*DRAFT*

**LONG-TERM STEWARDSHIP**

**BASELINE PLANNING HANDBOOK**

September 2003

U.S. Department of Energy

National Nuclear Security Administration Service Center

Environmental Programs
Department![](media/image1.jpeg){width="5.048611111111111in"
height="1.1402777777777777in"}

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CONTENTS

Acronyms ii

[**1.0** **INTRODUCTION** 1](#introduction)

[1.1 LTS Background 1](#lts-background)

[1.2 Roles and Responsibilities 1](#roles-and-responsibilities)

[2.0 DOCUMENTING LTS PLANNING ACTIVITIES IN THE BASELINE
3](#documenting-lts-planning-activities-in-the-baseline)

[2.1 PCT Plan and LTS Plan Preparation
4](#pct-plan-and-lts-plan-preparation)

[2.2 Transitioning LTS Work 5](#transitioning-lts-work)

[2.3 Determining and Documenting LTS Phase Activities During the EM
Project Phase
7](#determining-and-documenting-lts-phase-activities-during-the-em-project-phase)

[2.4 Milestones 7](#milestones)

[2.5 Lifecycle Funding Needs 7](#lifecycle-funding-needs)

[3.0 LTS-PHASE BASELINE GUIDANCE 9](#lts-phase-baseline-guidance)

[3.1 Work Breakdown Structure (WBS) Development
9](#work-breakdown-structure-wbs-development)

[3.2 Risk Management and Analysis 12](#risk-management-and-analysis)

[3.3 Schedule 13](#schedule)

[3.4 Cost Estimating 13](#cost-estimating)

[3.5 Performance Measures 13](#performance-measures)

[4.0 PROJECT REPORTING 14](#project-reporting)

[4.1 IPABS-IS PEM 14](#ipabs-is-pem)

[4.2 Periodic LTS Updates and Performance Review
14](#periodic-lts-updates-and-performance-review)

[5.0 REFERENCES AND RESOURCES 15](#references-and-resources)

[6.0 Glossary 16](#glossary)

Appendix A - Critical Decision-4 Turnover and Closeout Requirements and
Template

Appendix B - Project Closure and Transition Plan Content and Checklists

Appendix C - Example LTS Plan Outline

Appendix D - Example WBS Template

Acronyms

CERCLA Comprehensive Environmental Restoration, Compensation, and
Liability Act

D&D decontamination and decommissioning

DOE U.S. Department of Energy

EM Office of Environmental Management

EP Environmental Programs Department

ER environmental restoration

*Handbook* Long-Term Stewardship Baseline Handbook

HQ DOE Headquarters

HSWA Hazardous and Solid Waste Amendments of 1984

IPABS Integrated Planning, Accounting, and Budgeting System

IPABS-IS PEM IPABS-Information System Program Execution Module

KCP Kansas City Plant

LANL Los Alamos National Laboratory

LTS Long-Term Environmental Stewardship

LTRA Long-Term Response Action

M&O management and operations

MOA memorandum of agreement

NFA No Further Action

NNSA National Nuclear Security Administration

NRDA Natural Resource Damage Assessments

PARS Project Assessment and Reporting System

PCT Plan Project Closure and Transition Plan

PRS potential release site

PSO Principal Secretarial Offices

RCRA Resource Conservation and Recovery Act

SNL Sandia National Laboratories

SNL/NM Sandia National Laboratories/New Mexico

TL Task Leader

WBS work breakdown structure

# INTRODUCTION 

The U.S. Department of Energy (DOE) National Nuclear Security
Administration (NNSA) Service Center Environmental Programs Department
(EP) acknowledges the following definition of long-term stewardship
(LTS):

> The proactive management approach toward sustainable use and
> protection of natural and cultural resources affected by DOE
> operations and operational legacies, including activities ensuring
> protection of human health and the environment following closure of
> Office of Environmental Management (EM) projects.

As EM projects move toward mission completion, planning, integrating,
and documenting LTS is increasingly important to help ensure smooth
transition to the site steward.

The purpose of the *LTS Baseline Handbook (Handbook)* is to provide
suggestions for properly documenting LTS planning and execution in EM
project life-cycle baselines (baselines). Due to the range of LTS
activities anticipated at sites and the magnitude of information
required in baselines, site offices are encouraged to use a graded
approach to integrate LTS planning into EM project closure and
transition. This *Handbook* is intended to provide approaches for
addressing LTS in baselines that have not already been documented in
existing EM guidance and requirements (e.g. DOE M 413.3-1).

The initial development of the Handbook began in the summer of 2001 when
it appeared that LTS planning guidance would not be forthcoming for the
non-closure sites. The initial Handbook was developed prior to the NNSA
reorganization and was oriented to provide guidance to those sites that
had reported through the Albuquerque Operations Office. Upon stand up of
the new NNSA organization, and the commensurate movement of management
responsibilities from Operation Offices to Site Offices, it became
necessary to update the Handbook to reflect NNSA's new structure.

The Handbook is intended to provide LTS planning information for all EM
projects at NNSA sites that will have LTS activities after EM mission
completion. Most of the LTS activities remaining at a site will related
to environmental restoration, however, legacy waste and decontamination
and decommissioning projects may also have LTS requirements.

This Handbook should be considered guidance for sites reporting through
EP. Although not guidance, the Handbook was also developed to provide
beneficial planning information for the NNSA sites managed independently
by the Site Offices. Other sites are also welcome to use the Handbook as
they find appropriate.

## LTS Background 

The draft *Long-Term Environmental Stewardship Strategic Plan* (DOE,
2002a) contains long-term stewardship principles, goals, and objectives
and both programmatic and site-specific planning assumptions. Strategic
Plan implementation is accomplished by incorporating LTS principles and
objectives into planning and operations, either through site-specific
LTS plans or other existing planning efforts and baseline scope, cost,
and schedule documentation. In addition, EM has distributed fact sheets
providing guidance on EM Completion and Transition of Long-Term Response
Action (LTRA) responsibilities. LTRA activities and responsibilities
outlined in the fact sheets are synonymous with LTS activities and
responsibilities described in this *Handbook*.

This *Handbook* outlines approaches for integrating LTS into baseline
documentation, based on site-specific planning. However, until
Secretarial policy regarding transition is finalized, the specific site
steward for NNSA sites cannot be identified or assigned.

## Roles and Responsibilities 

Organizational roles and responsibilities unique to LTS are:

-   DOE Headquarters (HQ)

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-   EM is responsible for planning for LTS, including developing LTS
    cost estimates and ensuring all activities necessary for closeout of
    the EM projects have occurred.

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-   NNSA, as site landlord, is responsible for all mission activities at
    NNSA sites, including coordination with EM and the site steward on
    LTS activities at the sites.

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```
-   NNSA Service Center Environmental Programs Department (EP) is
    responsible for supporting the NNSA site offices and for directly
    managing several EM projects. EP provides technical and programmatic
    expertise to support planning, implementation, and transition to
    LTS. EP also provides integration between the projects, other sites
    and HQ; HQ advocacy; site office technical and programmatic support;
    and assists with budget development.

-   Site Offices are responsible for LTS management, negotiating and
    evaluating performance measures, and incorporating LTS into
    management and operations (M&O) contracts.

-   M&O contractors are responsible for executing LTS pursuant to site
    steward requirements.

-   Other parties with a vested interest in LTS, including regulators,
    stakeholders, and other site tenants and lessees have
    responsibilities such as participating in advisory boards and
    providing land use planning input.

# DOCUMENTING LTS PLANNING ACTIVITIES IN THE BASELINE

Baseline documentation should include separately tracked and managed
project scope descriptions, costs, and schedules for LTS. This separate
tracking allows DOE to anticipate the resources necessary for LTS.
Primary baseline planning activities include:

-   Documenting EM Project closure activities and transition including
    preparing a Project Closure and Transition (PCT) Plan

-   Defining LTS and the developing the LTS Plan

-   Identifying LTS-phase activities, milestones, and life-cycle funding
    requirements.

![](media/image2.wmf)LTS should be integrated into existing baselines,
however, for budget purposes LTS for each project will be documented in
a unique Project Baseline Summary (PBS). EM Project Closeout and LTS
Phase baseline activities are described in Section 3.0. Figure 2.1
presents a generic timeline for EM Project completion and LTS
activities.

**Figure 2.1. EM Completion and Transition**

\*The term LTS is interchangeable with Long-term Response Action (LTRA)
as defined in the January 2003 EM Fact Sheet, "Definition of EM
Completion and DOE Site Closure."

The *Integrated Planning, Accounting, and Budgeting System (IPABS)
Handbook* (DOE, 2002b) contains generic, nonspecific site guidance for
preparing the LTS PBSs. EM developed the *Long-Term Stewardship Plan
Guidance for the Closure Sites* (DOE, 2002c) and the Office of Legacy
Management will be responsible, or share responsibility, for developing
additional LTS guidance.

## PCT Plan and LTS Plan Preparation

DOE M 413.3-1 requires that "All projects shall have a project
transition/closeout plan that clearly defines the basis for attaining
initial operating capability, full operating capability, or project
closeout, as applicable." EM Project planning also requires the
preparation of a LTS Plan during the transition period (Figure 2.1). The
EM Project baseline should include the scope, cost, and schedule for all
activities associated with preparing the PCT Plan, LTS Plan, and any
other document affecting transition to LTS. If these plans have not been
prepared, the scope, cost, and schedule for preparing them should be
included in the baseline. Sites have flexibility regarding integration
of LTS planning and LTS-phase activities into the work breakdown
structure (WBS) since no specific guidance on the WBS structure has been
provided by EM.

### PCT Plan-- Documenting EM Project Closure and Transition 

The PCT Plan is an internal document developed by project teams to
ensure systematic, efficient, and complete EM Project closure. It states
the necessary actions to administratively close-out the EM Project as
required to meet DOE M 413.3-1, RCRA/Hazardous and Solid Waste
Amendments of 1984 (HSWA), state, and other requirements.

The PCT Plan also describes the transfer process and LTS
responsibilities to be transferred from EM to the site steward. The
transfer process should take into consideration requirements for project
closeout as described in DOE M 413.3-1 and the EM National Focus Project
Fact Sheet, "EM Completion: Transitioning LTRA Responsibilities."

When the project is complete, long-term remediation systems are
operational, and surveillance, monitoring and maintenance activities are
in place, DOE Order 413.3 Critical Decision-4 (CD-4) documentation will
be submitted to obtain project closeout approval. The process and
guidance for reaching CD-4 approval is provided in Appendix A. CD-4 is
presented to the Acquisition Executive and the appropriate Energy System
Acquisition Advisory Board (ESAAB). The NNSA sites' Acquisition
Executive is the Deputy Secretary (S-2). EM should coordinate with the
site steward organization on CD-4 documentation to ensure readiness to
assume LTS responsibility. [Appendix
B](#appendix-b---project-closure-and-transition-plan-content-and-checklists)
also includes an example PCT Plan outline and associated checklists,
including a crosswalk to CD-4 prerequisites and post-closure activities.

### Defining LTS -- The LTS Plan

LTS plans are public documents and the primary mechanism for describing
LTS implementation. For this reason, LTS plans should be developed
according to DOE P 141.2, Public Participation and Community Relations.
Input should be solicited from stakeholders, including regulators and
local government, and either incorporated or otherwise addressed. The
LTS Plan also should be prepared in coordination with the site steward
to facilitate smooth transition.

LTS Plans should be prepared during transition, well in advance of
project completion (Figure 2.1) and can be written at a summary level if
adequate elements of LTS are described in other documents. Other
documents may be cited (rather than reiterated) if they are reasonably
retrievable. Health and safety, quality assurance, stakeholder
involvement, emergency response, and other pertinent plans should be
reviewed and modified, if necessary, to incorporate LTS considerations.

LTS plans should describe Site Office LTS requirements and list primary
assumptions and risks. Regulatory acceptance documentation and a summary
site status describing remedies and remaining hazards, risk assessment
results, and performance criteria and limitations should be completed
and included in the LTS Plan. An example of how this information may be
documented using a Response Action Reference Matrix is provided in the
June 2003 National Focus Project Fact Sheet, "EM Completion:
Transitioning LTRA Responsibilities." [Appendix
C](#appendix-c---example-lts-plan-outline) includes suggested LTS Plan
contents and an example outline.

## Transitioning LTS Work 

Transitioning LTS responsibilities will require early and frequent
interaction between project personnel and the site steward. Scope, cost,
and schedule for activities related to transition should be clearly
documented in the baseline. Work elements related to transition are
included in the following sections.

### Planning for Transfer

The documentation necessary for transfer should be discussed and agreed
to with the site steward at least 3 years in advance of project closure.
Project closure requires a CD-4 decision (Section 2.1.1). However, it
may be necessary to formalize agreements prior to the submission of a
CD-4 request. A Memorandum of Agreement (MOA) may be used to reach
agreement on the transfer of LTS activities. If an MOA is used, it
should include the steps and conditions necessary for project turnover,
the organizations responsible for conducting LTS activities and the
amount and timing of funds transfer. Guidance for developing an MOA and
obtaining approval will be forthcoming. Even though the final decision
on transfer is at the S-2 level, documents initially will be drafted by
project personnel. Therefore, the activities associated with transfer,
such as drafting a MOA and CD-4 package, should be incorporated in the
EM project life-cycle baseline.

### LTS Plan Integration

Site steward staff should be involved during development of the LTS Plan
to ensure acceptance of the document. EM project and site steward
personnel should ensure that the LTS Plan and supporting documentation
are compatible with site policies, procedures, and the Site-Wide
Integrated Safety Management Plan, as applicable. Additional information
about safety management and authorization basis can be found at
[http://www.doeal.gov/laaoabt/internet/GenInfo.htm.]{.underline}

### Information Management

Activities for transitioning and integrating EM information and records
management should be included in EM project baselines, including records
management required for LTS planning efforts. EM Project information
such as PCT Plan-related archives, active files, and real estate data
should be accessible for integration into site steward institutional
environmental systems and procedures and the Site-Wide Integrated Safety
Management Plan.

### Permitting Issues

Permit-related activities such as corrective action close-out,
post-closure permits, state requirements, and other regulatory
activities necessary to close the EM project should be included in
project baselines as part of LTS planning. Project personnel should
communicate with the site steward and regulators, as appropriate, to
ensure that regulatory requirements and authorities are understood and
clearly identified and documented. The PCT Plan should provide
information on permit requirements and status. Also, the EM CD-4
template (Appendix A) requires a summary of the status of regulatory
requirements prior to turnover.

### Programmatic Risks and Vulnerabilities

Programmatic risks and vulnerabilities such as remedy failure, federal
tort liability, and other risks could significantly affect scope,
schedule, and/or LTS costs. EM project and site steward personnel should
identify and quantify programmatic risks in a Programmatic Assumptions
Document. Examples of programmatic risk include:

-   Active sites -- Potential release sites (PRSs) that cannot be
    remediated because the area or facility is still operational. The
    current cleanup scope does not include active sites and therefore,
    they are not included in site baselines. Active sites are a
    programmatic risk because they should be remediated as they become
    inactive, posing a site steward management responsibility.

-   Excess facilities -- Process contaminated facilities that become
    excess after EM mission completion may be a site steward
    responsibility.

-   Ongoing Comprehensive Environmental Response, Compensation, and
    Liability Act (CERCLA) issues -- Several aspects of CERCLA could
    affect post EM completion costs. Natural Resource Damage Assessment
    (NRDA) liability could occur if natural resource trustees chose to
    pursue damages. CERCLA liability may also occur if waste management
    facilities used by DOE become Superfund sites.

-   Newly identified PRSs -- Site stewards may be responsible for PRSs
    identified after EM mission completion.

### Alternative Lessees, Tenants, and Stakeholders

EM Project personnel, the site steward, and NNSA should coordinate on
issues affecting lessees, tenants, and stakeholders. The EM Project
baseline should include scope, cost, and schedule for addressing
potential issues with alternative lessees, tenants, or third parties
that might have a vested interest or could be affected by transition or
LTS activities. For example, SNL/NM maintains facilities and test sites
on lands permitted by the U.S. Air Force and the U.S. Forest Service for
use by DOE. Transition planning should include involvement and input
from all such stakeholders.

### Budget Transfer

The site steward will need to request budget for LTS no later than 2
years in advance of EM project closeout. The LTS cost estimates
contained in the approved EM baselines are identified in LTS PBSs in the
IPABS database. No transfer of funds from EM to the site steward will
take place as EM does not include the costs for LTS in its planning
budget.

### Public Involvement

Public involvement will be necessary during LTS and should be performed
in accordance with the policy DOE P 141.2. EM Project personnel should
coordinate with the site steward on transition of public participation
plans and public involvement issues such as disseminating information,
public meetings, and reasonable public access to unclassified documents.

## Determining and Documenting LTS Phase Activities During the EM Project Phase

As identified in the EM National Focus Project Fact Sheet, "Definition
of EM Completion and DOE Site Closure", as response actions are
completed projects and subprojects are transitioned to operations and
maintenance (O&M). The time period during which response actions move
from the EM Project to LTS is identified in Figure 2.1 as Transition.
Sites should identify transition activities in the baseline WBS,
including preparing the LTS Plan and PCT Plan and conducting site
maintenance and interim O&M activities such as:

-   Monitoring of landfills (e.g., ground water, methane)

-   Maintenance of restricted use-area fencing

-   Monitoring of ground water related to a specific PRS or engineered
    system.

Scope, cost, and schedule for O&M activities with regulatory-approved
final decision should be included as part of the EM project in the
baselines.

The EM Project baselines also should include activities for project
turnover. Project turnover requires understanding and documenting
engineering system requirements and performance evaluation,
institutional controls, funding issues, and land use constraints.
Documentation must be complete, controls in place, and systems operating
according to regulatory and technical requirements prior to transfer to
the site steward.

## Milestones 

Project baseline schedules should present LTS start dates, end dates,
duration of significant planning and LTS-phase activities, and
milestones. LTS milestones include:

-   Project completion date

-   LTS Plan completion

-   DOE approval of final radioactive-contaminated (only) PRS

-   Submittal of final closure documentation to the regulatory authority

-   Regulatory authority approval of the final closure document (e.g.,
    the final permit modification request, Corrective Measure
    Implementation Report, or final No Further Action Report)

-   Date of Resource Conservation and Recovery Act (RCRA) post-closure
    permit issuance, for sites under RCRA 40 CFR 265, Part G

-   Estimated EM mission completion (same as LTS start date)

-   Dates of active remediation system shut-down and transition to
    monitoring and/or closure

-   Estimated LTS completion date

Milestones will be unique to each project, depending on project
completion definitions, applicable regulatory requirements, and specific
site features and contaminants of concern.

## Lifecycle Funding Needs

Sites will develop and annually update a funding estimate for LTS annual
and lifecycle costs. These costs will be captured in the LTS PBS for
each project. Guidance concerning the number of years to consider in
estimating lifecycle costs varies; however, when possible for planning
purposes, sites should use known lifecycle periods supported by backup
documentation. When the LTS lifecycle is not known, a 70-year planning
window is recommended. Sites estimating LTS to extend more than 70 years
should document duration expectations in appropriate baseline technical
summary documents.

Sites may consider planning in terms of the 30-year RCRA post-closure
monitoring period. However, monitoring does not necessarily end at the
end of 30 years if contaminants in the monitored media are still present
above standards. Thus, the 70-year period is intended to prevent
stakeholder concerns that monitoring could be terminated after 30 years,
regardless of remaining risk.

# LTS-PHASE BASELINE GUIDANCE 

This section provides guidance for incorporating LTS requirements into
program or project life cycle baselines.

## Work Breakdown Structure (WBS) Development 

Sites should develop an appropriate LTS WBS. A national DOE-mandated LTS
WBS does not currently exist, but [Appendix
D](#appendix-d---example-wbs-template) includes an example WBS and list
of typical LTS activities and major elements that should be described in
baselines. Sites are unique, both in project maturity and complexity.
However, the template should be evaluated and useful components
incorporated in baselines. The WBS outline also is useful for presenting
and reporting LTS baseline requirements. WBS levels 5 through 9 are
directly related to LTS and described in this document and Appendix D.
WBS levels 1 through 4 are not described because they are not specific
to LTS. WBS levels 1 and 2 identify EM HQ and the specific EM HQ program
(i.e., ER or WM), Level 3 indicates that the work is done in either a
plant or a laboratory, and Level 4 identifies a specific plant or
laboratory. A WBS Level 5 LTS number is assigned for each site (see
Appendix D example).

Site Offices are encouraged to estimate LTS activities to at least Level
6 to provide consistency within EM portions of baselines and facilitate
reviews and validation of estimates.

LTS work has many activities in common with other EM project tasks,
including project management, program and technical support, land use
planning, monitoring and maintenance, scheduling, risk quantification
and management, and cost estimating. This *Handbook* generally follows
the example WBS template in Appendix D, which also includes graphics
illustrating the WBS structure.

The following sections provide information associated with LTS-specific
issues or activities. Specific guidance does not exist for all of the
WBS levels and activities indicated in the template, but in most cases
guidance is provided for WBS levels 6 and 7. Some WBS Levels 8 and 9
activities also are addressed.

### Project Management

Project management baseline documentation is described in the *Project
Control System Handbook*.

### 3.1.2 Technical Management and Support {#technical-management-and-support .unnumbered}

This section describes general baseline technical management and support
requirements. Areas specific to LTS that could be included in the LTS
portion of baselines are:

#### **3.1.2.1 Technical Evaluations** {#technical-evaluations .unnumbered}

Appropriate technical evaluations should be performed during LTS to
optimize opportunities and minimize duration and costs. Evaluations may
be conducted for engineered system performance reviews, new
technologies, integrating technologies, formal program reviews, and
site-wide strategic planning. System performance reviews should be
conducted and options developed to correct deficiencies, as necessary.
Costs associated with performing formal reviews should be included in
baselines.

EM work is dynamic and it is expected that closure strategies,
identification of additional corrective action sites, and other
closure-related issues will have an impact on LTS. Site‑wide strategic
planning options will be considered through ongoing evaluations and new
technologies will be evaluated to identify potential applications at
post-EM completion sites.

#### **3.1.2.2 Regulatory Support** {#regulatory-support .unnumbered}

LTS regulatory support costs included in baseline documentation will
depend on the post-EM completion regulatory framework. Discussions with
regulators regarding requirement should begin well in advance of LTS, to
ensure adequate planning. Examples of regulatory support activities
include:

-   Routine scheduled meetings

-   Preparing position papers on issues that could affect the LTS-phase
    of work

-   Discussions and negotiations with regulatory personnel on emerging
    issues, strategies, and LTS completion

-   Maintaining and updating permits

-   Preparing reports for regulatory authorities.

The following websites provide information about potentially applicable
Federal and DOE requirements. State and local requirements should also
be considered.

-   <http://lts.apps.em.doe.gov/center/reports/pdf/overview_statutes_regs.pdf>\
    Major Environmental Statutes, Regulations, and Executive Orders for
    Long-Term Stewardship at DOE sites

-   <http://lts.apps.em.doe.gov/center/reports/pdf/DOE_Orders_Policies_Table.pdf>\
    Overview of DOE Order and Policy directives relevant to long-term
    stewardship

#### **3.1.2.3 Risk Assessment and Evaluation** {#risk-assessment-and-evaluation .unnumbered}

Baseline documentation also may need to include post-EM completion risk
assessment activities, such as:

-   Evaluating the risk knowledge based on changes of facility
    operations, site-wide environmental issues, or unexpected conditions

-   Monitoring and evaluating sites' engineered systems performance
    during LTS and modifying systems or implementing alternate
    strategies when necessary

-   Assessing human health and ecological risks associated with site
    performance and land use changes

#### **Information Management**

Information management activities documented in baselines should include
activities, such as:

-   Implementing and maintaining long-term storage and retrieval of
    electronic and hard copy data, reports, and correspondence

-   Preparing and delivering internal project communications

-   Designing and maintaining websites

-   Maintaining accessibility to information by public, regulators, and
    others

#### **Stakeholder Involvement**

Planning and implementing LTS will require a credible, effective
stakeholder participation process. This will include communication with
the public, other tenants and site owners, and related parties.
Activities that might be part of baseline documentation include:

-   Planning and holding public meetings

-   Preparing and distributing brochures, reports, updates, and other
    information

-   Preparing official public notices for significant events or
    decisions

### 3.1.3 Land Use and Institutional Controls {#land-use-and-institutional-controls .unnumbered}

Institutional controls are legal or administrative means of limiting
access to, or warning of hazards associated with a property. Land use
plan modifications, engineered remediation systems, resource management
issues, or newly identified contaminated sites determine or affect
institutional controls identified and documented in baselines. The EM
Project should include integration of LTS issues and land use planning,
including periodic reviews to ensure continuing validity of current
institutional controls, in the baseline.

### 3.1.4 Site Wide Environmental Monitoring and Physical Controls  {#site-wide-environmental-monitoring-and-physical-controls .unnumbered}

LTS activities not related to specific PRSs should be included in the
LTS portion of baselines. Non-site specific post-closure environmental
monitoring can be incorporated into the baseline by media type and
should include a section describing physical controls, as appropriate.
Media monitored during LTS could include groundwater, surface water,
soils and sediments, and biota.

The organization of scope descriptions and associated resource sheets
for monitoring activities will depend on the volume and complexity of
work. However, the scope should be clearly defined and coordinated with
site-wide monitoring plans to reduce potential redundancy.

### 3.1.5 PRSs With Engineered, Signed, and/or Fenced Units {#prss-with-engineered-signed-andor-fenced-units .unnumbered}

Physical controls include barriers, fences, engineered systems, locked
gates, or patrols used to protect human health and the environment.
Sites with PRSs that require physical controls should be identified in
the LTS portion of baselines through scope descriptions and resource
sheets. The Appendix D WBS template distinguishes these PRSs according
to the following Level 7 divisions:

-   Signed and fenced units

-   Engineered units

Signed and fenced units consist of structural controls and, as needed,
security controls. These units are typically associated with sites that
contain regulated substances above background or unrestricted use levels
in surface or near surface soils, or sites that present a physical
hazard. Examples include:

-   Fencing restricting access at testing areas containing depleted
    uranium fragments from ordinance detonation, or firing sites
    containing residual lead or other heavy metal fragments; associated
    sign to post warnings

-   Fencing around mineshafts, adits, and pits to restrict access;
    associated sign to post warnings

Controls providing protection from hazards present in surface or near
surface soils that may or may not be implemented in conjunction with
fenced units include:

-   Native soil or vegetative covers to minimize erosion and
    infiltration of water through units with residual constituents of
    concern

-   Berms to protect units from runoff and reduce erosion

Units requiring structural controls are generally low maintenance sites
and depending on complexity and quantity, can be grouped for baseline
documentation purposes. LTS activities include:

-   Monitoring and maintenance -- ensuring that physical controls are in
    place and effective, and repairing damaged areas

-   Surveys and object removal -- performing visual, radiation, and
    other survey methods to evaluate the presence of hazards. Object
    removal, including removing uranium fragments revealed by natural
    weather processes, might be required occasionally to reduce hazards

Engineered units contain engineered controls that detect, control,
and/or contain contaminant migration or collect contaminants and can
have monitoring systems to determine remedial system effectiveness.
Generally, engineered units also have structural controls. Examples of
engineered units include:

-   Landfills with designed cover, caps, and or leachate collection and
    detection systems

-   Contaminated areas with vadose zone extraction and monitoring
    systems

-   Groundwater pump and treat systems to remove contaminants

-   Other designed containment systems such as lined impoundments and
    barrier walls.

The scope of work required for monitoring and maintaining engineered
unit systems can be significant. Thus, each engineered unit should have
individual scope descriptions, schedules, and resource sheets. LTS
activities may include:

-   Monitoring and maintenance of engineered and structural controls

-   Data management and reporting

-   Evaluating system integrity

## Risk Management and Analysis

DOE O 413.3 and the *Project Controls System Handbook* contain risk
analysis requirements. Risk analysis includes risk management, and
analysis of both programmatic (out-of-scope) risks and contingency
(in-scope risks). Project risks should be listed in the baseline. These
risks should be organized into two categories:

-   Risks that might occur during LTS but do not affect the LTS portion
    of work

-   Risks that might occur as a direct result of LTS activities and
    engineered or structural controls

Costs due to risks not affecting LTS work or not a result of LTS
activities are not included in the baseline lifecycle cost estimate.
However, the risks should be identified in other LTS baseline
documentation to make the LTS managers aware of potential project risks.
Risks that might occur during the LTS-phase of work include:

-   Active sites could become inactive, possibly requiring investigation
    and remediation work

-   New sites might be identified that require mitigation

> The risk of excess facilities becoming inactive and requiring
> decommissioning and decontamination should be documented as suggested
> in the D&D Handbook.

Risks that could affect LTS include:

-   Unexpected system failures

-   Remedial Actions that do not meet performance requirements

-   NRDA liability suits

-   Regulatory changes (e.g. changes in cleanup levels) affecting
    closure strategies or operations. (The long-term nature of LTS
    increases likelihood of regulatory changes.)

-   Newly identified contaminants of concern

-   New technologies that could eliminate risks or otherwise accelerate
    termination of LTS

-   Changes in land use scenarios or conditions that affect closure
    (e.g. changes in future land-use from industrial to residential)

Risks should be described in baseline documentation, including estimates
of potential effects on scope, schedule, and cost. The scope, schedule,
and cost to develop and maintain a Risk Management Plan also should be
included in LTS baselines.

## Schedule

Resource loaded project schedules are required for EM projects and
should be included for LTS work. Refer to *Project Control Systems
Handbook* for detailed information. EM IPABS guidance requires the
schedule to include milestones as described in Section 2.5 Milestones.

## Cost Estimating 

LTS activity-based cost estimates are required in EM baselines and
should be included for LTS estimates. Refer to *Cost Estimating
Handbook* for detailed guidance.

## Performance Measures

EM and the site steward will negotiate LTS performance measures.
Examples of potential LTS-related performance measures include:

-   Meeting post-closure permit dates

-   Reduction in number of PRSs requiring LTS

# PROJECT REPORTING 

The scope, cost, and schedule for project reporting required during LTS
should be included in the baseline. EM Reporting requirements include
updating IPABS-IS PEM, yearly updates and site monitoring and evaluation
reports. Some reporting through the Project Assessment and Reporting
System (PARS) may be appropriate, although most LTS activities will not
require PARS reporting. Reporting in the Facility Information Management
System of certain LTS related information is also required.

## IPABS-IS PEM

IPABS-IS PEM data and reporting requirements have changed annually. EM
will notify sites of new or changed requirements and performance
measures. Project baseline summary managers and site managers need to be
aware of these changes and provide timely input. The scope and cost of
meeting IPABS-IS PEM reporting requirements should be presented in the
baseline.

## Periodic LTS Updates and Performance Review

Yearly updates and reviews will proceed through the baseline change
control process described in the *Project Control System Handbook.* The
scope and cost to prepare the yearly baseline update should be budgeted
in the baseline. The report should include the following:

-   Engineering system and site-wide monitoring data results and
    interpretation

-   Physical controls and systems operation descriptions, including
    significant issues affecting performance

-   Significant changes in land use planning, institutional controls,
    and any other issue that could impact the baseline scope, schedule,
    or budget

-   An explanation of expectations and accomplishments for the next year

LTS updates may also be necessary to:

-   Ensure continued effectiveness of engineered and institutional
    controls

-   Evaluate remedy controls to optimize maintenance and monitoring
    costs

-   Minimize duplicative documentation

# REFERENCES AND RESOURCES

DOE G 1324.5B, *Records Management Program*, January 12.
<http://www.directives.doe.gov/cgi-bin/explhcgi?qry1981735854;doe-285>

DOE P 141.2, *Public Participation and Community Relations*, May 2,
2003.

DOE Manual 413.3-1, *Project Management for the Acquisition of Capital
Assets*, U.S. Department of Energy Office of Management, Budget and
Evaluation, March 28, 2003.
<http://www.sc.doe.gov/sc-80/sc-81/man/intro.pdf> or
http://oecm.energy.gov/policies

DOE O 413.3, *Program and Project Management for the Acquisition of
Capital Assets*, October 13.
[http://www.directives.doe.gov/cgi-bin/explhcgi?qry1441935954;doe-114](http://www.directives.doe.gov/cgi-bin/explhcgi?qry1200901437;doe-113)

DOE. 2002a. *Long-Term Environmental Stewardship Strategic Plan*,
Revision 2, Draft. Albuquerque Operations Office, Office of
Environmental Programs, March 6.

DOE. 2002b. *IPABS FY 2002 Guidance Documents, Volume 2: FY 2002 IPABS
Users Manual,* Office of Environmental Management.
<https://ipabs-is.em.doe.gov/ipabs> *and*
[https://ipabsreporting.em.doe.gov*/*](https://ipabsreporting.em.doe.gov/)

DOE. 2002c. *Long-Term Stewardship Plan Guidance for the Closure Sites*,
Draft. Office of Environmental Management, May.

DOE 2003. *Definition of EM Completion and DOE Site Closure*. Office of
Environmental Management Corporate Projects Initiative National Focus
Project. January 2003.

DOE 2003. *EM Completion: Transitioning LTRA Responsibilities*. Office
of Environmental Management Corporate Projects Initiative National Focus
Project. June 2003.

DOE. 2003\*. *Baseline Review Handbook*. National Nuclear Security
Administration Service Center, Environmental Programs Department.

DOE. 2003\*. *Cost Estimating Handbook.* National Nuclear Security
Administration Service Center, Environmental Programs Department.

DOE. 2003\*. *Handbook for Integrated Project Management.* National
Nuclear Security Administration Service Center, Environmental Programs
Department.

DOE. 2003\*. *Project Control System Handbook.* National Nuclear
Security Administration Service Center, Environmental Programs
Department.

*\** This document is available from NNSA Service Center EP. It is
anticipated that this document will be published as a final document in
2003.

[]{.mark}

# Glossary 

**active site** -- a potential release site that is not addressed in the
EM Project baseline because of its continued use.

**baseline** --Environmental Management Project life-cycle baselines

**EM mission completion --** Per *FY2002 IPABS User's Manual,* Chapter
4, (DOE, 2002b) and *Definition of EM Completion and DOE Site Closure*,
Office of Environmental Management Corporate Projects Initiative
National Focus Project (January 2003)

> Mission complete indicates that the scope of the project has met the
> relevant criteria used for overall site completion (deactivation and
> decommissioning of all facilities have been completed, all releases to
> the environment have been cleaned up in accordance with agreed-upon
> cleanup standards, groundwater contamination has been contained or
> long-term treatment or monitoring is in place, nuclear materials and
> spent fuel have been stabilized and/or placed in safe long-term
> storage, and legacy waste has been disposed of in an appropriate
> manner). Each PBS is required to have a mission complete date.

**engineered controls** -- designed remedial alternatives that inhibit
or control the spread of contamination, contain or remediate the
contaminated media, or control the infiltration of water at contaminated
sites. Examples include pump and treat systems, landfill caps, and lined
disposal cells.

**excess facilities** -- facilities no longer needed for mission and/or
at the end of their lifecycle use.

**institutional controls** -- legal or administrative means of limiting
property access or warning of hazards.

**site steward** -- the organization or office that will be responsible
for long-term stewardship at a site.

**Memorandum of Agreement** **(MOA)** -- a written agreement between EM
and the site steward describing conditions necessary for transfer of
LTS.

**Natural Resource Damage Assessment** -- a calculation of damages to
natural resources resulting from a discharge of oil or a release of a
hazardous substance covered under CERCLA (as amended by SARA) or the
Clean Water Act, in order to recover damages from a responsible party or
parties.

**Project Closure and Transition Plan** **(PCT Plan)** -- an internal
document developed by project teams to ensure systematic, efficient, and
complete EM Project closure. It states the necessary actions to
administratively close-out the EM Project as required to meet DOE M
413.3-1, RCRA/Hazardous and Solid Waste Amendments of 1984 (HSWA),
state, and other requirements. DOE M 413.3-1 requires that "All projects
shall have a project transition/closeout plan that clearly defines the
basis for attaining initial operating capability, full operating
capability, or project closeout, as applicable."

**physical controls** -- barriers, fences, engineered controls, locked
gates, or patrols employed at PRSs to ensure protection of human health
and the environment.

**potential release site (PRS)** -- an area of land impacted by a
hazardous substance. For this document, the term includes solid waste
management units, areas of concern, operable units, and other specific
areas requiring LTS

**Response Action --** activities necessary to address a potential risk
to human health or the environment

**Site office** -- Site offices are individual NNSA offices responsible
for managing a site or sites. NNSA Site Offices include Los Alamos Site
Office (LASO), Sandia Site Office (SSO), Pantex Site Office (PSO),
Kansas City Site Office (KCSO), Lawrence Livermore Site Office, Nevada
Site Office, Y-12 Site Office, and Savannah River Site Office.

**structural controls** -- physical controls preventing access to or
containing a PRS, including berms, fences, gates, walls, and warning
signs.

**transfer --** the change of project management and control of LTS from
EM to the site steward, occurring following EM Project close-out,
usually represented by a milestone.

**transition and closeout -** as specified in DOE Manual 413.3-1, the
progression of a project from implementation to turnover for operations.
For EM projects, initial operating capability may be defined as the
transition to long-term maintenance and surveillance. This occurs at
Critical Decision-4.

####### **Appendix A - Critical Decision-4 Turnover and Closeout Requirements and Template** {#appendix-a---critical-decision-4-turnover-and-closeout-requirements-and-template .unnumbered}

The following template is provided to assist in preparing for a Critical
Decision-4 (CD). The CD-4 decision is a briefing presented by the Site
Manager or Federal Project Director to the Acquisition Executive (AE),
who is either the Deputy Secretary (S-2), Under Secretary (S-3), or the
Assistant Manager for Environmental Management (EM-1) and the
appropriate Energy System Acquisition Advisory Board (ESAAB).

The project type will dictate the requirements and information that
needs to be presented to the ESAAB. For Environmental Restoration and
Decommissioning and Decontamination projects or sites, CD-4 requires the
following:

-   the cleanup activities have been completed,

-   the EM completion criteria met,

-   regulators and stakeholders are satisfied,

-   regulatory documents (releases, permits, licenses, agreements, etc.)
    are current,

-   buildings and land are in the agreed upon condition,

-   receiving organization is ready to assume responsibility,

-   funds are available for post-closure activities,

-   documents and contracting officer authority transferred (if
    necessary),

-   staffs have transitioned, and

-   all parties are in agreement that the project or site is ready for
    the acquisition executive to approve the turnover from one
    organization to another.

The following CD-4 Transition (Turnover)/Closeout template outlines
information that is required by 413.3 and addressed by the ESAAB.
Because the board is comprised of senior managers, the briefing should
be developed in appropriate detail. Back-up slides and additional detail
should be available if questions are asked or additional information
requested. In addition, a decision memorandum should be prepared from
the Site Manager through EM-1 and the Under Secretary, if the Deputy
Secretary is the Acquisition Executive . Conditional approvals may also
be granted (i.e. approval granted when certain conditions are met or
actions completed).

**Critical Decision-4 Transition (Turnover) and Closeout**

1.  **[Project/Site Name:]{.underline}** Name of project or site to be
    turned over

2.  **[Date:]{.underline}** ESAAB Meeting Date

**3. [Project/Site Location :]{.underline}** City and state

**4. [Field Office:]{.underline}** Managing Field Office

**5. [Releasing HQ Organization:]{.underline}** Program Office releasing
the project or site (EM)

**6. [EM Completion Date:]{.underline}** As defined in the National
Focus Project Fact Sheet, "Definition of EM Completion and DOE Site
Closure".

**7. [Receiving HQ Organization]{.underline}**: Program Office receiving
the project or site (i.e., Office of Science)

**8. [Site Closure Date (if known):]{.underline}** Enter a date or TBD

**9. [Planned Turnover Date:]{.underline}** Enter the date the project
or site is scheduled for turnover

**10. [State & Federal Regulatory Authorities:]{.underline}** Enter the
names of State and Federal Regulator organizations (i.e., New Mexico
Environment Department, EPA)

**11. [Describe Project/Site Turnover Agreements:]{.underline}**

Identify pre-CD-4 turnover agreements such as prior CD decisions, MOAs,
or Memorandums and include copies. Summarize key elements of agreements,
such as turnover requirements, site conditions, turnover packages, spare
parts, documents and records, vendor data, and key dates.

**12. [Describe Item(s) Being Turned Over, and the Current Condition of
Each Item: ]{.underline}**

Include buildings and facilities as well as areas (i.e., technical
areas) and current condition (i.e., greenfield, restricted use, limited
access, use restrictions, etc.). For line item construction projects,
verify that the facility, equipment, or system has been checked, tested
and evaluated, commissioned, has undergone an operational readiness
review with deficiencies corrected, and has a final safety analysis
report. Operating and maintenance procedures, trained staff, project
records, design packages, and documents transferred to operators or
occupants must also be included.

**13. [Summarize the EM Scope of Work Performed for Turnover Including
EM Completion Criteria:]{.underline}** Example: Demolished buildings 123
and 567 and shipped all contaminated debris offsite; capped Pond A with
YY, buried 10 tons of LLW in an onsite landfill in Area B, and developed
a groundwater remediation strategy.

**14. [Summarize the Receiving Organizations Scope of Work Including Any
Work Started By EM and Being Completed by Receiving Organization (if
applicable): ]{.underline}**

Example: Groundwater monitoring in areas A&F will be done by the
receiving organization from MM/YY to MM/YY, experiments on XX will be
conducted in Lab ZZ until MM/YY, waste generated after MM/YY will be
disposed by the receiving organization. Also describe steward
responsibilities and list planning (such as the LTS Plan) and regulatory
documents that must be revised, closed, transferred, or obtained from
state or federal organizations.

**15. [Summarize Any EM Scope Of Work That Will Extend Past the Turnover
Date, if applicable:]{.underline}**

Example: Ship final four tons of soil to XX on MM/YY, obtain final
release for Area A from the Department of Health, resolve all contract
and closeout issues, budget actions, and final reports.

**16. [Summarize the Status of Regulatory Requirements for Turnover
Item(s), if applicable: ]{.underline}**

Identify the status of regulatory requirements such as permits,
licenses, reports, and federal facility agreements for facilities,
buildings, or areas being turned-over, including actions (i.e., closed,
pending, transferring to receiving organization, etc.).

**17. [Are Resources Available and in Place for Turnover (staff, funds,
and facilities): ]{.underline}**

Provide both organizations' prior year, turnover year, and next year
funding profiles for turnover item(s) and describe any issues, such as
funds transfers, reprogramming actions, or shortfalls. Include staffing
levels, staffing plans, and transition of federal staff (transfers,
relocations, new hires, RIFs, etc.). Describe training that has been
provided and verify that staff is in place and ready to assume
responsibility. Verify that administrative facilities have been
transferred, equipped, and are ready for staffing, if applicable.

**18. [Identify Outstanding Items that must be Completed to Finalize EM
Completion and Turnover, if applicable:]{.underline}**

Example: Transfer \$200K from EM to Office of Science, complete report
on XX, and modify the permit for ZZ.

***NOTE: If the information requested is already provided in another
document, reference the document and attach a copy.***

***References: As a Reference and Guide to completing turnover utilize
the Long-Term Stewardship Site Acceptance Criteria and Environmental
Cost Element Structure***

***[DOE Manual 413.3-1 Chapter 7]{.underline}***

#######  {#section .unnumbered}

This page is intentionally blank.

#######  {#section-1 .unnumbered}

####### **Appendix B - Project Closure and Transition Plan Content and Checklists** {#appendix-b---project-closure-and-transition-plan-content-and-checklists .unnumbered}

The PCT Plan should describe the project transition, covering the
following topics and including adequate documentation of applicable
prerequisites for Critical Decision-4 (DOE M 413.3-1, Section 7.9.1) and
management agreement for final fiscal cost and administrative closure:

1.  Authorities and responsibilities -- describe EM, NNSA, and
    regulators' responsibilities, including responsibilities of specific
    personnel for meeting closure actions and provision of a trained and
    qualified operations and maintenance staff.

2.  Records management -- present records management requirements and
    procedures for ensuring EM activities are properly documented
    through project completion. Records document project completion,
    minimize future legal liability, and guide work during LTS. Records
    management must comply with National Archives and Records
    Administration policies and DOE Guidance 1324.5B.

3.  Regulatory activities -- detail regulatory procedures and
    requirements for achieving closure of various types of impacted
    areas. Closure requirements differ for areas of concern closed under
    the formal RCRA process (e.g., Corrective Action Management Unit),
    through voluntary corrective actions, or by DOE
    (radioactively-contaminated only sites). Information should also be
    provided on permit requirements and status.

4.  Disposition of government property -- address actions required for
    ensuring all excess equipment and materials are disposed of in
    accordance with DOE property disposition regulations and internal
    site requirements.

5.  Financial closeout -- detail closeout requirements for subcontracts
    and permits.

6.  Project completion report - document site conditions describing
    remedies and remaining hazards, results of human health and
    ecological risk assessments, and verification of performance
    criteria and limitations.

7.  Final Safety Analysis Report or other appropriate safety
    documentation.

8.  Operating and maintenance procedures.

9.  Completed acceptance testing documentation, including corrected
    deficiencies.

10. Completed readiness assessment or operational readiness review.

EM project managers should consistently use a closure checklist and
project record checklists for ensuring documentation requirements,
including those satisfying DOE M 413.3-1 Prerequisites for Critical
Decision-4.

**Example Closure Checklist**

+----------+------------------------------------------------------+---+
| **Ca     | **Description**                                      | * |
| tegory** |                                                      | * |
|          |                                                      |  |
|          |                                                      | * |
|          |                                                      | * |
+----------+------------------------------------------------------+---+
| Records  | Submit LTS related project records to the Site       |  |
|          | Steward.                                             |   |
|          |                                                      |   |
|          | Submit other project records to the Records Center   |   |
|          | for archiving.                                       |   |
+----------+------------------------------------------------------+---+
|          | Review records inventory list with the Federal       |  |
|          | Project Director for completeness.                   |   |
+----------+------------------------------------------------------+---+
|          | Provide Repository with current contact information  |  |
|          | (telephone number, organization).                    |   |
|          |                                                      |   |
|          | Review and change ownership of the information in    |   |
|          | the project databases (site tracking, compliance,    |   |
|          | case management, lab, etc.).                         |   |
+----------+------------------------------------------------------+---+
|          | Provide designated record owner information to the   |  |
|          | Records Center.                                      |   |
+----------+------------------------------------------------------+---+
| Property | Submit subject property information and recommended  |  |
|          | reapplication to the Project Manager.                |   |
+----------+------------------------------------------------------+---+
|          | Redirect any property and equipment purchases to the |  |
|          | Site Steward.                                        |   |
+----------+------------------------------------------------------+---+
| F        | Confirm post-CD-4 requirements are budgeted for by   |  |
| inancial | receiving organization                               |   |
+----------+------------------------------------------------------+---+
|          | Close out all reimbursements.                        |  |
+----------+------------------------------------------------------+---+
| Per      | **Verify performance criteria have been met.**       |  |
| formance |                                                      |   |
| Criteria | Meet with Project Control Specialist to review       |   |
|          | status, any outstanding action items related to the  |   |
| EM       | baseline (baseline review, etc.).                    |   |
| Co       |                                                      |   |
| mpletion |                                                      |   |
| Criteria |                                                      |   |
+----------+------------------------------------------------------+---+
|          | Review and update all scope documents and underlying |  |
|          | assumptions.                                         |   |
+----------+------------------------------------------------------+---+
|          | Review and brief the Site Steward on the regulatory  |  |
|          | status of each site.                                 |   |
+----------+------------------------------------------------------+---+
|          | Conduct field tour with Site Steward to brief the    |  |
|          | history and status of each site.                     |   |
+----------+------------------------------------------------------+---+
|          | Discuss all sources of information and their         |  |
|          | location to the Site Steward.                        |   |
+----------+------------------------------------------------------+---+
|          | Meet Site Steward to identify and resolve any        |  |
|          | transition issues.                                   |   |
+----------+------------------------------------------------------+---+
| General  | Meet with Administration Team for financial and      |  |
| Admini   | contracting closeout review.                         |   |
| strative |                                                      |   |
+----------+------------------------------------------------------+---+
| Ma       | Meet with project manager, Federal Project Director, |  |
| nagement | and Site Steward to review completion of each        |   |
| Review   | checklist item.                                      |   |
+----------+------------------------------------------------------+---+
|          | Review final standing with respect to Transition     |  |
|          | Plan                                                 |   |
+----------+------------------------------------------------------+---+

####### **Appendix C - Example LTS Plan Outline** {#appendix-c---example-lts-plan-outline .unnumbered}

Appendix C contains an example outline for LTS plans. LTS plans should
refer to, rather than duplicate, documents and plans that provide
detail, minimizing the need to update more than one document as plans
change. LTS plan appendices should be used to provide detail.

1.0 Introduction

  -------------- ---------------------------------------------------------
  Objectives     State the purpose of the LTS and how it should be used.

  Scope          Describe physical boundaries addressed by the plan and
                 the breadth of activities it encompasses. Include map(s).

  LTS Plan       Summarize key aspects of the LTS Plan. A timeline may be
  Summary        helpful to depict anticipated events. []{.mark}

  Limitations/   Describe limitations and assumptions associated with
  Assumptions    potential funding, technical, and political issues.

  Authority and  State authority under which the LTS is written and will
  History        be maintained. Summarize how the LTS plan was developed
  -------------- ---------------------------------------------------------

2.0 Site Description

+-----------+-----------------------------------------------------------+
| B         | Summarize operational history including former occupants  |
| ackground | and operators, what operations were conducted and when,   |
|           | contaminants that were generated and media affected, and  |
|           | acquisition history.                                      |
|           |                                                           |
|           | Summarize remediation history including cleaning up site  |
|           | contaminants; closing, stabilizing, and decontamination   |
|           | and decommissioning (D&D) of onsite facilities.           |
+-----------+-----------------------------------------------------------+
| Physical  | Describe relevant geology, hydrogeology, topography, and  |
| Setting   | climate. Provide the location and characteristics of      |
|           | natural, archaeological, and cultural resources.          |
+-----------+-----------------------------------------------------------+
| Real      | State the location, legal description, and boundaries.    |
| Estate    | Describe adjacent ownership, liens, property rights, or   |
|           | other real estate issues associated with the site.        |
|           | Describe current land use and land use agreements.        |
+-----------+-----------------------------------------------------------+
| Risk      | Summarize the Risk Based End State (RBES) Vision that was |
| Based End | developed as required by DOE Policy 455.1.                |
| State     |                                                           |
| Vision    |                                                           |
+-----------+-----------------------------------------------------------+
| Affected  | Describe nearby communities and affected by the site,     |
| Community | including employment history, growth, and economic        |
|           | relationship of the site and community.                   |
+-----------+-----------------------------------------------------------+

3.0 LTS Approach

  ---------------- -----------------------------------------------------------
  Site Conditions  Describe anticipated conditions at EM project completion,
                   including units that will have engineering, institutional,
                   and physical controls. Describe discrete LTS-managed areas,
                   location, and residual and physical hazards. State
                   assumptions associated with site end state.

  Land Use         Describe current and future land use and restrictions.
                   Describe how the engineered, institutional, and physical
                   controls will affect land use; potential land use changes
                   as engineering controls progress; land uses restrictions;
                   and offsite areas that are directly impacted by LTS
                   activities. Include map(s).

  Conceptual Site  Summarize the current understanding of known or potential
  Model            contamination problems by diagramming the conceptual site
                   model describing relationships between contaminant sources,
                   release mechanisms, exposure pathways and routes, and
                   receptors. Use the Conceptual Site Model that was developed
                   as part of the RBES Vision.

  Engineered,      Describe each engineered, institutional, and physical
  Institutional,   control and how it will be being implemented and
  and Physical     maintained. Include anticipated effectiveness of each
  Controls         control, surveillance and maintenance activities, and roles
                   and responsibilities for maintaining the controls.
                   Reference other documents describing controls.

  Monitoring       Describe media to be monitored, frequency, response
                   thresholds, and integration with the Site steward's
                   Site-Wide Monitoring Program.

  Risk Management  Discuss uncertainties associated with LTS and how they are
                   managed, including factors such as regulatory changes,
                   onsite and offsite land use change, failures in controls,
                   technology effectiveness, changes in ambient subsurface
                   conditions, and changes in facility use.
  ---------------- -----------------------------------------------------------

4.0 LTS Management

  ------------------ ---------------------------------------------------------
  Roles and          Identify groups responsible for LTS site and
  Responsibilities   administrative activities (include document management)
                     and describe their responsibilities. Include regulatory
                     agencies responsible for enforcing LTS activities.
                     Describe the site steward management and LTS management
                     teams.

  ------------------ ---------------------------------------------------------

5.0 Regulatory Framework and Authorities

+----------+-----------------------------------------------------------+
| Legal    | The legal authorities under which LTS will be conducted   |
| Aut      | should be identified and tied to LTS activities. Refer to |
| horities | documents prepared under those authorities. Include       |
|          | contracts with private parties (e.g., land access         |
|          | agreements). These websites provide information about     |
|          | potentially applicable requirements. State and local      |
|          | requirements should also be researched.                   |
|          |                                                           |
|          | <http://lts.apps.em                                       |
|          | .doe.gov/center/reports/pdf/overview_statutes_regs.pdf> - |
|          | Federal                                                   |
|          |                                                           |
|          | <http://lts.apps.em.do                                    |
|          | e.gov/center/reports/pdf/DOE_Orders_Policies_Table.pdf> - |
|          | DOE                                                       |
+----------+-----------------------------------------------------------+
| Co       | Describe regulatory framework considerations (e.g.,       |
| mpliance | decision logic and criteria for changes in sampling plans |
| Plan     | or required reporting).                                   |
+----------+-----------------------------------------------------------+

6.0 Information Management

  --------------- ---------------------------------------------------------
  Communication   Describe communication required between LTS managers,
  Plan            site workers, regulators, and the public. Include
                  reporting requirements. Include or reference a points of
                  contacts list.

  Records         Describe electronic and physical records management
  Management      systems. Identify records to be managed (e.g., LTS plan
                  \[and revisions\], sampling and surveillance and
                  maintenance data, audit reports, training records, legal
                  agreements, permits). Identify how and where records will
                  be stored and accessed.
  --------------- ---------------------------------------------------------

7.0 Health and Safety

  ----------- -----------------------------------------------------------
  Worker      Describe a health and safety program including health and
  Safety      safety training requirements. Reference health and safety
              plan or provide as an appendix.

  Public      Refer to access restrictions described in the institutional
  Safety      controls section.

  Emergency   Describe emergency response capabilities and arrangements
  Response    with local, state, and Federal response programs.
  ----------- -----------------------------------------------------------

8.0 Quality Assurance

  ----------- -----------------------------------------------------------
  QA Plan     Summarize and reference the LTS Quality Assurance Plan.

  ----------- -----------------------------------------------------------

9.0 LTS Funding and Scheduling

  -------------- --------------------------------------------------------
  Funding        Describe known and anticipated LTS funding source(s) and
  Sources        management.

  Costs          Provide cost estimates and assumptions.

  Schedule       Provide schedule for LTS activity start and end dates,
                 including milestones and anticipated dates.
  -------------- --------------------------------------------------------

LTS Plan Appendices

The example below provides information may be contained in LTS Plan
appendices. Appendices should be used to describe specific remedies or
provide information not contained in existing, cited documents.

+----+-----+-----------------------------------------------------------+
| *  |     |                                                           |
| *E |     |                                                           |
| xa |     |                                                           |
| mp |     |                                                           |
| le |     |                                                           |
| ** |     |                                                           |
|    |     |                                                           |
| *  |     |                                                           |
| *S |     |                                                           |
| it |     |                                                           |
| e- |     |                                                           |
| Wi |     |                                                           |
| de |     |                                                           |
| G  |     |                                                           |
| ro |     |                                                           |
| un |     |                                                           |
| dw |     |                                                           |
| at |     |                                                           |
| er |     |                                                           |
| Mo |     |                                                           |
| ni |     |                                                           |
| to |     |                                                           |
| ri |     |                                                           |
| ng |     |                                                           |
| Sy |     |                                                           |
| st |     |                                                           |
| em |     |                                                           |
| ** |     |                                                           |
+----+-----+-----------------------------------------------------------+
|    | **  |                                                           |
|    | Des |                                                           |
|    | cri |                                                           |
|    | pti |                                                           |
|    | on, |                                                           |
|    | Goa |                                                           |
|    | ls, |                                                           |
|    | and |                                                           |
|    | Unc |                                                           |
|    | ert |                                                           |
|    | ain |                                                           |
|    | tie |                                                           |
|    | s** |                                                           |
+----+-----+-----------------------------------------------------------+
|    |     | -   Location and Legal Description                        |
+----+-----+-----------------------------------------------------------+
|    |     | -   Conceptual Site Model                                 |
+----+-----+-----------------------------------------------------------+
|    |     | -   Regulatory Framework                                  |
+----+-----+-----------------------------------------------------------+
|    |     | -   Closure Goals/Contingency Plans/Corrective Actions    |
+----+-----+-----------------------------------------------------------+
|    |     | -   Assumptions and Uncertainties                         |
+----+-----+-----------------------------------------------------------+
|    | **L |                                                           |
|    | and |                                                           |
|    | Use |                                                           |
|    | Re  |                                                           |
|    | str |                                                           |
|    | ict |                                                           |
|    | ion |                                                           |
|    | s/I |                                                           |
|    | nst |                                                           |
|    | itu |                                                           |
|    | tio |                                                           |
|    | nal |                                                           |
|    | C   |                                                           |
|    | ont |                                                           |
|    | rol |                                                           |
|    | s** |                                                           |
+----+-----+-----------------------------------------------------------+
|    |     | -   Operation and Maintenance                             |
+----+-----+-----------------------------------------------------------+
|    |     | -   Surveillance                                          |
+----+-----+-----------------------------------------------------------+
|    | **  |                                                           |
|    | Sys |                                                           |
|    | tem |                                                           |
|    | Ope |                                                           |
|    | rat |                                                           |
|    | ion |                                                           |
|    | s** |                                                           |
+----+-----+-----------------------------------------------------------+
|    |     | -   Sampling                                              |
+----+-----+-----------------------------------------------------------+
|    |     | -   Well Maintenance                                      |
+----+-----+-----------------------------------------------------------+
|    |     | -   Data Analysis and Reporting                           |
+----+-----+-----------------------------------------------------------+
|    | **C |                                                           |
|    | ost |                                                           |
|    | and |                                                           |
|    | Sc  |                                                           |
|    | hed |                                                           |
|    | ule |                                                           |
|    | for |                                                           |
|    | Sit |                                                           |
|    | e-W |                                                           |
|    | ide |                                                           |
|    | Gr  |                                                           |
|    | oun |                                                           |
|    | dwa |                                                           |
|    | ter |                                                           |
|    | Mon |                                                           |
|    | ito |                                                           |
|    | rin |                                                           |
|    | g** |                                                           |
+----+-----+-----------------------------------------------------------+

####### **Appendix D - Example WBS Template** {#appendix-d---example-wbs-template .unnumbered}

+-----------+---+---+----+---+----+----------------------------------------+---+
| Handbook  | E |   |    |   |    |                                        |   |
| Section   | x |   |    |   |    |                                        |   |
|           | a |   |    |   |    |                                        |   |
|           | m |   |    |   |    |                                        |   |
|           | p |   |    |   |    |                                        |   |
|           | l |   |    |   |    |                                        |   |
|           | e |   |    |   |    |                                        |   |
|           | W |   |    |   |    |                                        |   |
|           | B |   |    |   |    |                                        |   |
|           | S |   |    |   |    |                                        |   |
|           | L |   |    |   |    |                                        |   |
|           | e |   |    |   |    |                                        |   |
|           | v |   |    |   |    |                                        |   |
|           | e |   |    |   |    |                                        |   |
|           | l |   |    |   |    |                                        |   |
|           | s |   |    |   |    |                                        |   |
|           | a |   |    |   |    |                                        |   |
|           | n |   |    |   |    |                                        |   |
|           | d |   |    |   |    |                                        |   |
|           | W |   |    |   |    |                                        |   |
|           | o |   |    |   |    |                                        |   |
|           | r |   |    |   |    |                                        |   |
|           | k |   |    |   |    |                                        |   |
|           | E |   |    |   |    |                                        |   |
|           | l |   |    |   |    |                                        |   |
|           | e |   |    |   |    |                                        |   |
|           | m |   |    |   |    |                                        |   |
|           | e |   |    |   |    |                                        |   |
|           | n |   |    |   |    |                                        |   |
|           | t |   |    |   |    |                                        |   |
|           | s |   |    |   |    |                                        |   |
+===========+===+===+====+===+====+========================================+===+
| **3.1**   | * |   |    |   |    |                                        |   |
|           | * |   |    |   |    |                                        |   |
|           | L |   |    |   |    |                                        |   |
|           | e |   |    |   |    |                                        |   |
|           | v |   |    |   |    |                                        |   |
|           | e |   |    |   |    |                                        |   |
|           | l |   |    |   |    |                                        |   |
|           | 5 |   |    |   |    |                                        |   |
|           | ( |   |    |   |    |                                        |   |
|           | * |   |    |   |    |                                        |   |
|           | * |   |    |   |    |                                        |   |
|           | 1 |   |    |   |    |                                        |   |
|           | . |   |    |   |    |                                        |   |
|           | 4 |   |    |   |    |                                        |   |
|           | . |   |    |   |    |                                        |   |
|           | 2 |   |    |   |    |                                        |   |
|           | . |   |    |   |    |                                        |   |
|           | 6 |   |    |   |    |                                        |   |
|           | . |   |    |   |    |                                        |   |
|           | 4 |   |    |   |    |                                        |   |
|           | . |   |    |   |    |                                        |   |
|           | ) |   |    |   |    |                                        |   |
|           | * |   |    |   |    |                                        |   |
|           | * |   |    |   |    |                                        |   |
|           | - |   |    |   |    |                                        |   |
|           | - |   |    |   |    |                                        |   |
|           | S |   |    |   |    |                                        |   |
|           | i |   |    |   |    |                                        |   |
|           | t |   |    |   |    |                                        |   |
|           | e |   |    |   |    |                                        |   |
|           | L |   |    |   |    |                                        |   |
|           | T |   |    |   |    |                                        |   |
|           | S |   |    |   |    |                                        |   |
|           | S |   |    |   |    |                                        |   |
|           | u |   |    |   |    |                                        |   |
|           | m |   |    |   |    |                                        |   |
|           | m |   |    |   |    |                                        |   |
|           | a |   |    |   |    |                                        |   |
|           | r |   |    |   |    |                                        |   |
|           | y |   |    |   |    |                                        |   |
|           | * |   |    |   |    |                                        |   |
|           | * |   |    |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
| **3.1.1** |   | * |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
|           |   | L |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | v |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | l |    |   |    |                                        |   |
|           |   | 6 |    |   |    |                                        |   |
|           |   | - |    |   |    |                                        |   |
|           |   | - |    |   |    |                                        |   |
|           |   | P |    |   |    |                                        |   |
|           |   | r |    |   |    |                                        |   |
|           |   | o |    |   |    |                                        |   |
|           |   | j |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | c |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   | M |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | g |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | m |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | Ma |   |    |                                        |   |
|           |   |   | na |   |    |                                        |   |
|           |   |   | ge |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Bu |   |    |                                        |   |
|           |   |   | dg |   |    |                                        |   |
|           |   |   | et |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | P  |   |    |                                        |   |
|           |   |   | er |   |    |                                        |   |
|           |   |   | so |   |    |                                        |   |
|           |   |   | nn |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | R  |   |    |                                        |   |
|           |   |   | ep |   |    |                                        |   |
|           |   |   | or |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   | (  |   |    |                                        |   |
|           |   |   | DO |   |    |                                        |   |
|           |   |   | E/ |   |    |                                        |   |
|           |   |   | Si |   |    |                                        |   |
|           |   |   | te |   |    |                                        |   |
|           |   |   | st |   |    |                                        |   |
|           |   |   | ew |   |    |                                        |   |
|           |   |   | ar |   |    |                                        |   |
|           |   |   | d* |   |    |                                        |   |
|           |   |   | )* |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | Ba |   |    |                                        |   |
|           |   |   | se |   |    |                                        |   |
|           |   |   | li |   |    |                                        |   |
|           |   |   | ne |   |    |                                        |   |
|           |   |   | D  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | op |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Pr |   |    |                                        |   |
|           |   |   | og |   |    |                                        |   |
|           |   |   | ra |   |    |                                        |   |
|           |   |   | mm |   |    |                                        |   |
|           |   |   | at |   |    |                                        |   |
|           |   |   | ic |   |    |                                        |   |
|           |   |   | Is |   |    |                                        |   |
|           |   |   | su |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | co |   |    |                                        |   |
|           |   |   | pe |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Sc |   |    |                                        |   |
|           |   |   | he |   |    |                                        |   |
|           |   |   | du |   |    |                                        |   |
|           |   |   | le |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Bu |   |    |                                        |   |
|           |   |   | dg |   |    |                                        |   |
|           |   |   | et |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | Co |   |    |                                        |   |
|           |   |   | st |   |    |                                        |   |
|           |   |   | Es |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ma |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | Ad |   |    |                                        |   |
|           |   |   | mi |   |    |                                        |   |
|           |   |   | ni |   |    |                                        |   |
|           |   |   | st |   |    |                                        |   |
|           |   |   | ra |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ve |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | up |   |    |                                        |   |
|           |   |   | po |   |    |                                        |   |
|           |   |   | rt |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | P  |   |    |                                        |   |
|           |   |   | ro |   |    |                                        |   |
|           |   |   | je |   |    |                                        |   |
|           |   |   | ct |   |    |                                        |   |
|           |   |   | Co |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | ro |   |    |                                        |   |
|           |   |   | ls |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | L  |   |    |                                        |   |
|           |   |   | eg |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | up |   |    |                                        |   |
|           |   |   | po |   |    |                                        |   |
|           |   |   | rt |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
| **3.1.2** |   | * |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
|           |   | L |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | v |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | l |    |   |    |                                        |   |
|           |   | 6 |    |   |    |                                        |   |
|           |   | - |    |   |    |                                        |   |
|           |   | - |    |   |    |                                        |   |
|           |   | T |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | c |    |   |    |                                        |   |
|           |   | h |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | i |    |   |    |                                        |   |
|           |   | c |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | l |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | d |    |   |    |                                        |   |
|           |   | M |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | g |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | m |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   | S |    |   |    |                                        |   |
|           |   | u |    |   |    |                                        |   |
|           |   | p |    |   |    |                                        |   |
|           |   | p |    |   |    |                                        |   |
|           |   | o |    |   |    |                                        |   |
|           |   | r |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
| **        |   |   | L  |   |    |                                        |   |
| 3.1.2.1** |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | T  |   |    |                                        |   |
|           |   |   | ec |   |    |                                        |   |
|           |   |   | hn |   |    |                                        |   |
|           |   |   | ic |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | E  |   |    |                                        |   |
|           |   |   | va |   |    |                                        |   |
|           |   |   | lu |   |    |                                        |   |
|           |   |   | at |   |    |                                        |   |
|           |   |   | io |   |    |                                        |   |
|           |   |   | ns |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | tr |   |    |                                        |   |
|           |   |   | at |   |    |                                        |   |
|           |   |   | eg |   |    |                                        |   |
|           |   |   | ic |   |    |                                        |   |
|           |   |   | Pl |   |    |                                        |   |
|           |   |   | an |   |    |                                        |   |
|           |   |   | ni |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Te |   |    |                                        |   |
|           |   |   | ch |   |    |                                        |   |
|           |   |   | no |   |    |                                        |   |
|           |   |   | lo |   |    |                                        |   |
|           |   |   | gy |   |    |                                        |   |
|           |   |   | Re |   |    |                                        |   |
|           |   |   | vi |   |    |                                        |   |
|           |   |   | ew |   |    |                                        |   |
|           |   |   | s, |   |    |                                        |   |
|           |   |   | In |   |    |                                        |   |
|           |   |   | te |   |    |                                        |   |
|           |   |   | gr |   |    |                                        |   |
|           |   |   | at |   |    |                                        |   |
|           |   |   | io |   |    |                                        |   |
|           |   |   | n, |   |    |                                        |   |
|           |   |   | De |   |    |                                        |   |
|           |   |   | pl |   |    |                                        |   |
|           |   |   | oy |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Sy |   |    |                                        |   |
|           |   |   | st |   |    |                                        |   |
|           |   |   | em |   |    |                                        |   |
|           |   |   | P  |   |    |                                        |   |
|           |   |   | er |   |    |                                        |   |
|           |   |   | fo |   |    |                                        |   |
|           |   |   | rm |   |    |                                        |   |
|           |   |   | an |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   | R  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | ie |   |    |                                        |   |
|           |   |   | ws |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | C  |   |    |                                        |   |
|           |   |   | on |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | cy |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | Co |   |    |                                        |   |
|           |   |   | rr |   |    |                                        |   |
|           |   |   | ec |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ve |   |    |                                        |   |
|           |   |   | Ac |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | on |   |    |                                        |   |
|           |   |   | P  |   |    |                                        |   |
|           |   |   | la |   |    |                                        |   |
|           |   |   | ns |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | F  |   |    |                                        |   |
|           |   |   | iv |   |    |                                        |   |
|           |   |   | e- |   |    |                                        |   |
|           |   |   | Ye |   |    |                                        |   |
|           |   |   | ar |   |    |                                        |   |
|           |   |   | R  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | ie |   |    |                                        |   |
|           |   |   | ws |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
| **        |   |   | L  |   |    |                                        |   |
| 3.1.2.2** |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | Re |   |    |                                        |   |
|           |   |   | gu |   |    |                                        |   |
|           |   |   | la |   |    |                                        |   |
|           |   |   | to |   |    |                                        |   |
|           |   |   | ry |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | up |   |    |                                        |   |
|           |   |   | po |   |    |                                        |   |
|           |   |   | rt |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | R  |   |    |                                        |   |
|           |   |   | CR |   |    |                                        |   |
|           |   |   | A/ |   |    |                                        |   |
|           |   |   | CE |   |    |                                        |   |
|           |   |   | RC |   |    |                                        |   |
|           |   |   | LA |   |    |                                        |   |
|           |   |   | Is |   |    |                                        |   |
|           |   |   | su |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | NR |   |    |                                        |   |
|           |   |   | DA |   |    |                                        |   |
|           |   |   | Is |   |    |                                        |   |
|           |   |   | su |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | NE |   |    |                                        |   |
|           |   |   | PA |   |    |                                        |   |
|           |   |   | Is |   |    |                                        |   |
|           |   |   | su |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | ta |   |    |                                        |   |
|           |   |   | te |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | O  |   |    |                                        |   |
|           |   |   | th |   |    |                                        |   |
|           |   |   | er |   |    |                                        |   |
|           |   |   | Re |   |    |                                        |   |
|           |   |   | gu |   |    |                                        |   |
|           |   |   | la |   |    |                                        |   |
|           |   |   | to |   |    |                                        |   |
|           |   |   | ry |   |    |                                        |   |
|           |   |   | Is |   |    |                                        |   |
|           |   |   | su |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | Re |   |    |                                        |   |
|           |   |   | qu |   |    |                                        |   |
|           |   |   | ir |   |    |                                        |   |
|           |   |   | em |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | ts |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
| **        |   |   | L  |   |    |                                        |   |
| 3.1.2.3** |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | Ri |   |    |                                        |   |
|           |   |   | sk |   |    |                                        |   |
|           |   |   | As |   |    |                                        |   |
|           |   |   | se |   |    |                                        |   |
|           |   |   | ss |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | Ev |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | ua |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | on |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Si |   |    |                                        |   |
|           |   |   | te |   |    |                                        |   |
|           |   |   | P  |   |    |                                        |   |
|           |   |   | er |   |    |                                        |   |
|           |   |   | fo |   |    |                                        |   |
|           |   |   | rm |   |    |                                        |   |
|           |   |   | an |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | La |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | Re |   |    |                                        |   |
|           |   |   | st |   |    |                                        |   |
|           |   |   | ri |   |    |                                        |   |
|           |   |   | ct |   |    |                                        |   |
|           |   |   | io |   |    |                                        |   |
|           |   |   | ns |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | H  |   |    |                                        |   |
|           |   |   | um |   |    |                                        |   |
|           |   |   | an |   |    |                                        |   |
|           |   |   | He |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | th |   |    |                                        |   |
|           |   |   | A  |   |    |                                        |   |
|           |   |   | ss |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   | sm |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | ts |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Ec |   |    |                                        |   |
|           |   |   | ol |   |    |                                        |   |
|           |   |   | og |   |    |                                        |   |
|           |   |   | ic |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | A  |   |    |                                        |   |
|           |   |   | ss |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   | sm |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | ts |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | He |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | th |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | af |   |    |                                        |   |
|           |   |   | et |   |    |                                        |   |
|           |   |   | y, |   |    |                                        |   |
|           |   |   | Q  |   |    |                                        |   |
|           |   |   | ua |   |    |                                        |   |
|           |   |   | li |   |    |                                        |   |
|           |   |   | ty |   |    |                                        |   |
|           |   |   | As |   |    |                                        |   |
|           |   |   | su |   |    |                                        |   |
|           |   |   | ra |   |    |                                        |   |
|           |   |   | nc |   |    |                                        |   |
|           |   |   | e, |   |    |                                        |   |
|           |   |   | Tr |   |    |                                        |   |
|           |   |   | ai |   |    |                                        |   |
|           |   |   | ni |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | Ge |   |    |                                        |   |
|           |   |   | og |   |    |                                        |   |
|           |   |   | ra |   |    |                                        |   |
|           |   |   | ph |   |    |                                        |   |
|           |   |   | ic |   |    |                                        |   |
|           |   |   | I  |   |    |                                        |   |
|           |   |   | nf |   |    |                                        |   |
|           |   |   | or |   |    |                                        |   |
|           |   |   | ma |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | on |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | ys |   |    |                                        |   |
|           |   |   | te |   |    |                                        |   |
|           |   |   | ms |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
| **        |   |   | L  |   |    |                                        |   |
| 3.1.2.4** |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | I  |   |    |                                        |   |
|           |   |   | nf |   |    |                                        |   |
|           |   |   | or |   |    |                                        |   |
|           |   |   | ma |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | on |   |    |                                        |   |
|           |   |   | Ma |   |    |                                        |   |
|           |   |   | na |   |    |                                        |   |
|           |   |   | ge |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Up |   |    |                                        |   |
|           |   |   | da |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   | Si |   |    |                                        |   |
|           |   |   | te |   |    |                                        |   |
|           |   |   | Co |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | it |   |    |                                        |   |
|           |   |   | io |   |    |                                        |   |
|           |   |   | ns |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | R  |   |    |                                        |   |
|           |   |   | ec |   |    |                                        |   |
|           |   |   | or |   |    |                                        |   |
|           |   |   | ds |   |    |                                        |   |
|           |   |   | Ma |   |    |                                        |   |
|           |   |   | na |   |    |                                        |   |
|           |   |   | ge |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | W  |   |    |                                        |   |
|           |   |   | eb |   |    |                                        |   |
|           |   |   | si |   |    |                                        |   |
|           |   |   | te |   |    |                                        |   |
|           |   |   | D  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | op |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
| **        |   |   | L  |   |    |                                        |   |
| 3.1.2.5** |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | ta |   |    |                                        |   |
|           |   |   | ke |   |    |                                        |   |
|           |   |   | ho |   |    |                                        |   |
|           |   |   | ld |   |    |                                        |   |
|           |   |   | er |   |    |                                        |   |
|           |   |   | I  |   |    |                                        |   |
|           |   |   | nv |   |    |                                        |   |
|           |   |   | ol |   |    |                                        |   |
|           |   |   | ve |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Co |   |    |                                        |   |
|           |   |   | mm |   |    |                                        |   |
|           |   |   | un |   |    |                                        |   |
|           |   |   | ic |   |    |                                        |   |
|           |   |   | at |   |    |                                        |   |
|           |   |   | io |   |    |                                        |   |
|           |   |   | ns |   |    |                                        |   |
|           |   |   | wi |   |    |                                        |   |
|           |   |   | th |   |    |                                        |   |
|           |   |   | L  |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   | se |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | O  |   |    |                                        |   |
|           |   |   | th |   |    |                                        |   |
|           |   |   | er |   |    |                                        |   |
|           |   |   | Si |   |    |                                        |   |
|           |   |   | te |   |    |                                        |   |
|           |   |   | Ow |   |    |                                        |   |
|           |   |   | ne |   |    |                                        |   |
|           |   |   | rs |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Pu |   |    |                                        |   |
|           |   |   | bl |   |    |                                        |   |
|           |   |   | ic |   |    |                                        |   |
|           |   |   | P  |   |    |                                        |   |
|           |   |   | ar |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ci |   |    |                                        |   |
|           |   |   | pa |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | on |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
| **3.1.3** |   | * |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
|           |   | L |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | v |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | l |    |   |    |                                        |   |
|           |   | 6 |    |   |    |                                        |   |
|           |   | - |    |   |    |                                        |   |
|           |   | - |    |   |    |                                        |   |
|           |   | L |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | d |    |   |    |                                        |   |
|           |   | U |    |   |    |                                        |   |
|           |   | s |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | d |    |   |    |                                        |   |
|           |   | I |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | s |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   | i |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   | u |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   | i |    |   |    |                                        |   |
|           |   | o |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | l |    |   |    |                                        |   |
|           |   | C |    |   |    |                                        |   |
|           |   | o |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   | r |    |   |    |                                        |   |
|           |   | o |    |   |    |                                        |   |
|           |   | l |    |   |    |                                        |   |
|           |   | s |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   | T |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | s |    |   |    |                                        |   |
|           |   | k |    |   |    |                                        |   |
|           |   | M |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | g |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | m |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   | L |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | d |    |   |    |                                        |   |
|           |   | U |    |   |    |                                        |   |
|           |   | s |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | M |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | g |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | m |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   | P |    |   |    |                                        |   |
|           |   | l |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | d |    |   |    |                                        |   |
|           |   | R |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | v |    |   |    |                                        |   |
|           |   | i |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | w |    |   |    |                                        |   |
|           |   | s |    |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   | R |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | s |    |   |    |                                        |   |
|           |   | o |    |   |    |                                        |   |
|           |   | u |    |   |    |                                        |   |
|           |   | r |    |   |    |                                        |   |
|           |   | c |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | M |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | g |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | m |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   | A |    |   |    |                                        |   |
|           |   | c |    |   |    |                                        |   |
|           |   | t |    |   |    |                                        |   |
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|           |   | v |    |   |    |                                        |   |
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|           |   | F |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
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|           |   | s |    |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
| **3.1.4** |   | * |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
|           |   | L |    |   |    |                                        |   |
|           |   | e |    |   |    |                                        |   |
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|           |   | 6 |    |   |    |                                        |   |
|           |   | - |    |   |    |                                        |   |
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|           |   | W |    |   |    |                                        |   |
|           |   | i |    |   |    |                                        |   |
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|           |   | n |    |   |    |                                        |   |
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|           |   | n |    |   |    |                                        |   |
|           |   | m |    |   |    |                                        |   |
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|           |   | t |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | l |    |   |    |                                        |   |
|           |   | M |    |   |    |                                        |   |
|           |   | o |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
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|           |   | g |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | n |    |   |    |                                        |   |
|           |   | d |    |   |    |                                        |   |
|           |   | P |    |   |    |                                        |   |
|           |   | h |    |   |    |                                        |   |
|           |   | y |    |   |    |                                        |   |
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|           |   | c |    |   |    |                                        |   |
|           |   | a |    |   |    |                                        |   |
|           |   | l |    |   |    |                                        |   |
|           |   | C |    |   |    |                                        |   |
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|           |   | s |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   |  - |   |    |                                        |   |
|           |   |   | Ta |   |    |                                        |   |
|           |   |   | sk |   |    |                                        |   |
|           |   |   | Ma |   |    |                                        |   |
|           |   |   | na |   |    |                                        |   |
|           |   |   | ge |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | L  |   |    |                                        |   |
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|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | Gr |   |    |                                        |   |
|           |   |   | ou |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | W  |   |    |                                        |   |
|           |   |   | at |   |    |                                        |   |
|           |   |   | er |   |    |                                        |   |
|           |   |   | Mo |   |    |                                        |   |
|           |   |   | ni |   |    |                                        |   |
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|           |   |   | ri |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Sa |   |    |                                        |   |
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|           |   |   | li |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | We |   |    |                                        |   |
|           |   |   | ll |   |    |                                        |   |
|           |   |   | M  |   |    |                                        |   |
|           |   |   | ai |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
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|           |   |   | an |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | St |   |    |                                        |   |
|           |   |   | ru |   |    |                                        |   |
|           |   |   | ct |   |    |                                        |   |
|           |   |   | ur |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | Co |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | ro |   |    |                                        |   |
|           |   |   | ls |   |    |                                        |   |
|           |   |   | M  |   |    |                                        |   |
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|           |   |   | an |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | E  |   |    |                                        |   |
|           |   |   | qu |   |    |                                        |   |
|           |   |   | ip |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | Su |   |    |                                        |   |
|           |   |   | pp |   |    |                                        |   |
|           |   |   | li |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Da |   |    |                                        |   |
|           |   |   | ta |   |    |                                        |   |
|           |   |   | Ma |   |    |                                        |   |
|           |   |   | na |   |    |                                        |   |
|           |   |   | ge |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | R  |   |    |                                        |   |
|           |   |   | ep |   |    |                                        |   |
|           |   |   | or |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | ur |   |    |                                        |   |
|           |   |   | fa |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   | W  |   |    |                                        |   |
|           |   |   | at |   |    |                                        |   |
|           |   |   | er |   |    |                                        |   |
|           |   |   | Mo |   |    |                                        |   |
|           |   |   | ni |   |    |                                        |   |
|           |   |   | to |   |    |                                        |   |
|           |   |   | ri |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Sa |   |    |                                        |   |
|           |   |   | mp |   |    |                                        |   |
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|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | tr |   |    |                                        |   |
|           |   |   | uc |   |    |                                        |   |
|           |   |   | tu |   |    |                                        |   |
|           |   |   | re |   |    |                                        |   |
|           |   |   | M  |   |    |                                        |   |
|           |   |   | ai |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | an |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | St |   |    |                                        |   |
|           |   |   | ru |   |    |                                        |   |
|           |   |   | ct |   |    |                                        |   |
|           |   |   | ur |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | Co |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | ro |   |    |                                        |   |
|           |   |   | ls |   |    |                                        |   |
|           |   |   | M  |   |    |                                        |   |
|           |   |   | ai |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | an |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | E  |   |    |                                        |   |
|           |   |   | qu |   |    |                                        |   |
|           |   |   | ip |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | Su |   |    |                                        |   |
|           |   |   | pp |   |    |                                        |   |
|           |   |   | li |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Da |   |    |                                        |   |
|           |   |   | ta |   |    |                                        |   |
|           |   |   | Ma |   |    |                                        |   |
|           |   |   | na |   |    |                                        |   |
|           |   |   | ge |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | R  |   |    |                                        |   |
|           |   |   | ep |   |    |                                        |   |
|           |   |   | or |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | A  |   |    |                                        |   |
|           |   |   | ir |   |    |                                        |   |
|           |   |   | Mo |   |    |                                        |   |
|           |   |   | ni |   |    |                                        |   |
|           |   |   | to |   |    |                                        |   |
|           |   |   | ri |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Sa |   |    |                                        |   |
|           |   |   | mp |   |    |                                        |   |
|           |   |   | li |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | tr |   |    |                                        |   |
|           |   |   | uc |   |    |                                        |   |
|           |   |   | tu |   |    |                                        |   |
|           |   |   | re |   |    |                                        |   |
|           |   |   | M  |   |    |                                        |   |
|           |   |   | ai |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | an |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | St |   |    |                                        |   |
|           |   |   | ru |   |    |                                        |   |
|           |   |   | ct |   |    |                                        |   |
|           |   |   | ur |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | Co |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | ro |   |    |                                        |   |
|           |   |   | ls |   |    |                                        |   |
|           |   |   | M  |   |    |                                        |   |
|           |   |   | ai |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | an |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | E  |   |    |                                        |   |
|           |   |   | qu |   |    |                                        |   |
|           |   |   | ip |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | Su |   |    |                                        |   |
|           |   |   | pp |   |    |                                        |   |
|           |   |   | li |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Da |   |    |                                        |   |
|           |   |   | ta |   |    |                                        |   |
|           |   |   | Ma |   |    |                                        |   |
|           |   |   | na |   |    |                                        |   |
|           |   |   | ge |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | R  |   |    |                                        |   |
|           |   |   | ep |   |    |                                        |   |
|           |   |   | or |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
|           |   |   | el |   |    |                                        |   |
|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | oi |   |    |                                        |   |
|           |   |   | ls |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | S  |   |    |                                        |   |
|           |   |   | ed |   |    |                                        |   |
|           |   |   | im |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | ts |   |    |                                        |   |
|           |   |   | Mo |   |    |                                        |   |
|           |   |   | ni |   |    |                                        |   |
|           |   |   | to |   |    |                                        |   |
|           |   |   | ri |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Sa |   |    |                                        |   |
|           |   |   | mp |   |    |                                        |   |
|           |   |   | li |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | St |   |    |                                        |   |
|           |   |   | ru |   |    |                                        |   |
|           |   |   | ct |   |    |                                        |   |
|           |   |   | ur |   |    |                                        |   |
|           |   |   | al |   |    |                                        |   |
|           |   |   | Co |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | ro |   |    |                                        |   |
|           |   |   | ls |   |    |                                        |   |
|           |   |   | M  |   |    |                                        |   |
|           |   |   | ai |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | en |   |    |                                        |   |
|           |   |   | an |   |    |                                        |   |
|           |   |   | ce |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | E  |   |    |                                        |   |
|           |   |   | qu |   |    |                                        |   |
|           |   |   | ip |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | Su |   |    |                                        |   |
|           |   |   | pp |   |    |                                        |   |
|           |   |   | li |   |    |                                        |   |
|           |   |   | es |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | Da |   |    |                                        |   |
|           |   |   | ta |   |    |                                        |   |
|           |   |   | Ma |   |    |                                        |   |
|           |   |   | na |   |    |                                        |   |
|           |   |   | ge |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
|           |   |   | a  |   |    |                                        |   |
|           |   |   | nd |   |    |                                        |   |
|           |   |   | R  |   |    |                                        |   |
|           |   |   | ep |   |    |                                        |   |
|           |   |   | or |   |    |                                        |   |
|           |   |   | ti |   |    |                                        |   |
|           |   |   | ng |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
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|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | B  |   |    |                                        |   |
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|           |   |   | /O |   |    |                                        |   |
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|           |   |   | to |   |    |                                        |   |
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+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
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|           |   |   | a  |   |    |                                        |   |
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|           |   |   | Ma |   |    |                                        |   |
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|           |   |   | me |   |    |                                        |   |
|           |   |   | nt |   |    |                                        |   |
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|           |   |   | ti |   |    |                                        |   |
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+-----------+---+---+----+---+----+----------------------------------------+---+
| **3.1.5** |   | * |    |   |    |                                        |   |
|           |   | * |    |   |    |                                        |   |
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|           |   | * |    |   |    |                                        |   |
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+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
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|           |   |   | 7  |   |    |                                        |   |
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|           |   |   | Si |   |    |                                        |   |
|           |   |   | gn |   |    |                                        |   |
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|           |   |   | nd |   |    |                                        |   |
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|           |   |   | ra |   |    |                                        |   |
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|           |   |   | io |   |    |                                        |   |
|           |   |   | n, |   |    |                                        |   |
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|           |   |   | l) |   |    |                                        |   |
|           |   |   |    |   |    |                                        |   |
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|           |   |   | Mo |   |    |                                        |   |
|           |   |   | ni |   |    |                                        |   |
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|           |   |   | ri |   |    |                                        |   |
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|           |   |   |    |   |    |                                        |   |
|           |   |   | E  |   |    |                                        |   |
|           |   |   | qu |   |    |                                        |   |
|           |   |   | ip |   |    |                                        |   |
|           |   |   | me |   |    |                                        |   |
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|           |   |   | a  |   |    |                                        |   |
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|           |   |   | Su |   |    |                                        |   |
|           |   |   | pp |   |    |                                        |   |
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|           |   |   | Ma |   |    |                                        |   |
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|           |   |   | ti |   |    |                                        |   |
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+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   | L  |   |    |                                        |   |
|           |   |   | ev |   |    |                                        |   |
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|           |   |   | 7  |   |    |                                        |   |
|           |   |   | -- |   |    |                                        |   |
|           |   |   | En |   |    |                                        |   |
|           |   |   | gi |   |    |                                        |   |
|           |   |   | ne |   |    |                                        |   |
|           |   |   | er |   |    |                                        |   |
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|           |   |   | ni |   |    |                                        |   |
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+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   |    | L |    |                                        |   |
|           |   |   |    | e |    |                                        |   |
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|           |   |   |    | 8 |    |                                        |   |
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|           |   |   |    | : |    |                                        |   |
|           |   |   |    | L |    |                                        |   |
|           |   |   |    | a |    |                                        |   |
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|           |   |   |    | u |    |                                        |   |
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|           |   |   |    | d |    |                                        |   |
|           |   |   |    | W |    |                                        |   |
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|           |   |   |    | t |    |                                        |   |
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|           |   |   |    | M |    |                                        |   |
|           |   |   |    | o |    |                                        |   |
|           |   |   |    | n |    |                                        |   |
|           |   |   |    | i |    |                                        |   |
|           |   |   |    | t |    |                                        |   |
|           |   |   |    | o |    |                                        |   |
|           |   |   |    | r |    |                                        |   |
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|           |   |   |    | g |    |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   |    |   |    | Level 9 -- Leachate Collection System  |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Operation and Maintenance              |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Sampling                               |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Structural Controls Monitoring         |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Equipment and Supplies                 |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Data Management and Reporting          |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   |    |   |    | Level 9 -- Vadose Zone Extraction and  |   |
|           |   |   |    |   |    | Monitoring                             |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Operation and Maintenance              |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Sampling                               |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Structural Controls Monitoring         |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Equipment and Supplies                 |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Data Management and Reporting          |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   |    |   |    | Level 9 -- Ground water Monitoring     |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Operation and Maintenance              |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Sampling                               |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Structural Controls Monitoring         |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Equipment and Supplies                 |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Data Management and Reporting          |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   |    |   | L  |                                        |   |
|           |   |   |    |   | ev |                                        |   |
|           |   |   |    |   | el |                                        |   |
|           |   |   |    |   | 8  |                                        |   |
|           |   |   |    |   | -- |                                        |   |
|           |   |   |    |   | Ex |                                        |   |
|           |   |   |    |   | am |                                        |   |
|           |   |   |    |   | pl |                                        |   |
|           |   |   |    |   | e: |                                        |   |
|           |   |   |    |   | Fo |                                        |   |
|           |   |   |    |   | rm |                                        |   |
|           |   |   |    |   | er |                                        |   |
|           |   |   |    |   | Di |                                        |   |
|           |   |   |    |   | sp |                                        |   |
|           |   |   |    |   | os |                                        |   |
|           |   |   |    |   | al |                                        |   |
|           |   |   |    |   | C  |                                        |   |
|           |   |   |    |   | el |                                        |   |
|           |   |   |    |   | l, |                                        |   |
|           |   |   |    |   | Gr |                                        |   |
|           |   |   |    |   | ou |                                        |   |
|           |   |   |    |   | nd |                                        |   |
|           |   |   |    |   | W  |                                        |   |
|           |   |   |    |   | at |                                        |   |
|           |   |   |    |   | er |                                        |   |
|           |   |   |    |   | Pu |                                        |   |
|           |   |   |    |   | mp |                                        |   |
|           |   |   |    |   | a  |                                        |   |
|           |   |   |    |   | nd |                                        |   |
|           |   |   |    |   | T  |                                        |   |
|           |   |   |    |   | re |                                        |   |
|           |   |   |    |   | at |                                        |   |
|           |   |   |    |   | a  |                                        |   |
|           |   |   |    |   | nd |                                        |   |
|           |   |   |    |   | Mo |                                        |   |
|           |   |   |    |   | ni |                                        |   |
|           |   |   |    |   | to |                                        |   |
|           |   |   |    |   | ri |                                        |   |
|           |   |   |    |   | ng |                                        |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   |    |   |    | Level 9 -- Ground Water Pump and Treat |   |
|           |   |   |    |   |    | System                                 |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Operation and Maintenance              |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Sampling                               |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Structural Controls Monitoring         |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Equipment and Supplies                 |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Data Management and Reporting          |   |
+-----------+---+---+----+---+----+----------------------------------------+---+
|           |   |   |    |   |    | Level 9 -- Ground Water Monitoring     |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Monitoring                             |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Well Maintenance                       |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Structural Controls Maintenance        |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Equipment and Supplies                 |   |
|           |   |   |    |   |    |                                        |   |
|           |   |   |    |   |    | Data Management and Reporting          |   |
+-----------+---+---+----+---+----+----------------------------------------+---+

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height="3.4097222222222223in"}

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