the COR.
Inspection of Storage Containers.
The Contractor shall inspect storage containers and areas within its area of responsibility that receive, store, or dispense petroleum products or hazardous wastes for leaks or spills weekly IAW the SPCC Plan and the ISCP.
Clean-Up of Contractor Spills or Releases.
Any Contractor spills or releases shall be addressed in accordance with paragraph 2.7 above. The Contractor shall be liable for containment and environmental clean-up of the spill or release of such substance on a reimbursable basis.
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