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PLN-5502 Rev. 1 Contractor Quality Control Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project U.S. Army Corps of Engineers Buffalo District, Buffalo, New York Applicability: Luckey FUSRAP Remediation Effective Date: 06/24/16

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Page 1: Rev. 1 Contractor Quality Control Plan for the Luckey ......Jun 24, 2016  · Final Scope of Work, Remediation of Soils Operable Unit, Luckey Site (USACE 2014) and other supporting

PLN-5502 Rev. 1

Contractor Quality Control Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project

U.S. Army Corps of Engineers Buffalo District, Buffalo, New York

Applicability: Luckey FUSRAP Remediation

Effective Date: 06/24/16

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CONTRACTOR QUALITY CONTROL PLAN LUCKEY FORMERLY UTILIZED SITES REMEDIAL

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History of Revisions

Revision Issue Date Action Description

0 03/21/16 New document Initial issue

1 06/24/16 Revise document Comments from the Buffalo tech editor.

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Table of Contents

1.  INTRODUCTION .............................................................................................................................. 6 

1.1  Project Description and Scope ............................................................................................... 6 

1.2  Quality Objective................................................................................................................... 6 

2.  QUALITY CONTROL ORGANIZATIONAL STRUCTURE .......................................................... 6 

2.1  Quality Control Project Personnel and Responsibilities ........................................................ 7 

2.1.1  Project Manager .................................................................................................. 7 2.1.2  Corporate Quality Control Manager ................................................................... 7 2.1.3  Contractor Quality Control System Manager ...................................................... 8 2.1.4  Site Superintendent ............................................................................................. 8  

3.  THREE-PHASE CONTROL SYSTEM ............................................................................................. 9 

3.1  Preparatory Phase Meeting/Inspection ................................................................................ 10 

3.2  Initial Phase Inspection ........................................................................................................ 10 

3.3  Follow-Up Phase ................................................................................................................. 11 

4.  TESTING REQUIREMENTS .......................................................................................................... 11 

5.  DEFINABLE FEATURES OF WORK ........................................................................................... 14 

5.1  Support Zone Preparation and Mobilization ....................................................................... 14 

5.2  Monitoring ........................................................................................................................... 14 

5.3  Laboratories and Testing ..................................................................................................... 15 

5.4  Storage Area (S1) Area Preparation and Mobilization ........................................................ 15 

5.5  Water Management ............................................................................................................. 15 

5.6  Remediation of Contaminated Waste and Disposition of Clean Soils ................................ 15 

5.7  Waste Handling, Packaging, and Transport ........................................................................ 15 

5.8  Backfill and Site Restoration ............................................................................................... 16 

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5.9  Demobilization .................................................................................................................... 16 

5.10  Construction Completion Report ......................................................................................... 16 

6.  REPORTING AND RECORD KEEPING ....................................................................................... 16 

6.1  Daily Quality Control Reports ............................................................................................. 17 

6.2  Document and Material Submittals ..................................................................................... 18 

6.2.1  Submittal Register ............................................................................................. 18  

6.3  Recordkeeping ..................................................................................................................... 18 

6.4  Document Control ............................................................................................................... 20 

7.  CORRECTIVE ACTIONS ............................................................................................................... 20 

8.  REFERENCES ................................................................................................................................. 21 

APPENDIX A – Resumes of Key Quality Personnel ................................................................................. 23 

APPENDIX B – Letter of Assignment of CQCSM .................................................................................... 35 

Figures

2-1. Quality Control Organizational Structure. .......................................................................................... 7 

Tables

2-1. Responsibilities of the Luckey Team Members. ................................................................................. 9 4-1. Testing Specifications. ...................................................................................................................... 12 

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ACRONYMS

COC constituents of concern

COR contracting officer’s representative

CQCP contractor quality control plan

CQCSM contractor’s quality control site manager

DFW definable feature of work

DQCR Daily Quality Control Report

FUSRAP Formerly Utilized Sites Remedial Action Program

PM project manager

QC quality control

QCM quality control manager

QCS Quality Control System

S1 storage area

USACE United States Army Corps of Engineers

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1. INTRODUCTION

1.1 Project Description and Scope

This contractor quality control plan (CQCP) describes the quality protocols required for remedial activities at the Formerly Utilized Sites Remedial Action Program (FUSRAP) Luckey Soils Remediation Project in Luckey, Wood County, Ohio, to be executed by Portage, Inc., Idaho Falls, Idaho, under United States Army Corps of Engineers (USACE) Indefinite Delivery/Indefinite Quantity Contract W912P4-15-D-0006-0001. The work includes development of work plans, environmental monitoring, excavation, waste characterization, waste packaging, transport and disposal of materials, building demolition, and development and implementation of site closure protocols. The site is contaminated with FUSRAP-related constituents of concern (COCs). The COCs at the site include beryllium, lead, radium-226, thorium-230, uranium-234, and uranium-238.

A more complete description of work activities can be found in the Site Operations Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016a).

1.2 Quality Objective

The goal of this CQCP is to ensure that Portage, Inc., completes all project activities as defined in the project planning documents and procedures and meets all cleanup requirements as delineated in the Record of Decision (ROD) for the Soils Operable Unit, Luckey Site (USACE 2006). Portage will meet this goal by implementing this CQCP to monitor all site activities. Portage will prepare and maintain documentation and field records during and after completion of work activities, so it can demonstrate it has completed work, and performance requirements of the plans meet quality control (QC) protocols. In addition, Portage maintains a rigorous Quality Assurance Program and will follow it throughout this contract.

2. QUALITY CONTROL ORGANIZATIONAL STRUCTURE

This section describes the organizational structure that establishes effective QC of all aspects of this project. The function of the QC organization is to prescribe the duties of QC personnel as outlined in this CQCP. Personnel directly responsible for QC are described below. An organizational chart is presented showing lines of reporting (Figure 2-1). Appendix A presents the resumes of the QC personnel.

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m U.S. Army Corps of Engineers

Contracting Officer Representative

Luckey Program Manager Portage)

Luckey Project Manager ~Portage)

Site Superintendent •••• (Envirocon)

Corporate Quality

~ ~

CQC System Manager

(Portage)

Portage Executive

~ ~

Site Safety & Health officer .,

Figure 2-1. Quality Control Organizational Strncture.

2.1 Quality Control Project Personnel and Responsibilities

2.1.1 Project Manager

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Portage's project manager (PM) shall be responsible for the overall execution of all project activities and for developing and contrnlling the technical approaches and level of effo1i required on each task. The PM is responsible for day-to-day operations at the site and for coordinating interaction and input from suppo1i personnel, USACE, and subcontractors. The PM is responsible for ensuring that work is completed in accordance with the approved work plans and contract specifications, identifying and furnishing all needed resources to execute the work, and ensuring overall technical quality and consistency of project activities and deliverables.

2.1.2 Corporate Quality Control Manager

Po1iage's co1p orate QC manager (QCM) shall be responsible for ensuring that the project team implements the procedures required under the USACE contract and the project work plans. He is responsible for ensuring that coITective action is taken if perfo1mance does not meet internal or USACE standards or quality requirements. The Po1iage QCM shall work closely with the Luckey PM and Po1iage 's QC system manager (CQCSM) to ensure that the established procedures and protocols for this project are implemented and the work is perfo1med in

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accordance with the Final Scope of Work, Remediation of Soils Operable Unit, Luckey Site (USACE 2014) and other supporting project work plans. The QCM may conduct periodic audits as part of the quality control process.

2.1.3 Contractor Quality Control System Manager

The CQCSM shall be responsible for day-to-day compliance with the site operations plan, this CQCP, and all other project plans and procedures. The CQCSM is responsible for maintaining the submittal register. The CQCSM shall provide and maintain an effective QC system for all on-site activities and monitor QC activities to ensure conformance with authorized policies, procedures, contract requirements, approved work plans, and sound work practices, including safety activities. The CQCSM, or his/her designee, shall conduct daily quality checks and shall prepare the Daily Quality Control Report (DQCR) and provide the daily reports to the USACE contracting officer’s representative (COR). The CQCSM will use the USACE Quality Control System (QCS) software to input the DQCR and for input and management of any quality issues.

The CQCSM will be responsible for managing Portage’s use of the QCS system. The CQCSM shall be on-site during all site activities and reports directly to the QCM. The CQCSM shall receive training from USACE in executing the three phases of the quality system. Appendix B is a letter from the QCM assigning the on-site quality control responsibilities to the CQCSM.

2.1.4 Site Superintendent

The site superintendent, is responsible for ensuring that equipment operators and craft personnel are sufficiently trained and qualified to execute assigned tasks and for assessing and reporting field progress to the PM. The site superintendent is responsible for supervising field activities, in-house and subcontract laborers, and coordinating site logistics. The site superintendent shall routinely assess work activities to ensure that tasks are performed in accordance with the requirements detailed in work packages. The site superintendent shall also ensure that equipment is inspected and adequate to meet the specifications of the remediation. The site superintendent shall ensure that all required testing, including quality tests, are performed in a timely manner. Table 2-1 summarizes the responsibilities of each team member described above.

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Table 2-1. Responsibilities of the Luckey Team Members. Title Responsibilities

Project • Stop work for conditions averse to quality or safety . Manager • Direct all project field activities to safely execute work in

accordance with the work scope, schedule, and budget.

• Ensure adherence to approved work plans and all federal, state, and local laws and regulations.

• Ensure work is properly planned with paii icipation from all applicable functional disciplines.

• Ensure hazards and hazard contrnls are identified and communicated to all affected individuals.

• Identify project resources and equipment. Quality Control • Stop work for conditions adverse to quality or safety . Manager • Ensure overall project quality objectives ai·e met.

• Interact with CQCSM to confnm that daily quality goals are being met.

• Conduct periodic audits to ensure quality goals ai·e met. Contractor • Stop work for conditions adverse to quality or safety . Quality Control • Develop and implement the CQCP . System • Monitor activities on a day-to-day basis to ensure confo1mance Manager with contract specifications and work plans.

• Implement the three-phase control system for all aspects of work.

• Maintain effective Submittal Register.

• Ensure issues identified ai·e documented in Issues Management System and followed to closure.

Site • Stop work for conditions adverse to quality or safety . Superintendent • Provide day-to-day technical execution of on-site project

activities.

• Provide supervision of on-site project personnel.

• Ensure equipment and other project resources ai·e in working order.

• Work closely with CQCSM to ensure quality tests ai·e completed as required.

3. THREE-PHASE CONTROL SYSTEM

To ensure that constrnction activities comply with the requirements of the specifications, the CQCSM shall implement the three-phase QC system. The three-phase QC system consists of:

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Preparatory phase meetings/inspections.

Initial phase inspections.

Follow-up phase inspections.

These phases are described in the following subsections and shall be performed for each definable feature of work (DFW). A DFW is a task that is separate and distinct from other tasks and has separate control requirements. The DFWs for this project are presented in Section 5 of this CQCP.

3.1 Preparatory Phase Meeting/Inspection

A preparatory phase meeting/inspection shall be performed prior to commencement of work on each DFW. The preparatory phase meeting/inspection shall consist of:

Reviewing contract requirements.

Reviewing contract plans, specifications, and drawings.

Ensuring that provisions have been made for required QC testing.

Ensuring that all materials and equipment have been tested, submitted, and approved.

Reviewing the Activity Hazard Analyses.

Examining the work area, if applicable, to ensure that materials, equipment, and samples conform to approved submittal data.

The USACE’s COR shall be notified in advance of each preparatory phase meeting/inspection. Using a Preparatory Phase Checklist, the CQCSM shall create a record of each preparatory phase inspection, including meeting minutes and a list of meeting attendees.

3.2 Initial Phase Inspection

The initial control phase (Readiness Evaluation) occurs before USACE gives the approval to begin work for each DFW; it ensures the task starts correctly. The evaluation must:

Verify the contractor has implemented QC requirements identified during the preparatory phase.

Confirm worker training levels and credentials/certifications of personnel.

Examine proposed work methods and safety controls.

Verify contractual and regulatory compliance.

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Comply with established procedures.

Resolve any differences that may occur.

The scope/level of the evaluation shall be completed using a graded approach linked to the hazard level of the work. The CQCSM and USACE shall determine the adequacy and accuracy of readiness. Deficiencies shall be corrected before continuing with the DFW. Portage shall notify USACE before beginning an inspection. Using an Initial Phase Checklist, the CQCSM shall prepare a record of each initial phase inspection, including meeting minutes.

3.3 Follow-Up Phase

The purpose of the follow-up phase in the three-phase QC process is to monitor work in progress to ensure continuous quality compliance. The CQCSM or designee shall make daily QC assessments to ensure ongoing compliance with contract requirements, including control testing, until completion of each DFW. The assessments shall be documented in the daily reports. The QC reports shall present an accurate and complete picture of the control activities and work items completed. Follow-up inspections may occur on a daily, routine, or predetermined basis to ensure strict compliance with the work plans.

The CQCSM shall identify, document, and track to completion outstanding and nonconforming items. Final follow-up checks shall be conducted and all deficiencies corrected before the start of additional features of work. The CQCSM shall continually refer back to the standards set during the preparatory and initial phases.

Additional preparatory and initial inspections on the same DFW may be required at the discretion of the CQCSM (with COR approval) or the COR. Reasons for additional inspections may include: unsatisfactory work, as determined by Portage or USACE; changes in key personnel; resumption of work after a substantial period of inactivity; or changes to the project scope of work/specifications.

4. TESTING REQUIREMENTS

Table 4-1 details requirements for sampling and analysis of various media expected to be encountered during the execution of this project.

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Table 4-1 . Testing Specifications.

Testing Media sow

Frequency Responsible Compliance

Section Person Document

Meteorological Weather 5.2.1 Continuous Site Site Operations conditions superintendent Plan (USACE

2016a)

Radiological Potentially 5.2.2 Baseline and Radiological Radiation monitoring contaminated periodic technician Protection Plan

radiological surveys of (USACE components general 2016b);

areas, Sampling and excavation, Analysis Plan . .

(USACE 2016c) mcommg materials, waste packaging and shipping, and released equipment

Air monitoring Air quality 5.2.3 Continuous Air monitoring Contamination and sampling monitoring, technician Control Plan

daily (USACE 2016d) sampling/ analysis

SW/GW/ Various 5.2.5 As contacted Sampling Water Liquid waste with technician Management

suspected Plan (USACE contaminated 2016e) media

Sampling soil Various 5.2.6 Daily Sampling Sampling and and sediment technician Analysis Plan

(USACE 2016c)

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Testing Media sow

Frequency Responsible Compliance

Section Person Document

Sampling Cutback soils, 5.2.7 Daily Radiological Sampling and radioactive contaminated technician Analysis Plan contaminated soils (USACE media 2016c);

Radiation Protection Plan (201 5b)

Laborato1y All potentially 5.2.8 Daily Chemist(s) Sampling and chemical contaminated Analysis Plan analysis media (USACE 2016c)

Radioactive Suspect 5.2.9 Daily Raidiochemist Sampling and waste analysis radioactively Analysis Plan

contaminated (USACE materials 2016c);

Waste Management Plan (USACE 2016f)

Geo technical Compacted 5.2.10 As needed Geo technical Backfill and testing soils engmeer Restoration Plan

(USACE 2016g); Sampling and Analysis Plan (USACE 2016c)

Onsite All media 5.2.11 Daily Chemist(s) Laboratory laborato1y Quality operations Assurance Plan

(USACE 2016h); Sampling and Analysis Plan (USACE 2016c)

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Testing Media sow

Frequency Responsible Compliance

Section Person Document

Be1y llium Background, 5.2.12 Daily Ce1i ified Chronic monitoring, suspected and industrial Be1yllium sampling, known areas hygienist Disease testing, and of be1y llium (sampling), Prevention Plan analysis contamination chemist (USACE 2016i);

(analytics) Sampling and Analysis Plan (USACE 2016c)

5. DEFINABLE FEATURES OF WORK

The DFWs include those constmction activities that need to be controlled as a result of their impact on the quality of the final product and/or compliance with contractual and work plan requirements. All DFWs require preparato1y, initial, and follow-up inspections to detennine the quantity and quality of work perfo1med. These DFWs may change because of changing site conditions, work methods, or technology. The contractor and USACE will dete1mine and agree upon DFWs dming coordination meetings held before each task.

5.1 Support Zone Preparation and Mobilization

a. Personnel mobilization and training. b. Be1y llium and radiological surveys of the suppo1i zone. c. Installation and initiation of background air sampling. d. Clearing and gmbbing. e. Fencing. f. Signage. g. Topographic surveys and utilities installation. h. Trailer mobilization and installation. 1. Roads, parking, walkways.

5.2 Monitoring

a. Meteorological. b. Air monitoring and sampling. c. Radioactive monitoring. d. Be1y llium and chemical monitoring/sampling. e. Water and waste liquid.

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5.3 Laboratories and Testing

a. On-site laboratory. b. Off-site laboratory. c. Geotechnical testing.

5.4 Storage Area (S1) Area Preparation and Mobilization

a. Clearing and grubbing. b. Treating and excavating contaminated soil from S1. c. Water supply well rehabilitation and commissioning. d. Concrete pad installations. e. Temporary enclosure installation. f. Decontamination pad installation. g. Installation and commissioning of soil sorter. h. Waste processing equipment and facility installation.

5.5 Water Management

a. Stormwater pollution prevention measures and monitoring. b. Water treatment system installation and commissioning. c. Water treatment system operation and monitoring. d. Water treatment system decommissioning.

5.6 Remediation of Contaminated Waste and Disposition of Clean Soils

a. Excavation of beryllium, lead, and radionuclide-impacted soils and debris. b. Waste sizing and processing. c. Soil sorter operations, sizing, screening and sampling. d. Water management and effluent monitoring. e. Stockpiling of soils for offsite disposal or non-FUSRAP soils. f. Stockpiling of clean soils and place-back soils for backfill.

5.7 Waste Handling, Packaging, and Transport

a. Packaging waste for off-site transport. b. Weighing of waste containers. c. Radiological and beryllium surveys of waste containers. d. Decontamination of waste containers. e. Transport of waste containers.

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5.8 Backfill and Site Restoration

a. Rolling final status surveys for radionuclides, beryllium, and lead. b. Placement, compaction, and grading of place-back fill. c. Placement, compaction, and grading of off-site fill. d. Placement, compaction, and grading of topsoil. e. Grading and seeding. f. Topographic restoration and engineering.

5.9 Demobilization

a. Final decontamination and radiological and beryllium release survey of equipment. b. Demobilization of site equipment and tools. c. Removal of all temporary structures, security measures, site restrictions. d. Completion of USACE punch list item. Any deficiencies discovered, either by the

contractor or subcontractor, will be promptly corrected.

5.10 Construction Completion Report

a. A prefinal inspection attended by contractor quality control personnel, the superintendent, and contractor management will be conducted by the USACE. Any deficiencies noted by the USACE will be added to a punch list, which the contractor will promptly correct in a timely manner. The means of tracking and completing the contract will be by use of the QCS, which is discussed more fully in the following section.

b. Records of all remediation activities completed during this project will be furnished to the USACE.

6. REPORTING AND RECORD KEEPING

Portage will use the QCS developed by USACE throughout the contract period to record all phases of the contract. Portage will transmit required submittals through the QCS and maintain a submittal record. The QCS includes the means to manage the preparatory, initial, and follow-up control phases of the contract. This automated tool will assist in scheduling and recording the preparatory and initial phases since the program furnishes the initial inspection check-sheets for organizing these inspections. During the follow-up phase(s), the Daily Quality Control Report will be key in tracking daily activities, including any quality deficiencies and their resolution. In addition, Portage will use the QCS for completion and closeout of the contract.

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6.1 Daily Quality Control Reports

Portage shall maintain daily records pertaining to site work activities and shall submit daily reports detailing those activities. The reports shall be factual records containing written and numerical data of the contractor’s daily QC activities and resulting actions. Portage will submit the reports to the USACE COR or designee on the DQCR form by noon of the next workday following the day of the work activity. Portage will use the USACE QCS system for this report. Portage will provide the reports it generates for the last day of a week or work period to USACE at the beginning of the next week or work period, or sooner if practical.

The report shall contain a record of activities related to the three-phase QC system. The Portage CQCSM may submit separate reports for different phases of work, or the CQCSM may consolidate the reports into one report if it covers all QC activities and results and identifies the responsible QC personnel.

In all cases, the CQCSM shall verify and sign the report or reports. The verification shall contain the statement that all supplies and materials incorporated in the work are in compliance with the terms of the contract, except where noted.

The reports shall include:

Phase or phases of remediation underway at the time of the report, including a listing of equipment and personnel on-site and hours worked.

Completed QC activities, with identification of the phase.

Results of QC activities, including nature of any deficiencies observed and corrective actions taken or to be taken.

Documentation of samples collected with sample locations, including samples for chemical, beryllium, and radiological analysis and screening. The contractor will attach analytical results, including computations, to the report, as available. In any case where results cannot be completed by the time the report is submitted, Portage will note that the test was performed and the approximate date test results shall be available. Portage will submit delayed test results with a report on the date it receives those results.

Quantity of materials received and statement as to acceptability and storage.

Quantity of waste material identified, excavated, containerized, loaded, and stored.

Submittals reviewed, name of reviewer, and action taken.

Other information on factors applicable to the project, including:

Weather conditions.

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Subcontractor operations. Monitoring materials and equipment upon arrival on-site for compliance with work

plans, damage during transit, and proper storage. Job safety evaluations stating what was checked, results, and instructions or

corrective actions.

6.2 Document and Material Submittals

Portage will submit documents and materials to USACE using USACE Engineer (ENG) Form 4025, as appropriate. The contractor shall track material submittals using ENG Form 4288.

6.2.1 Submittal Register

Portage shall track formal submittals on a Submittal Register, Form 4288. The approval status of outstanding submittals shall be reviewed at each weekly progress meeting.

The Submittal Register shall include current submittal numbering sequences and dates; however, this document is subject to change during the course of the remediation, and, as such, Portage shall generate updated versions of the Submittal Register. Each updated version shall supersede prior versions, and Portage shall transmit it to USACE with an accompanying ENG Form 4025.

6.3 Recordkeeping

Portage shall maintain current records of QC operations, activities, and tests performed, including the work of subcontractors and suppliers. Documents generated as a result of implementing of this CQCP shall undergo review and signoff by appropriate personnel for both QC and safety review.

Portage will maintain a master file of CQCP documents at the site in its office/field trailer, with backup copies maintained in the Portage off-site project office. The master file may include the following documents, as applicable:

Project plans and contractual documentation (contract plans and specifications).

Area maps for site identification and documenting sampling locations.

Project photographs (including pre-remediation conditions, post-remediation conditions, and key activities in the interim).

Project logbooks, forms, logs, and tables.

Field logbooks (completed in indelible ink pen).

Sample summary tables.

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Field instrument calibration tables.

Tables for recording of any field data generated.

DQCRs.

Shipping container checklist.

Chain-of-custody forms.

Laboratory notification checklist.

Sample shipping documents (e.g., air bills, weight tickets).

Waste shipment manifests.

Site visitor logs.

Significant communication and phone logs.

Copies of ENG Form 4025, transmittal of documents.

Safety data sheets.

Field instrument manuals.

Quality records may be originals, legible copies, microfilm, magnetic disks, optical disks, or other electronic media, as appropriate, and shall be identifiable by subject, date, originator, and data recorder/author.

Storage, preservation and safekeeping of quality records shall be in accordance with approved corporate procedures and should describe the following:

The storage facility (i.e., single- or dual-storage).

The indexing system to be utilized.

The system for verifying that the records received are legible and otherwise acceptable.

The system for verifying that the records are those designated.

Rules governing access to and control of the storage facility.

The system for maintaining control of and accountability for records removed from the storage facility.

The system for filing supplemental information and disposing of superseded records.

Responsibility for distribution and receipt control.

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Portage shall turn over quality control records to USACE after completing the final closure report.

6.4 Document Control

Documents that affect how quality work activities are performed shall be prepared, reviewed for adequacy, and approved for release by authorized personnel. Portage maintains a strict document control system. Portage will distribute project documents and ensure their use at locations where the prescribed activity is performed, as may be required. Revisions shall be subject to the same controls as the original document. Documents Portage submits to USACE on this project shall be in accordance with the Submittal Register.

Minor changes that do not alter the intent of a document (e.g., minor grammatical errors or typographical errors) may be made in lieu of issuance of a revision to the document when identified. Documents shall be uniquely identified and the revision level shall be clearly indicated (e.g., DRAFT, DRAFT FINAL, or FINAL). Individual copies of documents or manuals containing collections of documents, designated herein as Controlled documents, or those designated as such by the document originator, shall be subject to the following requirements:

The Controlled status shall be indicated on the title or cover page of the document and a unique copy number shall be assigned to each copy. Portage shall maintain a list of holders by copy number to enable up-to-date version control.

A control system shall be used to distribute Controlled documents. This shall provide instructions for replacement and disposition of superseded information and acknowledgment of receipt.

Portage shall mark all copies of documents that are not Controlled to indicate the Uncontrolled status or store them where they are not accessible for use. Uncontrolled copies may be provided to persons or organizations external to Portage for information purposes, with approval by the USACE. Uncontrolled copies are current only at the time of issue, and are not required to be maintained up to date.

7. CORRECTIVE ACTIONS

When any work, feature, or material is found to be deficient, does not meet specifications, or is adverse to quality, Portage shall implement corrective action(s). Issues affecting quality can range from a minor matter, such as momentary misuse of a hard hat (requiring a verbal correction), to a major issue affecting the overall integrity of the project. For work, material, or test results found to be deficient, Portage shall initiate a corrective action. A stop-work order may be issued. Portage shall report any issue adverse to quality to the COR. For any non-

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compliant issue, it shall be the responsibility of the CQCSM to initiate and maintain a Corrective Action Log. In addition, Portage maintains a comprehensive Issues Management System that reports, assigns responsibility, and verifies issues adverse to quality. Essentially, the system fully supports the efforts of personnel tasked with resolving an issue adverse to quality. Significant conditions found to be adverse to quality or safety may result in a root cause analysis performed by a team of individuals with diverse disciplines.

8. REFERENCES

USACE, 2006, Record of Decision for Soils Operable Unit, Luckey Site, U.S. Army Corps of Engineers, Luckey Ohio, June 2006.

USACE, 2014, Final Scope of Work, Remediation of Soils Operable Unit, Luckey Site, U.S. Army Corps of Engineers, May 2014.

USACE, 2016a, Site Operations Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5500, U.S. Army Corps of Engineers, Luckey, Ohio.

USACE, 2016b, Radiation Protection Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5513, U.S. Army Corps of Engineers, Luckey, Ohio.

USACE, 2016c, Sampling and Analysis Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5503, U.S. Army Corps of Engineers, Luckey, Ohio.

USACE, 2016d, Contamination Control Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5509, U.S. Army Corps of Engineers, Luckey, Ohio.

USACE, 2016e, Water Management Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5506, U.S. Army Corps of Engineers, Luckey, Ohio.

USACE, 2016f, Waste Management Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5507, U.S. Army Corps of Engineers, Luckey, Ohio.

USACE, 2016g, Backfill and Restoration Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5510, U.S. Army Corps of Engineers, Luckey, Ohio.

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USACE, 2016h, Laboratory Quality Assurance Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, U.S. Army Corps of Engineers, Luckey, Ohio.

USACE, 2016i, Chronic Beryllium Disease Prevention Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5512, U.S. Army Corps of Engineers, Luckey, Ohio.

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APPENDIX A Resumes of Key Quality Personnel

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U.S. Army C<:<ps of Engineers, Buffalo Ostrict ,, H II LUCKEY FUSRAP REMEDIATION : •• • : Sdicitation No. W912P4-14-R--0002

. . . . ' . . Name: PMP Employer: Portage

Education: B.S., Mini~ Engineering, Michigan Technological Univeisity, 1985 (accredited by the Higher Learning Comrnssion. North Central Assoaation of Colleges and Schools) Regis1rations/Cenifications: Project Management Professional, No. 185426 Training: OSHA 40-Hour HAZWOPER and 8-hour Refresher; Characterizing Waste; Conduct of Operations; DOE Radiological Worker II; PM Training - Numerous Courses in Project Management - Scope Management, Change Control, Scheduling, Resource Planning and Cost Estimating, Cost Control, Quality Management. Communication. Risk Management. Procurement and Contracting. Earned Value Management Special Qualifications: • Safely managed large DOE HTRW projects at Hanford, Los Alamos National Laboratory, and Moab UMTRA involving sdls and debris contaminated v.ith radionuclides, beryllium, lead and olher heavy metals. asbestos, and other contaminants • Strong understandng of and application of condJct of operations procedures and protocols (DOE Order 5480. 19) to maintain wcrk environment wi ttin safety boundaies • Experience in integration of S&H and quality control through application of DOE's Safety Conscious Wak Environment processes • 7 years of experience serving as Portage PM IOI two major cost reimbursable projects v.ith revenues in excess of $200 million; strong working kno\Medge of Portage's internal financial. accounting. and project management systems • Managed prqect staff of over 100 professional and aafl personnel • Outstanding prior waking relationship with Luckey Team members- Amee FW on the Moab UMTRA project. ARS on the LANL MDA B projec~ and is a former Envirocon PM at Hanford.

Expenence

I Quallf1cat1ons Section 6.1.2 • B.S .. Mning Engileemg • 29 years or professional HTRW

experience; 26 years of HTRW projoot management experience; his first ~or raddogica dean up was at DOE-Hanford, 1se1

• 26 years of expenence v..th beryllium and radonudides, PM for projects with for!M beryllium medcal monitoring programs aoo dust contrds for 15years

• 14 years of experience in managing cost reirrtlursable contracts

• Excellent waking kna>Medge of apjjicatfo federa. stale. and local laws and regtj ations (CE RC LA. RCRA. CWA. CAA. DOT waste transpcrt) through heavily regt•ated DOE remedation projo::ts in NM, WA, and UT

Project Title: DOE, Moab Uranium Mill Tailirv,:is Remedial Action Project, Moab, Utah (Project 113, Past Performance)

Title: Project Manager Dates: 2012 - Present Cost: CR $100M; FFP $32M

Duties/ Responsibilities: Portage PM responsible for safe ~erations of this multi-year HTRW remedation of a 130-acre urarium mll tailings pile with multiple waste transport modes (track. rail) and landill disposal. Activities include excavabon and condtioning of rad-contaminated mill tailings and debris material; waste pad<a~ng into intermodal containers; transport U'f rail to lhe disposal facility located in Crescent Junction, Utah; operati on of the dsposal facility ; and other support functions. Responsible for the excavation and disposal of 3 mllion tons of residual radioactive material, 4,500 Lons per day. Serves as the primary point of contact IMth DOE regarding contract execution and performance. Responsible !Cf effective oommunication and management of an integrated team consisting of 17 professionals (field engineers. site superintendents. ESQ&H. Radiation Control. and transportation and facility maintenance staff). 93 field staff (equipment operators. truck ctivers. mechanics. security. and laborers) and three maja subcontractors (induding 2 yeas -....1th Amee FW and transitioning operations with Envirocon). Responsible for resource panning and effective oommunication among team members. Ensures task performance requirements are met with sufficient available staff and resources and approves all work plans. addenda. and work packages. Provides leaders tip in promoting safety and quality culture and led implementation of DOE's Safety Conscious WorK Environment initiative. Coordina1ed readiness reviews IM1h site managers, Quality and S&H managers; and worked closely with the QA manager performing internal assessments and self-checks. Most work performed in PPE Levels C and D. Responsible for cost, schedule, and budget using earned value to measure cost and schedule performance for both the cost reimbursable and fixed unit rate contracts using Primavera P6 and Dettek's COBRA (EV software). Works dosely v.ith the project directer in interacti ons with federal (BLM. NRC. DOT. DOI) and state regulatcry authorities. as well as local Moab community entities. Manages dust control program and oversees air monita ing corr;erns ~ntial

radiological dust concern for nearby residents or Moab and for recreational users of Arches National Park. Under­leadership, the project has had zero lost time accidents or injuries. zero environmental releases. zero regulatory violations. and excellent earned value metrics (CPI of 1. 00 and SPI of 1. 03) Proposed Luckey Program Manager.- and Cost Scheduler, supported n this project

~~~~~~~~~~~~~~~~~~~~~~~~~~~

~~~~~~~~~~~~,:~PORTAGE~~~~~~~~~~~~ Volume I, Factor 1-Sub·factor 3

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U.S. Army C<:<ps of Engineers, Buffalo Ostrict ,, H II LUCKEY FUSRAP REMEDIATION : •• • : Sdicitation No. W912P4-14-R--0002

Project Title: DOE, Los Alamos National Laboratory Material Disposal Area B, Los Alamos, New Mexico (Project HZ, Past Performance)

Title: Project Manager Dates: 2008 - 2012 Cost: CR $71M

Duties/ Responsibilities: Portage PM for excavation of 47,000 yd3 of buried radioactive and hazardous waste from the MDA B landfill, a series or Manhatlan-era trenches. the most complex remediation project undertaken at the Laboratory. Contaminan1s included t.ranium, beryllium, plutonium, asbestos, lead and other heavy metals, and organic solvents. Work was performed under a Chronic Beryllium Disease Prevention Program (CBDPP) due to the presence of beryllium. Worked dosely v.ith the client when anomalies were encountered, includng uncovering jars of beryllium shavings, gas cylinders al nid<el tetracarbonyl and other unknowns. 300 jars and containers IMth unknown solids andlor liquids. asbestos materials. and drums containing unknown materials. Managoo 35 professionals (field engineers, site superintendents. ES&H. RCT, and waste-certification staff), 120field personnel (equipment operators and teamsters), and 15 subcon1ractors (facility a-action. electric<( equipment maintenance. field staffing, and an onsite laboratory). Served as the pcint of contact for the client and led plan-of-the-day and weekly status meetings with dient and staff. Prqect activities included mobilization and site startup, engineering design, waste excavation and sorbng, waste profiling pacKaging, waste paekaging ror disposal, excavation baeknlling, connrmation sampling, and site regrading. Managed cost and schedule using Primavera P6; inte;irated our schedulekesources with cient's master integrated schedule. ConduG!ed internal assessments (self-<:heck walk throughs) and ensured effective hazard canmunicslion and implementation of required safety protocols (work performed primarily in Level B PPE). Responsible for cost, schedule, and budget performance and successfully managed scope changes and funding fluctuations caused by ARRA and congressional funding. Supported the dient in interactions with the New Mexico Environment Department. Proposed Luckey SSHO, and Luckey Team member, ARS, suppcrted

- on this project.

Project Title: DOE, Hanford CERCLA Environmental Restoration Disposal Facility, Hanford, Washington

Title: Project Manager Dates: 2005 - 2007 Cost: CR $10M annually

Duties/ Responsibilities: Managed operation of the Environmental Restoration Disposal Facility (ERDF), a 4M-yd3 landfill that accepted up to 5,CXJO Ions of waste per day, including radioaciive wastes, berylli lJTI, lead and other heavy metals, asbestos, and organic solvents. Work was performed under a CPDPP in accordance with 10 CFR 850. Oversaw 70 personnel responsible for trench excavation, waste placement, waste acceptance, S&H compliance, QA oversight, and cost and schedule. Led innovative solutions for handling difficult, non-standard wastes in accordance IM!h DOE, Stale of Washing1on, and applicable regulatory requirements. All work was completed l'lith zero lost-time accidents.

Project Title: DOE, Hanford W-314 HLW CERCLA Tank Farm Upgrades Project, Hanford, Washington

Title: Project Manager Dates: 2002 - 2004 Cost: CR $285M

Duties/ Responsibilities: PM responsible for design, construction, installation, and startup of upgraded waste transfer lines and ventilation, control systems, and electrical distribution systems. Served as the point of contact with DOE. Supe-vised 100 FT Es and 30 subcontrac1ors. M~e. schedule, and budget per DOE ocders requiring sale installation or equipment in a high-hazard environment During-enure on the W-314 ixoject, project-to-date cost variance wen1 from $10.GM (over budget) to $988,000 (under budget) in 16 months; schedule va-iance improved from $7.1 M behind schedule to 0% schedule variance; and forecast-at-completion of the project was reduced by $47M to $238M. Completed v.ith zero lost-time accidents and zero environmental violations occurred.

Project Title: DOE, Hanford 300-FF-2 Remediation Project, Hanford, Washington

Title: Project Manager (for Envirocon) Dates: 2004 - 2005 Cost: FFP $20M

Duties/ Responsibilities: Project manager for excavation, packaging, and dspositioning 70,000 yrF of buried waste v~th contaminants of uranium. plutonium. beryllium. asbestos, heavy metals, and organic solvents Werk performed under a CPDPP. Led a staff of 45 who prepared project plans and procedures; excavated and sorted high-hazard waste material from five waste burial grounds; and profiled, packaged, and transported waste. Oversaw design and construction of support facilities, and successfully managed e<n;t and schedule, which led to the ER OF assignmen1 noted above. Work completed with zero OSHA recordable accidents and zero environmental violations.

~~~~~~~~~~~~,:~PORTAGE~~~~~~~~~~~~ Volume I, Factor 1-Sub·factor 3

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U.S. Army C<:<ps of Engineers, Buffalo Ostrict ,, H II LUCKEY FUSRAP REMEDIATION : •• • : Sdicitation No. W912P4-14-R--0002

Constructmn Quality Name: PG, PMP Employer: Portage

Education and Training: B.S., Geology, Tennessee Tech, 1985; M.S., Geology, Louisiana Slate Universily, 1989 (including Design or Env. Management Systems and HTRW remediation) (accredited by the Southern Association of Colleges and Schools) Registrations/Certifications: Professional Geologist, Mississippi, No. 482; Project Management Professional, No. 6527 Training: USACE CQCSM; USACE CQM; OSHA HAZWOPER 40-hour; 8-hour OSHA Refresher; OSHA 8-hour Superviscr; OSHA 30-hour Construction; Naturally Occurring Radioactive Material (NORM); 40-hour Radiation Safety Officer; DOE Radiological Worker II; NORM (Rad) 8-hour Surveyor; Quality Improvement Process Management; Restoration AdViscry Board; Project Management Institute Seminar, Government Earned Value and Cosl/Schedule Repor1ing; Field sampling at HTRW Sites Special Qualifications: • 7 years FUSRAP and 1-ITRW CQCSM, and QC specialist for USA CE, Navy, and DOE, including the Painesville FUSRAP project in Ohio for the Buffalo District • 18 years' contractor quality manager experience for moderate to large-scale and multi-task-order IDJIQ contracts for federal programs • Expert in radiological, chanical, biological, and geological sampling campaigns • Proficient in all SW-846 field sampling methodolcgies, completing 8 large-scale soils and GW remedial actions, 6 remedal investigations. and 9 radiological demolitions • Extensive background in assessing quality problems. facilitating results using QC tools and methodologies, and performing quality audits.

Fxpenence

I uual1f1cauons Section 6.1 ./ • M.S , Geelcgy, Louisiana State

University • 23totalyears ofHTRW

experience, indudng 1Syears' experience in CQCSM/QC project roles

• Extensive HTRW continuing education

• Excellent wa-kirg koolMe~e of fedeJ'al, state, and local laws and regulations m Ohio and other states through 40 prqectS/ contracts for USACE, DOE, and Navy

• Workiny knowledge of RMS/QCS • USACE CQCSM certification

Project Title: USACE Buffalo, FUSRAP Shallow Land Disposal Area, Health Physics Services, Vandergrift, Pennsylvania

Title: CQCSM (for ARS) Dates: 2011 - Present Cost: FFP $2.67M

Duties/ Responsibilities: CQCSM responsible for ensuring that prqect activities are conducted according to prescribed quality standards tor this HTRW project involving radiologically contaminated sals. Produces daily QC reports tracl\ing day-to-day site activities reporting cireclly to USAGE Buffalo District. Conducts daily QC assessments and periocic audits. tracl<s deficiencies and corrective actions. Ensures compliance wi th contract specifications and requirements in CQC plan. Participated in the USACE lhre!7 phase QC procedure and submitted reports and data packages to USA CE Buffalo District Conducts material and equipment inspections; inspects S&H ins1ruments to ensure calibration and proper operation and quality assurance audts. Performs QC of all chemicavrad laboratory results. noting deficiencies. sui:ervises well installation. monttors activities. monitors ac sample testing. and assists with sample colection. Pro'lides oversight of sample management for fi nal status survey.

Project Title: USACE Buffalo, FUSRAP Painesville Site Remediation, Painesville, Ohio

Title: CQCSM (for ARS) Dates: 2010- 201 1 Cost: FUR and FFP $1 5.8M

Duties/ Responsibilities: Authored QAPP, CQC plan, SAP, FSP, and SSHP induding AHAS and SOPs for ttis large HTRW remediation project involving radiologically contaminated softs. Ensured compliance with contract specifications and requirements or CQC plan. Participated in USA CE three-phase QC process. Conducted preparatory inspections of materials and equipment received onsite as well as daily inspection of S&H instruments to ensure calibration and proper operation. Authored daily CQC reports. obtained and reviewed laboratory results. entered and rollated data points fer reports to USACE. Prepared Final RepOfl of Qua/i1y Data for submission to USACE Buffalo. Prepared relatat:le database for USA CE using project data.

Project Title: USACE Buffalo, FUSRAP Tonawanda Landfill Operable Unit, Phase II RI, Tonawanda, New York

Title: CQCSM/Site Geologist (for ARS) Dates: 2009 - 201 1 Cost: FFP $373K

Duties/ Responsibilities: Served in dual role as the CQCSM and site geologist for RI, field sampling, and surveying of radiologically contaminated soil and water. Characterized and logged soi cores and temporary well points using Geoprobe drilling methods up to 70 n below ground surface. Reviewed and approved subcontractcr submiuals. Assisted with authoring QAPP, SAP, FSP, and si1e-specific SSHP, including AHAs and SOPs. Participated in the USACE three-phase QC process, and ensured com liance with contracts ecifications and CQC Ian. Worked with drill in subcontractor to ensure inte rated uali com liance.

~~~~~~~~~~~~~~~~~1~ P()RT.A.GE~~~~~~~~-v-01-um-.-,-,F-a-ct-or_l_-S_u_b-.f-ac-1o_r_3

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Corporate Environment, Safety, Health, and Quality Manager

Education

PLN-5502 I 28of36

B.S., Industrial Technology, emphasis in Quality Assurance and Waste Management, University ofldaho, Moscow, Idaho, 2003 Certificate of Proficiency in Quality Assurance, University of Idaho, Moscow, Idaho, 200 I

Experience Summary

has more than 20 years of experience providing quality assurance (QA) engineering/auditing support to programs, pro1ccts. and facilities in a nuclear-related waste management, construction, and operations environment. 1 has developed, implemented. and provided control/oversight for various QA programs. He has qualified as a quality engineer through the certification program at the U.S. Department of Energy's (DOE) Idaho National Laboratory (!NL). He has qualified and served as a waste certification official for waste materials being shipped to the Nevada Test Site (NTS) and the Waste Isolation Pilot Plant is a lso an ASME NQA-1 lead auditor.

Professional Highlights

• Manages the DOE Carlsbad Field Office Technical Assistance Contract (CTAC) Audits and Assessments/QA group. fills this position concurrently with the Portage coworatc Environment, Safety, Health, and Quality (ESH&Q) manager position. In this role •••••• supervises QA auditors and technical experts supporting the DOE field office to ensure that radioactive waste shipped to the Waste Isolation Pilot Plant (WIPP) meets applicable federal and state requirements.

• Manages the Portage ESH&Q Department. reports to the company owners and provides direction and cohesion to company ESH&Q professionals. In this position, has had supervisory/management responsibi lity for more than 40 people with varied disciplines. He also filled a key role, with subordinate managers, in obtaining and maintaining Portage's certification to ISO 900 I, ISO 14001, and OHSAS 18001 standards.

• Managed the Portage QA Department, oversee ing implementation of the corporate QA prog ram and implementation of procedures. His duties included administering program elements that required corporate-level reporting and control, consulting with management at all levels to assist with the application of QA principles, and supervising QA professionals in support of company projects.

Served as a senior-level QA specialist for North Wind, Inc. nsured projects were pcrfonned in accordance with contract requi rements and that pertinent regulatory and client-imposed requirements were implemented. He also pla1med inspections and conducted assessments, surveillances, and compliance audits, including documenting the results. He identified conditions adverse to quality, evaluated proposed corrective actions, and perfonned verification of completion and effectiveness of corrective actions. Additional duties included the following:

o Served as a lead auditor for internal audits, subcontractors, !NL projects, and other contract engineering activities

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Portage page 2

o Perfom1ed engineering design reviews on equipment, materials, and structures to be built and purchased as well as reviewed design documents for adequacy using QA standards and regulation~

o Assumed responsibility for environmenlal compliance oversight, ensuring I hat al l activi ties were conducted in compliance with DOE orders and federal, state, and local regulations

o Provided assislance for org:mizalions and projects in evalualing the effec1iveness of1heir QA prog1-am implementation, identifying areas for improvement, and pa11icipating in con·ecfive action and ve1ification

o Evaluated vendors for placemen! on an approved suppl ierii list.

• Supported INL's Advanced Mixed Waste Treatment Project (BBWI, Idaho Falls, Idaho) through compliant disposal ofbacklo<~ed and new-generalion, low-level waste. He oversaw collection of waste characterization data 1ogether wilh labeling, staging, loading, and shipping of waste conlainers to meet schedules and ensure compliance. lso contributed to the development of department processes, procedures, and liaining programs to be used in ongoing waste disposal operalions. Additionally, he participated in Resource Conservation and Recovery Act (RCRA) hazardous waste management compliance activities, such as satellite accumulation a1·ea/tempora1-y accumulation area (SAAffAA) management and inspection.

• Serviecl as the N011hwest Arca QA lead for S. M. Stolkr Corporation. In th.is role, ckveloped QA documents, including the quality plan and implementing procedures, and administered the QA program for lhe INL CERCLA Disposal Facilily. Program administration included QA/quality control activities for landfill development and operation, general operational oversight, and routine support of client or cxtemal audits. He coordinaled and administered QA program elements. including design configuration management, mate1ial controls, measuring and test equipment control (calibration tracking), audit/assessment/surveillance programs, issue/corrective action tracking, vendor/ subcontractor qualification, software configuration management, document control , and testing/data management. He also conhibuted to the development of a corporate ISO 9000-based QA program.

• Se1ved as the lead quality engineer to the !NL Waste Generator Se1vices organization.­developed and adminislered a projecl-specific QA program under an overarching co1pora1e QA program. He implemented and led the Data Quality Group for evaluation and tracking of data quality and software change conlrol for the Integrated Waste Tracking System, which is used to track and documenl information related lo waste charnctc1ization and movements al INL. He also developed the first INL low-level radioactive waste certification program and served as lNL's first NTS waste cet1ification official for shipment of radioactive wastes to the NTS.

• Worked as a full-time auditor/lead audilor for more than 4 years as part ofINL's Waste Management Compliance Team. 1l1e team's function was to audit loca l and national generalors of waste material that was intended for treatmenr and/or disposal at one of the INL waste 1reatment storage and disposal facilities. Audi ls were conducted to the rc;c.;iving facility 's waste accc;ptancc; criteria, which included rcquiromcnts fo.-cornpliancc to nuelcar QA standards. 's cxpc1icnced in developing audit plans, writing checklisls , leading audit meetings, and developing reporls .

Se1ved as a security trainer for 7 years in the field of nuclear security operations. As such, he gained experience as a supervisor and a trainer. He developed h·aining plans and has presented !raining lo DOE, military, and state law enforcemenl personnel.

Professional Certifications, Registrations, and Licenses

• NQA· l QA Lead Auditor

• INL Quality Engineer

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• INL Wasle Generator Services Waste Technical Specialist

WIPP and NTS Wasle Cerlifica1ion Official

Training

• Accident Investigation

• 40-Hour HAZWOPER

Ch:U"acteriz.ing Wast~

• Conduct of Operations

• DOE Radiological Worker II

• Environmental Radiochemistry

• Implementing Management Assessments

ISO 14000 (Lead Auditor)

• Managing Environmental Data

• RCRA Regulation

Root Cause Analysis

• SANT AA Operations

• Supeivisory Sk iJ ls

• Suspect Counte1feit Patts

• TSCA Regulations

Waste Analysis Plans

Gov11rnm11nt Clsarancss

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page3

~oes not hold a current govemment clearance. He has held DOE Q and L clearances in the past and is capable of having clearances renewed.

Employment History

2010- Present

2010- Present

2008- 2010

2007- 2008

2007- 2007

2003- 2007

1998- 2003

1993- 1998

1988- 1993

1984- 1988

CT AC Audits and AssessmentsfQA Manager, Portage, lnc., Carlsbad, New Mexico

Corporate ESH&Q Manager, Portage, Inc. Idaho Falls, Idaho

Corporate QA Manager, Portage, Inc., Idaho Falls, Idaho

Senior QA Specialist, North Wind, Inc., Idaho Falls, Idaho

Technical Specialist (6 months), BBWI, Idaho Falls, Idaho

Lead QA Engineer, S. M. S101ler Corporation, Idaho Falls, Idaho

Quality Engineer/ Audit.or, BBWI, Idaho Falls, Idaho

Quality/Environmental Auditor, Lockheed, Idaho Falls, Idaho

Secu.rity Trainer - QA, Protection Teclmologies, Idaho Falls, Idaho

Nuclear Secu1ity Operatiom, Ame1ican Protec1ive Se1viccs, Idaho Falls, Idaho

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U.S. Army C<:<ps of Engineers, Buffalo Ostrict ,, H II LUCKEY FUSRAP REMEDIATION : •• • : Sdicitation No. W912P4-14-R--0002

ProP.oscd Job l 11lc· Name: CHST Employer: Env1rocon

Education: A.S .. Criminal Justice, Joliet Junior Col lege, Joliet, Illinois, 1986 Certifications: Construction Health and Safety Technician, Soard of Certified Safety Protess1ona1s Training: 40-Hour HAZWOPER; 8-Hour HAZWOPER Supervisor; Licensed Asbestos Supervisor; Licensed Lead Supervisor; OSHA 3(}-hour Construction Safety Certification; 10 CFR 850 Beryllium Program Qualified Excavation Competent Person; Hoisting and Rigging Certification; Scaffolding Competent Person; DOE Radiation W01ker II ; NFPA ?OE, Electrical Protection Certification; CPR-First Aid. Blood Borne Pathogen Certification Special Qualifications: 25 years' experience in construction. D&D. and remediation activities involving radionuclides, beryllium, heavy metals (induding lead), asbestos, PCBs, VOCs, and SVOCs • 5 years' radionudide and beryll ium contamination control expe-ience at DOE Hanford and Rocky Flats • FUSRAP experience at Iowa Army Ammunition Plant • Extensive experience implementing large-scale remedation and D&D projects at DOE facilities/sites (Hanfcrd, savannah River Plant, Argonne National Lat:icratory, RocKy Flats, OaK Ridge National Laboratory, Lav.Jencelivenncre National Labaatory) • Possesses expertise/experience in asbestos abatement; lead and beryllium decontamination and remediation; RCRA treatment, storage, and disposal corrective actions; CERCLA hazardous waste investigations/remedal response activities: and UST investigations/removal projects

Expenence

Quallf1cat1ons Section 6. 1.3 • 20 years' expelience at mt.J Upe

HTRW sites across the DOE canpex. performing remedation, atetement. and D&D

• 7 years' DOE experience perform ng ber)ilium decontamination and remedation under 10 CFR 850

• 15years' experience supe111ising and managing construction era~ personnel

• 5 years' WOl'l:ing on cost rEimbt.-satle contracts for DOE

• Full undefslandng of federa , state, and loc" raglfations through project wak on mutipe DOEµ-ojects at 6 majcrfacilies/$ites, indudng nuclear conduct of operations experience execudng highfisk 1V011< saiely end effectively

Project Title: DOE, Hanford 1000/0R/H Area Remediation, Richland, Washington (Project #5, Past Performance)

Title: Site Superintendent Dates: 2012 - 2014 Cost: FFP S39.9M Duties/ Responsibilities: Responsible for scheduling/managing field activities related to large-scale remediation of multiple radiological and chemically contaminated waste sites. burial grounds. and pipelines in the 100H Area. COCs included radionudides. beryllium, chromium, VOCs, and SVOCs. Worked under CBDPP. Responsibili ties incluctld interacting with onsite and subcontraci engineers regarding design and execution of the wcrk; procuring equipmenVmaterials: and providng input on work planning documents, induding the SSHP, oil management plan, site operations plan, traffic control plan, and SW PPP. Supported development of work control documents as part of a sophisticated work control program integrating operations planning with health and safety, radiological, industrial hygiene, security and environmental controls. Supervised 25-30 craft personnel. Champoned work involvement in the work planning and execution processes and solicited feedback from workers. The 100 H Area portion of the project was completed on ti me and below budget, \Mth zero incidents.

Project Title: FUSRAP, Iowa Army Ammunition Plant. Depleted Uranium Impacted Soil Soning, Middletown, Iowa

Title: Site Superintendent Dates: 2014 (Part Time) Cost: FFP $2.5M

Duties/ Responsibilities: Backup site superintendent supporting implementation of depleted uranium (OU) remedial action in suppcrt of the Amee FW ORION ScanscrtSM system used for segregating DU fragments and impacted sol above the cleanup goal (CG) from scil with uranium aciivity below the CG. Supe-vised operator and labor crews perfcrming debris seg-egation, contaminated soil excavation, sorter feedstock management, and management of soil stockpiles processed by sorter (dean and contaminated). Supervised 4-7 craft and subcontract pe-sonnel. Developed wor1< activity plans, conducted pre-task safety briefings, and coordinated Plan of the Day v.ith client and USAGE representatives. Coordinated sampling and backfill activities v.ith USAGE representatives. Implemented SW PPP: performed scheduled and post-rai n-evenl inspections Initiated repairs or modifications to sediment controls as required. Accomplished incident-free performance.

Project Title: DOE. 100N River Structure Sediment Removal. Richland, Washington

Title: Site Superintendent Dates: 2011 - 2012 Cost: CR $1.7M

Duties/ Responsibilities: Managed activities of specialty subcontractors and integrated \\1th fieldmrk, induding underwater vacuum removal and filtration of material removed from the outfall areas of the 1 OON rive1 structure. Performed oversight of subcontract divers. setup of air lines, and removal ol hatchways Day-to-day activities included site stat.mzation: setting barricades

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U.S. Army Corps of Engineers, Buffalo District LUCKEY FUSRAP REMEDIATION Sollcltalion No. W912P4-14-R.0002

Proposed Job Title Radiation Safety Office~ Name: CHP Employer: Amee Foster Wheeler

Education: M.S., Rooiological Health, University of Michigan, 1992 (accredited by Higher Learning Commission, North Central Association of Schools and Colleges); BA , Psychoneuroimmunology, University of Michigan, 1990 Registrations/Certifications: Certified Health Physicist, No. 4259 Training: OSHA 40-hour HAZWOPER plus Refresher, Asbestos Awareness, MARSSIM, DOT HAZMAT, Decommissioning Nuclear Facilities Special Qualifications: 21 years' experience as a health physicist, including RSO at FUSRAP (Superior Steel, Guterl, ABB Windsor, and Iowa MP) and HTRW sites under USACE purview (Welsbach); prepared and implemented RPPs, SAPs, H&S plans for sites under CERCLA and RCRA; worked effectively wilh NRC on license termination • Good working relationship with USACE Buffalo personnel on RPP development and implementation at FUSRAP sites • Highly familia with Amee FW Orion ScanSortsM and mobile ScanPlol'm technologies for site characterization and remediation • 3 years of day-to-day RSO responsibilities for significant beryllium dust CERCLA remediation adjacent to residential creas, Nuclear Metals Site, Concord, MA • Gamma spectroscopy, radiation modeling, and management of onsite radiological lab; radiation dosimetry; radiation dose assessments; radiation safety procedures; worker training; rooiation hazard identification and mitigation; selection and use of safety equipment and procedures; implementation of worker and amb!ent exposure monitoring programs • Worked closely with USEPA Region 5 and Ohio EPA in 2011 for remediation of contaminated buildings in Cincinnati • OSH, NRC, CERCLA, and stale regulations and guidance, including MARSSIM surveys and radioactive material and waste.transportation/disposal requirements.

Experience

Qualifications Section 6.1.6 • M.S., Radiological Health • Certified Health Physicist • 12 years' experience in devel-Opment

and implementation of RPPs and radiation safety programs for HTRW site cleanup involving racionuclidas and beryllium

• Completed specialized training in MARSSIM surveys, Nuclear Facility D&D, Radioactive Material Transport Radiation Safety, Air Monitoring,

• RSO and drected the onsite radiological lab for ABB Windsor FUSRAP for 6 years

• 12 years' experience in management of field staff

• 12 years' experience with FSS to address MARSSIM

• Working knowledge of federal, state, and local occupational safety and health regulations in Ohio and other states.

Project TiUe: USACE Buffalo, Superior Steel FUSRAP Site Remedial Investigation, Carnegie, Pennsylvania

Title: Certified Health Physicist/RSO Dates: 2013 - Present Cost: FFP $2.6M

Duties/ Responsibilities: Provides identification of radiation hazards and development of hazards control for work plans and field investigation as part of on-going CERCLA RI involving 25-acre former steel manufacturing facility with radionuclide and beryllium contamination. Primary focus is development of RPP, worker training and safety, and oversight of radiological surveys and screening of environmental samples for uranium with an onsite gamma spectroscopy laboratory. Implements MARSSIM approach to radiological surveys, integration of Beryllium Safety Program and sampling, and surveys of radioactivity contamination levels using Amee FW's innovative mobile detection tool, ScanPlot5" '· Provides oversight of field staff conducting radiation exposure monitoring, performed work area inspections, and reviewed/reported results.

Project TiUe: ABB Windsor FUSRAP Remediation, Windsor, Connecticut (Project #4, Past Performance)

ntle: Radiation Safety Officer Dates: 2007 - 2013 Cost: CR $82M FFP $23M

Duties/ Responsibilities: Responsible for RPP for 640-acre site cleanup and NRC license termination in support of FUSRAP remediation of a former government-contractor-operated nuclear manufacturing facility, which supported AEC activities similar to the Luckey site. Rural setting with several abutters and a staff of approximately 50 workers who remained onsile and close lo the work sites throughout the remediation project. Similar to Luckey, this site has neighboring settled areas, requiring careful management of perimeter monitoring program, risk communication, dust control, and monitoring. Managed the Radiation Protection Program and developed integrated hazard analysis for site investigations, soil excavation, building D&D, and waler treatment system O&M. Managed the training of site workers and established PPE levels for various activities. Revised the decommissioning plan to address excavation and offsite disposal of soil and debris. Worked closely with USEPA Region 1, Connecticut Department of Energy and Environmental Protection (CT DEEP), and USACE New England on all RSO-related aspects of the cleanup planning and execution. Supervised the Environmental Monitoring Program, wrote the onsite laboratory protocols for analysis of enriched uranium, and managed three onsite radiological laboratory staff. Supervised four radiation technicians performing rad and chemical waste transportation and offsite disposal.

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APPENDIX B Letter of Assignment of CQCSM

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Memo Toe

From:

CC:

Date: 11/16/2015

Re: Luckey FUSRAP Site Remediation Project Quality Assurance Delegation

The purpose of this memorandum is to document my delegation of authority to you to act as the Contractor Quality Control System Manager (CQCSM) for the Luckey FUSRAP Site Remediation Project in Wood County, Ohio. This authority is effective immediately. The CQCSM is an important role. As the CQCSM, you have the authority to act in all CQC matters for Portage on the project. You may designate some of your responsibilities to another qualified person, but that delegation must be approved by the Corporate Quality Control Manager. You, or your designated alternate, must be accessible during field activities that require QC inspection or oversight by the CQCSM. All submittals generated as a result of this project will be reviewed by you or your designated alternate

This delegation of authority allows you to initiate a "Stop Work" when an activity does not comply with contract specifications or presents a safety hazard to project personnel. This authority includes approval of corrective actions prior to resuming work.

QC is an essential component of our plan to successfully fulfill the requirements of the contract and associated the Luckey Remediation Project. I am confident that you will carry out these duties on my behalf.

Sincerely,