Stack_Testing_PWS_-_CAAA-_Final.pdf

18 Oct 2019

Rev 1

Thermal Treatment Demilitarization Systems Environmental Compliance Support for

Naval Surface Warfare Center (NSWC) - Crane Division

Performance Work Statement

1.0 INTRODUCTION. The Product Director for Demilitarization (PD Demil) mission is to demilitarize the stockpile of excess, obsolete, and unserviceable conventional ammunition. One key method of demilitarization (demil) is the use of thermal treatment systems to include rotary kiln incinerators (RKIs). The Joint Munitions Command (JMC) supports the demil mission by managing the demil stockpile and associated demilitarization activities, including open burning/open detonation (OB/OD) and RKI operations. The Army’s RKIs are considered a

Hazardous Waste Combustor (HWC) under the Clean Air Act (CAA). Operations of the furnace are regulated under the National Emission Standards for Hazardous Air Pollutants for Hazardous

Waste Combustors (HWC NESHAP). Hazardous Waste Combustors are also regulated by the

Federal Resource Conservation and Recovery Act (RCRA). Federal regulations require extensive permitting and testing to establish and demonstrate compliance with CAA HWC

NESHAP emission limitations and operating requirements which are outlined in 40 CFR Part 63

Subpart EEE.

1.1 All work under this effort is subject to periodic inspection and on-the-spot performance assessment. All performance assessments and periodic inspection results will be supplied in writing describing the positive, neutral, negative results or determination. In the event the

Contractor is found to have failed to comply with contract requirements, corrective action will be initiated. The corrective action process will be governed by the applicable rules and regulations and administered by the Contracting Officer’s Representative (COR). Minor issues will normally be handled onsite with a corrective action report being issued at the discretion of the COR. For more serious issues and unresolved minor issues (to include repetitive minor problems) the COR may issue the Contractor a Contract Discrepancy Report (CDR) through the Contracting Officer

(KO). The KO will present the CDR to the Contractor with instructions. The U.S. Government reserves the right to seek consideration in the event of unresolved contract discrepancies and serious incidents impacting the effort.

2.0 REQUIREMENTS AND PERFORMANCE REQUIREMENTS SUMMARY

The Contractor shall provide the necessary qualified labor, materials, supplies, services, facilities, and equipment to perform work in the following areas.. Frequency, duration, and locations will be detailed within the Tasks.

2.1 Comprehensive Performance Test (CPT). NSWC will complete a CPT to demonstrate compliance with the applicable HWC NESHAP emission standards and to establish new operating parameter limits (OPLs). The Contractor shall oversee completion of the CPT, subcontract stack testing services, develop the CPT report, and Notification of Compliance

(NOC). The Contractor shall oversee conduct of the CPT, ensure the CPT is conducted in accordance with regulatory requirements, and perform all required air pollution emission testing.

The Contractor shall conduct analysis of all air emission samples collected during the test in accordance with regulatory requirements. The Contractor shall provide all necessary personnel, materials, equipment, and supplies to perform the sampling. During the CPT test, NSWC Crane will establish new OPLs for the system and will demonstrate compliance with each of the HWC

NESHAP regulated pollutants. The Contractor shall coordinate with the U.S. Government and advise of required on site support to ensure successful sampling. Following the successful completion of the CPT the Contractor shall document the results of the test in the form of a CPT

Technical Report IAW 40 CFR Part 63 Subpart EEE within the regulatory suspense dates (90 days as defined by the MACT rule for CPTs), provide a NOC documenting compliance with the dioxin and furan emission standards. Testing shall commence at NSWC Crane in Crane, Indiana at the APE1236 deactivation furnace NLT 12 February 2020 to remain in permit compliance.

The tasks required to complete the CPT are outlined below:

2.1.1 Oversight of Comprehensive Performance Test (CPT). The CPT shall consist of three test series. Each test series will include three test runs of varying duration. The CPT test series is estimated to require eight days, ten hours in length, of work to include:

mobilization, set up, testing, and demobilization. During the CPT, the firm that the

Contractor has subcontracted with to perform the stack testing shall collect emission samples of the furnace exhaust and send the collected samples to a laboratory for analysis. The Contractor’s role during the test will be to oversee all testing operations, coordinate unit operations with the subcontracted stack testing activities, and ensure compliance with the test protocol.

2.1.2 Subcontracted Testing Services. The Contractor shall subcontract a qualified stack tester to perform stack testing for the CPT. Three test series are planned for the CPT.

Each test series will consist of three separate test runs. Required test program is shown in the table below. In conjunction with the first test series, the subcontractor will also complete a Relative Accuracy Test Audit on the Continuous Emissions Monitoring

System (CEMS).

Test Series Pollutants Method Duration

1 Dioxin/furan SW846 Method 0023A 3 hours

Total hydrocarbons USEPA Method 25A Continuous

Semivolatile and low volatile metals

USEPA Method 29 1 hour

Hydrogen chloride/chlorine

USEPA Method 26A 1 hour

Dioxin/Furan SW846 Method 0023A 3 hours

Particulate Matter USEPA Method 5 1 hour

Total Hydrocarbons USEPA Method 25A Continuous

2.1.3 Comprehensive Performance Test Report. Following completion of the testing activities, the Contractor will collect operating data from the furnace and emissions data from the stack testing subcontractor. The Contractor will review the operating data and determine the appropriate OPLs that resulted from the testing. The Contractor shall review the emissions data, verify emissions calculations, and provide a data quality review of the associated laboratory report. Following review of all specified data, the

Contractor shall assemble the results of the test into a CPT report. The CPT report shall summarize the unit operating conditions, present the stack test results, and specify the new OPLs for the furnace. The CPT report shall include a NOC, which NSWC Crane will review, sign, and submit to the Indiana Department of Environmental Management

(IDEM). Consistent with HWC NESHAP requirements, the complete, assembled report must be provided for submittal no later than 90 days following completion of onsite testing activities.

2.2 Operator Training. The Contractor shall coordinate with the Joint Munitions Command

Ammunition Peculiar Equipment office (through the COR), to develop a HWC Operator

Training Course that fulfills the MACT regulatory requirements and ensure that HWC operators are adequately trained. The course shall include an approximately 8-hour annual refresher course for between 6 and 20 students. The Contractor shall present the 8-hour HWC Operator

Refresher Training Course on-site at Crane Army Ammunition Activity (CAAA). Operator training will take place at CAAA in fourth quarter fiscal year 2020 and must be completed prior to 30 Sep 2020, date must be coordinated and scheduled with CAAA, Tooele Army Depot-

Ammunition Equipment Directorate, and JMC through the COR.

3.0 Contractor Personnel Requirements

3.1 The services provided under this contract are strictly non-personal in nature. Under this contract, no employer-employee relationship will exist between the U.S. Government and the

Contractor and/or between the U.S. Government and the Contractor’s employees. No contractor employee will be directly supervised by the U.S. Government. All individual employee assignments and daily work direction will be given by the Contractor. If the Contractor believes any U.S. Government action, inaction, or communication would create a personal services relationship, or appearance of, between the U.S. Government and any contractor employee, the

Contractor shall promptly notify the KO. Additionally, the Contractor shall ensure all contracted employees fully understand the Government–Contractor relationship. All contractor employees must be fully aware that U.S. Government personnel do not have direct authority over contractor personnel. Additionally, all contractor employees must fully understand that only the KO has the authority to change the terms of the contract and only the KO has authority to direct work. Both the KO and COR can provide guidance.

3.2 The Contractor shall provide the appropriate amount of personnel with required training, skills, and experience in order to accomplish the tasks required under this Performance Work

Statement (PWS). Additionally, the Contractor must exercise due diligence in its hiring practices to validate required skills and ensure employee probity. Moreover, the Contractor shall provide its employees with detailed instruction on U.S. Government policies and regulations in the areas of safety, security, and environmental compliance as they pertain to the operations specified or implied in this PWS and subsequent modifications. The Contractor shall not allow any employees that are not certified, trained, or licensed for a particular task to perform such work.

4.0 Contract Administration

4.1 The KO has authority to administer the contract and approve any changes to the contract. The

KO will appoint representatives to assist in contract administration including a COR. Any work performed outside of the terms of this contract or its subsequent modifications, and without prior authorization from the KO, will be performed at the sole risk of the Contractor and may not be reimbursed.

4.2 The COR monitors all technical aspects of the contract and assists the KO in contract administration. The COR performs the following functions: ensures the Contractor performs the technical requirements of the contract; performs necessary inspections in connection with contract performance; maintains written and oral communication with the Contractor concerning technical aspects of the contract; and monitors the Contractor’s performance. The COR shall notify both the KO and the Contractor of any deficiencies.

5.0 Contractor Performance Evaluation

5.1 The Contractor shall develop and maintain an effective Quality Control Program to ensure services are performed in accordance with this PWS.

5.2 If any aspect of performance is not in conformance with the requirements of this contract, the

U.S. Government will have the right to issue a CDR. Upon issuance of a CDR by the COR, the

Contractor supervisor shall immediately sign a copy and return it to the COR, who will forward it to the KO for signature. The Contractor shall explain, in writing, within five business days why performance was not in conformance with the requirements of this contract, how performance will be returned to conformance, and how recurrence of the problem will be prevented in the future.

6.0 Contractor Manpower Reporting

6.1 The contractor shall report ALL contractor labor hours (including subcontractor labor hours) required for performance of services provided under this contract for the U.S. Army via a secure data collection site. The contractor is required to completely fill in all required data fields using the following web address: http://www.ecmra.mil/, and then click on “Department of the Army

CMRA” or the icon of the DoD organization that is receiving or benefitting from the contracted services.

6.2 Reporting inputs will be for the labor executed during the period of performance during each

Government fiscal year (FY), which runs October 1 through September 30. While inputs may be reported any time during the FY, all data shall be reported no later than October 31 of each calendar year. Contractors may direct questions to the help desk by clicking on “Send an email” which is located under the Help Resources ribbon on the right side of the login page of the applicable Service/Component’s CMR website”.