Attachment_6_-_MAES_2017_Hypothetical_Sample_Problem_rev_10072016.pdf

Hypothetical Sample Technical Problem

Remedial Measures at Site F Revised 7 October 2016

(revisions have been highlighted) (7-Oct-16 revisions shown in red italics)

1.0 SITE BACKGROUND

The area of concern - Site F, is a fictional 18-acre area located within the confines of a 420-acre military compound. The site is located in Onondaga County, New York and began operation in 1948. The operations of the site have changed throughout its 60+ year history.

Site F, an 18-acre parcel, was originally part of the National Defense Stockpile from 1948- 1958 in which the primary mission was the storage of materials and metallurgical ores essential for manufacturing defense and/or strategic materials. After 1958 and all the buildings and stockpiles were removed from Site F, the land was annexed over to the adjacent Camp Imaginary. From 1965-2008, a portion (0.5 acre) of Site F was used for fire training activities.

A Radiological Historical Site Assessment of Site F was performed in 2010 and revealed that several stockpiles of ore were stored at the site from 1948-1958. Stockpiled materials included thorium nitrate and baddeleyite (zirconium) ore. The thorium nitrate were packaged in steel or galvanized drums and stored in a warehouse; the baddeleylite ore was stored as stockpiles in an open area. The contaminants of concern associated with the receipt and storage of these ores are natural uranium and thorium, both in secular equilibrium with their daughter products.

Once Site F was transferred to Camp Imaginary, a portion of the Site (Figure 1) was used as fire training area. The fire training area consisted of a 50 meter diameter unlined, bermed burn pit. From 1965 through 2008 fire training exercises occurred on a weekly to monthly basis. Typical activities included flooding the fire pit with flammable liquids, igniting the fluids, and extinguishing the fire with fire fighting agents including aqueous film forming foam (AFFF). Spent fuel was allowed to pool in the burn pit until it either evaporated or infiltrated into the subsurface.

A preliminary site investigation was performed in 2009 and a Remedial Investigation (RI) in 2012 indicating that Site F soils were contaminated with metallic and radiologic waste from the use as a stockpile area; and soil and groundwater were contaminated from fire training activities with hydrocarbons and perfluorochemicals. The contaminants of concern pose an unacceptable risk for current and future industrial/commercial use.

The U.S. Army Corps of Engineers (USACE) is utilizing the administrative, procedural, and regulatory provisions of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 United States Code (U.S.C.) Section (§) 9601, et seq. and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R.

Part 300, to guide the remediation process at Site F. USACE is the lead agency, the Environmental Protection Agency (EPA) and the New York State Department of Environmental Conservation (NYSDEC) are regulatory partners/stakeholders for this CERCLA response action.

Site F is situated on approximately 100 feet of unconsolidated glacial material overlying shale bedrock. The bedrock has low permeability and acts as a hydraulic barrier to groundwater flow. The hydrogeology of the area consists of a water table aquifer separated by a semi-permeable confining layer, approximately 60 feet below ground surface (bgs).

The depth to water in the shallow groundwater aquifer is approximately 9 feet bgs. The geology of this water table aquifer is glacial in origin consisting mostly of silty sand with some gravel, and has a hydraulic conductivity of 0.57 ft/day. The semi-permeable confining unit is 4 feet thick and has a vertical hydraulic conductivity of 0.00025 ft/day.

Below the semi-permeable confining unit is another aquifer consisting of sandy silt with several clay stringers, also of glacial origin. The depth to water recorded in wells screened in this lower aquifer averages 10 feet bgs, and has a hydraulic conductivity of 1.4 ft/day.

This deeper aquifer continues to the bedrock, located approximately 100 feet below grade.

Approximately 250 feet downgradient and to the Northeast of Site F is Abstract Creek.

Currently, the plume presently does not extend off Government controlled property, so there is no complication regarding rights-of-entry for implementing a remediation on private property.

2.0 EXAMPLE PROBLEM CONTRACTING BASIS

For the purpose of this example problem it will be assumed that the Contractor will be given a Task Order under this Multiple Award Environmental Services (MAES) contract with the performance objectives and standards detailed below. The contract will be a combination of Fixed Firm Price and Cost Reimbursable and will be performed as a Performance Based Contract (PBC). See the bid sheet for the cost type for each CLIN.

The PBC will require that the contractor perform all necessary environmental services required to meet the performance objectives and standards, including addressing any unforeseen environmental, scheduling, and/or regulatory issues, as well as assume all contractual liability and responsibility for the work.

3.0 SCOPE OF WORK

The work at Site F is separated into two operable units, one representing the soil and the other groundwater due to the contamination and the remedial response associated with them.

3.1 Soil Operable Unit

The results of the RI at Site F revealed that approximately 5-acres of soil are contaminated with radioactive materials and associated metals from the former stockpiles and warehouses and associated roads and railroads. The horizontal extent of contamination exceeding regulatory criteria is outlined in green on Figure 1. Maximum concentrations detected in the surface soil (0-1 feet bgs) are 303.2 pCi/g of Th-232, 42.65 pCi/g of U-238 and 1,245mg/kg of lead. The vertical extent of contamination exceeding regulatory criteria is 1 foot.

Another area of soil, the former fire training pit (approximately 0.5-acres), is contaminated with hydrocarbons and perfluorochemicals. The highest surface soil benzene concentration was measured at 122.3 mg/kg, perfluorooctanoate (PFOA) concentrations of

2202.3 ug/kg, and perfluorooctanesulfonate (PFOS) was detected at 10230.4 ug/kg. The vertical extent of contaminant concentrations exceeding regulatory criteria is 3 feet.

All soil contamination must be addressed in this PWS and go through the CERCLA process to Remedial Response complete within the restraints of period of performance.

3.2 Groundwater Operable Unit

The RI revealed that there is a soil vapor intrusion risk for industrial workers in both Buildings 423 and 426 from the former fire training pit area. In Site F groundwater there is a significant groundwater plume of benzene and PFOA/PFOS migrating downgradient of former fire training pit (groundwater is flowing to the northeast). Maximum groundwater concentrations were 623.55 ug/L for benzene, 120.3 ug/L for PFOA, and

15.78 ug/L for PFOS. Based on hydrogeologic data reported in the RI, it is known that in the subject area the water table aquifer depths average 9-feet below grade, with predominantly silty sand & gravel and the groundwater is moving in a northeasterly direction. The water table aquifer is approximately 51 feet thick and is separated by a semi-permeable confining unit approximately 60 feet below grade.

The groundwater contamination must be addressed in this PWS and go through the CERCLA process and achieve an approved remedial design within the restraints of the period of performance.

4.0 TECHNICAL APPROACH

4.1 Performance Objectives and Standards

Table 1: Performance Objectives Summary

Performance Objective Performance Standard

1. Approved Project Management Plan (PMP), Quality Assurance Surveillance

USACE approval of PMP and QASP by Contracting Officer’s Representative

(COR).

Plan (QASP), and all PM responsibilities throughout the life of the project:

Draft PMP and QASP within 20-days of Notice to Proceed (NTP)

Final PMP and QASP within 10-days of Contracting Officer’s Representative (COR) comments on draft.

Acceptance by the COR of monthly reports.

2. Remedial Response Complete for Soil OU at Site F within 5 years of NTP.

Meet USACE, USEPA and NYSDEC standards for Remedial Response Complete.

Acceptance by the COR that the Contractor has demonstrated that the proposed remedy represents the lowest 30-year present worth cost to the Army, and is acceptable to the regulators.

3. Complete Design of Remedial Action for Groundwater OU at Site F within 5-years of NTP.

Approval of Remedial Design by USACE, USEPA and NYSDEC.

Acceptance by the COR that the Contractor has demonstrated that the proposed remedy represents the lowest 30-year present worth cost to the Army, and is acceptable to the regulators.

4.2 Overall Technical Approach

Provide an overall technical approach for the task order, addressing each of the following:

1. Health and safety considerations

2. Regulatory considerations

3. Stakeholder considerations

4. Portions of work to be self performed and portions to be subcontracted

5. Labor hours by technical discipline for each major task (to be submitted in

Volume III)

6. Any assumptions not provided above

4.3 Sample Problem Submittal

The Sample Technical Problem should include the technical approach and the project schedule under Factor 1. The cost estimate for the Sample Technical Problem should be submitted in Volume III.

5.0 PROJECT MANAGEMENT

The PBA approach requires careful coordination of project activities to ensure that all stakeholders are kept informed of the project status, existing or potential problems, and any changes required to prudently manage the project and meet the needs of the Installation's project stakeholders and decision-makers. The Contractor shall be responsible for the following project management activities:

5.1 Project Management Plan

The Contractor shall develop and maintain a detailed Project Management Plan (PMP).

The PMP, based on the schedule prepared as part of the Contractor proposal, shall specify the schedule, technical approach and resources required for the planning, execution, and completion of the performance objectives. The first draft of the PMP shall be due within twenty (20) calendar days of contract award and shall include a payment milestone plan.

Elements of this draft PMP shall be part of the offeror’s proposal submittal. The draft PMP, proposed payment milestones, and subsequent revisions shall be subject to Army review and approval, through the COR. The final PMP shall be due within ten (10) calendar days of receipt of COR comments on the draft PMP. A payment milestone will be established for Army approval of the final PMP through the COR.

The PMP shall identify and implement a means for providing project status reports to the COR. The PMP shall address the frequency and content of status reports.

The PMP will reflect current progress towards achievement of the performance objectives and delineate proposed actions to accomplish future project milestones.

A draft and final quality assurance surveillance plan (QASP) will be submitted with the PMP, and will be used by the Government to conduct QA of the Contractor’s work throughout the life of the task order to ensure conformance with contract requirements.

The QASP sets forth procedures and guidelines that USACE will use in evaluating technical and safety performance.

The QASP is intended to accomplish the following, at least on a basic level: (a) Define the roles and responsibilities of participating Government officials; (b) Define the types of work to be performed with required end results; (c) Document the evaluation methods that will be employed by the Government in assessing the Contractor’s performance; (d) Provide the Surveillance Activity Checklists and CAR forms that will be used by the Government in documenting and evaluating the Contractor’s performance; (e) Describe the process of performance documentation; and (f) Outline QA procedures to be employed by the Government during performance of the task order to confirm that work is conducted according to accepted standards.

5.2 Project Schedule

The PMP will be maintained and updated with USACE approval on a monthly basis a current Activity-Based Schedule that fully supports the technical approach and outlines activities and milestones defined at the appropriate detail level and logically sequenced to support and manage completion of the performance objectives in this PWS. Additionally, the due dates for all payable deliverables shall be identified. A payment plan shall be included with the schedule that may allow for payments to the Contractor based on successful completion of interim milestones proposed by the Contractor. Activities identified in the QASP should be appropriately coded in the project schedule to allow for planning of QA inspections. It is the Army’s intent to make all payments after verification of milestone completion in accordance with this schedule. Unless otherwise noted in Table 1 of this PWS, all performance objectives must be completed within the allowable contract period of performance. The project schedule must take into account the existing or future schedules developed under the applicable regulatory drivers listed in Section 1.0 of this PWS. The project schedule must show coordination between the contractor and the USACE to ensure that the proposed project schedule does not conflict with other contractor activities on site, or interrupt Installation mission activities.

5.3 Milestone Presentations

Milestone presentations shall not be required, but rather detailed in a monthly progress report provided to the Government. All milestones must have a defined means for demonstrating completion in order to facilitate certification and approval of this PWS.

Major Milestones for Government Approval

Approval of the Final PMP and QASP, Approval of the Final APP/SSHP, Completion of Verification Sampling Results Report Approval of Soil Final Feasibility Study, Approval of Soil Proposed Plan, Approval of Soil ROD, Approval of Final Soil Remedial Action Work Plan, Approval of Final Soil Remedial Action Report, Approval of Final Groundwater Feasibility Study, Approval of Groundwater Proposed Plan, Approval of Groundwater ROD, Approval of Final Groundwater Treatment Plan, Approval of Final Groundwater Treatability Report, Approval of Final Groundwater Design Report.

5.4 Environmental Requirements

The following shall be identified; all applicable federal, state and local laws and regulations; applicable Installation-specific orders, agreements, or rules; and perform its work in accordance with said authorities. All activities performed by the Contractor’s personnel, subcontractors and suppliers are executed in accordance with said authorities.

Any incident of noncompliance noted by the Contractor shall immediately be brought to the attention of the COR and Installation telephonically and then by written notice.

Nothing in this contract shall relieve the Contractor of its responsibility to comply with applicable laws and regulations. The Contractor shall obtain all permits, licenses, approvals, and/or certificates required or necessary to accomplish the work. When the work to be performed requires facility clearances, such as utility clearance, digging, and drilling permits, the Contractor shall obtain such clearances and/or permits, with the assistance of the installation point of contact, prior to any drilling or excavating operations.

The Contractor shall coordinate all such work with Installation maintenance personnel prior to performing work. Contractors on environmental sites are required to perform their own utility checks based on Installation-supplied utility maps. The Contractor shall comply with all Installation- or site-specific time and procedural requirements (federal, state, and local) described in the permits obtained. The Army technical experts will also independently review Contractor work to ensure compliance with all applicable requirements.

The Contractor shall review and fully understand "Executive Order 13693 – Sustainability in the Next Decade. The Contractor shall also be required to review and adhere to the installation's environmental management system, including the environmental policy and significant aspects / impacts.

The Contractor shall consider and implement green response/remediation strategies and applications to maximize sustainability, reduce energy and water usage, promote carbon neutrality, promote industrial materials reuse and recycling, and protect and preserve land resources, consistent with DOD’s Policy on Consideration of Green and Sustainable Remediation Practices in the Defense Environmental Restoration Program. The contractor shall present green remediation options and approaches in its work plans, maintain records of “green-related” activities, and report this information to the COR in its project status reports.

5.5 Health and Safety Requirements

Prior to beginning any field work, the Contractor shall prepare and implement a written Safety and Occupational Health (SOH) Program which includes an APP and SSHP. The SOH program shall be compliant with federal, state, and local laws and regulations and accepted by USACE. As a minimum, the APP and SSHP shall be prepared in accordance with Engineering Manual (EM) 385-1-1, Appendix A (APP), Section 28.B (SSHP), and include all other pertinent sections of the manual. The APP and SSHP must be submitted to USACE at least 30 days prior to beginning work. The Contractor shall ensure that its subcontractors, suppliers and support personnel comply with the approved plans. The Contractor may, at its discretion, have the Site Supervisor act if qualified also in the capacity as the Site Safety/Health Officer.

The APP shall be developed and submitted by the Contractor in the format provided in Appendix A of EM 385-1-1. Each element/sub-element outlined in Appendix A shall be addressed in the order that they are provided in the manual.

As a minimum, the SSHP shall contain the following elements: site description and contaminant characterization, safety and health hazard(s) assessment and risk analysis, safety and health staff organization and responsibilities, site specific training and medical surveillance parameters, personal protective equipment (PPE) and decontamination facilities and procedures to be used, monitoring and sampling required, safety and health work precautions and procedures, site control measures, on-site first aid and emergency equipment, emergency response plans and contingency procedures (on-site and off-site), logs, reports, and record keeping. Training and medical screening per 29 CFR 1910.120(e) is required for the contract.

The Army reserves the right to stop work under this contract for any violation of the APP/SSHP at no additional cost to the Army. The Contractor, authorized Installation personnel, and the COR have the responsibility to stop work immediately if the work is considered to be a serious threat to the safety and/or health of workers, other personnel, or the environment. Authorized Installation personnel include Installation safety officers, Environmental Division personnel, and commend personnel with responsibility for overall Installation operations. When work is stopped due to a hazard/threat to worker safety, health, or the environment, the situation and resolution must be documented and submitted to the KO. Once the Army verifies through the COR that the violation has been corrected, the Contractor shall be able to continue work. Work must be stopped when chemical and biological warfare agents are encountered.

5.6 Quality Management

The Contractor must ensure that the quality of all work performed or produced under this contract meets Army approval, through the COR. Quality control/assurance plans must be prepared and approved by the COR prior to performance of physical work. The Contractor is responsible for the accuracy and completeness of submittals. Any costs incurred due to multiple submittals of documents caused by inaccuracy, lack of coordination, and/or checking will be the sole responsibility of the Contractor. This shall include the handling and review time on the part of the Government. Acceptance actions taken by the Government shall in no way relieve the Contractor of their responsibility to comply with all applicable federal, state, local regulations and quality control requirements.

5.7 Quality Control

Quality Control (QC) shall be provided by the Contractor whenever sampling or analysis for chemical constituents is required in order to achieve milestones. Quality control for traditional soils or geotechnical testing shall also be included. All sampling and analysis shall comply with the requirements of the most recently approved DoD Quality Systems Manual (QSM). The laboratory (ies) to be used by the Contractor shall be DoD Environmental Laboratory Accreditation Program (DoD ELAP) certified. The Contractor may establish an on-site testing laboratory at the project site if determined necessary by the Contractor. However, on-site testing laboratory (ies) shall be DoD ELAP certified and meet the requirements of USEPA, specific state regulator requirements, and all requirements of the most recently approved DoD Quality Systems Manual (QSM).

Following contract award and during project implementation, the Contractor shall develop and submit documentation of project-specific quality assurance (QA) and QC activities prepared in accordance with the Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP). The Government will review and return the quality systems documentation, with comments, indicating acceptance or rejection. If necessary, the Contractor shall revise the documentation to address all comments and shall submit the revised documentation to the Government for acceptance. In addition, the Contractor shall develop and submit Quality Control Summary Reports to summarize the quality control details of the contract project. The problems and successes of the work done to control the quality of the chemical measuring activities and other chemically related cleanup activities shall be included in the summary reports.

A typical QA/QC process may involve the Contractor conducting a Quality Management Audit on each phase of a project. The Contractor may randomly select and audit a project site undergoing each phase of work. Examples include:

Project Planning Field Work Laboratory Analysis Data Analysis Report Preparation

Auditing each phase of work for a project constitutes a Quality Management Audit. The audit should evaluate compliance with the Performance Work Statement/Scope of Work, the UFP-QAPP, proper implementation of QC procedures, and proper documentation of QC inspections/findings. Results of each phase of the audit should be captured in a format to document deficiencies and subsequent corrective actions. The Contractor may compile the audit results from all phases of work into a QA Management Assessment Report.

5.8 Project Repository and Administrative Record

The Contractor will be required to deposit all documents and written correspondence into its Sharepoint site, and provide for a separate and secure electronic location for Government review of draft documents.

5.9 Monthly Status Reports

The Contractor shall submit by the 10th day of each month a monthly progress report summarizing activities of the preceding month (if at least 15 days of contract performance occurred in that month) and planned activities for the following month. The report shall be a concise summary and include at a minimum, the following information:

(1) Contracting Office, Contracting Officer, Contracting Officer’s Representative;

(2) Contract number, including task and delivery order number;

(3) Beginning and ending dates covered by the report;

(4) Date of the report;

(5) Contract completion date;

(6) Contractor name, address, phone number, e-mail address, identity of Contractor employee entering data;

(7) Summary of accomplishments for the report month and planned accomplishments for the following month;

(8) Indicate whether you are on or off schedule; reason for delay if applicable.

(9) Problems encountered during the period. Problems resolved or still outstanding?

Corrective action, if applicable.

(10) Safety reporting including field exposure hours and recordable and/or reportable accidents;

(11) Record of deliverables submitted;

(12) Record of communication, correspondence, and invoices;

(13) Estimate of percentage complete for each task and overall percentage complete;

(14) Personnel changes, and,

(15) If applicable an updated network analysis schedule.

Reports shall be submitted to the COR in hard copy as well as via email. Email attachments, if any, shall be in Adobe pdf or MS Word format only. Email submittals shall include the project manager, the Installation POC, and emdc.admin@usace.army.mil on the cc line.

The subject of the email shall be the contract number with task order followed by “Monthly Progress Report” followed by the year and month of the report (for example “W912DR- 99-D-9999 9999 Monthly Progress Report YYYY MM”).

5.10 Protection of Property

The Contractor shall be responsible for any damage caused to property of the United States (Federal property) by the activities of the Contractor under this contract and shall exercise due diligence in the protection of all property located on the premises against fire or damage from any and all other causes. Any property of the United States damaged or destroyed by the Contractor incident to the exercise of the privileges herein granted shall be promptly repaired or replaced by the Contractor to a condition satisfactory to the COR or reimbursement is made by the Contractor sufficient to restore or replace the property to a condition satisfactory to the COR in accordance with FAR Clause 52.245-2.

5.11 Project Stakeholders

For the purposes of this PWS, project stakeholders will include but are not limited to:

the Army the NYSDEC the U.S. Environmental Protection Agency (USEPA) Region II

5.12 Regulatory Involvement

All regulatory coordination shall be approved by the Army through the COR and the Installation. The Contractor shall provide the necessary support to initiate, schedule, and address all regulatory aspects of the project (e.g., organizing discussions with regulators concerning site response objectives and completion requirements, obtaining regulator comments on site documents and appropriately addressing them, and obtaining written documentation of remediation completion from the regulators for all of the sites identified in this PWS). The COR, installation representative, or designees, will attend and represent the Army at all meetings with the regulators. With approval of the COR and installation, the contractor may also informally discuss remediation issues with regulators and provide an after-action report back to the COR. The Army will be the signature authority for all regulatory agreements and remediation documentation.

5.13 Public Involvement

All public participation coordination shall be approved by the Installation through the COR. The Contractor shall provide the necessary support to initiate, schedule, and address all public participation aspects of the project (e.g., preparation of briefings, presentations, fact sheets, newsletters, articles/public notices to news media, and notifications to RAB members). The Contractor shall be responsible for requesting and addressing all public comments consistent with the applicable regulatory drivers. The Installation POC and COR, or designee, will attend and represent the Installation at all meetings with the public.

5.14 Communications

The Contractor shall not make available or publicly disclose any data or report generated under this contract unless specifically authorized by the COR and Installation. If any person or entity requests information from the Contractor about the subject of this scope of work or work being conducted hereunder, the Contractor shall refer them to the COR. All reports and other information generated under this performance work statement shall become the property of the Government, and distribution or presentation of any data, reports, or evaluation to any other source other than USACE and Installation by the Contractor is prohibited unless authorized by the COR.

5.15 Deliverable Requirements

All documents must be produced with at least draft, draft-final, and final versions. With Army concurrence, the Contractor may coordinate with appropriate regulatory agencies to determine if fewer versions of each deliverable are sufficient for review. The Army, through the COR, will receive initial draft documents and will provide comments to the Contractor within fifteen (15) calendar days. Once initial comments are addressed, the Army will review draft documents before submission to appropriate regulatory agencies.

The Contractor shall ensure that review periods are consistent with the applicable regulatory drivers noted in Section 1.0 of this PWS. All documents shall be identified as draft until completion of stakeholder coordination, when they will be signed and finalized.

Three (3) hard copies of the final document shall be provided to the Government with electronic media, and electronically placed within the Sharepoint site. One copy of the final document shall be placed in both the project repository and Administrative Record (for CERCLA documents).

5.16 Contractor Manpower Reporting

The Office of the Assistant Secretary of the Army (Manpower & Reserve Affairs) operates and maintains a secure Army data collection site where the Contractor will report ALL Contractor manpower (including sub-contractor manpower) required for performance of this contract. The Contractor is required to completely fill in all the information in the format using the following web address https://cmra.army.mil. The required information includes:

(1) Contracting Office, Contracting Officer, Contracting Officer’s Technical Representative;

(2) Contract number, including task and delivery order number;

(3) Beginning and ending dates covered by reporting period;

(4) Contractor name, address, phone number, e-mail address, identity of Contractor employee entering data;

(5) Estimated direct labor hours (including sub-contractor);

(6) Estimated direct labor dollars paid this reporting period (including sub-contractor);

(7) Total payments (including sub-contractor);

(8) Predominant Federal Service Code (FSC) reflecting services provided by Contractor (and separate predominant FSC for each including sub-contractor if different);

(9) Organizational title associated with the Unit Identification Code (UIC) for the Government Requiring Activity;

(10) Locations where Contractor and sub-contractors perform the work (specified by zip code in the United States and nearest City, Country, when in an overseas location, using standardized nomenclature provided on website);

(11) Presence of deployment or contingency contract language, and,

(12) Number of Contractor and sub-contractor employees deployed in theater this reporting period (by country). As part of its submission, the Contractor will also provide the estimated total cost (if any) incurred to comply with this reporting requirement. Reporting period will be the period of performance not to exceed 12 months ending September 30 of each Government fiscal year and must be reported by 31 October of each calendar year.