[3008(H) Order]

Scope of Work

Corrective Measure Implementation

1. Purpose

The purpose of this Corrective Measure Implementation (CMI) program is to design, construct, operate, maintain, and monitor the performance of the corrective measure or measures selected to protect human health and the environment. Respondents will furnish all personnel, materials and services necessary for the implementation of the corrective measure or measures.

2. Scope

The Corrective Measure Implementation program consists of four tasks:

1. Task XI: Corrective Measure Implementation Program Plan

1. Program Management Plan

2. Community Relations Plan

2. Task XII: Corrective Measure Design

1. Design Plans and Specifications

2. Operation and Maintenance Plan

3. Cost Estimate

4. Project Schedule

5. Construction Quality Assurance Objectives

6. Health and Safety Plan

7. Design Phases

3. Task XIII: Corrective Measure Construction

1. Responsibility and Authority

2. Inspection Activities

3. Monitoring or Testing Requirements

4. Documentation

4. Task XIV: Reports

   1. Progress Reports

   2. Draft Reports

   3. Final Reports

B.1. Task XI: Corrective Measure Implementation Program Plan

The Respondent shall submit a Final Corrective Measures Implementation Program Plan as described below and in accordance with Section VI.4 of the Order. The CMI Program Plan shall include, but not be limited to, the following elements:

A. Program Management Plan

The Respondent shall prepare a Program Management Plan which will document the overall management strategy for performing the design, construction, operation, maintenance and monitoring of corrective measure(s). The Plan shall document the responsibility and authority of all organizations and key personnel involved with the implementation. The Plan will also include a description of qualifications of key personnel directing the Corrective Measure Implementation Program, including contractor personnel. The Plan shall include a schedule(s) for completion of Task XII.

B. Community Relations Plan

The Respondent shall revise the Community Relations Plan as necessary to address the information needs of the community during design and construction activities.

1. Specific activities which must be conducted during the design stage are the following:

1. Revise the Facility Community Relations Plan to reflect knowledge of citizen concerns and involvement at this stage of the process; and

2. Prepare and distribute a public notice and an updated fact sheet at the completion of engineering design.

2. Depending on citizen interest at a Facility at this point in the corrective action process, community relations activities could range from group meetings to fact sheets on the technical status.

B.2. Task XII: Corrective Measure Design

The Respondent shall prepare a Final Corrective Measure Design (CMD) Report that addresses the requirements necessary to implement the selected corrective measure(s) at the Facility, as defined in the Corrective Measure Study. The CMD Report shall include, but not be limited to, the following elements:

A. Design Plans and Specifications

The Respondent shall develop clear and comprehensive design plans and specifications, which include but are not limited to the following:

1. Discussion of the design strategy and the design basis, including:

1. Compliance with all applicable or relevant environmental and public health standards; and

2. Minimization of environmental and public impacts.

2. Discussion of the technical factors of importance including:

1. Use of currently accepted environmental control measures and technology;

2. The constructability of the design; and

3. Use of currently acceptable construction practices and techniques.

3. Description of assumptions made and detailed justification of these assumptions.

4. Discussion of the possible sources of error and references to possible operation and maintenance problems.

5. Detailed drawings of the proposed design including:

1. Qualitative flow sheets; and

2. Quantitative flow sheets.

6. Tables listing equipment and specifications.

7. Tables giving material and energy balances.

8. Appendices including:

1. Sample calculations (one example presented and explained clearly for significant or unique design calculations);

2. Derivation of equations essential to understanding the CMD Report; and

3. Results of laboratory and/or field tests.

B. Operation and Maintenance Plan

The Respondent shall prepare an Operation and Maintenance Plan to cover both implementation and long term maintenance of the corrective measure(s). The Plan shall be composed of, but not be limited to, the following elements:

1. Description of normal operation and maintenance (O&M) requirements:

1. Description of tasks for operation;

2. Description of tasks for maintenance;

3. Description of prescribed treatment or operation conditions; and

4. Schedule showing frequency of each O&M task.

2. Description of potential operating problems:

1. Description and analysis of potential operation problems;

2. Sources of information regarding problems; and

3. Common and/or anticipated remedies.

3. Description of routine monitoring and laboratory testing:

1. Description of monitoring tasks;

2. Description of required laboratory tests and basic interpretation of data;

3. Required QA/QC; and

4. Schedule of monitoring frequency and date, if appropriate, when monitoring may cease.

4. Description of alternate O&M:

1. Should systems fail, alternate procedures to prevent undue hazard; and

2. Analysis of vulnerability and additional resource requirements should a failure occur.

5. Safety plan:

1. Description of precautions, of necessary equipment, etc., for site personnel; and

2. Safety tasks required in event of system failure.

6. > Description of equipment:

1. Equipment identification;

2. Installation of monitoring components;

3. Maintenance of site equipment; and

4. Replacement schedule for equipment and installed components.

7. Records and reporting mechanisms required:

1. Daily operating logs, as appropriate;

2. Laboratory records;

3. Records for operating costs;

4. Mechanism for reporting emergencies;

5. Personnel and maintenance records; and

6. Quarterly reports to State agencies.

An initial Operation and Maintenance Plan shall be submitted with the Draft CMD Report and the Final Operation and Maintenance Plan with the Final as-built Design Documents.

C. Cost Estimate

The Respondent shall develop cost estimates for the purpose of assuring that the Facility has the financial resources necessary to construct and implement the corrective measure(s). The cost estimate developed in the Corrective Measure Study shall be refined to reflect the more detailed and/or accurate design plans and specifications being developed. The cost estimate shall include both capital and operation and maintenance costs. An initial Cost Estimate shall be submitted simultaneously with the Draft CMD Report and the Final Cost Estimate with the Final Design Documents.

D. Project Schedule

The Respondent shall develop a detailed Project Schedule for construction and implementation of the corrective measure(s) (i.e. Task XIII), which identifies timing for initiation and completion of all critical path tasks. The Respondent shall specifically identify dates for completion of the project and major interim milestones which shall be enforceable terms of this Order. An initial Project Schedule shall be submitted simultaneously with the Draft CMD Report and the Final Project schedule with the Final Design Document.

E. Construction Quality Assurance Objectives

The Respondent shall identify and document the objectives and framework for the development of a construction quality assurance program including, but not limited to the following: responsibility and authority; personnel qualifications; inspection activities; sampling requirements; and documentation.

F. Health and Safety Plan

The Respondent shall modify the Health and Safety Plan developed for the RCRA Facility Investigation to address the activities to be performed at the Facility to implement the corrective measure(s).

G. Design Phases

The design of the corrective measure(s) should include, but not be limited to, the phases outlined below.

1. Correlating plans and specifications

General correlation between drawings and technical specifications, is a basic requirement of any set of working construction plans and specifications. Before submitting the project specifications, Respondent shall:

1. Coordinate and cross-check the specifications and drawings; and

2. Complete the proofing of the edited specifications and required cross-checking of all drawings and specifications.

These activities shall be completed prior to the 95% Pre-Final Design submittal to the Agency.

2. Equipment start-up and operator training

The Respondent shall prepare, and include in the technical specifications governing treatment systems, contractor requirements for providing the following elements: (1) appropriate service visits by experienced personnel to supervise the installation, adjustment, startup and initial operation of the treatment systems; and (2) training covering appropriate operational procedures once the startup has been successfully accomplished.

3. Additional Studies

Corrective Measure Implementation may require Additional Studies to supplement the available technical data. At the direction of the Agency for any such studies required, the Respondent shall furnish all services, including field work as required, materials, supplies, plant, labor, equipment, investigations, studies and superintendence. Sufficient sampling, testing and analysis shall be performed to optimize the required treatment and/or disposal operations and systems. There shall be an initial meeting of all principal personnel involved in the development of the program. The purpose will be to discuss objectives, resources, communication channels, role of personnel involved and orientation of the site, etc. The Interim Additional Studies report shall present the results of the testing with the recommended treatment or disposal system (including options). A review conference shall be scheduled after the interim report has been reviewed by all interested parties. The Final Additional Studies Report include all data taken during the testing and a summary of the results of the studies.

4. Pre-Final and Final Design

The Respondent shall submit the Pre-Final and Final Design documents in two parts. The first submission shall be at 95% completion of design (i.e., Pre-Final). After approval of the Pre-Final submission, the Respondent shall execute the required revisions and submit the Final Design documents 100% complete with reproducible drawings and specifications.

The Pre-Final Design submittal shall consists of the Design Plans and Specifications, Operation and Maintenance Plan, Capital and Operating and Maintenance Cost Estimate, Quality Assurance Plan and Specifications for the Health and Safety Plan and Project Schedule.

The Final Design submittal shall consist of the Final Design Plans and Specifications (100% complete), Respondent's Final Construction Cost Estimate, the Final Draft Operation and Maintenance Plan, Final Quality Assurance Plan and Health and Safety specifications. The quality of the design documents should be such that Respondents would be able to include them in a bid package and invite contractors to submit bids for the construction project.

B.3. Task XIII: Corrective Measure Construction

The Respondent shall develop and implement a Construction Quality Assurance (CQA) Plan to ensure, with a reasonable degree of certainty, that a completed corrective measure(s) meets or exceeds all design criteria, plans and specifications. The CQA Plan shall be submitted to EPA for review and approval concurrently with the Pre-Final Design. The CQA Plan is a Facility specific document which must be submitted to EPA for review and approval prior to the start of construction. At a minimum, the CQA Plan should include the elements which are summarized below. Upon EPA approval or modification of the CQA Plan and Final Design, Respondents shall construct and implement the corrective measure(s) in accordance with the approved design, schedule and the CQA Plan.

A. Responsibility and Authority

The responsibility and authority of all organizations (i.e., technical consultants, construction firms, etc.) and key personnel involved in the construction of the corrective measure(s) shall be described fully in the CQA Plan. Respondents must identify a CQA officer and the necessary supporting inspection staff.

B. Inspection Activities

The observations and tests that will be used to monitor the construction and/or installation of the components of the corrective measure(s) shall be summarized in the CQA Plan. The Plan shall include the scope and frequency of each type of inspection. Inspections shall verify compliance with all environmental requirements and include, but not limited to air quality and emissions monitoring records, waste disposal records (e.g., RCRA transportation manifests), etc. The inspection should also ensure compliance with all health and safety procedures. In addition to oversight inspections, the Respondent shall conduct the following activities:

1. Pre-Construction Inspection and Meeting

Respondents shall conduct a Pre-Construction Inspection and Meeting with EPA to:

1. Review methods for documenting and reporting inspection data;

2. Review methods for distributing and storing documents and reports;

3. Review work area security and safety protocol;

4. Discuss any appropriate modifications of the construction quality assurance plan to ensure that site-specific considerations are addressed; and

5. Conduct a site walk-around to verify that the design criteria, plans, and specifications are understood and to review material and equipment storage locations.

The Pre-Construction Inspection and Meeting shall be documented by a designated person and minutes should be transmitted to all parties.

2. Pre-Final Inspection.

Upon preliminary project completion, the Respondent shall notify EPA for the purposes of conducting a Pre-Final Inspection. The Pre-Final Inspection will consist of a walk-through inspection of the entire project site, as appropriate. The Inspection is to determine whether the project is complete and consistent with the contract documents and the EPA approved corrective measure. Any outstanding construction items discovered during the Inspection will be identified and noted. Additionally, treatment equipment will be operationally tested by Respondent. The Respondent will certify that the equipment has performed to meet the purpose and intent of the specifications. Retesting will be completed where deficiencies are revealed. The Pre-Final Inspection Report should outline the outstanding construction items, actions required to resolve items, completion date for these items, and date for Final Inspection.

3. Final Inspection

Upon completion of any outstanding construction items, Respondents shall notify EPA for the purposes of conducting a Final Inspection. The Final Inspection will consist of a walk-through inspection of the project site, as appropriate. The Pre-Final Inspection Report will be used as a checklist with the Final Inspection focusing on the outstanding construction items identified in the Pre-Final Inspection. Confirmation shall be made that outstanding items have been resolved.

C. Sampling Requirements

The sampling activities, sample size, sample locations, frequency of testing, acceptance and rejection criteria, and plans for correcting problems as addressed in the project specifications should be presented in the CQA Plan.

D. Documentation

Reporting requirements for CQA activities shall be described in detail in the CQA Plan. This should include such items as daily summary reports, inspections data sheet, problem identification and corrective measures reports, design acceptance reports, and final documentation. Provisions for the final storage of all records also should be presented in the CQA Plan.

B.4. Task XIV: Reports

The Respondent shall prepare plans, specifications, and reports as set forth in Task XI through Task XIV to document the design, construction, operation, maintenance and monitoring of the corrective measure. The documentation shall include, but not limited to the following:

1. Progress Reports

The Respondent shall at a minimum provide EPA with signed, quarterly progress reports containing:

1. A description and estimate of the percentage of the CMI completed;

2. Summaries of all findings and data;

3. Summaries of all changes made in the CMI during the reporting period;

4. Summaries of all contacts with representative of the local community, public interest groups or State government during the reporting period;

5. Summaries of all problems or potential problems encountered during the reporting period;

6. Actions being taken to rectify problems;

7. Projected work for the next reporting period; and

8. Copies of daily reports, inspection reports, laboratory/monitoring data, etc.

2. Reports

1. Respondent shall submit a Corrective Measure Implementation Program Plan as outlined in Task XI;

2. Respondent shall submit a Corrective Measure Design Report as outlined in Task XII, and in accordance with the EPA approved schedule included in the CMI Program Plan;

3. Respondent shall submit a Construction Quality Assurance Program Plan as outlined in Task XIII and in accordance with the EPA approved schedule included in the CMD Report; and

4. At the "completion" of the construction of the project, Respondent shall submit a Final Corrective Measure Implementation Report to EPA for review and approval. The CMI Report shall document that the project is consistent with the design specifications, and that the corrective measure is performing adequately. The CMI Report shall include, but not be limited to the following elements:

1. Synopsis of the corrective measure(s) and certification of the design and construction;

2. Explanation of any modifications to the plans and why these were necessary for the project;

3. Listing of the criteria, established before the corrective measure was initiated, for judging the functioning of the corrective measure and also explaining any modification to these criteria;

4. Results of Facility monitoring, indicating that the corrective measure(s) will meet or exceed the performance criteria; and

5. Explanation of the operation and maintenance (including monitoring) to be undertaken at the Facility.

The CMI Report should include, but not be limited to, all of the daily inspection summary reports, inspection summary reports, inspection data sheets, problem identification and corrective measure reports, block evaluation reports, photographic reporting data sheets, design engineers' acceptance reports, deviations from designated material specifications (with justifying documentation) and as-built drawings.

3. Final Reports

No later than thirty (30) days after receipt of EPA's comments on the plans and reports included in this Scope of Work, Respondent shall finalize said plans and reports, including: (1) Final CMI Program Plan; (2) Final CMD Report; (3) Final CQA Plan; and (4) Final CMI Report. The final plans and reports shall address all of EPA's comments to the satisfaction of EPA.

3. Facility Submission Summary

A summary of the activities and information reporting requirements contained in the Corrective Measure Implementation Scope of Work is present below: