1._ORC_PMP_Guidance_v1.0_20190920.docx

Optimized Remediation Contract (ORC) Program Management Plan (PMP) Guidance Version 1

September 2019

Prepared for:

Air Force Civil Engineer Center

(AFCEC/CZR)

Table of Contents

List of Tables

List of Figures

Acronym Listing

ACRONYM LISTING (CONT.)

Optimized Remediation Contract Program Management Plan Guidance iii

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 Contract Line Item Number (CLIN) structures, Work Breakdown Structures (WBSs), 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.

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1. Program Management Plan INSTRUCTIONS Overview 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 should refer to the applicable sections of the PWS for contract-specific requirements.

At a minimum, the PMP shall include the following sections: technical approach for achieving the Performance Objectives (POs) in accordance with the PWS, performance models, 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 Contractor is responsible for complying with the Air Force Civil Engineer Center (AFCEC) ORC PMP Guidance.

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 United States Army Corps of Engineers (USACE) Contracting Officer (KO)/Contracting Officer Representative (COR) and AF points of contact.

Program Management Plan Guidance The PMP provides information necessary to ensure successful achievement of the POs by the performance period specified for each site in Table 1 of the ORC PWS, for the contracted cost. The PMP also forms the basis for the AF and USACE QASP.

A large portion of the PMP can be incorporated from the proposal without substantial rework, and simply 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 PMP development process.

The Contractor shall address the technical approach at each site to include a description of 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. See Section 2 of this document for performance model guidance. The technical approach should identify any potential risks that can occur and associated mitigation and contingency actions. In addition, AF approval must be obtained before implementing contingency actions.

The AF recognizes that technical approaches may change from the time of proposal preparation to PMP preparation due to various factors (e.g., information obtained during questions and answers, regulatory input/requirements, site data updates, and remedial technology advances). 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 should be compared against the currently implemented remedy. An example BCA is presented in Attachment 1-2. The BCA should include:

A focused analysis of alternative approaches, to include conceptual designs and engineering cost estimates. The analysis should 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 IIMS/ MPS.

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. 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 the appropriate time. 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 USACE conduct surveillance for this contract?

A: Using the QASP in conjunction with the PMP, IMS/MPS, and performance model, the AF and USACE will conduct 100% reviews of all project deliverables. The USACE COR oversees all Surveillance activities, with AF point of contact 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. Descriptions of decision logic and processes, including consideration of contingency actions, are required parts of risk management in PMPs. The decision logic and process should 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 should show key personnel and subcontractor roles.

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

A: The USACE COR and AF point of contact have a primary point of contact 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/performance periods 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/ performance period /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. Any restructuring of the milestone payments in response to the need to employ contingent actions, for example, must be coordinated and approved by the USACE COR/AF point of contact.

Program Management Plan Checklist

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 Base’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 Base(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, such as Contract Number, USACE and AF points of contact, 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 point of contact and Restoration Program Manager, USACE, 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 should 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 should include a discussion of the overall approach for completing the entire task order scope. The technical approach should 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).

SUSTAINABILITY MEASURES

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 Task Order.)

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-CONTRACT LINE ITEM NUMBER (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 Deliverables

QUALITY MANAGEMENT

BASIC PRACTICES (Describe the Contractor corporate Quality Assurance 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 Flow Chart (Suggested) LIST OF ATTACHMENTS Statement of Objectives for ORC at Bases Technical Approach to Each Site (taken from Awarded Contract) Performance Indicators and scientifically-based models for each remedial action (for each remedial action at the degree of precision appropriate based on available performance data; include Process Improvement and Corrective Action ranges, and Process Failure and Contingency Action Ranges.)

IMS (Organize in a work breakdown structure to include: installation name, site number, CLIN/Sub-CLIN, task description, start and finish dates, milestone payment amount, percent complete, and predecessor and successor. Preferred as an integrated IMS and MPS within one Microsoft™ Project file.)

MPS (Organize in a work breakdown structure to include: installation name, site number, CLIN/Sub-CLIN, milestone payment identification number, milestone payment description, milestone payment amount, milestone payment percentage, completion date, percent complete, and invoice number. Preferred as an integrated IMS and MPS within one Microsoft™ Project file.)

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 warfighter, 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 warfighter 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.

$620

$385

$125

$545

$308

$75

Post Closure Care

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 base, there is a potential for future construction on base, including housing units, and a potential risk if the plume migrates past the base boundary.

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

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

Alternative-Specific Assumptions

Cost/Benefit Analysis

· 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

Scenario

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.

PERFORMANCE MODEL instructionS Overview In accordance with the ORC 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.

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 most directly represent 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 should 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.

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 (i.e., 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) should 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) should 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 should be further refined in the development of site-specific work plans. Contractors should 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 should 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 should 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 should 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 should 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, that consists of projecting expected performance, establishing performance thresholds, and identifying decision logic through use of performance indicator data, is described in Attachment 2-1.

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 should 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 should 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 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. Performance models are required for the PMP.

Performance Model Checklist

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 Specific Acquisition Planning (ISAP) team; 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 should 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:

Cw = ΣCi / n where Cw is the averaged concentration for an analyte in a given well per year, Ci is the measured concentrations for an analyte sampled in a given well for a given year, and n is the number of concentration data points for the respective analyte for that well in a given year.

· Calculate geometric mean of the annual average concentrations for a given well:

Cm(well,A) = where Cm(well,A) is the geometric mean of annual average concentrations in well A, Cw1(well,A) is the annual average concentration in well A in the 1st year of the dataset, and Cwn(well,A) is the annual average concentration in well A in the nth year of the dataset. This calculation is repeated for all selected performance monitoring wells to yield a single geometric mean value for each well.

· Determine the baseline concentration value using the median of the set of geometric mean values calculated for all wells.

b. METHOD B: Conduct trend analysis to determine baseline attenuation rate and extrapolate to the ORC performance period start date.

· Calculate the geometric mean of the annual average concentration for a given well in a given year:

Cm(yr,A) = where Cm(yr,A) is the geometric mean of all wells in year A. This calculation is repeated for all years included in the dataset to yield a single geometric mean value for each year.

· Plot the geometric mean values for each year.

· Use a best-fit model (generally, first-order decay) to represent the baseline attenuation rate and extrapolate through site end point (i.e., achievement of RL). The baseline concentration is given by the concentration at the performance period start date as determined by the extrapolated attenuation rate best-fit line. An example is shown in Figure 2-1 below.

Figure 2-1. Graphical Representation of Baseline Attenuation Rate and Extrapolation

· The trend analysis is only applied to data where statistically significant (e.g.,…