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HomeMy WebLinkAbout2023 12 11 Consent 301 - Lead & Copper Rule Revision Compliance & Lead Service Line Inventory AssistanceCONSENT AGENDA ITEM 301 CITY COMMISSION AGENDA | DECEMBER 11, 2023 REGULAR MEETING TITLE Lead & Copper Rule Revision Compliance & Lead Service Line Inventory Assistance SUMMARY The U.S. Environmental Protection Agency (EPA) published revisions to the Safe Drinking Water Act (SDWA) Lead and Copper Rule (LCR) in the Federal Register in January 2021 (with an enforced compliance date of October 16, 2024). The LCR Revisions (LCRR) require near term-strategies for public water system compliance for all utilities. Notably, the LCRR requires that all water systems create an inventory of lead service lines (LSLs), or demonstrate absence of LSLs, by the October 2024 compliance date. This LSL inventory requirement represents a significant step toward safeguarding public health from lead exposure through drinking water (by mandating all water utility providers to develop comprehensive inventories of their service lines). At this point in time, the purpose of the LCRR is to collect data, set the stage for informed decision-making and plan for any future replacements, if needed. While immediate replacement obligations are not imposed, a replacement plan for LSLs (if found) will be required by the October 2024 compliance date. Transparent, timely, and effective communication with the residents of Winter Springs is a key component of LCRR compliance. Carollo Engineers, Inc. will provide plan development, technical reporting, field coordination, regulatory support, and community outreach and communication to meet requirements of the LCRR by the compliance October 2024 date. This project will be ongoing for the next year and costs $262,521.76. FUNDING SOURCE RECOMMENDATION Staff recommends the Commission approve Carollo Engineers to provide work totaling $262,521.76 to meet the requirements of the Lead and Copper Rule Revisions and authorize the Interim City Manager and City Attorney to prepare and execute any and all applicable documents consistent with this item. 69 200 East Robinson Street, Suite 1400, Orlando, Florida 32801 P. 407.478.4642 F. 407.478.4643 Winter Springs LCRR Compliance and LSL Inventory Assistance Scope_ͭͬͮͱͮͯ.docx City of Winter Springs LCRR Compliance and LSL Inventory Assistance October ͮͬͮͯ SCOPE OF SERVICES PROJECT BACKGROUND AND DESCRIPTION The U.S. Environmental Protection Agency (EPA) published revisions to the Safe Drinking Water Act (SDWA) Lead and Copper Rule (LCR) in the Federal Register on January ͭͱ, ͮͬͮͭ (ʹͲ FR Ͱͭ͵ʹ). The LCR Revisions (LCRR) are delineated into six (Ͳ) key focus areas which include the following: ͭ. Identifying the areas most impacted. ͮ. Strengthening drinking water treatment requirements. ͯ. Replacing lead service lines. Ͱ. Increasing sampling reliability. ͱ. Improving risk communication. Ͳ. Protecting children in schools and childcare facilities. Several of the revisions require significant, near-term strategies for public water system compliance. Notably, the LCRR requires that water systems create an inventory of lead service lines (LSLs), or demonstrated absence of LSLs, by the October ͭͲ, ͮͬͮͰ compliance date. These inventories include classification of service lines with unknown materials as “lead status unknown” as well as service lines with galvanized pipes formerly or currently downstream of LSLs as “galvanized requiring replacement”. Water systems are required to alert customers annually if they are served by “lead,” “lead status unknown,” or “galvanized requiring replacement” service lines. Additional modifications under the LCRR include a new ͭͬ µg/L trigger level based on ͵ͬth percentile lead concentrations, and follow-up requirements for individual tap samples above ͭͱ µg/L. Under the LCRR, water systems are also required to sample ͮͬ% of all schools and childcare facilities each year for five years until all such facilities have been sampled. Water systems must develop a list of childcare facilities and elementary schools in advance of the October ͭͲ, ͮͬͮͰ deadline. The LCRR requires that water systems complete the following steps by October ͭͲ, ͮͬͮͰ: • Develop a lead service line inventory (LSLI); • Develop an LSL replacement plan, unless all service lines are confirmed to be non-lead; • Update the list of lead and copper compliance sampling locations as applicable to meet the revised tiering structure under the LCRR; • Prepare a list of childcare facilities and elementary schools within the service area; and • Develop updated communications that address new public education and outreach requirements under the LCRR. 70 City of Winter Springs LCRR Compliance Plan and LSL Inventory Assistance Scope of Services Page ͮ This Scope of Services authorizes Carollo Engineers, Inc. (Carollo) to assist the City of Winter Springs (City) with developing a LCRR compliance plan and the initial LSL inventory. Tasks are also included in this Scope of Services to provide the City with: ͭ. An LSL Replacement Plan (if the City is known or expected to have LSLs). ͮ. An updated LCRR sampling plan if the findings of the LSL inventory require updates to the sampling pool or protocols. ͯ. School and childcare facility sampling guidance, including the initial list of facilities and guidance based on the LCRR requirements for sampling procedure and outreach. Ͱ. Communications and outreach templates based on LCRR requirements. The following presents the specific tasks that will be performed as part of this Scope of Services. Certain assumptions have been made in preparing this Scope of Services. To the extent possible, they are stated herein, and are reflected in the attached Project Budget. As of this Scope of Services, FDEP has not provided guidance or state-specific rule language. This Scope of Services assumes that FDEP requirements will be identical to federal requirements. SCOPE OF SERVICES The scope of services to be provided as part of this project is summarized by the following tasks:  Task ͭ – Data Review and Compliance Plan o Task ͭ.ͭ – LCRR Data Request and Review o Task ͭ.ͮ – LCRR Compliance Plan  Task ͮ – LSL Inventory and LCRR Compliance Assistance o Task ͮ.ͭ – LSL Inventory Development o Task ͮ.ͮ – LSL Replacement Plan o Task ͮ.ͯ – LCRR Sampling Plan Updates o Task ͮ.Ͱ – School and Childcare Facilities Sampling Guidance o Task ͮ.ͱ – Communications and Outreach Templates  Task ͯ – Project Management, Meetings, and Regulatory Coordination o Task ͯ.ͭ – Project Management and Meetings o Task ͯ.ͮ – Regulatory Coordination  Task Ͱ – As-Needed Contingency Carollo will coordinate and perform quality assurance and quality control (QA/QC) for the project, facilitated by a Quality Manager assigned to the project. Hours for QA/QC are included in the associated task. TASK ͭ – DATA REVIEW AND COMPLIANCE PLAN Task 1.1 – LCRR Data Request and Review Carollo will develop and submit a data request to establish existing conditions pertinent to the City’s LCRR compliance strategy. The data request will be submitted at the beginning of the project. Carollo will perform a preliminary review of the information prior to the kickoff meeting so that the kickoff meeting can be a productive workshop. If data gaps are identified during the workshop, Carollo will communicate these gaps to the City and work with the City to address these gaps. 71 City of Winter Springs LCRR Compliance Plan and LSL Inventory Assistance Scope of Services Page ͯ Items requested for background may include, but are not limited to: ͭ. Historical lead and copper monitoring data. ͮ. Locations of historical monitoring data. ͯ. Methods for lead and copper sampling. Ͱ. Historical water quality data for the City’s water supplies. Water quality data of interest includes lead, copper, pH, alkalinity, calcium, chloride, sulfate, total dissolved solids, temperature, and other water quality parameters impacting corrosion. ͱ. Representative subset of tax assessor records on property ages, tap cards, and plumbing permits. Ͳ. Maps of distribution system, neighborhood or subregional water systems, and service line materials (shapefiles). ͳ. Information on the City’s programs that could be sources of information on service line materials (e.g., meter replacement programs, if applicable). ʹ. Available information on childcare facilities and schools. ͵. Information on current LCR communication practices and materials. Carollo will provide a cursory review of the historical water quality and lead and copper data to evaluate potential compliance considerations under the LCRR. Carollo will work with the City to review a subset of the historical records that EPA requires water systems to review under the LCRR to identify which source(s) of information can be used to facilitate development of an initial service line inventory. This initial records review will also support LCRR requirements stating that water systems review construction and plumbing codes, permits, distribution system maps and drawings, historical records on service connection, meter installation records, and other information to identify service line materials for the initial inventory. Carollo will also review the City’s geographic information system (GIS) and identify opportunities to pull in records to facilitate inventory development. Findings will be presented at a monthly progress meeting to facilitate a discussion with the City on data management preferences for the LSL inventory (e.g., using ESRI’s LSL Inventory display tools, and/or the EPA template). Task ͭ.ͭ Deliverables:  Data request, submitted electronically in .pdf or Microsoft Excel format. Task 1.2 – LCRR Compliance Plan Carollo will develop a concise memorandum for the City to comply with the LCRR. For each major rule revision that could impact the City, Carollo will outline the City’s current compliance status (e.g., documentation of publicly owned portion of the service lines) and a strategy for compliance. • LSL Inventory Guidance. A range of approaches have been proposed/used for utilities to identify LSLs that can be categorized as either direct or indirect identification. Indirect identification includes reviewing property records, using machine learning to improve predictions of LSL locations, or conducting sample profiles correlated to aliquots of water coming from inside the house, versus the service line. Customer surveys can also be used, specifically for information on materials used in the privately-owned portion of the service line. Direct identification methods include inspecting the service lines at the meter box, using CCTV, and/or excavating or potholing to confirm service line materials from the curb stop to the house. Carollo will work with the City to 72 City of Winter Springs LCRR Compliance Plan and LSL Inventory Assistance Scope of Services Page Ͱ identify available data which may be incorporated into the LSL Inventory. After meeting with the Florida Department of Environmental Protection (FDEP) under Task ͯ.ͮ to confirm approaches that meet state requirements for developing information on service line materials (focused on the privately owned portion that has not yet been documented), Carollo will provide recommendations to the City. • Review Communication Strategy. The LCRR requires new public communication steps such as ͮͰ- hour notice prior to the disturbance of an LSL and individual notification of all persons served by a sampled tap that exceeds the ͭͱ ug/L action level within ͳͮ hours. Carollo will review current public communication strategies for needed modifications to meet the various new requirements under the LCRR. • Modified Sampling Plan and Locations. Carollo will review potential impacts of the rule revisions on the City’s current LCR monitoring locations and methodologies to provide recommendations for any changes factoring in available information on LSLs. Carollo will review sample sites and identify any changes in sample locations based on the LCRR. Carollo will also review current sampling protocols for any changes required to comply with the LCRR. For example, the LCRR requires collection of the fifth liter sample (rather than the first liter) from homes with LSLs. Carollo will review LCRR requirements for sampling licensed childcare facilities and elementary schools and identify steps for City compliance. • Review Water Treatment Requirements. Carollo will review the City’s lead data to preliminarily assess whether the City could be impacted by reporting requirements for individual sample values above ͭͱ µg/L. Concentrations could change with revised sampling locations and procedures (i.e., ͱth liter) under the LCRR. Carollo will also review rule changes to identify other possible impacts to the City. For example, Carollo will review the current corrosion control treatment approach for compatibility with LCRR requirements on strengthening corrosion control treatment. • Coordinate with FDEP. Carollo will coordinate with FDEP under Task ͯ.ͮ to confirm state requirements for LCRR compliance. • Draft and Final LCRR Compliance Plan. Carollo will develop a draft and final LCRR Compliance Strategy Plan memorandum. The LCRR Compliance Strategy Plan is intended to provide a roadmap for compliance with the new requirements by the stipulated deadlines (e.g., completion of an LSL inventory by October ͭͲ, ͮͬͮͰ). The steps will be prioritized and delineated into multiple phases to help group projects/activities for sequential completion. Task ͭ.ͮ Deliverables:  Draft and Final LCRR Compliance Plan memorandum, submitted electronically in .pdf format. TASK ͮ – LSL INVENTORY AND LCRR COMPLIANCE ASSISTANCE Task 2.1 – LSL Inventory Development Carollo will implement the plans for developing the LSL Inventory, as provided in the LCRR Compliance Plan, which will include the following major activities: • Develop Data Management Framework. Development of a data management framework, potentially using a combination of the City’s GIS system and the EPA service line inventory template. • Review Historical Records. Based on feedback from the City and FDEP during Task ͭ.ͮ, Carollo will compile and review historical records that inform the service line material designations. 73 City of Winter Springs LCRR Compliance Plan and LSL Inventory Assistance Scope of Services Page ͱ • Integrate Historical Record Data. Data integration from historical records into the data management platform, including property age, pipe size diameter, and any additional relevant data from work order requests, plumbing codes and permits, etc. If FDEP allows for and the City elects to include customer surveys, profiled sampling, and/or geostatistics to support the LSL inventory development, Carollo can support those activities as part of this task. Note, however, that the fee estimate does not include costs for geostatistical modeling, profiled sampling, or survey application. A Draft LSL Inventory, based on the record review alone, will be developed prior to field investigations. • Field Investigation Support. Carollo will work with the City to develop a prioritized list of properties for field inspection, focused on homes constructed prior to ͭ͵ʹ͵ and with service line diameters less than a predetermined pipe diameter (e.g., ͮ-inches). The percentage of homes for field verification will require concurrence from FDEP. The Florida ban on lead plumbing materials was first promulgated on January ͭʹ, ͭ͵ʹ͵, and field verification could therefore be a substantial effort if there are many unknown lines. It is possible that historical records or plumbing practices show lead typically not installed after an earlier date, so these investigations will be dependent on the reliability of historical information. Properties for field inspection will focus on a subset of homes within neighborhoods constructed around the same time, using similar plans. Carollo will meet with FDEP under Task ͯ.ͮ to confirm the percentage of homes requiring inspection. Carollo will then develop standard operating procedures (SOPs), training, and limited quality control for field inspection activities. SOPs and training could be provided for City staff or contractors that respond to work order requests, conduct meter replacements, or read meters, taking advantage of ongoing activities to also document service line materials. This scope of work assumes the City will perform all field investigations, including potholing for a small subset of homeowner service lines. Carollo will perform on-site field investigation quality control of up to twenty City-performed investigations, limited by the hours presented in the fee breakdown sheet. Carollo will perform the on-site field investigation quality control between the hours of ʹ:ͯͬ am and Ͱ:ͯͬ pm for homes either requiring, or not requiring, potholing. • Continued Regulatory Coordination. Carollo will continue to meet with FDEP under Task ͯ.ͮ to confirm state requirements for developing the LSL inventory. In addition to email and phone communication, one meeting is assumed. • LSL Inventory Submittal Support. Carollo will coordinate with the City and FDEP to submit the FDEP-compliant LSL inventory by October ͭͲ, ͮͬͮͰ. Under this subtask, Carollo will also support the City in completing a GIS-based inventory with a publicly available map if the City elects to use this format. Task ͯ.ͭ includes up to two coordination meetings with the City, limited to the hours in the fee breakdown sheet, for final QA/QC of the inventory and to complete any final steps for the LSL Inventory submittal. Task ͮ.ͭ Deliverables:  Draft and Final Field Inspection SOPs, submitted electronically in .pdf format.  Draft and Final LSL Inventory submitted electronically. Task 2.2 – LSL Replacement Plan Under this subtask, Carollo will prepare lead service line replacement (LSLR) plan for the City including the following information: 74 City of Winter Springs LCRR Compliance Plan and LSL Inventory Assistance Scope of Services Page Ͳ  LSLR prioritization strategy. Carollo will develop a LSLR prioritization strategy that may be based on factors, including but not limited to, the targeting of known LSLs, LSLR for disadvantaged consumers, and populations most sensitive to the effects of lead. This prioritization could include GIS tools for vulnerable communities if available.  Unknown Service Line Strategy. Carollo will develop a utility-wide strategy for determining the composition of lead status unknown service lines in the City’s inventory.  LSLR Goal Rate. In conjunction with the City and FDEP, Carollo will develop a recommended LSLR goal rate in the event of a lead trigger exceedance level (the minimum mandatory full LSLR requirement rate is ͯ% annually).  Full LSLR Procedures. Carollo will review the City’s existing LSLR procedures, if available, and develop procedures for full LSLR if required. Carollo will also develop procedures and strategies for informing customers before LSLR and flushing service lines.  Funding strategy. Carollo will work with the City to evaluate funding strategies for conducting LSLRs which considers ways to accommodate customers that are unable to pay to replace the portion they own. The plan will also include a strategy for informing customers before full or partial LSLRs and a procedure for customers to flush their service lines and plumbing of particulate lead. Task ͮ.ͮ Deliverables:  Draft and Final LSL Replacement Plan submitted electronically. Task 2.3 – LCRR Sampling Plan Updates After substantial completion of the LSL inventory, Carollo will review current LCR sample locations and work with the City to update the sampling pool to reflect the new tiering structure. Carollo will develop a comprehensive sampling plan specific to the City’s needs, factoring in revised sampling locations and protocols (e.g., ͱth liter samples for any lead or galvanized requiring replacement (GRR) service lines). Carollo will support the City in submitting the LCRR-compliant sampling plan to FDEP. Task ͮ.ͯ Deliverables:  Revised list of sampling sites, if changed under the LCRR.  Revised tap sampling protocols, if changed under the LCRR. Task 2.4 – School and Childcare Facilities Sampling Guidance Carollo will support the City in preparing for and completing the first year of school sampling, including developing: • A list of schools and childcare facilities. • Sampling protocols for school sampling. Task ͮ.Ͱ Deliverables:  List of schools and childcare facilities.  Tap sampling protocols for schools and childcare facilities. 75 City of Winter Springs LCRR Compliance Plan and LSL Inventory Assistance Scope of Services Page ͳ Task 2.5 – Communications and Outreach Templates Carollo will develop templates for public education materials required under the LCRR, including: • Updated language on lead in drinking water for the consumer confidence report; • Communication to customers with LSLs, GRR, or lead status unknown service lines (LSUSLs); • Communication to property owners identified under the LCRR-compliant sampling plan; • Draft surveys for customer input on service line material type on the privately-owned side of the meter (optional); and • Communication material for sampling in schools. These public education material templates will be included in an LCRR Communications Plan to be submitted to the City. Transparent, timely, and effective communication is a key component of LCRR compliance. Even more importantly, communication is critical for maintaining public confidence in the potable water supply and for customer participation in key compliance activities, including sampling at new locations under the revised tiering structure, completion of surveys to identify service line materials on the customer side of the meter, and sampling in schools. Task ͮ.ͱ Deliverables:  Draft and Final LCRR Communications Plan, including templates for public education requirements. TASK ͯ – PROJECT MANAGEMENT, MEETINGS, AND REGULATORY COORDINATION Task 3.1 – Project Management and Meetings Carollo will perform project management tasks including the following: ͭ. Manage project team, activities, and budget. ͮ. Prepare for and attend one (ͭ) kick-off meeting and up to eight (ʹ) progress meetings with City staff. Task ͯ.ͭ Deliverables:  Monthly invoices and progress reports to be submitted electronically.  Meeting agenda and minutes, to be submitted electronically. Task 3.2 – Regulatory Coordination Carollo will continue to coordinate with FDEP throughout the project. FDEP has not yet published state- specific requirements for some aspects of the LCRR. Carollo will meet with FDEP early in the project during the development of the LCRR compliance plan to confirm state requirements. Additionally, state allowance for using geostatistical methods to confirm service line material type will be discussed if those tools are of interest to the City. During the LSL inventory development in Task ͮ.ͭ, Carollo will continue to meet with FDEP to confirm state requirements for the inventory. In addition to email and phone communication, this task includes up to four meetings with FDEP, limited to the hours in the fee breakdown sheet. 76 City of Winter Springs LCRR Compliance Plan and LSL Inventory Assistance Scope of Services Page ʹ TASK Ͱ – AS-NEEDED CONTINGENCY Task 4.1 – Additional Field Investigation and Funding Support Depending on the quality and quantity of existing data records, as well as the availability of City staff, support from Carollo may be required. This task is intended to provide as-needed field investigation support to the City crew through as-needed contractor or surveyor services (i.e., completing site visits, pulling meter boxes, verifying pipe material, in-field inventory/logging via GIS, etc.). This task does not include Carollo independently performing field work. As the level of effort is unknown at this time for this as-needed support, the scope of work under this task is limited by the allotted budget. This task is also intended to provide support to the City in identifying funding opportunities for the Project, within the allotted budget. WORK ASSIGNMENT ASSUMPTIONS Because of the nature of this project, certain assumptions apply to this Scope of Services. To the extent possible, these assumptions are stated within this document and are reflected in the budget. If the project task requirements are different from the assumptions presented in this Scope of Services, or if the City desires additional services, the resultant change in scope will serve as a basis for amending this project assignment or initiating the development of a new project assignment as agreed to by both the City and Carollo. The EPA is currently developing additional legislation, known as the Lead and Copper Rule Improvements (LCRI). According to the EPA, all aspects of the LCRR are potentially subject to revision except for the initial LSL inventory. However, potential future revisions in the LCRI do not remove or adjust the existing compliance deadline for the LCRR. This scope of work assumes that utility compliance requirements will not change prior to the compliance date of October ͭͲ, ͮͬͮͰ. The following additional assumptions and City responsibilities apply to this project: ͭ. This project will be executed collaboratively by the City and Carollo. ͮ. The general work split between the City and Carollo for Task ͮ.ͭ – LSL Inventory Development is assumed to be as follows: a. Carollo will prepare a draft LSL inventory for review by the City prior to field investigations. b. Carollo will prepare forms or other tools for use in gathering data during field investigations. c. The City will be responsible for performing or hiring and managing contractors to perform field work. d. The City will be responsible for notifying customers and property owners about field inspections. e. Carollo will accompany the City or their contractor(s) on initial field investigations for the purpose of observing the process. ͯ. The City will provide data and information as listed in Carollo’s data request in electronic spreadsheet format to the extent possible. Ͱ. Carollo shall be entitled to rely upon the accuracy of the data and information supplied by the City without independent review or evaluation. 77 City of Winter Springs LCRR Compliance Plan and LSL Inventory Assistance Scope of Services Page ͵ ͱ. The City shall attend all workshops and review meetings to maintain the progress of the project according to the schedule. Ͳ. The City will provide Carollo with access to facilities for data gathering if necessary. ͳ. Carollo will complete only a cursory review of corrosion control treatment, water quality, and corrosion indices during Task 2.1. ʹ. The scope is focused on meeting compliance items required by October ͭͲ, ͮͬͮͰ. ͵. The LSL Inventory submittal will consist of the required forms coupled with a GIS interface using the ESRI tool. ͭͬ. The City will provide all required information within the period established in the schedule contained in this Scope of Services. The schedule is based on timely receipt of data from the City. The City shall review Draft deliverables and provide comments to Carollo within a two- week period. ͭͭ. Carollo has no control over the cost of labor, materials, equipment or services furnished by others, over the incoming water/wastewater quality and/or quantity, or over the way the City’s plant(s) and/or associated processes are operated and/or maintained. Data projections and estimates are based on Carollo’s opinion based on experience and judgment. Carollo cannot and does not guarantee that actual costs and/or quantities realized will not vary from the data projections and estimates prepared by Carollo and Carollo will not be liable to and/or indemnify the City and/or any third party related to any inconsistencies between Carollo’s data projections and estimates and actual costs and/or quantities realized by the City and/or any third party in the future. ͭͮ. The services to be performed by Carollo are intended solely for the benefit of the City. No person or entity not a signatory to this Scope of Work shall be entitled to rely on Carollo's performance of its services hereunder, and no right to assert a claim against Carollo by assignment of indemnity rights or otherwise shall accrue to a third party as a result of this Scope of Work or the performance of Carollo's services hereunder. DELIVERABLES As outlined in the individual tasks of this Scope of Services, Carollo will provide the City with the following deliverables: ͭ. Task ͭ – Data Review and Compliance Plan a. Data request, submitted electronically in .pdf or Microsoft Excel format. b. Draft and Final LCRR Compliance Plan memorandum, submitted electronically in .pdf format. ͮ. Task ͮ – LSL Inventory and LCRR Compliance Assistance a. Draft and Final Field Inspection SOPs, submitted electronically in .pdf format. b. Draft and Final LSL Inventory submitted electronically. c. Draft and Final LSL Replacement Plan submitted electronically. d. Revised list of sampling sites, if changed under the LCRR. e. Revised tap sampling protocols, if changed under the LCRR. f. List of schools and childcare facilities. g. Tap sampling protocols for schools and childcare facilities. h. Draft and Final LCRR Communications Plan, including templates for public education requirements. 78 City of Winter Springs LCRR Compliance Plan and LSL Inventory Assistance Scope of Services Page ͭͬ ͯ. Task ͯ – Project Management, Meetings, and Regulatory Coordination a. Monthly invoices and progress reports to be submitted electronically. b. Meeting agenda and minutes, to be submitted electronically. Ͱ. Task Ͱ – As-Needed Contingency a. Unknown at this time but may include documents related to field data collection and funding support documents. PROJECT FEE Compensation for the services described above shall be delivered for the not-to-exceed amount of ͈ͮͲͮ,ͱͮͭ.ͳͲ. The basis for this not-to-exceed amount is provided in the attached Exhibit A. PROJECT SCHEDULE The services described above are anticipated to be completed in accordance with the draft schedule shown in Exhibit B. Time durations listed below are weeks measured from the date upon which Carollo received the notice to proceed for the work. The draft schedule is dependent on timely receipt of applicable information and data. This length of time is also dependent on the following assumptions:  The City will complete all reviews within ten business days of receiving the submittals. 79 200 East Robinson Street, Suite 1400, Orlando, Florida 32801 P. 407.478.4642 F. 407.478.4643 Winter Springs LCRR Compliance and LSL Inventory Assistance Scope_ͭͬͮͱͮͯ.docx 80 200 East Robinson Street, Suite 1400, Orlando, Florida 32801 P. 407.478.4642 F. 407.478.4643 Winter Springs LCRR Compliance and LSL Inventory Assistance Scope_ͭͬͮͱͮͯ.docx Exhibit B 81