NPRA_Drum_Removal_SOW.pdf

Scope of Work Bureau of Land Management

National Petroleum Reserve in Alaska Drum Removal Project

1 OBJECTIVE AND BACKGROUND

The tasks identified in this scope of work include the removal and proper disposal of abandoned drums and other debris at four locations within the National Petroleum Reserve in Alaska (NPR-A) and providing reporting deliverables in accordance with Bureau of Land Management (BLM) guidelines and standards.

The Contractor shall furnish all labor, management, facilities, supplies, equipment, transportation, and material (other than those to be furnished by the Government as hereinafter provided), and do all things necessary for, or incidental to, performance of the work as set forth below. The Contractor shall furnish to the Government reports, and other data together with supporting material developed during the duration of the contract. During the progression of the work, the Contractor shall provide adequate professional supervision and quality control to assure the accuracy, quality, completeness, and progress of the work.

The BLM manages the NPR-A, an area encompassing approximately 23 million acres on Alaska’s north slope. The BLM has identified four sites within the NRP-A with drums and other debris present as a result of past activities. These locations are only accessible by helicopter the summer, or by overland travel in the winter.

Table 1 - Site List

Site ID Site Name Lat/Long Legal Description (Umiat Meridian)

Site 1 Skull Cliff Legacy Well 70.9004, -157.6012 Section 23, Township 13 North, Range 22 West

Site 2 Drums Near ASTAC Trail 70.7156, -157.5562 Section 27, Township 16 North, Range 22 West

Site 3 Drums Near Lake East of Atquasuk

70.4497, -156.7227 Section 26, Township 13 North, Range 19 West

Site 4 Drums Near Mead River South of Atqasuk

70.1498, -156.9935 Section 9, Township 8 North, Range 21 West

Attachment 1 includes a map of the site locations, site photos, and site descriptions. A brief description of each site is provided below.

1.1 SITE 1 - SKULL CLIFF LEGACY WELL

This site is located on the coast of the Chukchi Sea, approximately 33 miles southwest of Utqiagvik and 30 miles north of Atqasuk. There are over 200 drums at the site, along with other solid waste including an old battery, a metal rig track, and other wooden and metal debris.

The Skull Cliff test well consists of a 7-inch diameter casing sticking up about 5 feet above the ground inside a shallow wood cellar. The BLM has plans to plug and abandon the Skull Cliff test well in the future. To support future work, this project includes the collection of soil samples around the wellhead.

1.2 SITE 2 – DRUMS NEAR ASTAC TRAIL

This site is approximately 45 miles southwest of Utqiagvik and 17 miles north of Atqasuk. A pile of approximately 20 was drums was observed from the air at this location; the BLM did not land at this site to make observations.

1.3 SITE 3 – DRUMS NEAR LAKE EAST OF ATQASUK

This site is located approximately 60 miles south of Utqiagvik and 16 miles east of Atqasuk. This location consists of approximately 65 drums and other solid waste. There are about 30 drums on the bluff above the lake shore, with about 15 clustered together and the other 15 scattered around, and another 35 drums on the lake shore, with some of them in the water. Numerous smaller metal cans were observed along the side of the bluff, along with two metal rig tracks and other metal debris.

1.4 SITE 4 – DRUMS NEAR MEAD RIVER SOUTH OF ATQUASUK

This site is approximately 80 miles south of Utqiagvik and 25 miles southeast of Atqasuk. This location consists of a pile of 16 drums. There were also a few small cans and pieces of wood observed in the area.

2 DESCRIPTION OF TASKS

The tasks to be accomplished are identified below. All work shall be performed in accordance with all applicable State and Federal regulations, policies, and procedures. The Contractor shall be responsible for identifying the Federal, State, and Local regulations that will affect this contract and obtaining all necessary permits and authorizations. This work will occur within the NPR-A and will need to comply with the applicable Required Operating Procedures in Appendix A of the 2022 NPR-A Integrated Activity Plan Record of Decision.

Task 1 – Project Management

Task 2 – Planning Documents

Task 3 – Drum and Solid Waste Removal

Task 4 – Sampling

Task 5 - Reporting

2.1 TASK 1 – PROJECT MANAGEMENT

The Contractor shall provide overall project management for the duration of this contract. Management activities shall include but are not limited to:

• Timely and appropriate responses to inquiries from the Contracting Officer Representative (COR) and Project Manager (PM) regarding the project

• Coordination with local communities

• Management and control of all project performance including subcontracted services

• At least one planning meeting with the BLM to

• The Contractor shall prepare and submit to BLM minutes of all conferences and meetings and documentation of results community coordination.

2.2 PLANNING DOCUMENTS

The Contractor shall prepare and submit draft and final versions of the planning documents for BLM review and comment.

Planning documents shall include the following sections:

1. Project Schedule

2. Work Plan

3. Accident Prevention Plan/Site Safety and Health Plan

Project Schedule: The Contractor shall submit a detailed schedule showing the periods in which work will be performed and milestone dates to complete the planning, fieldwork, and reporting tasks.

Work Plan: The Contractor shall prepare a detailed and comprehensive plan for all work to be performed under this contract. No work at any site shall be performed until the work plan is accepted by BLM. The work plan shall describe who, what, where, when, why, and how to allow the BLM to fully understand how the work will be conducted. The work plan shall be organized in a logical format so it may be understood by personnel performing the work and by persons reviewing the plan. The work plan shall include a sampling and analysis plan.

Accident Prevention Plan/Site Safety and Health Plan: The Contractor shall develop and follow an Accident Prevention Plan (APP) for all field activities associated with this contract and for all persons performing work under this contract. The APP shall be developed and maintained in compliance with Occupational Safety and Health Administration (OSHA) standard 29 Code of Federal Regulations (CFR) 1910 and all applicable Federal, State, and local safety and occupational health laws and regulations.

The APP shall include a Site Safety and Health Plan. Matters of interpretation of standards shall be submitted to the appropriate administrative agency for resolution before starting work. Where the requirements of applicable laws, criteria, ordinances, regulations, and referenced documents vary, the most stringent requirements shall apply.

2.3 DRUM AND SOLID WASTE REMOVAL

The contractor shall implement the approved work plan to remove drums and other solid waste from the four sites, including any contents of the drums if present. The location of the drums and solid waste will be documented prior to removal. All wastes must be properly disposed of at appropriately permitted facilities.

This project does not include the removal of any buried waste. Any solid waste identified but not removed shall be inventoried and spatial data collected to facilitate future removal.

2.4 SAMPLING

2.4.1 Drum and Solid Waste Removal Sampling

The contractor shall be prepared to collect soil samples during the drum and solid waste removal actions based on field observations such as stained soil, odors, or distressed vegetation. The contractor shall plan on a maximum of 8 discrete surface soil samples to be analyzed for gasoline range organics (GRO) using method AK101, diesel range organics (DRO) using method AK102, benzene, toluene, ethylbenzene, and xylenes (BTEX) using method 8021, and polynuclear aromatic hydrocarbons (PAHs) using method 8270. Samples shall be collected by an Alaska Department of Environmental Conservation (ADEC) qualified environmental professional. At the Skull Cliff Legacy Well site, a soil sample shall be collected at the location of the batteries to be analyzed for Resource Conservation and Recovery Act (RCRA) metals using method 6010.

If there are no indications of a release at a site, the contractor will provide documentation of their observations and no soil samples will be collected. All indications of releases observed will be documented, including spatial data, and described in detail so they may be located again in the future.

Spatial data will be collected for each sample location.

2.4.2 Skull Cliff Legacy Well Soil Sampling

To facilitate future plugging and abandonment work at the Skull Cliff Legacy Well, the contractor shall collect 4 surface and 4 subsurface soil samples within a 15 feet radius of the wellhead. The samples shall be collected by an ADEC qualified environmental professional and analyzed for GRO using method AK101, DRO using method AK102, volatile organic compounds (VOCs) using method 8260, PAHs using method 8270, RCRA metals using method 6010, and polychlorinated biphenyls (PCBs) using method 8020. Spatial data will be collected for each sample location.

2.5 REPORTING

The contractor shall document the results of the drum and solid waste removal and sampling activities in a single report with separate sections discussing each site. The report shall include a description of tasks performed, any deviations from the work plan, and a discussion of results. The report shall provide documentation of proper disposal of the drums and solid waste removed and identify any remaining solid waste that was not removed.

3 PROJECT TECHNICAL REQUIREMENTS AND STANDARDS

3.1 PERMITS

The Contractor shall obtain all permits as required by state and local regulatory agencies, including coordinating with the BLM for an authorization to work in the NPR-A. Work shall comply with applicable federal, state, and local regulatory requirements.

3.2 CONTRACTOR QUALITY CONTROL

The Contractor shall ensure that appropriate internal quality control practices are employed throughout the performance of this contract. The objectives of the Contractor’s quality control practices shall be to ensure that submittals are complete, internally consistent, technically accurate, in compliance with accepted industry practices, and generally free from copy errors such as misspellings, grammatical errors, formatting problems, etc.

Additional objectives of the Contractor’s quality control practices shall be to ensure that all procedures, including but not limited to chemical data review, field practices, and oversight of subcontractors’ work, are checked for completeness, consistency, technical accuracy, compliance with accepted industry practices, and general absence of errors throughout the performance of the procedure. The goal of the Contractor’s quality control practices shall be to identify and correct problems before they are carried forward in the project, and to ensure that submittals meet professional standards of quality. Documents and procedures that are incomplete, internally inconsistent, and technically inaccurate, out of compliance with accepted industry practices, affected by large numbers of copy errors, or otherwise not completed or submitted in accordance with the requirements specified in this scope of work will be rejected.

3.3 SUBMITTALS

The submittals for this project include draft and final planning documents and a draft and final report.

Complete versions of the draft planning documents and draft report shall be submitted as a bookmarked PDF.

The final planning documents and final report shall be compiled in a bookmarked PDF file that includes all tables, figures, appendices, and attachments. In addition to the PDF file, one hard copy of the final planning documents and one hard copy of the final report shall be submitted.

4 PUBLIC AFFAIRS

All data and reports generated under this contract shall become the property of the Government.

Distribution of data or reports to any other source is prohibited. The contractor shall not make available to the news media or publicly disclose any data generated or reviewed under this contract. If approached by the media, the contractor shall refer them to the contracting officer for a response.

5 AUTHORITY AND POINTS OF CONTACT

The BLM Contracting Officer is the only person with the authority to act as agent of the Government under this contract. Only the Contracting Officer has authority to:

• Direct or negotiate any changes in the Scope of Work or specifications

• Modify or extend the delivery date

• Change the delivery schedule

• Otherwise change any terms and conditions of this contract.

The BLM Contracting Officer is the only person authorized to make or approve any changes in any of the requirements of this contract and not withstanding any provisions contained elsewhere in this contract, the said authority remains solely in the BLM Contracting Officer. In the event the Contractor makes any changes at the direction of any person other than the BLM Contracting Officer, the change will be considered to have been made without authority and no adjustment will be made in the contract price to cover any increase in costs incurred as a result thereof.

The Government may conduct periodic inspections of the Contractor’s work to determine compliance with the requirements of this contract. The BLM Contracting Officer will notify the Contractor of any work that is determined to be noncompliant with the contract requirements. The Contractor shall take immediate corrective action after receipt of such notice. The BLM Contracting Officer may issue an order stopping all or part of the work until satisfactory corrective actions have been taken.

Verbal directions, instructions, explanations, commitments, and or acceptance given to the Contractor or his personnel by any Government employee shall not be construed by the Contractor as a change to this SOW. The Contracting Officer must issue any change in scope of work in writing to be binding on the Government.

Project Manager:

Melody Debenham 222 University Avenue Fairbanks, AK 99709

(907) 474-2307 kdebenham@blm.gov

Contracting Officer:

Patrick Euler 222 W. 7th Ave, #13 Anchorage, AK 99513

(907) 271-4136 ppeuler@blm.gov mailto:kdebenham@blm.gov mailto:ppeuler@blm.gov

6 REFERENCES

Alaska Department of Environmental Conservation (ADEC). 2023. 18 AAC 75, Oil and Other Hazardous Substances Pollution Control. As amended through February 5.

ADEC. 2022. Field Sampling Guidance for Contaminated Sites and Leaking Underground Storage Tank Sites

ADEC. 2017. Site Characterization Work Plan and Reporting Guidance for Investigation of Contaminated Sites

2.5 Reporting