DRAFT_TASK_ORDER_PWS_-_Air_Quality_FOR_BESS_III_DATED_17_DEC_2015.docx

Sample Task Order Performance Work Statement (PWS) For Air Quality Compliance Support

1.0 SCOPE.

Air quality in Maryland is regulated by the U.S. Environmental Protection Agency (EPA) Region 3 and the Maryland Department of the Environment (MDE). The Clean Air Act (CAA) and its amendments grant the EPA responsibility to establish the primary and secondary National Ambient Air Quality Standards (NAAQS) (as defined in Title 40 of the Code of Federal Regulations (CFR), Part 50) for the protection of the public health and welfare, allowing for an adequate margin of safety. They have set the maximum acceptable concentration levels for six criteria air pollutants: carbon monoxide (CO), sulfur dioxide (SO2), ozone (O3), nitrogen dioxide (NO2), particulate matter less than 10 microns in diameter (PM10) and particulate matter less than 2.5 microns in diameter (PM2.5), and lead (Pb). The EPA has also established regulations for about 200 hazardous air pollutants (HAPs), and the MDE has established regulations for about 750 toxic air pollutants (TAPs). Precursors that form criteria pollutants may include ammonia (NH4), nitrous oxides (NOX), and Volatile Organic Compounds (VOCs).

This effort is to support Aberdeen Proving Ground's (APG) compliance with state and federal CAA regulations in the following areas: Two Title V permits compliance maintenance and reporting, new regulatory compliance, preparation of technical reports for APG emission units, determination of coverage for special projects, State Implementation Plan inputs, emission inventory reports, major general conformity documents, updating Aberdeen Proving Ground Regulation APGR 200-30, Risk Management Plan (RMP) updates, ozone depleting chemicals plan compliance, emission audits, chillers compliance, and emission modeling and to support new permits and new major general conformity determinations. This effort shall not perform personal services.

1.1 Background.

APG is located in the Baltimore Nonattainment Area, which is currently in attainment status for CO, NO2, SO2, PM10, and Pb; maintenance for PM2.5; and nonattainment for O3 Under federal definitions, APG is a major source for NOX and an area source for HAPs.

Several operations at APG are subject to EPA’s Chemical Accident Prevention Program for RMP under 40 CFR Part 68, and the Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) Standard under 29 CFR 1910.119. The requirements of these two rules are very similar. The principal difference is the requirement under RMP to perform Offsite Consequence Analyses (OCAs) to assess the potential impacts of accidental chemical releases on public receptors outside the facility boundaries.

Under these two rules, owners/operators of covered processes must conduct compliance audits at least every three years to verify that the procedures and practices developed under the regulations are adequate and are being followed. The most recent RMP/PSM audits were conducted and reported in 2014.

1.2 Objective.

The objective of this task order is to provide technical support services to the Environmental Compliance Branch of the Environmental Division of the Directorate of Public Works (DPW) at APG in maintaining compliance with the CAA permits and regulations and keeping APG in compliance with applicable federal, state, local, and Army regulations.

2.0 SUPPORT DOCUMENTS.

Selected support documents are intended to allow the contractor to become familiar with air emission units, current permits, and the desired deliverables. The following supporting documents are included for review:

2.1 APGR 200-30

2.2 Title 40 Code of Federal Regulations, Part 98 – Mandatory Greenhouse Gas Reporting

2.3 Title 40 Code of Federal Regulations, Part 60 Appendix A

2.4 Title V Permits to Operate, Sample past reports, and sample data collected by in-house staff will be made available for on-site review

These support documents cover the majority of the applicable requirements, but there are additional state, federal and Army regulatory requirements that also have applicability to this performance work statement (PWS). Examples of additional requirements under CAA regulations which may not be included in this list are National Emissions Standards for Hazardous Air Pollutants (NESHAP) regulations and New Source Reviews (NSR). The Code of Maryland Regulations (COMAR), Chapter 26, Subtitle 11 and other Subtitles also contain air quality regulations, permits, and permit renewals requirements within the State of Maryland. The contractor has the responsibility to become familiar with all the requirements of the CAA and COMAR 26.11 to fulfill those requirements as applicable.

3.0 REQUIREMENTS.

The contractor shall strictly adhere to the following requirements as they are part of the PWS.

3.1 All work under this PWS shall be performed in a safe manner in accordance with (IAW) the approved Health and Safety Plan (HASP) under the basic contract.

3.2 The contractor’s Project Manager shall be a CAA subject matter expert with a Bachelor’s of Science (BS) degree in engineering and a minimum ten (10) years of full-time work experience in CAA projects similar in size, scope, complexity, and dollar value. Additional project support staff members shall each have a BS degree in engineering or other sciences and a minimum five (5) years of experience in CAA projects similar in size, scope, complexity, and dollar value.

3.3 The contractor shall meet with the Contracting Officer Representative (COR) on a biweekly basis to discuss status of ongoing projects, work plans, issues, and technical approach for performing the work. The contractor shall attend bi-monthly meetings of the Air Quality Control Subcommittee and serve as a subject matter expert to answer all questions asked in the meeting by the committee members. These meetings are hosted by the COR, take place at APG, and typically last about an hour.

3.4 All documents, reports, and correspondence require coordination with the stakeholders, such as personnel from Garrison and Tenant Organizations. Frequently, the stakeholders provide comments through the COR. Sometime these comments are made more than one time by the same stakeholder. The contractor shall be responsible for addressing all comments submitted through the COR.

3.5 To ensure clear understanding of the task element requirements and complexities of field data gathering effort, the contractor shall submit a brief technical outline of their work plan to the COR prior to initiation of the work. The purpose of the outline is to ensure that the contractor fully understands the PWS, data requirements, and complexity of data gathering process, and that the contractor’s efforts and interpretations are directly related to that task.

3.6 The contractor shall ensure that all deliverables are complete, prepared IAW regulatory guidelines, and meet regulatory requirements. The contractor shall submit to the COR at least two hard copies and one electronic copy of each deliverable report for regulatory submittals and office use, unless specified otherwise. All regulatory reports shall have transmittal letters to be signed by the government official designated by the COR. All deliverables shall be submitted at least two weeks prior to the regulatory deadline as indicated in the permits for internal coordination and reviews IAW the List of Deliverables included with this PWS. After the submittal, if a regulator believes that the deliverable did not meet the requirements, the contractor shall correct deficiencies to ensure that the deliverable is acceptable to the regulators. All deliverables, backup data, field notes, and other information gathered for performance of the work are the property of the Government.

3.7 The contractor shall maintain a file system to include deliverables, PWS, a copy of the contract award, all official notifications, email correspondence, monthly progress reports, and other project-related correspondence.

3.8 The contractor shall implement a document review and quality controls process to ensure the deliverables are free from errors.

3.9 Task 1: Title V Reports For Aberdeen Area (AA) And Edgewood Area (EA) Title V Permits

3.9.1 Subtask 1A: Annual Emissions Certification Reports for AA & EA Permits

The contractor shall collect and compile all necessary information and prepare an "Emissions Certification Report" IAW Title V Permit requirements and applicable regulations, using regulatory forms if specified by the regulators for the calendar year 2016.

The contractor shall collect and review available emissions data from permitted and registered sources of emissions (e.g. permitted generators and boilers) located at both the Aberdeen and Edgewood Areas of APG to ascertain its current applicability. This review shall include an evaluation of current operational and material usage data to establish existing air emissions inventory if data is representative of a source's current emissions. The COR will typically have necessary data acquired from Garrison and Tenant Organizations on applicable emissions units (i.e. material usage at paint spray booths) from quarterly inspections available for the contractor. If such data is unavailable or incomplete, the contractor shall coordinate through the COR to acquire the missing data directly from the applicable Garrison or Tenant Organization. All non-compliance issues shall be reported immediately to the COR. The contractor shall submit the report through the COR IAW Section 5.1.1 of this PWS using "Emission Certification Report" form obtained from the MDE.

3.9.2 Subtask 1B: Title V Annual Compliance Certification Reports for AA & EA Title V Permits

The contractor shall prepare two (2) Title V Annual Compliance Certification Reports, one for the Aberdeen Area Title V Permit and one for Edgewood Area Title V Permit. Each report covers a calendar year and uses information from two (2) semi-annual reviews for the calendar year, IAW Title V Permit requirements and applicable regulations.

The contractor shall prepare two (2) semi-annual Six-Month Monitoring (SIXMON) reports, one for the Aberdeen Area and one for the Edgewood Area, for the period July 1 through December 31, 2016. The contractor shall also prepare two (2) SIXMON reports, one for the Aberdeen Area and one for the Edgewood Area, for the period January 1 through June 30, 2017. Each report will be submitted separately through the COR IAW Section 5.1.2 of this PWS. The contractor shall use these SIXMON reports to prepare the two Title V Annual Compliance Certification Reports for calendar year 2016 (as described in above). The contractor shall provide each SIXMON report with a certification statement to satisfy the EPA and MDE certification requirements upon submittal through the COR for submittal to EPA and MDE.

The Title V Compliance Certification reports shall comply with the requirements for all plant-wide sources of air pollution IAW specific and insignificant source conditions as identified in the Aberdeen and Edgewood Area Title V Permits. Non-Title V sources shall not be included in the Title V Certification report but shall be reported to the COR with respect to their adherence with applicable emission/regulatory standards. The contractor shall provide the Compliance Certification report with a certification statement to satisfy the EPA and MDE certification requirements upon submittal through the COR for submittal to EPA and MDE.

3.9.3 Subtask 1C: Annual Visible Emissions Certification for Heating Season.

The contractor shall prepare two (2) reports, one for the Aberdeen Area and one for the Edgewood Area, to determine the opacity of visible emissions from all the operating permitted boilers at APG during the period from November 1, 2016 through March 1, 2017 IAW Title V Permit requirements and Section 5.1.3 of this PWS. The contractor shall obtain field observation records from the DPW inspector upon request for the preparation of these reports.

3.9.4 Subtask 1D: Semi-Annual Boiler Reports.

The contractor shall prepare one (1) semi-annual boiler report for the period from July 1 through December 31, 2016, and one semi-annual boiler report for the period from January 1 through June 30, 2017, IAW Title V Permit requirements and applicable regulations. Both reports shall be submitted to the MDE and the EPA through the COR IAW Section 5.1.4 of this PWS. The Contractor shall gather and check information from the DPW concerning the boiler usage for both the Aberdeen and Edgewood Areas in each calendar year, as well as fuel certification records.

3.9.5 Subtask 1E: Safety Determinations for Open Burn Permit.

The contractor shall prepare two (2) semi-annual Open Burn Reports and the permit applications, one for the period from July 1 through December 31, 2017, and one for the period from January 1 through June 30, 2017. These reports shall be submitted through the COR for approvals by the Harford County Health Office IAW Title V Permit requirements and Section 5.1.5 of this PWS. The contractor shall coordinate through the COR with the Army Research Laboratory (ARL), the Army Testing Center (ATC), the APG Fire Department, and other tenants conducting open burning and testing to obtain their scheduled open testing and open burning activities for each calendar year. Two (2) semi-annual Safety Determinations for Open Burning Reports along with the permit application shall be submitted to the MDE Health Office in Harford County detailing the scheduled activities, including dates, type of activity, and projected duration. The Health Office gives approval for the permit and the associated burn activities. Each permit is valid for a six month period.

3.10 Task 2A: APG Risk Management Plan (RMP) Minor Update.

As required under 40 CFR Part 68 and 29 CFR 1910.119, the contractor shall perform an update requiring less than five (5) hours of professional time per year (e.g. change of commander, change of contact information) to the RMP documentation during the period of performance IAW Title V Permit requirements and Section 5.2 of this PWS.

3.11 Task 2B: Mandatory Greenhouse Gas Report.

The contractor shall collect required data and prepare a single online Mandatory Greenhouse Gas Report for both the Aberdeen and Edgewood Area of APG. This report shall be submitted by the COR onto the EPA's electronic Greenhouse Gas Reporting Tool (e-GGRT) website: https://ghgreporting.epa.gov/. After the data entry, the COR will certify and officially submit the report to the EPA website as the authorized person on behalf of APG IAW Section 5.3 of this PWS.

3.12 Task 3: Training.

In order to meet training and certification requirements of the CAA, the contractor shall provide regulatory combustion optimization training to all staff identified by the COR and needed by DPW and Tenant Organizations IAW Title V Permit to Operate, Section IV, Table IV (Operator Training); and Section 5.4 of this PWS. This training course must be certified by MDE. The contractor shall also provide a CAA and Title V Awareness training course intended for operators and technicians working at APG as needed. The contractor shall conduct at least two (2) 4-hour classes for combustion optimization and two (2) 3-hour classes for CAA and Title V Awareness training, each for approximately 30 attendees.

4.0 ADMINISTRATION

4.1 Security.

The contractor shall obtain security badges through the DPW for personnel that require access to restricted areas of the installation. The contractor shall be responsible for fulfilling all necessary security clearance requirements for such badges, such as proof of citizenship and background information.

4.2 Data.

The contractor has the responsibility to review the quarterly data provided by the DPW, gather all other data that might be required but has not been collected in DPW's quarterly inspections, gather all missing data, perform quality control checks to ensure it is reasonable and accurate, and prepare appropriate reports and submittals as required in this PWS. The contractor shall thoroughly review all necessary documents provided by DPW upon request to identify CAA requirements, permits, reports, data requirements for each task, the location of that data, and the means of acquiring it. The contractor shall be aware that some necessary data will not be immediately available and shall acquire it as necessary, accommodating for unforeseeable delays or setbacks. The contractor shall perform quality control on all data before using it in deliverables. The contractor shall document the erroneous data and discuss problems and resolutions with the COR.

5.0 ITEMS AND DATA TO BE DELIVERED

5.1 Task 1: Title V Reports For Aberdeen Area (AA) And Edgewood Area (EA) Title V Permits

5.1.1 Subtask 1A: Annual Emissions Certification Report for AA & EA Permits

The contractor shall deliver three hard copies (two for regulators and one for the DPW office) and an electronic copy of the reports and a corresponding cover letter addressed to MDE to COR by March 10, 2017 for the calendar year 2016.

5.1.2 Subtask 1B: Title V Annual Compliance Certification Reports for AA & EA Title V Permits

The contractor shall submit two hard copies and one electronic copy of each of the following reports to the COR by the dates listed:

1) One Title V Annual Compliance Certification report for the Aberdeen Area for calendar year 2016 using the two SIXMON reports by March 10, 2017.

2) One Title V Annual Compliance Certification report for the Edgewood Area for calendar year 2016 using the two SIXMON reports by March 10, 2017.

3) Two SIXMON Reports (one for the Aberdeen Area and one for the Edgewood Area) for the July 1 through December 31, 2016 period by January 15, 2017.

4) Two SIXMON Reports (one for the Aberdeen Area and one for the Edgewood Area) for the January 1 through June 30, 2017 period by July 15, 2017.

5.1.3 Subtask 1C: Annual Visible Emissions Certification for Heating Season.

The contractor shall prepare a report that shall include boiler location, date of opacity determination, and results of opacity determination. The field data sheets shall be included in the report as an Appendix. The field data sheets shall be similar to the forms shown as Figure 9-1, Record of Visual Determination of Opacity, and Figure 9-2, Observation Record, in 40 CFR 60, Appendix A. The contractor shall submit two (2) hard copies and one (1) electronic copy of each report (one for the Aberdeen Area and one for Edgewood Area) to the COR by March 15, 2017.

5.1.4 Subtask 1D: Semi-Annual Boiler Reports IAW Title V Permit requirements.

The contractor shall prepare and submit the semi-annual report covering the boiler usage in both the Aberdeen and Edgewood Areas from July 1 through December 31, 2016 to the COR by January 15, 2017. The contractor shall prepare and submit the semi-annual report covering the boiler usage in both the Aberdeen and Edgewood Areas from January 1 through June 30, 2017 to the COR by July 15, 2017.

5.1.5 Subtask 1E: Safety Determinations for Open Burn Permit.

The contractor shall prepare and submit the semi-annual report covering the period from January 1 through June 30, 2017 to the COR by November 30, 2016. The contractor shall and submit the semi-annual report covering the period from July 1 through December 31, 2017 to the COR by May 31, 2017. Both reports shall be submitted to an address provided by the COR.

5.2 Task 2A: APG Risk Management Plan (RMP) Update.

The contractor shall submit an update through the COR the online RMP database. The contractor shall submit a hard copy and an electronic copy of all deliverables to the COR by August 31, 2016.

5.3 Task 2B: Mandatory Greenhouse Gas Report.

The contractor shall prepare the Mandatory Greenhouse Gas report for online submittal through the COR and submit a hard copy and an electronic copy of the report to the COR by March 15, 2017. The Contractor will prepare the report ready for submittal by the COR online via the website: https://ghgreporting.epa.gov/

5.4 Task 3: Training.

Two (2), four (4) hour classes for combustion optimization and two (2), three (3) hour classes for CAA and Title V Awareness training, each for approximately 30 attendees, shall be conducted. The combustion optimization training course shall be conducted IAW Title V Permit to Operate, Section IV, Table IV (Operator Training). A certificate of completion shall be provided for all attendees. The contractor shall coordinate with the COR to schedule the classes, shall complete all necessary training, and submit proof of completion and copies of all certification to the COR by July 15, 2017.

6.0 OPERATIONAL SECURITY.

The contractor will be required to obtain all required clearances performing work on this Task Order. The requirements are included in the base contract. The contractor will work through COR to get any specific security pass and escort requirements to go into sensitive areas.

7.0 HAZARDS INFORMATION.

There could some hazard risks associated with this effort. Examples include visiting abandoned buildings, sites, etc.

8.0 TRAVEL REQUIREMENTS.

There are no travel requirements associated with this effort.

9.0 PERIOD OF PERFORMANCE.

The period of performance (POP) for this requirement will be twelve (12) months starting from the date of award (e.g. POP will be from July 2016 to June 2017). For CY 2016 compliance reports are due by March 31, of CY 2017.

10.0 CONTRACTING OFFICER’S REPRESENTATIVE (COR)

To be completed upon award of task order