From: Claxton, Marshall Sent: Friday, October 06, 2017 1 ...From: Claxton, Marshall To: Jump,...

From: Claxton, MarshallTo: Jump, ChristineSubject: Final: Revised: FFS Schedule and Cost Estimate Review TM-West Lake LF OU1 ProjectDate: Monday, December 18, 2017 9:25:22 PMAttachments: 2017_10_05 West Lake Landfill FS Cost-Schedule Review Summary Rv2.pdf

2017_10_05 West Lake Landfill FS Cost-Schedule Review Summary Rv2.docx

Chris, Attached for the file is a final revised FFS Schedule and Cost Estimate Review TM for the West LakeLF OU1 Project. A pdf version and word version was provided. Please let us know if you have any additional comments on this information. Marshall ClaxtonBlack Veatch Special ProjectsPE Kansas/NebraskaO 913 458-6508M 913 [email protected]

From: Claxton, Marshall Sent: Friday, October 06, 2017 1:45 PMTo: 'Jump, Christine'Cc: Law, PrestonSubject: Revised: FFS Schedule and Cost Estimate Review TM-West Lake LF OU1 Project Chris, During our discussion this morning I noted a comment that needed to be deleted (previouscomment 40 was already covered by comment 38). This has been corrected in the attachedrevision. Similar to previous we have attached bot a pdf and word version of this document for youruse. Let us know if you have any additional questions. Marshall ClaxtonBlack Veatch Special ProjectsPE Kansas/NebraskaO 913 458-6508M 913 [email protected]
mailto:[email protected]:[email protected]:[email protected]

www.bv.com

MEMORANDUM

Subject: West Lake Landfill OU1– Feasibility Study Cost and Schedule Review

Date: October 5, 2017 To: Chris Jump (USEPA) From: Marshall Claxton (BVSPC)

Based on USEPA request received by email on 9/21/17, this memorandum provides our preliminary thoughts regarding the review of the cost and schedule appendices in the Final Feasibility Study (FFS) for the West Lake Landfill Operable Unit 1 (OU1) Site in Bridgeton, Missouri. Our scope was to focus our review on Appendix G - Conceptual Environmental Monitoring Program, Appendix J – Estimated Project Schedules for the Remedial Alternatives, and Appendix K – Cost Estimates. The entire FFS was also provided to assist in the review of the cost and schedule information. Following are our comments from this review. Some general comments on the FFS that may have impacts on the schedule and cost are provided first, followed then by more specific comments on the Project Schedule and the Cost Estimate.

General FS Comments

Based on our review of the FFS, following are general comments on technical aspects of the remedial action alternatives that could result in impacts on schedule durations and costs associated with their implementation:

1. Although increased costs are incurred, the revised UMTRCA landfill cap will provide

increased protection from the ROD-selected remedy cap alternative as identified in the FFS.

The additional measures that appear to provide added value include the following:

The relocated biointrusion layer will provide increased protection to the infiltration

barriers.

The reduced clay permeability will substantially reduce infiltration through the cap.

The drainage layer above the infiltration barrier will reduce infiltration through the cap.

The inclusion of the geosynthetic clay layer (GCL) on the flatter slopes will protect the

underlying low permeability clay and provide additional infiltration protection.

2. The following general observations were noted which could have cost and schedule impact

for the excavation alternatives:

2.1 The accuracy of the identification of the extent of the targeted RIM material is critical to

the execution of the excavation plans. Significant changes in the identified RIM extent

will impact the sequencing of the excavations. The FFS consistently indicates the extent

of the RIM material based on the 50% estimate is anticipated to underestimate the

volume of RIM material. Subsection 5.5.1 states a value of 2 over the 50% estimate is

possible. Therefore, the schedule and estimate for the cost and time of completion of

WEST LAKE LANDFILL OU1– FEASIBILITY STUDY COST AND SCHEDULE - PAGE 2

the excavation options is subject to considerable uncertainty. This may exceed the

+50% cost estimate accuracy.

2.2 The FFS states there is uncertainty on the acceptability of the RIM material mixed with

municipal solid waste (MSW) material for offsite disposal and this assumption would

need to be verified during the Remedial Design (Subsection 6.2.4.3.2). In general,

before determining the acceptability of any of the excavation alternatives, it is

recommended that all transportation and disposal issues and costs be fully considered

and clarified within the evaluations provided.

2.3 The FFS indicates that the extent of RIM material will be verified during excavation.

These confirmation activities will impact the progress of work and as indicated in the

FFS, will reduce the efficiency of the excavation, thus lengthening the duration of the

full and partial excavation alternatives. This reduction in efficiency will add to the

schedule and cost uncertainty by further impacting the accuracy of the estimates. As

indicated in the FFS, the excavation alternatives require significant excavation and

relocation of municipal solid waste (MSW) materials.

2.4 The FFS also raises the issues of bird and odor control and states mitigation measures

will be instituted. Mitigation measures will help reduce odor and potential bird

nuisance issues. However, the need to excavate and expose the MSW to ambient air

and new oxygen sources and the relocation of the MSW material has a high potential for

odor releases regardless to institution of mitigation measures, as noted in the FFS.

These issues may not only be undervalued by current cost and schedule considerations,

but may also be a significant public issue, particularly for the relatively long durations

associated with the excavation schedules. The Federal Aviation Administration also

expressed significant concerns with bird issues and issues related to long exposures to

MSW materials during extended periods of excavation.

2.5 The excavation plans require significant double handling of non-RIM material. The cost

was significantly impacted by implementation of detailed excavation versus mass

excavation. Changes in the amount and extent of intermingling of the RIM and non-RIM

material will impact the quantities being handled, and therefore the rate of excavation

and associated costs. Also as indicated in the FFS, there remains a high degree of

uncertainty in regards to the means and ability to separate the RIM from the MSW that

would not be established until the Remedial Design phase of the project which could

also increase the time and cost of the project. In the FFS, it was suggested that a pilot

scale type study would be conducted to further address this issue; however, no cost was

allocated within the cost estimate for this type of study within the excavation

alternatives.


Schedule Specific Comments

Following are comments that are specific to the schedule. These comments are based primarily on

the review of Appendix J-Estimated Project Schedules of the FFS. For ease of review and reference,

the comments that follow have been first been categorized as General and Alternative-Specific

Comments, then within each of these comment categories, comments regarding the schedule

format and logic are provided first, followed by content-specific schedule comments.

General Schedule Comments

3. The schedule methodology suggests that durations are resource and calendar driven and

that the activities are not resource-leveled or balanced. It is understood that activities that

are occurring in parallel have not been synchronized and that only the critical activity

(longest calendar duration) were considered as the drivers of project duration. Therefore,

using this approach, overall conservative (but very limited on logic dependencies) schedules

have been developed for FFS alternatives.

4. The schedule methodology suggests the schedules were developed with some “task

dependency logic”; furthermore, the methodology declares that logic was incorporated “as

needed”. Using this approach, would it would be assumed that the schedule was developed

following a Critical Path Method (CPM). However, the CPM relies on complete logic of all

planned events, even if they are not critical drivers. Based on our review of the alternative

project schedules, there are a summary or hammock activities that appear to contain

completed logic ties, but those activities not logically tied to their dependencies. Using this

approach it is difficult for an independent reviewer to objectively trace or follow the logic to

validate the critical sequence.

5. Typically for a CPM duration activity schedule, electronic generated and associated

illustrated schedules would designate a better identifiable method (i.e., use of consistent

color schemes [red color throughout]), to identify the tasks that would be on the critical

path. By review of review of the copy and electronic files, and through reverse engineering,

we believe there has been an attempt to do this manually (by selection of a red color

scheme to indicate the critical path) by the selection of the longest duration activities within

tasks, then construction of the overall critical path from longest durations from the tasks,

while also designating other colors for the other activities (blue color) for those tasks that

are not on the critical path. However, limited explanation is provided to support this

observation and the schedule presentations in Appendix J are very hard to follow. It is

suggested that for the final schedule presentations it would be better to use only one

designated color scheme (e.g., red throughout) to show the overall critical path, then use

another color to show longest durations activities within a task that do not have an impact

on the critical path, and another color(s) to show those activities within Tasks that are just


shown for information or accountability that have little or no impact on the critical path. It

is also suggested that a legend be provided on the detailed project schedule illustrations to

better define the importance of the color scheme used.

6. Project schedule durations (time to reach remedial action objectives) for the alternatives in

the Executive Summary did not match the projection schedule durations determined in

Appendix J. The differences are shown below:

Alternative Ex Sum Duration Appendix J

ROD-Selected Remedy Cap 2.8 year 1.8 years

UMTCRA Cap 2.8 years 2.8 years

Full Excavation 14.9 years 13.6 years

Partial Excavation (5.92 pCi/g) 5.8 years 4.0 years

Partial Excavation (1000 pCi/g) 8.6 years 7.3 years

It is assumed that Appendix J is correct based on the backup provided for schedules.

Clarification is requested to verify which schedule durations are correct.

7. Although a brief explanation of the method used to determine durations was provided, an

example to demonstrate how cost information was used to determine activity durations

should have been provided to allow reviewers a better understanding of how activity

durations were determined (e.g., from cost estimates: durations=quantities (project specific

inputs)/daily construction rates (as defined by reference source RS Means)).

8. The estimated length of construction durations listed for the ROD-selected remedy cap and

the UMTRCA cap provided in the project schedules in Appendix J (1.8 years) are slightly

higher than those defined and used in the Cost Estimates in Appendix K (1.7 years). It is

suggested for consistency that the durations be clarified and that only one duration be used

for both assessments.

ROD-Selected Remedy Cap Alternative Schedule Comments

9. Within the detailed schedules for this alternative, the “Clean Frac Tanks” and “Clean

Leachate Frac Tanks” activities (IDs 44, 122, and 132) are highlighted red in the Gantt Chart

illustration, suggesting they are critical activities in the overall project sequence. In a typical

CPM schedule, these activities would not be considered as major construction events

(critical driver). However because in this instance they have long activity durations, they

appears as major contributors for the schedule of this Alternative. This is example of the

consideration defined by previous comments 3-5. An additional explanation for justification

for this type of activities’ criticality is recommended because this type of activity would not


normally be considered a major construction event that would normally contribute to the

overall project duration.

10. The logic displayed within the schedule appears to suggest that the clay layer material

acquisition and staging cannot begin until the bio-intrusion layer construction has been

completed. It also appears as if the acquisition of the clay layer material is weather

constrained. Because of these factors, construction appears to be halted for 5+ months

when clay acquisition is not possible and delayed an additional 2 months while it is

delivered. This duration contributes to the overall scenario duration and could likely be

mitigated by better material planning, storage, and staging. A similar condition exists within

the schedule for the bio-intrusion layer, yet is less impactful – 1 month.

UMTRCA Cap Alternative

11. The same duration as the ROD-selected remedy cap is assumed. Although the ROD-selected

cap and UMCTRA have the same overall thickness (~5.5 ft thick) the similar assumption of

similar duration wouldn’t seem quite correct since the UMCTA cap appears to be more

complex to build (more layers of different materials than the ROD-selected remedy cap).

However, assuming all activities and durations were the same up to and following the final

cover installation (which is actually the longest duration activity of the schedule), a

verification check using the cost estimate duration calculations was conducted and the final

cover durations for longest individual layer tasks for the two alternatives were within a few

days of each other. Therefore, the assumption that an equal duration of these two

alternatives occurs appears to be valid.

12. The similarities between the UMTRCA Cap method and the ROD-selected engineered cap

are justifiably similar; however, this is only the case in the event that the material

acquisition constraints are addressed. These two scenarios would be very similar in

construction duration; however, similar to the concern presented in Comment 10, the actual

acquisition and delivery of materials could result in a very different overall duration of the

two methods, depending on when the schedules are oriented to a calendar, and when the

construction starts on the impacted layers.

Full Excavation Alternative

13. There are large periods of duration within the detailed version of the schedule where no

activities are displayed as critical. This is the case between mid-2019 to early 2022, mid-

2022 to mid-2025, and mid-2026 to early 2029. Driving activities occur during these times,

but are not logically tied in a way that would ensure critical path logic is correct and can be

traced and verified.

14. Budgeted weather days (dewatering and lack of productivity) should be scheduled on the

critical path as a contingency layer for the overall duration of the scenario. These activities


should be based on NOAA weather data and should be driven by overall project duration

more so than cubic area of disturbed land. Budgeted weather days appear to be a driving

activity, yet logic is incomplete and the activity is not marked as critical. Also, there is no

methodology included in the report for how this duration was calculated.

Partial Excavation to 52.9 pCi/g Alternative

15. Similar to capping scenarios, there is a bio-intrusion layer material delay built into the

critical path of the schedule that increases the project duration by a couple months. This

should be optimized and avoided.

16. Similar to the capping scenarios, there are tank cleaning activities on the critical path that

typically would not be considered as major construction events or contribute to the overall

project duration (see comment 9).

17. Similar to the full excavation scenario, there are periods of duration within the detailed

version of the schedule where no activities are displayed as critical. This is the case in mid-

2019 and early 2020.

Partial Excavation to 1000 pCi/g Alternative








version of the schedule where no activities are displayed as critical. This is the case in early


Cost Estimate-Specific Comments

The following are comments provided primarily based on the review of Appendix K-Estimated Costs for the Remedial Alternatives. In addition to Appendix K, Appendix G-Conceptual Environmental Monitoring Programs was also reviewed to verify the basis for monitoring costs. For ease of review, the cost estimate comments have been categorized into General Cost Estimate Comments and Alternative-Specific Cost Estimate Comments.

General Cost Estimate Comments

Based on the review of Appendix K-Estimated Costs for the Remedial Alternatives, following are cost-specific comments for the ROD-selected remedy alternative that generally apply to other Alternatives.


21. The quantities of items used in the estimates were only spot checked and appeared to be

reasonable for the cost task and activity items defined.

22. The unit costs were primarily based on the 2017 RS Means on-line database. RS Means is a

reliable source for FS estimates especially those related to typical construction-related

activities such as those used for the cap and excavation related alternatives. Pertinent

reference information was provided to verify the detail of the unit costs as well as

information used for estimating project schedule durations as defined previously.

23. Using RS Means assumes following: unit cost rates for Labor are fully burdened; 100%

productivity; total costs includes Contractor overhead and profit of 10% on materials plus

sales tax, 15% on labor plus burden, and 10% on equipment. Bridgeton taxes of 7.4% are

applied to all work in the cost estimates. This appears to be a duplication in costs since sales

tax is already included on unit cost items obtained from RS Means (i.e., materials costs).

24. Although the disposal of facilities could not ensure capacity would be available for future

disposal activities, the use of “turn-key” unit costs from facilities that could potentially

receive this type of waste seems to be appropriate for this FFS, although the basis of these

estimates were primary based on the disposal of RIM soil and not RIM MSW (which is not

typically disposed of at these facilities).

25. The contingency (bid and scope contingencies) and professional services (Project

Management, Engineering Design, and Construction Management) percentages were

obtained and applied to capital costs from the EPA’s FS cost guidance A Guide to Developing

and Documenting Cost Estimates During the Feasibility Study (EPA 540-R-00-002) appear to

be appropriate for this FFS. Based on EPA’s FS cost guidance, the contingencies

(percentages for scope and bid) are typically applied first to the capital costs, then the

professional services costs percentages are applied to the combination of the capital costs

and contingencies. Although this order method was reversed in the cost estimates shown in

Appendix K (with professional services percentages applied first, then contingency on the

subtotal of capital cost and professional services), the overall construction (capital) costs

from either method results in the same values.

26. Based upon the conceptual level of design maturity for the FFS, the percentage of 10.0% of

scope contingency for the cap alternatives appears to be reasonable. However, it should be

noted that based on RS Mean, the scope contingency for these types of activities would be

3.0% at the working drawing stage.

27. The scope contingency of 55 percent (maximum recommended percentage defined in EPA’s

FS cost guidance) for on-site excavation activities seems fairly reasonable based on the large

amount of uncertainties defined (e.g., estimated volumes of RIM soil/MSW requiring


disposal, uncertainty of radiation surveying and confirmatory sampling required, double

handling of materials, production rates, etc.), plus the indication that the cost of physical

segregation/separation and radiological segregation/separation cannot be determined at

this time.

28. There appears to be some duplication of Construction Management costs because

construction management personnel are included in the itemized Temporary Construction

Facilities/Utilities/Personnel and then applied as a percentage to the overall Construction

Costs.

29. For present worth costs, not only were annual and periodic operations, maintenance, and

monitoring (OM&M) costs discounted, but capital costs were also discounted, for proposed

implementation durations. Although this seems to be an appropriate approach, it is

assumed that the durations within the construction cost calculations were somehow used to

proportion these costs out; however, no information was provided to clarify the method

used to provide these breakdowns.

30. The evaluation of presents worth costs using the standard EPA FS cost guidance discount

rate of 7% is appropriate. Justification to evaluate present worth using the OMB discount

rate of 0.7%, and evaluation of OM&M costs for 30-years (EPA FS guidance standard) as well

as periods of 200 years and 1000 years seems reasonable, although more limited durations

for the excavation alternatives may be more appropriate.

No Action Alternative Cost Estimate Comments

31. Based on the application of different discount rates (7%, 0.7%, and no rate) at different time

frames (30 years, 200 years, 1,000 years), it appears that after 200 years (if not sooner) the

present worth at the discount rate of 7% does not significantly change, while present worth

values for lower discount rates and longer durations would continue to increase.

ROD-Selected Remedy Cap Alternative Cost Estimate Comments

32. All activities defined for the ROD-selected remedy alternative appear to be accounted for by

primary capital construction costs, ancillary construction costs (radiological surveys through

institutional controls), and both annual and periodic OM&M costs provided in the cost

estimate.

33. In Appendix K-2, for clarification with other task-subject construction costs, suggest adding a

note to storm water monitoring and inspection and air monitoring costs that the applicable

number of quarters needs to be applied to these quarterly unit costs.

34. Based on the review of monitoring costs versus the descriptions of proposed monitoring

programs defined in Appendix G, the following observations were noted:


Overall, the scope of monitoring activities planned for this alternative in Appendix G

covered in detail what would be required especially at the FS level.

Although costs were provided in the estimate for storm water monitoring during

construction, no details were provided in the descriptions in Appendix G that define

or discuss the need for these activities. Suggest an additional description of this

monitoring activity be added to Appendix G.

The number of groundwater wells (24 wells with 12 new wells and 12 existing wells)

and landfill gas wells (31 wells) defined to be installed and monitored match in the

text for Appendix G and the cost estimate, but do not match the number provided

in the summary table (Table 6) in Appendix G. Suggest correcting the number of

groundwater wells and gas wells in Table 6.

35. The ROD-selected remedy cost discussion in Section 6.2.2.7 (page 274) of FFS refers to

additional handling, sampling analysis, shipping and treatment cost for mixed waste. Clarify

whether this is needed in cost estimate for this alternative or not and include as necessary.

UMTCRA Cap Alternative Cost Estimate Comments

36. All activities defined for the UMTCRA cap alternative appear to be accounted for by primary

capital construction costs, ancillary construction costs (radiological surveys through


estimate.

37. Comments 33 and 34 also apply to this alternative.

38. Comment 35 also applies to this alternative, but in citation is in Section 6.2.3.7 (page 306 of

FFS). Also revise reference from ROD-selected remedy to UMTCRA cap if this applies.

39. Cost differences between the UMTCRA cap versus ROD-selected remedy cap were spot

checked and the only differences were in capital cost of final cover layers and associated

applied contingencies and professional services allocations (percentages of the capital

costs). The differing final cover layer costs were checked and verified.

Full Excavation Alternative Cost Estimate Comments

40. All activities defined for the Full Excavation alternative appear to be accounted for by



estimate.



42. The description of Post-Construction landfill gas monitoring provided in Appendix G, defines

that only landfill gas monitoring for radon would be provided for this alternative. However,

the cost estimate for this alternative also includes costs for radon flux monitoring ($27,000).

Suggest that the radon flux monitoring be removed from the cost estimate because full

excavation and removal of RIM is provided by this alternative.

43. The monitoring cost estimate and the text provided in Appendix G indicate that a 5-year

review would be included as part of this alternative. However, the alternative description in

Section 5.5.6 of the FFS (page 206) indicates that a 5-year review would not be necessary.

Clarification needs to be provided to which assumption is correct.

Partial Excavation to 52.9 pCi/g, but no greater than 16 ft, Alternative Cost Estimate Comments

44. All activities defined for the Partial Excavation to 52.9 pCi/g, but no greater than 16 ft,

alternative appear to be accounted for by primary capital construction costs, ancillary

construction costs (radiological surveys through institutional controls), and both annual and

periodic OM&M costs provided in the cost estimate.


Partial Excavation to 1000 pCi/g Alternative Cost Estimate Comments

46. All activities defined for the Partial Excavation to 1,000 pCi/g alternative appear to be

accounted for by primary capital construction costs, ancillary construction costs (radiological

surveys through institutional controls), and both annual and periodic OM&M costs provided

in the cost estimate.


West Lake Landfill OU1– Feasibility Study Cost and Schedule - PAGE 2

MEMORANDUM

Subject:West Lake Landfill OU1– Feasibility Study Cost and Schedule Review

Date:October 5, 2017

To: Chris Jump (USEPA)

From: Marshall Claxton (BVSPC)


General FS Comments


1. Although increased costs are incurred, the revised UMTRCA landfill cap will provide increased protection from the ROD-selected remedy cap alternative as identified in the FFS. The additional measures that appear to provide added value include the following:

· The relocated biointrusion layer will provide increased protection to the infiltration barriers.

· The reduced clay permeability will substantially reduce infiltration through the cap.

· The drainage layer above the infiltration barrier will reduce infiltration through the cap.

· The inclusion of the geosynthetic clay layer (GCL) on the flatter slopes will protect the underlying low permeability clay and provide additional infiltration protection.

2. The following general observations were noted which could have cost and schedule impact for the excavation alternatives:

2.1 The accuracy of the identification of the extent of the targeted RIM material is critical to the execution of the excavation plans. Significant changes in the identified RIM extent will impact the sequencing of the excavations. The FFS consistently indicates the extent of the RIM material based on the 50% estimate is anticipated to underestimate the volume of RIM material. Subsection 5.5.1 states a value of 2 over the 50% estimate is possible. Therefore, the schedule and estimate for the cost and time of completion of the excavation options is subject to considerable uncertainty. This may exceed the +50% cost estimate accuracy.

2.2 The FFS states there is uncertainty on the acceptability of the RIM material mixed with municipal solid waste (MSW) material for offsite disposal and this assumption would need to be verified during the Remedial Design (Subsection 6.2.4.3.2). In general, before determining the acceptability of any of the excavation alternatives, it is recommended that all transportation and disposal issues and costs be fully considered and clarified within the evaluations provided.

2.3 The FFS indicates that the extent of RIM material will be verified during excavation. These confirmation activities will impact the progress of work and as indicated in the FFS, will reduce the efficiency of the excavation, thus lengthening the duration of the full and partial excavation alternatives. This reduction in efficiency will add to the schedule and cost uncertainty by further impacting the accuracy of the estimates. As indicated in the FFS, the excavation alternatives require significant excavation and relocation of municipal solid waste (MSW) materials.

2.4 The FFS also raises the issues of bird and odor control and states mitigation measures will be instituted. Mitigation measures will help reduce odor and potential bird nuisance issues. However, the need to excavate and expose the MSW to ambient air and new oxygen sources and the relocation of the MSW material has a high potential for odor releases regardless to institution of mitigation measures, as noted in the FFS. These issues may not only be undervalued by current cost and schedule considerations, but may also be a significant public issue, particularly for the relatively long durations associated with the excavation schedules. The Federal Aviation Administration also expressed significant concerns with bird issues and issues related to long exposures to MSW materials during extended periods of excavation.

2.5 The excavation plans require significant double handling of non-RIM material. The cost was significantly impacted by implementation of detailed excavation versus mass excavation. Changes in the amount and extent of intermingling of the RIM and non-RIM material will impact the quantities being handled, and therefore the rate of excavation and associated costs. Also as indicated in the FFS, there remains a high degree of uncertainty in regards to the means and ability to separate the RIM from the MSW that would not be established until the Remedial Design phase of the project which could also increase the time and cost of the project. In the FFS, it was suggested that a pilot scale type study would be conducted to further address this issue; however, no cost was allocated within the cost estimate for this type of study within the excavation alternatives.


Following are comments that are specific to the schedule. These comments are based primarily on the review of Appendix J-Estimated Project Schedules of the FFS. For ease of review and reference, the comments that follow have been first been categorized as General and Alternative-Specific Comments, then within each of these comment categories, comments regarding the schedule format and logic are provided first, followed by content-specific schedule comments.


3. The schedule methodology suggests that durations are resource and calendar driven and that the activities are not resource-leveled or balanced. It is understood that activities that are occurring in parallel have not been synchronized and that only the critical activity (longest calendar duration) were considered as the drivers of project duration. Therefore, using this approach, overall conservative (but very limited on logic dependencies) schedules have been developed for FFS alternatives.

4. The schedule methodology suggests the schedules were developed with some “task dependency logic”; furthermore, the methodology declares that logic was incorporated “as needed”. Using this approach, would it would be assumed that the schedule was developed following a Critical Path Method (CPM). However, the CPM relies on complete logic of all planned events, even if they are not critical drivers. Based on our review of the alternative project schedules, there are a summary or hammock activities that appear to contain completed logic ties, but those activities not logically tied to their dependencies. Using this approach it is difficult for an independent reviewer to objectively trace or follow the logic to validate the critical sequence.

5. Typically for a CPM duration activity schedule, electronic generated and associated illustrated schedules would designate a better identifiable method (i.e., use of consistent color schemes [red color throughout]), to identify the tasks that would be on the critical path. By review of review of the copy and electronic files, and through reverse engineering, we believe there has been an attempt to do this manually (by selection of a red color scheme to indicate the critical path) by the selection of the longest duration activities within tasks, then construction of the overall critical path from longest durations from the tasks, while also designating other colors for the other activities (blue color) for those tasks that are not on the critical path. However, limited explanation is provided to support this observation and the schedule presentations in Appendix J are very hard to follow. It is suggested that for the final schedule presentations it would be better to use only one designated color scheme (e.g., red throughout) to show the overall critical path, then use another color to show longest durations activities within a task that do not have an impact on the critical path, and another color(s) to show those activities within Tasks that are just shown for information or accountability that have little or no impact on the critical path. It is also suggested that a legend be provided on the detailed project schedule illustrations to better define the importance of the color scheme used.

6. Project schedule durations (time to reach remedial action objectives) for the alternatives in the Executive Summary did not match the projection schedule durations determined in Appendix J. The differences are shown below:

Alternative

Ex Sum Duration

Appendix J

ROD-Selected Remedy Cap

2.8 year

1.8 years

UMTCRA Cap

2.8 years

2.8 years

Full Excavation

14.9 years

13.6 years

Partial Excavation (5.92 pCi/g)

5.8 years

4.0 years

Partial Excavation (1000 pCi/g)

8.6 years

7.3 years

It is assumed that Appendix J is correct based on the backup provided for schedules. Clarification is requested to verify which schedule durations are correct.

7. Although a brief explanation of the method used to determine durations was provided, an example to demonstrate how cost information was used to determine activity durations should have been provided to allow reviewers a better understanding of how activity durations were determined (e.g., from cost estimates: durations=quantities (project specific inputs)/daily construction rates (as defined by reference source RS Means)).

8. The estimated length of construction durations listed for the ROD-selected remedy cap and the UMTRCA cap provided in the project schedules in Appendix J (1.8 years) are slightly higher than those defined and used in the Cost Estimates in Appendix K (1.7 years). It is suggested for consistency that the durations be clarified and that only one duration be used for both assessments.


9. Within the detailed schedules for this alternative, the “Clean Frac Tanks” and “Clean Leachate Frac Tanks” activities (IDs 44, 122, and 132) are highlighted red in the Gantt Chart illustration, suggesting they are critical activities in the overall project sequence. In a typical CPM schedule, these activities would not be considered as major construction events (critical driver). However because in this instance they have long activity durations, they appears as major contributors for the schedule of this Alternative. This is example of the consideration defined by previous comments 3-5. An additional explanation for justification for this type of activities’ criticality is recommended because this type of activity would not normally be considered a major construction event that would normally contribute to the overall project duration.

10. The logic displayed within the schedule appears to suggest that the clay layer material acquisition and staging cannot begin until the bio-intrusion layer construction has been completed. It also appears as if the acquisition of the clay layer material is weather constrained. Because of these factors, construction appears to be halted for 5+ months when clay acquisition is not possible and delayed an additional 2 months while it is delivered. This duration contributes to the overall scenario duration and could likely be mitigated by better material planning, storage, and staging. A similar condition exists within the schedule for the bio-intrusion layer, yet is less impactful – 1 month.


11. The same duration as the ROD-selected remedy cap is assumed. Although the ROD-selected cap and UMCTRA have the same overall thickness (~5.5 ft thick) the similar assumption of similar duration wouldn’t seem quite correct since the UMCTA cap appears to be more complex to build (more layers of different materials than the ROD-selected remedy cap). However, assuming all activities and durations were the same up to and following the final cover installation (which is actually the longest duration activity of the schedule), a verification check using the cost estimate duration calculations was conducted and the final cover durations for longest individual layer tasks for the two alternatives were within a few days of each other. Therefore, the assumption that an equal duration of these two alternatives occurs appears to be valid.

12. The similarities between the UMTRCA Cap method and the ROD-selected engineered cap are justifiably similar; however, this is only the case in the event that the material acquisition constraints are addressed. These two scenarios would be very similar in construction duration; however, similar to the concern presented in Comment 10, the actual acquisition and delivery of materials could result in a very different overall duration of the two methods, depending on when the schedules are oriented to a calendar, and when the construction starts on the impacted layers.


13. There are large periods of duration within the detailed version of the schedule where no activities are displayed as critical. This is the case between mid-2019 to early 2022, mid-2022 to mid-2025, and mid-2026 to early 2029. Driving activities occur during these times, but are not logically tied in a way that would ensure critical path logic is correct and can be traced and verified.

14. Budgeted weather days (dewatering and lack of productivity) should be scheduled on the critical path as a contingency layer for the overall duration of the scenario. These activities should be based on NOAA weather data and should be driven by overall project duration more so than cubic area of disturbed land. Budgeted weather days appear to be a driving activity, yet logic is incomplete and the activity is not marked as critical. Also, there is no methodology included in the report for how this duration was calculated.


15. Similar to capping scenarios, there is a bio-intrusion layer material delay built into the critical path of the schedule that increases the project duration by a couple months. This should be optimized and avoided.

16. Similar to the capping scenarios, there are tank cleaning activities on the critical path that typically would not be considered as major construction events or contribute to the overall project duration (see comment 9).

17. Similar to the full excavation scenario, there are periods of duration within the detailed version of the schedule where no activities are displayed as critical. This is the case in mid-2019 and early 2020.


18. Similar to capping scenarios, there is a bio-intrusion layer material delay built into the critical path of the schedule that increases the project duration by a couple months. This should be optimized and avoided.

19. Similar to the capping scenarios, there are tank cleaning activities on the critical path that typically would not be considered as major construction events or contribute to the overall project duration (see comment 9).

20. Similar to the full excavation scenario, there are periods of duration within the detailed version of the schedule where no activities are displayed as critical. This is the case in early 2019 and early 2021.





21. The quantities of items used in the estimates were only spot checked and appeared to be reasonable for the cost task and activity items defined.

22. The unit costs were primarily based on the 2017 RS Means on-line database. RS Means is a reliable source for FS estimates especially those related to typical construction-related activities such as those used for the cap and excavation related alternatives. Pertinent reference information was provided to verify the detail of the unit costs as well as information used for estimating project schedule durations as defined previously.

23. Using RS Means assumes following: unit cost rates for Labor are fully burdened; 100% productivity; total costs includes Contractor overhead and profit of 10% on materials plus sales tax, 15% on labor plus burden, and 10% on equipment. Bridgeton taxes of 7.4% are applied to all work in the cost estimates. This appears to be a duplication in costs since sales tax is already included on unit cost items obtained from RS Means (i.e., materials costs).

24. Although the disposal of facilities could not ensure capacity would be available for future disposal activities, the use of “turn-key” unit costs from facilities that could potentially receive this type of waste seems to be appropriate for this FFS, although the basis of these estimates were primary based on the disposal of RIM soil and not RIM MSW (which is not typically disposed of at these facilities).

25. The contingency (bid and scope contingencies) and professional services (Project Management, Engineering Design, and Construction Management) percentages were obtained and applied to capital costs from the EPA’s FS cost guidance A Guide to Developing and Documenting Cost Estimates During the Feasibility Study (EPA 540-R-00-002) appear to be appropriate for this FFS. Based on EPA’s FS cost guidance, the contingencies (percentages for scope and bid) are typically applied first to the capital costs, then the professional services costs percentages are applied to the combination of the capital costs and contingencies. Although this order method was reversed in the cost estimates shown in Appendix K (with professional services percentages applied first, then contingency on the subtotal of capital cost and professional services), the overall construction (capital) costs from either method results in the same values.

26. Based upon the conceptual level of design maturity for the FFS, the percentage of 10.0% of scope contingency for the cap alternatives appears to be reasonable. However, it should be noted that based on RS Mean, the scope contingency for these types of activities would be 3.0% at the working drawing stage.

27. The scope contingency of 55 percent (maximum recommended percentage defined in EPA’s FS cost guidance) for on-site excavation activities seems fairly reasonable based on the large amount of uncertainties defined (e.g., estimated volumes of RIM soil/MSW requiring disposal, uncertainty of radiation surveying and confirmatory sampling required, double handling of materials, production rates, etc.), plus the indication that the cost of physical segregation/separation and radiological segregation/separation cannot be determined at this time.

28. There appears to be some duplication of Construction Management costs because construction management personnel are included in the itemized Temporary Construction Facilities/Utilities/Personnel and then applied as a percentage to the overall Construction Costs.

29. For present worth costs, not only were annual and periodic operations, maintenance, and monitoring (OM&M) costs discounted, but capital costs were also discounted, for proposed implementation durations. Although this seems to be an appropriate approach, it is assumed that the durations within the construction cost calculations were somehow used to proportion these costs out; however, no information was provided to clarify the method used to provide these breakdowns.

30. The evaluation of presents worth costs using the standard EPA FS cost guidance discount rate of 7% is appropriate. Justification to evaluate present worth using the OMB discount rate of 0.7%, and evaluation of OM&M costs for 30-years (EPA FS guidance standard) as well as periods of 200 years and 1000 years seems reasonable, although more limited durations for the excavation alternatives may be more appropriate.


31. Based on the application of different discount rates (7%, 0.7%, and no rate) at different time frames (30 years, 200 years, 1,000 years), it appears that after 200 years (if not sooner) the present worth at the discount rate of 7% does not significantly change, while present worth values for lower discount rates and longer durations would continue to increase.


32. All activities defined for the ROD-selected remedy alternative appear to be accounted for by primary capital construction costs, ancillary construction costs (radiological surveys through institutional controls), and both annual and periodic OM&M costs provided in the cost estimate.

33. In Appendix K-2, for clarification with other task-subject construction costs, suggest adding a note to storm water monitoring and inspection and air monitoring costs that the applicable number of quarters needs to be applied to these quarterly unit costs.

34. Based on the review of monitoring costs versus the descriptions of proposed monitoring programs defined in Appendix G, the following observations were noted:

· Overall, the scope of monitoring activities planned for this alternative in Appendix G covered in detail what would be required especially at the FS level.

· Although costs were provided in the estimate for storm water monitoring during construction, no details were provided in the descriptions in Appendix G that define or discuss the need for these activities. Suggest an additional description of this monitoring activity be added to Appendix G.

· The number of groundwater wells (24 wells with 12 new wells and 12 existing wells) and landfill gas wells (31 wells) defined to be installed and monitored match in the text for Appendix G and the cost estimate, but do not match the number provided in the summary table (Table 6) in Appendix G. Suggest correcting the number of groundwater wells and gas wells in Table 6.

35. The ROD-selected remedy cost discussion in Section 6.2.2.7 (page 274) of FFS refers to additional handling, sampling analysis, shipping and treatment cost for mixed waste. Clarify whether this is needed in cost estimate for this alternative or not and include as necessary.


36. All activities defined for the UMTCRA cap alternative appear to be accounted for by primary capital construction costs, ancillary construction costs (radiological surveys through institutional controls), and both annual and periodic OM&M costs provided in the cost estimate.


38. Comment 35 also applies to this alternative, but in citation is in Section 6.2.3.7 (page 306 of FFS). Also revise reference from ROD-selected remedy to UMTCRA cap if this applies.

39. Cost differences between the UMTCRA cap versus ROD-selected remedy cap were spot checked and the only differences were in capital cost of final cover layers and associated applied contingencies and professional services allocations (percentages of the capital costs). The differing final cover layer costs were checked and verified.


40. All activities defined for the Full Excavation alternative appear to be accounted for by primary capital construction costs, ancillary construction costs (radiological surveys through institutional controls), and both annual and periodic OM&M costs provided in the cost estimate.


42. The description of Post-Construction landfill gas monitoring provided in Appendix G, defines that only landfill gas monitoring for radon would be provided for this alternative. However, the cost estimate for this alternative also includes costs for radon flux monitoring ($27,000). Suggest that the radon flux monitoring be removed from the cost estimate because full excavation and removal of RIM is provided by this alternative.

43. The monitoring cost estimate and the text provided in Appendix G indicate that a 5-year review would be included as part of this alternative. However, the alternative description in Section 5.5.6 of the FFS (page 206) indicates that a 5-year review would not be necessary. Clarification needs to be provided to which assumption is correct.


44. All activities defined for the Partial Excavation to 52.9 pCi/g, but no greater than 16 ft, alternative appear to be accounted for by primary capital construction costs, ancillary construction costs (radiological surveys through institutional controls), and both annual and periodic OM&M costs provided in the cost estimate.



46. All activities defined for the Partial Excavation to 1,000 pCi/g alternative appear to be accounted for by primary capital construction costs, ancillary construction costs (radiological surveys through institutional controls), and both annual and periodic OM&M costs provided in the cost estimate.


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6

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From: Claxton, Marshall Sent: Thursday, October 05, 2017 10:25 AMTo: Jump, ChristineCc: Law, PrestonSubject: RE: FFS Schedule and Cost Estimate Review TM-West Lake LF OU1 Project Chris, Sorry try again this time with the attachments. Marshall ClaxtonBlack Veatch Special ProjectsPE Kansas/NebraskaO 913 458-6508M 913 [email protected]

From: Claxton, Marshall Sent: Thursday, October 05, 2017 10:19 AMTo: 'Jump, Christine'Cc: Law, PrestonSubject: FFS Schedule and Cost Estimate Review TM-West Lake LF OU1 Project Chris, Attached is the Technical Memorandum for our review of the West Lake LF OU1 FFS Schedule andCost Estimate. We have attached both a pdf version and the Word version of this memo just in caseyou would like to use word version to edit and/or provide with any other comments that you aregenerating. Overall we would say that that the information was very thorough and did not find a lot of majorissues with those two Appendices. In the process of our review, we also reviewed portions of theFFS and Appendix G (Monitoring Programs). We have incorporated our comments regardingschedule and cost on the FFS (where we noted them) and on Appendix G within this TM. Please let us know if you have any questions or comments on this information. Marshall ClaxtonBlack Veatch Special ProjectsPE Kansas/NebraskaO 913 458-6508

mailto:[email protected]

M 913 [email protected]

From: Jump, Christine [mailto:[email protected]] Sent: Thursday, September 21, 2017 12:28 PMTo: Claxton, MarshallCc: Law, Preston; Juett, Lynn; Fritz, KoniSubject: West Lake project, Contract No. EP-S7-05-06 Marshall- Attached are electronic copies of Appendices G and J of the August 25,2017 revised draft Final Feasibility Study, West Lake Landfill OperableUnit-1 (revised FFS). A copy of the revised FFS text and tables, andAppendix K will follow in separate emails. A full copy of the revised FFSwill be provided to you in a CD. Please review and provide comments on revised FFS appendices G, J, andK associated with costs and scheduling. EPA is not requesting that youreview the full revised FFS document at this time, but please use thedocument as necessary to assist your review of the cost and scheduleinformation. Please provide a Technical Review Memorandum forAppendices G, J and K within 14 days of receiving the Task Order andinitiating your review. I have also included a link to the public EPA West Lake website that has adocument library which contains draft versions of the RemedialInvestigation Addendum and other site related documents.https://semspub.epa.gov/src/collection/07/SC31560 Please do not initiate work on this project until you receive the final TaskOrder. Let me know if you have any questions Chris Jump, L.G.SUPR/MOKSUS EPA, Region [email protected](913) 551-7141 Mailing address: 11201 Renner Boulevard, Lenexa, KS 66219

mailto:[email protected]:[email protected]://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fsemspub.epa.gov%2Fsrc%2Fcollection%2F07%2FSC31560&data=02%7C01%7CClaxtonM%40bv.com%7C7a9d3bffbef34af15e2108d501162c44%7C7a53b4fce87d4c4699720570ac271b27%7C0%7C0%7C636416117837742702&sdata=bSoqK7%2BNcJCJdcSJIT7FgP2ykP3Lp88woIr3tNOGfSY%3D&reserved=0mailto:[email protected]

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MEMORANDUM

Subject: West Lake Landfill OU1– Feasibility Study Cost and Schedule Review

Date: October 5, 2017 To: Chris Jump (USEPA) From: Marshall Claxton (BVSPC)


General FS Comments


1. Although increased costs are incurred, the revised UMTRCA landfill cap will provide

increased protection from the ROD-selected remedy cap alternative as identified in the FFS.

The additional measures that appear to provide added value include the following:

The relocated biointrusion layer will provide increased protection to the infiltration

barriers.

The reduced clay permeability will substantially reduce infiltration through the cap.

The drainage layer above the infiltration barrier will reduce infiltration through the cap.

The inclusion of the geosynthetic clay layer (GCL) on the flatter slopes will protect the

underlying low permeability clay and provide additional infiltration protection.

2. The following general observations were noted which could have cost and schedule impact

for the excavation alternatives:

2.1 The accuracy of the identification of the extent of the targeted RIM material is critical to

the execution of the excavation plans. Significant changes in the identified RIM extent

will impact the sequencing of the excavations. The FFS consistently indicates the extent

of the RIM material based on the 50% estimate is anticipated to underestimate the

volume of RIM material. Subsection 5.5.1 states a value of 2 over the 50% estimate is

possible. Therefore, the schedule and estimate for the cost and time of completion of


the excavation options is subject to considerable uncertainty. This may exceed the

+50% cost estimate accuracy.

2.2 The FFS states there is uncertainty on the acceptability of the RIM material mixed with

municipal solid waste (MSW) material for offsite disposal and this assumption would

need to be verified during the Remedial Design (Subsection 6.2.4.3.2). In general,

before determining the acceptability of any of the excavation alternatives, it is

recommended that all transportation and disposal issues and costs be fully considered

and clarified within the evaluations provided.

2.3 The FFS indicates that the extent of RIM material will be verified during excavation.

These confirmation activities will impact the progress of work and as indicated in the

FFS, will reduce the efficiency of the excavation, thus lengthening the duration of the

full and partial excavation alternatives. This reduction in efficiency will add to the

schedule and cost uncertainty by further impacting the accuracy of the estimates. As

indicated in the FFS, the excavation alternatives require significant excavation and

relocation of municipal solid waste (MSW) materials.

2.4 The FFS also raises the issues of bird and odor control and states mitigation measures

will be instituted. Mitigation measures will help reduce odor and potential bird

nuisance issues. However, the need to excavate and expose the MSW to ambient air

and new oxygen sources and the relocation of the MSW material has a high potential for

odor releases regardless to institution of mitigation measures, as noted in the FFS.

These issues may not only be undervalued by current cost and schedule considerations,

but may also be a significant public issue, particularly for the relatively long durations

associated with the excavation schedules. The Federal Aviation Administration also

expressed significant concerns with bird issues and issues related to long exposures to

MSW materials during extended periods of excavation.

2.5 The excavation plans require significant double handling of non-RIM material. The cost

was significantly impacted by implementation of detailed excavation versus mass

excavation. Changes in the amount and extent of intermingling of the RIM and non-RIM

material will impact the quantities being handled, and therefore the rate of excavation

and associated costs. Also as indicated in the FFS, there remains a high degree of

uncertainty in regards to the means and ability to separate the RIM from the MSW that

would not be established until the Remedial Design phase of the project which could

also increase the time and cost of the project. In the FFS, it was suggested that a pilot

scale type study would be conducted to further address this issue; however, no cost was

allocated within the cost estimate for this type of study within the excavation

alternatives.

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Following are comments that are specific to the schedule. These comments are based primarily on

the review of Appendix J-Estimated Project Schedules of the FFS. For ease of review and reference,

the comments that follow have been first been categorized as General and Alternative-Specific

Comments, then within each of these comment categories, comments regarding the schedule

format and logic are provided first, followed by content-specific schedule comments.


3. The schedule methodology suggests that durations are resource and calendar driven and

that the activities are not resource-leveled or balanced. It is understood that activities that

are occurring in parallel have not been synchronized and that only the critical activity

(longest calendar duration) were considered as the drivers of project duration. Therefore,

using this approach, overall conservative (but very limited on logic dependencies) schedules

have been developed for FFS alternatives.

4. The schedule methodology suggests the schedules were developed with some “task

dependency logic”; furthermore, the methodology declares that logic was incorporated “as

needed”. Using this approach, would it would be assumed that the schedule was developed

following a Critical Path Method (CPM). However, the CPM relies on complete logic of all

planned events, even if they are not critical drivers. Based on our review of the alternative

project schedules, there are a summary or hammock activities that appear to contain

completed logic ties, but those activities not logically tied to their dependencies. Using this

approach it is difficult for an independent reviewer to objectively trace or follow the logic to

validate the critical sequence.

5. Typically for a CPM duration activity schedule, electronic generated and associated

illustrated schedules would designate a better identifiable method (i.e., use of consistent

color schemes [red color throughout]), to identify the tasks that would be on the critical

path. By review of review of the copy and electronic files, and through reverse engineering,

we believe there has been an attempt to do this manually (by selection of a red color

scheme to indicate the critical path) by the selection of the longest duration activities within

tasks, then construction of the overall critical path from longest durations from the tasks,

while also designating other colors for the other activities (blue color) for those tasks that

are not on the critical path. However, limited explanation is provided to support this

observation and the schedule presentations in Appendix J are very hard to follow. It is

suggested that for the final schedule presentations it would be better to use only one

designated color scheme (e.g., red throughout) to show the overall critical path, then use

another color to show longest durations activities within a task that do not have an impact

on the critical path, and another color(s) to show those activities within Tasks that are just

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shown for information or accountability that have little or no impact on the critical path. It

is also suggested that a legend be provided on the detailed project schedule illustrations to

better define the importance of the color scheme used.

6. Project schedule durations (time to reach remedial action objectives) for the alternatives in

the Executive Summary did not match the projection schedule durations determined in

Appendix J. The differences are shown below:

Alternative Ex Sum Duration Appendix J

ROD-Selected Remedy Cap 2.8 year 1.8 years

UMTCRA Cap 2.8 years 2.8 years

Full Excavation 14.9 years 13.6 years

Partial Excavation (5.92 pCi/g) 5.8 years 4.0 years

Partial Excavation (1000 pCi/g) 8.6 years 7.3 years

It is assumed that Appendix J is correct based on the backup provided for schedules.

Clarification is requested to verify which schedule durations are correct.

7. Although a brief explanation of the method used to determine durations was provided, an

example to demonstrate how cost information was used to determine activity durations

should have been provided to allow reviewers a better understanding of how activity

durations were determined (e.g., from cost estimates: durations=quantities (project specific

inputs)/daily construction rates (as defined by reference source RS Means)).

8. The estimated length of construction durations listed for the ROD-selected remedy cap and

the UMTRCA cap provided in the project schedules in Appendix J (1.8 years) are slightly

higher than those defined and used in the Cost Estimates in Appendix K (1.7 years). It is

suggested for consistency that the durations be clarified and that only one duration be used

for both assessments.


9. Within the detailed schedules for this alternative, the “Clean Frac Tanks” and “Clean

Leachate Frac Tanks” activities (IDs 44, 122, and 132) are highlighted red in the Gantt Chart

illustration, suggesting they are critical activities in the overall project sequence. In a typical

CPM schedule, these activities would not be considered as major construction events

(critical driver). However because in this instance they have long activity durations, they

appears as major contributors for the schedule of this Alternative. This is example of the

consideration defined by previous comments 3-5. An additional explanation for justification

for this type of activities’ criticality is recommended because this type of activity would not

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normally be considered a major construction event that would normally contribute to the

overall project duration.

10. The logic displayed within the schedule appears to suggest that the clay layer material

acquisition and staging cannot begin until the bio-intrusion layer construction has been

completed. It also appears as if the acquisition of the clay layer material is weather

constrained. Because of these factors, construction appears to be halted for 5+ months

when clay acquisition is not possible and delayed an additional 2 months while it is

delivered. This duration contributes to the overall scenario duration and could likely be

mitigated by better material planning, storage, and staging. A similar condition exists within

the schedule for the bio-intrusion layer, yet is less impactful – 1 month.


11. The same duration as the ROD-selected remedy cap is assumed. Although the ROD-selected

cap and UMCTRA have the same overall thickness (~5.5 ft thick) the similar assumption of

similar duration wouldn’t seem quite correct since the UMCTA cap appears to be more

complex to build (more layers of different materials than the ROD-selected remedy cap).

However, assuming all activities and durations were the same up to and following the final

cover installation (which is actually the longest duration activity of the schedule), a

verification check using the cost estimate duration calculations was conducted and the final

cover durations for longest individual layer tasks for the two alternatives were within a few

days of each other. Therefore, the assumption that an equal duration of these two

alternatives occurs appears to be valid.

12. The similarities between the UMTRCA Cap method and the ROD-selected engineered cap

are justifiably similar; however, this is only the case in the event that the material

acquisition constraints are addressed. These two scenarios would be very similar in

construction duration; however, similar to the concern presented in Comment 10, the actual

acquisition and delivery of materials could result in a very different overall duration of the

two methods, depending on when the schedules are oriented to a calendar, and when the

construction starts on the impacted layers.


13. There are large periods of duration within the detailed version of the schedule where no

activities are displayed as critical. This is the case between mid-2019 to early 2022, mid-

2022 to mid-2025, and mid-2026 to early 2029. Driving activities occur during these times,

but are not logically tied in a way that would ensure critical path logic is correct and can be

traced and verified.

14. Budgeted weather days (dewatering and lack of productivity) should be scheduled on the

critical path as a contingency layer for the overall duration of the scenario. These activities

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should be based on NOAA weather data and should be driven by overall project duration

more so than cubic area of disturbed land. Budgeted weather days appear to be a driving

activity, yet logic is incomplete and the activity is not marked as critical. Also, there is no

methodology included in the report for how this duration was calculated.









version of the schedule where no activities are displayed as critical. This is the case in mid-










version of the schedule where no activities are displayed as critical. This is the case in early






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21. The quantities of items used in the estimates were only spot checked and appeared to be

reasonable for the cost task and activity items defined.

22. The unit costs were primarily based on the 2017 RS Means on-line database. RS Means is a

reliable source for FS estimates especially those related to typical construction-related

activities such as those used for the cap and excavation related alternatives. Pertinent

reference information was provided to verify the detail of the unit costs as well as

information used for estimating project schedule durations as defined previously.

23. Using RS Means assumes following: unit cost rates for Labor are fully burdened; 100%

productivity; total costs includes Contractor overhead and profit of 10% on materials plus

sales tax, 15% on labor plus burden, and 10% on equipment. Bridgeton taxes of 7.4% are

applied to all work in the cost estimates. This appears to be a duplication in costs since sales

tax is already included on unit cost items obtained from RS Means (i.e., materials costs).

24. Although the disposal of facilities could not ensure capacity would be available for future

disposal activities, the use of “turn-key” unit costs from facilities that could potentially

receive this type of waste seems to be appropriate for this FFS, although the basis of these

estimates were primary based on the disposal of RIM soil and not RIM MSW (which is not

typically disposed of at these facilities).

25. The contingency (bid and scope contingencies) and professional services (Project

Management, Engineering Design, and Construction Management) percentages were

obtained and applied to capital costs from the EPA’s FS cost guidance A Guide to Developing

and Documenting Cost Estimates During the Feasibility Study (EPA 540-R-00-002) appear to

be appropriate for this FFS. Based on EPA’s FS cost guidance, the contingencies

(percentages for scope and bid) are typically applied first to the capital costs, then the

professional services costs percentages are applied to the combination of the capital costs

and contingencies. Although this order method was reversed in the cost estimates shown in

Appendix K (with professional services percentages applied first, then contingency on the

subtotal of capital cost and professional services), the overall construction (capital) costs

from either method results in the same values.

26. Based upon the conceptual level of design maturity for the FFS, the percentage of 10.0% of

scope contingency for the cap alternatives appears to be reasonable. However, it should be

noted that based on RS Mean, the scope contingency for these types of activities would be

3.0% at the working drawing stage.

27. The scope contingency of 55 percent (maximum recommended percentage defined in EPA’s

FS cost guidance) for on-site excavation activities seems fairly reasonable based on the large

amount of uncertainties defined (e.g., estimated volumes of RIM soil/MSW requiring

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disposal, uncertainty of radiation surveying and confirmatory sampling required, double

handling of materials, production rates, etc.), plus the indication that the cost of physical

segregation/separation and radiological segregation/separation cannot be determined at

this time.

28. There appears to be some duplication of Construction Management costs because

construction management personnel are included in the itemized Temporary Construction

Facilities/Utilities/Personnel and then applied as a percentage to the overall Construction

Costs.

29. For present worth costs, not only were annual and periodic operations, maintenance, and

monitoring (OM&M) costs discounted, but capital costs were also discounted, for proposed

implementation durations. Although this seems to be an appropriate approach, it is

assumed that the durations within the construction cost calculations were somehow used to

proportion these costs out; however, no information was provided to clarify the method

used to provide these breakdowns.

30. The evaluation of presents worth costs using the standard EPA FS cost guidance discount

rate of 7% is appropriate. Justification to evaluate present worth using the OMB discount

rate of 0.7%, and evaluation of OM&M costs for 30-years (EPA FS guidance standard) as well

as periods of 200 years and 1000 years seems reasonable, although more limited durations

for the excavation alternatives may be more appropriate.


31. Based on the application of different discount rates (7%, 0.7%, and no rate) at different time

frames (30 years, 200 years, 1,000 years), it appears that after 200 years (if not sooner) the

present worth at the discount rate of 7% does not significantly change, while present worth

values for lower discount rates and longer durations would continue to increase.


32. All activities defined for the ROD-selected remedy alternative appear to be accounted for by



estimate.

33. In Appendix K-2, for clarification with other task-subject construction costs, suggest adding a

note to storm water monitoring and inspection and air monitoring costs that the applicable

number of quarters needs to be applied to these quarterly unit costs.

34. Based on the review of monitoring costs versus the descriptions of proposed monitoring

programs defined in Appendix G, the following observations were noted:

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Overall, the scope of monitoring activities planned for this alternative in Appendix G

covered in detail what would be required especially at the FS level.

Although costs were provided in the estimate for storm water monitoring during

construction, no details were provided in the descriptions in Appendix G that define

or discuss the need for these activities. Suggest an additional description of this

monitoring activity be added to Appendix G.

The number of groundwater wells (24 wells with 12 new wells and 12 existing wells)

and landfill gas wells (31 wells) defined to be installed and monitored match in the

text for Appendix G and the cost estimate, but do not match the number provided

in the summary table (Table 6) in Appendix G. Suggest correcting the number of

groundwater wells and gas wells in Table 6.

35. The ROD-selected remedy cost discussion in Section 6.2.2.7 (page 274) of FFS refers to

additional handling, sampling analysis, shipping and treatment cost for mixed waste. Clarify

whether this is needed in cost estimate for this alternative or not and include as necessary.


36. All activities defined for the UMTCRA cap alternative appear to be accounted for by primary

capital construction costs, ancillary construction costs (radiological surveys through


estimate.


38. Comment 35 also applies to this alternative, but in citation is in Section 6.2.3.7 (page 306 of

FFS). Also revise reference from ROD-selected remedy to UMTCRA cap if this applies.

39. Cost differences between the UMTCRA cap versus ROD-selected remedy cap were spot

checked and the only differences were in capital cost of final cover layers and associated

applied contingencies and professional services allocations (percentages of the capital

costs). The differing final cover layer costs were checked and verified.


40. All activities defined for the Full Excavation alternative appear to be accounted for by



estimate.


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42. The description of Post-Construction landfill gas monitoring provided in Appendix G, defines

that only landfill gas monitoring for radon would be provided for this alternative. However,

the cost estimate for this alternative also includes costs for radon flux monitoring ($27,000).

Suggest that the radon flux monitoring be removed from the cost estimate because full

excavation and removal of RIM is provided by this alternative.

43. The monitoring cost estimate and the text provided in Appendix G indicate that a 5-year

review would be included as part of this alternative. However, the alternative description in

Section 5.5.6 of the FFS (page 206) indicates that a 5-year review would not be necessary.

Clarification needs to be provided to which assumption is correct.


44. All activities defined for the Partial Excavation to 52.9 pCi/g, but no greater than 16 ft,

alternative appear to be accounted for by primary capital construction costs, ancillary

construction costs (radiological surveys through institutional controls), and both annual and

periodic OM&M costs provided in the cost estimate.



46. All activities defined for the Partial E

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