B.08 FY23 Carolina Group ORC_Final PWS_3APR23.pdf

PERFORMANCE WORK STATEMENT

FOR

CAROLINA GROUP

OPTIMIZED REMEDIATION CONTRACT

AT

JOINT BASE CHARLESTON-AIR, SOUTH CAROLINA

JOINT BASE CHARLESTON-WEAPONS, SOUTH CAROLINA

NORTH AUXILIARY AIRFIELD, SOUTH CAROLINA

SEYMOUR JOHNSON AIR FORCE BASE, NORTH CAROLINA

30 MARCH 2023

FY23 Version 1.2

CONTENTS

1.0 SCOPE

1.1 INTRODUCTION

1.2 OVERVIEW OF ORC SCOPE AND REQUIREMENTS

1.2.1 Scope Discussion and Limits

1.2.2 Preliminary Assessment/Site Inspection, Remedial Investigation or Remedial Investigation/Feasibility

Study (including Supplemental Investigations), and Decision Document

1.2.3 Response Complete or Site Closeout

1.2.4 Remedial Action-Operation with Optimization

1.2.5 Remedial Action-Operation and Reduce Life Cycle Cost; Long Term Management and Reduce Life

Cycle Cost

1.2.6 Remedial Action-Operation or Long-Term Management (as appropriate)

1.2.7 Alternate Objectives

1.3 PERFORMANCE REQUIREMENTS

1.3.1 Table 1: Performance Table

1.3.2 Additional Scope Discussion and Limits

2.0 APPLICABLE DOCUMENTS

3.0 GOVERNMENT FURNISHED INFORMATION AND PROPERTY

4.0 MANAGEMENT, PLANNING, AND REPORTING REQUIREMENTS

4.1 PROJECT MANAGEMENT PLAN

4.2 SCHEDULE AND PLANNING REQUIREMENTS – INTEGRATED MASTER SCHEDULE

4.3 MILESTONE PAYMENT SCHEDULE

4.4 COST AND STATUS REPORTING

4.5 ORC DOCUMENT REPOSITORY – TO INCLUDE ALL DOCUMENT VERSIONS, AND REGULATORY CORRESPONDENCE.

4.6 MEETING AND CONFERENCE REQUIREMENTS

4.6.1 Meeting/Teleconference Support

4.6.2 Public Meetings and Hearings

4.7. SPATIAL DATA (MAP) REQUIREMENTS

4.8 INFORMATION SECURITY

4.8.1 Computer and Network Access Requirements:

4.8.2 Cybersecurity Reporting

4.9 NOTIFICATION REQUIREMENTS

4.10 PERMITS

4.10.1 Environmental Permits

4.10.2 Rights of Access to Non-AF Real Property

4.11 PHOTO DOCUMENTATION

4.12 REMOTE AND/OR AUSTERE SITES

4.13 SITE ACCESS

4.14 WORKSITE ACTIVITIES AND COORDINATION

4.14.1 Coordination of Activities

4.14.2 Hazardous Material, and Hazardous Waste Permitting and Reporting

5.0 CHEMISTRY REQUIREMENTS

5.1 QUALITY ASSURANCE

5.2 LABORATORY SELECTION

5.3 ANALYTICAL DATA MANAGEMENT

5.4 RECORD KEEPING

6.0 PLANS AND REPORTS

6.1 QUALITY PROGRAM PLANS

6.1.1 Work Plans

6.1.2 Health and Safety Plan

6.1.3 Construction Quality Plan

6.2 TECHNICAL PLANS AND REPORTS

7.0 SITE WORK

7.1 CONSERVATION

7.2 SITE CHARACTERIZATION AND FIELD INVESTIGATION

7.3 SITE PREPARATION

7.4 DEMOLITION

7.5 SITE RESTORATION

8.0 ENVIRONMENTAL REQUIREMENTS

8.1 ENVIRONMENTAL RESTORATION PROCESS APPLICATION

8.1.1 Conceptual Site Model Guidance

8.1.2 Exit Strategy

8.1.3 Performance and Optimization

8.2 TRANSITION OF WORK

8.3 ENVIRONMENTAL CONSTRUCTION

8.3.1 Design

8.3.2 Inspection

8.3.3 Delivery and Warranty

8.4 ENVIRONMENTAL RESOURCES PROGRAM INFORMATION MANAGEMENT SYSTEM

8.5 INNOVATIVE AND PROVEN TECHNOLOGIES

8.6 OPERATIONS AND MAINTENANCE

8.7 ORDNANCE REMOVAL AND SUPPORT

8.8 HAZARDOUS WASTE REMOVAL AND SUPPORT

8.9 STUDY EFFORT INCIDENTAL TO REMEDY OR CORRECTIVE ACTION

8.10 FIVE-YEAR REVIEW SUPPORT

9.0 QUALITY ASSURANCE SURVEILLANCE PLAN

10.0 POINTS OF CONTACT

11.0 KEY PERSONNEL

11.1 ANTITERRORISM (AT) AND OPERATIONS SECURITY (OPSEC)

11.2 AT LEVEL I TRAINING

11.3 GENERAL SECURITY REQUIREMENTS AND GUIDANCE

11.4 PHYSICAL SECURITY AND ACCESS CONTROL REQUIREMENTS

11.5 CONTRACT PERSONNEL REQUIRING A COMMON ACCESS CARD

11.6 TRAINING REQUIREMENTS FOR THE PROTECTION OF SENSITIVE INFORMATION

11.7 COUNTERINTELLIGENCE AWARENESS TRAINING

11.8 CONTRACTS REQUIRING A FORMAL OPSEC PROGRAM

Enclosure 1 – Acronyms and Definitions

Enclosure 2 – Government Furnished Information (GFI)

1.0 SCOPE

This requirement is for environmental remediation activities at Joint Base Charleston-Air

(JBCA), Joint Base Charleston-Weapons (JBCW), and North Auxiliary Airfield (NAAF), in

South Carolina (SC); and Seymour Johnson Air Force Base (SJAFB), in North Carolina (NC).

This Performance Work Statement (PWS) defines the scope of environmental services necessary to conduct site restoration under the Optimized Remediation Contract (ORC). The range of activities includes maintenance of established remedies, optimization at applicable sites, and achievement of site-specific objectives. The Contractor shall undertake Environmental

Remediation activities to achieve Performance Objectives (POs) at fifty-four (54) Installation

Restoration Program (IRP) sites and eleven (11) Military Munitions Response Program (MMRP) sites.

NOTE: For purposes of this ORC, the term “Government” includes the Air Force (AF) and

United States Army Corps of Engineers (USACE). While regulators are a governmental entity, they are also a third party over whom the Air Force has no control and, as such, will be referred to as “regulators.”

1.1 Introduction

Joint Base Charleston-Air (JBCA)

Joint Base Charleston-Air is located on the west bank of the Cooper River about ten miles north of Charleston, SC and is within North Charleston city limits. JBCA is home to the 437th Airlift

Wing (AW), 315th Airlift Wing (AW) (Reserves), and 628th Airbase Wing (ABW) and encompasses approximately 3,400 acres of land. The 315th AW operates the C-17 Globemaster

III strategic airlift aircraft and shares the same aircraft with 437th AW. The 437th AW provides airlift of troops and passengers, military equipment, cargo, and aeromedical equipment and supplies worldwide in support of tasking by Air Mobility Command and unified combatant commanders. The 628th ABW provides installation support to 53 Department of Defense

(DOD) and federal agencies as well as mission-ready expeditionary Airmen to combatant commanders in support of joint and combined operations.

Remediation activities at Joint Base Charleston-Air are being conducted pursuant to the National

Oil and Hazardous Substances Contingency Plan (NCP), and the Resource Conservation and

Recovery Act (RCRA) requirements. Regulatory oversight is provided by the South Carolina

Department of Health and Environmental Control (SCDHEC). Cleanup is performed under

RCRA, but the Air Force maintains its CERCLA authority. The Environmental Protection

Agency (EPA) may be consulted by SCDHEC for issues with Risk Assessments and Permit

Renewals.

JB Charleston-Air operates under RCRA Corrective Action Permit SC3 570 024 460 effective through 16 Aug 2029; issued 31 July 2019. The Compliance office plans on initiating the next permit renewal application in 2028. The ORC contractor will need to support, as needed, updates for the Environmental Restoration program sections of the RCRA Permit applications.

Tier I and Tier II partnering meetings are conducted with SCDHEC monthly via teleconference;

the Contractor will attend in-person and support Tier I meetings semiannually during each year of the contract. These meetings are held in either Columbia, SC. or Charleston, SC.

Joint Base Charleston-Weapons (JBCW)

Joint Base Charleston-Weapons is located in the town of Goose Creek, Berkeley County, and is approximately 10 miles from the Air Base and 14 miles from downtown Charleston. The Naval

Weapons Station was commissioned in 1941, with two distinct missions: home for two strategic submarine squadrons and a tender, and an ordnance station with capacity for more than 60 million pounds of conventional ordnance. The ordnance mission continues today. JBCW is the only military installation in the continental US with completely unencumbered explosive safety arcs. JBCW is also a training center for the Naval Nuclear Power Training Command, Nuclear

Power Training Unit, and other tenants.

Remediation activities at Joint Base Charleston-Weapons are being conducted pursuant to the

National Oil and Hazardous Substances Contingency Plan (NCP), and the Resource

Conservation and Recovery Act (RCRA) requirements. Regulatory oversight is provided by the

South Carolina Department of Health and Environmental Control (SCDHEC). Cleanup is performed under RCRA, but the Air Force maintains its CERCLA authority. The Environmental

Protection Agency (EPA) may be consulted by SCDHEC for issues with Risk Assessments and

Permit Renewals.

JB Charleston-Weapons operates under RCRA Corrective Action Permit SC8 170 022 620 effective through 2031; issued 2021. The Compliance office plans on initiating the next permit renewal application in 2030. The ORC contractor will need to support, as needed, updates for the

Environmental Restoration program sections of the RCRA Permit applications.

Tier I and Tier II partnering meetings are conducted with SCDHEC monthly via teleconference;

the Contractor will attend in-person and support Tier I meetings semiannually during each year of the contract. These meetings are held in either Columbia, SC. or Charleston, SC.

North Auxiliary Airfield (NAAF)

North Auxiliary Airfield is located 65 miles northwest of JBCA and 45 miles southeast of the state capital of Columbia. NAAF has 2,400 acres of land, of which 1,150 acres is undeveloped.

The original dirt runway was constructed in 1943 and used by Hughes Aircraft Company for testing. Today the base has a 12,000 ft runway and a 3,000 ft assault runway. The 628th Civil

Engineer Squadron operates the base. The base supports the 437th and 315th Airlift Wing’s C-17

Globemaster III aircrew training and proficiency training.

Remediation activities at North Auxiliary Airfield are being conducted pursuant to the

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA) and the National Oil and Hazardous Substances Contingency Plan (NCP). Regulatory oversight is provided by the

South Carolina Department of Health and Environmental Control (SCDHEC). The

Environmental Protection Agency (EPA) may be consulted by SCDHEC for issues with Risk

Assessments and Permit Renewals.

Seymour Johnson Air Force Base (SJAFB)

Seymour Johnson Air Force Base is annexed to Goldsboro, North Carolina, and occupies 3,300 acres in the southeast section of Goldsboro. Seymour Johnson Field was opened in April 1942 as

Headquarters, Technical School, and Army Air Forces Technical Training Command. Seymour

Johnson Field was deactivated in May 1946. Seymour Johnson Air Force Base was reactivated as a Tactical Air Command base on April 1, 1956. Seymour Johnson has been an active Air

Force base since it reopened. The 4th Fighter Wing is the host unit at Seymour Johnson Air

Force Base and accomplishes its training and operational missions with 92 F-15E Strike Eagle aircraft. Two of the Wing’s four fighter squadrons are operational units capable of deploying world-wide on short notice and immediately generating combat power. The other two squadrons are responsible for training all F-15E aircrews for the Air Force.

Remediation activities at Seymour Johnson AFB are being conducted pursuant to the National

Oil and Hazardous Substances Contingency Plan (NCP), and the Resource Conservation and

Recovery Act (RCRA) requirements. Regulatory oversight is provided by the North Carolina

Department of Environment Quality (NCDEQ). Cleanup is performed under RCRA, but the Air

Force maintains its CERCLA authority.

Seymour Johnson AFB operates under RCRA Corrective Action Permit NC 7570024474R2 effective through 24 Sep 25. The Compliance office will submit the permit renewal application in FY24 (SJAFB RCRA permit will be due 24 Mar 25; the new permit will be effective for 10 years).

Tier I and Tier II partnering meetings are conducted with NCDEQ quarterly via teleconference

(or virtual meeting); the Contractor will attend in-person and support Tier I meetings once annually during each year of the contract. These meetings have been held previously at either

SJAFB or in Raleigh, North Carolina.

1.2 Overview of ORC Scope and Requirements

The Contractor shall perform all the necessary environmental remediation activities needed to achieve the performance requirement described in Section 1.3 of the PWS inclusive of the POs listed in Table 1, Performance Table, and additional scope in 1.3.2. This PWS and enclosures listed below detail the project requirements needed to meet the AF objectives:

• Enclosure 1 – Acronyms and Definitions

• Enclosure 2 – Government Furnished Information (GFI) o Enclosure 2A – Installation Administrative Record Spreadsheets o Enclosure 2B – Additional Site GFI Files and Spreadsheets o Enclosure 2C – Site Added Considerations Summaries

The intent of the ORC initiative is to advance site cleanup during the Period of Performance

(POP) in the most efficient and cost-effective manner as supported by a cost benefit analysis and exit strategy that achieves the greatest reduction in life-cycle cost (LCC). The AF is interested in http://www.globalsecurity.org/military/facility/seymour_johnson.htm http://www.globalsecurity.org/military/facility/seymour_johnson.htm substantial reduction of long-term environmental liabilities and total LCC. However, costs should be commensurate with the level of effort required to achieve each PO and all potential technical contingencies within reason. Technical approaches that are simply reduced to a minimal level of effort with no well-planned contingencies provide no insurance to the

Government that the POs will be achieved without work stoppages or change orders which is not in keeping with the intent of this performance based contracting effort. The AF is required to implement remedies as necessary to enable the mission, protect human health and the environment, and comply with laws and regulations. The goal of the ORC initiative is to ensure the AF continues to fulfill all facets of its Environmental Restoration Program (ERP) mission, by effectively and efficiently managing the program in a performance-based, results-oriented, and cost-conscious framework.

The AF desires that all sites be cleaned up to standards that allow for the current or reasonably anticipated future land use of the property. Accurate documentation and reporting of contaminant removal and cost savings are critical adjuncts to optimization success. In keeping with Defense Environmental Restoration Program (DERP) and Air Force Instruction (AFI) 32-

7020, the AF defines optimization under the ORC as: the reduction of contaminant mass and concentrations, reduction in LCC, or any combination of activities leading to acceleration of

Response Complete (RC)/Site Closeout (SC) as a result of remedial implementation the

Contractor undertakes, above and beyond what is required to maintain compliance in accordance with an approved Decision Document (DD).

The Contractor shall maintain compliance with all DDs/Records of Decision (RODs)/Proposed

Plans/RCRA Permits that are currently in place until no longer required, or an alternate approach is approved. The contractor shall conduct DD/ROD amendments or Explanation of Significant

Differences (ESD) as required to implement new approach(es).

The Contractor shall function as an integral team member in support of the Air Force Civil

Engineer Center (AFCEC) mission to include the sharing of information with USACE, other

AFCEC Contractors, and AF personnel, in cooperation with community stakeholders, regulators, and other Government entities.

Requirements for efficient management of this contract include, but are not limited to, the achievement of the POs in the Performance Period (PP) per Table 1 and work described in

Section 1.3.2 of this PWS, and timely identification and solution of impediments to successful project execution. The Contractor shall provide all personnel, equipment, supplies, tools, materials, and other items necessary to perform the tasks defined in this PWS. The Contractor is solely responsible for reviewing all available information and forming their independent, professional conclusions/interpretations of site conditions and requirements to achieve the POs of this contract within PP specified for each site. AFCEC will rely on the Contractor’s expertise in recognizing and addressing problematic issues during the execution of this contract. The

Contractor shall perform all work in accordance with federal, state, and local statutes and regulations. The Contractor shall also comply with installation regulations. Remedies shall conform to environmental permits, DD requirements, or other legal requirements. The

Contractor shall continue work throughout the entire duration of the POP. The Contractor’s local office presence will be relied upon to provide rapid-response actions for field activities and on-site meetings.

Site specific POs are identified in Section 1.3.1 Table 1: Performance Table and in Section 1.3.2.

POs that are in keeping with standard DERP milestones are defined in Enclosure 1. In addition, for certain categories of sites, the AF has set POs based on current site conditions and consistency with the POP of the contract and ORC goal.

1.2.1 Scope Discussion and Limits

The scope of this contract is to perform environmental restoration services for the sites listed in

Table 1 and Section 1.3.2. The ORC Contractor shall assume contractual liability and responsibility for achieving the POs. If the selected technical approach is not working, as demonstrated by the trends in the performance model, the Contractor shall develop and implement a revised technical approach to achieve the POs, including DD amendments, if required, to implement the remedial approach. This scope includes all known contaminants linked to the specific sites (includes contaminants on, under, or sourced at/migrating from the specific sites) without regard to quantity (e.g., plume size, concentrations). The AF remains statutorily responsible for all sites listed in Table 1 and work described in Section 1.3.2. The

Contractor shall perform all work in accordance with federal, state, and local statutes and regulations, as well as installation regulations, and is responsible for obtaining certifications and licenses required to complete all aspects of this project.

1.2.2 Preliminary Assessment/Site Inspection, Remedial Investigation or Remedial

Investigation/Feasibility Study (including Supplemental Investigations), and

Decision Document

Table 1 of the PWS identifies Preliminary Assessment/Site Inspection (PA/SI), Remedial

Investigation (RI) or RI/Feasibility Study (FS) (including Supplemental Investigations, and DDs as the PO for selected sites. The Contractor is responsible for achieving these POs as identified in Table 1 and work described in Section 1.3.2. See PO definitions in Enclosure 1, Acronyms and Definitions.

1.2.3 Response Complete or Site Closeout

Table 1 of the PWS identifies RC or SC as PO for selected sites. The Contractor is responsible for achieving these objectives as identified in Table 1 and work described in Section 1.3.2. See

PO definitions in Enclosure 1, Acronyms and Definitions. The performance components are described in Section 8.1.3.

1.2.4 Remedial Action-Operation with Optimization

Table 1 of the PWS identifies the following POs utilizing with optimization as follows: 1.

Remedy in Place (RIP) and Remedial Action-Operation (RA-O) with Optimization, 2. DD

Amendment (or Explanation of Significant Differences [ESD]) with Remedy Implementation and RA-O with Optimization, or 3. RA-O with Optimization as POs for selected sites in accordance with the optimization initiative. The Contractor is responsible for achieving these

POs as identified in Table 1 and work described in Section 1.3.2. See PO definitions in

Enclosure 1, Acronyms and Definitions. The optimization and performance components are described in Section 8.1.3.

1.2.5 Remedial Action-Operation and Reduce Life Cycle Cost; Long Term Management and Reduce Life Cycle Cost

Table 1 of the PWS identifies RA-O and Reduce LCC or Long-Term Management (LTM) and

Reduce LCC as the PO for selected sites. The goal of these POs is to minimize future AF liability and cost to the greatest degree feasible. Reduce LCC sites have achieved RIP or RC, have remedies that are effective (source control, risk mitigation, and plume stability), and have the potential for LCC reduction by optimizing some component of the existing remedy, by, for example:

• Reducing sampling frequency

• Reducing system operations

• Reducing number of wells sampled per event

• Reducing number of analytes per sampling event

The Contractor shall achieve the following objectives for each Reduce LCC site:

• Maintain compliance with all DDs and permits (currently in place or to be approved) throughout the POP.

• For RA-O sites, develop performance models addressing all Contaminants of Concern

(COCs) and breakdown products. Refer to Section 8.1.3.1, Performance Models.

• Deliver a Reduce LCC Plan, as a stand-alone plan or in the Project Management Plan

(PMP), that identifies opportunities to improve cost efficiency of RA-O or LTM activities, and the planned approach for implementation. The Reduce LCC Plan shall:

o Provide a basis for proposed reductions in LCC throughout the POP compared to the cost of status-quo RA-O activities (those required to maintain compliance).

The planned reduction can be illustrated using a line graph (current, planned, achieved) or verbiage describing the current and planned reductions.

o Document risk and mitigation strategies for implementing optimization activities to reduce LCC.

• Update or revise site-specific work plans, monitoring plans, and/or DDs, as appropriate.

• Deliver Reduce LCC Reports to document progress in achieving the planned reductions when those reductions are achieved. Reduce LCC Reports may be combined with monitoring reports. Reductions in required RA-O activities are contingent upon regulatory approval.

• Deliver an RA-O & Reduce LCC Summary and Forecasting Report two years prior to the

POP end date. The Reduce LCC Summary and Forecasting Report shall:

o Document optimization activities to date and forecast remaining activities and assumptions to further reduce LCC 10 years post-POP.

Provide a realistic projection to achieve SC or RC after the POP (the Contractor shall identify which PO is the optimal endpoint). See PO definitions in Enclosure 1, Acronyms and

Definitions.

1.2.6 Remedial Action-Operation or Long-Term Management (as appropriate)

Table 1 of the PWS identifies RA-O or LTM in accordance with the approved DD/ROD as the

PO for selected sites. The Contractor shall achieve the following objectives for each RA-O and

LTM site:

• Maintain compliance with all DDs and permits (currently in place or to be approved) throughout the PP. Update or revise site-specific work plans, monitoring plans, and/or

DDs, as appropriate.

• For RA-O sites, develop performance models addressing all COCs and breakdown products. Refer to Section 8.1.3.1, Performance Models.

• Provide a realistic projection to achieve SC or RC after the POP (the Contractor shall identify which PO is the optimal endpoint).

1.2.7 Alternate Objectives

This section and the subparagraphs below describe the Alternate Objective Sites and a general overview of the work associated with these sites. Please see Table 1 and work described in

Section 1.3.2 for specific elements of work required for each site with an Alternate Objective

PO. These sites have complex attributes that have, to date, inhibited progress towards the achievement of RC. For Alternate Objective sites, as for all sites in Table 1 of the PWS where applicable, the Contractor shall maintain compliance throughout the POP of the contract with all existing regulatory requirements including but not limited to regulations, FFAs, RCRA Permits, final or interim RODs, or other equivalent remedial DDs. The Contractor is responsible for implementing changes to the monitoring program based on activities conducted in the Advanced

Site Characterization (PWS Section 1.2.7.1) including the addition and decommissioning of wells in the monitoring well network as agreed by all parties and the addition of new delineation monitoring where new information indicates our understanding of the plumes is changed.

Based on technical review of existing site conditions/activities, the AF placed sites in the category of Alternate Objective if one or more of the following conditions exist:

1. Achieving RC is expected to require substantially longer than 30 years.

2. Achieving RC is unattainable with standard characterization and/or existing remediation technology due to technical or other limitations related to site conditions.

3. Achieving RC is anticipated to require advanced site characterization technologies to improve the Conceptual Site Model (CSM), determine appropriate remedial technology, and/or characterize recently regulated contaminants.

The AF will use data and information obtained during execution of this PWS to determine restoration potential and future investment strategies at Alternate Objective sites. Each Sub-

CLIN for the Alternate Objective sites will only be awarded if the activities are needed to determine the future investment strategy for the site. The decision to award each Sub-CLIN resides solely at the discretion of the AF.

For each Alternate Objective site, a summary of site-specific considerations is provided as GFI.

As with all GFI provided, this GFI is provided for informational purposes only; the Contractor remains responsible for developing their own independent, professional conclusions/interpretation of site conditions and requirements to achieve the PO. The Contractor shall conduct project scoping sessions before work plan development and throughout the planning and execution of the project to meet the PO including the Installation Point(s) of

Contact (POC[s]), the AFCEC Program Manager (PM) and Remedial Project Manager (RPM), the AF technical support team, and the USACE Contracting Officer’s Representative (COR).

Upon approval by the AF and the USACE COR, the Contractor shall participate in scoping sessions with the regulators, as appropriate.

1.2.7.1 Advanced Site Characterization

Based on existing data, the AF has determined that the existing remedial approaches at the

Alternative Objective sites are not achieving satisfactory remedial progress towards their intended goals. In order for the AF to determine the best path forward for these sites, the

Contractor shall conduct Advanced Site Characterization to collect data to update and refine the

CSM in order to achieve the following goals: (1) Fill data gaps; and (2) Collect data needed to:

(A) Determine why existing and previous remedial actions are not effective at achieving remedial progress; (B) Determine appropriate remedial technology(ies) based on site conditions;

C) Develop remediation design parameters for recommended technology(ies); and D) Determine extent and concentrations of recently regulated contaminants, if required.

Advanced Site Characterization includes one or more of the following three activities: (1)

Supplemental Site Investigation (SSI), (2) Revised CSM, and (3) Groundwater Monitoring

Program Update.

1.2.7.1.1 Supplemental Site Investigation

The Contractor shall conduct an SSI to collect data necessary to improve the CSM, determine appropriate remedial technology, support remediation design and construction, and/or characterize recently regulated contaminants. The Contractor shall implement advanced characterization methods, both established approaches and state-of-science techniques consistent with AF, regulatory, Interstate Technology and Regulatory Council (ITRC), and Strategic

Environmental Research and Development Program/Environmental Security Technology

Certification Program (SERDP/ESTCP) guidance to attain these objectives. Data collection includes better definition of the geology, hydrogeology, geochemistry, and/or source(s) and distribution of COCs, as required. The Contractor shall evaluate the need for, and collect the following data where appropriate: (1) Source Zone Delineation; (2) Source Mass/Extent1,2,3; (3)

Vertical and lateral extent of contamination, if not sufficiently defined; (4) Plume Stability4; (5)

Migration pathway, rates, and fluxes in 3-D; (6) Mass distribution; (7) Biogeochemical conditions and influences on contaminant degradation pathways; (8) Impact of recent and historical remedies on site conditions; and (9) Comprehensive Risk including the vapor intrusion pathway.

The SSI report shall document data collection efforts to include a risk evaluation, if appropriate.

The Contractor shall evaluate and provide recommendations regarding whether additional source

1 ITRC. (2015). Integrated DNAPL Site Characterization and Tool Selection.

2 SERDP/ESTCP. (2012). Matrix Diffusion Tool Kit.

3 USEPA. (2009). Evaluating Natural Source Zone Depletion at Sites with LNAPL.

4 USEPA. (2014). High Resolution Site Characterization for Groundwater Short Course, 23rd Annual NARPM

Training Program.

control is needed or whether the plume, or portions of the plume, are amenable to natural attenuation by conducting source strength and plume stability evaluations as needed.

1.2.7.1.2 Conceptual Site Model

The Contractor shall develop a revised CSM in 3-D to include establishing or updating existing fate and transport models based on existing data and data gathered during the SSI. The CSM should cover the source area and the distal plume, to include the lateral and vertical extent of the contaminants in the context of geologic/hydrogeological parameters and the remedial actions conducted to date.

1.2.7.1.3 Groundwater Monitoring Program Update

The Contractor shall evaluate the current horizontal and vertical well distribution to determine if the following can be properly evaluated:

Remedy performance in treatment areas

Hydrogeology, plume geometry, horizontal and vertical plume stability, and matrix diffusion across site

Plume migration through use of perimeter/boundary wells and sentinel wells

Based on the well network evaluation coordinated and approved by the Government and regulators (if required), the Contractor shall optimize the monitoring well network to include adjusting sample collection frequency and the addition of new wells as appropriate. The

Contractor shall update the Basewide or Site-Specific Monitoring Plan or other equivalent document, as appropriate.

1.2.7.2 Remedy Evaluation and Recommendation

Based on all existing data and data gathered during the Advanced Site Characterization, the

Contractor shall evaluate the existing active and/or passive remedy(ies)5,6,7. The Contractor shall provide recommendations to augment, modify, and/or replace the existing remedy8. The evaluation and recommendations will include a cost-benefit analysis and evaluation of the usability, expandability, and/or discontinued use of any existing infrastructure. All remedy recommendations must include a performance model addressing all COCs and breakdown products. Refer to Section 8.1.3.1, Performance Models.

Where necessary to evaluate the proposed technology, the Contractor shall conduct pilot scale technology demonstrations. The Contractor shall identify appropriate remedial technologies and target zones, design/plan, conduct, and evaluate the pilot and/or field scale technology consistent with AF, regulatory, and ITRC guidance. The Contractor shall determine performance monitoring criteria and identify a control sub-site (current state) for comparison and to evaluate results.

In some instances, achievement of RC may not be feasible with currently available technologies within a reasonable timeframe. If this is the case, Contractor shall develop and evaluate alternatives for site management that will be protective of human health and the environment. If

5 USEPA. (2010). Best Management Practices.

6 USEPA. (2014). Groundwater Remedy Completion Strategy.

7 ITRC. (2006). Performance-Based Management.

8 ITRC. (2010). Use and Measurement of Mass Flux and Mass Discharge.

this recommendation is made, it must include the rationale, recommended target when active remediation can cease, and a strategy for obtaining regulatory approval.

1.2.7.2.1 Cost/Benefit Analysis

The Contractor shall provide a cost/benefit analysis for proposed alternatives. Alternatives may include optimizing the remedy in the DD or other remedies with the potential for better performance. All alternatives identified should be evaluated against one another to determine which alternative can achieve RC in the shortest time and has the lowest overall LCC. The cost/benefit analysis 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 LCC of each alternative evaluated.

• Any risk inherent in implementing the alternative optimized remedy.

• A summary comparison of the LCC and risk of each alternative in a cost/benefit analysis that clearly states the recommended alternative.

1.2.7.3 Decision Document Amendment

Based on the results of the remedy evaluation and recommendation, it may be necessary to amend the Decision Document to augment, modify, and/or replace the existing remedy. If warranted, the Contractor shall update the Decision Document.

1.3 Performance Requirements

1.3.1 Table 1: Performance Table

Table 1 presents the POs, PPs, and Performance Standards associated with all installations/sites under this ORC. The PP specified in Table 1 starts from the Obligation Date of the first Sub-

Contract Line Item Number (CLIN) for the site unless otherwise specified. All approvals (both

Government and regulator) per the Performance Standard are required in writing. Additional scope discussion and limits can be found in Section 1.3.2.

Table 1: Performance Table Site Performance Objective Performance Period Performance Standard

N/A Project Management Plan (PMP):

1) Draft PMP

2) Final PMP

3) Updates as necessary

Draft PMP within 90 calendar days from contract award, Final

PMP within 21 calendar days of receipt of AF/ USACE comments on the draft. Update as necessary throughout the POP, AF/USACE will determine when whole document PMP updates are warranted

AF and USACE approval of

PMP.

The PMP should be maintained with accuracy and completeness based on the current technical approach for each site, management structure, etc.

N/A Integrated Master Schedule

(IMS)/Milestone Payment Schedule

(MPS)

Draft IMS/MPS within 90 calendar days from contract award, Final

IMS/MPS within 21 calendar days of receipt of AF and

USACE comments on the draft, and updates monthly throughout the POP

IMS/MPS.

N/A Basewide Quality Program Plans (QPP) for each Installation

Draft Basewide QPP within 60 calendar days from award and update as necessary throughout the POP

AF and USACE and

Regulatory approval of

Basewide QPP.

Joint Base Charleston-Air

All Open Sites

(IRP, MMRP,

PFAS, etc.)

Community Involvement Plan (CIP) for each Installation and associated

Geographically Separate Units (GSUs)*

One (1) year AF and USACE approval of

CIP.

DD540

(AOC P)

Underground

Fuel Line

Leak

RA-O with Optimization in accordance with the approved Statement of Basis and

RCRA Permit

Through the duration of the POP

AF, USACE, and Regulatory approval of RA-O documentation (e.g., Quarterly/Annual

Groundwater and Surface

Water Monitoring Reports, Corrective Measures

Implementation Progress

Reports, etc.)

FT003

(SWMU 55)

Fire Training

Area No. 3

RA-O in accordance with the approved

Statement of Basis, RCRA Permit and

Reduce LCC

LTM in accordance with the approved

Statement of Basis and RCRA Permit

Through the duration of the POP

Through the duration of the POP

AF, USACE, and Regulatory approval of RA-O documentation (e.g., Annual

Groundwater and Surface

Water Monitoring Reports, Corrective Measures

Implementation Progress

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

Reports).

LF002

(SWMU 69)

Landfill No. 4

LTM in accordance with the approved

Statement of Basis and RCRA Permit

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual approval of Groundwater

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

Groundwater Monitoring

LF004

(SWMU 66)

Landfill No. 1

LTM in accordance with the approved

Statement of Basis and RCRA Permit

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

LF006

(SWMU 68)

Landfill No. 3

LTM in accordance with the approved

Statement of Basis and RCRA Permit

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

LF017

(SWMU 67)

Landfill No. 2

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual approval of Groundwater and

Surface Water Monitoring documentation (e.g., Annual

Corrective Measures

Implementation Progress

Reports, Annual Groundwater

Monitoring Reports, etc.)

OT011

(SWMU 60)

Hardfill Area

No. 3

LTM in accordance with the approved

Statement of Basis and RCRA Permit

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

OT012

(SWMU 58)

Hardfill Area

No. 1

LTM in accordance with the approved

Statement of Basis and RCRA Permit

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

OT016

(SWMU 137)

Zone 2

Entomology

Shop

Response Complete (RC)

Continue Long Term Management (LTM) in accordance with the Statement of Basis and RCRA Permit

Ten (10) years AF, USACE, and Regulatory approval of RC documentation (e.g., Regulator approval of, and

Air Force signature on, Final

Remedial Action Completion

Report).

documentation (e.g., Land

Use Control Inspection

Reports, Annual Corrective

Measures Implementation

Progress Report).

RW532

(SWMU 118)

Bldg. 371

Wash rack and RCRA Permit

Five (5) years AF, USACE, and Regulatory approval of RC documentation (e.g., Regulator approval of, and

Air Force signature on, Final documentation (e.g., Land

Use Control Inspection

Reports and Groundwater

Monitoring documentation, e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

SS042

(SWMU 149)

Zone 4 TCE -

Bldg. 543 –

Bldg. 532

RA-O in accordance with the approved

Statement of Basis and RCRA Permit

FY25 – FY33 AF, USACE, and Regulatory approval of Groundwater and

Surface Water Monitoring documentation (e.g., Corrective Measures

Implementation Progress

SS042

(SWMU 149)

Zone 4 TCE -

Bldg. 543 –

Bldg. 532

Alternate Objectives:

1) Advanced Site Characterization

(Supplemental Site Investigation

(SSI), Revised Conceptual Site

Model (CSM), and Recommended

Monitoring Program Update)

2) Remedy Evaluation and

Recommendation (including results of any pilot study)

3) Decision Document Amendment

Eight (8) years AF, USACE, and Regulatory approval of SSI Report, revised CSM and Basewide

Monitoring Plan.

the remedy evaluation and recommended proposed remedial strategy including successful demonstration of the existing or alternate remedy (e.g., through pilot or field test) showing decreasing trends in COCs.

approval of Permit

Modifications or Stmt. Of

Basis Amendments (i.e., Air

Force, and Regulatory signatures on new Final

Permits or new Decision

Documents.)

ST027

(SWMU 145)

Bldg. 575

JP-4 Leak

Site Closeout (SC) Seven (7) years AF, USACE, and Regulatory approval of SC documentation (e.g., Site

Closeout Report and Well

Abandonment Confirmation

TS837

(AOC X)

Skeet Range 2 and RCRA Permit

Five (5) years AF, USACE, and Regulatory approval of RC documentation (e.g., Regulator approval of, and

Air Force signature on, Final documentation (e.g., Land

Use Control Inspection

TU542

(AOC V)

Shoppette

Site Closeout (SC) Ten (10) years AF, USACE, and Regulatory approval of SC documentation (e.g., Site

Closeout Report and Well

TU543

(SWMU 108)

Bldg. 58

Abandoned

Diesel Tank

Site Closeout (SC) Seven (7) years AF, USACE, and Regulatory approval of SC documentation (e.g., Site

Closeout Report and Well

Abandonment Confirmation

TU544

(AOC T)

Bldg. 129

UST

Site Closeout (SC) Seven (7) years AF, USACE, and Regulatory approval of SC documentation (e.g., Site

Closeout Report and Well

Joint Base Charleston-Weapons

PFAS, etc.)

Community Involvement Plan (CIP) for

Geographically Separate Units (GSUs)*

One (1) year AF and USACE approval of

AB062

(SWMU 62)

South Annex, Landfill 1st &

A-B Avenue

LTM in accordance with the approved

Statement of Basis and RCRA Permit

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

CG074

(SWMU 74)

South Annex

Boiler Slag

Pile

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

CS023

(SWMU 23)

Old South

Annex

Sanitary

Landfill

Injections to address concentration rebound (Option)

FY25 – FY33 AF, USACE, and Regulatory documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

DA017

(SWMU 17)

Old Southside

Missile &

Waste Oil

Disposal

RA-O in accordance with the approved

FY25 – FY33 AF, USACE, and Regulatory approval of RA-O documentation (e.g., Semi-

Annual Corrective Measures

Implementation Progress

Reports, Annual Groundwater

Monitoring Reports, Land

Use Control Inspection

DA017

(SWMU 17)

Missile &

Waste Oil

Disposal

Alternate Objectives:

1) Advanced Site Characterization

(Supplemental Site Investigation

(SSI), Revised Conceptual Site

Model (CSM), and Recommended

Monitoring Program Update)

2) Remedy Evaluation and

Recommendation (including results recommended proposed remedial strategy including successful demonstration of the existing or alternate remedy (e.g., through pilot or

Modifications or Stmt. Of

Basis Amendments (i.e., Air

Force, and Regulatory signatures on new Final

DA951

(AOC Q)

Eastside

Ordnance

Area 1

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

ED17178B

(SWMU 81)

Southside

EOD Storage

Area

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

FL066

Bldg. 3221 –

Old

Entomology

FY25 – FY33 AF, USACE, and Regulatory approval of RA-O documentation (Corrective

Measures Implementation

Progress Reports, Annual

Groundwater Monitoring

FL066

Bldg. 3221 –

Old

Entomology

(Supplemental Site Investigation

(SSI), Revised Conceptual Site

Model (CSM), and Recommended

Monitoring Program Update)

2) Remedy Evaluation and

Recommendation (including results recommended proposed remedial strategy including successful demonstration of the existing or alternate remedy (e.g., through pilot or

Modifications or Stmt. Of

Basis Amendments (i.e., Air

Force, and Regulatory signatures on new Final

FL073

(SWMU 73)

Bldg. 3440

Battery Shop and RCRA Permit

Five (5) years AF, USACE, and Regulatory approval of RC documentation (e.g., Regulator approval of, and

Air Force signature on, Final documentation (e.g., Land

ID068

(SWMU 68)

Bldg. 3637 and RCRA Permit

Five (5) years AF, USACE, and Regulatory approval of RC documentation (e.g., Regulator approval of, and

Air Force signature on, Final documentation (e.g., Land

LF003

(SWMU 3)

Old Northside

Landfill

Injections to address concentration rebound (Option) documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

LF010

(SWMU 10)

Bldg. 930

Area Former

Waste OTTO

Fuel S

LTM in accordance with the approved

Statement of Basis and RCRA Permit

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

LF016

(SWMU 16)

Landfill

LTM in accordance with the approved

Statement of Basis and RCRA Permit

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

MU17175A

(SWMU 79)

Marsh

Dumping Area

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

SA036

(SWMU 36)

Hazardous

Waste Storage and RCRA Permit

Eight (8) years AF, USACE, and Regulatory approval of RC documentation (e.g., Regulator approval of, and

Air Force signature on, Final documentation (e.g., Land

SS012

(SWMU 12)

Former

Bldg. 88

FY25 – FY33 AF, USACE, and Regulatory approval of RA-O documentation (e.g., Corrective Measures

Implementation Progress

SS012

(SWMU 12)

Former

Bldg. 88

(Supplemental Site Investigation

(SSI), Revised Conceptual Site

Model (CSM), and Recommended

Monitoring Program Update)

2) Remedy Evaluation and

Recommendation (including results recommended proposed remedial strategy including successful demonstration of the existing or alternate remedy (e.g., through pilot or

Modifications or Stmt. Of

Basis Amendments (i.e., Air

Force, and Regulatory signatures on new Final

ST042

(AOC G)

WW

Treatment

Facility

RA-O in accordance with the approved

Statement of Basis and RCRA Permit

FY25 – FY33 AF, USACE, and Regulatory approval of RA-O documentation (e.g., Corrective Measures

Implementation Progress

ST042

(AOC G)

WW

Treatment

Facility

Alternate Objectives:

1) Advanced Site Characterization

(Supplemental Site Investigation

(SSI), Revised Conceptual Site

Model (CSM), and Recommended

Monitoring Program Update)

2) Remedy Evaluation and

Recommendation (including results recommended proposed remedial strategy including successful demonstration of the existing or alternate remedy (e.g., through pilot or

Modifications or Stmt. Of

Basis Amendments (i.e., Air

Force, and Regulatory signatures on new Final

TU014

(SWMU 14)

Bldg. 58

Former Waste

OTTO

LTM in accordance with the approved

Statement of Basis and RCRA Permit

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

TU927

(TU/US-C10)

AOC B-2

Bldg. 1025

Site Closeout (SC)

Five (5) years AF, USACE, and Regulatory documentation (e.g., Site

Closeout Report and Well

TU933

(TU/US-506)

Bldg. 724

LTM in accordance with the approved

Statement of Basis and RCRA Permit

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

TU939

(TU/US-501)

AOC B-3

Old Bldg. 7

Five (5) years AF, USACE, and Regulatory documentation (e.g., Site

Closeout Report and Well

Abandonment Confirmation

XE001

(SWMU 82)

Northside Old

Grenade

Range

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

XE002

(AOC N)

Munitions

Disposal Area

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

XE003

(SWMU 22)

Annex

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

XE004

(AOC-O)

Dredge Spoil

Area

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

XE005

(SWMU 25)

Annex

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

XE006

(SWMU 20)

Annex

Wash Area

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

XE007

(AOC-L)

Borrow Pit

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

XU018

(SWMU 18)

Open Burn

Open

Detonation

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

ZZ075

(SWMU 75)

Mustard Gas

Barges

FY25 – FY33 AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

North Auxiliary Airfield

DA100-2

(LF100)

Debris Area 2 in accordance with the Decision

Document

Ten (10) years AF, USACE, and Regulatory approval of RC documentation (e.g., Regulator approval of, and

Air Force signature on, Final documentation (e.g., Land

DA100-4

(LF100)

Debris Area 4

Document

Ten (10) years AF, USACE, and Regulatory approval of RC documentation (e.g., Regulator approval of, and

Air Force signature on, Final documentation (e.g., Land

Use Control Inspection

TA001

POL Tank

Storage Area

Document

Five (5) years AF, USACE, and Regulatory approval of SC documentation (e.g., Site

Closeout Report and Well

Seymour Johnson AFB

PFAS, etc.)

Community Involvement Plan (CIP) for

Geographically Separate Units (GSUs)*

One (1) year AF and USACE approval of

FT007

Fire Training

Area No.3

LTM in accordance with the approved

Statement of Basis, RCRA Permit and

Reduce LCC

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

Reports, Reduce LLC

Summary Report, etc.).

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

LF006

Landfill No. 4

Statement of Basis and RCRA Permit

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

LF008

Landfill No. 1

Statement of Basis and RCRA Permit

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

LF015

Landfill No. 2

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

LF016

Landfill No. 3

Statement of Basis and RCRA Permit

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

OT029

Radar Tower

Site

LTM in accordance with the approved

Statement of Basis, RCRA Permit and

Reduce LCC

Through the duration of the POP

AF, USACE, and Regulatory approval of LTM documentation (e.g., Annual

Land Use Control Inspection

Reports, Reduce LLC

Summary Report, etc.).

Monitoring documentation

(e.g., Annual Corrective

Measures Implementation

Progress Reports, Annual

RW502

SWMU 55/76

Site Closeout

Ten (10) years documentation (e.g., Site

Closeout Report and Well

SA501

SWMU

86/87/AOC A

and RCRA Permit

Seven (7) years AF, USACE, and Regulatory approval of RC documentation (e.g., Regulator approval of, and

Air Force signature on, Final documentation (e.g., Land

SS009

Site 7 Haz.

Waste and RCRA Permit

Seven (7) years AF, USACE, and Regulatory…